United States
             Environmental Protection
             Agency
Solid Waste And
Emergency Response
5403G
EPA510-B-97-007
September 1997
&EPA     Straight Talk On Tanks

             Leak Detection Methods For
             Petroleum Underground Storage
             Tanks And Piping
              nventory Control or
              Manual Tank Gauging
                           Inventory Probe for
                           Automatic Tank Gauging
                                       Printed on Recycled Paper

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                            Contents
Do You Have Questions About Leak Detection?	1

An Overview Of Leak Detection Requirements	2

Secondary Containment With Interstitial Monitoring 	6

Automatic Tank Gauging Systems	8

Vapor Monitoring  	10

Groundwater Monitoring	12

Statistical Inventory Reconciliation  	14

Tank Tightness Testing With Inventory Control 	16

Manual Tank Gauging  	20

Leak Detection For Underground Piping	22

Publications And Videos About USTs 	26

State Contacts For UST Information	28
            Free Publications About UST Requirements

               You can go to EPA's UST Web site at
               http://www.epa.gov/OUST/ to order or read
               documents online. You can call EPA's toll-free
               RCRA/Superfund Hotline at 800 424-9346 and order
               up to 30 free copies of any title. Or you can write
               and ask for titles by addressing your request to
               NCEPI, our publication distributor: NCEPI, Box 42419,
               Cincinnati, OH 45242. Or you can make your request
               by calling NCEPI's toll-free number at  800 490-9198.
               Or you can fax your order to NCEPI at 513 891 -6685.

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Do You Have Questions About Leak Detection?
As an owner or operator of underground storage tanks (USTs) storing
petroleum:

#  Do you understand the basic leak detection requirements for USTs?

#  Do you need help choosing the best leak detection method for your
   USTs?

These are important questions, because your UST and its underground
piping must have leak detection NOW.

This booklet begins with an overview of the federal regulatory requirements
for leak detection. Each following section focuses on one leak detection
method or the special requirements for piping.

You will find answers in this booklet to many basic questions about how leak
detection methods work and which methods are  best for your UST site.

Why is leak detection so important?

As of March 1997, almost 330,000 UST leaks had been confirmed.
At sites without leak detection, leaks were discovered late, after
contamination had spread, requiring difficult and costly cleanups.

By contrast, if you have effective leak detection, you can respond  quickly to
signs of leaks. You can minimize the extent of environmental damage and
the threat to human health and safety. Early action on your part also protects
you from the high costs that can result from cleaning up extensive leaks and
responding to third-party liability claims.

If you  need an overview of all the federal requirements for USTs, please refer
to Musts For USTs, a booklet developed by the  U.S. Environmental
Protection Agency (EPA). You can order a free copy of this booklet by calling
EPA's toll-free Hotline at 800 424-9346 (see inside the front cover for full
ordering information).
If your USTs do not
meet the leak
detection
requirements
described in this
booklet, you can be
cited for violations
and fined.
ftEPA  Musts For USTs

     A Summary Of Federal
     Regulations For Underground
     Storage Tank Systems
                              Straight Talk On Tanks   1

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State or local
regulations may differ
from the federal
requirements, so find
out which
requirements apply to
your UST. See the list
of state UST contacts
starting on page 28.
An Overview Of Leak Detection Requirements

All new USTs (those installed after December 1988) must have leak
detection when they are installed.

USTs installed before December 1988 (called "existing USTs") had
compliance deadlines for leak detection phased in over 5 years.
By December 1993, all "existing USTs" had to have leak detection.

EPA has identified the following methods that owners and operators may use
to meet the federal leak detection requirements:

#  Secondary Containment With Interstitial Monitoring

#  Automatic Tank Gauging Systems

#  Vapor Monitoring

#  Groundwater Monitoring

#  Statistical Inventory Reconciliation

#  Other Methods Meeting Performance Standards

The leak detection methods noted above are all monthly monitoring
methods and eventually everyone must use at least one of them. However,
as a temporary method, you can combine tank tightness testing with
inventory control (or with manual tank gauging if you have a small tank), as
explained on page 4.

Underground piping connected to your USTs must also have leak
detection. See pages 22-25 for descriptions of the requirements for piping.


Brief descriptions of leak detection methods appear on the
next two pages.  More complete descriptions appear in the
following sections.
                                    Straight Talk On Tanks   2

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#  Secondary Containment With Interstitial Monitoring (see pages 6-7)

   Secondary containment often uses a barrier, an outer wall, a vault, or a
   liner around the LIST or piping.  Tanks can be equipped with inner
   bladders that provide secondary containment. Leaked product from the
   inner tank or piping is directed towards an "interstitial" monitor located
   between the inner tank or piping and the outer barrier.  Interstitial
   monitoring methods range from a simple dipstick to a continuous,
   automated vapor or liquid sensor permanently installed in the system.

#  Automatic Tank Gauging Systems (see pages 8-9)

   A probe permanently installed in the tank is wired to a monitor to provide
   information on  product level and temperature. These systems
   automatically calculate the changes in product volume that can indicate a
   leaking tank.

#  Vapor Monitoring (see pages 10-11)

   Vapor monitoring measures product "fumes" in  the soil around the LIST to
   check for a leak. This method requires installation of carefully placed
   monitoring wells. Vapor monitoring can be performed manually on a
   periodic basis or continuously using permanently installed equipment.

#  Groundwater Monitoring (see pages 12-13)

   Groundwater monitoring senses the presence of liquid product floating on
   the groundwater. This method requires installation of monitoring wells at
   strategic locations in the ground near the tank and along the piping runs.
   To discover if leaked product has reached groundwater, these wells can
   be checked periodically by hand or continuously with permanently installed
   equipment. This method cannot be used at sites where groundwater is
   more than 20 feet below the surface.

#  Statistical Inventory Reconciliation (see pages 14-15)

   In this method, a trained professional uses sophisticated computer
   software to conduct a statistical analysis of inventory, delivery,  and
   dispensing data, which you must supply regularly.

#  Other Methods Meeting Performance Standards

   Any technology can be used if it meets a performance standard of
   detecting a leak of 0.2 gallons per hour with a probability of detection  of at
   least 95 percent and a probability of false alarm of no more than 5
   percent.  Regulatory authorities can approve another method if you
   demonstrate that it works  as well as one of the  methods above and you
   comply with any condition the authority imposes.
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Automatic Tank Gauge
                              Straight Talk On Tanks   3

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Make sure the vendor
of the leak detection
method you use has
provided you with
evidence that your
leak detection meets
regulatory
requirements for
performance.
#  Tank Tightness Testing With Inventory Control (see pages 16-19)

   This method combines periodic tank tightness testing with monthly
   inventory control. Inventory control involves taking measurements of tank
   contents and recording amount pumped each operating day, as well as
   reconciling all this data at least once a month. This combined method
   must also include tightness tests, which are sophisticated tests performed
   by trained professionals.  This combined method can be used only
   temporarily (usually for 10 years or less)—see page 19 for time
   restrictions.

#  Manual Tank Gauging (see  pages 20-21)

   Manual tank gauging can be  used only for tanks of 2,000 gallons or less
   capacity. This method requires keeping the tank undisturbed for at least
   36 hours each week, during which the contents of the tank are measured
   twice at the beginning and twice at the end of the test period. At the end
   of each week you compare the results to the standards shown on page 21
   to see if your tank may be leaking. This method can be used by itself only
   for tanks up to 1,000 gallons. Tanks between 1,001 and 2,000 gallons can
   use this method only in combination with periodic tank tightness testing.
   This combined method can be used only temporarily (usually for 10
   years or less)—see page 21  for time restrictions.

Look For The "Proof" Of A Third-Party Evaluation

An evaluation performed by a third party (someone who is  independent of the
manufacturer or vendor of the leak detection system) shows that a leak
detection system can work as designed. The evaluation follows required
evaluation procedures, and often takes place in a laboratory. EPA and third
parties have  developed evaluation procedures for all leak detection systems.

