SEPA
United States
Environmental Protection
Agency
UPDATED 2015
Musts For USTs
EPA 510-K-15-001
November 2015
*w Printed on Recycled Paper
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EPA wrote this booklet for owners and operators of underground storage tanks (USTs).
This booklet describes the 2015 revised federal UST regulation. Many states and territories
(referred to as states in this booklet) have state program approval from EPA. To find a list of states
'rogram approval, see
programs
iur UST systems are located in a state with state program approval, your requirements may be
different from those identified in this booklet. To find information about your state's UST
regulation contact vour implementins asencv or visit its website You can find links to state UST
websitf
www.epa.gov/ust/underground-storage-tank-ust-contactsfetates
If your UST
in this booklet and the state requirements apply to you.
>th the requirements
If your UST systems are located in Indian country, the requirements in this booklet apply to you.
Free Publications About UST Requirements
www.epa.gov/ust
See EPA's underground storage tank (UST) websit
read documents online. Write to the National Service
(NSCEP), EPA's publication distributor: NSCEP, PO Box -,^-,^, ^,,,^ «.,,
toll-free number 800-490-9198. Fax your order to NSCEP 301-604-3408
order, download, or
-nmental Publications
incinnati, OH 45242. Call NSCEP's
Image credits:
MVI Field Services (inspector on cover and page 21)
Highland Tank & Manufacturing Company (steel tanks on cover and in headers)
OPW (fill sump on cover, spill bucket on page 7, automatic shutoff device on page 8, ball float valve
on page 9)
Federated Environmental Associates, Inc. (under-dispenser containment on page 5, spill bucket on
page 10, delivery on page 11)
Musts For USTs
November 2015
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Contents
What Is This Regulation About? 1
What Must You Do When You Install An UST? 5
What Must You Report? 6
What Are Your Spill And Overfill Prevention Requirements? 7
What Are Your Corrosion Protection Requirements? 12
What Are Your Release Detection Requirements? 15
What Must You Do For Walkthrough Inspections? 21
Compatibility With Biofuels And Other Regulated Substances 23
What Are The Operator Training Requirements? 25
How Do You Repair UST Systems? 26
Financial Responsibility 28
What Must You Do About UST Releases? 29
How Do You Close USTs? 31
What Records Must You Keep? 33
For Hazardous Substance USTs Only 34
Links For More Information ...,..,., ...,..,., ...,..,., 36
Disclaimer
This document provides information about the 2015 federal
underground storage tank (UST) system requirements. The
document is not a substitute for U.S. Environmental Protection
Agency regulations nor is it a regulation itself — it does not
impose legally binding requirements.
For regulatory requirements regarding UST systems, refer to the
federal regulation governing UST systems (40 CFR part 280).
Musts For USTs
November 2015
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As of 2015, the U.S. Environmental Protection Agency
(EPA) regulates over one-half million underground storage
tank systems (USTs) that contain petroleum or hazardous
substances. EPA's Office of Underground Storage Tanks
was formed in response to the discovery in the early 1980s
that thousands of USTs had leaked and contaminated
groundwater supplies in the United States. While the number
of annual releases since that time has gone down
significantly, releases of petroleum from USTs into the
environment are still a significant concern today.
Underground storage tanks form a crucial part of our
country's fueling infrastructure. It is important for USTs to
be constructed, maintained, and operated in a manner such
that petroleum and other regulated substances are stored
safely. EPA developed the UST regulation to help owners
and operators meet those goals.
A properly installed and managed UST system should not
threaten our health or environment. Congress passed federal
laws, which required EPA to develop the UST regulation
described in this booklet. The federal UST regulation in 40
Code of Federal Regulations (CFR) part 280 requires owners
and operators of USTs to:
• Prevent releases from USTs;
• Detect releases from USTs; and
• Correct the problems created by releases from USTs.
In addition, the regulation requires UST owners and
operators maintain documentation showing they have the
ability to pay for cleaning up a release if their USTs leak.
How Will The UST Regulation Affect You?
The UST regulation describes steps you, as an UST owner or
operator, must take to help protect our health and
environment from potential UST releases. These steps will
also help you avoid the high cost of cleaning up the
environment and possible legal actions if your UST system
leaks.
Musts For USTs
November 2015
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Check With Your Implementing Agency
Many states and territories (referred to as states in this booklet)
have state program approval from EPA. To find a list of states
with state program approval, see www. epa. gov/ust/state-
under ground- storage-tank-ust-program s.
If your UST systems are located in a state with state program
approval, your requirements may be different from those identified
in this booklet. Check with the state UST program in the state
where your USTs are located for your state's requirements.
If your UST systems are located in a state without state program
approval, both the requirements in this booklet and the state
requirements apply to you.
If your UST systems are located in Indian country, the
requirements in this booklet apply to you.
What Is An UST?
An UST is one or more tanks and any underground piping
connected to the tanks that have at least 10 percent of their
combined volume underground. The federal UST regulation
applies only to USTs storing petroleum, petroleum blended with
biofuels, and certain other hazardous substances.
The For Hazardous Substance USTs Only section on pages 34-35
describes special requirements for USTs storing hazardous
substances. Generally, the requirements for petroleum USTs and
hazardous substance USTs are very similar.
Some kinds of tanks are not covered by this regulation:
• 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 stormwater and
wastewater.
• Flow-through process tanks.
• Emergency spill and overfill tanks.
• Other storage sites, such as surface impoundments.
A list of state contacts
can be found at
www. epa.gov/ust/
underaround-storage-tank-
ust-contacts#states
The 2015 UST regulation
removes the deferral for
field constructed tanks and
airport hydrant systems,
making them subject to all of
the UST requirements.
Because these UST systems
can be large and unique
when compared to
conventional UST systems,
some of the requirements
are different from those
described in this booklet.
Therefore, these systems are
not covered in this booklet.
Please see EPA's field
constructed tanks and
airport hydrant systems
www. epa.gov/ust/fleld-
constructed-tanks-and-
airport-hydrant-systems-
2015-requirements
Musts For USTs
November 2015
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What Are Your Requirements?
The requirements listed below include 1988 requirements plus 2015 requirements and their
implementation dates. Throughout this document, bold type and orange updated boxes
indicate new requirements in the 2015 UST regulation. Remember you need to keep records
for most of these requirements. See page 33 for your recordkeeping requirements.
