SEPA
UPDATED 2016
United States
Environmental Protection
Agency
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Operating And Maintaining
Underground Storage Tank Systems
Practical Help And Checklists
EPA 510-K-16-001
February 2016
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
with state program approval, see
If your 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
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.
Free Publications About UST Requirements
Download or read Operating And Maintaining Underground Storage Tank Systems on EPA's
underground storage tank (UST) website at . Order printed copies of many, but
not all, of our documents from the National Service Center for Environmental Publications
(NSCEP), EPA's publication distributor: write to NSCEP, PO Box 42419, Cincinnati, OH 45242; call
NSCEP's toll-free number 800-490-9198; or fax your order to NSCEP 301-604-3408.
Image credits:
MVI Field Services (inspector on cover and page 52)
Highland Tank & Manufacturing Company (steel tanks on cover and in headers)
OPW (spill bucket on page 31, automatic shutoff device on page 35, ball float valve on page 39)
Federated Environmental Associates, Inc. (delivery and under-dispenser containment on cover)
Operating And Maintaining Underground Storage Tank Systems
February 2016
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How To Use This Booklet 1
Section 1: Identifying The Equipment At Your UST Facility 3
Section 2: Release Detection 5
Section 3: Suspected Or Confirmed Releases 26
Section 4: Spill And Overfill Protection 30
Section 5: Corrosion Protection 43
Section 6: Walkthrough Inspections 52
Section 7: For More Infomiatlon[[[ 55
Disclaimer
This document provides information on operating and
maintaining underground storage tank (UST) systems. 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
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Who Should Read This Booklet?
This booklet is for owners and operators of underground
storage tank (UST) systems regulated under 40 CFR part
280.
You are responsible for making sure your USTs do not leak.
This booklet can help you meet your UST responsibilities.
How Can This Booklet Help You?
This booklet can help you:
• Understand the 2015 UST regulation and its impact
on regular operation and maintenance (O&M)
procedures.
• Identify and understand the O&M procedures you
should follow routinely to make sure your USTs do
not leak and possibly damage the environment or
endanger human health. These O&M procedures will
help you avoid cleanup costs and liability concerns.
• Stay in compliance with EPA's UST O&M
requirements.
• Identify O&M records you must keep on file.
What Should You Do With Each Section Of This
Booklet?
Read through each section carefully and use the checklists to
help you establish clear O&M procedures.
By identifying and understanding the O&M tasks you should
perform routinely, you will help ensure timely repair or
replacement of components when problems are identified.
Throughout this document, bold type and orange
updated boxes indicate new requirements in the 2015
UST regulation.
Releases from USTs can
threaten human health and
the environment,
contaminating both soil and
groundwater supplies. As of
2015, more than 525,000
UST releases have been
confirmed.
About hall
of the United States
population uses
groundwater as a sourc
of drinking water.
Operating And Maintaining Underground Storage Tank Systems
February 2016
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How Can You Use The Checklists Effectively?
You can select the specific mix of checklists that matches your
UST facility. Once you identify your site-specific group of
checklists, use them to perform operation and maintenance
activities at your UST facility. Make several copies and complete
them periodically.
By using these checklists, you can track your O&M activities and
know you have done what was necessary to properly operate and
maintain your UST system. Proper O&M activities help reduce
releases of regulated substances 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 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.
Key Terms
An UST is a storage tank and
underground piping
connected to the tank that
has at least 10 percent of its
combined volume
underground. The federal
regulation applies only to
USTs storing petroleum,
including biofuel blends, and
certain hazardous
substances.
O&M means operation and
maintenance procedures
that owners and operators
must follow to keep UST
systems from leaking, which
can result in costly cleanups.
Your implementing agency
may be the state UST agency,
EPA, or a local UST agency.
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Section 1:
Identifying The Equipmen
At Your UST Facility
UST Equipment Checklist
Use the checklist on page 4 to identify UST equipment at
your facility. Each part of the checklist refers you to the
appropriate section of this O&M booklet for relevant
information. After you identify your equipment, proceed
to the appropriate sections and identify the O&M actions
necessary for your specific UST system.
Problems Completing This Checklist
If you have trouble completing this checklist or others in
this booklet, you can contact:
• Your UST contractor, the vendor of your UST
equipment, and the manufacturer of your UST
equipment for help. Look through your records for
contact information. You may also use the contacts
provided in Section 7.
• Your implementing agency may be able to help you
identify equipment or sources of information about
your UST equipment. Identify additional or
different O&M procedures between those of your
implementing agency and those presented in this
booklet. See Section 7 for implementing agency
contact information.
Remember Compatibility
If you store regulated
substances containing
greater than 10 percent
ethanol or greater than 20
percent biodiesel (or any
other regulated substance
identified by your state UST
agency), you must notify
your implementing agency
at least 30 days prior to
switching to the fuel. You
must also keep records
demonstrating you meet the
compatibility requirement.
Keep these records for as
long as the UST system
stores the regulated
substance.
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General Facility Information (optional)
Facility Name
Facility ID #
Release Detection (Section 2)
Check at least one for each tank:
A. Release
ir Tanks1
Automatic tank gauging (ATG) system
Interstitial monitoring (with secondary containment)
Statistical inventory reconciliation (SIR)
Continuous in-tank leak detection (CITLD)
Vapor monitoring
Groundwater monitoring
Inventory control and tank tightness testing (TTT)2
Manual tank gauging only3
Manual tank gauging and tank tightness testing (TTT)4
Other release detection method (please specify)
1. If you install or replace a tank after April 1 1, 2016, it must have secondary containment and interstitial monitoring.
2. Allowed only for 10 years after the tank was installed. TTT required every five years.
3. Allowed only for tanks of 1,000 gallon capacity or less, with specified diameters.
4. Allowed only for tanks of 2,000 gallon capacity or less and only for 10 years after tank was installed. TTT required every five years.
B. Release Detection For Pressurized Piping1
A
(Automatic Line
Leak Detectors)
B
Automatic flow restrictor
Automatic shutoff device
Audible or visual alarm
Annual line tightness test
Monthly monitoring2
1. If you install or replace piping after April 1 1, 2016, it must have secondary containment and interstitial monitoring and have an automatic line leak detector.
2. Monthly monitoring for piping includes interstitial monitoring, vapor monitoring, groundwater monitoring, SIR, and CITLD.
C. Release Detection For Suction Piping1
Line tightness testing every three years
Monthly monitoring2
No release detection (safe suction)3
1. If you install or replace piping after April 1 1, 2016, it must have secondary containment and interstitial monitoring (except for safe suction piping).
2. Monthly monitoring for piping includes interstitial monitoring, vapor monitoring, groundwater monitoring, and other accepted methods (such as SIR and electronic line leak
detectors).
3. No re ease detection required only if it can be verified that you have a safe suction piping system with the following characteristics: only one check valve per line located
directly below the dispenser; piping sloping back to the tank; and system must operate under atmospheric pressure.
Spill And Overfill Protection (Section 4)
Spill catchment basin or spill bucket (check for each tank)
Automatic shutoff device
Overfill alarm
Ball float valve1
1. Ball float valves may not be used to meet this requirement when overfill prevention is installed or replaced after October 13, 2015.
Corrosion Protection (Section 5)
A. Corrosion Protection For Tanks
Coated and cathodically protected steel
Noncorrodible material (such as fiberglass reinforced plastic)
Steel jacketed or clad with noncorrodible material
Cathodically protected noncoated steel
Internally lined tank
Other method (please specify)
B. Corrosion Protection For Piping
Coated and cathodically protected steel
Noncorrodible material (such as fiberglass reinforced plastic or
flexible plastic)
Cathodically protected noncoated metal
Other method (please specify)
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Section 2:
Release Detection
UPDATED
What Are Your Release Detection Options?
For tanks installed on or before April 11, 2016, you can use
any of these release detection methods:
• Automatic tank gauging systems
• Interstitial monitoring (with secondary containment)
• Statistical inventory reconciliation
• Continuous in-tank leak detection
• Vapor monitoring
• Groundwater monitoring
• Inventory control with tank tightness testing
• Manual tank gauging
• Manual tank gauging with tank tightness testing
• Other methods meeting performance standards or
approved by the implementing agency
For underground piping installed on or before April 11,
2016, you may use any of the release detection methods
listed above that are appropriate for piping or conduct
periodic line tightness testing. In addition, pressurized
piping must have an automatic line leak detector.
Tanks and piping installed or replaced after April 11,
2016 must have secondary containment with interstitial
monitoring, except for piping that is considered safe
suction piping. Pressurized piping must continue to have
an automatic line leak detector.
Suction piping is considered safe suction piping if it:
• Is below-grade piping that operates under
atmospheric pressure;
• Slopes enough so that the product in the pipe can
drain back into the tank when suction is released;
and
• Has only one check valve, which is as close as
possible beneath the pump in the dispensing unit.
Safe suction piping is not required to have release detection.
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,
some 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
website at
No later than October 13,
2018, emergency generator
USTs installed on or before
October 13, 2015 must meet
the release detection
requirements described in
this booklet. Emergency
generators installed after
October 13, 2015 must meet
the release detection
requirements at installation.
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Inventory Control or
Manual Tank Gauging
Vapor
Monitoring
Well
nventory Probe for
Automatic Tank Gauging,
Continuous In-Tank Leak Detection,
and Statistical Inventory Reconciliation
Secondary
Containment
with Interstitial
Monitor
Groundwater
Monitoring
Well
What Are Your Existing Release Detection
Requirements?
You must use proper release detection methods to determine at
least every 30 days whether your tank and piping are leaking.
Your release detection method must be able to detect a leak from
any portion of the tank and connected underground piping that
routinely contains product.
You must keep the following records:
• Proof that performance claims, including probabilities of
detection and false alarm, are met and the means by which
performance was determined by either the equipment
manufacturer or installer. You must maintain these records
for at least five years.
• Results of any sampling, testing, or monitoring, except tank
tightness tests, must be maintained for at least one year.
You must maintain results of tank tightness tests until the
next test is conducted.
• All calibration, maintenance, and repair of release detection
equipment permanently located on site must be maintained
for at least one year after servicing work is completed.
• Any schedules of required calibration and maintenance
provided by equipment manufacturers must be retained for
five years from the date of installation.
Operating And Maintaining Underground Storage Tank Systems
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UPDATED
UPDATED
UPDATED
UPDATED
What Are Your Additional Release Detection
Requirements?
No later than October 13, 2018, you must conduct your first
annual test of your release detection equipment for proper
operation. The testing must be conducted according to one of
the following: manufacturer's instructions; a code of practice
developed by a nationally recognized association or
independent testing laboratory; or requirements your
implementing agency determines are no less protective of
human health and the environment than the other two options.
