United States
                        Environmental Protection
                        Agency
Solid Waste and Emergency
Response
(OS-420 WF)
EPA510-F-93-004
April 1993
&EPA            UST  Program  Facts
                         Detecting  Leaks:
                         Technical   Regulations
                        U.S. Environmental Protection Agency
                        (EPA) regulations

                        EPA designed the technical regulations for
                        underground storage tanks (USTs) to reduce
                        the chance of releases from USTs, increase
                        the likelihood of finding releases quickly
                        when they do occur, and secure prompt
                        cleanup. Owners and operators are
                        responsible for detecting, slopping, and
                        cleaning up leaks and spills.

                        Leak detection requirements for existing
                        USTs (installed before 1988)

                        In addition to meeting  1998 requirements  for
                        upgrading (see  Leak Prevention fact sheet in
                        this series), owners and operators of USTs
                        installed before 1988 must use one of the
                        leak detection methods described below to
                        detect leaks from both tanks and piping.
                        Deadlines for compliance with the leak
                        detection requirements have been phased in
                        based on the tank's age.  (See chart.)

                        Leak detection requirements for new
                        USTs (installed after  1988)

                        Owners and operators of USTs installed
                        after 1988 also must use one of the leak
                        detection methods described below to detect
                        leaks from tanks and piping. (See chart.)

                        Leak detection methods

                        Experts have developed several methods to
                        help UST owners ascertain whether their
                        tanks arc tight. Owners and operators must
                        choose a leak detection method that is listed
              in the regulations, meets a performance
              standard described in the regulations, or
              is approved by their state agency as
              being at least as stringent in detecting
              leaks as the methods and standards in the
              regulations.

              The choice of a method is important
              because of the inherent problems in
              monitoring a tank: the UST is emptied
              and refilled periodically; the product
              level underground is not visible to the
              eye;  and factors such as temperature can
              affect measurement.

              •      Internal types.

                    Tank tightness testing does not
                    require permanent installation of
                    equipment or large capital
                    expenditures. Line tightness
                    testing is a similar method for
                    checking the UST's connective
                    pipes for leaks.

                    Tank tightness testing must be
                    used in conjunction with
                    inventory control. Inventory
                    control is an ongoing accounting
                    system, like a checkbook, that
                    owners have typically used as a
                    business practice to keep track of
                    their product and to detect leaks.
                    This method, tank tightness
                    testing and inventory control, can
                    only be used on USTs installed
                    or upgraded within the last 10
                    years.

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Leak Detection Requirements For USTs
Type of Tank
or Piping
New tanks
(installed after
December 1988)
Existing tanks
Pressurized piping
Suction piping
Minimum Requirements
Monthly monitoring* or monthly inventory
control and tank tightness testing every 5
years.**
Monthly monitoring* or monthly inventory
control and annual tank tightness testing
(only permissible until December 1998) or
monthly inventory control and tank
tightness testing every 5 years.** Very
small tanks may be able to use manual
tank gauging.
Automatic line leak detector and either
annual line testing or monthly monitoring*
(except automatic tank gauging).
Monthly monitoring* (except automatic tank
gauging) or line testing every 3 years.
There are no requirements if the system
has the characteristics known as "safe
suction" described in the final regulations.
Deadlines
At installation
If installation
date unknown:
If installed
before 1965:
1965-1969:
1970-1974:
1975-1979:
1980-1988:
• Existing piping
• New piping
• Existing piping
• New piping
December 1 989
December 1989
December 1990
December 1991
December 1992
December 1993
December 1 990
At installation
Same as
existing tanks
At installation
'Monthly monitoring includes automatic tank gauging, vapor monitoring, interstitial monitoring, groundwater monitoring,
and other approved methods.
"For new tanks, permissible only for 10 years after installation; for existing tanks, permissible only for 10 years after
adding corrosion protection and spill/overfill prevention or until December 1998, whichever date is later.

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Automatic tank gauging
systems are permanently installed
in USTs and provide automated,
accurate inventory information
and leak testing.  Among the
more expensive methods, they
require minimal operator
involvement, cause few service
interruptions, and are relatively
precise and sensitive.  They do
not check piping and may not
work on very large tanks.

Manual tank gauging, an easy
and inexpensive release detection
method only for small USTs, can
detect leaks as small as 0.2
gallons per hour.  It requires
shutting down tanks and does not
check piping.

Statistical inventory
reconciliation is a newer method
that 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.

External types.

Soil vapor monitoring is a
release detection method that is
used primarily for petroleum
UST systems. As petroleum
leaks from a tank or its
connective pipes,  some of the
liquid evaporates and spreads into
the surrounding soil, where it can
be detected by a vapor sensor.

Groundwater monitoring
utilizes permanent observation
wells placed close to the tank
system. They must be checked
periodically for evidence of
leaking material floating on the
       groundwater. This method is
       effective only at sites where
       groundwater is within 20 feet of the
       surface.

       Secondary containment and
       interstitial monitoring involves
       placing a barrier outside the primary
       tank and a release detection device
       between the inner and outer barriers
       - a space called the interstitial
       space.  Either vapor or liquid
       monitors may be used, and the
       system detects leaks in tanks and
       piping.  New USTs holding
       chemicals must use this method.

Reporting and record-keeping
requirements for all tanks

In general, UST owners and operators need
to report to the  regulatory authority only at
the beginning and end of the UST system's
operating life.  Reportable information
includes data about the type of UST,
certification of correct installation,  and
description of the leak detection device.
Owners and operators also must report to
the regulatory authority suspected and
confirmed releases, as well as follow-up
actions planned or taken to correct  damage
caused by the leaking UST.

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.

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What if an owner or operator can't
afford to comply  with leak detection
requirements?

The cost of complying with prevention and
other requirements will be a burden to some
owners and operators, especially those with
older tanks.  Seventeen states have
established financial assistance programs
that serve to mitigate the overall economic
impact of the UST regulatory program.  In
six of those states, owners and operators are
eligible to receive  grants or low-interest
loans to put leak detection methods in place.
Detecting Leaks: Technical Regulations ix 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 language the
layperson can understand.  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 RCRAISuperfund Hotline at 800 424-9346.

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