Although an evaluation and its resulting documentation are technical, you
should be familiar with the evaluation's "results" form and,  when provided, its
"description" form. You should obtain these forms from the leak detection
vendor and keep them on file. They contain a signed certification that the
system performed as described, as well as documenting any limitations of the
system. This information is important to your compliance with the LIST
requirements. For example, if a tank tightness test was evaluated and
certified only for tests taking 2 hours or more, then your LIST must be tested
for at least 2 hours or it would fail to meet the leak detection requirements.
                                      Straight Talk On Tanks  4

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Required "Probabilities" For Some Leak Detection

The regulations require not only that leak detection methods be able to detect
certain leak rates, but that they also give the correct answer consistently. In
general, methods must detect the specified leak rate with a probability of
detection of at least 95 percent and a probability of false alarm of no more
than 5 percent. Simply stated, this means that, of 100 tests of USTs leaking
at the specified rate, at least 95 of them must be correctly detected. It also
means that, of 100 tests of non-leaking USTs, no more than 5 can  be
incorrectly called leaking. This is what is meant by the "probabilities" noted in
this booklet.

Which leak detection method is best for you?

There is no one leak detection system that is best for all sites, nor is there a
particular type of leak detection that is consistently the least expensive.
Each leak detection method has unique characteristics.  For example, vapor
detection devices work rapidly and most effectively in porous soils, while
liquid detectors are only appropriate for areas with
a high water table.

Identifying the best leak detection choice for your LIST depends on
a number of factors including cost (both initial installation cost and
long-term operation and maintenance cost), facility configuration
(such  as complexity of piping runs and  manifolded tanks), groundwater
depth, soil type, seasonal rainfall and temperature ranges, availability of
experienced installers, and other variables.

You should look around extensively for experienced, professional vendors
and installers of leak detection. Ask questions that help you find the most
reliable, cost-effective  leak detection for your type  of facility. Some  possible
information sources are: references from fellow LIST owners, oil  marketers,
equipment suppliers, trade journals, trade associations,  state and local trade
associations (especially those for petroleum  marketers and LIST owners), and
state and local regulatory authorities. (See the list  of state LIST contacts
starting on page 28.)
Your state may also have an assistance fund that may be able to help you pay
for your UST's leak detection.

EPA provides a free publication—List Of Leak Detection Evaluations For
LIST Systems—that contains a detailed summary of specifications, based on
third-party evaluations, for over 250 leak detection systems. (See inside the
front cover for ordering information.) Although the List can  be used to help
select systems and determine their compliance or acceptability, the publication
is not  a list of "approved" leak detection systems. Approval or acceptance of
leak detection systems rests with the implementing agency, in most cases the
state environmental agency.

For additional information about federal LIST requirements, contact EPA's
RCRA/Superfund Hotline at 800 424-9346.
Some states
maintain lists of
those leak detection
systems that have
been evaluated by
third parties.  Check
with your state to
see which systems
are allowed in your
state. See list of
state contacts
starting on page 28.
                               Straight Talk On Tanks  5

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Secondary Containment With Interstitial Monitoring

Will you be in compliance?

When installed and operated according to the manufacturer's specifications,
secondary containment with interstitial monitoring meets the federal leak
detection requirements for USTs. Operation of the monitoring device at least
once each month fulfills the requirements for the life of the tank. Secondary
containment with interstitial monitoring can also be used to detect leaks from
piping (see the section on leak detection for piping starting on page 22).

How does  the leak detection method work?

Secondary containment

#  Secondary containment provides a barrier between the tank and the
   environment. The barrier holds the leak between the tank and the barrier
   so that the leak is detected. The barrier is shaped so that a leak will be
   directed towards the interstitial monitor.

#  Barriers include:

   >•  Double-walled or "jacketed" tanks, in which an outer wall partially or
      completely surrounds the primary tank;

   -  Internally fitted liners ("bladders"); and

   -  Leakproof excavation liners that partially or completely surround the
      tank.

#  Clay and other earthen materials cannot be used as barriers.

Interstitial monitors

#  Monitors  are used  to check the area between the tank and the barrier for
   leaks and alert the operator if a leak is suspected.

#  Some monitors indicate the physical presence of the leaked product,
   either liquid or gaseous. Other monitors check for a change in condition
   that indicates a hole in the tank, such  as a loss of vacuum or a change in
   the level of a monitoring liquid between the walls of a double-walled tank.

#  Monitors  can be as simple as a dipstick used at the lowest point of the
   containment to see if liquid product has leaked and pooled there.
   Monitors  can also be sophisticated automated systems that continuously
   check for leaks.
            Straight Talk On Tanks   6

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What are the regulatory requirements?

#  The barrier must be immediately around or beneath the tank.

#  The interstitial monitor must be checked at least once every 30 days.

#  A double-walled system must be able to detect a release through the inner
   wall.

#  An excavation liner must:

   >  Direct a leak towards the monitor;

   >  Not allow the specific product being stored to pass through it any faster than
      10"6 cm/sec;

   «•  Be compatible with the product stored in the tank;

   «•  Not interfere with the UST's cathodic protection;

   «•  Not be disabled by moisture;

   «•  Always be above the groundwater and the 25-year flood plain; and

   «•  Have clearly marked and secured monitoring wells, if they are used.

#  A bladder must be compatible with the product stored and must be
   equipped with an automatic monitoring device.

Will it work at  your site?

#  In areas with  high groundwater or a lot of rainfall, it may be necessary to
   select a secondary containment system that completely surrounds the
   tank to prevent moisture from interfering with the monitor.

Anything else you should consider?

#  This method works effectively only if the barrier and the interstitial monitor
   are installed correctly. Therefore, trained and experienced installers are
   necessary.
Find out if there are
state or local
requirements on the
use of secondary
containment that
differ from those
described here.
                               Straight Talk On Tanks  7

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                    Automatic Tank Gauging Systems
Water Level f
  Float
Will you be in compliance?

When installed and operated according to the manufacturer's specifications,
automatic tank gauging systems (ATGS) meet the federal leak detection
requirements for tanks (this method does not detect piping leaks).  A test
performed each month fulfills the requirements for the life of the tank. (For
additional requirements for piping, see the section on leak detection for piping
starting on page 22.)

How does the leak detection method work?

#  The product level and temperature in a tank are measured continuously
   and automatically analyzed and recorded by a computer.

#  In the "inventory mode," the ATGS replaces the use of the gauge stick to
   measure product level and perform inventory control. This mode records
   the activities of an in-service tank, including deliveries.

#  In the "test mode," the tank is taken out of service and the product level
   and temperature are measured for at least one hour. Some systems,
   known as "continuous ATGS," do not require  the tank to be taken out of
   service to perform a test.  This is because these systems can gather and
   analyze data during many short periods when no product is being added
   to or taken from the tank.

#  Some methods combine aspects of automatic tank gauges with statistical
   inventory reconciliation. See pages 14-15 for more information about
   these methods
                    What are the regulatory requirements?

                    #  The ATGS must be able to detect a leak of 0.2 gallons per hour with
                       certain probabilities of detection and of false alarm. Some ATGS can also
                       detect a leak of 0.1 gallons per hour with the required probabilities.

                    Will it work at your site?

                    #  ATGS have been used primarily on tanks containing gasoline or diesel,
                       with a capacity of up to  15,000 gallons.  If considering using an ATGS for
                       larger tanks or products other than gasoline or diesel, discuss its
                       applicability with the manufacturer's representative.

                    #  Water around a tank may hide a leak by temporarily preventing the
                       product from leaving the tank.  To detect a leak in this situation, the ATGS
                       should be capable of detecting water in the bottom  of a tank.
                                Straight Talk On Tanks   8

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Anything else you should consider?

#  The ATGS probe is permanently installed through an opening (not the fill
   pipe) on the top of the tank. Each tank at a site must be equipped with a
   separate probe.