UPDATED
UPDATED
UPDATED
UPDATED
For These Tanks Or Facilities:
All Tanks
All Facilities
All Tanks Installed On Or Before
October 13, 2015 Ever Receiving
Deliveries Greater Than 25 Gallons
You Must Have This Equipment Or Perform These Actions:
Installation (page 5)
If you install an UST system, meet the requirements concerning correct
installation
Under-dispenser containment for new dispensers installed after
April 11,2016
Reporting (page 6)
After you bring an UST system into use, notify your implementing
agency within 30 days
Notify your implementing agency at least 30 days before permanently
closing an UST
Notify your implementing agency within 30 days of acquiring an
UST
Notify your implementing agency at least 30 days before switching
to regulated substances blended with greater than 10 percent
ethanol or greater than 20 percent biodiesel or other regulated
substances identified by your implementing agency
^^2M!^^^SillMSi
Spill buckets
Automatic shutoff devices or overfill alarms or ball float valves1
Use correct filling practices
No later than October 13, 2018, begin testing spill buckets every
three years2
No later than October 13, 2018, begin inspecting overfill prevention
equipment every three years
All Tanks Installed After October 13,
2015 Ever Receiving Deliveries
Greater Than 25 Gallons
Spill buckets
Automatic shutoff devices or overfill alarms
Use correct filling practices
Test spill buckets every three years2
Inspect overfill prevention equipment every three years
UPDATED
Tanks And Piping Installed On Or
Before December 22,1988
Tanks And Piping Installed After
December 22,1988
Tanks Installed On Or Before April
11,2016s
Same options as for tanks and piping installed after December 22, 1988; or
Cathodically protected steel; or
Tank interior lining; or
Tank interior lining andcathodic protection
Cathodic protection testing and internal lining inspections
Coated and cathodically protected steel; or
Noncorrodible material, such as fiberglass reinforced plastic (FRP) or
flexible plastic (piping only); or
Steel tank clad or jacketed with noncorrodible material (tanks only)
Cathodic protection testing
15 20)
Monthly monitoring;4 or
Manual tank gauging;5 or
Inventory control or manual tank gauging4 plus tank tightness testing (only for
10 years after installation)
Pressurized Piping Installed On Or
Before April 11,2016s
Automatic line leak detector; and
Annual line tightness test or
Monthly monitoring4 (except automatic tank gauging)
No later than October 13, 2018, begin testing containment
sumps used for piping interstitial monitoring every three years2
Musts For USTs
November 2015
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UPDATED
UPDATED
UPDATED
UPDATED
UPDATED
UPDATED
UPDATED
UPDATED
For These Tanks Or Facilities:
Suction Piping Installed On Or
Before April 11,2016s
Tanks And Piping Installed Or
Replaced After April 1 1 , 2016
Release Detection Testing
Beginning October 13, 2018
Facilities Using Vapor Or
Groundwater Monitoring
You Must Have This Equipment Or Perform These Actions:
• Monthly monitoring;4 or
• Line tightness testing (every 3 years); or
• No requirements (if the system has the characteristics described on
page 19)
• No later than October 13, 2018, begin testing containment
sumps used for piping interstitial monitoring every three years2
• Secondary containment with interstitial monitoring
• Pressurized piping must also have an automatic line leak detector
• No requirements for suction piping (if the system has the characteristics
described on page 19)
• Test containment sumps used for piping interstitial monitoring
every three years2
• Annual release detection equipment operability testing
• No later than October 13, 2018, begin keeping a record of a site
assessment for as long as the method is used
All Facilities Beginning On October
13. 2018
• 30 day and annual walkthrough inspections
Use UST systems made of or lined with material compatible with the
substance stored
For systems storing certain regulated substances, maintain
records demonstrating compliance with the compatibility
requirement
All Facilities Beginning On October
13. 2018
• Have designated and trained Class A, B, and C operators
• Conduct testing following repairs to your tank, piping, or cathodic protection
system
• Test or inspect components within 30 days after a repair to spill or
overfill prevention equipment or secondary containment areas
All Facilities
All Facilities
Keep records demonstrating you have the financial resources to clean
up a site if a release occurs, correct environmental damage, and
compensate third parties for iniury to their property or themselves
Release Response (pages 29-30)
Take corrective action in response to releases
All Facilities
UPDATED
Properly temporarily or permanently close your UST system
Notes:
1 Ball float valves may not be used when overfill prevention is installed or replaced after October 13, 2015.
2 Spill containment and containment sump testing is not required if the containment is double-walled and
uses periodic interstitial monitoring.
3 USTs storing fuel for emergency power generation installed on or before October 13, 2015 must begin
meeting the release detection requirements on October 13, 2018. USTs storing fuel for emergency power
generation installed after October 13, 2015 must meet the release detection requirements at installation.
4 Monthly monitoring (not to exceed 30 days) includes: interstitial monitoring; automatic tank gauging; vapor
monitoring, groundwater monitoring; statistical inventory reconciliation; continuous in-tank leak detection; and other
methods approved by your implementing agency.
5 Tanks 2,000 gallons and smaller may be able to use manual tank gauging (page 18).
Musts For USTs
November 2015
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.jat Must You Do When
You Install An UST?
Make sure your UST system is installed correctly; use
qualified installers who follow industry codes and
manufacturers' instructions. (See
www.epa.gov/ust/underground-storage-tanks-usts-laws-
regulations#code for more information on industry codes
and installation practices.)
• Make sure the certification for proper installation on
the notification form is completed and signed. You
can find the notification form at
www.epa.gov/sites/production/files/2015-
07/documents/updated-form.pdf.
Installation problems may result from installation practices
that do not follow standard industry codes and procedures.
Improper installation could result in UST system failures.
Installation includes activities such as excavation, UST
system siting, burial depth, tank system assembly,
backfilling around the UST system, and surface grading.
Make sure that installers carefully follow the correct
installation procedures called for by manufacturers'
instructions and industry codes.
What you must do for under-dispenser
containment:
Mistakes can be made
during installation. For
example, mishandling of the
tank during installation can
cause issues with tanks, tank
coatings, and cathodic
protection. Improper layout
of piping runs, incomplete
tightening of joints,
inadequate cover pad
construction, and
construction accidents can
lead to failure of delivery
piping.
UPDATED
Dispensers installed after April 11, 2016 must have
under-dispenser containment. Under-dispenser
containment must be liquid-tight on its sides, bottom,
and at any penetrations. Under-dispenser containment
must allow for visual inspection and access to the
components in the containment system or be periodically
monitored for leaks from the dispenser system.
Musts For USTs
November 2015
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You must report to your implementing agency on the following occasions:
UPDATED
UPDATED
When This Happens:
After you install an UST
After you acquire an UST,
such as by purchasing a
gas station
Before switching to certain
biofuels or other
substances identified by
your implementing agency
When you suspect a release
When you confirm a release
Before you permanently
close your UST
You Must Report This:
You must complete and submit a
notification form available from
your implementing agency. This
form requests information about
your UST, including a certification
of correct installation. You should
have already used this form to
identify your existing USTs. If you
have not done that yet, do so
now.
By This Time:
Within 30 days of bringing the UST
into use
You must complete and
submit a notification of
ownership change form
available from your
implementing agency.
You must notify your
implementing agency (page
23).
You must report suspected
releases to your implementing
agency (page 29).
You must report follow-up
actions you plan or have taken
to correct the damage caused
by your UST (page 30^
Within 30 days after you acquire
an UST
At least 30 days before switching
to certain biofuels or other
substances identified by your
implementing agency
Within 24 hours (or another period
specified by your implementing
agency)
You must notify your
implementing agency (page 32).
