Introduction
Release Prevention
EPA designed part of the technical regulations for underground storage tank (UST) systems to prevent releases from USTs. The regulations require owners and operators to properly install UST systems. They are required to protect their USTs from spills, overfills, and corrosion and require correct filling practices to be followed. In addition, owners and operators must report the existence of new UST systems, suspected releases, UST system closures, and keep records of operation and maintenance.
Release Detection
Because detecting UST systems releases quickly helps stop contamination before it spreads from UST sites, EPA requires owners and operators to detect releases from their UST systems. EPA allows three categories of release detection: interstitial, internal, and external. These three categories include seven release detection methods.
Tank and Piping Installation
In 2015, EPA revised the underground storage tank (UST) regulations. Below you will find the requirements for tank and piping installation.
If you install a UST system after December 22, 1988, it must be properly installed according to a code of practice developed by a nationally recognized association or independent testing laboratory and according to the manufacturer’s instructions (40 CFR Part 280.20(d)). Some states may require that UST installers be certified (in addition to being qualified) to conduct this type of work. You should check with your implementing agency to be sure that you follow the appropriate regulations.
2015 requirement for secondary containment and under-dispenser containment – Beginning on April 11, 2016, all new and replaced tanks and piping must meet the secondary containment requirements, including interstitial monitoring, according to the 2015 requirements for secondary containment. EPA considers piping replaced when 50 percent or more of the piping is removed and other piping is installed. In addition, beginning on April 11, 2016, new dispenser systems must have under-dispenser containment.
Installation includes excavation, tank system siting, burial depth, tank system assembly, backfilling around the tank system, and surface grading. Many mistakes can be made during installation. For example, mishandling of the tank during installation can cause structural failure of fiberglass-reinforced plastic tanks or damage to steel tank coatings and cathodic protection. The improper layout of piping runs, incomplete tightening of joints, inadequate cover pad construction, and construction accidents can lead to failure of the piping.
You need to make sure that installers carefully follow the correct installation procedures called for by industry codes and follow the manufacturer’s instructions.
Federal Regulations
In addition, federal regulations (40 CFR Part 280.20 (e)) require that owners and operators ensure one or more of the following methods of certification, testing, or inspection is used to demonstrate compliance with the installation requirements by providing certification of compliance on the UST notification form.
- the installer has been certified by the tank and piping manufacturers; or
- the installer has been certified or licensed by the implementing agency; or
- the installation has been inspected and certified by a registered professional engineer with education and experience in UST system installation; or
- the installation has been inspected and approved by the implementing agency; or
- all work listed in the manufacturer’s installation checklists has been completed; or
- the owner/operator has complied with another method for ensuring compliance with the installation requirements that are determined by the implementing agency to be no less protective of human health and the environment.
For more information regarding financial responsibility, operations and maintenance, and closure, visit the EPA website.