#  The ATGS probe is connected to a console that displays ongoing product
   level information and the results of the monthly test.  Printers can be
   connected to the console to record this information.

#  ATGS are often equipped with alarms for high and low product level, high
   water level, and theft.

#  ATGS can be linked with computers at other locations, from which the
   system can be programmed or read.

#  For ATGS that are not of the "continuous" type, no product should be
   delivered to the tank  or withdrawn from it for at least 6 hours before the
   monthly test or during the test (which generally takes 1 to 6 hours).

#  An ATGS can be programmed to perform a test more often than once per
   month (a recommended practice).
Find out if there are
state or local
requirements on the
use of ATGS that
differ from those
described here.
                             Straight Talk On Tanks  9

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Vapor Monitoring

Will you be in compliance?

When installed and operated according to the manufacturer's instructions,
vapor monitoring meets the federal leak detection requirements for USTs.
Operation of a vapor monitoring system
at least once each month fulfills the requirements for the life of the tank.
Vapor monitoring can also be installed to detect leaks from piping
(see the section on leak detection for piping starting on page 22).

How does the leak detection method work?

#  Vapor monitoring senses or measures "fumes" from leaked product in the
   soil around the tank to determine if the tank is leaking.

#  Fully automated vapor monitoring systems have permanently installed
   equipment to continuously or periodically gather and  analyze vapor
   samples and respond to a release with a visual or audible alarm.

#  Manually operated vapor monitoring systems range from equipment that
   immediately analyzes a gathered vapor sample to devices that gather a
   sample that must be sent to a laboratory for analysis.  Manual systems
   must be used at least once a month to monitor a site.

#  All vapor monitoring devices should be periodically calibrated according to
   the manufacturer's instructions to ensure that they are properly
   responding.

#  Before installation, a site assessment is necessary to determine the soil
   type, groundwater depth and flow direction, and the general geology of the
   site.  This can only be done by a trained professional.

#  The number of wells and their placement is very important. Only an
   experienced contractor can properly design and construct an effective
   monitoring well system.  Vapor monitoring  requires the installation of
   monitoring wells within the tank backfill. A minimum  of two wells is
   recommended for a single tank excavation. Three or more wells  are
   recommended for an excavation with two or more tanks.  Some state and
   local agencies have developed regulations for monitoring well placement.
            Straight Talk On Tanks   10

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What are the regulatory requirements?

#  The LIST backfill must be sand, gravel or another material that will allow
   the vapors to easily move to the monitor.

#  The backfill should be clean enough that previous contamination does not
   interfere with the detection of a current leak.

#  The substance stored in the LIST must vaporize easily so that the vapor
   monitor can detect a release.  Some vapor monitoring systems do not
   work well with diesel fuel.

#  High groundwater, excessive rain, or other sources of moisture must not
   interfere with the operation of vapor monitoring for more than
   30 consecutive days.

#  Monitoring wells must be secured and clearly marked.

Will it work at your site?

#  Before installing a vapor monitoring system, a site assessment must be
   done to determine whether vapor monitoring is appropriate at the site.  A
   site assessment usually includes at least a determination of the
   groundwater level, background contamination, stored product type, and
   soil  type. This assessment  can only be done by a trained professional.
Find out if there are
state or local
requirements on the
use of vapor
monitoring that
differ from those
described here.
                             Straight Talk On Tanks  11

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                       Groundwater Monitoring
NOTE:
Groundwater
monitoring cannot
be used at sites
where groundwater
is more than
20 feet below
the surface.
Will you be in compliance?

When installed and operated according to the manufacturer's instructions, a
groundwater monitoring system meets the federal leak detection
requirements for USTs. Operation of a groundwater monitoring system at
least once each month fulfills the requirements for the life of a tank.
Groundwater monitoring can also be used to detect leaks in piping (see the
section on leak detection for piping starting on page 22).

How does the leak detection method work?

#  Groundwater monitoring involves the use of permanent monitoring wells
   placed  close to the LIST. The wells are checked at least monthly for the
   presence of product that has leaked from the LIST and is floating on the
   groundwater surface.

#  The two main components of a groundwater monitoring system are the
   monitoring well (typically a well of 2-4 inches in diameter) and the
   monitoring device.

#  Detection devices may be permanently installed in the well for automatic,
   continuous measurements for leaked product.

#  Detection devices are also available in manual form.  Manual devices
   range from a bailer (used to collect a liquid sample for visual inspection) to
   a device that can be inserted into the well to electronically indicate the
   presence of leaked product. Manual devices must be used at least once
   a month.

#  Before  installation, a site assessment is necessary to determine the soil
   type, groundwater depth and flow direction, and the general geology of the
   site.  This assessment can only be done by a trained professional.

#  The number of wells and their placement is very important. Only an
   experienced contractor can properly design and construct an effective
   monitoring well system.  A minimum of two wells is recommended for a
   single tank excavation.  Three or more wells are recommended for an
   excavation with two or more tanks.  Some state and local agencies have
   developed regulations for monitoring well placement.
                                   Straight Talk On Tanks   12

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What are the regulatory requirements?

#  Groundwater monitoring can only be used if the stored substance does
   not easily mix with water and floats on top of water.

#  If groundwater monitoring is to be the sole method of leak detection, the
   groundwater must not be more than 20 feet below the surface, and the
   soil between the well and the LIST must be sand, gravel or other coarse
   materials.

#  Product detection devices must be able to detect one-eighth inch or less
   of leaked product on top of the groundwater.

#  Monitoring wells must be properly designed and sealed to keep then from
   becoming contaminated from outside sources. The wells must also be
   clearly marked and secured.

#  Wells should be placed in the LIST backfill so that they can detect a leak
   as quickly as possible.

Will it work at your site?

#  In general, groundwater monitoring works best at LIST sites where:

   «• Monitoring wells are installed in the tank backfill; and

   •• There are no previous releases of product that would falsely indicate a
     current release.

#  A professionally conducted  site assessment is critical for determining
   these site-specific conditions.
Find out if there are
state or local
requirements on the
use of groundwater
monitoring that
differ from those
described here.
                             Straight Talk On Tanks   13

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                        Statistical  Inventory Reconciliation

                        Will you be in compliance?

                        Statistical inventory reconciliation (SIR), when performed according to the
                        vendor's specifications, meets federal leak detection requirements for USTs as
                        follows.  SIR with a 0.2 gallon per hour leak detection capability meets the
                        federal requirements for monthly monitoring for the life of the tank and piping.
                        SIR with a 0.1 gallon per hour leak detection capability meets the federal
                        requirements as an equivalent to tank tightness testing.  SIR can, if it has the
                        capability of detecting even smaller leaks, meet the federal requirements for
                        line tightness testing as well. (For additional requirements for piping, see the
                        section on leak detection for piping starting on page 22.)

                        How does the leak detection method work?
You can order a
free booklet,
Introduction To
Statistical
Reconciliation, that
describes the use of
this method. See
inside the front
cover for ordering
information.
#  SIR analyzes inventory, delivery, and dispensing data collected over a
   period of time to determine whether or not a tank system is leaking.

#  Each operating day, the product level is measured using a gauge stick or
   other tank level monitor.  You also keep complete records of all withdrawals
   from the LIST and all deliveries to the LIST. After data have been collected
   for the period of time required by the SIR vendor, you provide the data to
   the SIR vendor.

#  The SIR vendor uses sophisticated computer software to conduct a
   statistical analysis of the data to determine whether or not your LIST system
   may be leaking.  The SIR vendor provides you with a test report of the
   analysis.

#  Some methods combine aspects of automatic tank gauges with statistical
   inventory reconciliation. In these methods, sometimes called  hybrid
   methods, a gauge provides liquid level and temperature data  to a computer
   running SIR software, which performs the analysis to detect leaks.

What are the regulatory requirements?

