1. Alabama Tools Seminars
February 8 – Decatur
February 13 – Pelham
February 15 – Montgomery
February 20 – Mobile
New EPA UST Regulations:
What You Must Have Done by October 13, 2018
adem.alabama.gov

2. New Regulations already in effect
ADEM revised regulations became effective December 8, 2017
Compatibility demonstration requirements and ball float ban already in effect
adem.alabama.gov

3. What Testing is Due by October 13, 2018?
Overfill prevention equipment inspections
Containment sump testing (if used for interstitial monitoring)
30 day and annual walkthrough inspections
Release detection equipment testing
Release detection for emergency power generator USTs
adem.alabama.gov

4. Reminder – Compatibility Requirements
Beginning December 6, 2017, for any UST storing greater than 10% ethanol or 20% biodiesel, owners must notify the department and demonstrate the compatibility of their systems with the fuels being stored.
Records must be kept for as long as the UST is storing that fuel
adem.alabama.gov

5. Reminder – Ban on Ball Float Valves
December 8, 2017, ball float valves may not be used to meet over fill requirements on new installations
Current ball float valves may remain in use, but must pass overfill inspection
If a ball float fails, it may be repaired
If it cannot be repaired, it must be replaced by an automatic shutoff device or high level alarm
adem.alabama.gov

6. What Constitutes a Repair?
If the ball float valve can be returned to operation with its original parts, it is an allowable repair
If new parts are needed (e.g. new cage, new ball), it is not an allowable repair and the ball float must be replaced by a flapper valve or high level alarm
adem.alabama.gov

7. Replacing Ball Floats
According to PEI RP , a ball float valve set to activate at 90% will interfere with a flapper valve set to activate at 95%
When replacing a ball float valve, remove the entire assembly
Ball floats set to 95% will not interfere with operation of a flapper calve set to 95%
adem.alabama.gov

8. New Requirement Annual Release Detection Equipment Tests
Automatic tank gauge systems and other controllers
Probes and sensors
Automatic line leak detectors (mlld & elld)
Vacuum pumps and pressure gauges
Hand held electronic sampling equipment associated with vapor and groundwater monitoring
Keep records three years
adem.alabama.gov

9. New Requirement Three Year Inspections and Testing
Overfill prevention equipment must be inspected every three years
Containment sumps used for interstitial monitoring must be tested for integrity every three years
Low level test method developed by ADEM
Keep records three years
adem.alabama.gov

10. Walkthrough Inspections
Every 30 days
Check spill prevention equipment and fill pipe
Check release detection equipment to ensure proper operation
Check impressed current cathodic protection system rectifier
Annually
Check containment sumps
Check hand held release detection equipment
First inspection due by October 13, 2018
adem.alabama.gov

11. Emergency Generator Tanks
New federal regs now cover EPG tanks
EPG tanks currently in use must have leak detection by October 13, 2018
New EPG tanks installed on or after December 8, 2017 must have leak detection at installation
Leak detection systems on EPG tanks will NOT be required to shut off or restrict flow, may use audio or visual alarm alone
adem.alabama.gov

12. Recap - Implementation Timeframes
On December 8, 2017:
Ban on vent flow restrictor overfill device for new USTs and upon replacement
Testing after repairs
Overfill device (Inspection)
Secondary containment equipment used for interstitial monitoring
Compatibility demonstration
adem.alabama.gov

13. Recap - Implementation Timeframes
On October 13, 2018:
Overfill prevention equipment inspections
Containment sump testing (if used for interstitial monitoring)
30 day and annual walkthrough inspections
Release detection equipment testing
Release detection for emergency power generator USTs
adem.alabama.gov

15. Inspections and Testing Resources
ADEM O&M Manual (currently under revision)
PEI RP900 - Recommended Practices for the Inspection and Maintenance of UST Systems
PEI RP 1200 – Recommended Practices for the Testing and Verification of Spill, Overfill, Leak Detection and Secondary Containment Equipment at UST Facilities
adem.alabama.gov

16. Contact Information
Sonja Massey
David Batchelor
Latoya Hall
adem.alabama.gov