Minimum requirements for testing various release detection
components are covered under each release detection checklist.
You must keep records of this testing for at least three years.
See the sample annual release detection testing recordkeeping
form on page 10.
No later than October 13, 2018, you must conduct your first
periodic walkthrough inspection of your release detection
equipment. You must keep records of these inspections for at
least one year. See more information about walkthrough
inspections in Section 6.
No later than October 13, 2018, if you use groundwater or
vapor monitoring for release detection, you must demonstrate
proper installation and performance through a site assessment.
You must maintain the site assessment for as long as the
method is used for release detection at your facility. Site
assessments completed after October 13, 2015, must be signed
by a licensed professional.
What About Compatibility?
If you store regulated substances containing greater than 10
percent ethanol or greater than 20 percent biodiesel or any
other regulated substance identified by your implementing
agency, keep records demonstrating compatibility of the
release detection components, such as probes and sensors, in
contact with the regulated substance for as long as the UST
system stores the regulated substance.
Remember, your release
detection method must meet
specific performance
requirements relating to its
ability to detect a release.
You must also ensure you
use a method appropriate to
your UST system and the
product you store.
Operating And Maintaining Underground Storage Tank Systems
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Do You Know If Your Release Detection Meets
Performance Requirements?
Release detection must meet specific performance requirements.
UST system owners and operators must keep written verification
of equipment performance. Equipment manufacturers or installers
provide this verification. Some equipment vendors or
manufacturers supply their own performance documentation, but
more often an impartial third party is paid to test the release
detection equipment and certify that performance requirements are
met. An independent workgroup of release detection experts
periodically reviews and maintains a list of submitted third-party
certifications, thus providing a free and reliable list of evaluations
of third-party certifications for various release detection
equipment. Frequently updated, this list is available at
www.nwglde.org: the publication is List Of Leak Detection
Evaluations For Storage Tank Systems. If you cannot find the
performance documentation, contact your implementing agency;
see Section 7 for contact information.
You should check the performance documentation to ensure your
method is appropriate for use with your UST system equipment.
By checking the documentation, you may discover the method you
use has not been approved for use with the type of tank or piping
you have. For example, you may learn from the documentation
that your method will not work with manifolded tanks, certain
products, high throughput, or certain tank sizes. That is why you
must make sure your release detection method has clear
performance documentation stating it will work effectively at your
site with its specific characteristics.
What Are Your Release Detection O&M Responsibilities
At Your UST Site?
If you do not understand your release detection O&M
responsibilities and do not know what O&M tasks you must
routinely perform, your UST site could become contaminated
through spills, overfills, or releases from UST equipment. To
avoid these problems use the checklists on the following pages,
which describe each type of release detection method, discuss
actions necessary for proper O&M, and note the records you
should keep.
Locate the methods of release detection you are using at your
facility, review these pages, and periodically review the checklists.
You might want to print the checklists and periodically complete
them later.
Operating And Maintaining Underground Storage Tank Systems
February 2016
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If you have questions about your release detection system, review
your owner's manual or call the vendor of your system. Your
implementing agency may be able to provide assistance as well.
You will find sample release detection recordkeeping forms in this
section. Keeping these records increases the likelihood that you
are conducting good O&M and providing effective release
detection at your UST site. For example, the following page has a
sample recordkeeping form for your required annual release
detection testing.
If you ever suspect or confirm a release, refer to Section 3. Never
ignore release detection alarms or failed release detection tests.
Treat them as potential leaks.
Operating And Maintaining Underground Storage Tank Systems
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Sample Annual Release Detection Testing Recordkeeping Form
Date(s) of annual release detection operation test:
Automatic tank gauge and other
controllers: test alarm; verify system
configuration; test battery backup.
Action Taken
To Correct
Probes and sensors: inspect for residual
buildup; ensure floats move freely;
ensure shaft is not damaged; ensure
accessible cables are free of kinks and
breaks; test alarm operability and
communication with controller.
Automatic line leak detector: test to
ensure device can detect 3 gallons per
hour at 10 pounds per square inch (or
equivalent) within one hour by
simulating a leak.
Vacuum pumps and pressure gauges:
ensure proper communication with
sensors and controller.
Hand-held electronic sampling
equipment associated with groundwater
and vapor monitoring: ensure proper
operation.
Other Components Tested:
Notes:
Release Detection Tester Signature Date
Keep this record for three years.
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Checklist For Automatic Tank Gauging Systems (For Tanks Only)
UPDATED
UPDATED
UPDATED
UPDATED
UPDATED
UPDATED
Automatic Tank Gauging Systems (For Tanks Only)
Description
Perform
These O&M
Actions
Keep These
O&M Records
An automatic tank gauging (ATG) system consists of a probe permanently installed in
a tank and wired to a monitor to provide information on product level and temperature.
ATG systems automatically calculate the changes in product volume that can indicate
a leaking tank.
D Use your ATG system to test for leaks at least every 30 days.
D Make sure the amount of product in your tank is sufficient to run the ATG leak test.
The tank must contain a minimum amount of product to perform a valid leak test.
One source for determining that minimum amount is the performance
documentation for your release detection equipment.
D No later than October 13, 2018, you must begin inspecting and testing your
ATG system every year. At a minimum, test the alarm, battery back-up, and
verify the system configuration. For probes and sensors, you must inspect
for residual build-up, ensure floats move freely, ensure the shaft is not
damaged, ensure accessible cables are free of kinks and breaks, and test
alarm operability and communication with controller.
D No later than October 13, 2018, you must begin performing periodic
walkthrough inspections. See Section 6 for more information about these
required walkthrough inspections.
D If your ATG ever fails a test or indicates a release, see Section 3 for information
on what to do next.
D Make sure employees who run, monitor, or maintain the release detection system
know exactly what they have to do and to whom to report problems. No later
than October 13, 2018, LIST owners must have designated and trained
operators. Most states already require operator training.
D Keep results of your 30-day release detection monitoring for at least one year.
Your monitoring equipment may provide printouts that can be used as records.
See page 25 for a sample 30 day recordkeeping form.
D Keep results for your annual ATG system operation tests for at least three
years.
D Keep all records of calibration, maintenance, and repair of your release detection
equipment for at least one year.
D Keep any schedules of required calibration and maintenance provided by the
release detection equipment manufacturer for at least five years from the date of
installation.
D Keep all performance claims supplied by the installer, vendor, or manufacturer for
at least five years.
D Keep your periodic walkthrough inspection records for at least one year.
D If you store regulated substances containing greater than 10 percent ethanol
or greater than 20 percent biodiesel or any other regulated substance
identified by your implementing agency, keep records demonstrating
compatibility for as long as the LIST system stores the regulated substance.
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Checklist For Secondary Containment With Interstitial Monitoring (For Tanks And
Piping)
UPDATED
UPDATED
UPDATED
UPDATED
UPDATED
UPDATED
UPDATED
UPDATED
UPDATED
Secondary Containment With Interstitial Monitoring (For Tanks And Piping)
Description
Perform
These O&M
Actions
Keep These
O&M
Records
Secondarily-contained LIST systems have an inner and outer barrier with an interstitial
space that is monitored for leaks. This term includes containment sumps when used
for interstitial monitoring of piping. Examples of secondary containment include an
outer tank or piping wall, an excavation liner, and a bladder inside an LIST.
D Use your release detection system to test for leaks at least every 30 days.
D No later than October 13, 2018, you must begin inspecting and testing your
release detection system every year. You must inspect probes and sensors
for residual build-up, ensure floats move freely, ensure the shaft is not
damaged, ensure accessible cables are free of kinks and breaks, and test
alarm operability and communication with the controller.
D No later than October 13, 2018, you must begin testing all containment sumps
used for piping interstitial monitoring every three years for liquid tightness or
use a double-walled containment sump with annual interstitial monitoring.
D No later than October 13, 2018, you must begin performing periodic
walkthrough inspections. See Section 6 for more information about these
required walkthrough inspections.
D If you repair any secondary containment areas, you must test them for
tightness within 30 days after the repair.
D If your release detection ever fails a test or indicates a release, see Section 3 for
information on what to do next.
D Make sure employees who run, monitor, or maintain the release detection system
know exactly what they have to do and to whom to report problems. No later than
October 13, 2018, LIST owners must have designated and trained operators.
Most states already require operator training.
D Keep results of your 30-day release detection monitoring for at least one year. Your
monitoring equipment may provide printouts that can be used as records. See page
25 for a sample 30 day recordkeeping form.
D Keep results for your annual release detection system operation tests for at
least three years.
D Keep all records of calibration, maintenance, and repair of your release detection
equipment for at least one year.
D Keep any schedules of required calibration and maintenance provided by the
release detection equipment manufacturer for at least five years from the date of
installation.
D Keep all performance claims supplied by the installer, vendor, or manufacturer for at
least five years.
D For containment sump and secondary containment equipment inspections
that are part of the periodic walkthrough inspection requirement, keep records
of the walkthrough inspection for at least one year.
D For containment sumps used for interstitial monitoring of piping, keep records
of containment sump testing for three years or keep documentation showing
the containment sump is double-walled and the integrity of both walls is
periodically monitored for as long as containment sump testing is not
performed. See page 33 for a sample recordkeeping form for the test.
D If you store regulated substances containing greater than 10 percent ethanol
or greater than 20 percent biodiesel or any other regulated substance
identified by your implementing agency, keep records demonstrating
compatibility for as long as the LIST system stores the regulated substance.
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Checklist For Statistical Inventory Reconciliation (For Tanks And Piping)
UPDATED
UPDATED
UPDATED
UPDATED
UPDATED
UPDATED
Statistical Inventory Reconciliation (For Tanks And Piping)
Description
Perform
These O&M
Actions
Keep These
O&M
Records
Statistical inventory reconciliation (SIR) is typically a method in which a trained
professional uses sophisticated computer software to conduct a statistical analysis of
inventory, delivery, and dispensing data. You must supply the professional with data
every month. Computer programs enable an owner or operator to perform SIR. In
either case, the result of the analysis may be pass, inconclusive, or fail.
D Supply daily inventory data to your SIR vendor at least every 30 days or use your
computer software at least every 30 days to test your tank for leaks.
D If your SIR method ever fails a test or indicates a release, see Section 3 for
information on what to do next.
D If you receive an inconclusive result, you and your SIR vendor must correct the
problem and use another method of release detection if SIR results are
inconclusive. An inconclusive result means that you have not performed release
detection for that month. If you cannot resolve the problem, treat the inconclusive
result as a suspected leak and refer to Section 3.
