UST Compliance FAQs

Emergency Power Generator Underground Storage Tank System

Emergency power generator UST systems in Louisiana must have met release detection requirements as follows:

• UST systems installed before August 9, 2009 must have begun using a form of release detection before September 20, 2021.
• UST systems installed on or after August 9, 2009 must have met the secondary containment with interstitial monitoring requirements at installation.

EPA has finalized and published new guidance and resources on emergency power generator UST systems on June 3, 2022. The following documents, as described by EPA below, are now available on the EPA OUST website:

• Federal UST Requirements for Emergency Power Generator UST Systems: https://www.epa.gov/system/files/documents/2022-05/epg-ust-system-requirements.pdf
  • This booklet summarizes the full gamut of federal UST requirements for EPGs - installation, reporting, spill and overfill prevention, corrosion protection, release detection, walkthrough inspections, compatibility, operator training, repairs, financial responsibility, release response, and closure.
  • This also covers Spill Prevention Control and Countermeasures (SPCC) related regulatory requirements specific to emergency power generator UST systems.
• Owner and Operator Introduction: Automated Interstitial Monitoring Systems for Underground Pressurized Piping on EPG UST Systems: https://www.epa.gov/system/files/documents/2022-05/aim-systems-owner-operator-intro.pdf
  • This document describes a new option for EPG UST system owners and operators to use interstitial monitoring to meet the line leak detector requirement of the federal UST regulation. EPA has determined this option, termed “automated interstitial monitoring (AIM) system,” may be used to meet the dual release detection requirements for pressurized piping systems at EPG UST systems. This document provides basic information and introduces EPG UST system owners and operators to AIM systems.
  • The document also contains forms and checklists to assist with verifying AIM system compliance with UST implementing agencies and for complying with periodic testing requirements for AIM systems. AIM systems are optional, and UST implementing agency requirements may differ. UST system owners and operators should contact their UST implementing agency to determine whether they allows the use of an AIM system, and whether the forms and checklists meet the agency’s documentation requirements.
  • In Indian Country, where the federal UST regulation applies and AIM systems are allowable, UST owners and operators should submit forms to the applicable EPA regional office.
• In-Depth Discussion: Automated Interstitial Monitoring Systems for Underground Pressurized Piping on Emergency Power Generator UST Systems: https://www.epa.gov/system/files/documents/2022-05/aim-systems-in-depth-discussion.pdf
  • This document contains a more complete discussion about AIM systems (the introduction document does not address all issues). This includes background and technical information on the EPA’s recognition of using automated interstitial monitoring systems to meet federal release detection requirements for underground pressurized piping systems on EPG UST systems.
  • This document can also assist UST system installers, fuel system designers, and other qualified professionals when installing or modifying fuel storage systems to meet federal UST regulatory requirements for underground pressurized piping systems.

• Fillable PDFs for Certification of Compliance and Periodic Testing and Inspections of AIM Systems: https://www.epa.gov/ust/certification-inspections-and-testing-forms-automated-interstitial-monitoring-systems
  • These PDFs are fillable versions of the Certification of Compliance Forms and AIM Systems Inspection and Testing Checklists (these are the forms contained in both AIM documents above).

In addition to these new documents, a reminder that EPA previously provided responses to questions on several important issues regarding EPG UST systems.  EPA made these responses available to the public in our UST Technical Compendium about the 2015 Federal UST Regulations under the subject Emergency Power Generators: https://www.epa.gov/ust/underground-storage-tank-ust-technical-compendium-about-2015-ust-regulation. Q&A topics include:

• Determining if emergency power generator systems must comply with federal UST regulation.
• Release detection requirements for piping operating at atmospheric pressure.
• Complying with National Fire Protection Association 110 to meet the federal UST regulation.
• Visual-based assessments for above ground tanks (e.g. day tanks) that are part of EPG UST systems.

LDEQ UST Division accepts Automated Interstitial Monitoring (AIM) as a valid form of pressurized piping release detection and recognizes that it meets the line leak detector release detection requirements only for emergency power generator UST systems.

The Certificate of Compliance form must be completed and signed by either an LDEQ-certified worker, a licensed professional engineer, or a licensed professional geoscientist. The form must be maintained by the facility and made available for review by the department. The form is not required to be submitted to LDEQ in order to use AIM as a release detection method.

Once the water has been removed from the tank hold, it cannot be discharged back into the tank hold.  Here are some options to properly dispose of the removed tank hold water:

LDEQ does not have an equipment approval program. All UST systems installed in Louisiana have to conform to the installation regulations specified in LAC 33:XI.303.  

General statements regarding piping slope with regards to interstitial monitoring, burial depth of piping, and testing of piping systems found in PEI RP100, API RP 1615, and NFPA 30A. All of the above issues listed in the guidance documents are qualified by statements such as “piping may slope”, or “as a general rule”. PEI, API, NFPA, and Louisiana UST regulations all state that UST equipment must be installed, operated, maintained, and tested in accordance with the manufacturer’s instructions. OPW has provided information verifying that a product release from any portion of the piping will travel to the nearest containment sump to allow detection. Ken Wilcox Associates has reviewed the Loop System and has stated that line leak detectors will work with this type system. 

After careful review of the guidance documents listed above, information provided by OPW,  and information provided by PEI and Ken Wilcox Associates (KWA) regarding these issues, LDEQ has no objection to the installation of the OPW Loop System for use as an underground storage tank system in Louisiana.

This approval not intended and should not be construed to be an endorsement of a particular product or an official equipment approval letter, as LDEQ does not have an equipment approval program.         

LDEQ will closely monitor OPW Loop Systems installed in Louisiana. If after installation, operational problem occur with this system that result in compliance issues with existing UST rules and regulations, LDEQ may withdraw this approval. Also, since LDEQ is an EPA authorized state, and if EPA determines that the use of this system is not approved, LDEQ may withdraw this approval. Click here to see OPW's memo regarding the differences between the Loop System and traditional piping system.

Diesel Exhaust Fluid (DEF) does not meet the regulatory definition of a regulated substance and underground storage tanks that contain DEF are not regulated underground storage tanks.

• Isolating the metal flexible hoses from soil or water by installing water-tight under-dispenser containment sumps and submersible pump containment sumps
• Isolating the metal flexible hoses by covering them with a protective covering or “boot”
• Protecting the metal flexible hoses from corrosion with either a cathodic protection system (anodes) or with an impressed current system

• Isolating the submersible pump from soil or water by installing water-tight submersible pump containment sumps
• Protecting the submersible pump from corrosion with either a cathodic protection system (anodes) or with an impressed current system

Yes, both spill and overfill protection are required for the proper installation of new UST systems unless approval is granted by the department. The spill prevention equipment must prevent the release of product to the environment when the transfer hose is detached from the fill pipe (i.e. spill catchment basin). In order to meet the minimum requirements that are stipulated in the regulations, overfill protection equipment must meet at least one of the following requirements: automatically shut off flow into the tank when the tank is no more than 95% full; alert the transfer operator when the tank is no more than 90% full by restricting flow into the tank or triggering a high level alarm; restricting the flow 30 minutes prior to overfilling, or alert he operator with a high-level alarm one minute before overfilling, or automatically shut off flow into the tank. Typical overfill devices include overfill prevention valves that are installed in the drop tubes (often called butterfly or flapper valves), ball float valves, and overfill alarm systems.

Only an individual certified in UST installation and repair may exercise supervisory control over the installation of a new UST system.

Click here to access Publications Related to Underground Storage Tanks developed by EPA

 

Third-party certifications can be located by accessing the NEIWPCC Vendor list with this link.