If your UST systems are
located in a state w/#? state
program approval, you must
follow the state requirements.
Their implementation time
frames may be different from
those identified in this
brochure. To find information
about your state's UST
regulation, contact your
implementing agency. You can
find contact information and
state UST websites at
www.epa.gov/oust/states/
statcon1.htm.
If your UST systems are
located in a state without state
program approval or in Indian
country, the implementation
time frames in this brochure
apply to you.

Note: This document is a resource to
promote compliance and does not replace the
federal UST regulation.
    EPA developed this
   compliance assistance
    brochure to help LIST
owners and operators comply
    with the federal UST
        regulation.
  This brochure highlights
 implementation time frames
   to meet the 2015 UST
       requirements.
 For more information about
 the 2015 UST requirements,
           visit

     www.eDa.aov/oust
 Implementation
Time Frames For
         2015
   Underground
   Storage Tank
  Requirements
                                       c/EPA
                                       Office of Underground Storage Tanks
                                       www.epa.gov/oust
                                       July 2015
                                       EPA-510-F-15-001
                                          Compliance Assistance For
                                       UST System Owners And Operators

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                                 Implementation Time Frames For 2015 LIST Requirements
2015 Requirement
Flow restrictors in vent lines may no longer be used to meet the overfill prevention
requirement at new installations and when an existing flow restrictor is replaced
Testing following a repair
Closure of internally lined tanks that fail the internal lining inspection and cannot be
repaired according to a code of practice
Notification of ownership changes
Demonstrating compatibility
For airport hydrant fuel distribution systems and LIST systems with field-constructed
tanks:
• Notification and financial responsibility1
• Release reporting
• Closure
Secondary containment and interstitial monitoring
Under-dispenser containment for new dispenser systems
Operator training
Site assessment records for groundwater and vapor monitoring
For previously deferred LIST systems:2
• Release detection for LIST systems that store fuel solely for use by emergency
power generators
• Subpart K (except notification, financial responsibility, release reporting, and
closure) for airport hydrant fuel distribution systems and LIST systems with field-
constructed tanks
Spill prevention equipment testing 2
Overfill prevention equipment inspections 2
Containment sump testing for sumps used for piping
interstitial monitoring 2
Release detection equipment testing
Walkthrough inspections
Implementation Time Frame
Owners and operators must begin meeting these
requirements after October 13, 2015
Owners and operators must begin meeting these
requirements after April 11, 2016
Owners and operators must begin meeting these
requirements after October 13, 2018
Owners and operators must conduct the first test or
inspection by October 13, 2018
1Note that EPA is requiring owners and operators to also submit a one-time notification of existence for these LIST systems by October 13, 2018. Owners and operators must
demonstrate financial responsibility when they submit the one-time notification form.
2UST systems installed after October 13, 2015 must meet these requirements at installation.

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