United States
Environmental Protection
Agency
Solid Waste And
Emergency Response
5403W
EPA510-F-94-011
August 1994
4>EPA UST Program Fact Sheets
Printed on Recycled Paper
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&EPA
United States
Environmental Protection
Agency
Solid Waste And
Emergency Response
5403W
EPA510-F-94-003
August 1994
UST Program Facts
Financial Responsibility
What are financial responsibility
requirements?
When Congress amended Subtitle I of the Resource
Conservation and Recovery Act in 1986, it directed
the U.S. Environmental Protection Agency (EPA)
to develop financial responsibility regulations for
owners and operators of underground storage
tanks.
Congress wanted owners and oi>erators of
underground storage tanks (USTs) to show that
they have the financial resources to clean up a site
if a release occurs, correct environmental damage,
and compensate third parties for injury to their
property or themselves. The amount of coverage
required depends on the type and size of the
business, as explained in the chart at the end of this
feet sheet.
How can owners and operators
demonstrate financial responsibility?
Owners and operators have several options: obtain
commercial environmental impairment liability
insurance; demonstrate self-insurance; obtain
guarantees, surety bonds, or letters of credit; place
the required amount into a trust fund administered
by a third party; or rely on coverage provided by a
state financial assurance fund. Local governments
have four additional compliance mechanisms
tailored to their special characteristics: a bond
rating test, a financial test, a guarantee, and a
dedicated fund.
When is financial responsibility required?
The chart at the end of this feet sheet presents five
groups of UST owners and operators, compliance
deadlines for each group, and required coverage
amounts.
What is the cost of demonstrating financial
responsibility?
EPA acknowledges that the cost of complying with
the technical and financial responsibility
requirements will be a burden to some owners and
operators, especially those with older tanks.
Because underwriting criteria for most private
insurance and eligibility requirements for some
state assurance funds require that tanks be in
compliance with federal or state technical
standards, many owners and operators are faced
with the costs of meeting technical requirements at
the same time they meet financial responsibility
costs.
The cost of meeting technical requirements
generally accounts for the majority of regulatory
compliance costs incurred by UST owners and
operators. Some states have established financial
assistance programs that can provide funds or low-
interest loans to help owners meet technical
requirements.
In terms of the costs for meeting financial
responsibility requirements, insurance premiums
for a facility with three to five upgraded tanks
usually run about $ 1,500 per year. Owners and
operators who participate in a state financial
assurance fund generally pay annual tank fees of
from $100 to $250 per tank.
In developing the regulations, EPA has been
sensitive to the financial impact of the regulations
on small business. EPA phased in compliance
deadlines, allowing the smallest businesses the
longest time to comply. It has since responded to
business owners' concerns by delaying compliance
dates for the smallest owners and operators. EPA
also has worked with states to develop state financial
assurance funds and grant and loan programs.
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How can state financial assurance funds
help?
States are developing financial assurance funds to
reduce the economic hardship of compliance with
financial responsibility requirements and to help
cover the costs of cleanups. State financial
assurance fund programs, which supplement or are
a substitute for private insurance, have been
especially useful for small-to-medium sized
petroleum marketers. Other characteristics of the
funds appear below:
• Financial assurance; funds are created by state
legislation and must be submitted to EPA for
approval before they can be used as
compliance mechanisms.
• In most cases, states generate money for the
funds with tank registration and petroleum
fees.
• Legislatures delegate authority for the fund to
a state agency addressing health,
environmental, or insurance issues.
• State assurance funds typically incorporate
eligibility requirements, such as
demonstrations that: facilities are in
compliance with technical recfuirements and
evidence of satisfactory inventory control and
recordkeeping.
• Most state funds contain some deductible that
the owner or operator is responsible
for paying. Details on the funds are specific
to each state.
Nationwide, these state funds raise about $1 billion
annually.
How many states have financial assurance
funds?
As of July 1994, 33 states had state; financial
assurance fund plans approved by EPA. Ten had
submitted fund plans for approval and three had
plans that they had not submitted for approval.
One additional state (Washington) hias a reinsurance
program that enables insurance companies to offer
lower-cost premiums to the state's UST owners.