#  To be allowable as  monthly monitoring, a SIR method must be able to
   detect a leak at least as small as 0.2 gallons per hour and meet the federal
   regulatory requirements regarding probabilities of detection and  of false
   alarm.  Data must be submitted at least monthly.

#  To be allowable as  an equivalent to tank tightness testing, a SIR method
   must be able to detect a leak at least as small 0.1 gallons per hour and
   meet the federal regulatory requirements regarding probabilities of detection
   and of false alarm.
                                     Straight Talk On Tanks   14

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#  The individual SIR method must have been evaluated with a test procedure
   to certify that it can detect leaks at the required level and with the
   appropriate probabilities of detection and of false alarm.

#  The method's evaluation must reflect the way the method is used in the
   field.  If a SIR method is not performed  by the SIR vendor, then the
   method's evaluation must be done without the involvement of the SIR
   vendor. Examples of this situation are SIR methods licensed to owners and
   hybrid ATGS/SIR methods.

#  If the test report is not conclusive, you must take the steps necessary to
   find out conclusively whether your tank  is leaking. Because SIR requires
   multiple days of data, you will probably  have to use  another method.

#  You must keep on file both the test reports and the  documentation that the
   SIR method used is certified as valid for your LIST system.

Will it work at your site?
#
#
#
SIR has been used primarily on tanks no more than 18,000 gallons in
capacity. If you are considering using a SIR method for larger tanks, check
the method's evaluation to confirm that it will meet regulatory requirements
and your needs.

A SIR method's ability to detect leaks declines as throughput increases.  If
you are considering using a SIR method for high throughput LIST systems,
check the method's evaluation to confirm that it will meet regulatory
requirements and your needs.
Water around a tank may hide a hole in the tank or distort the data to
analyzed by temporarily preventing a leak. To detect a leak in this
situation, you should check for water at least once a month.
be
Anything else you should consider?

#  Data, including product level measurements, dispensing data, and delivery
   data, should all be carefully collected according to the SIR vendor's
   specifications.  Poor data collection produces inconclusive results and
   noncompliance.

#  The  SIR vendor will generally provide forms for recording data, a calibrated
   chart converting liquid level to volume, and detailed instructions on
   conducting measurements.

#  SIR should not be confused with other release detection methods that also
   rely on periodic reconciliation of inventory, withdrawal, and delivery data.
   Unlike manual tank gauging or inventory control, SIR uses a sophisticated
   statistical analysis of data to detect releases.
      Find out if there are
      state or local
      requirements on the
      use of statistical
      inventory
      reconciliation that
      differ from those
      described here.
                              Straight Talk On Tanks  15

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Tank Tightness Testing With Inventory Control

Will you be in compliance?

When performed according to the manufacturer's specifications, periodic tank
tightness testing combined with monthly inventory control can temporarily
meet the federal leak detection requirements for tanks (this method does not
detect piping leaks). See page 19 for time restrictions.

These two leak detection methods must be used together, because neither
method alone meets the federal requirements for leak detection for tanks.
Tightness testing is also an option for underground piping, as described in the
section on leak detection for piping starting on page 22.

Because they must be used together, both tank tightness testing and
inventory control are discussed in this section. Tank tightness testing is
discussed first, followed by inventory control.


Tank Tightness Testing

How does the leak detection method work?

Tightness tests include a wide variety of methods. Other terms used for these
methods include "precision," "volumetric," and "nonvolumetric" testing.

#  Many tightness test methods are "volumetric" methods in which the
   change in product level in a tank over time is measured very precisely (in
   milliliters or thousandths of an inch).

#  Other methods use acoustics or tracer chemicals to determine the
   presence of a hole in the tank. With such methods, all of the factors in the
   following bullets may not apply.

#  For most methods, changes in product temperature also must be
   measured very precisely (thousandths of a degree) at the same time as
   level measurements, because temperature changes cause volume
   changes that interfere with finding a leak.

#  For most methods, a net decrease in product volume (subtracting out
   volume changes caused by temperature) over the time of the test
   indicates a leak.

#  The testing equipment is temporarily installed in the tank, usually through
   the fill pipe.

#  The tank must be taken out of service for the test.

#  Many test methods require that the product in the tank be a certain level
   before testing, which often requires adding product from another tank on-
   site or purchasing additional product.
            Straight Talk On Tanks   16

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#  Some tightness test methods require all of the measurements and
   calculations to be made by hand by the tester. Other tightness test
   methods are highly automated. After the tester sets up the equipment, a
   computer controls the measurements and analysis.

#  A few methods measure properties of the product that are independent of
   temperature, such as the mass of the product, and so do not need to
   measure product temperature.

#  Some automatic tank gauging systems are capable of meeting the
   regulatory requirements for tank tightness testing and can be considered
   as an equivalent method.

What are the regulatory requirements?

#  The tightness test method must be able to detect a leak at least as small
   as 0.1 gallon per hour with certain probabilities of detection and  of false
   alarm.

#  Tightness tests must be performed periodically.  New LIST systems—those
   installed after December 1988—must have tank tightness tests every 5
   years for 10 years following installation.
   In  most cases, existing LIST systems—those installed before December
   1988—that have spill, overfill, and corrosion protection must have tank
   tightness tests every 5 years for 10 years following upgrade. See page 19
   for some cases requiring fewer tightness tests. Existing LIST systems that
   have not been upgraded must have tank tightness tests annually until
   December 1998, after which these tanks must be upgraded, replaced, or
   closed.

#  After the applicable time period noted above, you must have a monitoring
   method that can be performed at least  once per month. See the other
   sections of this booklet for allowable monthly monitoring options.

Anything  else you should consider?

#  For most methods, the test is performed by a testing company. You just
   observe the test.

#  Tank tightness testing has been used primarily on tanks no more than
   15,000 gallons in capacity containing gasoline and diesel. If you  are
   considering using tightness testing for larger tanks or products other than
   gasoline or diesel, discuss the method's applicability with the
   manufacturer's representative.

#  Manifolded tanks generally should be disconnected and tested separately.

#  Procedure and personnel, not equipment, are usually the most important
   factors in a successful tightness test. Therefore,
   well-trained and experienced testers are very important. Some
   states and local authorities have tester certification  programs.
Find out if there are
state or local
requirements on the
use of these
methods that differ
from those
described here.
                             Straight Talk On Tanks  17

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Ltainq Err/circr/ CDrHro; HnjN

PCX
Inventory Control

How does the leak detection method work?

Inventory control requires frequent measurements of tank contents and math
calculations that let you compare your "stick" inventory (what you've
measured) to your "book" inventory (what your recordkeeping indicates you
should have).  Some people call this process "inventory reconciliation." If the
difference between your "stick" and "book" inventory is too large, your tank
may be leaking.

EPA has a booklet, Doing Inventory Control Right, that fully explains how to
do inventory control. The booklet also contains standard recordkeeping
forms. You  can  order this free booklet by calling EPA's toll-free Hotline at 800
424-9346. See inside the front cover for full ordering information.

#  LIST inventories are determined each operating day by using a gauge
   stick and recording the data on a form. The level on the gauge stick is
   converted to a volume of product in the tank using a calibration chart,
   which is often furnished by the LIST manufacturer.

#  The amounts of product delivered to and withdrawn from the LIST each
   operating day are also recorded. At least once each month, the gauge
   stick data and the sales and delivery data are reconciled and the month's
   overage or shortage is determined. If the overage or shortage is greater
   than or equal to 1.0 percent of the tank's flow-through volume plus 130
   gallons of product, the LIST may be leaking.

What are the  regulatory requirements?

#  Inventory control must be used in combination with periodic tank tightness
   tests.

#  The gauge stick should reach the bottom of the tank and be marked so
   that the  product level  can be determined to the nearest one-eighth of an
   inch. A monthly measurement should be taken to identify any water at the
   bottom of the tank.

