&EPA
United States
Environmental Protection
Agency
UST System Compatibility With Biofuels
EPA 510-K-15-002
November 2015
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
Drogram approval, s
i/ww.epa.gov/ust/state-underground-storage-tank-ust-
programs
IT your uii :
different from those identified in this booklet. To find information about your state's UST
regulation, contact your implementing agency or visit its website. You can find links to state UST
websi'
www.epa.gov/ust/underground-storage-tank-ust-contactsfetates
If your UST _,y_,..^iii_, ui^. ,^u^^. ,,, ^ ....u..^ ™,,.,,^,. Jtut^
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
See EPA's underground storage tank (UST) websiti
www.epa.gov/ust
order, download, or
read documents online. Write to the National Service Center for Environmental Publications
(NSCEP), EPA's publication distributor: NSCEP, PO Box 42419, Cincinnati, OH 45242. Call NSCEP's
toll-free number 800-490-9198. Fax your order to NSCEP 301-604-3408.
Image credits:
MVI Field Services (inspector on cover)
Highland Tank & Manufacturing Company (steel tanks on cover and in headers)
OPW (fill sump on cover)
UST System Compatibility With Biofuels
November 2015
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Contents
What Is This Booklet About? 1
How Do You Meet The Updated Compatibility Requirements? 7
Upgrading Equipment To Meet Compatibility Requirements For Storing Biofuels 11
Resources For More Information About Biofuel Compatibility Determinations 12
Publications About USTs 13
Appendices A-l
Disclaimer
This document provides information about underground storage
tank (UST) system compatibility. 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).
UST System Compatibility With Biofuels
November 2015
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What Is This
Booklet About?
As of 2015, the U.S. Environmental Protection Agency
(EPA) regulates over one-half million underground storage
tank (UST) systems 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.
Two biofuels, primarily ethanol and biodiesel, have
significantly increased their volume share of the total
national vehicle fuel market over the last decade.1 Other
biobased fuels are projected to enter the market soon.
Ensuring compatibility of UST systems with these fuels -
knowing the materials that make up the UST system will
maintain their respective chemical and physical properties
when in contact with the substance they are storing - is
essential. Storing a fuel in an UST system with which it is
not compatible may jeopardize the integrity of the UST
system and cause a release to the environment.2
1 Throughout this document, the term biofuel refers to all substances
listed in the 2015 UST regulation that require additional actions of
owners and operators pertaining to compatibility: gasoline blends
containing greater than 10 percent ethanol; diesel blends containing
greater than 20 percent biodiesel; or any other substance identified by the
implementing agency now or in the future. However, the primary focus
of this booklet is on the ethanol and biodiesel fuel blends in this footnote.
2 All UST systems must be compatible with the regulated substances they
store. The 2015 UST regulation requires additional notification,
demonstration, and record keeping actions of owners wishing to store
biofuels.
UST System Compatibility With Biofuels
November 2015
Releases from USTs can
threaten human health and
the environment,
contaminating both soil and
groundwater. As of 2015,
more than 525,000 UST
releases have been
confirmed.
Ensuring UST systems are
compatible with the
substances they store is
essential to preventing
releases of regulated
substances to the
environment.
About half
of the United States
population uses
groundwater as a source
of drinking water.
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This booklet will help you understand what you need to do in
order to meet the 2015 UST compatibility requirements when
storing biofuels and petroleum-biofuel blends and minimize
the risk of a release from your UST system due to
incompatibility.
Why Is Compatibility Important?
In an UST system, the regulated substances stored must not
interact with the materials comprising the system in any way that
would cause the material to change its performance. USTs contain
many components made of different materials. If any of these
materials are incompatible with the regulated substance stored and
even temporarily lose their manufactured properties such as shape
or flexibility, the UST system may fail to contain the substance.
This could lead to a release to the environment and possibly a
failure to detect the release. Examples of observed incompatibility
between fuels stored and UST materials include equipment or
components such as tanks, piping, or gaskets and seals that have
become brittle, elongated, thinner, or swollen when compared with
their as-installed conditions.
Compatibility In The 1988 UST Regulation
EPA has required UST systems to be compatible with the
substance stored in them since the 1988 UST regulation.
Compatibility is required for as long as the UST system is used to
store regulated substances. From the 1988 UST regulation:
• You must use an UST system made of or lined with
materials compatible with the regulated substance
stored in the UST system.
