Musts for USTs Draft Revised 2015


oEPA

United States
Environmental Protection
Agency

DRAFT

Updated June 2015

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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. In these states, the
state's UST regulation is used in lieu of the federal UST regulation. To find a list of states with state
program approval, see www.epa.gov/oust/states/spamap.htm.

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
regulation, contact your implementing agency or visit its website. You can find links to state UST
websites at www.epa.gov/oust/states/statconl.htm.

If your UST systems are located in a state without state program approval, 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

See EPA's underground storage tank (UST) website at www, e pa .gov/o u st to order, download, or
read documents online. Write to the National Service Center for Environmental Publications
(NSCEP), EPA's publication distributor: NSCEP, PO Box 42419, Cincinnati, OH 45242. Call NSCEP's
toll-free number 800-490-9198. Fax your order to NSCEP 301-604-3408.

Image credits:

MVI Field Services (inspector on cover and page 21)

Highland Tank & Manufacturing Company (steel tanks on cover and in headers)

OPW (fill sump on cover, spill bucket on page 7, automatic shutoff device on page 8, ball float valve

on page 9)

Federated Environmental Associates, Inc. (under-dispenser containment on page 5, spill bucket on
page 10, delivery on page 11)

Musts For USTs - DRAFT
Updated June 2015

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What Is This Regulation About?	1

What Must You Do When You Install An UST?		 5

What Must You Report?		 6

What Are Your Spill And Overfill Prevention Requirements?	7

What Are Your Corrosion Protection Requirements?	12

What Are Your Release Detection Requirements?		 15

What Must You Do For Walkthrough Inspections?				 21

Compatibility With Biofuels And Other Regulated Substances	23

What Are The Operator Training Requirements?		 25

How Do You Repair UST Systems?	26

Financial Responsibility		 28

What Must You Do About UST Releases?	29

How Do You Close USTs?	31

What Records Must You Keep?	33

For Hazardous Substance USTs Only 											 34

Links For More Information						 36

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Musts For USTs - DRAFT
Updated June 2015

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(EPA) regulates over one-half million underground storage
tank systems (USTs) that contain petroleum or hazardous
substances. EPA's Office of Underground Storage Tanks
was formed in response to the discovery in the early 1980s
that thousands of USTs nationwide had leaked and
contaminated groundwater supplies in the United States.
While the number of annual releases since that time has gone
down significantly, releases of petroleum from USTs into the
environment are still a significant concern today.
Underground storage tanks form a crucial part of our
country's fueling infrastructure. It is important for USTs to
be constructed, maintained, and operated in a manner such
that petroleum and other regulated substances are stored
safely. EPA developed the I'ST regulation to help owners
and operators meet those goals.

A properly installed and managed UST system should not
threaten our health or environment. Congress passed federal
laws, which required EPA to develop the UST regulation
described in this booklet. The federal UST regulation in 40
Code of Federal Regulations (CFR) part 280 require owners
and operators of USTs to:

•	Prevent releases from USTs;

•	Detect releases from USTs; and

•	Correct the problems created by releases from USTs.

In addition, the regulation requires UST owners and
operators to maintain documentation showing they have the
ability to pay for cleaning up a release if their USTs leak.

How Will The UST Regulation Affect You?

The UST regulation describes steps you, as an UST owner or
operator, need to take to help protect our health and
environment from potential UST releases. These steps will
also help you avoid the high cost of cleaning up the
environment and possible legal actions if your UST system
leaks.

Releases from USTs can
threaten human health and
the environment. UST
releases can also
contaminate soil and
drinking water supplies. As
of 2015, more than 525,000
UST releases have been
confirmed.

Your implementing agency
may be the state UST
agency, EPA, or a local UST
agency.

Musts For USTs - DRAFT
Updated June 2015

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Check With Your Implementing Agency

Many states and territories (referred to as states in this booklet)
have state program approval from EPA. In these states, the state's
UST regulation is followed in lieu of the federal UST regulation.
To find a list of states with state program approval, see

www.epa.gov/oust/states/spamap.htm.

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.

A list of contacts
can be found at

www.epa.aov

statconl.htm

If your UST systems are located in a state without state program
approval, the requirements in this booklet and the state
requirements apply to you.

If your UST systems are located in Indian country, the
requirements in this booklet apply to you.

What Is An UST?

An UST is one or more tanks and any underground piping
connected to the tanks that have at least 10 percent of their
combined volume underground. The federal UST regulation
applies only to USTs storing petroleum, petroleum blended with
biofuels, and certain other hazardous substances.

The For Hazardous Substance USTs Only section on pages 34-35
describes special requirements for USTs storing hazardous
substances. Generally, the requirements for petroleum USTs and
hazardous substance USTs are very similar.

Some kinds of tanks are not covered by this regulation:

•	Farm and residential tanks of 1,100 gallons or less capacity
holding motor fuel used for noncommercial purposes.

•	Tanks storing heating oil used on the premises where it is
stored.

•	Tanks on or above the floor of underground areas, such as
basements or tunnels.

•	Septic tanks and systems for collecting stormwater and
wastewater.

•	Flow-through process tanks.

•	Emergency spill and overfill tanks.

•	Other storage sites, such as surface impoundments.

Musts For USTs - DRAFT
Updated June 2015

The 2015 UST regulation
removes the deferral for
field-constructed tanks and
airport hydrant systems,
making them subject to all of
the UST requirements.
Because these UST systems
can be large and unique
when compared to
conventional UST systems,
some of the requirements
are different from those
described in this booklet.
Therefore, these systems are
not covered in this booklet.

Please see EPA's
Requirements For Field-
Constructed Tanks And
Airport Hydrant Systems
(coming soon) for
information on the
requirements for these UST
systems.

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What Are Your Requirements?

The requirements listed below include 1988 requirements plus 2015 requirements and their
implementation dates. Bold type indicates the 2015 requirements. Remember you need to
keep records for most of these requirements. See page 33 for your recordkeeping requirements.



For These Tanks Or Facilities:

You Must Have This Equipment Or Perform These Actions:



Installation (page 5)



All Tanks

•	If you install an UST system, meet the requirements concerning correct
installation. Submit a notification form to your implementing agency within
30 days of installation.

