1

DRAFT MEMORANDUM | 20 November 2008 

TO Cho-Yi Kwan and Tim Roberts, EPA 

FROM Cynthia Manson and Neal Etre, Industrial Economics, Inc. 

SUBJECT Preliminary Assessment and Scoping of Data Related to Potential Revisions to the UST 

Regulations; Tasks 2-4, Work Assignment 1-25 

EPA’s Office of Underground Storage Tanks (OUST) is currently exploring the 

possibility of revising the existing regulations associated with certain types of 

underground storage tank (UST) systems and equipment. Specifically, the Agency is 

considering amending the requirements to address four issues: (1) 

technical/administrative fixes, (2) deferred UST systems, (3) existing regulatory gaps, 

and (4) potential deregulatory options. 

Currently, the Agency is interested in developing a scoping analysis of the potential 

impacts of refining the existing regulations to do the following: 

• Eliminate deferrals of release detection requirements for emergency generator 

tanks under 40 CFR 280 SubPart D (40 CFR 280.40 ff); 

• Eliminate deferrals of technical standards and other requirements for field 

constructed tanks and airport hydrant refueling systems under 40 CFR 280 

Subparts B, C, D, and E, and G (40 CFR 280.2 ff); 

• Require periodic tightness testing for spill buckets and sumps; 

• Require leak detection and recordkeeping for spill buckets and sumps; 

• Remove certain long-term recordkeeping requirements related to system repairs 

and testing; and 

• Eliminate corrosion protection requirements for safe suction steel piping. 

This memorandum provides an initial scoping-level analysis of the universe of facilities 

and total annualized costs that would be associated with these changes. The memo is 

organized to include: 

• An overview of the baseline (existing) state regulations related to the targeted 

requirements, and an estimate of the number and type of facilities and tanks 

likely to be affected by each requirement; 

• A brief characterization of the facilities, locations, and industries likely to be 

affected by changes to the regulation; 

• A summary table of estimated costs associated with each of the changes under 

examination; 

INTRODUCTION AND 

BACKGROUND 
 

 2 

• A brief discussion of the general conclusions and next steps for refining this 

screening analysis; and 

• Three detailed appendices documenting the methodologies, assumptions, and 

analyses used to examine the regulatory revisions under consideration. 

o Appendix A describes the summary of baseline state regulations, and 

also includes the evaluation of universe of facilities and costs associated 

with removal of deferrals for emergency generator tanks, fieldconstructed tanks and airport hydrant refueling systems. 

o Appendix B describes the evaluation of the universe and costs associated 

with the implementation of tightness testing and vapor monitoring 

requirements for spill buckets and sumps. 

o Appendix C describes the evaluation of cost savings associated with 

removing specific long-term recordkeeping requirements for repairs and 

testing, and the elimination of corrosion protection requirements for safe 

suction steel piping. 

Note that the analyses presented in this memorandum and appendices are all limited to 

initial, screening-level efforts to assess general facility universes and costs. They are 

designed to help direct EPA’s efforts as the Agency refines its priorities. To address 

uncertainties, we present ranges of results where possible, and typically use conservative 

(i.e., high-cost) assumptions. 

The purpose of this memorandum is to develop general conclusions about the total cost of 

regulatory revisions and the comparative costs of different potential actions. A key part 

of this memorandum is the discussion of limitations and recommendations for next steps. 

The IEc team reviewed state regulatory information to determine the states that currently 

(i.e., in the baseline) have regulations consistent with the revisions that EPA is 

considering. The preliminary cost analyses assume that tanks in states with existing 

regulations incur no additional costs to come into compliance with revisions to UST 

regulations. Exhibit 1 summarizes the status of current state regulations associated with 

each of the revisions under consideration. Appendix A provides more detail on the 

methodology used to develop these estimates, and also provides a summary of the 

number of tanks of each type located in each state. 

As Exhibit 1 indicates, fewer than half of all states and territories already have baseline 

regulations consistent with the revisions that EPA is considering. However, some of the 

states that have removed deferrals from emergency generator tanks and require tightness 

testing of sumps are large states (e.g., California) with large populations of tanks. 

Note that these results represent screening level analysis of state underground storage 

tank requirements. A more detailed examination of specific state requirements may 

revise these initial findings if it is determined that state requirements are not consistent 

with EPA revisions or if additional state requirements (e.g., fire control requirements) are 

identified that might effectively regulate the targeted tanks. 

SUMMARY OF 

RELEVANT STATE 

REGULATIONS 
 

 3 

EXHIBIT 1: SUMMARY OF STATE AND TERRITORIAL REGULATIONS RELATED TO DEFERRED 

TANKS AND SPILL BUCKETS/SUMPS

State 

Emergency 

Generator 

UST 

Release 

Detection 

Required 

(Y/N) 

Airport 

Hydrants 

Deferred 

from 40 

CFR 280 

Subparts 

(Y/N) 

FieldConstructed 

Tanks 

Deferred 

from 

Subpart’s 

(Y/N) 

Spill 

Buckets/Sumps 

Tightness 

Testing 

Required (Y/N)

 B C D E G B C D E G 

Alabama Y Partial Y N Y N Y Partial Y N Y N Y Y 

Alaska Y Partial N Y N N Y Partial N Y N N Y N 

American 

Samoa 

 N Y Y Y Y Y Y Y Y Y Y Y Y N 

Arizona Y Y Y Y Y Y Y Y Y Y Y Y Y N 

Arkansas N Y Y Y Y Y Y Y Y Y Y Y Y N 

California Y N N N N N N N N N N N N Y 

Colorado N Y Y Y Y Y Y Y Y Y Y Y Y N 

Connecticut N Y Y Y Y Y Y Y Y Y Y Y Y N 

Delaware Y Partial Y Y Y N Y Partial Y Y Y N Y Y 

District of 

Columbia Y Partial 

YYYNY

Partial 

Y Y Y N Y N 

Florida N N N N N N N N N N N N N Y* 

Georgia N Y Y Y Y Y Y Y Y Y Y Y Y N 

Guam Y N N N N N N N N N N N N N 

Hawaii N Partial Y Y Y N Y Partial Y Y Y N Y N 

Idaho Y N N N N N N N N N N N N N 

Illinois Y Partial Y Y Y N Y Partial Y Y N N Y N 

Indiana N Y Y Y Y Y Y Y Y Y Y Y Y N 

Iowa N Y Y Y Y Y Y Y Y Y Y Y Y N 

Kansas N Y Y Y Y Y Y Y Y Y Y Y Y N 

Kentucky N Y Y Y Y Y Y Y Y Y Y Y Y N 

Louisiana N Y Y Y Y Y Y Y Y Y Y Y Y N 

Maine Y N N N N N N N N N N N N N 

Maryland N N N N N N N N N N N N N Y 

Massachusetts N N N N N N N N N N N N N Y 

Michigan N Y Y Y Y Y Y Y Y Y Y Y Y N 

Minnesota N Y Y Y Y Y Y N N N N N N N 

Mississippi N Y Y Y Y Y Y Y Y Y Y Y Y N 

Missouri N Y Y Y Y Y Y Y Y Y Y Y Y N 

Montana Y Partial Y Y Y N N Partial Y Y Y N N N 
 

 4 

State 

Emergency 

Generator 

UST 

Release 

Detection 

Required 

(Y/N) 

Airport 

Hydrants 

Deferred 

from 40 

CFR 280 

Subparts 

(Y/N) 

FieldConstructed 

Tanks 

Deferred 

from 

Subpart’s 

(Y/N) 

Spill 

Buckets/Sumps 

Tightness 

Testing 

Required (Y/N)

 B C D E G B C D E G 

Nebraska N Y Y Y Y Y Y Y Y Y Y Y Y N 

Nevada N Y Y Y Y Y Y Y Y Y Y Y Y N 

New 

Hampshire Y N 

NNNNN

N 

N N N N N Y* 

New Jersey N N N N N N N N N N N N N N 

New Mexico Y Y Y Y Y Y Y Y Y Y Y Y Y N 

New York Y N N N N N N N N N N N N N 

North 

Carolina N Y 

YYYYY

Y 

Y Y Y Y Y N 

North Dakota N Y Y Y Y Y Y Y Y Y Y Y Y N 

Northern 

Mariana 

Islands N Y 

YYYYY

Y 

Y Y Y Y Y N 

Ohio N Partial Y Y Y N Y Partial Y Y Y N Y Y 

Oklahoma N Partial Y Y Y N Y N N N N N N Y* 

Oregon N Y Y Y Y Y Y Y Y Y Y Y Y N 

Pennsylvania N N N N N N N N N N N N N Y* 

Puerto Rico Y Y Y Y Y Y Y N N N N N N N 

Rhode Island Y N N N N N N N N N N N N N 

South 

Carolina N Y 

YYYYY

Y 

Y Y Y Y Y N 

South Dakota N N N N N N N N N N N N N N 

Tennessee N Y Y Y Y Y Y Y Y Y Y Y Y N 

Texas Y N N N N N N N N N N N N N 

US Virgin 

Islands 

N Y Y Y Y Y Y Y Y Y Y Y Y N 

Utah N Y Y Y Y Y Y Y Y Y Y Y Y Y* 

Vermont Y N N N N N N N N N N N N N 

Virginia N Y Y Y Y Y Y Y Y Y Y Y Y N 

Washington Y Partial N Y Y N N Partial N Y Y N N N 

West Virginia N Y Y Y Y Y Y Y Y Y Y Y Y N 

Wisconsin Y Partial Y Y N Y Y Partial Y Y N Y Y N 

Wyoming Y Y Y Y Y Y Y Y Y Y Y Y Y N 
 

 5 

State 

Emergency 

Generator 

UST 

Release 

Detection 

Required 

(Y/N) 

Airport 

Hydrants 

Deferred 

from 40 

CFR 280 

Subparts 

(Y/N) 

FieldConstructed 

Tanks 

Deferred 

from 

Subpart’s 

(Y/N) 

Spill 

Buckets/Sumps 

Tightness 

Testing 

Required (Y/N)

 B C D E G B C D E G 

Total Yes 21 30 28 11 

Total No 35 15 18 45 

Total Partial NA 11 10 NA 

* While these states have some baseline tightness testing requirements, it is not clear that they require tightness testing of sumps and spill 

buckets after installation; therefore, they are not included as “baseline requirements” in the analysis of costs. 

EPA’s potential regulatory revisions would affect four different populations of tanks: 

• Tanks storing fuel to provide emergency generator support, with the exception of 

emergency tanks at nuclear power plants; 

• Tanks (both storage tanks and hydrants) that are part of stationary airport hydrant 

refueling systems; 

• Field-constructed tanks; and 

• Tanks, sumps, and spill buckets within the universe of facilities currently 

regulated under existing regulations. 

Exhibit 2 provides summary information about the populations of each of these tanks, 

including information about the characteristics of the “industries” and facilities that use 

these tanks. Our preliminary investigation has clearly identified only a small number of 

sectors with significant numbers of specific types of tanks. At this time, field constructed 

tanks appear to be in the process of being phased out, and the small remaining population 

is used principally by the Department of Defense. 

Similarly, airport hydrant refueling systems are relatively uncommon except for a small 

population at Department of Defense facilities and an even smaller population at 

commercial airports. Note that all of these facilities appear to use aboveground storage 

tanks as the principal storage unit for the hydrants, and may therefore not be subject to 

UST regulations. However, because the hydrants themselves are underground and could 

in some case, contain more than 10 percent of total system volume, we include all 

hydrant systems in this screening assessment. 

Exhibit 2 indicates that both commercial airport hydrant refueling systems and gasoline 

stations are in industry sectors that are dominated by small entities, with narrow profit 

margins of less than five percent and average revenues less than $3 million. This 

suggests that high capital or operations and maintenance (O&M) costs associated with 

revisions to the current regulations could have a significant impact on small businesses in 

TANK UNIVERSE AND 

INDUSTRY 

CHARACTERIZATION
 

 6 

these sectors. Alternatively, reductions in the burden associated with current 

requirements may be valuable to facilities in these sectors. Note, however, that the North 

American Industrial Classification System (NAICS) sector 48811 (Airport Operations) 

includes a range of airport operations from large commercial airports to general aviation 

facilities, and studies suggest that hydrant refueling systems are concentrated at larger 

facilities in this sector.1

 If that is the case, then Exhibit 2 likely overstates the potential 

that small entities would be affected by regulation of hydrant systems. 

Moreover, most airport hydrant refueling systems and virtually all field-constructed tanks 

appear to be restricted to Department of Defense facilities; changes in the management of 

these tanks will have no impact on small businesses. 

The regulations affecting sumps and spill buckets, similar to most underground storage 

tank regulations, address the entire universe of underground storage tanks. This universe 

is dominated by tanks operated by fuel service stations. While underground storage tanks 

are used in a broad range of industrial sectors (a previous analysis for EPA relying on 

state databases and industry associations has identified underground storage tanks in use 

in virtually every sector of the economy, including agriculture, commercial, 

communications and utilities, construction, government, institutions, manufacturing, 

mining, services, and transportation) the analyses concludes that over 80 percent of tanks 

are associated with retail motor fuel sales.2

 

Therefore, as a simple screening approach, we examine spill bucket and sump impacts 

assuming that all facilities with USTs are retail gasoline outlets, and have 2.65 tanks per 

facility. This assumption likely overstates small business impacts and facility-level 

implementation costs, and may understate total costs associated with paperwork (e.g., 

reading the regulations, recordkeeping requirements). However, given the uncertainty 

about total number of facilities, we determined that an initial, simple approach is more 

easily modified as EPA refines its analysis. 

The one specific population of tanks for which it has been difficult to make an industry 

characterization is emergency generator tanks. It is likely that these tanks are associated 

with a range of facility types and sizes, particularly manufacturing, research, power, and 

medical facilities, but also hotels, recreation and sports facilities, and retail or wholesale 

sales and storage locations. A more detailed examination of these facilities is anticipated 

as a next step in assessing potential small business impacts and costs; this revision could 

in turn be used to update spill bucket and sump assumptions. 

In addition, this analysis represents a screening level overview of general industry 

characteristics, but does not attempt to identify or characterize specific facilities likely to 

be affected by a change in regulation. 

 

1

 See, for example, Michael Kluttz, PE, “Aircraft Hydrant Fuel System Design Issues,” presented at The International Forum 

on Emergency and Risk Management, Singapore Aviation Academy, 10 – 12 January 2005 

2

 See Draft Industry and Facility Profiles, memorandum produced by E2 for EPA Office of Underground Storage Tanks, 

December 18, 2006. E2 estimates that over 84 percent of roughly 625,000 tanks are associated with retail fuel outlets. 

While this estimate does not include tanks related to construction, mining, or tanks owned by the government, it is unlikely 

that the dominance of retail gasoline outlets would be affected by adjustments to include these populations. 
 

 7 

EXHIBIT 2 TANK UNIVERSES AND INDUSTRY CHARACTERIZATION 

TANK TYPE 

ESTIMATED 

NUMBER OF 

TANKS AND 

FACILITIES IN 

UNIVERSEa

KEY SECTOR AND 

NAICS CODE 

PERCENTAGE OF 

“SMALL ENTITIES” b

AVERAGE 

REVENUES OF 

SMALLER 

FACILITIES IN 

SECTOR c

AVERAGE PROFIT 

MARGIN OF SMALLER 

FACILITIES IN SECTOR d

Emergency 

Generator Tanks 199,526 tanks Varies; more research needed TBD TBD TBD 

Airport Hydrant 

Refueling Systems 

201 hydrants National Security 

928110 Not applicable N/A N/A 

40 hydrants 

Airport 

Operations 

48811/488119e

89% of estab. In sector 

small (<$7 million 

revenue) 

Note: hydrant systems 

likely concentrated at 

large facilities 

$1.8 million 

4.5 percent (avg for all 

facilities in sector 

488119 w/ annual 

sales <$10 million) 

Field Constructed 

Tanks 239 tanks National Security 

928110 Not applicable N/A N/A 

Tanks with Sumps 

and Spill Buckets 

629,866 tanks 

237,865 

facilities 

Gasoline Stations 

w/Convenience 

Storesf

447110 

(80% of facilities) 

47% small or singleunit estab. (sales less 

than $25 million) 

$2.3 million <1 percent 

Other Gasoline 

Stations 

447190 

(20% of facilities) 

89% small or singleunit estab. (sales less 

than $8 million) 

$1.8 million 1.7 percent 

Notes and Sources: 

a. The estimate of tanks with sumps and spill buckets make a high-end assumption that all tanks are associated with 

gasoline stations and stations (facilities) each have 2.65 tanks. This estimate does not attempt to estimate facilities that 

may have more tanks or may have tanks for other reasons (e.g., emergency generator tanks). 

b. Small facility percentages are based on revenue definitions from the Small Business Administration (SBA) 

(http://www.naics.com/sba_sizestandards.htm), combined with information on the distribution of establishments of 

different sizes within specific NAICS codes from the U.S. 2002 Census of Manufactures. For gasoline stations, single 

establishment revenues are almost always under small business size limits; therefore all single-unit facilities are 

considered small businesses. Information on distribution of revenues per facility is at 

http://www.factfinder.census.gov/servlet/IBQTable?_bm=y&-NAICS2002=447110&-ds_name=EC0244SSSZ4&-_lang=en 

and http://www.factfinder.census.gov/servlet/IBQTable?_bm=y&-NAICS2002=447190&-ds_name=EC0244SSSZ1&-_lang=en

for stations with and without convenience stores, respectively. Information on single and multi-unit firms is at: 

http://factfinder.census.gov/servlet/IBQTable?_bm=y&-ds_name=EC0244SSSZ3&-NAICS2002=447190 and 

http://factfinder.census.gov/servlet/IBQTable?_bm=y&-ds_name=EC0244SSSZ3&-NAICS2002=447110 for gasoline stations 

without and with convenience stores, respectively. 

c. Revenues represent weighted average revenues reported by the U.S. 2002 Census of Manufacturers for facilities with 

revenues less than SBA size standards. See Census information outlined in note b above. 

d. Average profit margins based on Risk Management Associations’ 2006-2007 Annual Statement Studies. Profits after taxes 

identified as average for facilities in NAICS codes with revenues less than SBA standards 

e. Sector 48811 includes a range of operations (e.g., fuel supply, air traffic control) at airports of different sizes; the 

airports that employ hydrant refueling systems are likely larger than average facilities in this sector. Therefore, this 

information may overstate the percentage of hydrant systems that are operated by small entities. 

f. The Census definition of convenience stories is not specific; in contrast, the National Association of Convenience Stores 

specifies off-street parking, a specific range and number of products for sale (totaling over 500 products), square 

footage, and extended hours of operation as part of the definition of “convenience store.” To the extent that the 

Census facilities differ from NACS facilities, it will be necessary to reconcile these definitions to develop an accurate 

estimate of the number of USTs associated with convenience stores. 
 

 8 

SMALL BUSINESS SCREENING METHOD 

To assess the potential small business impacts, the IEc team used a simple screening 

approach that cross-references Small Business Administration (SBA) data on small 

business size classes with U.S. Census data identifying establishments by size. 

For airport hydrant refueling systems, IEc identified Airport Operations (NAICS code 

48811 and 488119) as the relevant industry; the SBA revenue standard for this industry is 

$6.5 million per year in sales. The 2002 Economic Census data for NAICS code 488119 

identified that 89 percent of establishments in the sector (which includes a range of 

operations) report annual sales of less than $7 million. IEc then calculated average 

revenues for these facilities by using a weighted average of the number of facilities in 

each U.S. Census revenue category and the mid-point value of the revenue category 

range. Finally, IEc examined average profit profiles from companies in the sector using 

Risk Management Associates’ Annual Statement Studies. 

To the extent that the airports with hydrant refueling operations are representative of 

establishments in NAICS code 488119, it is possible that several of these refueling 

systems are associated with small businesses. However, it appears likely that hydrants 

are used only at larger facilities; in this case small entity impacts would be limited. 

Furthermore, only 40 facilities in a sector of over 1,100 establishments are at issue, 

suggesting that the total number of affected facilities is unlikely to meet the threshold for 

a “substantial number” of small entities.3

 

To identify a “worst case” screen of the small business impacts associated with regulating 

spill buckets and sumps, the analysis assumes that all facilities are gasoline stations. This 

screen does not consider the range of industries associated with emergency generator 

tanks, or industries that employ fleet fueling facilities. While a more detailed 

examination of these sectors will provide a better estimate of the total number of small 

entities affected, it is likely that gasoline stations have a higher (i.e., worst case) 

proportion of small entities than most other sectors with USTs. 

For retail gasoline stations, IEc identified two relevant NAICS codes: 447110 (Gasoline 

Stations w/Convenience Stores) and 447190 (Other Gasoline Stations) with $25 million 

and $8 million SBA size standards for annual sales, respectively. IEc employed the 

same methodology with the same data sources, with one additional step: we also 

examined Census data on the number of single-unit and multi-unit firms in the industry. 

In the case of Gasoline Stations w/Convenience Stores, while over 99 percent of all 

establishments report sales of under $25 million, roughly half of these establishments are 

in multi-establishment firms; the initial screening assessment assumes that only singleunit establishments (47 percent of the total) in this sector are small businesses. Similarly, 

for Other Gasoline Stations, almost 95 percent of establishments report sales under the 

SBA size standard of $8.0 million, and only 10 percent of establishments are multi-unit. 

Therefore, the initial screening assessment concludes that at least 89 percent of these 

establishments are likely to be small businesses. 

 

3

 Because only 40 commercial facilities have hydrant systems, and because some of these are likely to be aboveground 

systems, it is unlikely that a “substantial number” of small entities would be affected in any scenario.
 

 9 

NOTE ON SPILLS FROM KEY TANK POPULATIONS 

As one part of this screening analysis, the IEc team attempted to identify the number of 

leaks associated specifically with deferred tank systems, and determined that no national 

level data sources provide sufficient information to isolate spills associated with specific 

tanks. The main national reporting system for oil-related releases is the Emergency 

Response Notification System (ERNS). ERNS is a database of oil and chemical spill 

incidents reported to the U.S. Coast Guard through its National Response Center, and 

includes spills from any facility that meet certain “reportable quantity” definitions. 

However, ERNS data does not consistently provide detailed information about the type of 

facility or source (i.e., tank) associated with the spill. 

State data sets may in some cases include information about leaks from tank systems 

deferred under Federal regulations, particularly in states that do not defer these systems. 

One potential approach to calculating the number of spills from deferred systems would 

be to collect and review data from states that require reporting from the relevant systems. 

If state data include sufficient descriptive tank information to identify specific tank types, 

then a systematic evaluation of the number of leaks from key tank populations may be 

possible. However, it is important to note two key limitations to this approach: 

• It is not clear at this time whether any states routinely track information that would 

allow identification of the specific tank populations in question (i.e., airport 

hydrant refueling system tanks, emergency generator tanks, and field-constructed 

tanks); and 

• It is not clear that states with reporting requirements for deferred systems are 

representative of national practice. If, for example, target states have more 

stringent requirements in other aspects of tank operations, then leaks may have 

different frequencies than leaks in other states. 

Using the information gathered about tank and facility populations and the data available 

on baseline state regulations, we have developed preliminary cost estimates for each of 

the regulatory revisions under examination. While each regulatory revision requires a 

slightly different methodology, all methodologies involve the same basic approach: 

• Identification of the universe of tanks and facilities likely subject to regulatory 

changes; 

• Identification of the number of tanks and facilities regulated in the baseline by 

state or other Federal regulations; 

• Estimation of the unit costs associated with capital, O&M, and recordkeeping 

activities that will change under the revisions under consideration; and 

• Adjustment as necessary to identify one-time, annual, total, and total annualized 

costs associated with the regulatory revisions. 

Exhibit 3 shows the preliminary cost estimates for each of the proposed regulatory 

revisions. Note that these initial estimates for emergency generator USTs and for 

regulations affecting spill buckets and sumps make the simplifying assumption that the 

each facility has an average number of 2.65 tanks. Particularly for emergency generator 

SUMMARY OF 

COST ESTIMATES 

FOR REGULATORY 

REVISIONS 
 

 10 

USTs, this assumption is likely to require revision as more refined analyses are 

developed. Until a better estimate of specific tank populations (e.g., emergency generator 

tanks) is available, however, a simple, consistent assumption appears reasonable. 

COSTS ASSOCIATED WITH PROPOSED REGULATORY REVISIONS 

PROPOSED REVISION NUMBER OF TANKS 

OR FACILITIES 

AFFECTED 

ONE-TIME COSTS 

PER FACILITY 

TOTAL ONETIME COSTS ANNUAL COSTS PER 

FACILITY 

TOTAL ANNUAL 

COST IMPACT 

Removal of Subpart D 

Deferral for 

Emergency Generator 

USTs 

129,364 tanks; 

48,817 facilities

$164.50 

For reading 

regulations 

$8.0 million ~$404 $19.7 million 

Removal of Subpart 

B,C,D,E, and G 

Deferrals for Airport 

Hydrant Refueling 

Systems 

241 tanks; 91 

facilities 

(38 – 56% of 

hydrants regulated 

in baseline for 

different Subparts) 

Retrofit costs 

for older 

existing 

facilities – 

$26,500 - 

$274,000 per 

facility 

Unknown – 

could be 

several 

million 

dollars if 

feasible 

~$342 

Doesn’t include 

O&M costs for 

upgraded leak 

detection systems 

$0.08 million 

Removal of Subpart 

B,C,D,E, and G 

Deferrals for FieldConstructed USTs 

239 tanks; 

90 facilities 

(55 – 88% of tanks 

regulated in 

baseline for 

different Subparts) 

$493.5 

For reading 

regulations 

$1,645 ~$953 $0.06 million 

Tightness Testing for 

Spill Buckets (1 & 3-

yr testing) 

629,866 tanks; 

237,685 facilities 

(~14% of tanks 

regulated in 

baseline) 

$64.75 

For reading 

regulations 

$15.4 

million 

$21 - $68 million $121 - $317 

million 

Includes $4 - 

$6 million in 

recordkeeping 

Excludes 

repair costs 

Tightness Testing for 

Sumps (1 and 3 year) $28 - $87 million 

Tightness Testing for 

Dispenser Pans (1 and 

3 year testing) 

$68 - $210 million 

Leak Detection for 

Spill Buckets (6 or 12 

mos recordkeeping) $129.75 

For reading 

regulations 

$30.8 

million 

$102 – $177 million 

$425 – 728 

million 

Includes $16 - 

$20 million in 

recordkeeping 

Leak Detection for 

Sumps (6 or 12 mos) $102 – $177 million 

Leak Detection for 

Dispenser Pans 

(6 or 12 mos) 

$205 - $354 million 

Reduction in 

recordkeeping for 

repairs 

18,875 facilities 

per year 

Not calculated Not 

Calculated 

$3.15 - $4.42 

savings - Reflects 

range of time 

frames 

Savings of 

$0.06 - $0.08 

million 

Reduction in leakdetection 

recordkeeping 

237,533 facilities Not calculated Not 

Calculated $18.81 savings Savings of 

$4.47 million 

Elimination of 

corrosion protection 

requirements for safe 

suction steel piping 

Very small number 

of facilities and 

tanks; declining 

Not calculated Not 

Calculated Not Calculated Not Calculated

EXHIBIT 3 
 

 11 

As Exhibit 3 illustrates, the potential costs associated with the regulatory revisions range 

considerably, including costs that range from less than $100,000 to over $700 million, 

and cost savings that range from less than $100,000 to over $4 million. The combination 

of a large population of tanks and high costs associated with additional equipment and 

testing result in very high costs associated with regulating spill buckets and sumps. 

Additional scenarios that consider the costs of repairs to sumps and spill buckets that fail 

tightness testing and also consider continuous automated leak detections calculate costs in 

excess of $1 billion; these scenarios are considered in detail in Appendix A. 

In contrast, the small universe of airport hydrant refueling systems and field-constructed 

tanks, combined with existing state regulations and requirements under 40 CFR 112 (the 

SPCC regulations) result in very modest cost impacts associated with removing deferrals 

from these tanks. Cost savings estimates are also driven by the number of facilities; 

costs per facility are modest in all cases. 

Detailed information about the methodologies and data used to develop these estimates is 

presented in Appendices A, B, and C. However, a number of key assumptions and 

limitations for each regulatory revision are noteworthy: 

• Emergency Generator USTs: The costs of removing the Subpart D deferral 

from emergency generator USTs are driven largely by the number of tanks and 

facilities. For this screening analysis, a high-end estimate of the number of 

emergency generator USTs was developed by assuming that all non-gasoline 

station USTs are emergency generators. A more refined estimate of this set of 

tanks could reduce the total cost estimate. 

• Airport Hydrants: Airport hydrant system costs reflect two significant 

assumptions. First, it is assumed that only the hydrants are targeted by the 

regulation because storage tanks associated with these systems are typically 

above-ground storage tanks (ASTs). Second, it is assumed that these systems, in 

part, are subject to standards under the SPCC regulations that are relatively 

consistent with the revisions under consideration by OUST, and will therefore not 

require significant capital upgrades.4

 However, retrofitting older systems with 

leak detection and tightness testing capabilities under Subpart D may be 

expensive or infeasible – more information is needed to determine how many 

facilities would require this and what unit costs would apply. 

• Field-Constructed Tanks: Field constructed tank costs reflect an assumption 

that existing tanks are generally compliant with SPCC regulations and current 

industry standards and will not require significant capital upgrades. This 

assumption may be less valid for piping and spill control systems associated with 

 

4

 While SPCC regulations do not specify particular leak detection protocols, the regulations require that plans conform with 

industry standards, and these can often be consistent with UST requirements. For example, industry standards relevant to 

leak detection identify commonly used inventory management systems such as automated tank gauging (ATG) systems and 

other types of inventory reconciliation, which provide continuous monitoring of the entire system and can alert operators to 

leaks. 
 

 12 

the tanks; if it is determined that these systems require upgrades beyond those 

required by SPCC, then cost estimates for this revision could increase. 

• Tightness Testing for Spill Buckets and Sumps: The main uncertainty 

associated with the costs of this regulatory revision is the treatment of the 

additional repair costs that will also result due to improved information from 

tightness testing. These repairs are not currently specified under existing Federal 

and state regulations, but could reasonably be considered baseline compliance 

costs. The current analysis summarized in Exhibit 3 does not include these costs, 

but Appendix A provides an estimate of their potential magnitude; they could 

represent an additional $64 - $231 million per year. 

• Leak Detection for Spill Buckets and Sumps: The significant cost range for 

this regulatory revision results from uncertainty about what technology will be 

used. Fixed, automated leak detection methods are both very expensive and 

potentially ineffective. Alternative methods that address only facilities that have 

failed tightness testing have lower costs and have been estimated in general, but it 

is not clear whether these alternatives are consistent with EPA priorities. 

• Cost Savings for Reductions in Recordkeeping: The estimates of reductions in 

recordkeeping costs are initial, high-end estimates of cost savings. They do not 

correct for the cost associated with reading regulations, or the potential that some 

states may not be able or willing to implement the same regulatory revisions. 

This issue will affect all cost-saving or de-regulatory options, and may be 

important to clarify. 

• Safe Suction Steel Piping: Preliminary research on the use of safe suction steel 

piping suggests that it is a rare and diminishing technology, and that cost savings 

associated with removing corrosion protection requirements would have modest 

impacts, if any. 

These analyses provide a reasonable screening level overview of the potential costs and 

cost savings associated with the various regulatory revisions identified by EPA. Based on 

the analysis, several initial conclusions can be drawn, as follows: 

• Regulatory changes targeted at field-constructed tanks and airport systems 

will have limited impact: The populations of these tanks and systems are small, 

and are dominated by Department of Defense facilities. It does not appear that a 

significant number of new systems is being installed. Moreover, a number of 

states and SPCC regulations are likely to assure that tanks, and to some extent 

piping and spill control, are consistent with UST regulations. As a result, both the 

costs and the impacts associated with removing deferrals on these types of tanks 

are likely to be modest.

• Tightness-testing and vapor monitoring of sumps is likely to incur significant 

costs: The number of facilities affected by tightness-testing and vapor monitoring 

of sumps ensures that the costs of these regulatory revisions will be significant, 

and will likely be in excess of $100 million. A number of states address tightness 

GENERAL 

CONCLUSIONS AND 

NEXT STEPS 
 

 13 

testing, but not all of these appear to address sumps and spill buckets, though 

further investigation could identify additional regulations (e.g., fire prevention 

regulations) that address vapor monitoring. These actions may also have impacts 

on small businesses, given the dominance of small entities in the gasoline station 

sector. 

• Cost savings efforts could be significant, but will depend on state 

implementation procedures: Cost savings associated with streamlining of 

recordkeeping and other activities could be significant if a large number of 

facilities are affected by the regulation. As noted, an 19 dollar savings per facility 

results in annual cost savings of over $4 million nationally. However, this initial 

exercise did not address the limitations on de-regulation that result from state 

restrictions or procedures that could prevent the implementation of cost-saving 

actions. 

These conclusions, and some of the limitations of the screening analysis, suggest the 

following next steps as EPA continues to assess regulatory revisions: 

• Clarify certain “standard” issues that will affect all regulatory changes. 

These include the limited ability of states to implement de-regulatory changes as 

noted above, and the need to clarify and harmonize the interpretation of 

paperwork requirements to ensure consistency and accurate estimates of costs 

associated with actions such as “reading regulations” that can affect multiple 

revisions. 

• Collect additional information clarifying tank and facility populations. This 

screening assessment uses several simplifying assumptions that should be refined 

to support a more detailed cost assessment. Specifically, the number of tanks at 

facilities (assumed to be 2.65 tanks per facilities for this screening assessment) is 

not likely to be accurate when addressing emergency generator, field constructed, 

and airport hydrant system tanks, and should be updated if EPA examines these 

populations more closely. Similarly, the industry sectors of importance may vary 

depending on the populations of tanks, and should be re-examined as specific 

popultions are examined more closely. The initial assumption that “all tanks are 

at gas stations” provides a conservative (i.e., high-end) estimate of the potential 

number of small businesses affected, but does not provide resolution about 

specific industry impacts associated with different tank types. 

• Address largest sources of uncertainty in cost estimates. Of the options 

considered in this analysis, the variables most likely to drive the largest costs are 

the selection of options for implementing vapor monitoring of sumps and spill 

buckets, and the extent to which new regulations would require additional 

maintenance and repair. Another issue of importance may be the remaining 

uncertainty regarding the extent to which states already address these activities 

through various regulatory frameworks. Given the large costs at issue, closer 

examination of this issue may be useful. 
 

 14 

• Consider a broader analysis of de-regulatory options. A review of the ICR 

materials indicates that OUST regulations in total impose a significant paperwork 

burden on regulated facilities. It may be possible to identify further opportunities 

to streamline regulations without affecting environmental quality, if EPA 

determines that a further review of options is worthwhile. 
Appendix A 
1 

300 North Lee Street, Suite 201 • Alexandria, VA 22314 • (703) 684-2060 (phone) • (703) 684-5343 (fax) 

MEMORANDUM July 2008 

To: Cynthia Manson, IEc 

From: John Chang, Quinton Ford, Rick Cool, Nandina Jinnoharra, and 

Frank Marcinkowski, PCCI 

Subject: Summary of the Preliminary Assessment of Baseline and Cost Impacts 

 Associated with Deferred UST Systems 

Overview of Memorandum 

This memorandum summarizes PCCI’s initial, screening-level characterization of the 

existing state underground storage tank (UST) regulations, the population of each 

deferred UST for characterization, and the unit and compliance cost estimates. PCCI did 

not contact any states to obtain information or data. The memorandum presents: 

• A summary of the current state UST regulations. 

• A description of the assessment methodology, including the identification of the 

main sources of data and information, assumptions, and limitations. 

• A set of tables that present the characterization results for each deferred UST 

population. 

• A summary of the overall conclusions about the cost estimates, including the key 

uncertainties of the results and additional information needs to refine the results. 

Subtask A: Summary of State Regulations 

Description of Methodology

PCCI used two main sources to screen the state UST regulations: 

• The U.S. EPA OUST UST program website pages containing information on the 

state UST programs and regulations. 

• Where promulgated, each state’s UST regulation. PCCI downloaded current state 

UST regulations from websites maintained by each state agency. 
2 

PCCI screened the applicability and exemptions or deferrals in each available 

promulgated state UST regulation to determine the status of the pertinent equipment 

under the state UST programs. PCCI did not review the technical standards in the 

state regulations but assumed that the requirements in the state regulations are at least 

as stringent as those in 40 CFR 280. 

Summary of Results

• Exhibit 1 identifies the states that follow/adopted 40 CFR 280 and the states that 

have promulgated UST regulations. 

• Exhibit 2 summarizes the deferral status of emergency generator USTs, airport 

hydrants, and field-constructed USTs for each state and territory. Exhibit 2 also 

identifies those states and territories that require tightness testing of UST spill 

buckets and sumps. 

• Attachment 1 to this memorandum identifies the states and territories with 

approved UST regulatory programs and/or UST regulations and contains the 

URLs to access the UST regulations as of June 2008.

Subtask B: Characterization of Tank Universe for Selected Tank Types 

Description of Methodology

• EPA’s semi-annual UST and LUST performance measures report for end of FY 

2007 provided the number of active USTs for each state.1

• To estimate the potential number of emergency generator USTs, field-constructed 

USTs, and hydrants in the U.S.- 

o PCCI obtained the number of fuel service stations for each state from the 

Energy Information Administration’s state energy profiles published at the 

agency’s website.2

o PCCI estimated the total number of fuel service station USTs in each state 

by multiplying the number of service stations by 2.65 USTs per facility. 

This the same assumption of 2.65 USTs per facility in EPA’s 24 October 

2007 ICR 1360.08. 

 

 

1

 EPA OSWER, FY 2007 End-of-Year Activity Report, December 5, 2007, 

http://www.epa.gov/OUST/cat/ca_07_34.pdf

2

 Energy Information Administration, State Energy Profiles, April 2008 Update, 

http://tonto.eia.doe.gov/state/
3 

o The total service station USTs exceeded the total active USTs identified in 

the EPA FY 2007 End-of-Year Activity Report in several cases by using 

2.65 USTs per service station. For these cases, PCCI reduced the 

assumption of USTs per facility to either 2 or 1 UST per service station to 

estimate the total number of service station USTs so as not to exceed the 

total number of active USTs for the particular state. 

 

o PCCI obtained the number of DoD owned or operated field-constructed 

USTs and their locations by state from the Defense Energy Support Center 

(DESC).3

 Conversation with representatives of commercial firms involved 

with the operations and maintenance of field-constructed USTs concerning 

estimates of non-DoD owned or operated field-constructed USTs in the 

U.S. indicated that it is very likely that DoD is the only organization that 

still owns or operates field-constructed USTs.4

 Subsequently, PCCI 

assumed that DoD owns and operates most of, if not all, the fieldconstructed USTs in the U.S. This approach produced an estimate of 239 

field-constructed USTs in the U.S. 

o PCCI reviewed the FAA U.S. airport classifications to estimate the 

number of commercial airport hydrants in the U.S.5

 According to the 

airport classifications, there are 40 class B airports in the U.S. Class B 

airports are the largest commercial airports that typically employ fixed 

hydrant fueling systems as part of the airport infrastructure. A 1993 

ASTM paper by Jairus D. Flora et al., also reported that there are about 40 

hydrant systems in the U.S.6 

o PCCI assumes that aboveground storage tanks supply the airport hydrant 

systems for this screening-level characterization. API/Energy Institute 

Recommended Practice 1540, Design, Construction, Operation and 

Maintenance of Aviation Fuelling Facilities, 4th Edition, interprets a 

hydrant system as a “system that allows for aviation products to be 

pumped direct from an airfield depot or satellite depot to a parking apron 

for delivery in bulk to aircraft.” Hydrants are the pressurized fuel transfer 

equipment in airport fueling systems. In addition, storage tanks for fixed 

airport hydrant systems are usually aboveground vertical steel storage 

tanks.7

 If an airport fueling system uses USTs, the USTs are not deferred 

 

3

 Laura Curtis, DESC, (703) 767-8312. DESC is responsible for supplying DoD with bulk aviation and 

ground fuels. DESC owns all the bulk petroleum products from the point of purchase until its final point of 

issue to aircrafts, ships, and ground equipment. 4

 Communications between Quinton Ford, PCCI and Tim Garner, Garner Environmental Services, (301) 

865-2111and Dennis O’berdove, Tank Integrity Services, (440) 237-9200, 11 June 2008 

5

 DOT/FAA Order JO 7400.9R, Subject: Airspace Designations and Reporting Points, 15 September 2007. 6

 Flora, J. D , Jr , Glauz, W. D., and Hennon, G. J , "Leak Detection Methods for Airport Hydrant 

Systems," Leak Detection for Underground Storage Tanks, ASTM STP 1161, Philip B Durgin and Thomas 

M. Young, Eds., American Society for Testing and Materials, Philadelphia, 1993. 7

 Michael Kluttz, PE, Aircraft Fuel Hydrant System Design Issues, The International Forum on Emergency 

and Risk Management, Singapore Aviation Academy, 10 – 12 January 2005 
4 

from any of the technical standards in 40 CFR 280 or in approved state 

UST programs under 40 CFR 281. 

o PCCI also obtained the number of DoD owned or operated airfield 

hydrants (201) and their locations by state from the Defense Energy 

Support Center (DESC). DESC is responsible for supplying bulk aviation 

fuel for these hydrants. However, the center is not responsible for 

supplying fuel to all DoD hydrants in the U.S. 

o To estimate the DoD hydrants that DESC does not supply bulk aviation 

fuel to operate, PCCI compiled a list of DoD airfields, air stations, and air 

bases in the U.S.8

 Initially, PCCI assumed that each identified installation 

operates at least one hydrant. This approach produced 279 DoD hydrants, 

which PCCI assumed included the 201 hydrants identified by DESC. 

PCCI believes that the actual number of DoD hydrants is likely much 

lower than 279, but it is at least 201 hydrants at present. For instance, 

based on PCCI’s work with Air National Guard bases, not all Air National 

Guard bases operate hydrants; these bases often use refueler trucks to fuel 

aircrafts. USCG air stations that are co-located on other DoD service 

component installations likely use the same service components’ hydrants 

at these installations. 

o For this screening, the estimate of the total airport hydrants in the U.S. is 

201 DoD hydrants together with 40 commercial airport hydrants or 241 

hydrants. 

o PCCI estimated the number of nuclear emergency generator USTs by 

reviewing the Energy Information Administration’s published 

compendium of nuclear reactor facilities for each state.9 PCCI assumed 1 

emergency generator UST per nuclear reactor facility, producing an 

estimate of 104 nuclear emergency generator USTs. 

o Finally, to obtain an estimate of the number of emergency generator and 

other USTs in each state, PCCI subtracted the number of fuel service 

station, field-constructed, and nuclear reactor facility emergency generator 

USTs from the total active number of USTs for each state. As a screening 

estimate, PCCI assumed that all “other” (i.e., not fuel service station, field 

constructed, or nuclear facility emergency generator) USTs in each state 

are essentially emergency generator USTs. 

 

8

 GlobalSecurity, as of June 2008, http://www.globalsecurity.org/military/facility/

9

 Energy Information Administration, States with Commercial Nuclear Industries, as of 22 October 2007, 

http://www.eia.doe.gov/cneaf/nuclear/page/at_a_glance/reactors/states.html
5 

• Regarding the equipment size, facility, industry NAICS code, and annual number 

of leak incidents dealing with field-constructed and emergency generator USTs 

and hydrantso Review of the UST registration/permit information and leak incident 

reports collected by each state will be required to identify the UST size, 

facility, industry NAICS code, and annual number of leak incidents for 

emergency generator USTs. This conclusion is based on PCCI’s screening 

of the UST information presently collected and reported to the public by 

EPA, the information collected by each state as reported on their internet 

sites, and knowledge of the spill data and their metadata in the NRC spill 

database and EPA’s Facility Oil Spills Database. 

o For this screening, PCCI assumed that the 239 field-constructed USTs in 

the U.S. are DoD USTs. The NAICS industry code is 928110, National 

Security.10 As 40 CFR 280 and various state UST regulations defer fieldconstructed USTs from notification requirements, determining the size of 

the field-constructed USTs will require surveying operators and/or states 

that require notification for the information (DoD). As shown in Exhibit 4 

summarizing the field-constructed UST deferral status, over 75% of these 

USTs are subject to state notification requirements. Review of the leak 

incident reports collected by states will be required to identify the annual 

number of leak incidents for the field-constructed USTs, assuming that 

states require the reporting of leaks from these types of USTs. Exhibit 4 

shows that the majority of the operators of field-constructed USTs (88%) 

are required to report releases to states. 

o The NAICS industry code for DoD hydrants is 928110, National Security, 

while the NAICS industry code for commercial airport hydrants is 

488190, Other Support Activities for Air Transportation. As 40 CFR 280 

and various state UST regulations defer airport hydrants from notification 

requirements, determining the hydrant capacities and sizes will require 

surveying states and/or operators for the information (DoD and 

commercial airport authorities). As in the case of field-constructed USTs 

and emergency generator USTs, review of the leak incident reports 

collected by states will be required to identify the annual number of leak 

incidents for hydrants, assuming that states require the reporting of leaks 

from airport hydrants. Exhibit 4 shows that in state UST regulations about 

50% of hydrants remain deferred from the standards that are otherwise 

deferred under 40 CFR 280. 

 

Summary of Results

• Exhibit 3 summarizes the estimate of the universe of field-constructed and 

emergency generator USTs and airport hydrants in the U.S. by state. 

 

10 U.S. Census Bureau, Bridge Between NAICS and SIC, 1997 Economic Census, June 2000. 
6 

Subtask D: Unit Costs and Compliance Cost Estimates 

Description of Methodology

• PCCI derived the screening cost estimates for the field-constructed USTs, 

emergency generator USTs, and airport hydrants based on costs in the EPA 

OUST ICR Number 1360.08, 24 October 2007. 

• Attachments 2 to 12 are the cost worksheets, which are based on the annual 

estimated cost burden worksheets for the pertinent 40 CFR 280 subparts in 

Exhibit 1 of the EPA 24 October 2007 ICR Number 1360.08. The cost 

worksheets show the assumptions underlying the estimate of the costs for 

removing the deferrals of the pertinent 40 CFR 280 subparts for emergency 

generator USTs, Attachment 2; field-constructed USTs, Attachments 3 to 7; and 

airport hydrants, Attachments 8 to12. 

• To estimate the costs of requiring annual spill bucket or sump tightness testing, 

PCCI obtained estimates of the test costs per spill bucket or sump from three 

firms that specialize in providing the tests.11 Test costs range from $100 to $400 

per spill bucket or sump. 

Summary of Results

• Exhibit 4 identifies the numbers of field-constructed USTs, the states in which 

they are located, and the numbers of tanks deferred for the subparts of interest in 

the respective states. 

• Exhibit 5 identifies the numbers of airport or airfield hydrants, the states in which 

they are located, and the numbers of hydrants deferred for the subparts of interest 

in the respective states. 

• Exhibit 6 estimates the cost of requiring annual spill bucket or sump tightness 

testing. 

• Exhibit 7 is the estimate of the cost of removing the deferral of the release 

detection standards in Subpart D for emergency generator USTs. 

o As emergency generator USTs are not subject to all of the technical 

standards of 40 CFR 280, including those deferred from specified 

standards in state UST programs approved under 40 CFR 281, they are 

subject to the SPCC requirements in 40 CFR 112.12 Under 40 CFR 112, 

 

11 Ed Kubinski, Crompco, (800) 646-3161; Tim Garner, Garner Environmental Services, (301) 865-2111; 

Dennis O’berdove, Tank Integrity Services, (440) 237-9200. 

12 40 CFR 112.1(d)(4) 
7 

completely buried tanks must be regularly leak tested in accordance with 

good engineering practice. Note that under 40 CFR 112, bunkered tanks 

and partially buried tanks are considered aboveground storage containers 

subject to the requirements of the SPCC regulation.13

o These USTs, as bulk storage containers under the SPCC regulation, have 

to be constructed, operated, and tested regularly to prevent and control 

spills in accordance with good engineering practice. 

• Exhibit 8 shows the estimates of the cost of removing the deferral of the standards 

in Subparts B, C, D, E, and G for field-constructed USTs. 

o As field-constructed USTs are not subject to all of the technical standards 

of 40 CFR 280, including those deferred from specified standards in state 

UST programs approved under 40 CFR 281, these USTs are subject to the 

SPCC requirements in 40 CFR 112. Under 40 CFR 112, completely buried 

field-constructed tanks have to have corrosion protection and must be 

regularly leak tested in accordance with good engineering practice. 

o These USTs, as bulk storage containers under the SPCC regulation, have 

to be constructed, operated, and tested regularly to prevent and control 

spills in accordance with good engineering practice. 

• Exhibit 9 shows the estimates of the cost of removing the deferral of the standards 

in Subparts B, C, D, E, and G for airport hydrants based on assumptions identified 

below and in the attached hydrant cost worksheets. However, based on below 

raised points concerning the wide range of potential release detection costs for 

hydrants, more information needs to be collected and reviewed to obtain a more 

effective cost characterization of the airport and airfield hydrant systems in the 

U.S., particularly with respect to hydrant leak detection and location technologies 

and equipment in use and their costs. For instance, 98 out of the 241, or 41%, 

airport/airfield hydrant systems in the U.S. are subject to the release detection 

standards established in state UST regulations. Consequently, one way to obtain 

the needed information is by surveying the states that do not defer hydrants from 

the requirements that are otherwise deferred under 40 CFR 280, in addition to 

surveying the hydrant operators. 

o PCCI assumed that hydrants are designed or retrofitted with cathodic 

protection and have release detection, and operators perform integrity 

testing per industry standards. About 41% of the hydrants in U.S. are not 

deferred from release detection requirements under state UST regulations. 

As in the case of field-constructed USTs, airport hydrants are subject to 

the SPCC requirements of 40 CFR 112 as the hydrants are deferred from 

certain technical standards in 40 CFR 280. 

 

13 Definitions of “bunkered tank” and “completely buried tank” in 40 CFR 112.2. 
8 

o Hydrants are the pressurized components of the aircraft fuel delivery 

system; they are not specifically USTs. Storage tanks for fixed airport 

hydrant systems are usually aboveground vertical steel storage tanks. 

Regardless of the type of storage tank, however, if over 10 percent of the 

total volume of fuel stored in a hydrant system is stored underground (i.e., 

in the hydrants) then the systems represent deferred underground storage 

systems. 

o Newer hydrants are likely designed with leak detection and tightness 

testing capabilities for a variety of reasons, for instance, to meet the spill 

prevention and control requirements of 40 CFR 112 and those established 

by certain states. For instance, it is likely that airport hydrant operators do 

inventory reconciliation for business reasons; inventory reconciliation is 

done for the entire fuel system, including the hydrant system. Older 

hydrants may require retrofitting with leak detection technology that meets 

the leak detection and tightness testing standard for pressurized piping. 

o Retrofitting older hydrants with technology that meets the leak detection 

and tightness testing standards for pressurized piping in 40 CFR 280 

Subpart D may not be feasible or present a wide range of costs to install, 

operate, and maintain, depending on site conditions. For instance, it may 

not be feasible or cost effective to retrofit an existing hydrant system with 

double-wall piping and interstitial monitors. 

 The U.S. Army Corps of Engineers reviewed eight main passive 

leak detection and location technologies for pipelines based on 

surveys of vendors to obtain maintenance, installation, and 

material costs for the hydrants surveyed on site visits to 1 

commercial and 7 DoD hydrant operators.14 This guide is in 

Attachment 13. Installation, equipment and construction material 

costs ranged from $26,250 to $274,000 depending on the 

technology and hydrant piping lengths. The guide reported annual 

maintenance costs that were available ranging $300 to $25,883, 

again depending on the technology. Total cost per foot of piping 

ranged from $9.85 to $66.00. 