#  Product dispensers must be calibrated to the local weights and measures
   standards.

Anything  else you should consider?

#  Inventory control is a  practical, commonly used management tool  that
   does not require closing down the tank operation for long periods.

#  The accuracy of tank  gauging can be greatly increased by spreading
   product-finding paste  on the gauge stick before taking measurements (or
   by using in-tank product level monitoring devices).

#  If your tank is not level, inventory control may need to be modified. You
   will need to get a corrected tank chart.
                                Straight Talk On Tanks   18

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Time restrictions on the use of this combined method...

Existing LIST systems—those installed before December 1988—that have not
been fully upgraded with spill, overfill, and corrosion protection must have
tank tightness tests annually until December 1998, after which these tanks
must be upgraded, replaced, or closed.

The combined method using tank tightness testing every 5 years is valid only
after the entire UST system has met spill, overfill, and corrosion  protection
standards. Following entire UST system upgrade, this combined method may
be used for 10 years (or until December 1998, whichever is later) after the
date the tank was installed or upgraded with corrosion protection. Note that
the end date is based on the compliance status of the tank only, not the
entire UST system. As a result, some USTs may not be  able to use this
combined method for as long as 10 years (see discussion below). At the end
of the valid time  period, you must use one of the monthly monitoring leak
detection choices described in this booklet.

Unique time restriction for some existing USTs...

For some existing USTs—those which had corrosion protection before the
entire UST system met upgrade standards—this combined method
of inventory control and tightness testing every 5 years may be valid for less
than 10 years.

Federal regulations state that the combined method can be used:
1) until December 1998 or 10 years after the tank is protected from corrosion
(whichever date  is later), and 2) the period of validity cannot begin until the
entire UST system meets upgrade standards.  Therefore,
in those cases where the tank had corrosion protection before the UST
system met upgrade standards, the period of validity is less than
10 years. The effect of this restriction will be clear in the following example: a
bare steel tank upgraded with corrosion protection in 1986 (or the tank was
made of noncorrodible material and installed in 1986), but the piping, spill,
and overfill upgrades were not added  until 1995. The UST system in this
example could start using the combined method only in 1995 (when the full
system met upgrade standards) and could use the combined method only
until 1998 (the date which is the later of either 1998 or 10 years after the tank
has corrosion protection).  In this example, the UST may use the combined
method to meet  federal leak detection requirements only for three years (from
1995 to 1998).

Correspondingly, when the period of validity is less than  10 years,
fewer periodic tightness tests may be required.

Check with your implementing agency for guidance.
The combined method
can be used only
temporarily.
Be sure you know how
long you can use the
combined method to
meet federal, state, or
local requirements.
                             Straight Talk On Tanks   19

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*fl*   Mor.ua! Ten
Manual Tank Gauging

Will you be in compliance?

NOTE: Manual tank gauging can be used only on tanks 2,000 gallons
or less capacity. Tanks 1,000 gallons or less can use this method alone.
Tanks from 1,001-2,000 gallons can temporarily use manual tank gauging
only when it is combined with tank tightness testing. Manual tank gauging
cannot be used on tanks over 2,000 gallons. When performed according to
recommended practices, manual tank gauging meets the federal leak
detection requirements for USTs with a capacity of 1,000 gallons or less for
the  life of the tank. Manual tank gauging detects leaks only from tanks (this
method does not detect piping leaks). For requirements for piping, see the
section on leak detection for piping starting on  page 22.

How does the leak detection method work?

EPA has a booklet, Manual Tank Gauging, that fully explains how to do
manual tank gauging correctly. The booklet also contains standard
recordkeeping forms. You can order this free booklet by calling EPA's toll-free
Hotline at 800 424-9346. See inside the front cover for complete ordering
information.

#  Four measurements of the tank's contents must be taken weekly,
    two at the beginning and two at the end of at least a 36-hour period
    during which nothing is added to or removed from the tank. See the table
    on the next page.

#  The average of the two consecutive ending measurements are
    subtracted from the average of the two beginning measurements to
    indicate the change in product volume.

#  Every week, the calculated change in tank volume is compared to the
    standards shown in the table on the next page. If the  calculated change
    exceeds the weekly standard, the LIST may be leaking.
    Also, monthly averages of the four weekly  test results must be compared
    to the monthly standard in the same way. See the table on the next page.

What are  the regulatory requirements?

#  Liquid level measurements must be taken with a gauge stick that is
   marked to measure the liquid to the nearest one-eighth of an inch.

#  Manual tank gauging may be used as the sole method of leak detection
   for tanks with a capacity of 1,000 gallons or less for the life of the tank.
   Tanks between 551 and 1,000 gallons have testing standards based on
   their diameter or their additional use of tightness testing (see table).
   These tanks may temporarily use a combination of manual tank gauging
   and periodic tank tightness (see next bullet on page 21).
            Straight Talk On Tanks  20

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           Table of Test Standards for Manual Tank Gauging
Tank Size
up to 550 gallons
551-1 ,000 gallons (when
tank diameter is 64")
551-1 ,000 gallons (when
tank diameter is 48")
551-1 ,000 gallons
(also requires periodic
tank tightness testing)
1 ,001-2,000 gallons (also
requires periodic tank
tightness testing)
Minimum
Duration Of Test
36 hours
44 hours
58 hours
36 hours
36 hours
Weekly Standard
(1 test)
10 gallons
9 gallons
12 gallons
13 gallons
26 gallons
Monthly
Standard (4-test
average)
5 gallons
4 gallons
6 gallons
7 gallons
13 gallons
#  For tanks with a capacity of 1,001-2,000 gallons, manual tank gauging
   must be combined with periodic tightness testing. This combined method
   will meet the federal requirements only temporarily. See page 19 for an
   explanation of time restrictions that also applies to the combination of
   manual tank gauging and tank tightness testing. You must eventually have
   another monitoring method that can be performed at least once a month.
   See the other sections of this  booklet for allowable monthly monitoring
   options. Also, see
   pages 16-17 on tank tightness testing for details on this method.

#  Tanks greater than 2,000 gallons in capacity may not use this method of
   leak detection to meet these regulatory requirements.

Anything else you should consider?

#  You can perform manual tank gauging yourself. Correct gauging,
   recording, and  math are the most important factors for successful tank
   gauging. The accuracy of tank gauging can be greatly increased by
   spreading product-finding paste on the gauge stick before taking
   measurements.
                             Straight Talk On Tanks   21

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Leak Detection For Underground Piping

Will you be in compliance?

When installed and operated according to the manufacturer's specifications,
the leak detection methods discussed here meet the federal regulatory
requirements for the life of underground piping systems. Your LIST may have
suction or pressurized piping, which are discussed below.

What are the regulatory requirements for suction piping?

#  No leak detection is required if the suction piping has (1) enough slope so
   that the product in the pipe can drain back into the tank when suction is
   released and (2) has only one check valve, which is as close as possible
   beneath the pump in the dispensing unit.  If a suction line is to be
   considered exempt based on these design elements, there must be some
   way to check that the line was actually installed according to these plans.

#  If a suction line does not meet all of the design criteria noted above, one
   of  the following leak detection methods must be used:

   *•  A line tightness test at least every 3 years; or

   *•  Monthly interstitial monitoring;  or

   -  Monthly vapor monitoring; or

   -  Monthly groundwater monitoring; or

   *•  Monthly statistical inventory reconciliation; or

   *•  Other monthly monitoring that  meets performance standards.

The line tightness test must be able to detect a leak at least as small as 0.1
gallon per hour at 1.5 times normal operating pressure with certain
probabilities of detection and of false alarm.

Interstitial monitoring, vapor monitoring, groundwater monitoring, and
statistical inventory reconciliation have the same regulatory requirements for
piping as they do for tanks. See the  earlier sections of this booklet on those
methods.
            Straight Talk On Tanks   22

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What are the regulatory requirements for pressurized piping?