•	Under-dispenser containment for new dispensers installed after
[180 days after effective date]







Reporting (page 6)



All Facilities Beginning On [effective
date]

•	After you install an UST system, notify your implementing agency within
30 days

•	Notify your implementing agency at least 30 days before permanently
closing an UST

•	Notify your implementing agency within 30 days of purchasing an
UST

•	Notify your implementing agency at least 30 days before storing
regulated substances blended with greater than 10 percent ethanol









or greater than 20 percent biodiesel or other regulated substances
identified by your implementing agency



Spill And Overfill Prevention (pages 7-11)



AIITanks Installed On Or Before
[effective date]Ever Receiving
Deliveries Greater Than 25 Gallons

® Spili buckets

® Automatic shutoff devices or overfill alarms or ball float valves1

•	Use correct filling practices

•	Beginning on [three years after effective date], test spill buckets
every three years or use a double-walled spill bucket with
interstitial monitoring









• Beginning on [three years after effective date], inspect overfill
prevention equipment every three years



AIITanks Installed AfterJteffeetive
date] Ever Receiving Deliveries
Greater Than 25 Gallons

•	Spill buckets

® Automatic shutoff devices or overfill alarms

•	Use correct filling practices

•	Test spill buckets every three years or use a double-walled spill
bucket with interstitial monitoring

•	Inspect overfill prevention equipment every three years







Corrosion Protection (pages 12-14)



Tanks And Piping Installed On Or
Before December 22,1988

•	Same options as for tanks and piping installed after December 22, 1988; or

•	Cathodically protected steel; or
® Tank interior lining; or

® Tank interior lining andcathodic protection

•	Cathodic protection testing and internal lining inspections



Tanks And Piping Installed After
December 22,1988

•	Coated and cathodically protected steel; or

•	Noncorrodible material (such as fiberglass reinforced plastic(FRP) or
flexible plastic (piping only)); or

•	Steel tank clad or jacketed with noncorrodible material (tanks only)

•	Cathodic protection testing



Release Detection (pages 15-20)



Tanks Installed On Or Before [180

• Monthly monitoring;3 or



Days After Effective Date]2

® Manual tank gauging;4 or

•	Inventory control or manual tank gauging4 plus tank tightness testing (only for
10 years after installation)

•	Beginning on [three years after effective date], test containment
sumps used for piping interstitial monitoring





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Musts For USTs - DRAFT
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For These Tanks Or Facilities: You Must Have This Equipment Or Perform These Actions:

Pressurized Piping Installed On Or • Automatic line leak detector and

Before [180 Days After Effective • Annual line tightness test or

Date]- • Monthly monitoring3 (except automatic tank gauging)

Suction Piping Installed On Or • Monthly monitoring;3 or

Before [180 Davs After Effective • Line tightness testing (every 3 years); or

HP • No requirements (if the system has the characteristics described on

page 19)

Tanks And Piping Installed Or • Secondary containment with interstitial monitoring
Replaced After [ 1H L ;jv= n • Pressurized piping must also have an automatic line leak detector
Effective Date] • No requirements for suction piping (if the system has the characteristics

described on page 19)

• Test containment sumps used for piping interstitial monitoring



Release Detection Testing ® Periodic release detection equipment operability testing

Beginning [three years after)
effective date]



Facilities Using Vapor Or • Beginning on [three years after effective date], keep a record of a
Groundwater Monitoring site assessment for as long as the method is used



Walkthrough Inspections (pages 21-22)



All Facilities Beginning On [three • Periodic walkthrough inspections

years after effective date]



Compatibility (pages 23-24)

All Facilities • Use UST systems made of or lined with material compatible with the

substance stored



All Facilities Beginning On [effective • For systems storing certain regulated substances, maintain
date] records demonstrating compliance with the compatibility

requirement



Operator Training (page 25)



All Facilities Beginning On [three • Designate and train Class A, B, and C operators

years after effective date]



Repairs (pages 26-27)

All Facilities

• Conduct testing following repairs to your tank, piping, or cathodic protection



system



• Beginning on [affectiv!^^®,testor inspect components within 30



days after a repair to spill or overfill prevention equipment or



secondary containment areas

Financial Responsibility (page 28)

All Facilities	• Keep records demonstrating you have the financial resources to clean

up a site if a release occurs, correct environmental damage, and
compensate third parties for injury to their property or themselves

Release Response (pages 29-30)

All Facilities

• Take corrective action in response to releases

Closure (pages 31-32)

All Facilities

• Properly temporarily or permanently close your UST system

Notes:

i1 Bali float valves may not be used when overfill prevention is installed or replaced after [effective date],
jfl 2 USTs storing fuel for emergency power generation installed on or before [effective |Me] must begin
meeting the release detection requirements on [3 years after effective date], USTs storing fuel for
emergency power generation installed after [effecti c date] must meet the release detection requirements
at installation.

3	Monthly monitoring (not to exceed 30 days) includes: interstitial monitoring; automatic tank gauging; vapor

monitoring, groundwater monitoring; statistical inventory reconciliation; continuous in-tank leak detection; and other
methods approved by your implementing agency.

4	Tanks 2,000 gallons and smaller may be able to use manual tank gauging (page 18).

Musts For USTs - DRAFT
Updated June 2015

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Mistakes can be made
during installation. For
example, mishandling of the
tank during installation can
cause issues with tanks, tank
coatings, and cathodic
protection. Improper layout
of piping runs, incomplete
tightening of joints,
inadequate cover pad
construction, and
construction accidents can
lead to failure of delivery
piping.

Make sure your UST system is installed correctly; use
qualified installers who follow industry codes and
manufacturers' instructions. (See

www.epa. gov/oust/cmplastc/standard.htm for more
information on industry codes and installation practices.)

• Make sure the certification for proper installation on
the notification form is completed and signed. You
can find the notification form at

www.epa.gov/oust/fedlaws/cfr.htm.

Installation problems may result from installation practices
that do not follow standard industry codes and procedures.
Improper installation could result in UST system failures.
Installation includes activities such as excavation, UST
system siting, burial depth, tank system assembly,
backfilling around the UST system, and surface grading.

Make sure that installers carefully follow the correct
installation procedures called for by manufacturers'
instructions and industry codes.

UPDATED

Dispensers installed after [180 days after effective date]
must have under-dispenser containment. Under-
dispenser containment must be liquid-tight on its sides,
bottom, and at any penetrations. Under-dispenser
containment must allow for visual inspection and access
to the components in the containment system or be
periodically monitored for leaks from the dispenser
system.

What you must do for under-dispenser
containment:

Musts For USTs - DRAFT
Updated June 2015

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What Must You Report?

You must report to your implementing agency on the following occasions:

When This Happens:

You Must Report This:

By This Time:

UPDATED

UPDATED

After you install an UST

You must complete and submit a
notification form available from
your implementing agency. This
form provides information about
your UST, including a certification
of correct installation. You should
have already used this form to
identify your existing USTs. If you
have not done that yet, do so
now.

Within 30 days after you install an
UST

After you acquire an UST,
such as by purchasing a
gas station

You must complete a
notification of ownership
change form available from
your implementing agency.

Within 30 days after you acquire
an UST (beginning on [effective
date])

Before storing certain
biofuels or other
substances identified by
your implementing agency

You must notify your
implementing agency (page
23).

At least 30 days before storing
certain biofuels or other
substances identified by your
implementing agency (beginning

on [effective date])

When you suspect a release

You must report suspected
releases to your implementing
agency (page 29).

Within 24 hours (or another period
specified by your implementing
agency)

When you confirm a release

You must report follow-up
actions you plan or have taken
to correct the damage caused
by your UST (page 30).

Within 20 days (or another period
specified by your implementing
agency)

Before you permanently
close your UST

You must notify your
implementing agency (page 32).

At least 30 days before you
permanently close your UST

Check with your implementing agency for additional requirements not noted above.