D No later than October 13, 2018, you must begin performing periodic
walkthrough inspections. See Section 6 for more information about these
required walkthrough inspections.
D No later than October 13, 2018, you must begin inspecting and testing your
release detection system every year. If you use an ATG system to gather SIR
data, annually test your ATG system. At a minimum, test the alarm, battery
backup, and verify the system configuration. For probes and sensors, you
must inspect for residual buildup, ensure floats move freely, ensure the shaft
is not damaged, ensure accessible cables are free of kinks and breaks, and
test alarm operability and communication with controller.
D If you stick your tank to gather data for the SIR vendor or your software, make sure
your stick can measure to one-eighth of an inch and can measure the level of
product over the full range of the tank's height.
D Make sure employees who run, monitor, or maintain the release detection system
know exactly what they have to do and to whom to report problems. No later than
October 13, 2018, LIST owners must have designated and trained operators.
Most states already require operator training.
D Keep results of your 30-day release detection monitoring for at least one year.
D Keep results for your annual release detection system operation tests for at
least three years.
D Keep all records of calibration, maintenance, and repair of your release detection
equipment for at least one year.
D Keep any schedules of required calibration and maintenance provided by the
release detection equipment manufacturer for at least five years from the date of
installation.
D Keep all performance claims supplied by the installer, vendor, or manufacturer for at
least five years. This includes the documentation of the SIR method discussed
above.
D Keep your periodic walkthrough inspection records for at least one year.
D If you store regulated substances containing greater than 10 percent ethanol
or greater than 20 percent biodiesel or any other regulated substance
identified by your implementing agency, keep records demonstrating
compatibility for as long as the LIST system stores the regulated substance.
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Checklist For Continuous In-Tank Leak Detection
UPDATED
UPDATED
UPDATED
UPDATED
UPDATED
UPDATED
Continuous In-Tank Leak Detection
Description
Perform
These O&M
Actions
Keep These
O&M
Records
Continuous in-tank leak detection (CITLD) encompasses all statistically based methods
where the system incrementally gathers measurements on an uninterrupted or nearly
uninterrupted basis to determine a tank's leak status. There are two major groups that
fit into this category: continuous statistical leak detection (also referred to as continuous
automatic tank gauging methods) and continual reconciliation. Both groups typically
use sensors permanently installed in the tank to obtain inventory measurements. They
are combined with a microprocessor in the ATG system or other control console that
processes the data. Continual reconciliation methods are further distinguished by their
connection to dispensing meters that allow for automatic recording and use of
dispensing data in analyzing tanks' leak status.
CITLD must operate on an uninterrupted basis or operate within a process that allows
the system to gather incremental measurements to determine the leak status of the tank
at least once every 30 days.
D No later than October 13, 2018, you must begin performing periodic
walkthrough inspections. See Section 6 for more information about these
required walkthrough inspections.
D No later than October 13, 2018, you must begin inspecting and testing your
release detection system every year. At a minimum, test the alarm, battery
backup, and verify the system configuration. For probes and sensors, you
must inspect for residual buildup, ensure floats move freely, ensure the shaft
is not damaged, ensure accessible cables are free of kinks and breaks, and
test alarm operability and communication with controller.
D If your CITLD method ever fails a test or indicates a release, see Section 3 for
information on what to do next.
D Make sure employees who run, monitor, or maintain the release detection system
know exactly what they have to do and to whom to report problems. No later than
October 13, 2018, LIST owners must have designated and trained operators.
Most states already require operator training.
D
D
Keep results of your 30-day release detection monitoring for at least one year. Your
monitoring equipment may provide printouts that can be used as records. A sample
30 day recordkeeping form is provided on page 25.
Keep results for your annual release detection system operation tests for at
least three years.
Keep all records of calibration, maintenance, and repair of your release detection
equipment for at least one year.
Keep any schedules of required calibration and maintenance provided by the
release detection equipment manufacturer for at least five years from the date of
installation.
Keep all performance claims supplied by the installer, vendor, or manufacturer for at
least five years.
Keep your periodic walkthrough inspection records for at least one year.
If you store regulated substances containing greater than 10 percent ethanol
or greater than 20 percent biodiesel or any other regulated substance
identified by your implementing agency, keep records demonstrating
compatibility for as long as the LIST system stores the regulated substance.
Operating And Maintaining Underground Storage Tank Systems
February 2016
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Checklist For Vapor Monitoring (For Tanks And Piping)
UPDATED
UPDATED
UPDATED
UPDATED
UPDATED
UPDATED
Vapor Monitoring (For Tanks And Piping)
Description
Perform
These O&M
Actions
Keep These
O&M
Records
Vapor monitoring checks for leaks by measuring product vapors in the soil at the LIST
site. A site assessment determines the number and placement of monitoring wells.
Please note that vapor monitoring will not work well with substances, such as diesel
fuel, that do not easily vaporize.
D No later than October 13, 2018, if you use vapor monitoring for release
detection, you must demonstrate proper installation and performance
through a site assessment. You must maintain a site assessment for as long
as vapor monitoring is used for release detection at your facility. Site
assessments completed after October 13, 2015 must be signed by a licensed
professional.
D No later than October 13, 2018, you must begin performing periodic
walkthrough inspections. These inspections include checking your hand-
held equipment for operability and serviceability. See Section 6 for more
information about these required walkthrough inspections.
D Use your release detection system to test for leaks at least every 30 days. Testing
more often than every 30 days can identify leaks sooner and reduce cleanup costs
and problems. Check all of your vapor monitoring wells.
D If your vapor monitoring method ever fails a test or indicates a release, see Section
3 for information on what to do next.
D No later than October 13, 2018, you must begin inspecting and testing your
release detection system every year. If you use permanently installed
electronic equipment for vapor monitoring, at a minimum, test the alarm,
battery backup, and verify the system configuration. For probes and sensors,
you must inspect for residual buildup, ensure floats move freely, ensure the
shaft is not damaged, ensure accessible cables are free of kinks and breaks,
and test alarm operability and communication with controller.
D Clearly mark and secure your vapor monitoring wells.
D Make sure employees who run, monitor, or maintain the release detection system
know exactly what they have to do and to whom to report problems. No later than
October 13, 2018, LIST owners must have designated and trained operators.
Most states already require operator training.
D Keep results of your 30-day release detection monitoring for at least one year. Your
monitoring equipment may provide printouts that can be used as records. See
page 25 for a sample 30 day recordkeeping form.
D Keep results for your annual release detection system operation tests for at
least three years.
D Keep all records of calibration, maintenance, and repair of your release detection
equipment for at least one year.
D Keep any schedules of required calibration and maintenance provided by the
release detection equipment manufacturer for at least five years from the date of
installation.
D Keep all performance claims supplied by the installer, vendor, or manufacturer for at
least five years.
D Keep your periodic walkthrough inspection records for at least one year.
D If you store regulated substances containing greater than 10 percent ethanol
or greater than 20 percent biodiesel or any other regulated substance
identified by your implementing agency, keep records demonstrating
compatibility for as long as the LIST system stores the regulated substance.
Operating And Maintaining Underground Storage Tank Systems
February 2016
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Checklist For Groundwater Monitoring (For Tanks And Piping)
Groundwater Monitoring (For Tanks And Piping)
Description
Groundwater monitoring looks for the presence of liquid product floating on groundwater at
the LIST site. To ensure a leak is detected, follow the site assessment plan, which
determines the number and placement of monitoring wells. Note that this method cannot be
used at sites where groundwater is more than 20 feet below the surface.
UPDATED
UPDATED
Perform
These O&M
Actions
UPDATED
UPDATED
D No later than October 13, 2018, if you use groundwater monitoring for release
detection, you must demonstrate proper installation and performance through a
site assessment. You must maintain a site assessment for as long as groundwater
monitoring is used for release detection at your facility. Site assessments
completed after October 13, 2015 must be signed by a licensed professional.
D No later than October 13, 2018, you must begin performing periodic walkthrough
inspections. These inspections include checking your hand-held equipment for
operability and serviceability. See Section 6 for more information about these
required walkthrough inspections.
D Use your release detection system to test for leaks at least every 30 days. Testing more
often than every 30 days can identify leaks sooner and reduce cleanup costs and
problems. Check all of your groundwater monitoring wells.
D If your groundwater monitoring method ever fails a test or indicates a release, see
Section 3 for information on what to do next.
D No later than October 13, 2018, you must begin inspecting and testing your release
detection system every year. If you use permanently installed electronic
equipment for groundwater monitoring, at a minimum, test the alarm, battery
backup, and verify the system configuration. For probes and sensors, you must
inspect for residual buildup, ensure floats move freely, ensure the shaft is not
damaged, ensure accessible cables are free of kinks and breaks, and test alarm
operability and communication with controller.
D Clearly mark and secure your groundwater monitoring wells.
D Make sure employees who run, monitor, or maintain the release detection system know
exactly what they have to do and to whom to report problems. No later than October
13, 2018, LIST owners must have designated and trained operators. Most states
already require operator training.
UPDATED
Keep
These O&M
Records
UPDATED
UPDATED
D Keep results of your 30-day release detection monitoring for at least one year. Your
monitoring equipment may provide printouts that can be used as records. See page 25
for a sample 30 day recordkeeping form.
D Keep results for your annual release detection system operation tests for at least
three years.
D Keep all records of calibration, maintenance, and repair of your release detection
equipment for at least one year.
D Keep any schedules of required calibration and maintenance provided by the release
detection equipment manufacturer for at least five years from the date of installation.
D Keep all performance claims supplied by the installer, vendor, or manufacturer for at least
five years.
D Keep your periodic walkthrough inspection records for at least one year.
D If you store regulated substances containing greater than 10 percent ethanol or
greater than 20 percent biodiesel or any other regulated substance identified by
your implementing agency, keep records demonstrating compatibility for as long
as the LIST system stores the regulated substance.
Operating And Maintaining Underground Storage Tank Systems
February 2016
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Checklist For Inventory Control And Tank Tightness Testing (For Tanks)
Inventory Control And Tank Tightness Testing (For Tanks)
Description
UPDATED
This temporary method combines monthly inventory control with periodic tank tightness
testing. Inventory control involves taking measurements of tank contents and recording the
amount of product pumped each operating day, measuring and recording tank deliveries,
and reconciling all this data at least once a month. This combined method also includes
tank tightness testing, a sophisticated test performed by trained professionals.
Please note that this combination method can only be used temporarily, for up to 10 years
after your LIST was installed. You may no longer use this method after April 11, 2026
because tanks and piping installed or replaced after April 11, 2016 must have
secondary containment and interstitial monitoring.