"Financial Responsibility" is one in a series of fact
sheets about underground storage tanks (USTs) and
leaking USTs. The series is designed to help EPA, other
federal officials, and state authorities answer the most
frequently asked questions about USTs with consistent,
accurate information in plain language. Keep the fact
sheets handy as a resource. This fact sheet addresses
federal regulations. You may need to refer to applicable
state or local regulations, as well. For more
Information on UST publications, call the
RCRA/Superfund Hotline at 800 424-9346.
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Financial Responsibility Requirements
Of
And Operator*
Deadline
Covers £0
GROUP 1:
Petroleum marketers with
1 ,000 or more tanks
OR
Nonmarketers with net worth of
$20 million or more
(for nonmarketers, the "per
occurrence" amount is the
same as Group 4-B below)
January
1989
$1 million
GROUP 2:
Petroleum marketers with
100-999 tanks
October
1989
GROUP 3:
Petroleum marketers with
1 3-99 tanks
April
1991
GROUP 4-A:
Petroleum marketers with
1-12 tanks
December
1993
$1 million
if you have
100 or
fewer tanks
OR
$2 million
if you have more
than 100 tanks
GROUP 4-B:
Nonmarketers with net worth of
less than $20 million
December
1993
GROUP 4-C:
Local governments (including
Indian tribes not part of Group 5)
February
1994
GROUP 5:
Indian tribes owning USTs on Indian
lands (USTs must be in compliance
with UST technical requirements )
December
1998
$500,000
if throughput is
10,000 gallons
monthly or less
OR
$1 million
if throughput is more
than 10,000 gallons
monthly
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4vEPA
United States
Environmental Protection
Agency
Solid Waste And
Emergency Response
5403W
EPA510-F-94-010
August 1994
UST Program Facts
Environmental Justice
What is environmental justice?
Over the last decade, concern about the impact of
environmental pollution on particular populations
has been growing. Low income and minority
communities, for example, may bear
disproportionately high and adverse risk to human
health and the environment from pollution.
Compounding the problem, thes;e communities often
lack the legal means necessary to effectively organize
political activities on their own behalf. These
concerns have resulted in a movement to assure
environmental justice for all populations.
What is EPA doing?
Early in her tenure, Administrator Carol Browner of
the U. S. Environmental Protection Agency (EPA)
designated the pursuit of environmental justice one
of the Agency s top priorities. EPA's Office of Solid
Waste and Emergency Response formed a task force
in November 1993 to analyze environmental justice
issues specific to waste programs and to develop
recommendations addressing these issues. In
February 1994, President Clinton signed an
Executive Order on Environmental Justice which
focused federal agencies' attention on environmental
justice issues. In response, EPA is currently
developing an Agencywide strategy for
environmental justice.
Is there an environmental justice issue for
UST programs?
Underground storage tanks (USTs) are everywhere:
in cities, towns, and rural areas. Federal regulations
cover more than 1 million petroleum USTs at
facilities across the natioa Federal and state UST
programs are ensuring that the large universe of
regulated USTs meets all technical requirements for
preventing and detecting leaks and that cleanups
keep pace with the growing number of confirmed
releases.
No matter where they are located, leaking USTs can
threaten drinking water supplies or cause explosive
vapors to accumulate in sewers or basements. These
threats in all cases must be met with quick
emergency response.
However, USTs that leak in communities facing
potential pollution from other sources (such as
landfills, concentrated sources of air emissions,
hazardous waste treatment facilities, or Superfund
sites) can add to cumulative human health risk.
When all other factors are equal, leaking USTs in
communities facing exposure to multiple
environmental risks should receive priority attention.
UST program officials must ensure that leaking
USTs are brought under control as quickly as
possible in all communities, including economically
disadvantaged and minority communities.
How can UST programs address
environmental justice concerns?
The federal UST program is engaged in several
activities:
• Distributing information on environmental
justice to states, tribes, and local agencies.
• Incorporating environmental justice criteria into
state UST grants and cooperative agreements.
Guidance may include, for example, specific
clauses requiring states to consider
environmental justice as they develop cleanup
and compliance/enforcement strategies.
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• Continuing efforts on Indian lands to identify
existing USTs, including hazardous substance
USTs and abandoned tanks.