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Musts For USTs - DRAFT
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UPDATED

UPDATED

What Are Your Spill And
Overfill Prevention
Requirements?

What you must do for spill prevention:

•	Your USTs must have spill prevention equipment
(commonly called spill buckets or catchment basins)
to contain drips and small spills that can occur when
the delivery hose is disconnected from the fill pipe,

•	You must test your spill prevention equipment at
least every three years for liquid tightness or use
a double-walled spill bucket with periodic
interstitial monitoring.

•	Beginning on [im | yi u - diu-r vi'lectn| date],
you must inspect your spill prevention equipment
at least every 30 days (or before each delivery if
you receive deliveries less frequently than every
30 days). See page 21 for more information about
what you must check during your walkthrough
inspections.

•	You and your fuel deliverer must follow industry
standards for correct filling practices.

Many releases at UST sites come from spills. Spills often
occur at the fill pipe when the delivery truck's hose is
disconnected. Although these spills are usually small,
repeated small releases can cause big environmental
problems.

What Are Spill Buckets?

Spill buckets are also called spill containment manholes or
catchment basins. Basically, a spill bucket is a contained
area around the fill pipe.

To protect against spills, the spill bucket should be large
enough to contain what may spill when the delivery hose is
uncoupled from the fill pipe. Spill buckets range in size
from those capable of holding only a few gallons to those
that are much larger - the larger the spill bucket, the more
spill protection it provides.

You should try to keep water out of spill buckets. Some
spill buckets can collect water and sediment, along with
spilled product, making draining this mixture into the tank
unwise. If this happens, you may pump out the spill bucket

If an UST never receives
more than 25 gallons at a
time, the UST does not have
to meet the spill prevention
requirements. Many small
used oil tanks fall in this
category.

Sloping the surrounding
surface away from the tops
of spill buckets helps keep
water out of them.

Musts For USTs - DRAFT
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Your equipment supplier can
help you choose the size and
type of spill bucket that
meets your needs.

and dispose of the liquid properly. If the liquid contains fuel or
chemicals, it could be considered a hazardous waste. Contact your
implementing agency responsible for hazardous waste for
information on testing and handling requirements.

What you must do for overfill protection:

•	Your UST must have overfill protection. Automatic
shutoff devices, overfill alarms, and ball float valves are
the three types of overfill protection devices, which are
described below.

•	You must inspect your overfill prevention equipment
every three years to ensure it will function properly to
prevent overfills.

•	You and your delivery person must follow industry
standards for correct filling practices.

Overfills usually release much larger volumes than spills. When a
tank is overfilled, large volumes can be released at the fill pipe and
at other areas of the UST system, such as loose fittings on the top
of the tank, vapor recovery ports, a loose vent pipe, or other tank
top openings.

To work properly, all overfill
devices must be installed
correctly at the proper
distance below the tank top
as specified by the
manufacturer.

You can solve overfill problems by:

•	Making sure there is enough room in the tank for the
delivery before the delivery is made;

•	Watching the entire delivery to prevent overfilling or
spilling; and

•	Using overfill protection devices.

Note: If you receive pumped deliveries, which means fuel is
delivered under pressure, you must make sure your overfill
protection device works properly with pumped deliveries. Also,
remember that overfill protection devices are effective only when
combined with careful filling practices.

What Are Automatic Shutoff Devices?

An automatic shutoff device installed in an UST's fill pipe slows
down and then stops delivery when the product reaches 95 percent
capacity or before the fittings on top of the tank are exposed to
product. This device - sometimes simply called a flapper valve -
has one or two valves that are operated by a float mechanism.

Some automatic shutoff devices work in two stages. The first
stage drasti cally reduces the flow of product to alert the delivery
person that the tank is nearly full. The delivery person can then

Musts For USTs - DRAFT
Updated June 2015

If an UST never receives
more than 25 gallons at a
time, the UST does not have
to meet the overfill
prevention requirements.
Many small used oil tanks
fall in this category.

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close the delivery valve and still have room in the tank for the
product left in the delivery hose.

If the delivery person does not pay attention and the liquid level
rises higher, the valve closes completely and no more liquid can be
delivered into the tank, leaving the delivery person with a delivery
hose full of product.

What Are Overfill Alarms?

Overfill alarms use probes installed in the tank to activate an alarm
when the tank is either 90 percent full or within 1 minute of being
overfilled. Either way, the alarm should provide enough time for
the delivery person to close the truck's shutoff valve before an
overfill happens. Alarms must be located where the delivery
person can see or hear them easily. Overfill alarms are often part
of automatic tank gauging systems.

Overfill alarms work only if they alert the delivery person at the
right time and the delivery person responds quickly. Remember to
put the alarm on an electrical circuit that is active all the time so
that the alarm will always work. Many deliveries are made at
night when the facility is closed. You do not want to turn off your
alarm when you turn off the office lights.

Ball Float Valves

In addition to the two types of overfill prevention described above,
ball float valves may be used on tanks installed on or before

!	] as long as the ball float valve continues to operate

properly. If the ball float valve must be replaced, owners and
operators must use one of two types of overfill prevention
described above.

Flow restrictors in vent lines, also called ball float valves, are
placed at the bottom of the vent line several inches below the top
of the UST. The ball floats on the product and rises with product
level during delivery until it restricts vapor flowing out the vent
line before the tank is full. Ball float valves must begin restricting
flow when the tank reaches 90 percent of its capacity, or 30
minutes before overfilling. If all tank fittings are tight, the ball
float valve can create enough back pressure to restrict product flow
into the tank - this can notify the delivery person to close the
truck's shutoff valve. However, if the UST has loose fittings,
sufficient back pressure may not develop and will result in an
overfill.

Note: Manufacturers do not recommend using ball float valves
with suction piping, pressurized delivery, or coaxial Stage I vapor
recovery.

Musts For USTs - DRAFT
Updated June 2015

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If you and your delivery
person follow standard
practices, nearly all spills
and overfills can be
prevented.

Beginning on [three years after effective date], you must begin
testing your ball float valves for proper operation once every
three years. If the ball float valve is not operating properly
and cannot be repaired, the overfill device must be replaced
with one of the other overfill prevention options described
above.

What Are Your Responsibilities For Correct Filling
Practices?

Human error causes most spills. You can avoid these mistakes by
following standard tank filling practices. For example, you must
make sure there is room in the UST for the delivery, and the
delivery person must watch the delivery at all times. For this
reason, the federal UST regulation requires that you follow
standard filling practices.

As an owner or operator, you are responsible for ensuring that
releases due to spilling or overfilling do not occur during fuel
delivery. As part of this responsibility, you must:

•	Ensure the amount of product to be delivered will fit into
the available empty space in the tank; and

•	Ensure the transfer operation is monitored constantly to
prevent overfilling and spilling.

What To Do Before Your USTs Are Filled

•	Post clear signs that alert the delivery person to the overfill
devices and alarms in use at your facility.

•	Make and record accurate readings for product and water in
the tank before fuel delivery.

•	Order only the quantity of fuel that will fit into 90 percent
of the tank.

