UST Regulatory Compliance & EPA Standards 3 — Questions and Answers
Question 1: A heating oil tank serving a single family home that is NOT used for resale is regulated under which category?
- Regulated UST requiring full 40 CFR Part 280 compliance
- Exempt UST under 40 CFR Part 280.10(b) (Correct answer)
- Conditionally exempt UST requiring annual testing
- State-only regulated tank
Correct answer: Exempt UST under 40 CFR Part 280.10(b)
Heating oil tanks used at the premises where stored and not for resale are specifically listed as excluded from federal UST regulation under 40 CFR 280.10(b).
Question 2: Under EPA standards, which method is NOT an acceptable form of financial assurance for UST corrective action and third-party liability?
- Performance bond
- Letter of credit
- Personal guarantee from the facility owner (Correct answer)
- Self-insurance with tangible net worth test
Correct answer: Personal guarantee from the facility owner
A personal guarantee from an individual facility owner is not an acceptable financial assurance mechanism under 40 CFR Part 280 Subpart H.
Question 3: When must an owner/operator notify the implementing agency of the permanent closure of a UST system?
- Within 30 days after closure
- At least 30 days before closure begins (Correct answer)
- Within 72 hours after closure
- At least 60 days before closure begins
Correct answer: At least 30 days before closure begins
Owners/operators must notify the implementing agency at least 30 days before beginning permanent closure or change-in-service operations.
Question 4: What concentration of petroleum-contaminated soil may trigger a site assessment requirement under EPA guidance during UST closure?
- Any detectable level above background
- Levels exceeding RCRA hazardous waste thresholds only
- Evidence of a release based on visual inspection or sampling (Correct answer)
- Only if groundwater is impacted
Correct answer: Evidence of a release based on visual inspection or sampling
During closure, if evidence of a release is found through visual inspection, odor, or sampling results, a site assessment must be conducted to determine the extent of contamination.
Question 5: Which EPA-approved lining material method is acceptable for upgrading an existing single-wall steel UST to meet current standards?
- Epoxy resin interior lining with annual tightness testing (Correct answer)
- Fiberglass overwrap applied to the exterior
- Polyethylene exterior bladder system
- Concrete encasement of the existing tank
Correct answer: Epoxy resin interior lining with annual tightness testing
Interior lining using approved epoxy or similar resin materials, combined with annual tightness testing and 3-year lining inspections, is an accepted upgrade method.
Question 6: Under 40 CFR Part 280 Subpart E, what is the primary purpose of the 'site assessment' during corrective action?
- To estimate property value after contamination
- To define the nature and extent of contamination from a confirmed release (Correct answer)
- To determine insurance liability amounts
- To identify responsible third parties
Correct answer: To define the nature and extent of contamination from a confirmed release
The site assessment characterizes the nature and extent of soil and groundwater contamination so that appropriate corrective action can be designed.
Question 7: The EPA's 'Red Flags' for release detection failures include all EXCEPT which of the following?
- Recurring unexplained inventory losses
- Customer complaints about fuel odors
- Failure to maintain monitoring equipment
- Slight variation in reconciliation totals within the ATG tolerance threshold (Correct answer)
Correct answer: Slight variation in reconciliation totals within the ATG tolerance threshold
Minor reconciliation variations within the ATG manufacturer's stated tolerance are expected and are not considered a release detection red flag.
UST Regulatory Compliance & EPA Standards 3
A heating oil tank serving a single family home that is NOT used for resale is regulated under which category?