However, the United States' fuel supply has changed significantly
since 1988 and there has been an exponential growth of the use of
alternative fuels. Biodiesel is commonly blended into diesel and
ethanol into gasoline. The resulting blended fuels stored in USTs
usually contain 20 percent biodiesel (B20) or less or 10 percent
ethanol (E10) or less of the petroleum based fuel volume.
However, in certain percentages petroleum-biofuel blends are more
aggressive toward certain materials used in UST system
construction than the petroleum based fuel without biofuels. In
addition to the compatibility requirement above, the 2015 UST
regulation includes requirements for owners and operators of
certain UST systems to help ensure UST systems are compatible
with biofuels prior to storing them.
Remember, compatibility
with the substance stored is
required for all UST systems.
Equipment incompatible
with the fuel stored could
harden, soften, swell, or
shrink and could lead to
release of fuel to the
environment.
The 2015 UST regulation
clarifies methods for
demonstrating compatibility
for fuels containing greater
than 10 percent ethanol or
greater than 20 percent
biodiesel. However,
implementing agencies may
have different compatibility
requirements for storing
biofuels, so it is important to
contact them before storing
higher blends ofbiofi
Most currently installed UST
systems have at least some
components that may not be
compatible with fuel blends
containing more than 10
percent ethanol or more
than 20 percent biodiesel.
However, components
compatible with higher
blends are now available. If
you choose to upgrade your
UST system, remember to
require that your installer
use compatible equipment.
UST System Compatibility With Biofuels
November 2015
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Why EPA Updated The Compatibility Requirements In The
2015 UST Regulation
The fuel supply in the United States is constantly evolving.
Ensuring compatibility prior to storing any regulated substance in
an existing or new UST system is important, because your UST
system may have been built with components that were not
intended for use with the biofuel you wish to store today.
One example that demonstrates the importance of knowing the
compatibility of your UST system involves ethanol, an oxygenate
commonly blended into fuel to improve engine efficiency and
emissions. Ethanol became widely used in the United States in
blends up to 10 percent by volume in the mid-2000s when methyl
tertiary butyl ether (MTBE), an oxygenate introduced to enhance
octane as lead was phased out of gasoline, was itself phased out
due to environmental concerns.
Research has shown that some materials, such as some polymers
and elastomers commonly used in UST system construction prior
to ethanol becoming widely used, may swell and lose their shape
when in contact with ethanol. In an UST system, these materials
may be intended to create a seal between components, but if
damaged, may not perform correctly and could lead to a release of
a regulated substance to the environment. These materials may
show the most swelling in gasoline blended with ethanol greater
than 10 percent by volume. Other regulated substances, such as
higher concentrations of biodiesel, may also present compatibility
considerations for these or other UST components.
UST systems are designed for long lifespans and are normally not
frequently replaced. As the fuel supply changed to incorporate
more ethanol, UST and fuels stakeholders found that some
installed UST systems were incompatible with lower level ethanol
blends. The UST system equipment industry responded to the
increasing use of biofuels and the risks identified by creating
equipment compatible with lower blends of these fuels. Over time,
the industry also began producing equipment compatible with
higher blends of ethanol and biodiesel - those that are generally
more aggressive towards more commonly used UST system
materials. EPA thinks that all new tanks and piping produced
today are compatible with blends of up to 100 percent ethanol and
biodiesel.
However, many of the ancillary components may still be available
in versions not compatible with up to 100 percent biodiesel or 100
percent ethanol. The whole UST system - including the tank,
piping, containment sumps, pumping equipment, release detection
equipment, spill prevention equipment, and overfill prevention
equipment - needs to be compatible with the fuel stored to prevent
Adding any amount of
ethanol to petroleum based
fuels changes how the fuel
interacts with materials.
Blends greater than 10
percent ethanol by volume
show the most ability to
affect the performance of
some materials in older UST
wrnotcriul
are compatible with tr ~
fuels are readily availt
material incompatibility
were not caused by biofuels,
but provide good exampl
of incompatibility. T
bottom are pipe elongation,
cracking of the internal tank
lining, and delamination of
product piping (in top left of
the picture.)
UST System Compatibility With Biofuels
November 2015
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releases to the environment. Biofuel blends with ethanol up to 98
percent (E98) and biodiesel up to 99 percent (B99) have been
stored compatibly in some UST systems around the country.
EPA thinks most UST systems are not fully compatible with higher
blends of biofuels because many were installed before some
compatible UST system equipment was available. EPA updated
the compatibility requirements in the 2015 UST regulation to
ensure higher blends of biofuels will be stored only in compatible
UST systems.