•	The formula for determining the maximum amount of
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

•	Ensure fuel delivery personnel know the type of overfill
device present at the tank and what actions to perform if it
activates.

•	Review and understand the spill response procedures.

•	Verify that your spill bucket is empty, clean, and will
contain spills.

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Musts For USTs - DRAFT
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What To Do While Your USTs Are Being Filled

•	Keep fill ports locked until the fuel delivery person
requests access.

•	Keep an accurate tank capacity chart available for the fuel
delivery person.

•	The fuel delivery person makes all hook-ups. The person
responsible for monitoring the delivery should remain
attentive and observe the entire fuel delivery; be prepared
to stop the flow of fuel from the truck to the UST at any
time; and respond to any unusual condition, leak, or spill
that may occur during delivery.

•	Keep response supplies readily available for use in case a
spill or overfill occurs.

•	Provide safety barriers around the fueling zone.

•	Make sure there is adequate lighting around the fueling
zone.

What To Do After Your USTs Are Filled

•	Following complete delivery, the fuel delivery person is
responsible for disconnecting all hook-ups.

•	Return spill response kit and safety barriers to proper
storage locations.

•	Make and record accurate readings for product and water in
the tank after fuel delivery.

•	Verify the amount of fuel received.

•	Make sure fill ports are properly secured.

•	Ensure the spill bucket is free of product and clean up any
small spills.

Delivery to USTs

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Corrosion results when bare metal and
soil and moisture conditions combine to
produce an underground electric current
that destroys hard metal. Over time,
unprotected USTs can corrode and leak.

Sacrificial anode system

The federal UST regulation requires corrosion
protection to help prevent your USTs from
releasing product into the environment.

Tanks and piping entirely made of non-
corrodible material, such as fiberglass, do
need cathodic protection.

What Are Cathodic Protection
Methods?

Sacrificial Anode System: Sacrificial anodes
are buried and attached to UST components for
corrosion protection. Anodes are pieces of
metal that are more electrically active than steel,
and thus they suffer the destructive effects of
corrosion rather than the steel they are attached
to.

Impressed Current System: An impressed
current system uses a rectifier to provide direct
current through anodes to the tank or piping to
achieve corrosion protection. The steel is
protected because the current going to the steel
overcomes the corrosion-causing current
flowing away from it. The cathodic protection
rectifier must always be on and operating to
protect your UST system from corrosion.

You must have a qualified cathodic protection
tester test your cathodic protection system at
least once every three years to make sure the
cathodic protection system is protecting the
UST system. If you have an impressed current
system, you must inspect it at least once every
60 days to make sure the impressed current
rectifier is running properly.

Never turn off your rectifier. If your rectifier is
off, your UST system is not being protected
from corrosion.

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Musts For USTs - DRAFT
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Corrosion Protection For Steel USTs installed On Or
Before December 22,1988

Steel tanks installed on or before December 22, 1988, must either
have been assessed and upgraded with corrosion protection using
one of the following three methods or meet the corrosion
protection requirements for tanks installed after December 22,
1988:

Added cathodic protection. The cathodic protection system
must have been tested by a qualified cathodic protection
tester within six months of installation and at least once
every three years thereafter. You must keep the results of
the last two tests to prove that the cathodic protection is
working. In addition, if you have an impressed current
cathodic protection system, you must inspect it at least once
every 60 days to verify that the system is operating. Keep
results of your last three inspections to prove that the
impressed current system is operating properly.

Added interior lining to the tank. The interior of a tank
could have been lined with a thick layer of noncorrodible
material (see www.epa. gov/oust/cmplastc/standard.htm for
industry codes). Tanks using only an interior lining for
corrosion protection must have passed an internal lining
inspection within 10 years of installation of the internal
lining and every five years after that to make sure that the
lining is sound. Keep records of the inspection results.
Combined cathodic protection and interior lining. You
could have added both cathodic protection and interior
lining. This combined method does not require you to have
the interior lining periodically inspected if your tank was
assessed and found to be structurally sound and free of
corrosion holes when you added cathodic protection. You
still must have the cathodic protection system periodically
tested and inspected and keep records as explained in the
first bullet point above.

Note that field-installed
cathodic protection must be
designed by a qualified
corrosion expert.

Only tanks that were proven
to be structurally sound
could have been lined.

Corrosion Protection For Piping Installed On Or Before
December 22,1988

Metal piping installed on before December 22, 1988 must have
cathodic protection. In addition, owners and operators must test,
inspect, and keep records as described above for tank cathodic
protection.

13

Musts For USTs - DRAFT
Updated June 2015

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Corrosion Protection For Steel Tanks And Piping
Installed After December 22,1988

Your tanks and piping must meet one of the following to be
protected from corrosion:

•	Tank and piping are completely made of a noncorrodible
material, such as fiberglass.

•	Tank is made of steel and completely isolated from contact
with the surrounding soil by being enclosed or jacketed in
noncorrodible material. This option does not apply to
piping.

•	Tank and piping are made of steel having a corrosion-
resistant coating and having cathodic protection, such as an
sti-P3® tank with appropriate piping. A corrosion-resistant
coating electrically isolates the coated metal from the
surrounding environment to help protect against corrosion.
An asphaltic coating does not qualify as a corrosion-
resistant coating. Galvanized steel does not meet the
corrosion protection requirements. You must have cathodic
protection systems tested and inspected and keep records as
explained in the first bullet point on the previous page.

Musts For USTs - DRAFT
Updated June 2015

-------
What Are Your Release
Detection Requirements?

You must provide your UST system with release detection
that allows you to meet the following basic requirements:

• You can detect a leak from any portion of the tank or
its piping that routinely contains product;

• Your release detection is installed and calibrated
according to the manufacturer's instructions; and

• Your release detection meets the performance
requirements described in the federal UST
regulation. See 40 CFR 280.43 and 280.44.

EPA will soon issue an updated version of its booklet
Straight Talk On Tanks, which focuses only on release
detection methods and requirements.

UPDATED

Beginning on [three years after effective date], you must
test your release detection equipment annually to make
sure it is working properly. You must keep records of
these tests for three years.

UPDATED

Beginning on [three years after effective date], you must
check your release detection equipment every 30 days.
In addition, you must check your hand-held release
detection equipment annually. You must keep records
of these checks for one year. See pages 21-22 for more
information about what you must do on your
walkthrough inspections.

UPDATED

Piping Replacements: Beginning on [ v
dT<*» i iv« i i .h • |, if you repair 50 percent or more of your
piping in a single piping run, that piping must be
replaced. This means you must remove the entire piping
run and install secondarily contained piping. You must
also use interstitial monitoring for release detection.

USTs storing fuel for emergency power generators must
begin meeting the release detection requirements. For
emergency generator UST systems installed on or before
[t'Hec(i\| dale], you must begin meeting the release
detection requirements by [three years after effective
-------
[effective date] but on or before [180 days after effective date],
you must begin meeting the release detection requirements at
installation by using one of the methods described below.
Emergency generator UST systems installed after [180 days

it | ] must be secondarily contained and use

interstitial monitoring upon installation.