Each pressurized piping run must have one leak detection method from each
set below:
   An Automatic Line Leak Detector:

     -  Automatic flow restrictor; or
     >•  Automatic flow shutoff; or
     >•  Continuous alarm system.

   And One Other Method:

     >•  Annual line tightness test; or
     >•  Monthly interstitial monitoring; or
     >•  Monthly vapor monitoring; or
     -  Monthly groundwater monitoring; or
     -  Monthly statistical inventory reconciliation; or
     -  Other monthly monitoring that meets performance standards.

#  The automatic line leak detector (LLD) must be designed to detect a leak
   at least as small as 3 gallons per hour at a line pressure of
   10 pounds per square inch within 1 hour by shutting off the product flow,
   restricting the product flow, or triggering an audible or visual  alarm.

#  The line tightness test must be able to detect a leak at least  as small as
   0.1 gallon per hour when the line pressure is 1.5 times its normal
   operating pressure. The test must be conducted each year.  If the test is
   performed at pressures lower than 1.5 times operating pressure, the leak
   rate to be detected must be correspondingly lower.

#  Automatic LLDs and line tightness tests must also be able to meet the
   federal regulatory requirements regarding probabilities of detection and
   false alarm.

#  Interstitial monitoring, vapor monitoring,  groundwater monitoring, and
   statistical inventory reconciliation have the same regulatory requirements
   for piping as they do for tanks.  See the  earlier sections of this booklet on
   those methods.
Find out if there are
state or local
requirements on the
use of leak
detection methods
for piping that differ
from those
described here.
How do the leak detection methods work?

Automatic line leak detectors (LLDs)

#  Flow restrictors and flow shutoffs can monitor the pressure within the line
   in a variety of ways:  whether the pressure decreases over time; how long
   it takes for a line to reach operating pressure; and combinations of
   increases and decreases in pressure.
                             Straight Talk On Tanks  23

-------
#  If a suspected leak is detected, a flow restrictor keeps the product flow
   through the line well below the usual flow rate. If a suspected leak is
   detected, a flow shutoff completely cuts off product flow in the line or
   shuts down the  pump.

#  A continuous alarm system constantly monitors line conditions and
   immediately triggers an audible or visual alarm if a leak is suspected.
   Automated internal, vapor, or interstitial line monitoring systems can also
   be set up to operate continuously and sound an alarm, flash a signal on
   the console, or even ring a telephone in a manager's office when a leak is
   suspected.

#  Both automatic flow restrictors and shutoffs are permanently installed
   directly into the  pipe or the pump housing.

#  Vapor, interstitial, or other monitoring systems can be installed to shut off
   flow, restrict flow, or trigger an alarm whenever a leak is detected. If it
   meets the applicable standards, such a setup meets the monthly
   monitoring requirement as well  as the LLD requirement.

Line tightness testing

#  Tracer methods do not measure pressure or flow rates of the product.
   Instead they use a  tracer chemical to determine if there is a hole in the
   line.  With tracer methods, all of the factors below may not apply.

#  The line is taken out of service and pressurized, usually above the normal
   operating pressure. A drop in pressure over time, usually an hour or
   more, suggests a possible leak.

#  Suction lines are not pressurized very much during a tightness test (about
   7 to 15 pounds per square inch).

#  Most line tightness tests are performed by a testing company.  You just
   observe the test.

#  Some tank tightness test methods can be performed to include a
   tightness test of the connected  piping.

#  For most line tightness tests, no permanent equipment is installed.

#  In the event of trapped vapor pockets, it may not be possible to conduct a
   valid line tightness  test. There is no way to tell definitely before the test
   begins if this will be a problem,  but long complicated piping runs with
   many risers and dead  ends are more likely to have vapor pockets.

#  Some permanently installed electronic systems (which often include
   ATGS) can meet the requirements of monthly monitoring or a line
   tightness test.
            Straight Talk On Tanks   24

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Secondary containment with interstitial monitoring

#  A barrier is placed between the piping and the environment. Double-
   walled piping or a leakproof liner in the piping trench can be used.

#  A monitor is placed between the piping and the barrier to sense a leak if it
   occurs.  Monitors range from a simple stick that can be put in a sump to
   see if a liquid is present, to continuous automated systems that monitor
   for the presence of liquid product or vapors.

#  Proper installation of secondary containment is the most important and
   the most difficult aspect of this leak detection method. Trained and
   experienced installers are necessary.

#  See the section on  secondary containment for additional information.
   Secondary containment for piping is similar to that for tanks.

Vapor or groundwater monitoring

#  Vapor monitoring detects product that leaks  into the soil and evaporates.

#  Groundwater monitoring checks for leaked product floating on  the
   groundwater near the piping.

#  A site assessment must be used to determine monitoring well  placement
   and spacing.

#  LIST systems using vapor or groundwater monitoring for the tanks are well
   suited to use the same monitoring method for the piping.

#  See the earlier sections on  vapor and groundwater monitoring. Use of
   these methods with piping is similar to that for tanks.
                             Straight Talk On Tanks   25

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                          Free Publications About UST Requirements
AVAILABLE FREE...You can go to our Web site at http://www.epa.gov/OUST/ to order or read
documents online. You can call EPA's toll-free RCRA/Superfund Hotline at 800 424-9346 and order
up to 30 free copies. Or you can write and ask for titles by addressing your request to NCEPI, our
publication distributor: NCEPI, Box 42419, Cincinnati, OH 45242.  Or you can make your request by
calling NCEPI's toll-free number at 800 490-9198.  Or you can fax your order to NCEPI at 513 891 -6685.
If you want more than 30 copies, contact Jay Evans at 703 603-7149.

TITLES	

Musts For USTs: A Summary Of Federal Regulations For Underground Storage Tank Systems
Booklet clearly summarizes federal UST requirements for installation, release detection, spill, overfill, and corrosion protection,
corrective action, closure, reporting and recordkeeping. Updated & revised 1995 (36 pages). Also available as Normas y
Procedimientos para T.SA,Spanish translation of 1988 edition of Musts For USTs (40 pages).

Straight Talk On Tanks: Leak Detection Methods For Petroleum Underground Storage Tanks
Booklet explains federal regulatory requirements for leak detection and briefly describes allowable leak detection methods.
Updated & revised 1995 (28 pages).

Doing Inventory Control Right: For Underground Storage Tanks
Booklet describes how owners and operators of USTs can use inventory control and periodic tightness testing to meet federal leak
detection requirements. Contains reporting forms (16 pages).

Manual Tank Gauging: For Small Underground Storage Tanks
Booklet provides simple, step-by-step directions for conducting manual tank gauging for tanks 2,000 gallons or smaller. Contains
reporting forms (12 pages).

Introduction To Statistical Inventory Reconciliation: For Underground Storage Tanks
Booklet describes how Statistical Inventory Reconciliation (SIR) can meet federal leak detection requirements (12 pages).

Don't Wait Until 1998: Spill, Overfill, And Corrosion Protection For Underground Storage Tanks
Information to help owners and operators of USTs meet the 1998 deadline for compliance with requirements to upgrade, replace,
or close USTs installed before December 1988. Materials available as a 16-page booklet, a trifold leaflet, or Spanish translation of
the booklet (No Espere Haste El 1998!).

Are You Upgrading An Underground Storage Tank System?
Trifold leaflet can help UST owners and operators make sound decisions about choosing tank integrity assessment methods and
upgrading USTs to meet 1998 deadline requirements.

Closing Underground Storage Tanks: Brief Facts
Trifold leaflet presents "brief facts" on properly closing USTs in order to comply with federal closure requirements.

Dollars And Sense: Financial Responsibility Requirements For Underground Storage Tanks
Booklet summarizes the "financial responsibility" required of UST owners and operators (16 pages).

An Overview Of Underground Storage Tank Remediation Options
Information about technologies for remediating petroleum contamination in soil and groundwater (26 pages).