The 2015 UST regulation describes the steps UST owners and
operators must take to help protect our health and environment
from potential UST releases due to incompatibility. These steps
will also help you avoid the high cost of cleaning up releases and
possible legal actions that can result if your UST system releases
product to the environment.
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-
underground-storage-tank-ust-programs.
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.
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.
This booklet describes EPA's
requirements for
compatibility, but your
implementing agency may
have requirements that are
somewhat different or more
stringent than the federal
requirements. Contactyour
implementing agency for its
specific compatibility
requirements. Many
agencies may require
owners who store biofuels
follow different
requirements, which could
include submitting
documents that differ from
the examples provided in
this booklet.
UST System Compatibility With Biofuels
November 2015
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Compatibility Requirements In The 2015 LIST
Regulation
The 2015 UST regulation maintains the requirement that all UST
systems must be made of or lined with materials compatible with
the substance stored in the UST system.
The 2015 UST regulation provides clarity to the 1988
compatibility requirement by specifying additional compatibility
requirements for owners and operators wishing to store certain
regulated substances, including gasoline containing more than 10
percent ethanol and diesel containing greater than 20 percent
biodiesel. Research has identified these substances as having a
higher likelihood of incompatibility with many existing UST
systems. By targeting the additional compatibility requirements
toward the specific subset of the UST operating universe with the
highest risk of failure due to incompatibility, the overall risk of
releases will be minimized.
The 2015 UST compatibility requirements incorporate some
elements similar to EPA's 2011 Guidance On Compatibility Of
UST Systems With Ethanol Blends Greater Than 10 Percent And
Biodiesel Blends Greater Than 20 Percent
(www.epa.gov/ust/guidance-compatibilitv-ust-systems-ethanol-
blends-greater-10-percent-and-biodiesel-blends), including
demonstrating that the UST system is compatible with the
substance stored and keeping certain records. Beginning on
October 13, 2015, in addition to the 1988 requirement of ensuring
that the UST system is compatible, UST owners and operators
intending to store regulated substances must also meet these
additional compatibility requirements:
Notification
www. epa.gov/ust/
underaround-storage-tank-
ust-contacts#states
You must notify your implementing agency at least 30
days before switching to any of the following products:
o Regulated substances containing greater than 10
percent ethanol
o Regulated substances containing greater than 20
percent biodiesel
o Any other regulated substance identified by your
implementing agency
UST System Compatibility With Biofuels
November 2015
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Please see Appendix 1 for a sample letter for notifying your
implementing agency that you plan to switch to store a biofuel.
Additionally, owners and operators storing one or more of these
regulated substances must meet the compatibility requirement by
demonstrating compatibility of the system with the fuel or by using
an alternative method approved by the implementing agency:
Demonstration of compatibility
• If you store any of these substances, you must either:
o Demonstrate that the following UST system
components are compatible with the regulated
substance: tank, piping, containment sumps,
pumping equipment, release detection
equipment, spill prevention equipment, and
overfill prevention equipment
o Use another option determined by the
implementing agency to be no less protective of
human health and the environment than the
demonstration method
Recordkeeping
• Beginning on October 13, 2015, if you store regulated
substances containing greater than 10 percent ethanol,
greater than 20 percent biodiesel, or other substances
identified by your implementing agency, you must keep
records showing that your UST system is compatible
with those substances. If you choose to follow an
alternative method determined to be no less protective
of human health and the environment established by
your implementing agency, then you must keep
documentation of adherence to this requirement as
required by the implementing agency's rules. You must
keep these records for as long as you store these
regulated substances
Owners and operators may wish to consult American Petroleum
Institute's Recommended Practice 1626, Storing and Handling
Ethanol and Gasoline-Ethanol Blends at Distribution Terminals
and Filling Stations. It may be useful in complying with the
compatibility requirement.
Note: In this list, pumping
equipment refers to the
equipment used to move the
fuel from the underground
storage tank to the fuel
dispenser. The regulation
does not address the fuel
dispenser itself because the
UST regulation only covers
equipment at or under the
surface of the ground.
Although not covered in the
UST regulation or this
document, you should make
sure your dispenser is also
compatible with the
substance stored. Check
with your local
implementing agency to find
out which department or
agency regulates fuel
dispensers in your area, so
that you can ensure you
meet all requirements for
fuel dispenser compatibility.
