Proposed Changes to Chapter 245 Regulations for Storage Tanks

January 22, 2017
William E. Hitchcock
MGKF Special Alert - Forecast 2017

At the December 6, 2016 meeting of the Storage Tank Advisory Committee (“STAC”), the Pennsylvania Department of Environmental Protection (“PADEP”) presented draft changes to the Chapter 245 regulations governing administration of the Storage Tank and Spill Prevention Program, and distributed drafts of technical guidance documents describing closure requirements for aboveground and underground storage tank systems.  Many of the proposed changes to these programs were prompted by EPA's July 2015 revisions to the federal storage tank regulations, which must be implemented at the state level within three years. 

Substantive changes are proposed to the Chapter 245 regulations, including periodic operation and maintenance requirements for Underground Storage Tank (“UST”) systems, periodic inspection requirements, changes to the types of acceptable overfill prevention devices, new secondary containment requirements, requirements to ensure system compatibility with alternative and biofuel blends, training requirements for tank operators, a new level of certification for tank inspectors, and additional reporting and recordkeeping requirements for tank inspections.  The proposed regulations will also apply to emergency generator USTs, which were previously deferred from regulation under the state and federal programs.  Many of the new requirements have a one-year "phase-in" period to allow the regulated community some time to bring existing tank systems into compliance.  PADEP intends to begin the public comment period for these proposed changes by the end of 2017.  The current draft documents can be accessed using the links below: