See the “Need More Information”

section in this leaflet for sources of

answers to such questions as 

“Is my tank an ‘UST’?”

Are You Upgrading An

Underground Storage Tank

System? 

Are you responsible for meeting federal

requirements that apply to underground

storage tank (UST) systems storing

petroleum and installed before 

December 22, 1988? You must take action

on one of the following if your UST system

does not have spill, overfill, and corrosion

protection:

C Replace the old UST with a new one that

has spill, overfill, and corrosion protection;

or

C Properly close the old UST; or

C Upgrade the old UST with spill, overfill,

and corrosion protection. 

The federal deadline for taking action on

these choices is December 22, 1998.

However, you should act as soon as

possible to avoid contractor backlogs or

rising costs as the deadline approaches.

If you fail to comply by the deadline you 

can be cited for violations and fined.

Continue reading for helpful information on

upgrading your UST.

Adding Spill And Overfill Protection

You must add spill protection by installing a

“spill bucket.” A spill bucket is a catchment

basin sealed around the fill pipe and

designed to catch spills from a fuel delivery. 

Overfill equipment is designed to restrict or

stop the flow of fuel during delivery before

the tank reaches full capacity. Your UST

needs to have one of the following overfill

protection devices: automatic shutoff device,

overfill alarm, or ball float valve.

Adding Corrosion Protection To Tanks

What do you need to consider when you add

corrosion protection to upgrade the tank?

First, are you sure your tank does not

already have corrosion protection? Your tank

has corrosion protection if the tank is:

C Completely made of noncorrodible

material, such as fiberglass; or

C Made of steel having a corrosion-resistant

coating and having cathodic protection; or

C Made of steel clad or jacketed with

noncorrodible material. 

If your tank doesn’t fit one of these

descriptions, you will need to add corrosion

protection by either lining the interior of the

tank with a noncorrodible material or adding

cathodic protection. Cathodic protection

(CP) systems are of two types: impressed

current or sacrificial anode. Impressed

current systems are most often used when

adding CP to older USTs. You can also

combine lining with CP.

Can Your Tank Have Corrosion Protection

Added?

Before you can internally line a tank or add

CP, you must first have an integrity

assessment of the tank conducted. This

assessment will determine whether the

tank’s structure is sound and free of holes.

One way to assess a tank is to have a

human-entry internal inspection of the tank,

during which a trained professional enters

the tank to determine if it can be upgraded.

Additional integrity assessment methods

may be available as alternatives to using

human-entry inspection. You should check

with your implementing agency—usually the

state regulatory authority— to find out which

methods are valid in your area. Alternative

integrity assessment methods fall into two

categories:

C Integrity assessment methods that

comply with a standard code of practice

developed by a nationally recognized

association (such as the American Society

for Testing and Materials) or independent

testing lab. These methods are usually 

technologies—such as corrosion rate

modeling or tank wall thickness

measurement—that are in accordance

with a standard code of practice. Codes of

practice are often updated over time, so

the code used must be the one applicable

at the time the assessment is conducted.

C Vendor-supplied procedures that have

been evaluated and certified by a third

party as meeting criteria for establishing

the integrity of the tank. The “third party”

must be independent and have no

financial or organizational conflict of

interest with the vendor. A vendor-supplied

procedure is an application of a

technology, usually marketed as a

patented brand name and procedure.

Once the tank has passed any of the above

integrity assessment methods, you can have

the tank lined, have CP added, or do both.
Exercise Care In Choosing An Integrity

Assessment Method

You should ask prospective vendors for

documentation showing that their

assessment procedures meet an industry

code of practice or have been successfully

evaluated by a third party. If you have any

doubt, check with others who have used this

integrity assessment vendor and compare

warranties offered by vendors—in short, use

common business sense. Also, contact your

implementing agency for a list of approved

vendor-supplied procedures or additional

guidance.

Corrosion Protection For Piping

Piping also needs corrosion protection. You

can add corrosion protection for piping by

installing new piping that is corrosion

protected or adding cathodic protection to

existing steel piping.

Completing The UST Upgrade

Regulations and industry codes require a

qualified corrosion expert to design,

supervise installation, and inspect CP

systems installed at the UST site. The

system must be operating at all times to

provide protection. The system must be

tested by a qualified CP tester within 6

months of installation and at least every 3

years thereafter. You will need to keep the

results of the last two tests to prove that the

CP is working. In addition, you must inspect

an impressed current system every 60 days

to verify that the system is operating

properly. Keep results of your last three

inspections to prove that the impressed

current system is operating properly.

You also need to have leak detection

monitoring for the life of the tank. Once your

tank, piping, spill, and overfill upgrades are

complete, you can start using inventory

control and tank tightness testing every 

5 years. After the later of two dates—either

10 years after the tank has corrosion

protection or December 22, 1998—you must Solid Waste and Emergency Response (5401G)

start using a monthly leak detection method,

such as automatic tank gauging,

groundwater or vapor monitoring, interstitial

monitoring, or statistical inventory

reconciliation. (However, the period during

which inventory control combined with

tightness testing can be used will be less

than 10 years in those cases in which the

tank had corrosion protection added before

the entire UST system met upgrade

requirements.) Check with your

implementing agency for more specific

guidance on leak detection compliance.

Need More Information?

EPA can provide free, plain-English booklets

on general UST requirements, the 1998

deadline, UST system closure, leak

detection methods, inventory control,

manual tank gauging, and statistical

inventory reconciliation.

To order free booklets, determine if your

tanks need to meet federal UST

requirements, get more information about

UST requirements, or identify state

regulatory authorities call EPA’s toll-free

Hotline at 800-424-9346. Remember,

requirements and deadlines may be different

in some states, so check with your state

UST program office.

You can also find UST publications, links to

state regulatory authorities, and other

information on USTs at EPA’s Office of

Underground Storage Tanks Web site at

http://www.epa.gov/OUST/.

United States EPA 510-F-97-009

Environmental Protection August 1997

Agency

 

Are You

Upgrading An

Underground

Storage Tank

System?

 

Printed on Recycled Paper