Controlling  UST Cleanup Costs
Fact sheet series on the cleanup process includes: Hiring a Contractor, Negotiating the Contract, Interpreting the Bill, Managing the
Process, and Understanding Contractor Code Words (10 pages).

Pay-For-Performance Cleanups: Effectively Managing Underground Storage Tank Cleanups
Booklet explores potential advantages of using pay-for-performance cleanup agreements to reduce the cost and time of cleanups
and more effectively manage cleanup resources (32 pages).

Financing Underground Storage Tank Work: Federal And State Assistance Programs
Booklet identifies potential sources of financial assistance to cover the costs of upgrading, replacing, or closing an UST, or of
cleaning up an UST release (30 pages).
                                         Straight Talk On Tanks   26

-------
                             Videos About UST Requirements
There are several helpful videos you can order, at cost, as explained below:
VIDEOS
TITLE/COST
   AVAILABLE FROM
Tank Closure Without Tears:  An Inspector's Safety Guide
Focuses on explosive vapors and safe tank removal (30 minutes).
Video and Booklet Cost: $35; Booklet: $5

What Do We Have Here?: An Inspector's Guide To Site Assessment At
Tank Closure
Inspecting sites for contamination where tanks have been removed.
Part 1: Site Assessment Overview (30 minutes); Part 2: Field Testing Instruments At
A Glance (14 minutes); Part 3: Soil And Water Sampling
At A Glance (7 minutes). Video and Booklet Cost: $45; Booklet: $5

Searching For The Honest Tank: A Guide To UST Facility Compliance
Inspection
Covers major aspects of UST inspections, including protocols, equipment, cathodic
protection, and leak detection. Directed at inspectors, yet also helpful to owners and
operators (30 minutes). Video and Booklet Cost: $40; Booklet: $5
New England Interstate
Environmental Training Center
ATTNVIDEOS
2 Fort Road
South Portland, ME 04106
207 767-2539
Tank Time
Humorous presentation explains what UST owners and operators must do to
comply with the December 1998 deadline to upgrade, replace, or close tanks
installed before December 1988 (18 minutes). Cost: $24
Doing It Right
Illustrates proper installation of underground tanks and piping for installation crews.
Part 1: Tanks (24 minutes); Part 2: Piping (16 minutes).

Doing It Right II: Installing Required UST Equipment
Illustrates installation of spill and overfill  equipment, observation wells, and piping
leak detection (23 minutes).

Keeping It Clean: Making Safe And Spill-Free Motor Fuel Deliveries
Making pollution-free deliveries to USTs. Includes Stage 1 vapor recovery, overfill
prevention and spill containment. For fuel tanker drivers and UST owner/operators
(25 minutes).

Petroleum Leaks Underground
How liquids and vapors move in the subsurface and why early response to leaked
petroleum is so important. Part 1: How Liquids Move (14 minutes);
Part 2: How Vapors Move (15 minutes).

Straight Talk on Leak Detection
Overview of the leak detection methods available for complying with federal
regulations (30 minutes).

RBCA: Initial Site Assessment
Overview of risk-based corrective action process produced by Shell Oil Company
(25 minutes).
Scene Three, Inc.
ATTN: "Tank Time"
1813 Eighth Avenue, South
Nashville, TN 37203
615385-2820
Contact EPA's Hotline at
800 424-9346 for cost and ordering
information.
                                    Straight Talk On Tanks   27

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                                 Slate  UST Program Offices
Alabama
Alabama Dept. of Env.
Mgt./Groundwater Section/
Water Div.
1751 Cong. Dickinson Dr.
Montgomery, AL 36130
Phone:(334)271-7986
Fax: (334)271-7950

Alaska
Alaska Dept. of Env.
Conservation
410WilloughbyAve.
Juneau.AK 99801-1795
Phone:(907)465-5203
Fax:(907)465-5218

Arkansas
Arkansas Dept. of Pollution
Control & Ecology
Regulated Storage Tanks
P.O. Box 8913
8101 Interstate 30,6ldgD
Little Rock, AR 72219-8913
Phone:(501)682-0744
Fax:(501)682-0880

Arizona
Arizona Dept. of Env. Quality
3033 North Central Ave.
Phoenix, AZ 85012
Phone:(602)207-4324
Fax:(602)207^346

California
California State Water Resources
Control Board
Div. of Clean Water Programs
P.O. Box944212
Sacramento, CA  94244-2120
Phone:(916)227-4313
Fax: (916)227-4349

Colorado
Colorado State Oil Inspection
1515ArapahoeSt.
Tower 3, Suite 600
Denver, CO 80202-2117
Phone: (303)620-4300
Fax: (303)620-4028

Connecticut
Connecticut Dept. of Env.
Protection/Waste Mgt. Bureau
State Office Bldg.
79 Elm Street
Hartford, CT  06106
Phone:(860)424-3374
Fax: (860)424-4057
Delaware
Delaware Dept. of Natural
Resources & Env. Control
UST Branch
715Grantham Lane
Newcastle, DE 19720^1801
Phone:(302)323-4588
Fax:(302)323^561

District of Columbia
D.C. Env. Reg. Adm./ Haz. Waste &
UST Division
2100 Martin Luther King Ave.,SE-
Suite 203
Washington,  DC 20020
Phone: (202)645-6080
Fax: (202)645-6622

Florida
Florida Dept. of Env.
Regulation/Tank Section
Twin Towers  Bldg.; Room 403
2600 Blair Stone  Road
Tallahassee, FL 32399-2400
Phone:(904)488-3935
Fax:(904)922^939

Georgia
Georgia Dept. of Natural
Resources/UST Mgt. Program
4244 Inter. Parkway; Suite 100
Atlanta, GA  30354
Phone:(404)362-2687
Fax:(404)362-2654

Hawaii
Hawaii Dept. of Health
Solid and Hazardous Waste Br.
919 Ala Moana Blvd.; Suite 212
Honolulu, HI 96814
Phone:(808)586-4226
Fax:(808)586-7509

Idaho
Idaho Div. of Env. Quality
1410 North Hilton
Boise, ID 83706
Phone:(208)373-0502
Fax:(208)373-0576

Illinois
Illinois Office of State Fire
Marshal/Div. of Petroleum &
Chemical Safety
1035StephensonDr.
Springfield, IL 62703
Phone:(217)785-5878
Fax:(217)782-1062

Indiana
Indiana Dept. of Env. Mgmt./Office of
Env. Response
1 DON. Senate Ave.
Indianapolis, IN 46206
Phone:(317)308-3060
Fax:(317)233-0909
Iowa
Iowa Dept. of Natural
Resources/UST Section
Wallace State Office Bldg.
900 East Grand
DesMoines, IA50319
Phone:(515)281-8135
Fax:(515)281-7212

Kansas
Kansas Dept.of Health &
Env./Bureau Env. Remed./ Storage
Tank Section
Forbes Field,  Bldg. 740
Topeka, KS 66620
Phone:(913)296-1678
Fax:(913)296-6190

Kentucky
Kentucky Division of Waste
Management/UST Branch
14ReillyRoad
Frankfort, KY 40601
Phone:(502)564-6716
Fax:(502)564^245

Louisiana
Louisiana Dept. of Env.
Quality/UST Division
P.O. Box82178
Baton Rouge, LA 70884-2178
Phone:(504)765-0243
Fax:(504)765-0366

Maine
Maine Dept. of Env. Protection
6ur. Remediation & Waste Mgt.
Ray Bldg, Station #17
Augusta, ME 04333
Phone:(207)287-2651
Fax:(207)287-7826

Maryland
Maryland Dept. of Env.
Waste Mgt. Admin.
Oil Control Program
2500 Broening Highway
Baltimore, MD 21224
Phone:(410)631-3442
Fax:(410)631-3092

Massachusetts
Massachusetts Dept. of Public
Safety/UST Program
One Ashburton Place; Rm 1310
Boston, MA 02108
Phone:(617)727-3200
Fax:(617)727^390