Release detection requirements for tanks installed on
or before [180 days after effective date]:

Below we list the monthly monitoring methods you may use to
meet the federal release detection requirements. As temporary
methods, you may instead use inventory control combined with
tank tightness testing, or manual tank gauging combined with tank
tightness testing, as described on pages 17-18. See additional
release detection requirements for piping on pages 18-20.

Monthly Monitoring Methods:

• Interstitial monitoring: This method detects leaks in the
space between the primary wall and a secondary barrier of
the tank. The federal UST regulation describes general
performance requirements for interstitial monitoring with
double-walled USTs, USTs fitted with internal liners, and
USTs using secondary barriers.

• Automatic tank gauging (ATG) systems. This method uses
automated processes to monitor product level and perform
inventory control.

• Continuous in-tank leak detection (CITLD). This method
encompasses all statistically based methods where the
system incrementally gathers measurements on an
uninterrupted or nearly uninterrupted basis to determine a

This booklet sometimes uses
the term monthly as it
applies to release detection
monitoring frequency. This
term means release
detection monitoring must
occur at least once every 30
days.

Release detection for USTs
installed on or before [180
days after effective date]
may consist of one or a
combination of the release
detection methods listed on
pages 16-18.

Musts For USTs - DRAFT
Updated June 2015

-------
tank's release status. This method typically uses sensors
permanently installed in the tank to obtain inventory
measurements, combined with a microprocessor in the
ATG system or other control console that processes the
data.

• Statistical inventory reconciliation (SIR): For this method,
typically a trained professional uses sophisticated computer
software to conduct a statistical analysis of inventory,
delivery, and dispensing data, which you must supply
regularly.

• Groundwater monitoring: This method monitors the
groundwater table near an LIST for the presence of released
free product on the water table. Monitoring wells near the
UST are checked frequently to see if petroleum can be
detected. The federal UST regulation describes several
requirements for using this method. For example, you
cannot use this method if the water table is more than 20
feet below the surface of the ground.

• Vapor monitoring: This method samples for petroleum
hydrocarbon vapors (sometimes called passive monitoring)
or tracer compound vapors (sometimes called active
monitoring) in the soil surrounding the UST. Released
petroleum, for example, produces vapors that can be
detected in the soil The federal UST regulation describes
several requirements for using this release detection
method. For example, this method requires using porous
soils in the backfill and locating the monitoring devices in
these porous soils near the UST system.

• Other methods: Methods that can detect a 0.2 gallon per
hour leak rate or 150 gallons within a month that meet
performance standards of a 95 percent probability of
detection and no more than a 5 percent probability of false
alarm may also be used. In addition, other methods
approved by your implementing agency that can be shown
to work as effecti vely as the methods described above for
release detection may be used.

Alternate Release Detection Method Allowed For Up To 10
Years After Installation

For USTs installed on or before [180 days after effective date]

instead of using one of the monthly monitoring methods noted
above, you can combine inventory control with tank tightness
testing, but only for 10 years after you installed the tank.

Inventory control involves taking daily measurements of tank
contents and recording deliveries and amount pumped. Based on
daily and monthly calculations, you can discover if your tank may
be leaking.

Starting on [threeyears
after effective date], if you
use vapor monitoring or
groundwater monitoring,
you must keep records of a
site assessment, for as long
as you use these methods,
showing that the monitoring
system is set up properly. If
you do not have a site
assessment for your vapor
monitoring or groundwater
monitoring, you will need to
have one conducted. Site
assessments conducted after
[effective date] have to be
signed by a licensed
professional.

Musts For USTs - DRAFT
Updated June 2015

-------
Tank tightness testing usually requires taking the UST out of
service while changes in level or volume over time are measured.
Your UST will need a tank tightness test every five years. After 10
years, you must use one of the monthly monitoring methods.

The success of this temporary combined method depends on your
performing inventory control correctly. See EPA's booklet, Doing
Inventory Control Right, which clearly explains how to do
inventory control with simple step-by-step directions

www.epa.gov/oust/pubs/doing.htm. The booklet includes example
forms for recording inventory data.

Additional Release Detection Method For Small Tanks

Tanks of 2,000 gallons capacity or less that were installed on or
before [ i ] may be able to use manual

tank gauging as a release detection method, either by itself or in
combination with tank tightness testing. This method involves
keeping the tank undisturbed for at least 36-58 hours each week,
during which the tank's contents are measured, twice at the
beginning and twice at the end of the test period. Manual tank
gauging can be used as the sole method of release detection for
tanks with a capacity of 550 gallons or less and for tanks with
capacities between 551 gallons and 1,000 gallons with a diameter
of either 48 inches or 64 inches.

All other tanks using manual tank gauging must combine the
method with tank tightness testing. These tanks may use the
combined method for up to 10 years after installation.

See EPA's booklet, Manual Tank Gauging For Small
Underground Storage Tanks, which clearly explains how to do
manual tank gauging with simple step-by-step directions

www.epa. gov/oust/pubs/manual.htm. The booklet includes
standard forms for recording inventory data.

A EPA

Doing Inventory Control
Right

For Underground Storage Tanks

EPA's Doing Inventory
Control Right booklet

sepa Manual Tank Gauging

For Small Underground
Storage Tanks

EPA's Manual Tank Gauging
booklet

Release detection requirements for piping installed on

or before [180 days after effective date]:

Pressurized piping installed on or before [180 days after effective
dale] must meet these requirements:

The piping must have an automatic line leak detector that
will stop or restrict flow, or activate an alarm when a
release is detected.

You must either conduct an annual tightness test of the
piping or use one of the following monthly methods noted
above for tanks: interstitial monitoring, vapor monitoring,
groundwater monitoring, statistical inventory

Musts For USTs - DRAFT
Updated June 2015

-------
reconciliation, continuous in-tank leak detection, or other
approved monthly methods.

If your UST has suction piping, your release detection
requirements will depend on which type of suction piping you
have. No release detection is required if the suction piping system
has:

• Below-grade piping that operates under atmospheric
pressure;

• Enough slope so that the product in the pipe can drain back
into the tank when suction is released; and

• Only one check valve, which is as close as possible beneath
the pump in the dispensing unit.

If a suction line is to be considered exempt based on these design
elements, there must be some way to verify that the line was
actually installed according to these criteria.

Suction lines installed on or before [ *¦' ; ]

that do not meet all of the design criteria noted above must have
release detection (either monthly monitoring using one of the
monthly methods noted above for use on pressurized piping or
tightness testing of the piping every three years).

Release detection requirements for tanks and piping

installed after [180 days after effective date]:

Tanks and piping installed after [180 days after effective date]
must have secondary containment and interstitial monitoring.

Interstitial monitoring detects leaks in the space between the
primaiy wall of the tank or pipe and a secondary barrier. In
addition, piping must have an automatic line leak detector. The
regulation describes general performance requirements for
interstitial monitoring with double-walled USTs, USTs fitted with
internal liners, and USTs using secondary barriers.

