EPA Clarifies Underground Storage Tank Rules

ASTM’s recently published new standards on testing raise questions on regulatory compliance.

April 02, 2020

WASHINGTON—The Environmental Protection Agency (EPA) recently reached out to the underground storage tank community to clarify new standards for spill bucket and sump testing recently published by the American Society for Testing and Materials (ASTM). 

These inquires and questions centered around whether or not the ASTM E3225-20 Standard Practice met the requirements of the federal UST regulation (40 CFR § 280.35) for spill prevention or sump testing. The 2015 UST regulation requires spill prevention and sump testing be done using a liquid, pressure or vacuum test.

In its communication, EPA made clear that the ASTM procedures do not meet the UST regulatory requirement. “The ASTM E3225-20 is visually based, and while a thorough visual check can always be beneficial, these procedures do not meet the requirements in 40 CFR § 280.35. If owners and operators follow this standard and do not perform the correct testing requirements, they will be in violation of the regulatory requirements, and subject to appropriate enforcement.”

To help clarify the issue, EPA added two new questions and answers to the Office of Underground Storage Tank (OUST)’s web-based UST Technical Compendium about the 2015 UST Regulation under the “Spill buckets, under dispenser containment sumps, containment sumps” section.