Michigan
Michigan Dept. of Env.
Quality/UST Division
P.O. Box30157
Lansing, Ml 48909-7657
Phone:(517)373-8168
Fax:(517)335-2245
Minnesota
Minnesota Pollution Control
Agency/UST Program
520 Lafayette Road North
St. Paul, MN 55155-3898
Phone:(612)297-8608
Fax:(612)297-8676

Mississippi
Mississippi Dept. of Env. Quality
Bureau of Pollution Control
UST Section
P.O. 60x10385
Jackson, MS  39289-0385
Phone:(601)961-5171
Fax:(601)354-6612

Missouri
Missouri Dept. of Natural
Resources/Haz. Waste
Program/Tanks Section
P.O. 6ox 176
Jefferson City, MO 65102-0176
Phone:(573)751-6822
Fax:(573)562-8922

Montana
Montana Dept. of Env.Quality
Waste Management Div.
P.O. 60x200901
Helena, MT 59620-0901
Phone:(406)444-5970
Fax:(406)444-1902

Nebraska
Nebraska State Fire Marshal
Flammable Liquid Storage
246 South 14th Street
Lincoln, NE 68508
Phone:(402)471-9465
Fax:(402)471-3118

Nevada
Nevada Dept. of Cons.  & Nat.
Resources/Div. of Env.Prot.
Capitol Complex
333 W.Nye Lane
Carson City, NV 89710
Phone:(702)687-5872
Fax:(702)687-6396

New Hampshire
New Hampshire Dept. of
Env. Services/Groundwater
Protection 8ureau
P.O. 6ox 95
6 Hazen Drive
Concord, NH  03302
Phone:(603)271-3644
Fax:(603)271-2181
                                              Straight Talk On Tanks    28

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                                        State UST Program Offices
New Jersey
New Jersey Dept. of Env. Prot. and
Energy/Responsible Party Site
Remediation
401 East State St. (CN-028)
Trenton, NJ 08625-0028
Phone:(609)292-8761
Fax:(609)633-1454

New Mexico
New Mexico Env. Dept.
UST Bureau
P.O. Box 26110
H. Runnels Bldg, Rm N2150
Santa Fe, NM 87504-0968
Phone:(505)827-2932
Fax:(505)827-0310

New York
New York Dept. of Env. Cons./Bulk
Storage Section
50 Wolf Road, Rm 340
Albany, NY 12233-3750
Phone:(518)457-4351
Fax:(518)457^332

North Carolina
North Carolina Pollution Control
Branch/Div. of Env. Mgt/Dept. Env.
Health&Natural Resources
441 N. Harrington St.
Raleigh, NC 27603
Phone:(919)733-8486
Fax:(919)733-9413

North Dakota
Div. of Waste Mgt./North Dakota
Dept. of Health
UST Program
1200 Missouri Ave.
P.O. Box 5520
Bismarck, ND 58506-5520
Phone:(701)328-5166
Fax:(701)328-5200

Ohio
Ohio Dept. of Commerce
Bureau of UST Regulations
P.O. Box 687
6606 Tussing Road
Reynoldsburg, OH 43068-9009
Phone:(614)752-7938
Fax:(614)752-7942

Oklahoma
Oklahoma Corp.  Commission
Fuel Storage Div.
Jim Thorpe Bldg.
2101 North Lincoln Blvd.
Oklahoma Cily, OK 73105
Phone:(405)521-3107
Fax:(405)521-6576

Oregon
Oregon Dept. of Env.
Quality/UST Program
811SW Sixth Ave.; 9th Floor
Portland, OR 97204
Phone:(503)229-5733
Fax:(503)229-6954
Pennsylvania
Pennsylvania Dept. of
Env. Prot./Bureau of Water Quality
MgtVStorage Tank Prgm
Rachel Carson State Off. Bldg.
P.O. Box 8762
Harrisburg, PA 17105-8762
Toll-free UST: 1-800-42TANKS
Phone:(717)772-5599
Fax:(717)772-5598

Rhode Island
Dept. of Env. Mgt./UST Section
291 Promenade St.
Providence, Rl 02908
Phone:(401)277-2234
Fax:(401)521^230

South Carolina
South Carolina Dept. of Health
and Env. Control/Bureau of UST
Management
2600 Bull St.
Columbia, SC 29201
Phone:(803)734-5331
Fax:(803)734-3604

South Dakota
South Dakota Dept. of Env. & Nat.
Resources/UST Program
523 East Capitol
Pierre, SD  57501
Phone:(605)773-3296
Fax:(605)773-6035

Tennessee
Tennessee Dept. of Env. and
Conservation/Div. of USTs
4th Floor, L & C Tower
401 Church St.
Nashville, TN 37243-1541
Phone:(615)532-0945
Fax:(615)532-0938

Texas
Texas Natural Resources
Conservation Commission
Petroleum Storage Tank Div.
MC: 133
P.O. Box13087
Austin, TX  78711-3087
Phone:(512)239-2106
Fax:(512)239-2177

Utah
Utah Dept.  of Env. Quality
Div. of Env. Response and
RemediatJon/UST Branch
P.O. Box 144840
Salt Lake City, UT 84114^840
Phone:(801)536-4100
Fax:(801)359-8853

Vermont
Dept. of Env. Conservation
Haz. Materials Mgt. Div.
103 South Main St.
Waterbury, VT 05676
Phone:(802)241-3882
Fax:(802)244-5141
Virginia
Virginia Dept. of Env. Quality
Underground Storage Tanks
P.O. Box10009
Richmond, VA  23240
Phone:(804)698-4313
Fax:(804)698^266

Washington
Washington Dept. of Ecology
Toxics Cleanup Program
P.O. 60x47600
Olympia, WA 98504-7600
Phone:(360)407-7170
Fax: (360)407-7154

West Virginia
West Virginia Div. of
Env. Protection/Office of Waste
Mgt./UST Section
1356HansfordSt.
Charleston, WV 25301
Phone:(304)558-6371
Fax:(304)558-2387

Wisconsin
Wisconsin Dept. of Commerce
Env. & Reg. Services Div.
P.O. 60x7969
201 East Washington Ave.
Madison, Wl 53707-7969
Phone: (608)266-7874
Fax:(608)267-0592

Wyoming
Wyoming Dept. Of Env. Quality
Water Quality Division
Herschler 6ldg.; 4th Floor West
122 West 25th St.
Cheyenne, WY 82002
Phone:(307)777-7096
Fax:(307)777-5973
U.S. Territories

American Samoa
American Samoa Env.
Protection Agency
Office of the Governor
American Samoa Government
ATTN: UST Program
Pago Pago, AS 96799
Phone:011-684-633-2304
Fax:011-684-633-5801

Northern Mariana Islands
Div. of Environmental Quality
Commonwealth of Northern
Mariana Islands
P.O. 6ox 1304
3rd Floor,  Morgens 8ldg.
San Jose
Saipan, MP 96950
Phone:011-670-234-1011
Fax:011-670-234-1003

Guam
Guam Env. Protection Agency
IT&E; Harmon Plaza
Complex Unit D-107
130RojasSt.
Harmon, GU 96911
Phone:011-671-646-8863
Fax:011-671-646-9402

Puerto Rico
Environmental Quality 8oard
P.O. 60x11488
Commonwealth of Puerto Rico
Santurce,  PR 00910
Phone:(787)767-8109
Fax:(787)767-1962

Virgin Islands
Div. of Env. Protection/Dept. of
Planning and  Nat.  Resources
396-1 Foster Plaza
Annas Retreat
Charlotte Amalie
St. Thomas, VI 00802
Phone:(809)774-3320
Fax:(809)775-5706

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&EPA
    United States
    Environmental Protection
    Agency
    5403W
    Washington, DC 20460

    Official Business
    Penalty for Private Use
    $300

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