Ira D. Conklin and Sons
EPA Underground Storage Tank Regulations Fact Sheet

Applicability - The U.S. Environmental Protection Agency (EPA) regulates underground storage tanks (USTs) and piping system in excess of 100 gallons that store petroleum (excluding fuel oils used consumptively on-site.)

Leak Detection Requirements

Underground Storage Tanks
All tanks must now have leak detection.  One of the following eight methods must be utilized:
  • Automatic tank gauging system.
  • Groundwater monitoring.
  • Vapor monitoring.
  • Secondary containment with interstitial monitoring.
  • Statistical inventory reconciliation - NOT daily inventory monitoring.
  • Manual task gauging (for tanks less than 2000 gallons).
  • Annual tank tightness testing and inventory control where tank and piping systems are not protected from corrosion or spill and overfill prevention have not been installed.
  • Five-year tank tightness testing and inventory control where tank and piping systems are protected form corrosion and have spill and overfill prevention equipment installed (can only be used for ten years after the tank is protected form corrosion or until December 1998, whichever is later).

Piping

Pressurized piping must have automatic line leak detectors and annual tightness testing or one of the following:
  • Groundwater monitoring.
  • Vapor monitoring.
  • secondary containment with interstitial monitoring.
  • Statistical inventory reconciliation - NOT daily inventory.
  • Monitoring.

Upgrading Requirements

You should be in compliance with the "upgrade" requirements if you meet all of the major () bullet points below:
  • Spill Protection provided by a catchment basin (to contain spills from delivery hoses).
  • Overfill protection provided by an automatic shutoff device, overfill alarm, or ball float valve.
  • Corrosion protection for the tank provided by one of the following:
    • Steel tank has corrosion-resistant coating AND cathodic protection (you must monitor the cathodic protection system annually).
    • Uncoated steel tank has cathodic protection system (you must monitor the cathodic protection system annually).
    • Uncoated steel tank has interior lined with noncorrodible material (you must internally inspect the tank after 10 years and every 5 years thereafter).
    • Uncoated steel tank has cathodic protection AND interior lined with noncorrodible material steel tank (you must monitor the cathodic protection system annually).
  • Corrosion Protection for piping provided by one of the following:
    • Uncoated steel piping has cathodic protection (you must monitor the cathodic protection system annually).
    • Steel piping has a corrosion-resistant coating AND cathodic protection (you must monitor the cathodic protection system annually).
    • Piping mad of (or enclosed in) noncorrodible material
  • If you have decided not to upgrade your existing UST system by December 1998 with the items above, you must properly close the UST system.  At closure a site assessment must be done to document that no contamination exists in the environment.  If you subsequently install a new UST system, the new installation meets all the regulatory requirements for installations after December 22, 1988.

For inquiries email bob@iraconklin.com

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Copyright © 1999 Ira D. Conklin & Sons, Inc.