 The leak rates from airport hydrants, which are large pressurized 

fuel containing systems, depend on the hydrant capacity and 

pressure. Increasing system size requires increasing leak detection 

accuracy.15

 

14 U.S. Army Corps of Engineers Public Works Technical Bulletin 420-49-36, 15 June 2001. 

15 Flora, J. D , Jr , Glauz, W. D., and Hennon, G. J , "Leak Detection Methods for Airport Hydrant 

Systems.” (p.33). 
Exhibits 
Exhibit 1. State UST Program and Regulations Status 

State 

 

Approved 

State 

Program 

(Y/N)a

State 

Regulations 

(Y/N)b

State adopted 

40 CFR 280 

(Y/N)c

Alabama Y Y N 

Alaska N Y N 

American Samoa N N N 

Arizona N Y N 

Arkansas Y N Y 

California N Y N 

Colorado Y Y N 

Connecticut Y Y N 

Delaware Y Y N 

District of Columbia Y Y N 

Florida N Y N 

Georgia Y Y* Y* 

Guam N Y N 

Hawaii Y Y N 

Idaho N Y* Y* 

Illinois N Y N 

Indiana Y Y N 

Iowa Y Y N 

Kansas Y Y* Y* 

Kentucky N Y* Y* 

Louisiana Y Y N 

Maine Y Y N 

Maryland Y Y N 

Massachusetts Y Y N 

Michigan N Y N 

Minnesota Y Y N 

Mississippi Y Y N 

Missouri Y Y N 

Montana Y Y N 

Nebraska Y Y N 

Nevada Y N Y 

New Hampshire Y Y N 
State 

 

Approved 

State 

Program 

(Y/N)a

State 

Regulations 

(Y/N)b

State adopted 

40 CFR 280 

(Y/N)c

New Jersey N Y N 

New Mexico Y Y N 

New York N Y N 

North Carolina Y Y* Y* 

North Dakota Y Y N 

Northern Mariana Islands N N Y 

Ohio N Y N 

Oklahoma Y Y N 

Oregon N Y N 

Pennsylvania Y Y N 

Puerto Rico Y Y N 

Rhode Island Y Y N 

South Carolina Y Y N 

South Dakota Y Y N 

Tennessee Y Y N 

Texas Y Y N 

US Virgin Islands N N Y 

Utah Y N Y 

Vermont Y Y N 

Virginia Y Y N 

Washington Y Y N 

West Virginia Y Y* Y* 

Wisconsin N Y N 

Wyoming Y Y N 

a

 Y indicates Federally Approved state program. Some programs (e.g., Florida) have 

separate regulations even without an approved program. 

b

 Y indicates state specific regulations without explicit reference to 40 CFR 280. A Y* 

indicates that state references 40 CFR 280 in its regulations and partially incorporates 

them. 

c Y indicates that 40 CFR 280 is either explicitly incorporated, unchanged, by state 

regulations, or that no state regulations exist. A Y* indicates that 40 CFR 280 is 

explicitly incorporated, but either with exceptions or additions specific to state 

regulations. 
Exhibit 2 – Summary of State Regulations and Deferrals 

State 

Emergency 

Generator 

UST Release 

Detection 

Required 

(Y/N) 

Airport Hydrants 

Deferred from 40 

CFR 280 Subparts 

(Y/N) 

Field- Constructed 

Tanks Deferred 

from Subpart’s 

(Y/N) 

B C D E G B C D E 

Alabama Y Partial Y N Y N Y Partial Y N Y N Alaska Y Partial N Y N N Y Partial N Y N N American Samoa N Y Y Y Y Y Y Y Y Y Y Y Arizona Y Y Y Y Y Y Y Y Y Y Y Y Arkansas N Y Y Y Y Y Y Y Y Y Y Y California Y N N N N N N N N N N N Colorado N Y Y Y Y Y Y Y Y Y Y Y Connecticut N Y Y Y Y Y Y Y Y Y Y Y Delaware Y Partial Y Y Y N Y Partial Y Y Y N District of Columbia Y Partial Y Y Y N Y Partial Y Y Y N Florida N N N N N N N N N N N N Georgia N Y Y Y Y Y Y Y Y Y Y Y Guam Y N N N N N N N N N N N Hawaii N Partial Y Y Y N Y Partial Y Y Y N Idaho Y N N N N N N N N N N N Illinois Y Partial Y Y Y N Y Partial Y Y N N Indiana N Y Y Y Y Y Y Y Y Y Y Y Iowa N Y Y Y Y Y Y Y Y Y Y Y 
State 

Emergency 

Generator 

UST Release 

Detection 

Required 

(Y/N) 

Airport Hydrants 

Deferred from 40 

CFR 280 Subparts 

(Y/N) 

Field- Constructed 

Tanks Deferred 

from Subpart’s 

(Y/N) 

B C D E G B C D E 

Kansas N Y Y Y Y Y Y Y Y Y Y Y Kentucky N Y Y Y Y Y Y Y Y Y Y Y Louisiana N Y Y Y Y Y Y Y Y Y Y Y Maine Y N N N N N N N N N N N Maryland N N N N N N N N N N N N Massachusetts N N N N N N N N N N N N Michigan N Y Y Y Y Y Y Y Y Y Y Y Minnesota N Y Y Y Y Y Y N N N N N Mississippi N Y Y Y Y Y Y Y Y Y Y Y Missouri N Y Y Y Y Y Y Y Y Y Y Y Montana Y Partial Y Y Y N N Partial Y Y Y N Nebraska N Y Y Y Y Y Y Y Y Y Y Y Nevada N Y Y Y Y Y Y Y Y Y Y Y New Hampshire Y N N N N N N N N N N N New Jersey N N N N N N N N N N N N New Mexico Y Y Y Y Y Y Y Y Y Y Y Y New York Y N N N N N N N N N N N North Carolina N Y Y Y Y Y Y Y Y Y Y Y North Dakota N Y Y Y Y Y Y Y Y Y Y Y Northern Mariana Islands N Y Y Y Y Y Y Y Y Y Y Y Ohio N Partial Y Y Y N Y Partial Y Y Y N Oklahoma N Partial Y Y Y N Y N N N N N Oregon N Y Y Y Y Y Y Y Y Y Y Y 
State 

Emergency 

Generator 

UST Release 

Detection 

Required 

(Y/N) 

Airport Hydrants 

Deferred from 40 

CFR 280 Subparts 

(Y/N) 

Field- Constructed 

Tanks Deferred 

from Subpart’s 

(Y/N) 

B C D E G B C D E 

Pennsylvania N N N N N N N N N N N N Puerto Rico Y Y Y Y Y Y Y N N N N N Rhode Island Y N N N N N N N N N N N South Carolina N Y Y Y Y Y Y Y Y Y Y Y South Dakota N N N N N N N N N N N N Tennessee N Y Y Y Y Y Y Y Y Y Y Y Texas Y N N N N N N N N N N N US Virgin Islands N Y Y Y Y Y Y Y Y Y Y Y Utah N Y Y Y Y Y Y Y Y Y Y Y Vermont Y N N N N N N N N N N N Virginia N Y Y Y Y Y Y Y Y Y Y Y Washington Y Partial N Y Y N N Partial N Y Y N West Virginia N Y Y Y Y Y Y Y Y Y Y Y Wisconsin Y Partial Y Y N Y Y Partial Y Y N Y Wyoming Y Y Y Y Y Y Y Y Y Y Y Y Total Yes 21 30 28 Total No 35 15 18 Total Partial NA 11 10 
Exhibit 3. Field-Constructed and Emergency Generator USTs and Airport Hydrants By State 

Note that total tanks in this exhibit exclude tanks on Tribal lands. 

State or Territory 

Fuel 

Service 

Stationsa 

[1] 

USTs/ 

Stationb 

[2] 

Total 

Active 

USTsc 

[3] 

Not Service 

Station 

Tanksd

[4] 

=[3]-([1]*[2]) 

FCT e 

[5] 

AHf 

[6] 

Nuclear 

EGTg 

[7] 

EGT & 

Othersh 

[8] 

=[4]-([5]+[7

Alabama 6,200 2.65 18,885 2455 0 2 5 2450 Alaska 566 2 1,151 19 4 6 0 15 American Samoa1 4 2.65 16 5 0 0 0 5 Arizona 2,000 2.65 7,003 1703 0 4 3 1700 Arkansas 2,754 2.65 9,455 2157 0 0 2 2155 California 9,970 2.65 37,498 11078 87 45 4 10987 Colorado 2,183 2.65 7,949 2164 0 1 0 2164 Connecticut 1,558 2.65 10,849 6720 0 0 2 6718 Delaware 377 2.65 1,467 468 0 3 0 468 District of Columbia2 134 2.65 696 341 0 0 0 341 Florida 9,217 2.65 28,862 4437 7 10 5 4425 Georgia 8,215 2.65 30,049 8279 0 6 4 8275 Guam2 42 2.65 267 156 33 0 0 123 Hawaii 344 2.65 1,692 780 24 7 0 756 Idaho 790 2.65 3,302 1209 0 2 0 1209 Illinois 5,000 2.65 22,574 9324 0 1 11 9313 Indiana 2,396 2.65 13,840 7491 0 1 0 7491 Iowa 2,659 2.65 7,372 326 0 1 1 325 Kansas 2,800 2 6,967 1367 0 3 1 1366 Kentucky 3,600 2.65 12,415 2875 0 3 0 2875 Louisiana 3,650 2.65 12,601 2929 0 4 2 2927 Maine 1,373 2 3,199 453 0 1 0 453 Maryland 2,339 2.65 9,243 3045 0 4 2 3043 
State or Territory 

Fuel 

Service 

Stationsa 

[1] 

USTs/ 

Stationb 

[2] 

Total 

Active 

USTsc 

[3] 

Not Service 

Station 

Tanksd

[4] 

=[3]-([1]*[2]) 

FCT e 

[5] 

AHf 

[6] 

Nuclear 

EGTg 

[7] 

EGT & 

Othersh 

[8] 

=[4]-([5]+[7

Massachusetts 2,700 2.65 11,021 3866 0 5 1 3865 Michigan 4,984 2.65 20,155 6947 0 3 4 6943 Minnesota 3,649 2.65 14,532 4862 0 1 3 4859 Mississippi 3,550 2 8,782 1682 0 3 1 1681 Missouri 4,178 2 10,267 1911 0 16 1 1910 Montana 400 2.65 3,290 2230 0 1 0 2230 Nebraska 1,486 2.65 6,903 2965 0 3 2 2963 Nevada 1,169 2.65 3,669 571 0 5 0 571 New Hampshire 1,700 1 3,063 1363 0 2 1 1362 New Jersey 3,301 2.65 16,830 8082 0 1 4 8078 New Mexico 1,170 2.65 4,027 927 0 13 0 927 New York 6,700 2.65 28,897 11142 0 5 6 11136 North Carolina 6,908 2.65 28,705 10399 0 20 5 10394 North Dakota 922 2 2,163 319 0 4 0 319 Northern Mariana Islands1 18 2.65 68 20 0 0 0 20 Ohio 4,935 2.65 22,998 9920 0 9 2 9918 Oklahoma 3,250 2.65 11,102 2490 0 6 0 2490 Oregon 1,696 2.65 6,112 1618 0 1 0 1618 Pennsylvania 4,703 2.65 24,677 12214 0 3 9 12205 Puerto Rico1 1,187 2.65 4,560 1414 0 0 0 1414 Rhode Island 377 2.65 1,627 628 0 0 0 628 South Carolina 3,677 2.65 11,981 2237 5 3 7 2225 South Dakota 1,053 2.65 3,021 231 2 4 0 229 Tennessee 4,650 2.65 17,105 4783 0 3 3 4780 Texas 13,760 2.65 54,946 18482 4 8 4 18474 US Virgin Islands1 37 2.65 144 46 0 0 0 46 Utah 1,125 2.65 4,024 1043 0 2 0 1043 
State or Territory 

Fuel 

Service 

Stationsa 

[1] 

USTs/ 

Stationb 

[2] 

Total 

Active 

USTsc 

[3] 

Not Service 

Station 

Tanksd

[4] 

=[3]-([1]*[2]) 

FCT e 

[5] 

AHf 

[6] 

Nuclear 

EGTg 

[7] 

EGT & 

Othersh 

[8] 

=[4]-([5]+[7

Vermont 646 2.65 3,067 1355 0 0 1 1354 Virginia 4,650 2.65 20,600 8278 23 3 4 8251 Washington 3,056 2.65 10,112 2014 50 11 1 1963 West Virginia 1,300 2.65 5,696 2251 0 0 0 2251 Wisconsin 3,919 2.65 13,725 3340 0 2 3 3337 Wyoming 573 2.65 1,980 462 0 0 0 462 Totals 165,600 627201 199,869 239 241 104 199,526 SOURCES AND METHODS a Energy Information Administration energy profiles. b EPA, Office of Underground Storage Tanks Information Collection Request (ICR), 2007. Note that in areas where the number of to

active USTs are less that 2.65 * the number of fuel service stations, the USTs per Station is calculated assuming the nearest integer (i.e

2 or 1) that supports the number of stations. 

c EPA, End of Year UST Activity Report, 2007. d Calculated as total active USTs – (number of Fuel Service Stations * USTs/Station). e Information from DESC data. f Information from DESC data and from FAA information on the locations of Class B airports. g Energy Information Administration energy profiles. h Calculated as “not service station tanks” – the sum of field constructed USTs and Nuclear emergency generator tanks. Airport 

Hydrant systems are not included because their associated “tanks” were identified as ASTs. NOTES 

1 Energy Information Administration does not maintain energy profiles for American Samoa, Northern Mariana Islands, Puerto Rico,

and the U.S. Virgin Islands. The fuel service station USTs average about 31% of a state's total active USTs. PCCI used this average 

percentage of fuel service station USTs to estimate the number of emergency generator USTs in American Samoa, Northern Mariana Islands, Puerto Rico, and the U.S. Virgin Islands. 

2 AOL Yellow Pages at http://yellowpages.aol.com/gas-stations/dc/washington accessed on 21 Jun 2008. 3 Guam Yellow Pages at http://www.informationpages.com accessed on 21 Jun 2008. 

AH- Airport HydrantEGT- Emergency Generator USTFCT- Field-Constructed UST
Exhibit 4. State Field-Constructed UST Deferred Subparts 

STATE 

Total 

FCTs B C D E G 

 FCTs Not Deferred From Subpart Requirements 

Alaska 4 4 4 4 

California 87 87 87 87 87 87 

Florida 7 7 7 7 7 7 

Guam 33 33 33 33 33 33 

Hawaii 24 24 

South Carolina 5 

South Dakota 2 2 2 2 2 2 

Texas 4 4 4 4 4 4 

Virginia 23 

Washington 50 50 50 50 

Total Not Deferred 239 187 133 137 211 183 

Total Deferred 52 106 102 28 56 

 

FCT- Field-Constructed UST 
Exhibit 5. State Airport Hydrant Deferred Subparts 

Total 

AHFS B C D E G 

STATE 

 AHFS Not Deferred From 

Subpart Requirements 

Alabama 2 2 2 

Alaska 6 6 6 6 

Arizona 4 

California 45 45 45 45 45 45 

Colorado 1 

Delaware 3 3 

Florida 10 10 10 10 10 10 

Georgia 6 

Hawaii 7 7 

Idaho 2 2 2 2 2 2 

Illinois 1 1 

Indiana 1 

Iowa 1 

Kansas 3 

Kentucky 3 

Louisiana 4 

Maine 1 1 1 1 1 1 

Maryland 4 4 4 4 4 4 

Massachusetts 5 5 5 5 5 5 

Michigan 3 

Minnesota 1 

Mississippi 3 

Missouri 16 

Montana 1 1 1 

Nebraska 3 

Nevada 5 

New Hampshire 2 2 2 2 2 2 

New Jersey 1 1 1 1 1 1 

New Mexico 13 

New York 5 5 5 5 5 5 

North Carolina 20 

North Dakota 4 

Ohio 9 9 

Oklahoma 6 6 
Total 

AHFS B C D E G 

Oregon 1 

Pennsylvania 3 3 3 3 3 3 

South Carolina 3 

South Dakota 4 4 4 4 4 4 

Tennessee 3 

Texas 8 8 8 8 8 8 

Utah 2 

Virginia 3 

Washington 11 11 11 11 

Wisconsin 2 2 

Total Not Deferred 241 107 92 98 136 102 

Total Deferred 134 149 143 105 139 

 

AHFS- Airport Hydrant Fueling 

System 
Exhibit 6. Spill Bucket/Sumps Tightness Testing Requirement by State 

State or Territory Total Active USTs 

Spill Buckets/Sumps 

Tightness Testing 

Required (Y/N) 

Spill 

Buckets/Sumps 

Not Required to 

be Tested 

Alabama 18,885 Y 

Alaska 1,151 N 1,151 

American Samoa 16 N 16.00 

Arizona 7,003 N 7,003 

Arkansas 9,455 N 9,455 

California 37,498 Y 

Colorado 7,949 N 7,949 

Connecticut 10,849 N 10,849 

Delaware 1,467 Y 

District of Columbia 696 N 696 

Florida 28,862 Y 

Georgia 30,049 N 30,049 

Guam 267 N 267 

Hawaii 1,692 N 1,692 

Idaho 3,302 N 3,302 

Illinois 22,574 N 22,574 

Indiana 13,840 N 13,840 

Iowa 7,372 N 7,372 

Kansas 6,967 N 6,967 

Kentucky 12,415 N 12,415 

Louisiana 12,601 N 12,601 

Maine 3,199 N 3,199 

Maryland 9,243 Y 

Massachusetts 11,021 Y 

Michigan 20,155 N 20,155 

Minnesota 14,532 N 14,532 

Mississippi 8,782 N 8,782 

Missouri 10,267 N 10,267 

Montana 3,290 N 3,290 

Nebraska 6,903 N 6,903 

Nevada 3,669 N 3,669 

New Hampshire 3,063 Y 

New Jersey 16,830 N 16,830 

New Mexico 4,027 N 4,027 

New York 28,897 N 28,897 

North Carolina 28,705 N 28,705 

North Dakota 2,163 N 2,163 

Northern Mariana Islands 68 N 68 

Ohio 22,998 Y 

Oklahoma 11,102 Y 
State or Territory Total Active USTs 

Spill Buckets/Sumps 

Tightness Testing 

Required (Y/N) 