• Working to develop tribal capacity on Indian
lands by providing funds and technical
assistance to tribal governments.
• Encouraging the use of minority contractors and
consultants for tank installation and removal and
for state-lead cleanups to broaden economic
redevelopment efforts in disadvantaged
communities.
State UST programs are being encouraged to:
• Consider environmental justice as a qualitative
factor when developing priority ranking systems
for state-lead cleanup and enforcement
strategies.
• Use qualified minority contractors and
consultants on state-lead cleanups.
• Encourage minority contractors to apply for
certification and ensure that minority firms are
represented on any contractor lists that the state
provides to the regulated community.
• Develop and distribute information materials on
USTs and leaking USTs to their regulated
communities, including minority populations.
Need more information on environmental
justice?
To learn more about environmental justice, contact
EPA's toll-free number for concerned citizens at 800
962-6215, or call the EPA Regional Coordinator for
your state. EPA's Office of Environmental Justice
202 260-6357 can provide regional contacts and
telephone numbers.
"EnvironmentalJustice" is one in a series of fact sheets
about underground storage tanks (USTs) and leaking
USTs. The series is designed to help EPA, other federal
officials, and state authorities answer the most frequently
asked questions about USTs with consistent, accurate
information in plain language. Keep the fact sheets
handy as a resource. This fact sheet addresses federal
regulations. You may need to refer to applicable state or
local regulations, as well. For more information on
UST publications, call the RCRA/Superfund Hotline at
800424-9346.
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&EPA
United States
Environmental Protection
Agency
Solid Waste And
Emergency Response
5403W
EPA510-F-94-009
August 1994
UST Program Facts
State UST Programs
What is the role of states in regulating
underground storage tanks?
The U.S. Environmental Protection Agency (EPA)
recognizes that, because of the size and diversity of
the regulated community, state and local
governments are in the best position to oversee
underground storage tanks (USTs):
• State and local authorities are closer to the
situation in their domain and are in the best
position to set priorities.
• Subtitle I of the Resource Conservation and
Recovery Act (RCRA) allows state UST
programs approved by EPA to operate in lieu
of the federal program.
• The state program approval regulations set
criteria for states to obtain the authority to
operate in lieu of the federal program. State
programs must be at least as stringent as
EPA's.
How do states receive program approval?
EPA's regional offices coordinate the state program
approval process for states and territories under
their jurisdiction. Ultimately, they approve the
programs, following federal standards.
EPA regional officials work closely with state
officials while state programs are under
development. Once state legislatures enact statutes
and state agencies develop regulations in accord
with EPA requirements and put other necessary
components of a program in place, states may
apply for formal approval. EPA must respond to
applications within 180 days.
A state program is approved if it is judged to meet
three criteria:
• It sets standards for eight performance criteria
that are no less stringent than federal standards.
• It contains provisions for adequate
enforcement.
• It regulates at least the same USTs as are
regulated under federal standards.
Which states have approved programs?
Fourteen states have approved programs: Georgia,
Kansas, Louisiana, Maine, Maryland, Mississippi,
Nevada, New Hampshire, New Mexico, North
Dakota, Oklahoma, Rhode Island, Vermont, and
Washington.
Which states may be next?
Since EPA regulations went into effect, cleanup has
been a priority for many states. Increasingly, states
are making program approval a priority. A total of
23 states have submitted drafts of state program
approval applications which EPA regional officials
are currently reviewing.
What are the benefits of state program
approval?
Because state programs operate in lieu of the
federal program, states that have an approved UST
program can eliminate an entire set of government
regulators from their regulated community.
Owners and operators do not have to deal with two
sets of statutes and regulations (state and federal)
that may be conflicting. States take pride in
obtaining federal approval of their programs.
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Once their programs aire approved, states will have
the lead role in UST program enforcement. In
states without an approved program, EPA will
work with state officials in coordinating UST
enforcement actions.
Need more information about a particular
state's program?
Contact die EPA regional office or the UST/LUST
program in your state, usually located in the state
environmental department. Pro^jram staff will
provide information or referrals.