Perform
These O&M
Actions
UPDATED
UPDATED
D Take inventory readings and record the numbers at least each day that product is added
to or taken out of the tank. You may use the sample daily inventory worksheet on page
18.
D Reconcile the fuel deliveries with delivery receipts by taking inventory readings before
and after each delivery. Record these readings on a daily inventory worksheet on page
18.
D Reconcile all your data at least every 30 days. Use a monthly inventory record; see the
sample on page 19.
D Conduct a tank tightness test at least every five years. A professional trained in
performing tank tightness testing must conduct this test.
D See Section 3 if your tank fails a tightness test or fails two consecutive months of
inventory control.
D Ensure that your measuring stick can measure to the nearest one-eighth inch and can
measure the level of product over the full range of the tank's height.
D Ensure that your product dispenser is calibrated according to local standards or to an
accuracy of 6 cubic inches for every 5 gallons of product withdrawn.
D Measure the water in your tank to the nearest one-eighth inch at least once a month and
record the results on the reconciliation sheet. You can use a paste that changes color
when it comes into contact with water. If you find water in your tank, you must
investigate and determine the reason for its presence. The presence of water in your
tank is an unusual operating condition. You should remove the water as soon as
possible because it can cause problems such as corrosion and degrading fuel quality.
D No later than October 13, 2018, you must begin performing periodic walkthrough
inspections. These inspections include checking your tank gauging stick for
operability and serviceability. See Section 6 for more information about these
required walkthrough inspections.
D Make sure employees who run, monitor, or maintain the release detection system know
exactly what they have to do and to whom to report problems. No later than October
13, 2018, LIST owners must have designated and trained operators. Most states
already require operator training.
Keep
These O&M
Records
D Keep results of your 30-day release detection monitoring for at least one year. See the
sample daily inventory worksheet and monthly inventory record on pages 18 and 19,
respectively.
D Keep the results of your most recent tightness test.
D Keep all performance claim documentation for tank tightness tests performed at your
LIST site for at least five years.
D Keep your periodic walkthrough inspection records for at least one year.
Operating And Maintaining Underground Storage Tank Systems
February 2016
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Sample Daily Inventory Worksheet
Facility Name:
Your Name:
Date:
Date
Tank Identification
Type Of Fuel
Tank Size In Gallons
End Stick Inches
Amount Pumped
Totalizer Reading
Totalizer Reading
Totalizer Reading
Totalizer Reading
Totalizer Reading
Totalizer Reading
Totalizer Reading
Totalizer Reading
Today's Sum Of Totalizers
Previous Day's Sum Of Totalizers
Amount Pumped Today
Delivery Record
Inches Of Fuel Before Delivery
Gallons Of Fuel Before Delivery
(from tank chart)
Inches Of Fuel After Delivery
Gallons Of Fuel After Delivery
(from tank chart)
Gallons Delivered (Stick)
[Gallons After - Gallons Before]
Gross Gallons Delivered
(Receipt)
Operating And Maintaining Underground Storage Tank Systems
February 2016
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Sample Monthly Inventory Record
Month/Year:
Tank Identification; Type Of Fuel:
Facility Name:
Date Of Water Check:
Level Of Water (Inches):
Start Stick
Inventory
(Gallons)
Gallons
Pumped
Inventory
(Gallons)
Inventory
Daily Ove
Short (-)
' - Book]
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
Total Gallons Pumped >
Leak Check:
Drop the last two digits
from the Total Gallons
Pumped number and enter here:.
Total Gallons Over
Or Short >
e I n
v
130 =
Compare these | numbers
_ gallons
Is the total gallons over or short larger than leak check result? Yes No (circle one)
If your answer is Yes for 2 months in a row, notify your implementing agency as soon as possible.
Keep this record for at least one year.
Operating And Maintaining Underground Storage Tank Systems
February 2016
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Checklist For Manual Tank Gauging (For Tanks 1,000 Gallons Or Less)
UPDATED
UPDATED
UPDATED
Manual Tank Gauging (For Tanks 1,000 Gallons Or Less)
Description
Perform These
O&M Actions
Keep These
O&M Records
Manual tank gauging involves taking your tank out of service for at least 36 hours
during the test period each week. During that time, the contents of the tank are
measured twice at the beginning and twice at the end of the test period. The
measurements are then compared to weekly and monthly standards to determine
if the tank is tight.
This method may be used only for tanks of 1,000 gallons or less capacity meeting
certain requirements. These requirements -tank size, tank dimension, and test
time - are listed on page 21 in the sample manual tank gauging record.
D Once a week, record two inventory readings at the beginning of the test, allow
the tank to sit undisturbed for the time specified in the sample manual tank
gauging record on page 21, and record two inventory readings at the end of
the test.
D Reconcile the numbers weekly and record them on a manual tank gauging
record; see page 21.
D At the end of four weeks, reconcile your records for the monthly standard and
record the result on a manual tank gauging record; see page 21.
D See Section 3 if your tank fails the weekly standard or monthly standard.
D Ensure that your measuring stick can measure to the nearest one-eighth inch
and can measure the level of product over the full range of the tank's height.
D No later than October 13, 2018, you must begin performing periodic
walkthrough inspections. These inspections include checking your
tank gauging stick for operability and serviceability. See Section 6 for
more information about these required walkthrough inspections.
D Make sure employees who run, monitor, or maintain the release detection
system know exactly what they have to do and to whom to report problems.
No later than October 13, 2018, LIST owners must have designated and
trained operators. Most states already require operator training.
D Keep results of your 30-day release detection monitoring for at least one year.
See the sample manual tank gauging record on page 21.
D Keep your periodic walkthrough inspection records for at least one
year.
Operating And Maintaining Underground Storage Tank Systems
February 2016
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Sample Manual Tank Gauging Record
Month: Year_
Tank Identification:
Person Completing Form:
Facility Name:
Tank Size
Up to 550 gallons
551 -1,000 gallons
(when tank diameter is 64")
551 -1,000 gallons
(when tank diameter is 46")
551 -1,000 gallons
(also requires periodic tank
tightness testing)
1,001 -2,000 gallons
(also requires periodic tank
tightness testing)
Minimum
Duration Of Test
36 hours
44 hours
58 hours
36 hours
36 hours
Weekly Standard
(1 test)
10 gallons
9 gallons
12 gallons
13 gallons
26 gallons
Monthly Standard
(4-test average)
5 gallons
4 gallons
6 gallons
7 gallons
13 gallons
Compare your weekly readings and the monthly average of the 4 weekly
readings with the standards shown in the table on the left.
If the calculated change exceeds the weekly standard, the LIST may be leaking.
Also, the monthly average of the 4 weekly test results must be compared to the
monthly standard in the same way.
If either the weekly or the monthly standards have been exceeded, the LIST may
be leaking. As soon as possible, call your implementing agency to report the
suspected leak and get further instructions.
Start Test (month,
day, and time)
Date:
Time: AM/PM
Date:
Time: AM/PM
Date:
Time: AM/PM
Date:
Time: AM/PM
First Initial
Stick
Reading
Second
Initial
Stick
Reading
Average
Initial
Reading
Initial
Gallons
(convert
inches to
gallons
[a])
End Test (month,
day, and time)
Date:
Time: AM/PM
Date:
Time: AM/PM
Date:
Time: AM/PM
Date:
Time: AM/PM
First
End
Stick
Reading
Keep this record for at least one year.
Second End
Stick
Reading
Average
End
Reading
End Gallons
(convert
inches to
gallons [b])
To see how close you are to the monthly
standard, divide the sum of the 4 weekly
readings by 4 and enter result here
Change In
Tank
Volume In
Gallons
-or(-)
[a-b]
Tank
Passes
Test
(circle
YorN)
Y N
Y N
Y N
Y N
Y N
Operating And Maintaining Underground Storage Tank Systems
February 2016
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Checklist For Manual Tank Gauging And Tank Tightness Testing (For Tanks 2,000
Gallons Or Less)
UPDATED
UPDATED
UPDATED
UPDATED
Manual Tank Gauging And Tank Tightness Testing (For Tanks 2,000 Gallons Or Less)
Description
Perform
These O&M
Actions
Keep These
O&M Records
This method combines manual tank gauging with periodic tank tightness testing. It
may be used only for tanks of 2,000 gallons or less capacity. Manual tank gauging
involves taking your tank out of service for at least 36 hours during the test period
each week. During that time, the contents of the tank are measured twice at the
beginning and twice at the end of the test period. The measurements are then
compared to weekly and monthly standards to determine if the tank is tight. This
combined method also includes tank tightness testing, a sophisticated test
performed by trained professionals.
Please note that this combination method can only be used temporarily, for up to 10
years after your LIST was installed. You may no longer use this method after
April 11, 2026 because tanks and piping installed or replaced after April 11,
2016 must have secondary containment and interstitial monitoring.
D
D
Once a week, record two inventory readings at the beginning of the test, allow
the tank to sit undisturbed for the time specified in the sample manual tank
gauging record on page 21, and record two inventory readings at the end of the
test.
Reconcile the numbers weekly and record them on a manual tank gauging
record; see page 21.
At the end of four weeks, reconcile your records for the monthly standard and
record the result on a manual tank gauging record; see page 21.
Conduct a tank tightness test at least every five years. This testing needs to be
conducted by a professional trained in performing tank tightness testing.
See Section 3 if your tank fails the tightness test, weekly standard, or monthly
standard.
Ensure that your measuring stick can measure to the nearest one-eighth inch
and can measure the level of product over the full range of the tank's height.
No later than October 13, 2018, you must begin performing periodic
walkthrough inspections. These inspections include checking your tank
gauging stick for operability and serviceability. See Section 6 for more
information about these required walkthrough inspections.
Make sure employees who run, monitor, or maintain the release detection
system know exactly what they have to do and to whom to report problems. No
later than October 13, 2018, LIST owners must have designated and trained
operators. Most states already require operator training.
D Keep results of your 30-day release detection monitoring for at least one year.
See the sample manual tank gauging record on page 21.
D Keep your periodic walkthrough inspection records for at least one year.
Operating And Maintaining Underground Storage Tank Systems
February 2016
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Checklist For Automatic Line Leak Detection (For Pressurized Piping)
UPDATED
UPDATED
UPDATED
UPDATED
Automatic Line Leak Detection (For Pressurized Piping)
Description
Perform
These O&M
Actions
Keep These
O&M Records
Automatic line leak detectors (LLDs) are designed to detect a catastrophic leak from
pressurized piping. Automatic LLDs must be designed to detect a leak at least as
small as 3 gallons per hour at a line pressure of 10 pounds per square inch within
one hour. When a leak is detected, automatic LLDs must shut off the product flow,
restrict the product flow, or trigger an audible or visual alarm. Please note that
mechanical LLDs need to be installed and operated as close as possible to the tank.