Spill 

Buckets/Sumps 

Not Required to 

be Tested 

Oregon 6,112 N 6,112 

Pennsylvania 24,677 Y 

Puerto Rico1 4,560 N 4,560 

Rhode Island 1,627 N 1,627 

South Carolina 11,981 N 11,981 

South Dakota 3,021 N 3,021 

Tennessee 17,105 N 17,105 

Texas 54,946 N 54,946 

US Virgin Islands 144 N 144 

Utah 4,024 Y 

Vermont 3,067 N 3,067 

Virginia 20,600 N 20,600 

Washington 10,112 N 10,112 

West Virginia 5,696 N 5,696 

Wisconsin 13,725 N 13,725 

Wyoming 1,980 N 1,980 

Totals 627,211 454,361 

Tightness Test Cost per Bucket/Sump 

$100 - $400 

Cost for Requiring Tests for Buckets/Sumps 

Currently Not Required to be Tested at 

$100/Test/Unit $45,436,100.00 

Cost for Requiring Tests for Buckets/Sumps 

Currently Not Required to be Tested at 

$400/Test/Unit 

$181,744,400.00 
Exhibit 7. Cost of Removing Subpart D Deferral for Emergency Generator USTs 

Number of Emergency Generator USTs in U.S. 199, 526 

Number of Emergency Generator USTs Currently Deferred from 

Release Detection Requirements in State UST Regulations 129,184 

Cost of Removing Subpart D Deferral For Emergency Generator USTs 

129,184 USTs * $153 per UST – See Attachment 2 $19,716,487 
Exhibit 8. Cost of Removing Subparts B, C, D, E and G Deferrals for FieldConstructed USTs 

See Attachments 3 – 7 for supporting data

Number of Field-Constructed USTs in U.S. 239 

Subpart B 

Number of Field-Constructed USTs Currently Deferred from Subpart 

B-Related Design, Construction, Installation and Notification 

Requirements in State UST Regulations 

52 

Cost of Removing Subpart B Deferral/Year (52 * $367 per UST) $19,060 

Subpart C 

Number of Field-Constructed USTs Currently Deferred from Subpart 

C-Related General Operating Requirements in State UST Regulations 106 

Cost of Removing Subpart B Deferral/Year (106 *$65 per UST) $6,889 

Subpart D 

Number of Field-Constructed USTs Currently Deferred from Subpart 

D-Related Release Detection Requirements in State UST Regulations 102 

Cost of Removing Subpart D Deferral/Year (102 * $154 per UST) $15,719 

Subpart E 

Number of Field-Constructed USTs Currently Deferred from Subpart 

E-Related Release Reporting, Investigation, and Confirmation 

Requirements in State UST Regulations 

28 

Cost of Removing Subpart E Deferral/Year (28 * $259 per UST) $7,256 

Subpart G 

Number of Field-Constructed USTs Currently Deferred from Subpart 

G-Related Out-of-Service UST Systems and Closure Requirements in 

State UST Regulations (56 * $137 per UST) 

56 

Cost of Removing Subpart G Deferral/Year $7,677 

Total Cost of Removing Subparts B, C, D, E and G Deferrals For FieldConstructed USTs $56,601 
Exhibit 9. Cost of Removing Subparts B, C, D, E and G Deferrals for Airport 

Hydrants 

See Attachements 8 – 12 for supporting data 

Number of Airport Hydrants in U.S. 241 

Subpart B 

Number of Airport Hydrants Currently Deferred from Subpart BRelated Design, Construction, Installation and Notification 

Requirements in State UST Regulations 

134 

Cost of Removing Subpart B Deferral/Year (134 * $3 per hydrant) $350 

Subpart C 

Number of Airport Hydrants Currently Deferred from Subpart CRelated General Operating Requirements in State UST Regulations 149 

Cost of Removing Subpart C Deferral/Year (149 * $142 per hydrant) $21,525 

Subpart D 

Number of Airport Hydrants Currently Deferred from Subpart DRelated Release Detection Requirements in State UST Regulations 143 

Cost of Removing Subpart D Deferral/Year (143 * $176 per hydrant) $25,163 

Subpart E 

Number of Airport Hydrants Currently Deferred from Subpart ERelated Release Reporting, Investigation, and Confirmation 

Requirements in State UST Regulations 

105 

Cost of Removing Subpart E Deferral/Year (105 * $338 per hydrant) $35,457 

Subpart G 

Number of Airport Hydrants Currently Deferred from Subpart GRelated Out-of-Service UST Systems and Closure Requirements in 

State UST Regulations 

139 

Cost of Removing Subpart G Deferral/Year (139 * $0.6 per hydrant) $82 

Total Cost of Removing Subparts B, C, D, E and G Deferrals For 

Airport Hydrants $82,577 
Attachments 
Attachment 1

State UST Program Aproval Status and Regulations URL as of June 2008

SPA

(Y/N)

Alabama Y CHAPTER 335-6-15 http://www.alabamaadministrativecode.state.al.us/docs/adem/McWord335-6-15.pdf

Alaska N 18 AAC 78.005 http://www.legis.state.ak.us/cgi-bin/folioisa.dll/aac/query=[group+18+aac+78!2E005!3A]/doc/%7B@1%7D/hits_only?American Samoa N http://www.epa.gov/oust/states/as.htm http://www.americansamoa.gov/departments/agencies/epa.htmArizona N Title 49 http://www.azleg.state.az.us/ArizonaRevisedStatutes.asp?Title=49Arkansas Y Regulation 12 http://www.adeq.state.ar.us/regs/files/reg12_final_071015.pdfCalifornia N Title 23 http://www.waterboards.ca.gov/water_issues/programs/ust/regulatory/docs/ccr_title23_2008.pdfColorado Y 7 C.C.R. 1101-14 http://oil.cdle.state.co.us/OIL/StatutesRegulations/Current Regs Jan 29 07.docConnecticut Y Sections 22a-449(d)-1, and Sections 22a-449(d) 101-113 http://www.ct.gov/dep/lib/dep/regulations/22a/22a-449(d)-1through113.pdfDelaware Y General Requirements for UST http://www.dnrec.state.de.us/dnrec2000/Divisions/AWM/ust/pdf/2008%20UST%20Regulations.pdfDistrict of Columbia Y Title 20 Environment UST Regulations http://doh.dc.gov/doh/frames.asp?doc=/doh/lib/doh/services/administration_offices/environmental/services2/ustd/pdf/allreg1.pdf&group=181Florida N CHAPTER 62-761 UST http://www.dep.state.fl.us/waste/quick_topics/rules/documents/62-761.pdfGeorgia Y 391-3-15-.02 http://rules.sos.state.ga.us/cgi-bin/page.cgi?g=GEORGIA_DEPARTMENT_OF_NATURAL_RESOURCES%2FENVIRONMENTAL_PROTECGuam N 10 GCA Chapter 76 http://www.guamepa.govguam.net/regs/chapter76.htmlHawaii Y HI UST Regulations http://hawaii.gov/health/environmental/waste/ust/rules.htmlIdaho N 58.01.07 http://adm.idaho.gov/adminrules/rules/idapa58/0107.pdfIllinois N Part 170 http://www.state.il.us/osfm/PetroChemSaf/Current170code.pdfIndiana Y IC 13-23 (IC 13-11) UST http://www.ai.org/legislative/ic/code/title13/ar23/index.htmlIowa Y Chapter 135 http://www4.legis.state.ia.us/Rules/Current/iac/567iac/e135/e135pp11.pdfKansas Y 28-44 http://www.kdheks.gov/pdf/regs/28-44.pdfKentucky N Tanks Exempt from UST regs http://www.waste.ky.gov/branches/ust/regs/Louisiana Y UST-Reg-01 http://www.deq.louisiana.gov/portal/LinkClick.aspx?link=UndergroundStorageTank%2fUST+Registration+Information+(2).pdf&tabid=2674Maine Y http://www.maine.gov/dep/rwm/ust/statutesrules.htm http://www.maine.gov/dep/rwm/ust/statutesrules.htmMaryland Y UST Systems Compliance Outline http://www.dsd.state.md.us/comar/subtitle_chapters/26_Chapters.htmMassachusetts Y 527 CMR http://www.mass.gov/Eeops/docs/dfs/osfm/cmr/cmr_secured/527009.pdfMichigan N R 29.2101 http://www.deq.state.mi.us/documents/deq-std-MUSTR.pdfMinnesota Y Chapter 7150 http://www.pca.state.mn.us/publications/ust-rule-final.pdfMississippi Y Part 280 http://www.deq.state.ms.us/newweb/MDEQRegulations.nsf/3d9fe41da6b657cb86256d6e00638e7a/2b4929acd771bdb286256ba5004842a3Missouri Y 10 CSR 20-10 http://www.sos.mo.gov/adrules/csr/current/10csr/10c20-10.pdfMontana Y Chapter 56 http://www.deq.state.mt.us/dir/legal/Chapters/Ch56-toc.aspNebraska Y Title 159 http://www.sfm.state.ne.us/regulations/title159.htmlNevada Y 40CFR280 http://ndep.nv.gov/bca/ust_reg.htm Adopted 40 CFR 280.New Hampshire Y NH UST regs env-wm 1400 http://www.des.state.nh.us/rules/env-wm1400.pdfNew Jersey N Chapter 14B http://www.state.nj.us/dep/srp/regs/ust/ustrule.pdfNew Mexico Y Title 20 Chapter 5 Part 5 http://www.nmcpr.state.nm.us/nmac/parts/title20/20.005.0005.htmNew York N http://www.dec.ny.gov/regs/4447.html#15662 http://www.dec.ny.gov/regs/2490.htmlNorth Carolina Y 15A NCAC 02N .0201 http://reports.oah.state.nc.us/searchRules.asp?title=%2Fncac%2Ftitle+15a+-+environment+and+natural+resources&chapter=&searchCriterNorth Dakota Y 33-24-08 http://www.legis.nd.gov/information/acdata/pdf/33-24-08.pdfNorthern Mariana Islands N CNMI UST Regulations http://deq.gov.mp/artdoc/Sec7art45ID101.pdfOhio N 1301:7-9-01 http://www.com.state.oh.us/sfm/pub/bust_1301_7-9.pdfOklahoma Y Title 165 Chapter 25 http://www.occeweb.com/Divisions/PST/Forms/Rules/Chapter25.pdfOregon N UST General Permit http://www.deq.state.or.us/regulations/rules.htmPennsylvania Y Chapter 245 http://www.pacode.com/secure/data/025/chapter245/chap245toc.html#245.1.Puerto Rico Y Puerto Rico UST Regulations http://www.jca.gobierno.pr/Enmiendas/ruleTAS.pdfRhode Island Y Rhode Island Rules http://www.dem.ri.gov/pubs/regs/regs/waste/ustreg07.pdfSouth Carolina Y Chapter 61-92 http://www.scstatehouse.net/coderegs/c061e.htm#61-92South Dakota Y Operational Compliance Guidance http://legis.state.sd.us/rules/DisplayRule.aspx?Rule=74:56:01Tennessee Y Chapter 1200-1-15 http://www.state.tn.us/sos/rules/1200/1200-01/1200-01-15.pdfTexas Y Title 30 Part 1 Chapter 334 http://info.sos.state.tx.us/pls/pub/readtac$ext.ViewTAC?tac_view=5&ti=30&pt=1&ch=334&sch=C&rl=YUS Virgin Islands N Title 19 Chapter 56 http://dpnr.gov.vi/dep/waste.htmUtah Y UT UST R 311 http://www.undergroundtanks.utah.gov/docs/ust_rules_091506.docVermont Y UST Regulations http://www.anr.state.vt.us/dec/wastediv/ust/regs/fullUSTregs.pdfVirginia Y VA UST Regulations http://www.deq.state.va.us/export/sites/default/tanks/pdf/usttech.pdfWashington Y Chapter 173 360 http://www.ecy.wa.gov/pubs/wac173360.pdfWest Virginia Y WV UST Regulations http://www.wvsos.com/csrdocs/pdfdocs/33-30.pdfWisconsin N Chapter Comm 10 http://www.legis.state.wi.us/rsb/code/comm/comm010.pdfWyoming Y WQD rules Chapter 17 http://deq.state.wy.us/wqd/WQDrules/Chapter_17.pdf

1 SPA- state program approval

State Regulation UST Regulation URL
Attachment 2

Emergency Generator USTs and Subpart D Costs

Legal Hours Managerial 

hours

Technical Hours

Clerical Hours

Response Hours/ Activity

Labor Cost/ Activity

Capital/Startup Costs per Activity

O&M Costs/ Activity

No. of Response or Activity

Fac- $92 CntrNA States-$47

Fac- $87 Cntr- $104 States-$47

Fac- $75 Cntr- $89 States-$47

Fac- $38 Cntr- $45 States-$26

0.5 0.5 1 0 2 $164.50 $0.00 $0.00 48749 0.5 0.5 1 0 2 $164.50 $0.00 $0.00 682 

0 0.25 0.15 0.25 0.65 $42.50 $0.00 $505.00 6550 0 0.25 0.15 0.25 0.65 $42.50 $0.00 $505.00 2357 0 0 1.67 0 1.67 $125.25 $733.00 0 1977 0 0 1.67 0 1.67 $125.25 $469.00 0 1977 0 0 0.6 0 0.6 $45.00 $384.00 0 45847 0 0 0.25 0 0.25 $18.75 0 $0.00 117893 0 0 0.05 0 0.05 $3.75 0 0 117893 0 0 1.5 0 1.5 $112.50 0 0 52397 0 0 0.02 0 0.02 $1.50 0 0 52397 0 0 0 1 1 $38.00 0 0 49431 

Subtotal Notes:Vapor MonitoringRecord results of monthly vapor monitoringGround-Water MonitoringConduct annual line tightness testRecord results of annual line tightness testLabor hours and rates and capital and O&M costs are from ICR 1360-08. Manual tank gauging with TTT and without TTT are standard business practice and ATG is automated so no increAutomatic Tank GaugingMaintain records for specified time periodsRecord results of monthly ground-water Interstitial MonitoringRecord results of monthly interstitial monitoringAlternative TechnologyRelease Detection for PipingConduct annual test of the operation of the automatic line leak detector in accordance with the manufacturer's requirementsRecord results of annual line leak detection testRelease Detection RecordkeepingPerform tank tightness testingManual Tank Gauging with Tank Tightness Perform tank tightness testingManual Tank Gauging Only (without Tank Tightness Testing)Subpart D, Release DetectionReading RegulationsInventory ControlRelease Detection for TanksReading Regulations One Time for Existing Facilities

1
Attachment 2

No of Subpart D deferred EG USTs 129184 No FCTs w inventory control and TTT 32748EG UST Population 199526 No of TTTs/yr 6550% Subpart D deferred 0.65 No FCTs w manual TG and TTT 11789New USTs/yr 2793 No of TTTs/yr 2358New USTs deferred/yr 1809 No FCTs w vapor monitoring and TTT 5240

No Facilities w/ new deferred FCTs 682 No of fac recording monthly VMs 1977

No Facilities w/exist. deferred FCTs 48749 No FCTs w interstitial monitor 45847

No of interstitial monitorings/month 45847No of line leak detection tests/yr 117893No of facility record maintain activities/yr 49431No of line tightness tests 52397No of ground water monitorings/yr 1977

EPA estimated 25% of existing and new USTs/yr use inventory control and TTT [p.56]. Using same estimate, 32,748 USTs ((129,184+1,808)(.25)) will result in 6,550 TTTs/yr (32,748/5 y

use manual tank gauging with TTT so 11,789 USTs ((130,992)(0.09)) will result in 2,357 TTTs/yr (11,789/5 yrs). 4% use vapor monitoring so 5,240 USTs (130,992)(.04) will result in month

facilities (5,240 USTs/2.65). Same estimate method for ground-water monitoring resulting in monthly ground-water monitorings for 1,977 facilities.

35% of existing and new USTs use interstitial monitoring resulting in 45,847 UST using this method ((130,992)(.35)). EPA estimates 90% of facilities use pressure pipelines. Assuming sa

detection tests ((130,992)(.9)). EPA estimates 40% of facilities use line tightness tests. Assuming same, 52,397 USTs require line tightness tests (130,992 USTs)(.4)).

Existing and new facilities have to maintain records regardless of release detection method used, so 49,431 facilities ((130,992/2.65)) have to maintain records.EPA estimated 8,500 new USTs/yr (1.4%), the average existing total USTs being 620,667 USTs [p.51, Table 2, ICR 1360-08]. 129,184 out of 199,526 generator USTs, 65%, are deferred 

state regulations. Assuming same % of new generator USTs as EPA estimate, new generator USTs/yr = 1.4% of 199,706 = 2,793. Out of the 2,793 new generator USTs/yr, assume 65% also be deferred under state regulations. If EPA removes deferral of Subpart D, using EPA estimate of 2.65 UST/facility [p.51, Table 2], 682 facilities/yr (1,808/2.65) will read regulatiUSTs or 48,749 facilities (129,184/2.65) after deferral removal will have to read regulations once . 

2
Attachment 3

Field-Constructed USTs (FCTs) and Subpart B Costs

Legal Hours Managerial 

hours

Technical Hours

Clerical Hours

Response Hours/ Activity

Labor Cost/ Activity

Capital/Startup Costs per Activity

O&M Costs/ Activity

No. of Response or Activity

Fac- $92 CntrNA States-$47 Fac- $87 Cntr- $104 States-

$47

Fac- $75 Cntr-

$89 States-$47

Fac- $38 Cntr- $45 States-$26

0.25 0.25 0.5 0 1 $82.25 $0.00 $0.00 20 0.25 0.25 0.5 0 1 $82.25 $0.00 $0.00 1 

0 0.5 1 0.5 2 $137.50 $0.00 $0.00 1 0 0 6 0 6 $450.00 $0.00 $1,410.00 10 0 0 0 0.1 0.1 $3.80 0 $0.10 52 0 0 0.5 0 0.5 $37.50 0 $0.43 1 

0.25 0.25 0.5 0.25 1.25 $91.75 0 $0.43 0 

Subtotal Notes:Labor hours and rates and O&M costs are from ICR 1360-08.Number of Subpart B deferred FCTs 52 No FCTs Upgraded with int. linings 52FCT Population 239 No int. FCT inspections/yr 10% Subpart B deferred 0.22New FCTs/yr 3New FCTs deferred/yr 1No Facilities w/new deferred FCTs 0No Facilities w/exist. deferred FCTs 20Subpart B, Design, Construction, Installation, and NotificationCertification of InstallationReading RegulationsObtain and provide a certification of proper installation on the notification formEPA estimated 8,500 new USTs/yr (1.4%), the average existing total USTs being 620,667 UST [p.51, Table 2, ICR 1360-08]. 52 out of 239 field-constructed USTs (FCTs), 22%, are defe

requirements in state regulations. Assuming same % of new FCTs in EPA estimate, new FCTs/yr = 1.4% of 239 = 3. Out of the 3 new FCTs/yr, assume 22% or 1 new FCT/yr will be defe

removes deferral of Subpart B, assume the one facility (with new FCT) will read regulations. 52 existing FCTs or 20 facilities (52/2.65) after deferral removal will have to read regula

been upgraded by internal lining so 10 FCTs will be inspected/yr (52 FCTs/5 yr = 10/yr). Assume 0 FCT sold/yr due to type of UST. Reading Regulations One Time for Existing FacilitiesPrepare and submit forms within 30 days of bringing an UST system into useNotify purchaser of an UST of owner's notification obligationsPeriodic Lining InspectionsHave the line tank inspected within ten years after lining and every five years thereafter- contractorMaintain recordsNotiifcation RequirementsPCCI assumes that all field-constructed USTs are constructed of steel with corrosion protection so removing deferral will not require site assessment by corrosion expert or maintaining reco

1
Attachment 4

Field-Constructed USTs (FCTs) and Subpart C Costs

Legal Hours Managerial 

hours

Technical Hours

Clerical Hours

Response Hours/ Activity

Labor Cost/ Activity

Capital/Startup Costs per Activity

O&M Costs/ Activity

No. of Response oActivity

Fac- $92 CntrNA States-$47

Fac- $87 Cntr- $104 States-$47

Fac- $75 Cntr-

$89 States-$47

Fac- $38 Cntr- $45 States-$26

0.25 0.25 0.5 0 1 $82.25 $0.00 $0.00 40.25 0.25 0.5 0 1 $82.25 $0.00 $0.00 

0 0.1 0.15 0 0.25 $19.95 0 $255.00 10 0.1 0.15 0 0.25 $19.95 0 $0.00 30 0 0 0.1 0.1 $3.80 0 $0.10 30 0 1 0 1 $75.00 0 $0.00 0 0.25 0.15 0.25 0.65 $42.50 0 $505.00 0 0 0 0.1 0.1 $3.80 0 $0.10 

Subtotal Notes:Labor hours and rates and O&M costs are from ICR 1360-08.No of Subpart C deferred FCTs 106 No of CP inspections/yr 19FCT Population 239 No of FCTs with IC systems 15% Subpart C deferred 0.44 No of facilities with IC systems 5New FCTs/yr 3 No of facility IC inspections /yr 33New FCTs deferred/yr 1 No of IC insp. record activities 36No Facilities w/new deferred FCTs 1 No of FCTs repaired/yr 3 (3% of new and existing deferred FCTs/year)No Facilities w/exist. deferred FCTs 40 No of Tightness Test/yr 1 (20% of repaired FCTs)Conduct inspection for impressed current cathodic protection systems every 60 daysMaintain recordsSubpart C, General Operating RequirementsReading RegulationsOperation and Maintenance of Corrosion ProtectionHave a qualified tester conduct inspection for all cathodic protection systems within six months of installation, at least every three years thereafter, and within six months of the repair of any cathodically protected systemReading Regulations One Time for Existing FacilitiesMaintenance of Repair RecordsGather information on each repairEPA estimated 8,500 new USTs/yr for a base average total UST of 620,667 USTs (1.4% of base). [p.51, Table 2, ICR 1360-08]. 106 out of 239 field-constructed USTs (FCTs), 44%, also derequirements in state regulations. Assuming same % of new FCTs as EPA estimate, new FCTs/yr = 1.4% of 239 = 3. Out of the 3 new FCTs/yr, assume 44% or 1 new FCT/yr will be defe

EPA removes deferral of Subpart C, assume the one facility (with new FCT) will read regulations . 106 existing FCTs or 40 facilities (106/2.65) after deferral removal will have to re

estimated that 45% of existing and new USTs will be protected by CP systems. [p.53, ICR 1360-08]. Using 45%, there will be 16 CP system inspections/yr (((106 FCTs + 1 new FCTs)(0.4

that 3% of new and existing USTs will be tested within 6 months of repair. Using same estimate, 3 FCTs will be tested within 6 months of repair ((106 FCTs + 1 new FCT)(.03)). Numbe

Facilities with impressed current systems have to maintain last 3 CP inspection results or 17 records/yr ((33)(3/6)) and together with the 19 CP system inspection records/yr, the total asso

estimated 3% of new and existing USTs will be repaired/yr. Assuming same, 3 FCTs/yr will have to be repaired ((107)*.03).

Conduct tightness testing 30 days after repairMaintain recordsEPA estimated that 30% of USTs with CP systems will be protected with impressed current systems [p.53, ICR 1360-08]]. Using 30%, there will be 15 FCTs with impressed current syste

facilities (15 FCTs/2.65 FCTs/facility). Number of impressed current tests/yr is 33 tests/yr ((15/2.65)*6).

1
Attachment 5

Field-Constructed USTs (FCTs) and Subpart D Costs

Legal Hours Managerial 

hours

Technical Hours

Clerical Hours

Response Hours/ Activity

Labor Cost/ Activity

Capital/Startup Costs per Activity

O&M Costs/ Activity

No. of Response or Activity

Fac- $92 CntrNA States-$47

Fac- $87 Cntr- $104 States-$47

Fac- $75 Cntr-

$89 States-$47

Fac- $38 Cntr- $45 States-$26

0.5 0.5 1 0 2 $164.50 $0.00 $0.00 38 0.5 0.5 1 0 2 $164.50 $0.00 $0.00 1 

0 0.25 0.15 0.25 0.65 $42.50 $0.00 $505.00 5 0 0.25 0.15 0.25 0.65 $42.50 $0.00 $505.00 2 0 0 1.67 0 1.67 $125.25 $733.00 0 2 0 0 1.67 0 1.67 $125.25 $469.00 0 2 0 0 0.6 0 0.6 $45.00 $384.00 0 36 0 0 0.25 0 0.25 $18.75 0 $0.00 93 0 0 0.05 0 0.05 $3.75 0 0 93 0 0 1.5 0 1.5 $112.50 0 0 41 0 0 0.02 0 0.02 $1.50 0 0 41 0 0 0 1 1 $38.00 0 0 39 

Subtotal Notes:Subpart D, Release DetectionReading RegulationsInventory ControlRelease Detection for TanksReading Regulations One Time for Existing FacilitiesPerform tank tightness testingManual Tank Gauging with Tank Tightness Perform tank tightness testingManual Tank Gauging Only (without Tank Tightness Testing)Automatic Tank GaugingMaintain records for specified time periodsRecord results of monthly ground-water Interstitial MonitoringRecord results of monthly interstitial monitoringAlternative TechnologyRelease Detection for PipingConduct annual test of the operation of the automatic line leak detector in accordance with the manufacturer's requirementsRecord results of annual line leak detection testRelease Detection RecordkeepingVapor MonitoringRecord results of monthly vapor monitoringGround-Water MonitoringConduct annual line tightness testRecord results of annual line tightness testLabor hours and rates and capital and O&M costs are from ICR 1360-08. Manual tank gauging with TTT and without TTT are standard business practice and ATG is automated so no incr

1
Attachment 5

No of Subpart D deferred FCTs 102 No FCTs w inventory control and TTT 26FCT Population 239 No of TTTs/yr 5% Subpart D deferred 0.43 No FCTs w manual TG and TTT 9New FCTs/yr 3 No of TTTs/yr 2New FCTs deferred/yr 1 No FCTs w vapor monitoring and TTT 4No Facilities w/new deferred FCTs 1 No of fac recording monthly VMs 2No Facilities w/exist. deferred FCTs 38 No FCTs w interstitial monitor 36

No of interstitial monitorings/yr 36

No of line leak detection tests/yr 93No of facility record maintain activities/yr 39No of line tightness tests 41No of ground water monitorings/yr 2

EPA estimated 25% of existing and new USTs/yr use inventory control and TTT [p.56, Table 4, ICR 1360-08]. Using same estimate, 26 FCTs ((102+1)(.25)) will result in 5 TTTs/yr (26/5 y

estimates, 9% use manual tank gauging with TTT so 9 FCTs ((103)(0.09)) will result in 2 TTT/yr (3/5 yrs). 4% use vapor monitoring so 4 FCTs (103)(.04) will result in monthly vapor mon

FCTs/2.65). Same estimate method for ground-water monitoring resulting in monthly ground-water monitoringd for 2 facilities.

EPA estimated that 35% of existing and new USTs use interstitial monitoring resulting in 36 FCTs using this method ((103)(.35)) and 36 monthly interstitial monitorings. EPA estimates 

pipelines. Assuming same, 93 FCTs require line leak detection tests ((103 FCTs)(.9)). EPA estimates 40% of facilities use line tightness tests. Assuming same, 41 FCTs require line ti

Existing and new facilities have to maintain records regardless of release detection method used, so 39 facilities ((103/2.65 FCTs/facility)) have to maintain records.

EPA estimated 8,500 new USTs/yr (1.4%), the average existing total USTs being 620,667 USTs [p.51, Table 2, ICR 1360-08]. 102 out of 239 FCTs, 43%, are deferred from Subpart D typregulations. Assuming same % of new FCTs as EPA estimate, new FCTs/yr = 1.4% of 239 = 3. Out of the 3 new FCTs/yr, assume 43% or 1 new FCT/yr will also be deferred under sta

deferral of Subpart D, assume one facility (with the 1 new FCT) will read regulations. 102 existing FCTs or 38 facilities (102/2.65) after deferral removal will have to read regulat

2
Attachment 6

Field-Constructed USTs (FCTs) and Subpart E Costs

Legal Hours Managerial 

hours

Technical Hours

Clerical Hours

Response Hours/ Activity

Labor Cost/ Activity

Capital/Startup Costs per Activity

O&M Costs/ Activity

No. of Response or Activity

Fac- $92 CntrNA States-$47

Fac- $87 Cntr- $104 States-$47

Fac- $75 Cntr-

$89 States-$47

Fac- $38 Cntr- $45 States-$26

0.25 0.25 0.5 0 1 $82.25 0 0 10.25 0.25 0.5 0 1 $82.25 0 0 

0 1 4 0 5 $387.00 0 $2,653.00 0 5 31 15 51 $3,954.00 0 $0.00 0 0.25 0 0 0.25 $21.75 0 $0.43 0 0.5 0 0 0.5 $36.50 0 $3.00 2 0 0.5 0 0 0.5 $36.50 0 $3.00 2 

Subtotal Notes:Labor hours and rates and O&M costs are from ICR 1360-08.No of Subpart E deferred FCTs 28 No of facility suspect release/yr 1

FCT Population 239 No of facility determine release/yr 1

% Subpart E deferred 0.12New FCTs/yr 3New FCTs deferred/yr 0No Facilities w/ new deferred FCTs 0No Facilities w/exist. deferred FCTs 11

Subpart E, Release Reporting, Investigation, and ConfirmationReport fill or overfill within 24 hours if over 25 gallons or the reportable quantityNotify the implementing agency if unable to cleanup a spill less than 25 gallons or the reportable quantityReading RegulationsReporting of Suspected ReleasesReport the suspected releaseReporting and Cleanup of Spills and OverfillsGather information - FacilityGather information - ContractorReading Regulations One Time for Existing FacilitiesBased on historical release records, EPA estimated that 12,500 owners and operators out of 237,533 or 5% will suspect release (12,500/237,533) [p.56, ICR 1360-08]. Using same estimatrelease from FCTs ((11)(.05)). EPA estimated further that 80% of facilities suspecting releases will determine that a release has occurred. Using same estimate, less than 1 or assume 1 F

that release has occurred. Assume 1 FCT/yr will notify implementing agency.

EPA estimated 8,500 new USTs/yr (1.4%), the average existing total USTs being 620,667 UST [p.51, Table 2, ICR 1360-08]. 28 out of 239 field-constructed USTs (FCTs), 12%, are defe

requirements in state regulations. Assuming same % of new FCTs as EPA estimate, new FCTs/yr = 1.4% of 239 = 3. Out of the 3 new FCTs/yr, assume 12% or 0 new FCTs/yr will also b

regulations; assume 1 new FCT/yr. If EPA removes deferral of Subpart E, using EPA estimate of 2.65 UST/facility [p.51, Table 2], 1 facility/yr (1/2.65 = 0.4 or 1) will read regulations. 2

facilities (28/2.65) after deferral removal will have to read regulations once . 

1
Attachment 7

Field-Constructed USTs (FCTs) and Subpart G Costs

Legal Hours Managerial 

hours

Technical Hours

Clerical Hours

Response Hours/ Activity

Labor Cost/ Activity

Capital/Startup Costs per Activity

O&M Costs/ Activity

No. of Response or Activity

TY

Fac- $92 CntrNA States-$47

Fac- $87 Cntr- $104 States-$47

Fac- $75 Cntr-

$89 States-$47

Fac- $38 Cntr- $45 States-$26

0.25 0.25 0.5 0 1 $82.25 0 0 21 0.25 0.25 0.5 0 1 $82.25 0 0 1 

0 0.25 0 0 0.25 $21.75 0 $3.00 1 0 2.75 0 0 2.75 $239.25 0 $2,333.00 1 0 6 40 18 64 $4,994.00 0 $0.00 1 0 0 0 0.1 0.1 $3.80 0 $0.10 1 0 0 0 0.5 0.5 $19.00 0 $3.00 0 

Subtotal Notes:Labor hours and rates and O&M costs are from ICR 1360-08.No of SubpartG deferred FCTs 56 No of FCTs closed/yr 1FCT Population 239% Subpart G deferred 0.23New FCTs/yr 3New FCTs deferred/yr 1No Facilities w/new deferred FCTs 0No Facilities w/exist. deferred FCTs 21EPA estimated 8,500 new USTs/yr (1.4%), the average existing total USTs being 620,667 UST [p.51, Table 2, ICR 1360-08]. 56 out of 239 field-constructed USTs (FCTs), 23%, also defrequirements in state regulations. Assuming same % of new FCTs as EPA estimate, new FCTs/yr = 1.4% of 239 = 3. Out of the 3 new FCTs/yr, assume 23% or 1 new FCT/yr will also b

regulations. If EPA removes deferral of Subpart G, using EPA estimate of 2.65 UST/facility [p.51, Table 2], assume 1 facility/yr (1/2.65 = 0.3 or 0) will read regulations. 56 existing FCT

after deferral removal will have to read regulations once. EPA estimated that facilities will close 16,500 USTs out of 629,167 USTs or 3% each year [p.51, Table 2]. Using same estimate, facilities will close 1 FCT/yr ((56+1)(.03)/2.65);however, assumption for FCTs. Assume that only large facilities have FCTs and can maintain records on site. Mail records to implementing agency if they cannot be maintained on sitePermanent Closure and Change-In-Service NotificationNotify the implementing agency of permanent closure or change-in-serviceConduct site assessment of excavation zone - FacilityConduct site assessment of excavation zone - Contr.Subpart G, Out-Of-Service UST Systems And ClosureReading RegulationsClosure RecordsMaintain records after permanent closure or change-in-service for at least three yearsReading Regulations One Time for Existing Facilities

1
Attachment 8

Airport Hydrant and Subpart B Costs

Legal Hours Managerial 

hours

Technical Hours

Clerical Hours

Response Hours/ Activity

Labor Cost/ Activity

Capital/Startup Costs per Activity

O&M Costs/ Activity

No. of Response or Activity

TotYe

Fac- $92 CntrNA States-$47 Fac- $87 Cntr- $104 States-

$47

Fac- $75 Cntr-

$89 States-$47

Fac- $38 Cntr- $45 States-$26

0.25 0.25 0.5 0 1 $82.25 $0.00 $0.00 134 0.25 0.25 0.5 0 1 $82.25 $0.00 $0.00 1 

0 0.5 1 0.5 2 $137.50 $0.00 $0.00 1 0 0 0.5 0 0.5 $37.50 0 $0.43 1 

0.25 0.25 0.5 0.25 1.25 $91.75 0 $0.43 1 

Subtotal Notes:Labor hours and rates are from ICR 1360-08. No of Subpart B deferred Hydrants 134Hydrant Population 241% Subpart B deferred 0.56New Hydrants/yr 1New Hydrants deferred/yr 0Assume 1 new hydrant system per year and 1 hydrant system per airport/airfield facility.Subpart B, Design, Construction, Installation, and NotificationCertification of InstallationReading RegulationsObtain and provide a certification of proper installation on the notification formReading Regulations One Time for Existing FacilitiesPrepare and submit forms within 30 days of bringing a hydrant system into useNotify purchaser of a hydrant system of owner's notification obligationsNotiifcation Requirements

1
Attachment 9

Airport Hydrant and Subpart C Costs

Legal Hours Managerial 

hours

Technical Hours

Clerical Hours

Response Hours/ Activity

Labor Cost/ Activity

Capital/Startup Costs per Activity

O&M Costs/ Activity

No. of Response or Activity

Fac- $92 CntrNA States-$47

Fac- $87 Cntr- $104 States-$47

Fac- $75 Cntr-

$89 States-$47

Fac- $38 Cntr- $45 States-$26

0.25 0.25 0.5 0 1 $82.25 $0.00 $0.00 149 0.25 0.25 0.5 0 1 $82.25 $0.00 $0.00 1 

0 0.1 0.15 0 0.25 $19.95 0 $255.00 55 0 0.1 0.15 0 0.25 $19.95 0 $0.00 270 0 0 0 0.1 0.1 $3.80 0 $0.10 0 0 1 0 1 $75.00 0 $0.00 5 0 0.25 0.15 0.25 0.65 $42.50 0 $505.00 1 0 0 0 0.1 0.1 $3.80 0 $0.10 3 

Subtotal Notes:Labor hours and rates and O&M costs are from ICR 1360-08. No of Subpart C deferred hydrants 149Hydrant Population 241% Subpart C deferred 0.62New Hydrants/yr 1New Hydrants deferred/yr 0Maintenance of Repair RecordsGather information on each repairAssume 1 new hydant system per year and 1 hydrant system per airport/airfield facility. Assume all hydrant systems are protected by CP systems. There will 50 CP system inspections/yr 

estimated that 3% of new and existing USTs will be tested within 6 months of repair. Using same estimate, 5 hydrants will be tested within 6 months of repair ((149+ 1)(.03)). Number 

tests/yr (50+5). Hydrant facilities with impressed current systems have to maintain last 3 CP inspection results or 22 records/yr ((45)(3/6)) and together with the 55 CP system inspection records/yr, the tot77/yr. EPA estimated 3% of new and existing USTs will be repaired/yr. Assuming same, 5 hydrants/yr will have to be repaired ((150)*.03).

Conduct tightness testing 30 days after repairMaintain recordsEPA estimated that 30% of USTs with CP systems will be protected with impressed current systems [p.53, ICR 1360-08]. Using 30%, there will be 45 hydrants with impressed current syof impressed current tests/yr is 270 tests/yr ((45)*6).Conduct inspection for impressed current cathodic protection systems every 60 daysMaintain recordsSubpart C, General Operating RequirementsReading RegulationsOperation and Maintenance of Corrosion ProtectionHave a qualified tester conduct inspection for all cathodic protection systems within six months of installation, at least every three years thereafter, and within six months of the repair of any cathodically protected systemReading Regulations One Time for Existing Facilities

1
Attachment 10

Airport Hydrant and Subpart D Costs

Legal Hours Managerial 

hours

Technical Hours

Clerical Hours

Response Hours/ Activity

Labor Cost/ Activity

Capital/Startup Costs per Activity

O&M Costs/ Activity

No. of Responor Activ

Fac- $92 Cntr- NA States-$47

Fac- $87 Cntr- $104 States-$47

Fac- $75 Cntr- $89 States-$47

Fac- $38 Cntr- $45 States-$26

0.5 0.5 1 0 2 $164.50 $0.00 $0.00 0.5 0.5 1 0 2 $164.50 $0.00 $0.00 

0 0 0.25 0 0.25 $18.75 0 $0.00 0 0 0.05 0 0.05 $3.75 0 0 0 0 1.5 0 1.5 $112.50 0 0 0 0 0.02 0 0.02 $1.50 0 0 0 0 0 1 1 $38.00 0 0 

Subtotal Notes:Labor hours and rates are from ICR 1360-08.No of Subpart D deferred Hydrants 143Hydrant Population 241% Subpart D deferred 0.59New Hydrants/yr 1New Hydrants deferred/yr 0144 hydrants require annual line leak detection tests and line tightness tests .Existing and new facilities have to maintain records regardless of release detection method used, so 144 hydrant facilities have to maintain records.

Assume 1 new hydrant system per year and 1 hydrant system per airport/airfield facility. Conduct annual line tightness testRecord results of annual line tightness testMaintain records for specified time periodsRelease Detection for HydrantConduct annual test of the operation of the automatic line leak detector in accordance with the manufacturer's requirements

Record results of annual line leak detection testRelease Detection RecordkeepingSubpart D, Release DetectionReading RegulationsReading Regulations One Time for Existing Facilities

1
Attachment 11

Airport Hydrant and Subpart E Costs

Legal Hours Managerial 

hours

Technical Hours

Clerical Hours

Response Hours/ Activity

Labor Cost/ Activity

Capital/Startup Costs per Activity

O&M Costs/ Activity

No. of Responor Activ

Fac- $92 Cntr- NA States-$47

Fac- $87 Cntr- $104 States-$47

Fac- $75 Cntr- $89 States-$47

Fac- $38 Cntr- $45 States-$26

0.25 0.25 0.5 0 1 $82.25 0 0 0.25 0.25 0.5 0 1 $82.25 0 0 

0 1 4 0 5 $387.00 0 $2,653.00 0 5 31 15 51 $3,954.00 0 $0.00 0 0.25 0 0 0.25 $21.75 0 $0.43 0 0.5 0 0 0.5 $36.50 0 $3.00 0 0.5 0 0 0.5 $36.50 0 $3.00 

Subtotal Notes:Labor hours and rates and O&M costs are from ICR 1360-08.No of Subpart E deferred Hydrants 105Hydrant Population 241% Subpart E deferred 0.44New Hydrants/yr 1New Hydrantss deferred/yr 0Subpart E, Release Reporting, Investigation, and ConfirmationReport fill or overfill within 24 hours if over 25 gallons or the reportable quantityNotify the implementing agency if unable to cleanup a spill less than 25 gallons or the reportable quantity

Reading RegulationsReporting of Suspected ReleasesReport the suspected releaseReporting and Cleanup of Spills and OverfillsGather information - FacilityGather information - ContractorReading Regulations One Time for Existing FacilitiesBased on historical release records, EPA estimated that 12,500 owners and operators out of 237,533 or 5% will suspect release (12,500/237,533) [p.56, ICR 1360-08]. facility/yr will suspect release from FCTs ((105+1)(.05)). EPA estimated further that 80% of facilities suspecting releases will determine that a release has occurred. hydrants/yr will determine that release has occurred and will notify implementing agency.

Assume 1 new hydrant system per year and 1 hydrant system per airport/airfield facility. 

1
Attachment 12

Airport Hydrant and Subpart G Costs

Legal Hours Managerial 

hours

Technical Hours

Clerical Hours

Response Hours/ Activity

Labor Cost/ Activity

Capital/Startup Costs per Activity

O&M Costs/ Activity

No. of Responor Activ

Fac- $92 Cntr- NA States-$47

Fac- $87 Cntr- $104 States-$47

Fac- $75 Cntr- $89 States-$47

Fac- $38 Cntr- $45 States-$26

0.25 0.25 0.5 0 1 $82.25 0 0 0.25 0.25 0.5 0 1 $82.25 0 0 

0 0.25 0 0 0.25 $21.75 0 $3.00 0 2.75 0 0 2.75 $239.25 0 $2,333.00 0 6 40 18 64 $4,994.00 0 $0.00 0 0 0 0.1 0.1 $3.80 0 $0.10 0 0 0 0.5 0.5 $19.00 0 $3.00 

Subtotal Notes:Labor hours and rates and O&M costs are from ICR 1360-08.No of Subpart G deferred Hydrants 139 No of Hydrants closed 0Hydrant Population 241 each year% Subpart G deferred 0.58New Hydrants/yr 1New Hydrants deferred/yr 0Subpart G, Out-Of-Service UST Systems And ClosureReading RegulationsClosure RecordsMaintain records after permanent closure or change-in-service for at least three years

Reading Regulations One Time for Existing FacilitiesAssume 1 new hydrant system per year and 1 hydrant system per airport/airfield facility. Mail records to implementing agency if they cannot be maintained on sitePermanent Closure and Change-InService NotificationNotify the implementing agency of permanent closure or change-in-serviceConduct site assessment of excavation zone - Facility

Conduct site assessment of excavation zone - Contr.

1
 

PUBLIC WORKS TECHNICAL BULLETIN 420-49-36 

15 June 2001 

LEAK DETECTION 
 

Public Works Technical Bulletins are published by the U.S. Army

Corps of Engineers, Washington, DC. They are intended to provide 

information on specific topics in areas of Facilities Engineering and 

Public Works. They are not intended to establish new DA policy. 
 

DEPARTMENT OF THE ARMY 

U.S. Army Corps of Engineers 

441 G Street, NW

Washington, DC 20314-1000 

CEMP-R 

Public Works Technical Bulletin 15 June 2001 

No. 420-49-36 

FACILITIES ENGINEERING 

UTILITIES 

LEAK DETECTION 

1. Purpose. The purpose of this Public Works Technical Bulletin (PWTB) is to transmit 

current information on active and passive leak detection technology for water, fuel, energy pipe 

and storage tank systems for implementation at Army installations. 

2. Applicability. This PWTB applies to all U.S. Army Public Works activities involving the

use of water, fuel, energy pipe and storage tank systems. 

3. References. 

a. AR 420-49-02, Facilities Engineering Utility Services, 28 May 1997. 

 b. Army Regulation (AR) 200-1, Environmental Protection and Enhancement, 21 February 

1997. 

c. U.S. Code of Federal Regulations (CFR), Title 40, Part 280, Technical Standards and 

Corrective Action Requirements for Owners and Operators of Underground Storage Tanks 

(UST), Vo. 53, No. 185, 23 September 1988. 

4. Discussion. 

 a. The consequences of utility system leaks are more noticeable now than in the past 

because of increasing requirements for environmental protection and emphasis on energy and 

water conservation. Leaks of fuels, other petroleum products and chemicals are a serious hazard. 

Leaks in water distribution systems waste water, energy and system capacity. Unfortunately it is 

not unusual for a water distribution system to have leakage rates of 20%. These factors 

highlight the growing importance of leak detection. 

b. This PWTB provides an evaluation of current leak detection technology applicable to 

water, fuel and energy pipe systems and provides lessons learned. The lessons provide insights 

into selection of appropriate leak detection technologies, installed either as post-construction 

system additions or during construction. The attached document provides detailed information 

on the leak detection technology and application.
PWTB 420-49-36 

15 June 2001 

5. Point of Contact. Questions and/or comments regarding this subject should be directed to 

the technical POC: 

U.S. Army Engineer Research and Development Center 

Construction Engineering Research Laboratory 

ATTN: CEERD-CF-M (Dr. Vincent Hock) 

2902 Newmark Drive 

Champaign, IL 61822-1072 

Tel. (217) 373-6753 

FAX: (217) 373-7222 

e-mail: v-hock@cecer.army.mil 

FOR THE COMMANDER: 

 

DWIGHT A. BERANEK, P.E. 

Chief, Engineering and Construction Division 

Directorate of Civil Works Encl 

2 
 

ACTIVE AND PASSIVE LEAK 

DETECTION 

TECHNOLOGY FOR WATER, FUEL, 

ENERGY PIPE AND STORAGE TANK 

SYSTEMS 

GUIDANCE
 

ACTIVE AND PASSIVE LEAK DETECTION TECHNOLOGY FOR WATER, FUEL, 

ENERGY PIPE AND STORAGE TANK SYSTEMS GUIDANCE

1. Introduction 

A single gallon of gasoline can render a million gallons of water non-potable. The cost of 

effecting leak repairs is approximately proportional to the amount of trenching needed to access 

the leak. Passive leak detection can provide leak location to within a 6 inch radius of the actual 

leak location. The use of this technology can save critical time when detecting and locating a 

leak, and minimize unproductive trenching for repairs. 

The U.S. Army maintains approximately 20,000 underground storage tanks (UST) and 

pressurized underground pipelines to store and deliver petroleum and other chemicals. According 

to the U.S. Environmental Protection Agency, approximately 25% of these are leaking. The 

average clean up cost of a petroleum leak is estimated by U.S. Army Toxic and Hazardous 

Materials Agency (USATHAMA) to be $193K, ranging higher where ground water is 

contaminated. 

The U.S. Army also maintains 3,000 miles of steam and High Temperature Hot Water (HTHW) 

distribution lines. A leak repair in these energy lines can cost in the range of $2-15K per leak, 

due in large part to the multiple trenching required to locate the source. 

The objective of this PWTB is to publish lessons learned, based on the evaluation of passive leak 

detection technology applicable to water, fuel and energy pipe systems. The lessons provide 

insights into selection of appropriate leak detection technologies, installed either as postconstruction system additions or during construction. 

The U.S. Army Corps of Engineers has reported1

 that the most likely technology for reliable and 

cost effective detection of fuel leaks in underground piping systems is manufactured by Arizona 

Instruments Inc., followed by the Tracer Research ALD 2000 system (continuous monitoring), 

and finally the various cable systems (with the constraint that they must be installed in double 

walled piping systems). 

Leak detection technologies applicable to water and energy pipe systems were researched 

through vendor information, but no installed systems were found in the DoD. 

2. Regulations 

The U.S. Naval Facilities Engineering Service Center has reported upon the pertinent regulations 

that apply to petroleum leaks2

. The key points are summarized here, please refer to the original 

1

 Timmins, J., Weber, R.A., Hock, V.F., Summary of Findings and Survey Results for Leak 

Detection Sensors for Water, Fuel and Energy Piping Systems, USACERL Report XX, 10 Sep 1997. 

2

 Lefave, J.P., Karr, L., Underground Pipeline Leak Detection and Location Technology 

Application Guide, Naval Facilities Engineering Service Center, Report UG-2028-ENV, April 1998. 
 

2 

report for a more detailed treatment of the regulatory subject as it applies to airport hydrant 

systems, USTs, ASTs, and their associated piping. 

a. Federal Environmental Protection Agency Regulations 

Federal regulations require >release detection= for underground storage tanks (USTs) and their 

associated piping. Federal regulations also defer the release detection requirement indefinitely 

(Section 280.10 c and 280.10 d of Ref. 23

) for field-constructed USTs, emergency power 

generator fuel tanks, and airport hydrant fuel distribution systems. Release detection methods 

that satisfy the Federal requirement for existing UST systems are discussed at Sections 280.41 

and 280.43 (for tanks), and Section 280.44 (for piping) (Ref. 23

). The options for release 

detection for pressurized piping are: 

 (1) Automatic line leak detection 

 (2) Annual line tightness testing 

 (3) Monthly monitoring of soil vapor, groundwater, or the interstitial 

 space of a double walled pipeline. 

Automatic line leak detectors must be able to detect leaks of 3 gallons per hour at a pressure of 

10 psig within an hour. The annual tightness test must be able to detect a leak rate of 0.1 gallon 

per hour. Other methods are also allowed if they can detect a 0.2 gallon per hour leak rate, a 

release of 150 gallons in a month, or are approved by the implementing agency (Ref. 23

 Section 

280.43(h)). 

 b. State Regulations 

Contacts at the State (or Territorial) regulating offices are available to answer leak detection 

questions. A list of contacts can be found at http://www.epa.gov/OUST/states/statcon1.htm. 

California, Florida, and Texas have special leak detection requirements. California=s 

requirements are governed by the California Code of Regulations, Title 23, Sections 2640 et.seq. 

Florida=s requirements are governed by Florida Administrative Code, Rule 62-761, 

Underground Storage Tank Systems, and Rule 62-762, Aboveground Storage Tank Systems. 

Texas= requirements are governed by the Texas Administrative Code, Chapter 334, 

Underground and Aboveground Storage Tanks. Table I provides a summary of the regulatory 

requirements for airport hydrant systems, USTs, ASTs, and their associated piping. 

 c. Regional Regulations 

Certain localities may impose regulations that differ from Federal and State requirements. 

Consult your local EPA office for more information on regional requirements. 

 3

 U.S. Code of Federal Regulations (CFR), Title 40, Part 280, Technical Standards and 

Corrective Action Requirements for Owners and Operators of Underground Storage Tanks (UST), 

Vo. 53, No. 185, 23 September 1988.
 

Table I. Regulatory Requirements Summary 

(from Ref. 4, Lefave and Karr)

Airport 

Hydrant 

Systems

UST 

and 

Associated Pressurized Piping

AST 

And Associated 

Pressurized Piping

Federal (Deferred) Same as tank (deferred for field 

constructed USTs); After 22 

December 1998, secondary

containment (for piping), 

AND 

Automatic Line Leak Detector 

required (3 gal/hr at 10 psig). Option

for approval of alternate release 

detection methods.

No requirement, unless 

piping is >10 percent of 

total volume, which 

makes the entire system a 

UST. 

California Same as 

UST>> 

Hourly (3.0 gal/hr) when pressurized 

AND 

Monthly (0.2-gal/hr) 

or 

Annual (0.1-gal/hr at 150 percent 

operating pressure)

No requirement, unless 

piping is >10 percent of 

total volume, which 

makes the entire system a 

UST. 