UST System Compatibility With Biofuels
November 2015
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This section explains how to meet the requirements for compatibility when storing biofuels.
Below is a chart of the requirements for the vehicle fuels most commonly stored in UST systems.
The chart is not a complete list of regulated substances which must meet the additional
compatibility requirements in the 2015 UST regulation. The chart is a quick guide to help
owners and operators storing regulated vehicle fuels understand which compatibility
requirements they must meet.
Type of regulated
substance
Must be
compatible
with UST
system
Must
Must notify demonstrate Must keep *Must keep
implementing compatibility these records records of
agency before of UST for as long as leak detectior
switching to system with the substance performance
agency before of UST
switching to system with
store this fuel the substance
being stored
is stored
claims
Regulated
substances
containing up to 10
percent ethanol.
This includes the fuel
commonly referred
to as E10.
Regulated
substances
containing up to 20
percent biodiesel,
called B20. This
includes fuels such
as B5, B10, and B20.
Regulated
substances
containing greater
than 10 percent
ethanol. This
includes fuels such
as E15or E85.
Regulated
substances
containing greater
than 20 percent
diesel, including
fuels such as B50 or
B99.
Other regulated
substances identified
by implementing
agency.
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*Leak detection performance claims are associated with equipment functionality in biofuels. See page 9 for more
information.
UST System Compatibility With Biofuels
November 2015
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How Can You Demonstrate That Your LIST System Is
Compatible With Biofuels?
Two options are available to demonstrate that your UST system is
compatible with fuels containing greater than 10 percent ethanol or
greater than 20 percent biodiesel.
• Certification or listing of UST system equipment or
components by a nationally recognized, independent testing
laboratory for use with the regulated substance stored; or
• Equipment or component manufacturer approval. This
manufacturer's approval must:
o be in writing,
o indicate an affirmative statement of compatibility,
o specify the range of biofuel blends the component is
compatible with, and
o be from the equipment or component manufacturer
See Appendix 2 for a sample checklist for owners and operators
wanting to determine compatibility of UST systems. Equipment
manufacturers should be able to provide information on the
substances for which their equipment is compatible. Determining
the compatibility status of some older UST equipment or
components for which paperwork has been lost could be
challenging, so remember to keep your documentation.
In addition to your UST implementing agency, the resources on
page 12 may help identify the compatibility status of your installed
UST system components. EPA anticipates that most older UST
systems will require retrofitting of some equipment with
compatible equipment, if the owners or operators choose to store
higher level biofuel blends in these systems.
Meeting The Compatibility Requirement Through Use Of An
Alternative Method Developed By The Implementing
Agency
The 2015 UST regulation allows implementing agencies to
determine alternative methods of meeting the compatibility
requirement for regulated substances containing greater than 10
percent ethanol, greater than 20 percent biodiesel, or other
substances identified by the agency. These alternative methods
must be no less protective of human health and the environment
than the manufacturer's approval or certification or listing by a
nationally recognized, independent testing laboratory. Contact
your implementing agency for the compatibility requirements that
apply to your USTs.
Remember to keep all
compatibility demonstration
documents for all UST
system equipment and
components that come into
contact with the substance
stored. You must also keep
records of any repairs to
these components or
equipment because the
records may be required to
demonstrate compatibility.
See Appendix 2 for a sample
checklist which can help
owners and operators
ensure they can meet the
compatibility requirements.
UST System Compatibility With Biofuels
November 2015
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What records must you keep?
The 2015 UST regulation requires you keep documentation
showing that your system is compatible when storing certain
biofuels:
Beginning on October 13, 2015, if you store regulated
substances containing greater than 10 percent ethanol,
greater than 20 percent biodiesel, or any other
substances identified by your implementing agency, you
must keep records showing that your UST system is
compatible with those substances. You must keep these
records for as long as you store these regulated
substances.
If you choose to follow an alternative method
determined to be no less protective of human health and
the environment established by the implementing
agency, then you must keep documentation
demonstrating compliance with this requirement as
required by the implementing agency's rules. You must
keep these records for as long as you store these
regulated substances.
You should also contact your implementing agency about the
particular recordkeeping requirements that apply to your USTs.
Generally follow this useful
rule of thumb for
recordkeeping: When in
doubt, keep it.
Compatibility Versus Functionality For Release
Detection Equipment
Compatibility of equipment, or the ability of two or more
substances to maintain their respective chemical and physical
properties when in contact with one another, is different from
functionality of equipment. Functionality is the ability of
equipment to perform the job it was designed to do.