"State UST Programs " is one in a series of fact sheets
about underground storage tanks (USIs) and leaking
USTs. The series is 'designed to help EPA, other federal
officials, and state authorities answer the most frequently
asked questions about USTs with consistent, accurate
information in plain language. Keep the fact sheets
handy as a resource. This fact sheet addresses federal
regulations. ]bu may need to refer to applicable state or
local regulations, as well For more information on
UST publications, call the RCRA/Si tperfund Hotline at
800424-9346.
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&EPA
United States
Environmental Protection
Agency
Solid Waste And
Emergency Response
5403W
EPA510-F-94-007
August 1994
UST Program Facts
Leaking Underground
Storage Tank Trust Fund
What is the "LUST" Trust Fund?
Congress created the Leaking Underground Storage
Tank (LUST) Trust Fund in 1986 by amending
Subtitle 1 of the Resource Conservation and
Recovery Act. In December 1990, Congress
reauthorized the Trust Fund for five more years.
The LUST Trust Fund has two purposes. First, it
provides money for overseeing (Corrective action
taken by a responsible party, who is usually the
owner or operator of the leaking underground
storage tank (UST). Second, the Trust Fund
provides money for cleanups at UST sites where
the owner or operator is unknown, unwilling, or
unable to respond, or which require emergency
action.
What's in the Trust Fund?
The Trust Fund is financed by a 0.1 cent tax on each
gallon of motor fuel sold in the country. As of May
1994, about $1.2 billion had been collected.
Of this amount, Congress has given $475 million to
the U.S. Environmental Protection Agency (EPA)
through fiscal year 1994. About $410 million—or
86 percent of the amount given to EPA—has been
dispersed to state programs for state officials to use
for administration, oversight, and cleanup work.
The remaining Trust Fund money—about $65
million or 14 percent of the total—has been used by
EPA for administrative activities: negotiating and
overseeing cooperative agreements; implementing
programs on Indian lands; and supporting regional
and state offices.
How does the Trust Fund work?
To receive money from the Trust Fund, a state
must enter into a cooperative agreement with the
federal government to spend the money for its
intended purpose. Every state except Florida
(which has its own state cleanup fund) has a
cooperative agreement with EPA.
The money is divided among EPA regional offices
based on a formula that uses state data. In fiscal
year 1994, each state received a base allocation
plus additional money depending on the following:
the number of confirmed releases in the state; the
number of notified petroleum tanks; the number of
residents relying on groundwater for drinking
water; and the number of cleanups initiated and
completed as a percent of total confirmed releases.
How do states use Trust Fund money?
States use Trust Fund money to oversee corrective
action by a responsible party and to clean up sites
where no responsible party can be found. Only
about 1 percent of all cases have been without a
responsible party.
To date, states have used about one-third of their
Trust Fund money for administration, one-third for
oversight and state-lead enforcement activities, and
one-third for cleanups.
How many USlfc are leaking?
As of July 1994, EPA, states, and local agencies
have confirmed more than 262,000 UST releases.
Over the next several years, EPA expects more
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than another 100,000 confirmed releases to be
reported, primarily releases discovered during the
replacement or closure of USTs. After this peak,
EPA expects fewer additional releases as USTs
comply with requirements.
How much do cleanups cost?
Cleanup costs depend on a variety of factors,
including the extent of contamination and state
cleanup standards. The average cleanup is
estimated to cost $125,000.
If only a small amount of soil needs to be removed
or treated, cleanup costs can run as low as
$10,000. However, costs; to clean more extensive
soil contamination can reach $125,(XX). Corrective
action for leaks that affect groundwater can cost
from $100,000 to over $1 million, depending on
the extent of contamination.
What cleanup activities have taken place?
As of July 1994, states have used Tnost Fund and
state money to:
• Confirm more than 262,000 releases,
• Oversee or conduct more than 7,800
emergency responses,
• Oversee or initiate more than 202,000
cleanups,
• Oversee or complete more than 101,000
cleanups, and
• Oversee or conduct more than 892,000
closures.
"Leaking Underground Storage Tank Trust Fund" is
one in a series of fact sheets about underground storage
tanks (USTs) and leaking USTs. The series is designed
to help EPA, other federal officials, and state authorities
answer the most frequently asked questions about USTs
with consistent, accurate information in plain language.