Within 20 days (or another period
specified by your implementing
agency)
At least 30 days before you
permanently close your UST
Check with your implementing agency for additional requirements not noted above.
Musts For USTs
November 2015
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What Are Your Spill And
Overfill Prevention
Requirements?
UPDATED
UPDATED
What you must do for spill prevention:
• Your USTs must have spill prevention equipment
(commonly called spill buckets or catchment basins)
to contain drips and small spills that can occur when
the delivery hose is disconnected from the fill pipe.
• You must test your spill prevention equipment at
least every three years for liquid tightness or use
a double-walled spill bucket with periodic
interstitial monitoring. The test must be
conducted according to a code of practice or
manufacturer's instructions.
• No later than October 13, 2018, you must begin
inspecting your spill prevention equipment at
least every 30 days (or before each delivery if you
receive deliveries less frequently than every 30
days). See page 21 for more information about
what you must check during your walkthrough
inspections.
• You and your delivery person must follow correct
filling practices.
Many releases at UST sites come from spills. Spills often
occur at the fill pipe when the delivery truck's hose is
disconnected. Although these spills are usually small,
repeated small releases can cause big environmental
problems.
What Are Spill Buckets?
Spill buckets are also called spill containment manholes or
catchment basins. Basically, a spill bucket is a contained
area around the fill pipe.
To protect against spills, the spill bucket should be large
enough to contain what may spill when the delivery hose is
uncoupled from the fill pipe. Spill buckets range in size
from those capable of holding only a few gallons to those
that are much larger - the larger the spill bucket, the more
spill protection it provides.
Musts For USTs
November 2015
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You should try to keep water out of spill buckets. Some spill
buckets can collect water and sediment, along with spilled product,
making draining this mixture into the tank unwise. If this happens,
you may pump out the spill bucket and dispose of the liquid
properly. If the liquid contains fuel or chemicals, it could be
considered a hazardous waste. Contact your implementing agency
responsible for hazardous waste for information on testing and
handling requirements.
Your equipment supplier can
help you choose the size and
type of spill bucket that
meets yo ur n eeds.
UPDATED
What you must do for overfill prevention:
• Your UST must have overfill prevention. Automatic
shutoff devices, overfill alarms, and ball float valves are
the three types of overfill prevention devices, which are
described below.
• You must inspect your overfill prevention equipment at
least once every three years to ensure it will function
properly to prevent overfills. The inspection must be
conducted according to a code of practice or
manufacturer's instructions.
• You and your delivery person must follow correct filling
practices.
Overfills usually release much larger volumes than spills. When a
tank is overfilled, large volumes can be released at the fill pipe and
at other areas of the UST system, such as loose fittings on the top
of the tank, vapor recovery ports, a loose vent pipe, or other tank
top openings.
You can solve overfill problems by:
• Making sure there is enough room in the tank for the
delivery before the delivery is made;
• Watching the entire delivery to prevent overfilling or
spilling; and
• Using overfill prevention devices.
Note: If you receive pumped deliveries, which means fuel is
delivered under pressure, you must make sure your overfill
prevention device works properly with pumped deliveries. Also,
remember that overfill prevention devices are effective only when
combined with careful filling practices.
What Are Automatic Shutoff Devices?
An automatic shutoff device installed in an UST's fill pipe slows
down and then stops delivery no later than when the product
reaches 95 percent capacity or before the fittings on top of the tank
are exposed to product. This device - sometimes called a flapper
Musts For USTs
November 2015
To work properly, all overfill
devices must be installed
correctly at the proper
distance below the tank top
as specified by the
manufacturer.
If an UST never receives
more than 25 gallons at a
time, the UST does not have
to meet the overfill
prevention requirements.
Many small used oil tanks
fall in this category.
-------
valve - has one or two valves that are operated by a float
mechanism.
UPDATED
Some automatic shutoff devices work in two stages. The first
stage drastically reduces the flow of product to alert the delivery
person that the tank is nearly full. The delivery person can then
close the delivery valve and still have room in the tank for the
product left in the delivery hose.
If the delivery person does not pay attention and the liquid level
rises higher, the valve closes completely and no more liquid can be
delivered into the tank, leaving the delivery person with a delivery
hose full of product.
What Are Overfill Alarms?
Overfill alarms use probes installed in the tank to activate an alarm
no later than when the tank is either 90 percent full or within 1
minute of being overfilled. Either way, the alarm should provide
enough time for the delivery person to close the truck's shutoff
valve before an overfill happens. Alarms must be located where
the delivery person can see or hear them easily. Overfill alarms
are often part of automatic tank gauging systems.
Overfill alarms work only if they alert the delivery person at the
right time and the delivery person responds quickly. Remember to
put the alarm on an electrical circuit that is active all the time so
that the alarm will always work. Many deliveries are made at
night when the facility is closed. You do not want to turn off your
alarm when you turn off the lights.
What Are Ball Float Valves?
In addition to the two types of overfill prevention described above,
ball float valves may be used on tanks installed on or before
October 13, 2015 as long as the ball float valve continues to
operate properly. If the ball float valve must be replaced, owners
and operators must use either an automatic shutoff device or
overfill alarm. Ball float valves may not be used when overfill
prevention is installed or replaced after October 13, 2015.
Flow restrictors in vent lines, also called ball float valves, are
placed at the bottom of the vent line several inches below the top
of the UST. The ball floats on the product and rises with product
level during delivery until it restricts vapor flowing out the vent
line before the tank is full. Ball float valves must begin restricting
flow no later than when the tank reaches 90 percent of its capacity,
or 30 minutes before overfilling. If all tank fittings are tight, the
ball float valve can create enough back pressure to restrict product
flow into the tank - this can notify the delivery person to close the
truck's shutoff valve. However, if the UST has loose fittings,
Musts For USTs
November 2015
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UPDATED
sufficient back pressure may not develop and could result in an
overfill.
Note: Manufacturers do not recommend using ball float valves
with suction piping, pressurized delivery, or coaxial Stage I vapor
recovery.
You must conduct your first ball float valve inspection no later
than October 13, 2018. If the ball float valve is not operating
properly and cannot be repaired, the overfill device must be
replaced with either an automatic shutoff device or overfill
alarm.
What Are Your Responsibilities For Correct Filling
Practices?
Human error causes most spills. You can avoid these mistakes by
following correct tank filling practices. For example, you must
make sure there is room in the UST for the delivery, and the
delivery person must watch the delivery at all times. For this
reason, the federal UST regulation requires that you follow correct
filling practices.
As an owner or operator, you are responsible for ensuring that
releases due to spilling or overfilling do not occur during fuel
delivery. As part of this responsibility, you must:
• Ensure the amount of product to be delivered will fit into
the available empty space in the tank; and
• Ensure the transfer operation is monitored constantly to
prevent overfilling and spilling.
What To Do Before Your USTs Are Filled
• Post clear signs that alert the delivery person to the overfill
devices and alarms in use at your facility.