LLDs are designed to detect a leak, restrict flow, or trigger an alarm only between
the detector and the dispenser.
D No later than October 13, 2018, you must begin inspecting and testing your
release detection system, including LLDs, every year. You must test your
LLDs by simulating a leak, which evaluates the LLDs' ability to detect a
leak.
D See Section 3 if your LLDs detect a release.
D Make sure employees who run, monitor, or maintain the release detection
system know exactly what they have to do and to whom to report problems. No
later than October 13, 2018, LIST owners must have designated and trained
operators. Most states already require operator training.
D Keep results for your annual release detection system operation tests for
at least three years.
D Keep all records of calibration, maintenance, and repair of your release detection
equipment for at least one year.
D Keep any schedules of required calibration and maintenance provided by the
release detection equipment manufacturer for at least five years from the date of
installation.
D Keep all performance claims supplied by the installer, vendor, or manufacturer
for at least five years.
D If you store regulated substances containing greater than 10 percent
ethanol or greater than 20 percent biodiesel or any other regulated
substance identified by your state LIST agency, keep records
demonstrating compatibility for as long as the LIST system stores the
regulated substance.
Operating And Maintaining Underground Storage Tank Systems
February 2016
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Checklist For Line Tightness Testing (For Piping)
UPDATED
UPDATED
UPDATED
UPDATED
Line Tightness Testing (For Piping)
Description
Perform
These O&M
Actions
Keep These
O&M Records
This method uses a periodic line tightness test to determine if your piping is leaking.
Tightness testing can be performed by either a trained professional or by using a
permanently installed electronic system, which is sometimes connected to an
automatic tank gauging system.
D
If you have pressurized piping and use line tightness testing, you must conduct
the test at least annually.
If you have suction piping and use line tightness testing, you must conduct the
test at least every three years. Safe suction piping, as described at the bottom
of page 5, does not need release detection.
You must have this tightness testing conducted by a professional trained in
performing line tightness testing or use a permanently installed electronic
system.
See Section 3 if your piping fails the tightness test or if the electronic system
indicates a release.
No later than October 13, 2018, you must begin inspecting and testing your
release detection system, including LLDs, every year. You must test your
LLDs by simulating a leak, which evaluates the LLDs' ability to detect a
leak.
Make sure employees who run, monitor, or maintain the release detection
system know exactly what they have to do and to whom to report problems. No
later than October 13, 2018, LIST owners must have designated and trained
operators. Most states already require operator training.
D Keep results of your most recent line tightness test. Keep any results for your
electronic release detection equipment operation and maintenance tests for at
least three years. Your monitoring equipment may provide printouts, which can
be used as records.
D If using an electronic line leak detector for tightness testing, keep results
for your annual release detection system operation tests for at least three
years.
D Keep all records of calibration, maintenance, and repair of your release detection
equipment for at least one year.
D Keep any schedules of required calibration and maintenance provided by the
release detection equipment manufacturer for at least five years from the date of
installation.
D Keep all performance claims supplied by the installer, vendor, or manufacturer
for at least five years.
D If you store regulated substances containing greater than 10 percent
ethanol or greater than 20 percent biodiesel or any other regulated
substance identified by your implementing agency, keep records
demonstrating compatibility for as long as the LIST system stores the
regulated substance.
Operating And Maintaining Underground Storage Tank Systems
February 2016
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Sample 30-Day Release Detection Monitoring Record
(May be used for monitoring wells, interstitial monitoring, automatic tank gauging, and CITLD)
Release Detection Method:_
Facility Name:_
—
ur Name
LIST System (Tank And Piping,
(Enter N for No Release Detected or Y for a Suspecte
"V Confirmed Relea N
Keep this record and associated printouts for
at least one year from the date of the last entry.
Operating And Maintaining Underground Storage Tank Systems
February 2016
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Section 3:
Suspected Or
Confirmed Releases
You must be fully prepared to respond to releases before
they occur. You must know what to do when release
detection methods indicate a suspected or confirmed release.
Be ready to take the following steps, as appropriate, if you
have a release.
Stop The Release
• Take immediate action to prevent the release of more
product.
• Use the emergency shutoff switch to stop the flow of
product. (Make sure you know where your
emergency shutoff switch is located.)
• Turn off the power to the dispenser and place a bag
over the nozzle.
• Identify any fire, explosion, or vapor hazards and
take action to neutralize these hazards.
• Empty the tank, if necessary, without further
contaminating the site. You may need the assistance
of your supplier or distributor.
Page 29 is a blank form to
list names and phone
numbers of important
contacts. Fill out this
information for your facility
so that you will know who
to call in case of an
emergency. Print this page
from the booklet, fill it out,
and post it in a prominent
place at your facility.
Print multiple copies of page
29 and update it often.
Make sure everyone at your
UST facility is familiar with
this list of contacts.
Call For Help
• Contact your local fire or emergency response
authority. Make sure you have these crucial
telephone numbers prominently posted where you
and your employees can easily see them.
Contain The Release
Contain, absorb, and clean up any surface spills or overfills.
You should keep enough absorbent material at your facility
to contain a spill or overfill of petroleum products until
emergency response personnel can respond to the incident.
The suggested supplies include, but are not limited to:
• Containment devices, such as containment booms,
dikes, and pillows.
Operating And Maintaining Underground Storage Tank Systems
February 2016
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• Absorbent material, such as kitty litter, chopped corn cob,
sand, and sawdust. Be sure you properly dispose of used
absorbent materials.
• Mats or other material capable of keeping spill or overfill
out of nearby storm drains.
• Spark-free flash light.
• Spark-free shovel.
• Buckets.
• Reels of caution tape, traffic cones, and warning signs.
• Personal protective gear.
Report To Authorities
If you observe any of the following, contact your implementing
agency to report a suspected or confirmed release as soon as
possible or within 24 hours:
• Any spill or overfill of petroleum that exceeds 25 gallons or
causes a sheen on nearby surface water. Spills and overfills
under 25 gallons that are contained and immediately
cleaned up do not have to be reported. If they cannot be
quickly cleaned up, you must report them to your
implementing agency.
• Any released regulated substances at the UST site or in the
surrounding area — such as the presence of liquid
petroleum; soil contamination; surface water or
groundwater contamination; or petroleum vapors in sewer,
basement, or utility lines.
• Any unusual operating conditions you observe — such as
erratic behavior of the dispenser, a sudden loss of product,
unexplained presence of water in the tank, or liquid in the
interstitial space of secondarily-contained systems.
However, you are not required to report if:
o The system equipment is found to be defective, but
did not have a release, and is immediately repaired
or replaced.
o For secondarily-contained systems, any liquid in the
interstitial space not used as part of the interstitial
monitoring method is immediately removed (for
example, fuel in the interstitial space of a
monitoring system intended to be operated with
brine).
• Results from your release detection system, including
investigation of an alarm, indicate a suspected release.
However, you are not required to report if:
o The monitoring device is found to be defective and
is immediately repaired, recalibrated, or replaced
and further monitoring does not confirm the initial
suspected release; or
Operating And Maintaining Underground Storage Tank Systems
February 2016
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o The leak is contained in the secondary containment
and any liquid in the interstitial space not used as
part of the interstitial monitoring method is
immediately removed and any defective system
equipment or component is immediately repaired or
replaced; or
o In the case of inventory control, a second month of
data does not confirm the initial result or the
investigation determines no release has occurred; or
o The alarm was investigated and determined to be a
non-release event; for example, from a power surge
or caused by filling the tank during release detection
testing.
Operating And Maintaining Underground Storage Tank Systems
February 2016
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Release Response
Important Contact Information
Contact Name
Phone#
Implementing LIST
Agency:
Local LIST Agency:
Fire Department:
Ambulance:
Police Department:
Repair Contractor:
Other Contacts:
Release Response Checklist
D Stop the release: Take immediate action to prevent the release of more product.
Use the emergency shutoff switch to stop the flow of product. Turn off the power
to the dispenser and place a bag over the nozzle. Empty the tank, if necessary,
without further contaminating the site.
D Contain the release: Contain, absorb, and clean up any surface releases.
Identify any fire, explosion, or vapor hazards and take action to neutralize these
hazards.
D Call for help and to report suspected or confirmed releases: Contact your local
fire or emergency response authority. Contact your implementing agency within
24 hours.
Operating And Maintaining Underground Storage Tank Systems
February 2016
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Section 4:
Spill And Overfill Protectio,
UPDATED
UPDATED
The purpose of spill and overfill protection equipment is to
reduce the potential for a release during fuel deliveries. The
equipment must be in working order and used properly to
provide adequate protection from spills and overfills.
Even the best spill and overfill protection equipment can
become faulty over time if not properly operated and
maintained. Small fuel leaks from a poorly maintained spill
bucket can result in large amounts of contaminated soil over
time. And improperly operating overfill prevention
equipment can result in tank overfills.
The 2015 federal UST regulation requires operability
testing of spill buckets and inspections of overfill
prevention equipment once every three years. The test
must be conducted according to a code of practice,
manufacturer's instructions, or requirements developed
by the implementing agency. In addition, it requires
walkthrough inspections that look at spill equipment at
least every 30 days. Records of walkthrough inspections
must be kept and must include a list of each area
checked, whether each area checked was acceptable or
needed action, and a description of actions taken to
correct an issue. If owners and operators receive
deliveries less frequently than every 30 days, spill
prevention equipment may be checked prior to each
delivery. Delivery records must be maintained if spill
prevention equipment is checked less frequently than
every 30 days.
If you repair your spill or overfill prevention equipment,
you must test or inspect, as appropriate, the equipment
within 30 days after the repair.
The following pages focus on how you can routinely make
sure your spill and overfill equipment are operating
effectively.
What Is The Difference?
Spill Protection
A spill bucket is installed at
the fill pipe to contain the
drips and spills of fuel that
can occur when the delivery
hose is uncoupled from the
fill pipe after delivery.
Overfill Protection
Equipment is installed on
the UST and designed to
stop product flow, reduce
product flow, or alert the
delivery person during
delivery that the tank is
nearing full capacity. This
allows the person filling the
tank to stop product
delivery before the tank
becomes full and begins
releasing product into the
environment.
Operating And Maintaining Underground Storage Tank Systems
February 2016
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What Are The Basics Of Spill Protection?
Your USTs must have spill buckets — also called catchment
basins — installed at the fill pipe to contain small-volume spills
that may occur as a result of fuel deliveries.