Keep the fact sheets handy as a resource. This fact slieet
addresses federal regulations. You may need to refer to
applicable state or local regulations, as well. For more
information on UST publications, call the
RCRA/Superfund Hotline at 800 424-9346.
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&EPA
United States
Environmental Protection
Agency
Solid Waste And
Emergency Response
5403W
EPA510-F-94-006
August 1994
UST Program Facts
Cleaning Up Releases
What is the cleanup program?
In Subtitle I of the Resource Conservation and
Recovery Act, Congress directed the U.S.
Environmental Protection Agency (EPA) to establish
regulatory programs that would prevent, detect, and
clean up releases from underground storage tank
systems (USTs). EPA regulations require UST
owners and operators to respond to a release by:
• Reporting a release,
• Removing its source,
• Mitigating fire and safety hazards,
• Investigating the extent of the contamination,
and
• Cleaning up soil and groundwater as needed to
protect human health and the environment.
EPA developed the UST regulations and program to
be flexible and to be implemented by state and local
agencies. Every state and many local governments
now have active UST cleanup programs.
How many releases need attention?
As of July 1994, more than 262:>000 UST releases
had been confirmed. As the graphic on the next
page shows, many of these releases have been
cleaned up, but much work remEiins to be done. The
number of new releases reported continues to
outpace the number of sites cleaned up.
EPA estimates that the total number of confirmed
releases could reach 400,000 in the next several
years, primarily releases discovered during the
closure or replacement of USTs. After this peak,
EPA expects fewer releases as USTs comply with
requirements.
Currently, state and local UST cleanup program staff
oversee an increasing caseload of active cleanups.
State staff frequently have 50-400 cases to manage
at any given time. Staff work is often further
complicated by administrative bottlenecks in
oversight processes. At the same time, state staff
face an increasing backlog of sites awaiting
response.
Increasing caseloads, administrative bottlenecks,
backlogged sites, and staff overload slow down
cleanup responses. Over time, release sites in the
planning stages of corrective action and those
awaiting a response gradually become more difficult
and costly to clean up. Regulators have difficulty
finding the time necessary to perform inspections
and review corrective action plans. Delays in the
cleanup process disrupt businesses and make
cleanups more expensive for many owners,
particularly small businesses.
Can streamlining and alternative
technologies help?
One of EPA's top priorities in the UST program is to
help state and local governments make cleanups
faster, cheaper, and more effective. Two approaches
being used to reach this goal are streamlining
administrative procedures and using alternative
cleanup technologies.
Streamlining
EPA staff and consultants help states to streamline
cleanup oversight processes:
• They teach Total Quality Management
techniques to help identify delays and other
opportunities for improvement.
• They show state managers and staff how to use
flowcharts and performance indicators to
document, analyze, and improve their programs.
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Growing Number Of Cleanup Sites
300,000
250,000
200,000
Cleanup Sto»
Confirmed Releases
Cleanups Started
Cleanups Completed
Cleanups Awaiting Action
150,000
100,000
50,000
1 1 r
Jity1990 July 1991 July 1992 July 1993 July 1994
• They support state managers and staff in
streamlining efforts: developing clear guidance
materials and hosting "consultants days" to
improve the quality of cleanup plans and
reports; designing process changes that reduce
delays and paperwork; and providing training
that enables people to perform more
efficiently.
Alternative Technologies
In cooperative efforts with contractors, consultants,
tank owners, and states, EPA is also working to
promote the use of alternatives to traditional site
assessment and cleanup technologies. Even though
some promising technologies—such as air sparging,
bioremediation, and low temperature thermal
desorption—have proven advantageous in field
applications, they are not yet widely used across the
country. EPA is using a variety of training,
demonstration, and outreach projects to increase the
acceptance and use of technologies that can help
make cleanups faster, less costly, or more effective.
Are EPA's efforts helping?
By streamlining cleanup oversight processes and
promoting wider use of alternative technologies for
site assessment and cleanup, many states have made
improvements. States have reduced delays in
permitting, site assessment, corrective action, and
reimbursement processes. States are providing
clearer guidance to consultants and contractors,
which is resulting in better plans and reports,
speeding up the work, and cutting paperwork costs.
