EPA UST Update

UST Regulatory Compliance Changes 2018 

Is your facility prepared for the EPA's regulations update for Underground Storage Tank systems in 2018?

Meeting UST Requirements in 2018

October 13th, 2018 is the deadline for UST owners and operators to meet the new underground storage tank requirements in the 2015 revised federal UST regulations. 

Below we provide a summary of the underground storage tank (UST) requirements for operation and maintenance (O&M), to help you understand the procedures you should follow in order to stay compliant in 2018. 

1. Release Detection

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.  

  

Additional 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.  

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.  

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.  

Make sure your site is ready for next year's EPA regulations update.

We will conduct a compliance review to determine what your facility will require to stay compliant with the upcoming 2018 EPA regulatory changes for underground storage tanks and provide you with information and proposed costs based on your site's specific needs. 

1.1. Automatic Tank Gauging Systems (For Tanks Only)  

O&M Actions  

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.  

You must begin performing periodic walkthrough inspections. See Section 6 for more information about these required walkthrough inspections.  

UST owners must have designated and trained operators. Most states already require operator training.  

O&M Records  

Keep results for your annual ATG system operation tests for at least three years and 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 UST system stores the regulated substance.  

1.2. Secondary Containment With Interstitial Monitoring (For Tanks And Piping)  

O&M Actions  

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.  

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.  

You must begin performing periodic walkthrough inspections.  

If you repair any secondary containment areas, you must test them for tightness within 30 days after the repair.  

UST owners must have designated and trained operators. Most states already require operator training.  

O&M Records  

Keep results for your annual release detection system operation tests for at least three years.  

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.  

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.  

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 UST system stores the regulated substance.

1.3. Statistical Inventory Reconciliation (For Tanks And Piping)  

O&M Actions  

You must begin performing periodic walkthrough inspections.  

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.  

UST owners must have designated and trained operators. Most states already require operator training.  

O&M Records  

Keep results for your annual release detection system operation tests for at least three 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 UST system stores the regulated substance.  

Make sure your site is ready for next year's EPA regulations update.

We will conduct a compliance review to determine what your facility will require to stay compliant with the upcoming 2018 EPA regulatory changes for underground storage tanks and provide you with information and proposed costs based on your site's specific needs. 

1.4. Continuous In-Tank Leak Detection  

O&M Actions  

You must begin performing periodic walkthrough inspections. 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.  

UST owners must have designated and trained operators. Most states already require operator training.  

O&M Records  

Keep results for your annual release detection system operation tests for at least three 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 UST system stores the regulated substance. 

1.5. Vapor Monitoring (For Tanks And Piping)  

O&M Actions  

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.  

You must begin performing periodic walkthrough inspections. These inspections include checking your handheld equipment for operability and serviceability. See Section 6 for more information about these required walkthrough inspections.  

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.  

UST owners must have designated and trained operators. Most states already require operator training.  

O&M Records  

Keep results for your annual release detection system operation tests for at least three 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 UST system stores the regulated substance. 

1.6. Groundwater Monitoring (For Tanks And Piping)  

O&M Actions  

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.  

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.  

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.  

UST owners must have designated and trained operators. Most states already require operator training.  

O&M Records  

Keep results for your annual release detection system operation tests for at least three 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 UST system stores the regulated substance. 

Make sure your site is ready for next year's EPA regulations update.

We will conduct a compliance review to determine what your facility will require to stay compliant with the upcoming 2018 EPA regulatory changes for underground storage tanks and provide you with information and proposed costs based on your site's specific needs. 

1.7. Inventory Control And Tank Tightness Testing (For Tanks)  

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.  

O&M Actions  

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.  

UST owners must have designated and trained operators. Most states already require operator training.  

O&M Records  

Keep your periodic walkthrough inspection records for at least one year.  

1.8. Manual Tank Gauging (For Tanks 1,000 Gallons Or Less)  

O&M Actions  

You must begin performing periodic walkthrough inspections. These inspections include checking your tank gauging stick for operability and serviceability.  

UST owners must have designated and trained operators. Most states already require operator training.  

O&M Records  

Keep your periodic walkthrough inspection records for at least one year.

1.9. Automatic Line Leak Detection (For Pressurized Piping)  

O&M Actions  

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.  

UST owners must have designated and trained operators. Most states already require operator training.  

O&M Records  

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, keep records demonstrating compatibility for as long as the UST system stores the regulated substance. 

1.10. Line Tightness Testing (For Piping)  

O&M Actions  

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.  

UST owners must have designated and trained operators. Most states already require operator training.  

O&M Records  

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.  

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 UST system stores the regulated substance.

Make sure your site is ready for next year's EPA regulations update.

We will conduct a compliance review to determine what your facility will require to stay compliant with the upcoming 2018 EPA regulatory changes for underground storage tanks and provide you with information and proposed costs based on your site's specific needs. 

2. Suspected or Confirmed Releases

No updates.

3. Spill And Overfill Protection

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. 

3.1. Spill Buckets  

 O&M Actions  

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.  

  • Visually check for any damage to the spill bucket. 
  • Remove any liquid or debris from the spill bucket. 
  • Check for and remove any obstructions, such as tank gauging sticks, in the fill pipe. 
  • Make sure your fill cap is securely fastened. 
  • 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 (It does not specify in writer’s document the deadline for the first 3 year test). 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.  

O&M Records  

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.  

Keep records of your periodic walkthrough inspections for one year.  

Keep delivery records for one year if you conduct walkthrough inspections of your spill bucket less frequently than every 30 days.  

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 UST system components in contact with the regulated substance, including spill buckets, for as long as the UST system stores the regulated substance.  

 3.2. Automatic Shutoff Devices  

O&M Actions  

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.  

Make sure the float operates properly. Make sure there are no obstructions in the fill pipe that would keep the floating mechanism from working.  

O&M Records  

You must maintain all records of the inspection for three years.  

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 UST system components in contact with the regulated substance, including overfill prevention equipment, for as long as the UST system stores the regulated substance. 

Make sure your site is ready for next year's EPA regulations update.

We will conduct a compliance review to determine what your facility will require to stay compliant with the upcoming 2018 EPA regulatory changes for underground storage tanks and provide you with information and proposed costs based on your site's specific needs. 

 3.3. Overfill Alarms 

O&M Actions  

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.

  • Ensure that the alarm can be heard or seen from where the tank is fueled.
  • Make sure that the electronic device and probe are operating properly.  


O&M Records  

You must maintain records of the inspection for three years.  

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 UST system components in contact with the regulated substance, including overfill prevention equipment, for as long as the UST system stores the regulated substance.(this paragraph was placed under “Compatibility Requirements”)  

3.4. Operating And Maintaining Your Ball Float Valve

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.  

Ball Float Valves  

O&M Actions  

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.  

O&M Records  

You must maintain records of the inspection for three years.  

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 UST system components in contact with the regulated substance, including overfill prevention equipment, for as long as the UST system stores the regulated substance.

4. Corrosion Protection

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.

5. Walkthrough Inspections

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.  

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. • 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. 


*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 federal regulation governing UST systems (40 CFR part 280).