Additional Release Detection For Piping

Pressurized piping must continue to have an automatic line leak
detector that will stop or restrict flow, or activate an alarm when a
release is detected.

If your UST has suction piping, your release detection
requirements will depend on which type of suction piping you
have. No release detection is required if the suction piping system
meets the requirements above.

Release detection for piping
is particularly important,
because a significant
percentage of leaks come
from an UST system's piping.

Musts For USTs - DRAFT
Updated June 2015

-------
If a suction line is to be considered exempt based on these design
elements, there must be some way to verify that the line was
actually installed according to these criteria.

Suction lines installed after [ i ' | that do

not meet all of the design criteria listed on page 19 must use
interstitial monitoring.

What you must do for containment sumps:

Beginning on [three years after effective date], you must begin

testing containment sumps used for interstitial monitoring of
piping at least every three years for liquid tightness or use
double-walled containment sumps with periodic interstitial
monitoring of the space between the two walls of the sump.

Musts For USTs - DRAFT
Updated June 2015

-------
UPDATED

Beginning not later than [three years after effective

date], you must conduct periodic walkthrough
inspections to make sure your equipment is working
properly and catch problems early. The walkthrough
inspections must cover:

Every 30 days:

• Spill prevention equipment

o Visually check for damage,
o Remove liquid or debris,
o Check for and remove obstructions in the
fill pipe.

o Check the fill cap to make sure it is

securely on the fill pipe,
o For double-walled spill prevention
equipment with interstitial monitoring,
check for a leak in the interstitial area,
o For tanks that receive deliveries less
frequently than every 30 days, the spill
prevention equipment inspection may be
conducted before each delivery.

• Release detection equipment

o Check to make sure the release detection
equipment is operating with no alarms or
other unusual operating conditions
present.

o Ensure records of release detection testing

are reviewed and current,
o Owners and operators who monitor their
release detection systems remotely may
check the release detection equipment and
records remotely, as long as the release
detection systems at the locations are in
communication with remote monitoring
equipment.

Inspecting a containment
sump

Musts For USTs - DRAFT
Updated June 2015

-------
Annually:

• Containment suinps

o Visually check for damage, leaks to the
containment area, and releases to the
environment.

o Remove liquid from contained sumps.

o Remove debris.

o For double-walled sumps with interstitial
monitoring, check for leaks in the interstitial
area.

• Hand-held release detection equipment

o Check devices such as tank gauge sticks or
groundwater bailers for operability and
serviceability.

You can also conduct walkthrough inspections according to a
standard developed by a nationally-recognized association or
independent testing laboratory or according to requirements
developed by your implementing agency, if the standard
checks equipment in a manner comparable to the requirements
above.

You may perform walkthrough inspections yourself or have a
third party conduct them.

You must keep records of your walkthrough inspections for
one year.

Musts For USTs - DRAFT
Updated June 2015

-------
Compatibility With
Biofuels And Other
Regulated Substances

Since 1988, EPA has required UST systems to be
compatible with the substance stored in them. As newer
fuels with different chemical properties enter the
marketplace, it is even more important for you to make sure
your UST system is compatible with the fuel stored in your
system. Compatibility is the ability of two or more
substances (in this case, your UST system and the regulated
substance stored) to maintain their respective physical and
chemical properties when in contact with one another.
Compatibility is required for the design life of the UST
system and under conditions likely to be encountered by the
UST.

In addition to ensuring compatibility, beginning on
[elTeciive ilale) you must meet these requirements.

You must notify your implementing agency at least 30
days before storing any of these products:

• Regulated substances containing greater than 10
percent ethanol.

• Regulated substances containing greater than 20
percent biodiesel.

• Any other regulated substance identified by your
implementing agency.

In addition, you must meet the compatibility
requirements for storing these fuels. You may either
demonstrate you are using equipment or components
approved for use with the regulated substance you will
store, or use another option determined by your
implementing agency to be no less protective of human
health and the environment than the compatibility
demonstration options listed below. Ways to
demonstrate compatibility include having the following
documentation:

• Certification or listing of the equipment or
component by a nationally recognized,
independent testing laboratory for use with the
regulated substance stored; or

Musts For USTs - DRAFT
Updated June 2015

Make sure your UST system
is compatible with the
substance it stores.

-------
• Written statement from the manufacturer affirming the
equipment or component is compatible with the
regulated substance stored.

As long as you store regulated substances containing greater
than 10 percent ethanol, greater than 20 percent biodiesel, or
any other regulated substance identified by your implementing
agency, you must keep records demonstrating compliance with
the compatibility requirement.

Musts For USTs - DRAFT
Updated June 2015

-------

8S ^gjjS

What Are The Operator

Training Requirements?

UPDATED

Beginning on [three years after effective date], you must
designate Class A, B, and C operators and train them on
their LIST responsibilities. There are three classes of
operators, each with different responsibilities:

• Class A operator is the person who has primary
responsibility to operate and maintain the UST
system according to the UST regulation. Class A
operator training provides a general knowledge
of the UST regulation.

• Class B operator is the person who has day-to-
day responsibility for implementing the UST
regulation. Class B operator training provides
more detailed knowledge of the UST regulation.

• Class C operator is any person responsible for the
immediate response to a problem at an UST
facility, such as a gas station attendant. Class C
operator training must cover how to respond to
an alarm or emergency.

A single individual may be designated as more than one
class of operator as long as that individual is trained in
all responsibilities for each class of operator designated.

Operators may need to be retrained if the UST system is
not in compliance.

You must keep a list of currently designated operators
trained for each facility and proof of training or
retraining for each operator. You may keep the records
off site.

Most states already have their own operator training
program. Contact your implementing agency for
information specific to the state where your USTs are
located.

For more information about
your state's operator
training program, contact
your implementing agency.
See a list of contacts at

www.epa.gov/oust/states/s
tatconl.htm

Musts For USTs - DRAFT
Updated June 2015

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Can Leaking Tanks Be Repaired?

You can repair a tank if the person who repairs the tank
carefully follows standard industry codes that establish the
correct way to conduct repairs. See

www.epa. gov/oust/crnplastc/standard.htm for industry codes
and standards.

Within 30 days of the repair, you must prove that the tank is
repaired by:

• Having the tank inspected internally or tightness
tested following standard industry codes; or

• Using one of the monthly release detection
monitoring methods on pages 16-17; or

• Using other methods approved by your
implementing agency.

UPDATED

Beginning on elective dale], within 30 days after

repairs to secondary containment areas of tanks, you
must have the secondary containment tested for
tightness.

UPDATED

Beginning on Infective date], within 30 days after

repairing spill or overfill prevention equipment, you
must test or inspect the repaired spill or overfill
prevention equipment to ensure it is operating properly.

Within six months of repair, USTs with cathodic protection
must be tested to show that the cathodic protection is
working properly.

Can Leaking Piping Be Repaired?

Damaged metal piping cannot be repaired and must be
replaced. Loose fittings can be tightened, and in some cases
that may solve the leaks.