As training and demonstration projects progress,
alternative technologies such as soil vapor
extraction, air sparging, and bioremediation are
being used more often.
"Cleaning Up Releases" is one in a series of fact sheets
about underground storage tanks (USTs) and leaking
USTs. The series is designed to help EPA, other federal
officials, and state authorities answer the most frequently
asked questions about USTs with consistent, accurate
information in plain language. Keep the fact sheets
handy as a resource. This fact sheet addresses federal
regulations. You may need to refer to applicable state or
local regulations, as -well For more information on
USTpublications, call the RCRA/Superfund Hotline at
800424-9346.
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&EPA
United States
Environmental Protection
Agency
Solid Waste And
Emergency Response
5403W
EPA510-F-94-008
August 1994
UST Program Facts
Overview Of The UST
Program
What's an "UST"?
An underground storage tank system (UST) is a
tank and any underground piping connected to the
tank that has at least 10 percent of its combined
volume underground. The federal UST regulations
apply only to underground tanks and piping storing
either petroleum or certain hazardous substances.
The U.S. Environmental Protection Agency (EPA)
estimates that there are about 1.2 million federally
regulated USTs buried at over 500,000 sites
nationwide. Nearly all USTs at these sites contain
petroleum. These sites include marketers who sell
gasoline to the public (such as service stations and
convenience stores) and! nonmarketers who use
tanks solely for their own needs (such as fleet
service operators and local governments). Only
about 30,000 tanks hold hazardous substances
covered by the UST regulations.
Why be concerned about USTfc?
Until the mid-1980s, most USTs were made of
bare steel, which is likely to corrode over time and
allow UST contents to leak into the environment.
Faulty installation or inadequate operating and
maintenance procedures also can cause USTs to
release their contents into the environment.
The greatest potential hazard from a leaking UST is
that the petroleum or other hazardous substance can
seep into the soil and contaminate groundwater, the
source of drinking water for nearly half of all
Americans. A leaking UST can present other
health and environmental risks, including the
potential for fire and explosion.
How have Congress and EPA responded to
concerns about USTs?
In 1984, Congress responded to the increasing
threat to groundwater posed by leaking USTs by
adding Subtitle I to the Resource Conservation and
Recovery Act (RCRA). Subtitle I required EPA to
develop a comprehensive regulatory program for
USTs storing petroleum or certain hazardous
substances.
Congress directed EPA to publish regulations that
would require owners and operators of new tanks
and tanks already in the ground to prevent, detect,
and clean up releases. At the same time, Congress
banned the installation of unprotected steel tanks
and piping beginning in 1985.
In 1986, Congress amended Subtitle I of RCRA
and created the Leaking Underground Storage
lank Trust Fund, which is to be used for two
purposes:
• To oversee cleanups by responsible parties.
• To pay for cleanups at sites where the owner
or operator is unknown, unwilling, or unable to
respond, or which require emergency action.
The 1986 amendments also established financial
responsibility requirements. Congress directed EPA
to publish regulations that would require UST
owners and operators to demonstrate they are
financially capable of cleaning up releases and
compensating third parties for resulting damages.
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Do all tanks have to meet EPA
regulations?
The following USTs are excluded from regulation
and, therefore, do not need to meet federal
requirements for USTs:
• Farm and residential tanks of 1,100 gallons or
less capacity holding motor fuel used for
noncommercial purposes;
• Tanks storing heating oil used on the premises
where it is stored;
• Tanks on or above the floor of underground
areas, such as basements or tunnels;
• Septic tanks and systems for collecting storm
water and wastewater;
• Flow-through process tanks;
• Tanks of 110 gallons or less capacity; and
• Emergency spill and overfill tanks.
What are the federal requirements for
USTs?
In 1988, EPA issued regulations setting minimum
standards for new tanks and requiring owners of
existing tanks to upgrade, replace, or close them.
The UST regulations are divided into three
sections: technical requirements, financial
responsibility requirements, and state program
approval objectives.
Technical requirements
EPA's technical regulations for USTs are
designed to reduce the chance of releases from
USTs, detect leaks and spills when they do
occur, and secure a prompt cleanup. To meet the
requirements, owners must upgrade, replace, or
close existing UST systems by 1998. Tanks
remaining in operation must have: leak detection
and leak prevention components. UST owners
and operators are responsible for reporting and
cleaning up any releases. (See the other fact sheets
in this series on "Preventing Releases," "Detecting
Releases," and "Cleaning Up Releases.")