• Make and record accurate readings for product and water in
the tank before fuel delivery.
• Order only the quantity of fuel that will fit into 90 percent
of the tank.
• The formula for determining the maximum amount of fuel
to order is:
(Tank capacity in gallons x 90%) - Fuel currently in tank
= Maximum amount of fuel to order
o Example: (10,000 gal. x 0.9) - 2,000 gal. =
7,000 gal. maximum amount to order
• Ensure the delivery person knows the type of overfill
device present at the tank and what actions to perform if it
activates.
• Review and understand the spill response procedures.
If you and your delivery
person follow correct filling
practices, nearly all spills
and overfills can be
prevented.
Spill bucket
Musts For USTs
November 2015
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• Verify that your spill bucket is empty, clean, and will
contain spills.
What To Do While Your USTs Are Being Filled
• Keep fill ports locked until the delivery person requests
access.
• Keep an accurate tank capacity chart available for the
delivery person.
• The delivery person makes all hook-ups.
• The person responsible for monitoring the delivery should
remain attentive and observe the entire fuel delivery; be
prepared to stop the flow of fuel from the truck to the UST
at any time; and respond to any unusual condition, leak, or
spill that may occur during delivery.
• Keep response supplies readily available for use in case a
spill or overfill occurs.
• Provide safety barriers around the fueling zone.
• Make sure there is adequate lighting around the fueling
zone.
What To Do After Your USTs Are Filled
• Following complete delivery, the delivery person is
responsible for disconnecting all hook-ups.
• Return spill response kit and safety barriers to proper
storage locations.
• Make and record accurate readings for product and water in
the tank after fuel delivery.
• Verify the amount of fuel received.
• Make sure fill ports are properly secured.
• Ensure the spill bucket is free of product and clean up any
small spills.
Musts For USTs
November 2015
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The federal UST regulation requires corrosion
protection to help prevent your USTs from
releasing product into the environment.
Tanks and piping entirely made of non-
corrodible material, such as fiberglass, do not
need cathodic protection.
What Are Cathodic Protection
Methods?
Sacrificial Anode System: Sacrificial anodes are
buried and attached to UST components for
corrosion protection. Anodes are pieces of
metal that are more electrically active than steel,
and thus they suffer the destructive effects of
corrosion rather than the steel they are attached
to.
Impressed Current System: An impressed
current system uses a rectifier to provide direct
current through anodes to the tank or piping to
achieve corrosion protection. The steel is
protected because the current going to the steel
overcomes the corrosion-causing current
flowing away from it. The cathodic protection
rectifier must always be on and operating to
protect your UST system from corrosion.
You must have a qualified cathodic protection
tester periodically test your cathodic protection
system to make sure the cathodic protection
system is protecting the UST system. If you
have an impressed current system, you must
inspect it at least once every 60 days to make
sure the impressed current rectifier is running
properly.
Never turn off your rectifier. If your rectifier is
off, your UST system is not being protected
from corrosion.
Musts For USTs
November 2015
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Corrosion Protection For Steel USTs Installed On Or
Before December 22,1988
Steel tanks installed on or before December 22, 1988, must either
have been assessed and upgraded with corrosion protection using
one of the following three methods or meet the corrosion
protection requirements for tanks installed after December 22,
1988:
Added cathodic protection. The cathodic protection system
must have been tested by a qualified cathodic protection
tester within six months of installation and at least once
every three years thereafter. You must keep the results of
the last two tests to prove that the cathodic protection is
working. In addition, if you have an impressed current
cathodic protection system, you must inspect it at least once
every 60 days to verify that the system is operating. Keep
results of your last three inspections to prove that the
impressed current system is operating properly.
Added interior lining to the tank. The interior of a tank
could have been lined with a thick layer of noncorrodible
material (see www.epa.gov/ust/underground-storage-tanks-
usts-laws-regulations#code for industry codes). Tanks
using only an interior lining for corrosion protection must
have passed an internal lining inspection within 10 years of
installation of the internal lining and every five years after
that to make sure that the lining is sound. Keep records of
the inspection results.
Combined cathodic protection and interior lining. You
could have added both cathodic protection and interior
lining. This combined method does not require you to have
the interior lining periodically inspected if your tank was
assessed and found to be structurally sound and free of
corrosion holes when you added cathodic protection. You
still must have the cathodic protection system periodically
tested and inspected and keep records as explained in the
first bullet point above.
Note that field installed
cathodic protection must be
designed by a corrosion
expert.
Only tanks that were proven
to be structurally sound
could have been lined.
Corrosion Protection For Metal Piping Installed On Or
Before December 22,1988
Metal piping installed on or before December 22, 1988 must have
cathodic protection. In addition, owners and operators must test,
inspect, and keep records as described above for tank cathodic
protection.
Musts For USTs
November 2015
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Corrosion Protection For Steel Tanks And Piping
Installed After December 22,1988
Your tanks and piping must meet one of the following to be
protected from corrosion:
• Tank and piping are completely made of a noncorrodible
material, such as fiberglass.
• Tank is made of steel and completely isolated from contact
with the surrounding soil by being enclosed or jacketed in
noncorrodible material. This option does not apply to
piping.
• Tank and piping are made of steel having a corrosion-
resistant coating and having cathodic protection, such as an
sti-P3® tank with appropriate piping. A corrosion-resistant
coating electrically isolates the coated metal from the
surrounding environment to help protect against corrosion.
An asphaltic coating does not qualify as a corrosion-
resistant coating. Galvanized steel does not meet the
corrosion protection requirements. You must have cathodic
protection systems tested and inspected and keep records as
explained in the first bullet point on the previous page.
Musts For USTs
November 2015
-------
What Are Your Release
Detection Requirements?
UPDATED
UPDATED
UPDATED
You must provide your UST system with release detection
that allows you to meet the following basic requirements:
• You can detect a release from any portion of the tank
or its piping that routinely contains product;
• Your release detection is installed and calibrated
according to the manufacturer's instructions; and
• Your release detection meets the performance
requirements described in the federal UST
regulation. See 40 CFR 280.43 and 280.44.
For more information about release detection methods and
requirements please see EPA's Release Detection For
Underground Storage Tanks And Piping: Straight Talk On
Tanks.
No later than October 13, 2018, you must perform your
first annual release detection equipment test to make
sure components such as probes, sensors, and automatic
line leak detectors are working properly. You must keep
records of these tests for three years.
No later than October 13, 2018, you must begin
conducting walkthrough inspections that check your
release detection equipment every 30 days. In addition,
you must check your hand-held release detection
equipment annually. You must keep records of the
walkthrough inspection for one year. See pages 21-22
for more information about what you must do on your
walkthrough inspections.
Piping Replacements: After April 11, 2016, if you repair
50 percent or more of your piping in a single piping run,
that piping must be replaced. This means you must
remove the entire piping run and install secondarily
contained piping. You must also use interstitial monitoring
for release detection. For pressurized piping, a piping run is
all piping that connects the submersible turbine pump to all
of the dispensers fed by that pump. For suction piping, a
piping run is the piping that runs between the tank and the
suction pump.