• Spill buckets are designed to temporarily contain product
spills that might occur during fuel delivery. To contain a
spill, the spill bucket must be liquid tight.
• Spill buckets are not designed to contain fuel for long
periods. After each delivery, empty and dispose of
contents properly.
• Spill buckets need to be large enough to contain any fuel
that may spill when the delivery hose is uncoupled from the
fill pipe. Spill buckets typically range in size from 5
gallons to 15 gallons.
• If you use correct delivery practices such as the ones
described on page 41, spills should be eliminated or
reduced to very small volumes that your spill bucket can
easily handle.
The checklist on the next page provides information on properly
maintaining your spill bucket.
FILL PIPE
Your equipment supplier can
help you choose the size and
type of spill bucket that
meets your needs.
If your UST only receives
deliveries of 25 gallons or
less at a time, the UST does
not need to meet the spill
and overfill protection
requirements. Many used oil
tanks fall into this category.
Even though these USTs are
not required to have spill
and overfill protection, you
should consider using spill
and overfill protection as
part of good UST system
managemt
Operating And Maintaining Underground Storage Tank Systems
February 2016
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Checklist For Spill Buckets
UPDATED
UPDATED
UPDATED
UPDATED
UPDATED
UPDATED
Description
Perform
These O&M
Actions
Keep These
O&M Records
Spill Buckets
Spill buckets are basins installed at the fill pipe to temporarily contain product spills
that may occur during fuel delivery.
D
No later than October 13, 2018, you must conduct your first 30 day
walkthrough inspection. Note that if you receive deliveries less frequently
than every 30 days, you may check your spill bucket before each delivery.
o Visually check for any damage to the spill bucket.
o Remove any liquid or debris from the spill bucket.
o Check for and remove any obstructions, such as tank gauging sticks,
in the fill pipe.
o Make sure your fill cap is securely fastened.
o If you have a double-walled spill bucket with interstitial monitoring,
check your interstitial monitoring device for a leak into the interstitial
area.
No later than October 13, 2018, you must conduct the first 3 year test of
your spill bucket. This test should be conducted by a person qualified to
conduct spill bucket testing. If you use a double-walled spill bucket and
check the interstitial space of your spill bucket for leaks during the
walkthrough inspection, then this testing is not required.
D Keep records of your spill bucket testing for three years or keep
documentation showing the spill bucket is double-walled and the integrity
of both walls is periodically monitored for as long as spill bucket testing is
not performed. See a sample recordkeeping form for this test on page 33.
D Keep records of your periodic walkthrough inspections for one year.
D Keep delivery records for one year if you conduct walkthrough inspections
of your spill bucket less frequently than every 30 days.
D If you store regulated substances containing greater than 10 percent
ethanol or greater than 20 percent biodiesel (or any other regulated
substance identified by your implementing agency), you must keep records
demonstrating compatibility of all LIST system components in contact with
the regulated substance, including spill buckets, for as long as the LIST
system stores the regulated substance.
Operating And Maintaining Underground Storage Tank Systems
February 2016
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Sample Recordkeeping Form For Liquid Tightness Tests For Spill Buckets And
Containment Sumps (For Use By A Qualified Tester)
Test Date:
Facility Name/ID:
Tank number
Product stoi
Spill bucket/cont;
Spill bucket/cont;
manufacture
Liquid or debris
bucket/sump?* ( _.._,
Visual inspection (no cracks, loose
parts, or separation) (circle on^
Starting water or vacui
Test start tir
Ending water or
Test end tim
Test dui
Water or va.
Test results (circle one)*
Comments
Yes / No
Pass / Fail
Pass / Fail
Yes / No
Pass / Fail
Pass / Fail
Yes / No
Pass / Fail
Pass / Fail
Yes / No
Pass / Fail
Pass / Fail
Yes / No
Pass / Fail
Pass / Fail
* All liquids and debris must be disposed of properly.
** Pass or fail criteria are based on the method used for testing. For example, EPA allows the Petroleum
Equipment Institute's Recommended Practice 1200 to be used for this testing. This code of practice
contains information about the pass or fail criteria.
Notes:
Testing company:.
Tester's name:
Tester's signature:.
Keep this record for three years.
Operating And Maintaining Underground Storage Tank Systems
February 2016
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UPDATED
What Are The Basics Of Overfill Protection?
Your USTs must have overfill protection installed to help prevent
overfilling of tanks.
Three types of overfill protection devices are commonly used:
• Automatic shutoff devices
• Overfill alarms
• Ball float valves, also referred to as flow restrictors or float
vent valves
These forms of overfill protection are discussed in detail on the
following pages.
Note that ball float valves may not be installed or replaced for
use as overfill protection after October 13, 2015.
How Can You Help The Delivery Person Avoid Overfills?
To protect your business, you must make every effort to help the
delivery person avoid overfilling your UST.
• Use correct filling practices. If correct filling practices are
used, you will not exceed the UST's capacity — see page
41 for a checklist of correct filling practices. Overfills can
result when the delivery person makes a mistake, such as
ignoring an overfill alarm.
• Use signs; alert your delivery person. The delivery person
should know what type of overfill device is present on each
tank at your facility and what action will occur if the
overfill device is triggered — such as a visual or audible
alarm or that the product flow into the tank will stop or
slow significantly. Educate and alert your delivery person
by placing a sign near your fill pipes, in plain view of the
delivery person. See the example below.
Delivery Person - Avoid Overfills
An overfill alarm is used for overfill protection at this facility.
Do not tamper with this alarm or attempt to defeat its purpose.
When the tank is 90% full, the overfill alarm whistles and a red light
flashes.
If you hear the alarm whistle or see the red light flashing, stop the
delivery immediately.
Operating And Maintaining Underground Storage Tank Systems
February 2016
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Make sure you order the right amount of product. Order
only the quantity of fuel that will fit into 90 percent of the
tank. For example, if you have a 10,000 gallon tank with
2,000 gallons already in the tank, you would order at most
a 7,000 gallon delivery (90 percent of 10,000 is 9,000
gallons; subtracting the 2,000 gallons already in the tank
leaves a maximum delivery of 7,000 gallons). Use the
formula on page 41. Calculate carefully and reduce the
chance of overfills.
What Should You Do To Operate And Maintain Your
Automatic Shutoff Device?
The automatic shutoff device is a mechanical device installed in
line with the drop tube in the fill pipe riser. It slows down and
stops delivery when product reaches a certain level in the tank. It
must be positioned so that the float arm is unobstructed and can
move through its full range of motion.
When installed and maintained properly, the shutoff valve will shut
off the flow of fuel to the UST at 95 percent of the tank's capacity
or before the fittings at the top of the tank are exposed to fuel.
The checklist on the next page provides information on properly
maintaining your automatic shutoff device.
FILL PIPE
SHUTOFF VALVE
FLOAT
Automatic shutoff device
You should not use an
automatic shutoff device for
overfill protection if your
UST receives pressurized
deliveries.
Operating And Maintaining Underground Storage Tank Systems
February 2016
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Checklist For Automatic Shutoff Devices
UPDATED
UPDATED
UPDATED
Automatic Shutoff Devices
Description
Perform
These O&M
Actions
Keep These
O&M Records
Automatic shutoff devices are mechanical devices installed in the fill pipe riser to slow
down and stop delivery when product reaches a certain level in the tank.
No later than October 13, 2018, you must conduct the first 3 year inspection
of your overfill device. This inspection should be conducted by a person
qualified to conduct overfill inspections. The purpose of the inspection is to
make sure the automatic shutoff device is functioning properly and the
device will shut off fuel flowing into the tank at 95 percent of the tank
capacity or before the fittings at the top of the tank are exposed to fuel. See
page 42 for a sample recordkeeping form for overfill equipment inspections.
o Make sure the float operates properly.
o Make sure there are no obstructions in the fill pipe that would keep the
floating mechanism from working.
You should post signs that the delivery person can easily see and that alert the
delivery person to the overfill warning devices and alarms in use at your facility.
D You must maintain all records of the inspection for three years.
D If you store regulated substances containing greater than 10 percent
ethanol or greater than 20 percent biodiesel (or any other regulated
substance identified by your implementing agency), you must keep records
demonstrating compatibility of all LIST system components in contact with
the regulated substance, including overfill prevention equipment, for as
long as the LIST system stores the regulated substance.
Operating And Maintaining Underground Storage Tank Systems
February 2016
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What Should You Do To Operate And Maintain Your
Electronic Overfill Alarm?
This type of overfill device activates an audible or visual warning
to delivery personnel when the tank is either 90 percent full or is
within one minute of being overfilled. The alarm must be located
so it can be seen or heard from the UST delivery location. Once
the electronic overfill alarm sounds, the delivery person has
approximately one minute to stop the flow of fuel to the tank.
Electronic overfill alarm devices have no mechanism to shut off or
restrict flow. Therefore, the fuel remaining in the delivery hose
after the delivery has been stopped will flow into the tank as long
as the tank is not yet full.
The checklist on the next page provides information on properly
maintaining your overfill alarm.
Automatic
Tank Gauge
~;J-T TTT |
In-Tank
Inventory
Probe
Electronic
Housing
Product
Level Float
Water
Level
Float
Overfill alarm
Operating And Maintaining Underground Storage Tank Systems
February 2016
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Checklist For Overfill Alarms
UPDATED
UPDATED
UPDATED
Overfill Alarms
Description
Perform
These O&M
Actions
Keep These
O&M Records
Overfill alarms activate an audible or visual warning to delivery personnel when the
tank is either 90 percent full or is within one minute of being overfilled. Electronic
overfill alarm devices have no mechanism to shut off or restrict flow.
No later than October 13, 2018, you must conduct the first 3 year inspection
of your overfill device. This inspection should be conducted by a person
qualified to conduct overfill inspections. The purpose of the inspection is to
make sure the electronic overfill alarm is functioning properly and the alarm
activates when the fuel reaches 90 percent of the tank capacity or is within
one minute of being overfilled. See page 42 for a sample recordkeeping
form for overfill equipment inspections.
o Ensure that the alarm can be heard or seen from where the tank is
fueled.
o Make sure that the electronic device and probe are operating properly.
You should post signs that the delivery person can easily see and that alert the
delivery person to the overfill warning devices and alarms in use at your facility.
D You must maintain records of the inspection for three years.
D If you store regulated substances containing greater than 10 percent
ethanol or greater than 20 percent biodiesel (or any other regulated
substance identified by your implementing agency), you must keep records
demonstrating compatibility of all LIST system components in contact with
the regulated substance, including overfill prevention equipment, for as
long as the LIST system stores the regulated substance.
Operating And Maintaining Underground Storage Tank Systems
February 2016
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What Should You Do To Operate And Maintain Your
Ball Float Valve?
