Effective Jan. 1, 2020, the following provides a summary of changes to Arizona’s Underground Storage Tank rules to align with EPA regulation:

Emergency Power Generators¹

• Newly installed UST systems that store fuel solely for emergency power generators must meet all requirements of UST regulations at the time of installation.
• On or before March 1, 2020, UST systems installed on or before Jan. 1, 2020, that store fuel solely for emergency power generators must meet release detection requirements.

Plan Review Process²

• Rules clarify the plan review requirements and process for UST installations, modifications and permanent closures.

Secondary Containment³

• Rules include requirement from statute that all tanks and piping installed or replaced after Jan. 1, 2009, must be secondarily contained and use interstitial monitoring.
• New dispensers installed or replaced after Jan. 1, 2009, must have under-dispenser containment installed.

Overfill Prevention⁴

• Ball float valves (flow restrictors) are no longer an option for new USTs or as replacements when a ball float valve fails. Owners must install a different type of overfill prevention device, such as a shut off valve in fill pipes or alarms.
• Overfill prevention for newly installed UST systems must be inspected at installation.
• On or before March 1, 2020, the initial functionality test must be conducted on overfill prevention devices for UST systems in use on or before Jan. 1, 2020.
• The functionality testing must be conducted every 3 years after the initial test.

Corrosion Protection⁵

• Rules clarify that tanks and piping that are not protected against corrosion will need to be permanently closed.
• A tank owner/operator must permanently close any tank with an internal liner that is no longer performing in accordance with the original design specifications if the liner cannot be repaired in accordance with industry standards.

Compatibility⁶

• Tank owners will need to notify ADEQ at least 30 days before storing biofuels containing greater than 10 percent ethanol, greater than 20 percent biodiesel, or any blend of isobutanol, and must demonstrate that their equipment is compatible with the biofuels.
• Compatibility documentation must be maintained for as long as the UST system stores any fuel.

Repairs Allowed⁷

• Rule clarifies that repaired equipment must be tested within 30 days following the repair.
• Repair records must be kept until the UST system is permanently closed or undergoes a change-in-service.

Record Keeping⁸

• Rules include records created as a result of new testing requirements and clarifies current record keeping requirements.
• Allows for electronic or paper record keeping.

Spill Prevention and Containment Sumps⁹

• Spill prevention and containment sumps (including under-dispenser containment) for newly installed UST systems must be inspected at installation.
• On or before March 1, 2020, the initial tightness testing must be conducted on spill prevention devices (buckets) and secondary containment sumps used for interstitial monitoring for UST systems in use on or before Jan. 1, 2020.
• Tightness testing must be conducted every 3 years after the initial test, unless the spill prevention equipment and containment sumps are double walled and the integrity of both walls is periodically monitored.

Walkthrough Inspections¹⁰

• Every 30 days, tank owners/operators must inspect for damage and proper operation of spill buckets, fill pipes and caps, interstitial areas of double-walled spill buckets, and release detection equipment. Note: If deliveries occur at intervals greater than every 30 days, the spill buckets only need to be checked prior to each delivery.
• Annually, tank owners/operators must inspect all containment sumps (including under-dispenser containment), interstitial areas of double-walled containment sumps, and handheld release detection equipment for damage, operability, and leaks (if applicable).

Operator Training¹¹

• Rules to include and clarify training program topic requirements from statute.
• Rule clarifies the acceptable sources of training (provided by ADEQ, third-party, etc.) and formats (online, in-person, etc.).
• Rule clarifies when operators need to be retrained (every 3 years, switching operator classifications, non-compliance).

Release Detection¹²

• Rules clarify that release detection equipment must be tested for proper operation annually.
• Rules clarify that tank owners must annually test the operation of electronic automatic line leak detectors by simulating a leak and ensuring the leak detector can detect leaks of three gallons per hour at 10 psi within one hour.
• Rules more specifically include statistical inventory reconciliation as a method of monthly leak detection.

Suspected Releases¹³

• Rule clarifies exemptions for reporting a suspected release, including systems with secondary containment.
• Rule clarifies tightness testing requirements for systems with secondary containment.
• Suspected releases must be investigated within 60 days of discovery or release notification, whichever is earlier.

Temporary Closure¹⁴

• A UST system that does not meet new installation or upgrade standards and has been temporarily closed for more than 12 months must be permanently closed.
• A standard or limited extension of temporary closure must be requested prior to the expiration of the 12-month period.

Airport Hydrant Fuel Distribution Systems and Field-Constructed USTs¹⁵

• Newly installed airport hydrant fuel distribution systems and field-constructed tanks must meet all the requirements for these systems at the time of installation.
• By Jan. 1, 2020, airport hydrant fuel distribution systems and field-constructed tanks installed on or before Jan. 1, 2020, must meet the requirements for release reporting, response, and investigation, closure, notification, and financial responsibility.
• On or before March 1, 2020, airport hydrant fuel distribution systems and field-constructed tanks installed on or before Jan. 1, 2020, must meet the requirements for release detection, upgrade requirements, general operating requirements, and operator training.

Other Notable Changes

• New and updated definitions¹⁶
• Updated UST system codes of practice and performance standards¹⁷
• Financial responsibility documentation must meet the requirements of the updated EPA regulation¹⁸

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