Some higher blends of biofuels could potentially affect both the
compatibility and functionality of UST equipment. Biofuels
containing ethanol can affect the amount of water absorbed or
retained in fuel. Some types of release detection equipment rely on
sophisticated technologies to evaluate product levels in
underground storage tanks. These methods for leak detection
could be adversely affected by ethanol's ability to dissolve and mix
with water, which could prevent them from functioning as
designed as a release detection device in fuels blended with
ethanol. Owners and operators should ensure that their release
detection equipment is both compatible with the biofuel stored and
meets EPA's release detection performance standards for use with
the biofuel.
Remember, compatibility is
different from functionality.
You can use testing protocols
to evaluate the functionality
of various release detection
technologies in different
regulated substances.
UST System Compatibility With Biofuels
November 2015
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EPA is updating our 1990 protocols Standard Test Procedures for
Evaluating Various Leak Detection Methods; these help
manufacturers certify that their leak detection equipment meets
federal performance standards for functionality. The updated
protocols will account for new fuels and technologies. You can
access the current protocols at www.epa.gov/ust/standard-test-
procedures-evaluating-various-leak-detection-methods.
UST System Compatibility With Biofuels
November 2015
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pgraamg tquipmen
Compatibility Requirements For
Storing Biofuels
It is possible that many owners and operators of existing UST
systems wishing to store higher blends of biofuels will find,
after evaluating their systems and documentation, they are
not able to demonstrate compatibility for their entire UST
system. These owners have three options.
One option is to use targeted retrofits of specific equipment
to upgrade their existing UST systems. Many owners may
already be able to demonstrate compatibility for the tanks and
piping in their UST systems. These components are often the
largest expenses associated with an UST system installation
and owners may have documentation available for this
equipment. In this situation, an owner may be able to
upgrade other components of his UST system with less
operational downtime and less cost because he will not need
to break the concrete pad over the UST system to replace
tanks or piping.
Another option is to install a new UST system that can be
demonstrated compatible with the substance to be stored.
When installing a new system for this purpose, an owner
should specifically request equipment that is compatible with
regulated substances containing greater than 10 percent
ethanol and greater than 20 percent biodiesel. The marginal
upgrade cost for equipment that is compatible with ethanol or
biodiesel blends up to 100 percent is a small percentage
increase compared with the overall cost of a new system.
However, owners must ensure they request such equipment
prior to equipment installation.
The other option is to not store the substance. This will
ensure no releases occur due to incompatibility of the
substance and the UST system. This could prevent an owner
from being out of compliance with the compatibility
requirements or becoming responsible for cleaning up a
release to the environment from an incompatible system.
Owners and operators can explore options for upgrading their
UST systems to meet compatibility requirements by
consulting with their implementing agency, UST servicing
contractor, or the resources listed on page 12.
Remember, keeping records
of equipment or
components installed or
repaired now may help to
determine compatibility of
that equipment at a later
date, even if you aren't
currently storing biofuels. If
you are already storing
biofuels, you may already be
required to keep such
documentation to
demonstrate compatibility
of the UST system.
Owners and operators
having a new UST system
installed may wish to choose
equipment that will be
compatible with gasoline
containing greater than 10
percent ethanol or diesel
containing greater than 20
percent biodiesel. This
provides owners with the
option of storing biofuels
later, even if they do not
store them now.
Remember that you must
specifically request
equipment that is
compatible with higher
biofuel blends from the
installer prior to the
installation or the installer
may install less expensive
equipment that may not be
compatible with biofuels.
UST System Compatibility With Biofuels
November 2015
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Kesources For More information
About Biofuel Compatibility
Determinations
Government
• EPA's alternative fuels and USTs:
www.epa.gov/ust/alternative-fuels-and-underground-
storage-tanks-usts
• EPA's industry codes and standards for USTs:
www. epa. gov/ust/underground-storage-tanks-usts-
laws-regulations#code
• Association of State and Territorial Solid Waste
Management Officials: www.astswmo.org
• New England Interstate Water Pollution Control
Commission: www.neiwpcc.org
Industry Organizations
• Petroleum Equipment Institute's UST Component
Compatibility Library: www.pei.org/ust-
component-compatibility -library
• American Petroleum Institute: www.api.org
• Fiberglass Tank & Pipe Institute:
www.fiberglasstankandpipe.com
• Steel Tank Institute: www. steel tank, com
• Petroleum Marketers Association of America:
www.pmaa.org
• NACS: The Association for Convenience & Fuel
Retailing: www.nacsonline.com
• Underwriters Laboratories Inc. (UL): http://ul.com/
UST System Compatibility With Biofuels
November 2015
-------
You can access EPA's free publications about USTs in these
ways:
• See EPA's UST website at www.epa.gov/ust to
order, download, or read documents online.