UPDATED
Ball float valves cannot be installed or replaced for use as
overfill protection after October 13, 2015. However, you may
continue using ball float valves already installed as long as they
operate properly.
The ball float valve — also called a flow restrictor or a float vent
valve — is installed at the vent pipe in the tank and restricts vapor
flow in an UST as the tank gets close to being full. The ball float
valve must be set at a depth that will restrict vapor flow out of the
vent line during delivery at 90 percent of the UST's capacity or 30
minutes prior to overfilling.
As the tank fills, the ball in the valve rises, restricting the flow of
vapors out of the UST during delivery. The flow rate of the
delivery will decrease noticeably and should alert the delivery
person to stop the delivery.
For ball float valves to work properly, the top of the tank must be
airtight so that vapors cannot escape from the tank. Everything
from fittings to drain mechanisms on spill buckets must be tight
and able to hold the pressure created when the ball float valve
engages.
The checklist on the next page provides information on properly
maintaining your ball float valves.
Ball float va.
You should not use a ball
float value for overfill
protection if your UST
receives pressured deliveries
or if your UST system has
suction piping or single point
(coaxial) stage 1 vapor
recovery.
Operating And Maintaining Underground Storage Tank Systems
February 2016
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Checklist For Ball Float Valves
UPDATED
UPDATED
UPDATED
Ball Float Valves
Description
Perform
These O&M
Actions
Keep These
O&M Records
Ball float valves are a type of overfill protection device that function by restricting vapor
flow in an LIST as the tank gets close to being full.
No later than October 13, 2018, you must conduct the first 3 year inspection
of your overfill device. This inspection should be conducted by a person
qualified to conduct overfill inspections. The purpose of the inspection is to
make sure the ball float valve is functioning properly and will restrict fuel
flowing into the tank at 90 percent of the tank capacity or 30 minutes prior to
overfilling. See page 42 for a sample recordkeeping form for overfill
equipment inspections.
o Ensure the air hole is not plugged.
o Make sure the ball cage is still intact.
o Ensure the ball still moves freely in the cage.
o Make sure the ball still seals tightly on the pipe.
You should post signs that the delivery person can easily see and that alert the
delivery person to the overfill warning devices and alarms in use at your facility.
D You must maintain records of the inspection for three years.
D If you store regulated substances containing greater than 10 percent
ethanol or greater than 20 percent iodiesel (or any other regulated
substance identified by your implementing agency), you must keep records
demonstrating compatibility of all LIST system components in contact with
the regulated substance, including overfill prevention equipment, for as
long as the LIST system stores the regulated substance.
Operating And Maintaining Underground Storage Tank Systems
February 2016
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What Are Your Responsibilities For 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 fuel 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
D Post clear signs that alert the delivery person to the overfill devices and alarms
in use at your facility.
D Make and record accurate readings for product and water in the tank before
fuel delivery.
D Order only the quantity of fuel that will fit into 90 percent of the tank.
D Remember, the formula for determining the maximum amount of gasoline to
order is:
(Tank capacity in gallons X 90%) - Product 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
D Ensure the delivery person knows the type of overfill device present at the tank
and what actions to perform if it activates.
D Review and understand the spill response procedures.
D Verify that your spill bucket is empty, clean, and will contain spills.
What To Do
While Your
USTs Are
Being Filled
D Keep fill ports locked until the delivery person requests access.
D Keep an accurate tank capacity chart available for the delivery person.
D The delivery person makes all hook-ups.
D 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 LIST at any time; and respond to any unusual condition, leak, or
spill that may occur during delivery.
D Keep response supplies readily available for use in case a spill or overfill
occurs; see section 3.
D Provide safety barriers around the fueling zone.
D Make sure there is adequate lighting around the fueling zone.
What To Do
After Your
USTs Are
Filled
D Following complete delivery, the delivery person is responsible for
disconnecting all hook-ups.
D Return spill response kit and safety barriers to proper storage locations.
D Make and record accurate readings for product and water in the tank after fuel
delivery.
D Verify the amount of fuel received.
D Make sure fill ports are properly secured.
D Ensure the spill bucket is free of product and clean up any small spills.
Operating And Maintaining Underground Storage Tank Systems
February 2016
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Sample Recordkeeping Form For Overfill Equipment Inspections
(For Use By A Qualified Inspector)
Inspection Date: / /
Facility Name/ID:
Tank number
Product st
Overfill equipme
Automatic
shutoff device
Ball float valve
Overfill alarm
Automatic
shutoff device
Ball float valve
Overfill alarm
Automatic
shutoff device
Ball float valve
Overfill alarm
Automatic
shutoff device
Ball float valve
Overfill alarm
Automatic
shutoff device
Ball float valve
Overfill alarm
Drop tube removed from tank?
Yes / No
Yes / No
Yes / No
Yes/No
Yes / No
Drop tube and float mechanisms
are free of debris?
Yes / No
Yes / No
Yes / No
Yes/No
Yes / No
Float moves freely without binding
and poppet moves into flow path?
Yes / No
Yes / No
Yes / No
Yes/No
Yes / No
Bypass valve in the drop tube (if
present) is open and free of
blockage?
Yes / No
Yes / No
Yes / No
Yes/No
Yes / No
Flapper is adjusted to shut off flow
at 95% capacity?
Yes / No
Yes / No
Yes / No
Yes/No
Yes / No
Electronic device and probe are
operating properly?
Yes / No
Yes / No
Yes / No
Yes/No
Yes / No
Alarm activates at 90% capacity or
within one minute of overfill?
Yes / No
Yes / No
Yes / No
Yes/No
Yes / No
Alarm can be heard or seen from
where the tank is fueled?
Yes / No
Yes / No
Yes / No
Yes/No
Yes / No
Tank top fittings are vapor-tight and
leak-free?
Yes / No
Yes / No
Yes / No
Yes / No
Yes / No
Ball float cage free of debris?
Yes / No
Yes / No
Yes / No
Yes / No
Yes / No
Ball is free of holes and cracks and
moves freely in cage?
Yes / No
Yes / No
Yes / No
Yes / No
Yes / No
Vent hole in pipe is open and near
top of tank?
Yes / No
Yes / No
Yes / No
Yes / No
Yes / No
Yes / No
Ball float pipe is proper length to
restrict flow at 90% capacity?
Inspection Results (Circle One)
(No to any question indicates a test Pass
failure.)
Yes / No
Yes / No
Yes / No
ass / Fail Pass / Fail Pass
Yes / No
ass / Fail
Comments
Inspecting company:
Inspector's name:
Inspector's signature:
Keep this record for three years.
Operating And Maintaining Underground Storage Tank Systems
February 2016
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'Jir -
Section 5:
Corrosion Protection
To prevent leaks, all parts of your UST system
that are in contact with the ground and routinely
contain product must be protected from
corrosion. The UST system includes the tank,
piping, and ancillary equipment, such as flexible
connectors, fittings, and pumps. Unprotected
metal UST components can deteriorate and leak
when underground electrical currents act upon
them.
One way to protect UST components from
corrosion is to make them with nonmetallic,
noncorrodible materials, such as USTs made of
or clad or jacketed with fiberglass reinforced
plastic or other noncorrodible materials.
Noncorrodible USTs like these do not require
O&M for corrosion protection.
UST components made from metal that are not
clad or jacketed with a noncorrodible material,
and that routinely contain product and are in
direct contact with the ground, must have
corrosion protection, typically cathodic
protection. In some cases, the interior of the
tank may be lined. These options require O&M.
Cathodic protection using sacrificial anode
systems - sacrificial anodes are buried and
attached to UST components for corrosion
protection by an anode attached to a tank.
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.
Cathodic protection using impressed current
systems - 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
Operating And Maintaining Underground Storage Tank Systems
February 2016
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UPDATED
UPDATED
on and operating to protect your UST system from
corrosion.
Corrosion protection using internal lining of the tank - this
corrosion protection option applies only to tanks installed
before December 22, 1988. These older tanks were
internally lined by trained professionals to meet the
corrosion protection requirements. Note that internal lining
may still be used in tanks for purposes other than corrosion
protection.
In the 2015 federal UST regulation, EPA revised the
internal lining requirement. Owners and operators must
permanently close tanks using internal lining as the sole
method of corrosion protection, if the internal lining
fails the periodic inspection and cannot be repaired
according to a code of practice.
The table below contains your corrosion protection options.
In addition to tanks and
piping, all other metal
components in direct contact
with the ground that
routinely hold product —
such as flexible connectors,
swing joints, fittings, and
pumps — most also be
protected from corrosion.
Noncorrodible Material
Steel Tank Clad Or Jacketed
With A Noncorrodible Material
Coated And Cathodically
Protected Steel Tanks Or
Piping
Cathodically Protected
Noncoated Steel Tanks Or
Piping
Internal Lining Of Tanks
Combination Of Cathodically
Protected Steel And Internal
Lining Of Tanks
Other Methods Used To
Achieve Corrosion Protection
The tank or piping is constructed of noncorrodible material.
Examples of cladding or jacket material include fiberglass and
urethane. Does not apply to piping.
Steel tank and piping are well coated with a dielectric material
and Cathodically protected. Cathodic protection may be provided
by sacrificial anodes or impressed current.
This option is only for steel tanks and piping installed before
December 22, 1988. Cathodic protection is usually provided by
an impressed current system.
In the 2015 federal UST regulation, EPA revised the internal
lining requirement; owners and operators must permanently
close tanks using internal lining as the sole method of
corrosion protection, if the internal lining fails the periodic
inspection and cannot be repaired according to a code of
practice. This option only pertained to steel tanks installed
before December 22, 1 988. A lining is applied to the inside of the
tank. Does not apply to piping.
This option is only for steel tanks installed before December 22,
1988. Cathodic protection is usually provided by an impressed
current system. Does not apply to piping.
If you have tanks or piping that do not meet any of the
descriptions above, check with your implementing agency to see
if your UST system meets the requirements for corrosion
protection. You also will need to ask about the operation,
maintenance, and recordkeeping requirements applicable to this
type of UST system.
Operating And Maintaining Underground Storage Tank Systems
February 2016
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Checklist For Corrosion Protection Systems Using Sacrificial Anodes Or
Impressed Current
Corrosion Protection (Sacrificial Anode And Impressed Current Systems)
Description
Cathodic protection is one way to protect LIST components from corrosion. Sacrificial
anode systems have buried anodes attached to LIST components; the anodes are
more electrically active than steel, so they suffer the destructive effects of corrosion
rather than the steel they are attached to.
Impressed current systems use 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.
Impressed current systems must also meet the additional requirements in the
checklist on the following page.
