Proposed Pennsylvania Storage Tank and Spill Prevention Program Rule Revisions

The Pennsylvania Environmental Quality Board (EQB) has proposed amendments to 25 Pa. Code Chapter 245 regarding the Storage Tank and Spill Prevention Program.  The proposed amendments are required by the U.S. Environmental Protection Agency (U.S. EPA) following the July 15, 2015 revised state program approval requirements for underground storage tanks (USTs).  These changes are intended to add requirements to periodically check the functionality of spill prevention, overfill prevention, and release detection equipment already required to be in place for USTs, aboveground storage tanks (ASTs) in underground vaults, and small ASTs.

What are the main proposed changes to the rule?

• Inspection of spill prevention equipment and release detection every 30 days
• Inspection of containment sumps and handheld release detection devices annually
• Inspection of overfill prevention equipment every three years
• Testing of spill prevention equipment every three years
• Testing of containment sumps used for interstitial monitoring every three years
• Testing of release detection equipment annually
• Release detection requirements for emergency generator USTs (previously deferred)
• Flow restrictors prohibited as an option for overfill prevention in new and replaced UST systems
• Increase in-service inspection frequency for ASTs to once every 3 or 5 years, depending on capacity and type of tank.

OK – These changes are all well and good, but what does this mean for my facility?

In addition to the items listed above, the proposed changes may require facilities to review and update their Preparedness Prevention and Contingency (PPC) Plan and other contingency plans (e.g., integrated contingency plans) to address the revised regulatory requirements.  In addition, facilities that are required to have a Spill Prevention Response (SPR) Plan would be required to submit amendments within 120 days of necessary updates to the plan.

ALL4 will continue to monitor this proposed rulemaking and provide updates as necessary.  If you have any questions, contact me at scunningham@all4inc.com or 610.422.1144.