Musts For USTs
November 2015
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UPDATED
USTs storing fuel for emergency power generators must begin
meeting the release detection requirements. For emergency
generator UST systems installed on or before October 13, 2015,
you must begin meeting the release detection requirements by
October 13, 2018 using one of the methods described below.
For emergency generator UST systems installed after October
13, 2015 but on or before April 11, 2016, you must begin
meeting the release detection requirements at installation by
using one of the methods described below. Emergency
generator UST systems installed after April 11, 2016 must be
secondarily contained and use interstitial monitoring upon
installation.
Release detection requirements for tanks installed on
or before April 11, 2016:
Below we list the monthly monitoring methods you may use to
meet the federal release detection requirements. As temporary
methods, you may instead use inventory control combined with
tank tightness testing, or manual tank gauging combined with tank
tightness testing, as described on pages 17-18. See additional
release detection requirements for piping on pages 18-20.
This booklet sometimes uses
the term monthly as it
applies to release detection
monitoring frequency. This
term means release
detection monitoring must
occur at least once every 30
days.
Inventory Control or
Manual Tank Gauging
Vapor
Monitoring
Well
Inventory Probe for
Automatic Tank Gauging,
Continuous In -Tank Leak Detection,
and Statistical Inventory Reconciliation
Secondary
Containment
with Interstitial
Monitor
Monthly Monitoring Methods
• Interstitial monitoring: This method detects leaks in the
space between the primary wall and a secondary barrier of
the tank. The federal UST regulation describes general
performance requirements for interstitial monitoring with
double-walled USTs, USTs fitted with internal liners, and
USTs using secondary barriers.
Release detection for USTs
installed on or before
April 11,2016 may consist of
one or a combination of the
release detection methods
listed on pages 16-18.
Musts For USTs
November 2015
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• Automatic tank gauging (ATG) systems: This method uses
automated processes to monitor product level and perform
inventory control.
• Continuous in-tank leak detection (CITLD): This method
encompasses all statistically based methods where the
system incrementally gathers measurements on an
uninterrupted or nearly uninterrupted basis to determine a
tank's release status. This method typically uses sensors
permanently installed in the tank to obtain inventory
measurements, combined with a microprocessor in the
ATG system or other control console that processes the
data.
• Statistical inventory reconciliation (SIR): For this method,
typically a trained professional uses sophisticated computer
software to conduct a statistical analysis of inventory,
delivery, and dispensing data, which you must supply
regularly.
• Groundwater monitoring: This method monitors the
groundwater table near an UST for the presence of released
free product on the water table. Monitoring wells near the
UST are checked frequently to see if petroleum can be
detected. The federal UST regulation describes several
requirements for using this method. For example, you
cannot use this method if the water table is more than 20
feet below the surface of the ground.
• Vapor monitoring: This method samples for petroleum
hydrocarbon vapors (sometimes called passive monitoring)
or tracer compound vapors (sometimes called active
monitoring) in the soil surrounding the UST. Released
petroleum produces vapors that can be detected in the soil.
The federal UST regulation describes several requirements
for using vapor monitoring. For example, this method
requires that the stored substance can migrate through a
porous backfill material so that it can be detected within 30
days. A site assessmnent must be conducted prior to using
the method to ensure site conditions meet the requirements.
• Other methods: Methods that can detect a 0.2 gallon per
hour leak rate or 150 gallons within a month that meet
performance standards of a 95 percent probability of
detection and no more than a 5 percent probability of false
alarm may also be used. In addition, other methods
approved by your implementing agency that can be shown
to work as effectively as the methods described above for
release detection may be used.
Alternate Release Detection Method Allowed For Up To 10
Years After Installation
For USTs installed on or before April 11, 2016, instead of using
one of the monthly monitoring methods noted above, you can
combine inventory control with tank tightness testing, but only for
Musts For USTs
November 2015
Starting on October 13,
2018, if you use vapor
monitoring or groundwater
monitoring, you must keep
records of a site assessment
for as long as you use these
methods showing that the
monitoring system is set up
properly. If you do not have
a site assessment for your
vapor monitoring or
groundwater monitoring,
you will need to have one
conducted. Site assessments
conducted after October 13,
2015 have to be signed by a
licensed professional.
-------
10 years after you installed the tank. Inventory control involves
taking daily measurements of tank contents and recording
deliveries and amount pumped. Based on daily and monthly
calculations, you can discover if your tank may be leaking.
Tank tightness testing usually requires taking the UST out of
service while changes in level or volume over time are measured.
Your UST will need a tank tightness test every five years. After 10
years, you must use one of the monthly monitoring methods.
The success of this temporary combined method depends on your
performing inventory control correctly. See EPA's booklet, Doing
Inventory Control Right, which clearly explains how to do
inventory control with simple step-by-step directions
www. epa.gov/ust/doing-inventory-control-right-underground-
storage-tanks. The booklet includes example forms for recording
inventory data.
Additional Release Detection Method For Small Tanks
Tanks of 2,000 gallons capacity or less that were installed on or
before April 11, 2016 may be able to use manual tank gauging as a
release detection method, either by itself or in combination with
tank tightness testing. This method involves keeping the tank
undisturbed for at least 36-58 hours each week, during which the
tank's contents are measured, twice at the beginning and twice at
the end of the test period. Manual tank gauging can be used
without tightness testing for tanks with a capacity of 550 gallons or
less and for tanks with capacities between 551 gallons and 1,000
gallons with a diameter of either 48 inches or 64 inches.
All other tanks using manual tank gauging must combine the
method with tank tightness testing. These tanks may only use the
combined method for up to 10 years after installation.
See EPA's booklet, Manual Tank Gauging For Small
Underground Storage Tanks, which explains how to do manual
tank gauging with simple step-by-step directions
www.epa.gov/ust/manual-tank-gauging-small-underground-
storage-tanks. The booklet includes standard forms for recording
inventory data.
*EPA Doing Inventory Control
Right
For Underground Storage Tanks
Manual Tank Gauging
For Small Underground
Storage Tanks
Release detection requirements for piping installed on
or before April 11, 2016:
Pressurized piping installed on or before April 11, 2016 must meet
these requirements:
Musts For USTs
November 2015
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• The piping must have an automatic line leak detector that
will stop or restrict flow, or activate an alarm when a
release is detected.
• You must either conduct an annual tightness test of the
piping or use one of these monthly methods that apply to
piping: interstitial monitoring, vapor monitoring,
groundwater monitoring, statistical inventory
reconciliation, continuous in-tank leak detection, or other
approved monthly methods.
If your UST has suction piping, your release detection
requirements will depend on which type of suction piping you
have. No release detection is required if the suction piping system
has:
• Below-grade piping that operates under atmospheric
pressure;
• Enough slope so that the product in the pipe can drain back
into the tank when suction is released; and
• Only one check valve, which is as close as possible beneath
the pump in the dispensing unit.