Perform
These O&M
Actions
D You must have a periodic test conducted by a qualified cathodic protection tester
to make sure your cathodic protection system is adequately protecting your LIST
system. This test needs to be conducted:
o Within six months of installation.
o At least every three years after the previous test.
o Within six months after any repairs to your LIST system:
• Make sure the cathodic protection tester is qualified to perform the test
and follows a standard code of practice to determine that test criteria
are adequate.
• If any test indicates your tanks are not adequately protected, you must
have a corrosion expert examine and fix your system.
• Testing more frequently can catch problems before they become big
problems.
Keep These
O&M Records
You must keep the results of at least the last two tests. See pages 48-49 for a
sample record for periodic testing of cathodic protection systems.
Operating And Maintaining Underground Storage Tank Systems
February 2016
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Checklist With Additional Requirements For Impressed Current Systems
Corrosion Protection (Additional Requirements For Impressed Current Systems)
Description
Perform
These O&M
Actions
Keep These
O&M Records
Impressed current systems use 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.
Impressed current systems must also meet the requirements in the checklist on
the previous page.
D You must inspect your rectifier at least every 60 days to make sure that it is
operating within normal limits.
o This inspection involves reading and recording the voltage and amperage
readouts on the rectifier. You or your employees can perform this periodic
inspection.
o Make sure your corrosion expert provided you with the rectifier's acceptable
operating levels so you can compare the readings you take with an
acceptable operating level. If your readings are not within acceptable
levels, you must contact a corrosion expert to address the problem.
D You should have a trained professional periodically service your impressed
current system.
D Never turn off your rectifier. If your rectifier is off, your LIST system is not
protected from corrosion.
D You must keep records of at least the last three rectifier readings. See page 50
for a sample 60-day impressed current cathodic protection system inspections
form.
Operating And Maintaining Underground Storage Tank Systems
February 2016
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Checklist For Internally Lined Tanks
UPDATED
Corrosion Protection (Internally Lined Tanks)
Description
Perform
These O&M
Actions
Keep These
O&M Records
Tanks installed before December 22, 1988, were internally lined by trained
professionals to meet the corrosion protection requirements.
D
P
P
Within 10 years after lining and at least every five years thereafter, the lined tank
must be inspected by a trained professional and found to be structurally sound
with the lining still performing according to original design specifications. Make
sure the professional performing the inspection follows a standard code of
practice.
You must permanently close tanks using internal lining as the sole method
of corrosion protection, if the internal lining fails the periodic inspection and
cannot be repaired according to a code of practice.
Keep records of the inspection, as specified in industry standards for lining
inspections.
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February 2016
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Sample Record For Periodic Testing Of Cathodic Protection Systems
(For Use By A Qualified Cathodic Protection Tester)
Test Date: / / Facility Name/ID:
Note: Draw site sketch in the space provided on the next page.
Cathodic Protection (CP) Tester Information:
Name: Phone Number:
Address:
A qualified CP tester must conduct testing. Indicate your qualifications as a CP tester:
Identify which of the following testing situations applies:
D Test required within six months of installation of CP system (installation date: _/_/__)
D Periodic three year test
D Test required within six months of any repair activity - note repair activity and date below:
repair activity: repair date: / /
Indicate which industry standard you used to determine that the cathodic protection test criteria are adequate:
Cathodic Protection Test Method Used (check one)
D 100 mV cathodic polarization test
D 850 mV test (circle one below)
• Polarized potential (instant off)
• Potential with CP applied, IR drop considered
Note: All readings taken must meet the -850 mV criteria to pass
D Other accepted method (please describe):
Is the cathodic protection system working properly? Yes No (circle one)
If answer is no, go to the directions at the bottom of the next page.
My signature below affirms that I have sufficient education and experience to be a cathodic protection tester; I
am competent to perform the tests indicated above; and that the results on this form are a complete and truthful
record of all testing at this location on the date shown.
CP Tester Signature: Date:
Keep this record for at least six years.
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Site Sketch: Draw a rough sketch of the tanks and piping, the location of each CP test, and each voltage value
obtained (use space below or attach separate drawing). Voltage readings through concrete or asphalt do not
provide accurate readings and are not acceptable. Perform sufficient testing to evaluate the entire LIST system.
If the CP system fails the test and is not working properly, you must have a corrosion expert investigate and fix
the problem. A corrosion expert has additional training, skills, and certification beyond the corrosion tester who
filled out the bulk of this form. A corrosion expert must be:
• Accredited or certified by NACE International-The Corrosion Society as a corrosion specialist or
cathodic protection specialist, or
• A registered professional engineer with certification or licensing in corrosion control.
As long as you have the LIST, be sure you keep a record that clearly documents what the corrosion expert did
to fix your CP system.
Keep this record for at least six years.
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Sample Form For 60-Day Impressed Current Cathodic Protection System
Inspections
Facility Name:
Amp Range Recommended:
Voltage Range Recommended:
.me Of Perso.
Conducting
Inspection
If the rectifier voltage or amperage outputs are outside the recommended
operating levels, contact a cathodic protection expert to address the
problem.
Never turn off your rectifier.
Keep this record for at least six months after the date of the last inspection.
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What If You Combine Internal Lining And Cathodic
Protection?
If you chose the combination of internal lining and cathodic
protection for meeting corrosion protection requirements on your
UST, you may not have to meet the periodic inspection
requirement for the lined tank. However, you must always meet
the requirements for checking and testing your cathodic protection
system as described in the checklists on pages 45-46. The 10-year
and subsequent five-year inspections of the lined tank are not
required if the integrity of the tank was ensured when cathodic
protection was added. You should be able to show an inspector
documentation of the passed integrity assessment.
Example 1:
If cathodic protection and internal lining were applied to your tank
at the same time, periodic inspections of the lined tank are not
required because an integrity assessment of the tank is required
prior to adding the cathodic protection and internal lining.
Example 2:
If cathodic protection was added to a tank in 1997 that was
internally lined in 1994 and the contractor did not perform an
integrity assessment of the tank at the time cathodic protection was
added or you cannot show an inspector documentation of the
passed integrity assessment, then periodic inspections of the lined
tank are required. This is required because you cannot prove that
the tank was structurally sound and free of corrosion holes when
the cathodic protection was added. The lined tank needs to be
periodically inspected because the lining may be the only barrier
between your product and the surrounding environment.
Do All UST Sites Need Corrosion Protection?
A corrosion expert may be able to determine the soil at an UST site
is not conducive to corrosion and will not cause the tank or piping
to leak during its operating life. If so, you must keep a record of
that corrosion expert's analysis for the life of the tank or piping to
demonstrate why your UST has no corrosion protection.
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:jg--^ '
Section 6:
Walkthrough Inspections
UPDATED
No later than October 13, 2018, you must conduct your
first walkthrough inspection. Below we provide details
and frequency of the inspection.
Every 30 days
• Check your spill prevention equipment for
damage and remove liquid or debris.
• Check for and remove obstructions in the fill
pipe.
• Check the fill cap to ensure it is securely on the
fill pipe.
• For double-walled spill prevention equipment
with interstitial monitoring, check for a leak in
the interstitial area.
Exception: if your UST system receives deliveries at
intervals greater than 30 days, you may check your
spill prevention equipment prior to each delivery.
• Check your release detection equipment to ensure
it is operating with no alarms or unusual
operating conditions present (for example ATG
consoles or pressure or vacuum gauges). You do
not have to check release detection equipment in
containment sumps. Release detection equipment
in these areas is tested annually.
• Review your release detection records and ensure
they are current.
Annually
• Check your containment sumps for damage and
leaks to the containment area or releases to the
environment.
• Remove liquid in contained sumps or debris.
• For double-walled containment sumps with
interstitial monitoring, check for leaks in the
interstitial area.
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• Check your hand-held release detection equipment,
such as groundwater bailers and tank gauge sticks, for
operability and serviceability.
In addition, the 2015 federal UST regulation allows owners
and operators to conduct O&M 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. The inspections must check equipment
in a manner comparable to the walkthrough inspection
requirements described above. Note that owners and
operators must use the entire code of practice if choosing this
option for meeting the walkthrough inspection requirement.
In addition to the requirements listed above, you may also want to
perform these good site management practices during your
walkthrough inspections:
• Fill and monitoring ports: Are covers and caps tightly
sealed and locked?
• Spill and overfill response supplies: Do you have the
appropriate supplies for cleaning up a spill or overfill?
• Containment areas: Is there significant corrosion on the
UST equipment in these areas? Corrosion could result in
equipment in the containment area not working properly.
• Dispenser hoses, nozzles, and breakaways: Are they in
good condition and working properly?
If you find problems during the inspection, you or your UST
contractor must take action quickly to resolve these problems and
avoid serious releases.
See the sample walkthrough inspection checklist on the next page.
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Sample Walkthrough Inspection Checklist
Date Of Inspection
Required Every 30 Days (exception: if your LIST system receives deliveries at intervals greater
than 30 days, you may check your spill prevention equipment prior to each delivery.
Visually check spill prevention equipment for damage.
Remove liquid or debris.
Check for and remove obstructions in fill pipe.
Check fill cap to ensure it is securely on fill pipe.
For double-walled spill prevention equipment with
interstitial monitoring, check for a leak in the interstitial
area.
Check release detection equipment to ensure it is
operating with no alarms or unusual operating conditions
present.
Review and keep current release detection records.
Required Annually
Visually check containment sumps for damage and
leaks to the containment area or releases to the
environment.
Remove liquid in contained sumps or debris.
For double-walled containment sumps with interstitial
monitoring, check for leaks in the interstitial area.
Check hand-held release detection equipment, such as
groundwater bailers and tank gauge sticks, for
operability and serviceability.
Recommended Activities
Fill and monitoring ports: Inspect all fill or monitoring
ports and other access points to make sure that the
covers and caps are tightly sealed and locked.
Spill and overfill response supplies: Inventory and
inspect the emergency spill response supplies. If the
supplies are low, restock the supplies. Inspect supplies
for deterioration and improper functioning.
Containment sump areas: Look for significant corrosion
on the LIST equipment.
Dispenser hoses, nozzles, and breakaways: Inspect for
loose fittings, deterioration, obvious signs of leaks, and
improper functioning.
Your initials in each box below the date of the inspection indicate the device or system was inspected
and satisfactory on that date.
In the following table, explain actions taken to fix issues.
Keep this record for at least one year after last inspection date on the form.
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Section 7:
For More Information
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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&EPA
United States
Environmental Protection
Agency
United States Environmental Protection Agency
5401R
Washington, DC 20460
EPA 510-K-16-001
February 2016
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