Piping made of fiberglass-reinforced plastic can be repaired,
but only according to the manufacturer's instructions or
national codes of practice. Within 30 days of the repair,

Musts For USTs - DRAFT
Updated June 2015

Replace damaged metal
piping; do not repair it.

-------
piping must be tested in the same ways noted above for testing
tank repairs, except for internal inspection.

Beginning on [¦Elective date], within 30 days after repairs to
secondary containment areas of piping used for interstitial
monitoring and to containment sumps used for interstitial
monitoring of piping, you must have the secondary
containment tested for tightness.

Beginning on Mfective date], for I'STs installed after
December 22,1988, when 50 percent or more of the piping
connected to a single tank is removed and replaced, the entire
piping run must be replaced with piping that has secondary
containment and interstitial monitoring.

What Records Must I Keep?

You must keep records for each repair until the L S I' is
permanently closed or undergoes a change-in-service.

Musts For USTs - DRAFT
Updated June 2015

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Financial Responsibility

You must maintain documentation showing you have the
financial resources to clean up a site if a release occurs,
correct environmental damage, and compensate third parties
for injury to their properties or themselves. The amount of
coverage depends on the type and size of your business, as
summarized in the chart below.

Group Of UST
Owners And
Operators

Per

Occurrence
Coverage

Aggregate
Coverage

Petroleum marketers
or

owners and operators
who handle more than
10,000 gallons per
month

$1 million

$1 million if you
have 100 or fewer
USTs

$2 million
if you have more
than 100 USTs

All others

$500,000

You have several options to demonstrate financial
responsibility. These include:

• obtain insurance coverage from an insurer or a risk
retention group;

• use a financial test to demonstrate self-insurance;
obtain corporate guarantees, surety bonds, or letters
of credit;

• place the required amount into a trust fund
administered by a third party; or

• rely on coverage provided by a state financial
assurance fund.

Local governments also have four additional options
tailored to their specific characteristics: a bond rating test, a
financial test, a guarantee, and a dedicated fund.

EPA's booklet, Dollars And Sense, briefly summarizes the
financial responsibility requirements.

www.epa.gov/oust/pubs/do
llars.htm

Musts For USTs - DRAFT
Updated June 2015

-------
UPDATED

Warning signals indicate that your LIST may be leaking and
creating problems for the environment and your business.
You can minimize these problems by paying careful
attention to early warning signals and reacting quickly
before major problems develop.

You should suspect a release when you observe these
warning signals:

• Unusual operating conditions. Check first to see if
the problem results from equipment failure that can
be repaired. Remember to remove any liquid from
the interstitial space of secondarily contained
systems.

• Results from release detection monitoring and
testing that indicate a release. What at first appears
to be a release may be the result of faulty equipment
that is part of your UST system or its release
detection. Check this equipment carefully for
failures.

If you investigate an unusual operating condition or release
detection alarm and determine a release has not occurred,
you do not need to report a suspected release as long as you
immediately fix the problem. Otherwise, you need to call
your implementing agency and report the suspected release.
Then find out quickly if the suspected release is an actual
release. Use these investigative steps:

• Conduct tightness testing or interstitial integrity
testing of the entire UST system.

• Check the site for additional information on the
presence and source of contamination.

If the system tests and site checks confirm that a release has
occurred, follow the actions for responding to confirmed
releases described below.

You must also respond quickly to any evidence of released
petroleum that appears at or near your site. For example,
neighbors might tell you they smell petroleum vapors in
their basements or taste petroleum in their drinking water. If

Musts For USTs - DRAFT
Updated June 2015

Unusual operating
conditions include such
things as erratic behavior of
the dispensing pump and
liquid in the interstitial
space of secondarily
contained systems.

-------
evidence of this type is discovered, you must report this discovery
immediately to your implementing agency and take the
investigative steps and follow-up actions noted above.

Your action to confirmed releases comes in two stages: short term
and long term.

Short-Term Actions

• Take immediate action to stop and contain the release.

• Report the release to your implementing agency within 24
hours or the time frame required by your implementing
agency. However, petroleum spills and overfills of less
than 25 gallons do not have to be reported if you
immediately contain and clean up these releases.

• Make sure the release poses no immediate hazard to human
health and safety by removing explosive vapors and fire
hazards. Your fire department should be able to help or
advise you with this task. You must also make sure you
handle contaminated soil properly so that it poses no
hazard, for example, from vapors or direct contact.

• If necessary, remove petroleum from the UST system to
prevent further release into the environment.

• Find out how far the petroleum has moved and begin to
recover the released petroleum, such as product floating on
the water table. Report your progress and any information
you collect to your implementing agency no later than 20
days after confirming a release.

• Investigate to determine if the release has damaged or
might damage the environment. This investigation must
determine the extent of contamination both in soils and
groundwater. You must report to your implementing
agency what you have learned from an investigation of
your site according to the schedule established by your
implementing agency. At the same time, you must also
submit a report explaining how you plan to clean up the
site. Additional site studies may be required.

Long-Term Actions

Based on the information you provide, your implementing agency
will decide if you must take further action at your site. You may
need to take two more actions:

• Develop and submit a corrective action plan that shows
how you will meet requirements established for your site
by your implementing agency.

• Make sure you implement the actions approved by your
implementing agency for your site.

Contact your implementing
agency for guidance on
doing site assessments and
corrective action.

Musts For USTs - DRAFT
Updated June 2015

-------
You may close your UST temporarily or permanently.

Closing Temporarily

UPDATED

You may temporarily close your UST for up to 12 months
by following these requirements:

Continue to maintain and monitor corrosion
protection systems

Continue to maintain financial responsibility
Beginning on [3 years after effective date], your
operators must be trained

If your temporarily closed UST is not empty, you
must also:

o Continue to monitor for leaks by performing

release detection
o Perform monthly walkthrough inspections
for your release detection beginning on [3
years after effective date]
o Perform annual inspections and tests of
release detection equipment beginning on
[3 years after effective date]
o Perform three year containment sump
testing if using the containment sump for
interstitial monitoring of the piping
beginning on [3 years after effective date]
If a release is discovered, quickly stop the release,
notify your implementing agency, and take
appropriate action to clean up the site.

If the U ST remains temporarily closed for more than
three months, leave vent lines open, but cap and
secure all other lines, pumps, manways, and
ancillary equipment.

Facilities with USTs in
temporary closure must
have trained operators
beginning on [3 years after
effective date].

USTs in temporary closure are not required to meet the
following requirements:

• Spill testing

• Overfill inspections

• Empty USTs do not require:

o Release detection

Note that some
implementing agencies
require removal of the
regulated substance from
the tank while in temporary
closure. Other
implementing agencies may
require permanent closure
after one year.

Musts For USTs - DRAFT
Updated June 2015

-------
o Annual release detection testing and inspections
o Monthly walkthrough inspections
o Three year containment sump testing

An UST is considered empty if no more than one inch of residue is
present or not more than 0.3 percent by weight of the total capacity
of the UST system remains in the system.