If suction piping is to be considered exempt based on these design
elements, there must be some way to verify that the piping was
installed according to these criteria.
Suction piping installed on or before April 11, 2016 that does not
meet all of the design criteria noted above must have release
detection (either monthly monitoring using one of the monthly
methods noted above for use on pressurized piping or tightness
testing of the piping every three years).
Release detection requirements for tanks and piping
installed after April 11, 2016:
Tanks and piping installed after April 11, 2016 must have
secondary containment and interstitial monitoring. Interstitial
monitoring detects leaks in the space between the primary wall of
the tank or pipe and a secondary barrier. The regulation describes
general performance requirements for interstitial monitoring with
double-walled USTs, USTs fitted with internal liners, and USTs
using secondary barriers.
Additional Release Detection For Piping
Pressurized piping must have an automatic line leak detector that
will stop or restrict flow, or activate an alarm when a release is
detected.
Musts For USTs
November 2015
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UPDATED
If your UST has suction piping, your release detection
requirements will depend on which type of suction piping you
have. No release detection is required if the suction piping system
meets the requirements on page 19.
If suction piping is to be considered exempt based on these design
elements, there must be some way to verify that the piping was
actually installed according to these criteria.
Suction piping installed after April 11, 2016 that does not meet all
of the design criteria listed on page 19 must use interstitial
monitoring.
What you must do for containment sumps:
No later than October 13, 2018, you must perform your first
three year containment sump test for liquid tightness on sumps
used for interstitial monitoring of piping or use double-walled
containment sumps with periodic interstitial monitoring of the
space between the two walls of the sump.
Musts For USTs
November 2015
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UPDATED
No later than October 13, 2018, you must begin
conducting periodic walkthrough inspections to make
sure your equipment is working properly and catch
problems early. Walkthrough inspections must cover:
Every 30 days:
• Spill prevention equipment
o Visually check for damage.
o Remove liquid or debris.
o Check for and remove obstructions in the
fill pipe.
o Check the fill cap to make sure it is
securely on the fill pipe.
o For double-walled spill prevention
equipment with interstitial monitoring,
check for a leak in the interstitial area.
o For tanks that receive deliveries less
frequently than every 30 days, the spill
prevention equipment inspection may be
conducted before each delivery.
• Release detection equipment
o Check to make sure the release detection
equipment is operating with no alarms or
other unusual operating conditions
present.
o Ensure release detection records are
reviewed and current.
o Owners and operators who monitor their
release detection systems remotely may
check the release detection equipment and
records remotely, as long as the release
detection systems at the locations are
determined to be in communication with
remote monitoring equipment.
Musts For USTs
November 2015
-------
Annually:
• Containment sumps
o Visually check for damage, leaks to the
containment area, and releases to the
environment.
o Remove liquid from containment sumps.
o Remove debris.
o For double-walled sumps with interstitial
monitoring, check for leaks in the interstitial
area.
• Hand-held release detection equipment
o Check devices such as tank gauge sticks or
groundwater bailers for operability and
serviceability.
You can also conduct walkthrough inspections according to a
standard code of practice developed by a nationally-recognized
association or independent testing laboratory or according to
requirements developed by your implementing agency, if the
code of practice checks equipment in a manner comparable to
the requirements above.
You may perform walkthrough inspections yourself or have a
third party conduct them.
You must keep records of your walkthrough inspections for
one year.
Musts For USTs
November 2015
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Compatibility With
Biofuels And Other
Regulated Substances
UPDATED
Since 1988, EPA has required UST systems to be
compatible with the substance stored in them. As newer
fuels with different chemical properties enter the
marketplace, it is even more important for you to make sure
your UST system is compatible with the fuel stored in your
system. Compatibility is the ability of two or more
substances (in this case, your UST system and the regulated
substance stored) to maintain their respective physical and
chemical properties when in contact with one another.
Compatibility is required for the design life of the UST
system and under conditions likely to be encountered by the
UST.
In addition to the original compatibility requirement,
you must meet these requirements.
You must notify your implementing agency at least 30
days before switching to any of these products:
• Regulated substances containing greater than 10
percent ethanol.
• Regulated substances containing greater than 20
percent biodiesel.
• Any other regulated substance identified by your
implementing agency.
In addition, you must meet specific requirements when
storing these fuels. You may either demonstrate you are
using equipment or components approved for use with
the regulated substance stored, or use another option
determined by your implementing agency to be no less
protective of human health and the environment than
the compatibility demonstration options listed below.
Ways to demonstrate compatibility include having the
following documentation:
• Certification or listing of the equipment or
component by a nationally recognized,
independent testing laboratory for use with the
regulated substance stored; or
Musts For USTs
November 2015
-------
• Written statement from the manufacturer affirming the
equipment or component is compatible with the
regulated substance stored.
As long as you store regulated substances containing greater
than 10 percent ethanol, greater than 20 percent biodiesel, or
any other regulated substance identified by your implementing
agency, you must keep records demonstrating compliance with
the compatibility requirement.
Musts For USTs
November 2015
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UPDATED
No later than October 13, 2018, you must have
designated Class A, B, and C operators and trained
them on their UST responsibilities. There are three
classes of operators, each with different responsibilities:
• Class A operator is the person who has primary
responsibility to operate and maintain the UST
system according to the UST regulation. Class A
operator training provides a general knowledge
of the UST regulation.
• Class B operator is the person who has day-to-
day responsibility for implementing the UST
regulation. Class B operator training provides a
more in-depth understanding of operation and
maintenance aspects of UST systems.
• Class C operator is any person responsible for the
immediate response to a problem at an UST
facility, such as a gas station attendant. Class C
operator training must cover how to respond to
an alarm or emergency.
A single individual may be designated as more than one
class of operator, as long as that individual is trained in
all responsibilities for each class of operator designated.
Operators may need to be retrained if the UST system is
not in compliance.
You must keep a list of currently designated operators
trained for each facility and proof of training or
retraining for each operator. You may keep the records
off site.
Most states already have their own operator training
program. Contact your implementing agency for
information specific to the state where your USTs are
located.
www.epa.gov/ust
underground-storage-tank
ust-contacts#states
Musts For USTs
November 2015
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UPDATED
UPDATED
How Do You Repair UST
Systems?
Can Leaking Tanks Be Repaired?
You can repair a tank if the person who repairs the tank
carefully follows standard industry codes that establish the
correct way to conduct repairs. See
www.epa.gov/ust/underground-storage-tanks-usts-laws-
regulations#code for industry codes and standards.
Within 30 days of the repair, you must prove that the tank is
repaired by:
• Having the tank inspected internally or tightness
tested following standard industry codes; or
• Using one of the monthly release detection
monitoring methods on pages 16-17; or
• Using other methods approved by your
implementing agency.
Within 30 days after repairs to secondary containment
areas of tanks, you must have the secondary
containment tested for tightness.