• Write to the National Service Center for
Environmental Publications (NSCEP), EPA's
publication distributor: NSCEP, PO Box 42419,
Cincinnati, OH 45242.
• Call NSCEP's toll-free number 800-490-9198.
• Fax your order to NSCEP 301-604-3408.
UST System Compatibility With Biofuels
November 2015
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Appendices
Appendix 1: Sample Notification Letter
Below is a sample letter that you can use as a template for
notifying your implementing agency at least 30 days before
you switch to regulated substances containing greater than
10 percent ethanol, greater than 20 percent biodiesel, or any
other substance identified by your implementing agency.
You may also call or email the implementing agency, but
you should include the same information described in this
sample letter.
[Date]
[Name of LIST Implementing Agency
Street Address
City, State, Zip Code]
Dear Sir or Madam:
This letter is notifying you that pursuant to the federal
underground storage tank (UST) regulation at 40 CFR
280.32,1 intend to store [type of regulated substance]
beginning on [date] in my underground storage tank system,
which is uniquely identified as [USTsystem identification
number]. My underground storage tank facility is located at
[facility address]. I understand my UST system must be
fully compatible with [type of regulated substance]. If you
have questions, please contact me at [phone number].
Sincerely,
[signature]
[owner or operator name]
UST System Compatibility With Biofuels
November 2015
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Appendix 2: Sample Checklist For Determining LIST System Compatibility
This sample checklist can help owners and operators determine and document the compatibility
of their UST systems. Be sure to check with your implementing agency for their specific
compatibility requirements. They may require you submit a compatibility documentation
checklist that differs from the sample checklist provided below.
Checklist For Determining And Documenting UST System Compatibility
Instructions: Complete all sections. This will help ensure you have the required information to
demonstrate compatibility of an UST system with biofuels containing more than 10 percent ethanol or
more than 20 percent biodiesel.
Facility Owner:
Facility Name:
Facility Number:
Facility's Street Address, City, State, Zip Code:
UST System
Identifier:
Type And Blend Of Regulated Substance:
UST Capacity In
Gallons:
Complete the checklist below, listing compatibility determination, method*, and description. All
answers must be Yes and supported with a sufficient description or documentation for your system to
be demonstrated compatible with the biofuel.
UST System
Components
Documentation
Demonstrating
Compatibility With
The Substance
Listed Above?
Method*
A, B, Or
C
Description Of Component Type, Model
Number, And National Laboratory
Certification, Listing Or Manufacturer
Approval
Tank
No
Yes
Piping
No
Yes
Containment Sumps
No
Yes
UST System Compatibility With Biofuels
November 2015
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Pumping Equipment
Release Detection
Equipment
Spill Equipment
Overfill Prevention
Equipment
No
No
No
No
Yes
Yes
Yes
Yes
*Methods:
A: Certification or listing of LIST system equipment or components by a nationally recognized,
independent testing laboratory for use with the regulated substance stored
B: Equipment or manufacturer approval. The manufacturer's approval must be in writing, indicate an
affirmative statement of compatibility, specify the range of biofuel blends the component is compatible
with, and be from the equipment or component manufacturer
C: Use another option determined by your implementing agency to be no less protective of human
health and the environment than methods A or B. If using C, list your implementing agency and
immediately below describe the approved alternative method for meeting the compatibility requirement
Method C Description:
Note: Owners and operators may find American Petroleum Institute's Recommended Practice 1626,
Storing and Handling Ethanol and Gasoline-Ethanol Blends at Distribution Terminals and Filling
Stations, useful in complying with the compatibility requirements.
In order to be in compliance with the 2015 LIST regulation compatibility requirements for storing
biofuels, you must keep documentation of compatibility of the LIST system components listed on this
page as long as you store the fuel.
For your records, you should update this checklist each time you repair or replace components of your
LIST system to ensure you have all the required compatibility documentation while storing biofuels.
UST System Compatibility With Biofuels
November 2015
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United States
Environmental Protection
Agency
United States Environmental Protection Agency
5401P
Washington, DC 20460
EPA 510-K-15-002
November 2015
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