After 12 months of temporary closure, you must permanently close
your UST. Your UST, however, can remain temporarily closed
indefinitely if it meets the requirements for new or upgraded USTs,
except that spill and overfill requirements do not have to be met,
and you meet the requirements above for temporarily closed USTs.

Closing Permanently

If you decide for any reason to close your UST permanently,
follow these requirements for permanent closure:

You must notify your implementing agency 30 days before
you permanently close your UST.

You must determine if contamination from your UST is
present in the surrounding environment. If there is
contamination, you will have to take the actions described
on page 30.

You can either remove the UST from the ground or leave it
in the ground. In both cases, the tank must be emptied and
cleaned by removing all liquids, dangerous vapor levels,
and accumulated sludge. These potentially very hazardous
actions need to be carried out carefully by following
standard safety practices. See

www.epa.gov/oust/cmplastc/standard.htm for a safe closure
standard. If you leave the UST in the ground, you must
also either fill it with a harmless, chemically inactive solid,
like sand, or close it in place in a manner approved by
your implementing agency. Your implementing agency
can help you decide how best to close your UST so that it
meets local requirements for closure.

People can be killed or
injured while closing or
removing tanks. Use safe
removal practices; see

www.e pa.'

/standard.htm

for a safe
closure standard. Only
trained professionals should
close or remove USTs.

Musts For USTs - DRAFT
Updated June 2015

-------
You must keep records that you can provide to an inspector during an inspection and prove your
facility m eets certain requirements. Check with your implementing agency to determine if there
are additional records you must keep.

You Must Keep These Records:

For This Long:

Spill And Overfill Prevention

UPDATED 1

Testing and inspection records for spill and overfill prevention equipment and
containment sumps used for interstitial monitoring of piping (beginning on
[three years after effective date])

Three years

Corrosion Protection

Records of your 60-day inspections for your corrosion protection system

Three most recent
inspections

Records of 3-year cathodic protection tests for your corrosion protection system

Two most recent tests

Release Detection

30-day monitoring results

One year

Tightness test results

Until the next test

UPDATED 1

Records for vour annual release detection equipment tests (beqinninq on rthrfl

Three years

years after effective date])

Copies of performance claims provided by release detection equipment manufacturers
or equipment installers

Five years

Records of maintenance, repair, and calibration of on-site release detection equipment

One year after servicing
is completed

If you use vapor monitoring or groundwater monitoring, you must keep records
of a site assessment showing that the monitoring system is set up properly
(beginning on [three years after effective date])

For as long as vapor
monitoring or
groundwater

UPDATED 1

monitoring is used

Walkthrough Inspections

UPDATED 1

Records showing you performed periodic walkthrough inspections (beginning on
[three years after effective date])

One year

Compatibility

UPDATED

If you store certain biofuels or other substances identified by your implementing
agency, you must keep records demonstrating compliance with the compatibility
requirement (beginning on [effective date])

For as long as the UST
system stores the
regulated substance

Operator Training

Records for each designated Class A, B, and C operator showing they have been For as long as the
trained (beginning on [three- years after effective- date]) operator is designated

at the facility

Repairs

Records showing that a repaired UST system was properly repaired

Until the UST system is
permanently closed or
undergoes a change-in-
service

Financial Responsibility

Records that document you have financial responsibility, as explained in EPA's
booklet. Dollars And Sense www.epa.qov/oust/Dubs/dollars.htm

Closure

Records of the site assessment results required for permanent closure

For at least three years
after closing an UST

Musts For USTs - DRAFT
Updated June 2015

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Section 101(14) of the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980
(CERCLA) designated hundreds of substances as hazardous.

The federal UST regulation applies to the same hazardous
substances designated in CERCLA, except for those listed
as hazardous wastes. These hazardous wastes are already
regulated under Subtitle C of the Resource Conservation
and Recovery Act and are not covered by the federal UST
regulation. See 40 CFR parts 260-270 for hazardous waste
regulations. Information on CERCLA hazardous substances
is available from EPA's Superfund Information Center at
800-424-9346.

What Requirements Apply To Hazardous
Substance USTs?

Hazardous substance USTs must meet the same
requirements described earlier concerning correct
installation; spill, overfill and corrosion protection;
corrective action; and closure. See pages 3-33.

In addition, hazardous substance USTs must have secondary
containment and interstitial monitoring for release detection,
as described below.

Secondary Containment

Hazardous substance USTs must have secondary
containment. A single-walled tank is the first (primary)
containment. Using only primary containment, a leak can
escape into the environment. But by enclosing an UST
within a second wall, leaks can be contained and detected
quickly before harming the environment.

There are several ways to construct secondary containment:

• Placing one tank inside another tank or one pipe
inside another pipe, making them double-walled
systems.

• Placing the UST system inside a concrete vault.

Hazardous substance USTs
must have secondary
containment and interstitial
monitoring.

Musts For USTs - DRAFT
Updated June 2015

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• Lining the excavation zone around the UST system with a
liner that the hazardous substance cannot penetrate.

Interstitial Monitoring

A hazardous substance UST must have a release detection system
that can indicate the presence of a leak in the confined space
between the first and the second wall. Several devices are
available to monitor this confined interstitial space. Interstitial
means between the walls. The federal UST regulation describes
these various methods and the requirements for their proper use.

For hazardous substance USTs installed before [ i e date],
you could have applied for an exception, called a variance, from
the requirement for secondary containment and interstitial
monitoring. Variances are not available for hazardous

substance USTs installed after Infective date].

What If You Have A Hazardous Substance Release?

You must follow the same short-term and long-term actions for
petroleum releases described on page 30, with two exceptions.

First, you must immediately report hazardous substance spills or
overfills that meet or exceed their reportable quantities to the
National Response Center at 800-424-8802 or 202-267-2675.

Second, you must also report hazardous substance spills or
overfills that meet or exceed reportable quantities to your
implementing agency within 24 hours.

However, if spill s or overfills are smaller than their reportable
quantities and are immediately contained and cleaned up, you do
not need to report them. You can get information on reportable
quantities by calling EPA's Superfund Information Center at 800-
424-9346.

Musts For USTs - DRAFT
Updated June 2015

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Government Links

• U.S. Environmental Protection Agency's Office
of Underground Storage Tanks:
www.epa.gov/oust. EPA's UST compliance
assistance:

www.eDa.gov/oust/cmplastc/index.htm

• State UST program contact information:
www, epa. gov/oust/states/statcon 1 .htm

• Tanks Subcommittee of the Association of State
and Territorial Solid Waste Management Officials
(ASTSWMO):

www.astswmo.org/Pages/Who We Are/Subcom
mittees/Tanks.htm

• New England Interstate Water Pollution Control
Commission (NEIWPCC): www.neiwpcc.org

Industry Codes And Standards

www, epa. gov/oust/cmpl astc/standard .htm

Other Organizations To Contact For UST
Information

www.epa.gov/oust/resource/othrasoc.htm

Musts For USTs - DRAFT
Updated June 2015

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xvEPA

United States
Environmental Protection
Agency

United States Environmental Protection Agency
5401P

Washington, DC 20460

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