Financial responsibility regulations
The financial responsibility regulations ensure that,
in the event of a leak or spill, an owner or operator
will have the resources to pay for costs associated
with cleaning up releases and compensating third
parties. (Seethe "Financial Responsibility "fact
sheet in this series.)
State program approval objectives
EPA recognizes that, because of the large size and
great diversity of the regulated community, state
and local governments are in the best position to
oversee USTs. Subtitle I of RCRA allows state
UST programs approved by EPA to operate in lieu
of the federal program, and EPA's state program
approval regulations set standards for state
programs to meet. (See the "State UST Programs "
fact sheet in this series.)
States may have more stringent regulations than the
federal requirements. People who are interested in
requirements for USIs should contact their state UST
program for information on state requirements.
"Overview of the UST Program" is one in a series of
fact sheets about underground storage tanks (USTs) and
leaking USTs. The series is designed to help EPA, other
federal officials, and state authorities answer the most
frequently asked questions about USTs with consistent,
accurate information in plain language. Keep the fact
sheets handy as a resource. This fact sheet addresses
federal regulations. You may need to refer to applicable
state or local regulations, as well. For more
information on UST publications, call the
RCRA/Superfund Hotline at 800 424-9346.
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Add interior lining
Owners and operators must also keep records on:
Add a thick layer of noncorrodible material to the
interior of the tank. This interior lining must be
periodically inspected
Combine cathodic protection and interior lining
Combine cathodic protection and interior lining.
USTs using this option are not recpiired to have the
interior lining periodically inspected
What about piping?
Steel piping must have cathodic protectioa Piping
entirely made of (or enclosed in) noncorrodible
material does not need cathodic protectioa
How do you properly close an UST?
To properly close an UST:
• Notify the regulatory authority 30 days before
closing.
• Determine if the tank has leaked and damaged
the environment. If it has, take appropriate
notification and corrective action.
• Empty and clean the UST according to standard
safety practices.
• Either remove the UST from the ground or leave
it in the ground (USTs left in the ground must
be filled with a harmless and chemically inactive
solid).
Are there reporting and recordkeeping
requirements?
UST owners must notify state or local authorities of
the existence of an UST and its leak prevention
measures, or of the permanent closure of an UST.
Technical regulations also set guidelines for
notifying authorities of spills of more than 25
gallons.
• Inspection and test results for the cathodic
protection system.
• Repairs or upgrades.
• Site assessment results after closure.
Is there financial help to comply with
prevention requirements?
Some states have established financial assistance
programs that can provide funds or low-interest
loans to help owners upgrade or replace their tanks.
"Preventing Releases " is one in a series of fact sheets
about underground storage tanks (USTs) and leaking
USTs. The series is designed to help EPA, other federal
officials, and state authorities answer the most frequently
asked questions about USTs with consistent, accurate
information in plain language. Keep the fact sheets
handy as a resource. This fact sheet addresses federal
regulations. You may need to refer to applicable state or
local regulations, as well. For more information on
UST publications, call the RCRA/Superfund Hotline at
800424-9346.
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4VEPA
United States
Environmental Protection
Agency
Solid Waste And
Emergency Response
5403W
EPA510-F-94-005
August 1994
UST Program Facts
Detecting Releases
Why have release detection?
The U. S. Environmental Protection Agency
designed part of the technical regulations for
underground storage tanks (USTs) to make sure
releases or "leaks" from USTs an; discovered quickly
before contamination spreads from the UST site.
Owners and operators are responsible for detecting
leaks from their tanks and piping
Who needs leak detection?
All USTs must now have leak detection. USTs
installed after December 22,1988 must have leak
detection when they are installed USTs installed
before December 22,1988 had compliance deadlines
that varied with the age of the USTs. By December
22,1993, all of these "older" USTs had to be in
compliance with leak detection requirements.
What are the leak detection methods?
Owners and operators of petroleum USTs must use
at least one of the seven leak detection methods
below, or other methods approved by their state
agency.