Within 30 days after repairs to spill or overfill
prevention equipment, you must test or inspect the
repaired spill or overfill prevention equipment, as
appropriate, to ensure it is operating properly.
Within six months of repair, USTs with cathodic protection
must be tested to show that the cathodic protection is
working properly.
Can Leaking Piping Be Repaired?
Damaged metal piping cannot be repaired and must be
replaced. Loose fittings can be tightened, and in some cases
that may solve the leaks.
Piping made of fiberglass-reinforced plastic can be repaired,
but only according to the manufacturer's instructions or
national codes of practice. Within 30 days of the repair,
piping must be tested in the same ways noted above for
testing tank repairs, except for internal inspection.
Musts For USTs
November 2015
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UPDATED
UPDATED
Within 30 days after repairs to secondary containment areas of
piping used for interstitial monitoring and to containment
sumps used for interstitial monitoring of piping, you must have
the secondary containment tested for tightness.
After April 11, 2016, when 50 percent or more of the piping
connected to a single tank is removed and replaced, the entire
piping run must be replaced with piping that has secondary
containment and interstitial monitoring.
What Records Must You Keep?
You must keep records for each repair until the UST is
permanently closed or undergoes a change-in-service.
Musts For USTs
November 2015
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Financial Responsibility
You must maintain documentation showing you have the
financial resources to clean up your UST site if a release
occurs, correct environmental damage, and compensate
third parties for injury to their properties or themselves. The
amount of coverage depends on the type and size of your
business, as summarized in the chart below.
Group Of UST
Owners And
Oerators
Petroleum marketers
owners and operators
who handle more than
10,000 gallons per
month
All others
Per
Occurrence
Coverage
$1 million
$500,000
$1 million if you
have 100 or fewer
USTs
$2 million
if you have more
than 100 USTs
You have several options to demonstrate financial
responsibility. These include:
• Obtain insurance coverage from an insurer or a risk
retention group;
• Use a financial test to demonstrate self-insurance;
obtain corporate 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 also have four additional options
tailored to their specific characteristics: a bond rating test, a
financial test, a guarantee, and a dedicated fund.
EPA's booklet, Dollars And Sense, briefly summarizes the
financial responsibility requirements.
www.epa.gov/ust/dollars-
and-sense-financial-
responsibilitv-requirements-
underground-storage-tanks
Musts For USTs
November 2015
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UPDATED
What Must You Do About
UST Releases?
Warning signals indicate that your UST may be leaking and
creating problems for the environment and your business.
You can minimize these problems by paying careful
attention to early warning signals and reacting quickly
before major problems develop.
You should suspect a release when you observe these
warning signals:
• Unusual operating conditions. Check first to see if
the problem results from equipment failure that can
be repaired. Remember to remove any liquid not
used for interstitial monitoring from the interstitial
space of secondarily contained systems.
• Results from release detection monitoring and
testing that indicate a release. What at first appears
to be a release may be the result of faulty equipment
that is part of your UST system or its release
detection. Check this equipment carefully for
failures.
If you investigate an unusual operating condition or release
detection alarm and determine a release has not occurred,
you do not need to report a suspected release as long as you
immediately fix the problem. Otherwise, you need to call
your implementing agency and report the suspected release.
Then find out quickly if the suspected release is an actual
release. Use these investigative steps:
• Conduct tightness testing or interstitial integrity
testing of the entire UST system.
• Check the site for additional information on the
presence and source of contamination.
If the system tests and site checks confirm that a release has
occurred, follow the actions for responding to confirmed
releases described below.
You must also respond quickly to any evidence of released
petroleum that appears at or near your site. For example,
neighbors might tell you they smell petroleum vapors in
their basements or taste petroleum in their drinking water. If
evidence of this type is discovered, you must report this
Musts For USTs
November 2015
-------
discovery immediately to your implementing agency and take the
investigative steps and follow-up actions noted above.
Your action to confirmed releases comes in two stages: short term
and long term.
Short-Term Actions
• Take immediate action to stop and contain the release.
• Report the release to your implementing agency within 24
hours or the time frame required by your implementing
agency. However, petroleum spills and overfills of less
than 25 gallons do not have to be reported if you
immediately contain and clean up these releases.
• Make sure the release poses no immediate hazard to human
health and safety by removing explosive vapors and fire
hazards. Your fire department should be able to help or
advise you with this task. You must also make sure you
handle contaminated soil properly so that it poses no
hazard, for example, from vapors or direct contact.
• If necessary, remove petroleum from the UST system to
prevent further release into the environment.
• Find out how far the petroleum has moved and begin to
recover the released petroleum, such as product floating on
the water table. Report your progress and any information
you collect to your implementing agency no later than 20
days after confirming a release.
• Investigate to determine if the release has damaged or
might damage the environment. This investigation must
determine the extent of contamination both in soils and
groundwater. You must report to your implementing
agency what you have learned from an investigation of
your site according to the schedule established by your
implementing agency. At the same time, you must also
submit a report explaining how you plan to clean up the
site. Additional site studies may be required.
Long-Term Actions
Based on the information you provide, your implementing agency
will decide if you must take further action at your site. You may
need to take two more actions:
• Develop and submit a corrective action plan that shows
how you will meet requirements established for your site
by your implementing agency.
• Make sure you implement the actions approved by your
implementing agency for your site.
Contact your implementing
agency for guidance on
doing site assessments and
corrective action.
Musts For USTs
November 2015
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How Do You Close USTs?
You may close your UST temporarily or permanently.
UPDATED
UPDATED
UPDATED
UPDATED
Closing Temporarily
You may temporarily close your UST by following these
requirements:
• Continue to maintain and monitor corrosion
protection systems
• Continue to maintain financial responsibility
• No later than October 13, 2018, your operators
must be trained
• If your temporarily closed UST is not empty, you
must also:
o Continue to monitor for leaks by performing
release detection.
o Begin performing monthly walkthrough
inspections for your release detection no
later than October 13, 2018.
o Begin performing annual inspections and
tests of release detection equipment no
later than October 13, 2018.
o Begin performing three year containment
sump testing if using the containment
sump for interstitial monitoring of the
piping no later than October 13, 2018.
• If a release is discovered, quickly stop the release,
notify your implementing agency, and take
appropriate action to clean up the site.
• If the UST remains temporarily closed for more than
three months, leave vent lines open, but cap and
secure all other lines, pumps, manways, and
ancillary equipment.
USTs in temporary closure are not required to meet the
following requirements:
• Spill prevention equipment and periodic testing.
• Overfill prevention equipment and periodic
inspections.
• Empty USTs do not require:
Musts For USTs
November 2015
-------
o Release detection.
o Annual release detection testing and inspections.
o Monthly walkthrough inspections.
o Three year containment sump testing.
An UST is considered empty if no more than one inch of residue is
present or not more than 0.3 percent by weight of the total capacity
of the UST system remains in the system.