1. Automatic tank gauging systems use monitors
permanently installed in the tank. These monitors
are linked electronically to a nearby control device to
provide information on product level and
temperature. During a test period! of several hours
when nothing is put into or taken from the tank, the
gauging system automatically calculates the changes
in product volume that can indicate a leaking tank.
This method does not work on piping.
2. 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 is
effective only at sites where groundwater is within
20 feet of the surface.
3. Vapor monitoring senses and measures product
vapor in the soil around the tank and piping to
determine the presence of a leak. This method
requires installation of carefully placed monitoring
wells. Vapor monitoring can be performed
periodically using manual devices or continuously
using permanently installed equipment
4. Secondary containment and interstitial
monitoring involves placing a barrier between the
UST and the environment The barrier provides
"secondary" containment and can be a vault, liner,
or double-walled structure. Leaked product from the
UST is directed toward a monitor located in the
"interstitial" space between the UST and the outer
barrier. Interstitial monitoring methods range from a
simple dip stick to automated vapor or liquid sensors
permanently installed in the system. New USTs
holding hazardous substances must use this method
5. Statistical inventory reconciliation uses
sophisticated computer software to determine
whether a tank system is leaking. The computer
conducts a statistical analysis of inventory, delivery,
and dispensing data collected over a period of time
and provided by the operator to a vendor.
6. Manual tank gauging can be used only on tanks
2,000 gallons or smaller. This method does NOT
work on tanks larger than 2,000 gallons or on
piping. This method requires taking the tank out of
service for at least 36 hours each week to take
measurements of the tank's contents. Tanks 1,000
gallons or less can use this method alone. Tanks
from 1,001-2,000 gallons can use this method only
when it is combined with periodic tank tightness
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testing and only for 10 years after installation or
upgrade of the UST. After 10 years, these USTs
must use one of the leak detection methods listed
above in 1-5.
The additional method below can be used
temporarily at all petroleum UST sites:
7. Tank tightness testing and inventory control
combines two methods. Tank tightness testing
requires periodic tests conducted by vendors who
temporarily install special equipment that tests the
soundness of the tank. Tank tightness testing must
be used in combination with inventory control.
Inventory control is an ongoing accounting system,
like a checkbook, kept by the UST owner or operator
to detect leaks. Inventory control requires taking
daily accurate measurements of the tank's contents
and performing monthly calculations to prove that
the system is not leaking. Tank tightness testing
and inventory control can be used only for 10
years after installation or upgrade of an UST.
After 10 years, these USTs must use one of the leak
detection methods listed above in 1-5.
What does piping need?
Pressurized piping needs automatic line leak
detectors (these can be automatic flow restrictors,
automatic flow shutofls, or continuous alarm
systems). Pressurized piping also needs one of the
following: groundwater monitoring., vapor
monitoring, secondary containment and interstitial
monitoring, or an annual tightness fojst of the piping.
Suction piping needs no leak detection if it meets
two design requirements: 1) piping slopes so that
the product drains back into the tank when suction is
released, and 2) piping hais only one check valve
located closely beneath the pump in the dispensing
unit. Suction piping not meeting these design
requirements must use one of the following:
tightness test of the piping every 3 years,
groundwater monitoring, vapor monitoring, or
secondary containment and interstitial monitoring.
Reporting and recordkeeping necessary?
UST owners and operators need to report to the
regulatory authority data about the UST, including
description of the leak detection method If
operation of the leak detection method indicates a
possible leak, UST owners and operators need to
report the potential release to the regulatory
authority. UST owners and operators must keep
records on leak detection performance and upkeep.
These include the previous year's monitoring results,
the most recent tightness test results, performance
claims by the leak detection device's manufacturer,
and records of recent maintenance and repair.
"Detecting Releases " is one in a series of fact sheets
about underground storage tanks (USTs) and leaking
USTs. The series is designed to help EPA, other federal
officials, and state authorities answer the most frequently
asked questions about USTs with consistent, accurate
information in plain language. Keep the fact sheets
handy as a resource. This fact sheet addresses federal
regulations. You may need to refer to applicable state or
local regulations, as -well. For more information on
UST publications, call the RCRA/Superfund Hotline at
800424-9346.
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