After 12 months of temporary closure, you must permanently close
your UST if the tank does not meet the corrosion protection
requirements. You can indefinitely keep your UST closed
temporarily, if it meets the requirements for new or upgraded
USTs, except that spill and overfill requirements do not have to be
met, and you meet the requirements above for temporarily closed
USTs.
USTs in temporary closure
do not need spill or overfill
prevention equipment
because they should not be
receiving fuel deliveries.
UPDATED
Closing Permanently
If you decide for any reason to close your UST permanently,
follow these requirements for permanent closure:
• You must notify your implementing agency 30 days before
you permanently close your UST.
• You must determine if contamination from your UST is
present in the surrounding environment. If there is
contamination, you will have to take the actions described
on pages 29-30.
• You can either remove the UST from the ground or leave it
in the ground. In both cases, the tank must be emptied and
cleaned by removing all liquids, dangerous vapor levels,
and accumulated sludge. These potentially very hazardous
actions need to be carried out carefully by following
standard safety practices. See www.epa.gov/ust/resources-
owners-and-operators#closing for a safe closure standard.
If you leave the UST in the ground, you must also either fill
it with a harmless, chemically inactive solid, like sand or
cement, or close it in place in a manner approved by
your implementing agency. Your implementing agency
can help you decide how best to close your UST so that it
meets local requirements for closure.
People can be killed or
injured while closing or
removing tanks. Use safe
www. epa.gov/ust/
resources-owners-and-
operators#closing
led professionals should
close or remove USTs.
Musts For USTs
November 2015
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UPDATED
UPDATED
UPDATED
UPDATED
UPDATED
UPDATED
What Records Must You
Keep?
You must keep records that you can provide to an inspector during an inspection and prove your
facility meets certain requirements. Check with your implementing agency to determine if there
are additional records you must keep.
You Must Keep These Records:
Testing and inspection records for spill and overfill prevention equipment and
containment sumps used for interstitial monitoring of piping (beginning on
October 13, 2018)
Records of your 60-day inspections for your impressed current corrosion
protection system
Records of cathodic protection tests for your corrosion protection system
Release Detection
30-day monitoring results
Tightness test results
Records for your annual release detection equipment operability tests
(beginning on October 13, 2018)
Copies of performance claims provided by release detection equipment manufacturers
or equipment installers
Records of maintenance, repair, and calibration of on-site release detection equipment
If you use vapor monitoring or groundwater monitoring, records of a site
assessment showing that the monitoring system is set up properly (beginning
on October 13, 2018)
Records showing you performed periodic walkthrough inspections (beginning on
October 13, 201 8)
Compatibility
If you store certain biofuels or other substances identified by your implementing
agency, records demonstrating compliance with the compatibility requirement
Records for each designated Class A, B, and C operator showing they have been
trained (beginning on October 13, 2018)
Records showing that a repaired LIST system was properly repaired
Records that document you have financial responsibility, as explained in EPA's
booklet, Dollars And Sense www.epa.aov/ust/dollars-and-sense-financial-
resDonsibilitv-reauirements-underaround-storaqe-tanks
Records of the site assessment results required for permanent closure
For This Long:
Three years
Three most recent
inspections
Two most recent tests
One year
Until the next test
Three years
Five years
One year after servicing
is completed
For as long as vapor
monitoring or
groundwater
monitoring is used
One year
For as long as the UST
system stores the
regulated substance
For as long as the
operator is designated
at the facility
Until the UST system is
permanently closed or
undergoes a change-in-
service
Until the UST system is
permanently closed or
undergoes a change-in-
service
For at least three years
after closing an UST
Musts For USTs
November 2015
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For Hazardous Substance
USTs Only
Section 101(14) of the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980
(CERCLA) designated hundreds of substances as hazardous.
The federal UST regulation applies to the same hazardous
substances designated in CERCLA, except for those listed
as hazardous wastes. These hazardous wastes are already
regulated under Subtitle C of the Resource Conservation
and Recovery Act and are not covered by the federal UST
regulation. See 40 CFR parts 260-270 for hazardous waste
regulations. Information on CERCLA hazardous substances
is available from EPA's Superfund Information Center at
800-424-9346.
What Requirements Apply To Hazardous
Substance USTs?
Hazardous substance USTs must meet the same
requirements described earlier concerning correct
installation; spill, overfill and corrosion protection;
corrective action; and closure. See pages 3-27 and 29-33.
In addition, hazardous substance USTs must have secondary
containment and interstitial monitoring for release detection,
as described below.
Secondary Containment
Hazardous substance USTs must have secondary
containment. A single-walled tank is the first (primary)
containment. Using only primary containment, a leak can
escape into the environment. But by enclosing an UST
within a second wall, leaks can be contained and detected
quickly before harming the environment.
There are several ways to construct secondary containment:
• Placing one tank inside another tank or one pipe
inside another pipe, making them double-walled
systems.
• Placing the UST system inside a concrete vault.
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UPDATED
• Lining the excavation zone around the UST system with a
liner that the hazardous substance cannot penetrate.
Interstitial Monitoring
A hazardous substance UST must have a release detection system
that can indicate the presence of a leak in the confined space
between the first and the second wall. Several devices are
available to monitor this confined interstitial space. Interstitial
means between the walls. The federal UST regulation describes
these various methods and the requirements for their proper use.
For hazardous substance USTs installed on or before October 13,
2015, you could have applied for an exception, called a variance,
from the requirement for secondary containment and interstitial
monitoring. Variances are not available for hazardous
substance USTs installed after October 13, 2015.
What If You Have A Hazardous Substance Release?
You must follow the same short-term and long-term actions for
petroleum releases described on page 30, with two exceptions.
First, you must immediately report hazardous substance spills or
overfills that meet or exceed their reportable quantities to the
National Response Center at 800-424-8802.
Second, you must also report hazardous substance spills or
overfills that meet or exceed reportable quantities to your
implementing agency within 24 hours.
However, if spills or overfills are smaller than their reportable
quantities and are immediately contained and cleaned up, you do
not need to report them. You can get information on reportable
quantities by calling EPA's Superfund Information Center at 800-
424-9346.
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Links For More Informatio.
Government Links
• U.S. Environmental Protection Agency's Office
of Underground Storage Tanks:
www.epa.gov/ust. EPA's UST compliance
assistance: www.epa.gov/ust/resources-owners-
and-operators
• State UST program contact information:
www. epa. gov/ust/underground-storage-tank-ust-
contacts#states
• Tanks Subcommittee of the Association of State
and Territorial Solid Waste Management Officials
(ASTSWMO): www.astswmo.org
• New England Interstate Water Pollution Control
Commission (NEIWPCC): www.neiwpcc.org
Industry Codes And Standards
www.epa.gov/ust/underground-storage-tanks-usts-laws-
regulations#code
Other Organizations To Contact For UST
Information
www. epa. gov/ust/underground-storage-tank-ust-
contacts#other
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United States
Environmental Protection
Agency
United States Environmental Protection Agency
5401P
Washington, DC 20460
EPA 510-K-15-001
November 2015
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