Texas Same as 

UST>> 

Hourly (0.2-gal/hr) 

AND 

Annual Tightness Test 

(0.1-gal/hr at 150 percent of operating 

pressure) 

<< Same as UST. 

Florida 

(Current 

reg=s)

Thru 

1999 

Same as 

UST >> 

Annual Tightness Test << Same as UST. 

After 

1999 

Same as 

UST >> 

In-Line Leak Detector 

(0.3-gal @ 10 psig) 

OR 

Quarterly Pressure Test 

Hydrant & bulk product 

piping (3-inch+ 

diameter.): << same as 

USTs; 

Other piping upgrade 

with secondary 

containment. 

Florida 

(Proposed) 

Same as 

UST >> 

Annual Tightness Test 

OR 

Monthly Release Detection system

Hydrant & bulk product 

piping: Annual tightness 

test. 

3 
 

4 

3. Technology Overview 

There are eight main technologies in use for the detection of liquid leaks, each associated with 

physical phenomena which occurs either at a leak site or in the system due to the leak: 

a. Gas sniffing systems detect changes in chemical concentration, and require the leak to 

provide changes in concentration which are detectable above normal, naturally occurring 

chemical levels. 

 b. Cable systems involve laying a cable in probable leak sites and monitoring for 

changes in the cable=s impedance, conductivity or (in the case of fiber optic cables) the 

refractive index, to determine when the cable comes in contact with a liquid. 

 c. Acoustic systems rely on noise produced by turbulent liquid flow through the leak to 

detect leaks in piping systems. Two sensors mounted either temporarily or permanently to the 

pipe can locate the leak in relation to the sensors. 

 d. Infrared methods rely on the difference in temperature between the piping system 

and surrounding soil to provide a thermal signature which can be observed by special imaging 

equipment. 

 e. Magnetic flux leakage detection systems (also known as a >pigs=) are instruments 

which identify and record information about pipeline anomalies such as corrosion pits, 

mechanical damage, dents, mill defects, wrinkle bends, hard spots, and hydrogen blisters. A pig 

must be launched with the pipeline completely evacuated and requires special launch and 

recovery stations. 

 f. Temperature compensated volumetric testing systems measure the volume of liquid 

that must be added to a piping system to maintain a constant pressure, thus providing the flow 

rate of a leak (or leaks) in gallons per hour. 

 g. Pressure point analysis systems detect pressure waves caused by the sudden onset of a 

leak in a pipeline. 

h. Supervisory Control and Data Acquisition (SCADA) systems rely on process control 

sensors to detect discrepancies in the performance of the system which could indicate a leak. One 

subset of the SCADA system category (which is often used as a stand-alone leak detection 

system) is Level Monitoring, which can be used only in closed systems which allow an 

accounting system to detect losses. The other SCADA subsystem (which can also be used as a 

stand-alone system) is Mass Flow measurement methods, which rely on various physical 

phenomena to obtain accurate measurements of the total mass flow between two points on a 

pipeline. Irrespective of the portion of the SCADA system utilized as the detection system, each 

requires the use of a computer, sensor data acquisition, and an analysis algorithm to evaluate the 

sensor data and produce a leakage determination. 
 

5 

Each technology mentioned has a detection sensitivity associated with the system it is used with. 

These eight technologies are evaluated further in Appendix A in terms of the phenomena 

exploited, their system applicability, and their advantages and disadvantages when applied to the 

detection of leaks in a buried pipe system responsible for carrying liquids. 

4. Technology Selection Criteria 

Implementation of a leak detection and location (LDL) system is a tradeoff between cost and 

performance. Many variables should be considered when selecting LDL equipment. These 

considerations are listed in Table II and are discussed in this section. Further information on 

these LDL methods is contained in the Appendices of this report. 

a. Soil Conditions: Soil conditions can affect LDL technology performance. For 

example, tracer gas migrates more quickly in dry, porous soil than in wet soil. Acoustic 

techniques may also be affected by the type of soil around the pipeline. Tidally influenced saltwater environments pose special corrosion problems for pipelines. When researching leak 

detection equipment, always consider the soil conditions. 

 b. Water Table: Some LDL techniques don=t work well if the pipeline runs below the 

water table or the high tide level. Tracer techniques are less effective if the pipeline is under 

water, because leaking tracer gas may be washed away before it reaches a sensor. Or, the tracer 

may migrate and be detected by another sensor, thus indicating a leak in the wrong location. 

 c. Condition of Pipeline: The age and condition of a pipeline are important 

considerations when selecting leak detection equipment. Static pressure testing techniques 

require modern high-quality valves, so that a leaky pipeline can be distinguished from a leaky 

valve. Older small diameter pipelines containing sharp bends may be unsuitable for pigging. 

d. Operations: Certain LDL techniques can be affected by routine operations. For 

example, temperature compensated pressure tests must be conducted when a pipeline is >quiet=, 

which may require temporary suspension of operations. Acoustic techniques can be disturbed by 

vibrations generated from heavy traffic in the surrounding area. Pressure point analysis 

techniques may be hampered by fuel facility operations. 

 e. Time Monitoring: Some LDL methods provide leak detection 24 hours a day 

(continuous monitoring). Other methods provide a >snap shot=, or assessment of the pipeline 

condition at that moment. Regulators may require that a snap shot technique be employed at 

specified time intervals to implement an effective leak control program. 

 f. Spatial Resolution: Leak detection and location techniques provide different levels of 

spatial resolution. When properly applied, pigging, cables, and acoustic techniques can 

accurately locate leaks. However, the accuracy of tracer leak location is a function of the spacing 

between sampling points. Static pressure testing techniques don=t locate leaks at all. Sometimes 

the best way to solve leak detection problems is to first identify a leak with one technique, such 

as pressure testing, and then locate it with another technique, such as tracers. 
 

6 

 g. Leak Rate Resolution: Some leak detection techniques, such as temperature 

compensated pressure testing, provide a volumetric measure of the leak rate. Other techniques, 

such as product sensitive cables, indicate where fuel has been detected, but not how much fuel is 

present. 

h. Ease of Retrofit: Most underground piping systems have been in service for many 

years. It is therefore important to address whether a LDL technology can be applied to an 

existing pipeline. Some techniques, such as temperature compensated pressure testing, can be 

easily applied on most pipelines, new or old. The hardware associated with these techniques is 

not an integral part of the pipeline system and can brought to the pipeline by a contractor who 

performs the test. However, these systems can be made a part of the fueling system, if that is 

determined to be cost effective. 

5. Cost Data 

Table II. Cost Data for Surveyed Field Installed Leak Location Systems

(from Ref. 3, Timmins, Weber and Hock) 

Leak Detection System Cost Data Source Installation Cost Equip. and Constr. 

Materials 

Maintenance Cost 

(Annual) 

Length of Pipline in 

feet 

Total Cost in 

first Year 

Total Cost Per 

Foot 

Soil Sentry 12XP Pipeline and 

AST Environmental Monitoring 

System 

Site Costs Pensacola 

NAS (Based on 

26,400') 

$274,000 $300 26,400 $274,300 $10.39 

AZI Soil Sentry (Tracer Research 

Tracer Tightness used on storage 

Tanks - not included in cost data) 

Site Costs Ellsworth 

AFB (Based on 7908') 

$104,000 $40,000 $300 7,908 $144,300 $18.25 

Soil Sentry 12XP Pipeline and 

AST Environmental Monitoring 

System 

Manufacturer 

Estimate (Based on 

1000') 

$15,500 $10,750 $995 1,000 $27,245 $27.25 

Tracer Research: ALD 2000 Manufacturer 

Estimate (Based on 

5,000') 

$134,941 $25,883 5,000 $160,824 $32.16 

Raychem: Trace Tek (Quote by 

Tracer Research) 

Manufacturer 

Estimate (Based on 

5,000') 

$113,000 $8,000 5,000 $121,000 $24.20 

PermAlert: PAL-AT Leak 

Detection System 

Manufacturer 

Estimate (Based on 

5,000') 

$49,246 5,000 $49,246 $9.85 

Vista Research: Model LT100 Manufacturer 

Estimate (Based on 

1,000') 

$42,000 1,000 $42,000 $42.00 

Hansaconsult: TCS Tightness 

Control System 

Manufacturer 

Estimate (Based on 

1,000') and Converted 

to US Dollars 

$66,000 1,000 $66,000 $66.00 

Argus Technologies Manufacturer 

Estimate (Based on 

5,280') 

$209,457 5,280 $209,457 $39.67

This table was derived from questionnaires were to both installations and vendors to determine 

applicable current pricing on maintenance, installation, and materials costs for the system types 

being surveyed. Table II illustrates the relative breakdown of the cost data obtained. Vendors 

were supplied with a hypothetical piping system 1000 ft long, carrying JP-8 in a single wall pipe 
 

7 

buried 4 ft. beneath grade. DoD installations were asked to include similar system descriptions 

with installation and maintenance cost data for their individual systems. 

6. Implementation Guidance 

To achieve sufficient performance from a leak detection system, the pipeline should first be 

verified for integrity before having a continuous monitoring system installed and tested. The leak 

detection system must also be relatively maintenance free and inexpensive to operate. None of 

the systems surveyed or researched provide the optimal level of leak detection on their own. 

Leak detection in underground piping systems is a multifaceted problem, which requires several 

technologies to achieve a satisfactory solution. 

The aspects of leak detection which are and will continue to be the most critical are leak location 

and magnitude. A highly sensitive system which monitors infrequently does little to protect the 

user from the high costs resulting from a major discharge. A system which monitors 

continuously but is only able to detect major discharge events puts the user at the same risk level. 

Of the leak detection systems investigated, the most promising technology for reliable detection 

of fuel leaks in underground fuel piping systems appears to be the gas sniffing systems. This 

technology has proven its ability to detect numerous hydrocarbons from natural gas, hydraulic 

fluid, or JP8. However, the system is not applicable to water or energy pipe systems, and current 

systems are susceptible to water invasion. 

The AZI leak detection and location system seems to have a good potential. It provides sufficient 

sensitivity to detect smaller leaks and has the ability to continuously monitor the piping system. 

The AZI system can also provide leak location to within 10 ft. with 20 ft. well spacing. The AZI 

system could be feasibly made impervious to water by the addition of the Argus Technologies 

proprietary sensor tube, which is selectively permeable. Because the AZI system draws a 

vacuum on the sensor tubing, the rate of diffusion of concentrated hydrocarbons could be 

increased enough to reduce the idle time required, and still provide a system that continuously 

monitors the site. 

Tracer gas systems also have good potential. These systems are suitable for intermittent pipeline 

integrity tests and do not depend on prior knowledge of the pipeline condition. These systems are 

based on the detection of a unique marker gas introduced into the product carried in the pipeline 

and detected through gas chromatography. They are not useful for potable water piping systems 

due to the toxicity of the marker gas. 

The technology used in cable systems appear to be useful for both energy pipe systems and new 

potable water systems which incorporate double wall piping. There are also cables available for 

the detection of hydrocarbon liquids, which makes this technology applicable to fuel, water, and 

energy pipe systems. 

Table III lists the various leak detection and location technologies discussed in this bulletin, and 

indicates their relative suitability to various field applications under different conditions.
Table III. LDL Suitability to Application 

Utility 

Potable Water Petroleum High Temp Hot Water Material Backfill Water Table

Pressure 

Material Backfill Water Table

Pressure 

Material 

Backfill Water Table

Pressure 

LDL Technology 

Cast Iron

Transite 

Copper Plastic 

Steel 

Sand

Gravel 

Clay

Below Pipe

Above Pipe 

Varies 

0 – 10 psi

Above 10 psi

Aluminum

Sand

Gravel 

Clay

Below Pipe

Above Pipe 

Varies 

0 – 10 psi

Above 10 psi

Steel Copper 

Sand

Gravel 

Clay

Below Pipe

Above Pipe 

Varies 

0 – 10 psi

Above 10 psi

Gas Sniffing X X X X X X X X X X X X X X X X X Cable X X X X X X X X X X X X X X X X X X X X X X X X X X X X Acoustic X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X 

Infrared X X X X X X X X X

Magnetic Flux Leakage X X X X X X X X X X X X X X X X X X X X X X X X X X X X Temp. Compensated Volumetric 

X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X

Pressure Point Analysis X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X XSCADA X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X 

8 
APPENDIX A

Detailed Technology Descriptions
Detailed Technology Descriptions 

1. Gas Sniffing

Technology: Electro-chemical sensors are calibrated to background concentration levels of the 

particular compound of interest. In some situations this compound can be an additive to the 

liquid to make detection feasible. Sensors are located or transported to a suspected leak location, 

where readings are taken and compared with threshold values to determine either a >leak= or 

>no leak= condition. 

Use: These sensors are commonly used with Volatile Organic Compounds (VOCs) which 

produce highly localized concentrations of vapor when a leak occurs. They can also be utilized 

with tracing gases, which are introduced into the system. 

Installation: Some gas detection equipment can be installed permanently and remotely 

monitored, however, the most frequent configuration is a hand-held unit which is used in 

surveys. 

Advantages: This system is good for some liquids, such as petroleum products, which produce 

vapor that can permeate through the soil covering the pipe system and produce an area of 

concentration sufficient for detection around the leak location. 

Disadvantages: Leaks of liquids with varying ambient concentrations, such as water, can easily 

be masked by the background noise. It is also not possible to chemically detect the presence of a 

water leak without adding a marker compound to the liquid. This would not be acceptable for 

potable water distribution systems, as the tracing additives are sometimes toxic. 

2. Cable Systems

Technology:

(1) Impedance Mismatch - A cable with a permeable outer shield is excited with a 

known frequency. Because the dry cable has a known impedance and length, when a leak 

changes the dielectric properties at a particular location within the cable, it creates an impedance 

which can be located along the length of the cable by signal attenuation and phase 

measurements. 

(2) Conductivity - Two conductors (generally stainless steel) are woven into a 

specially treated cable or ribbon. When a conductive liquid forms a continuity path between the 

two wires, a leak condition is indicated and can signal an alarm. 

A1 
A2 

 (3) Refractive Index - A fiber optic cable is given a coating that interacts with a 

contaminant. In the presence of the contaminant, the light passing through the fiber is affected, 

providing a means of detecting and locating the contaminant. 

Use: This technology is used to detect aqueous leaks or (with special polymers) leaks of fuel, 

solvents, electrolytes, acids, and bases. The cable can be installed during construction in limited 

access applications, or, as in the case of computer room floors and other accessible areas, 

installed after the fact. 

Installation: The cable is installed in locations where leaking fluid is likely to accumulate. The 

cable is run along the bottom annulus of double walled pipe and terminated at monitoring 

stations. For area applications, the cable is laid in a serpentine pattern. In multi-branch pipe 

systems, individual cables can be run from branching junctions. 

Advantages: This system can be sensitive to different types of liquids and can be easily installed. 

It can be used in piping systems as well as in storage tanks. The system presents a >leak= or >no 

leak= indication. 

Disadvantages: After exposure to water or fuel, the cable may need to be replaced. System 

design allows for false indications depending on initial designed sensitivity. 

3. Acoustic Methods

Technology: Acoustic leak detection methods rely on piezoelectric transducers to translate 

pressure waves generated by fluid escaping the piping system into an electrical signal. The 

system generally consists of a piezoelectric (a crystalline material which produces a voltage 

potential when stressed) transducer and an amplifier/signal conditioning unit. The operator then 

makes a >leak= or >no leak= determination. Research is currently investigating the permanent 

installation of transducers on a piping system at specific locations to continually monitor the 

system=s condition. 

Use: This technology can be applied to any system which is carrying fluids under pressure. 

Installation: For permanent or semi-permanent installation, transducers are connected to piping 

junctions acoustically via waveguides (metallic connections which conduct vibrations efficiently 

from the pipe to the transducer). The monitoring system then acts as either a data logger or a 

remote unit, both of which maintain a record of the acoustic activity in the pipe system within 

acoustic range by storing the acoustic signals received above a set threshold in either volatile 

memory or by transmitting them to a central computer. Portable units are used in a search pattern 

over the piping system, which may include direct acoustic coupling to the system where it is 

accessible through manholes or vents. 

Advantages: Leak location can be determined to within several feet or even within fractions of 

an inch, depending upon the location of the pipe and its surroundings. Because the system can be 

used to scan a piping system, the cost to detect a leak in a large system is only dependent on the 

man-hours required to cover the system. 
A3 

Disadvantages: The system can give false positives due to flow noise around valves and other 

geometry changes. The system can also give false negatives due to noise interference from the 

surroundings. Systems which depend upon operators to evaluate the signals require an 

experienced operator. 

4. Infrared Imaging

Technology: Infrared inspections are performed with a video camera capable of recording 

infrared radiation. The camera records the temperature differential and the images are processed 

to show the different temperatures in a color spectrum. Data can be videotaped for future review 

and processing. 

Use: These systems are generally used on piping systems which can produce significant thermal 

signatures through several feet of earth. This limits them to use with piping systems which 

transport liquids significantly above the surrounding ambient ground temperature, such as 

heating water or steam. 

Installation: These systems are used for surveys only. When conditions permit, the system or 

suspect locations within the system are scanned for leak indications. 

Advantages: The advantages of this system are that it can be used to scan large areas at a time 

and does not require any excavation. The infrared technique is especially useful for surveying 

heating and cooling distribution piping systems. 

Disadvantages: The disadvantages of this process are that it cannot be used for any piping 

system that does not present a temperature differential. 

5. Magnetic Flux Leakage (Pigging)

Technology: Magnetic flux leakage detection is done with instruments which identify and record 

information about pipeline anomalies such as corrosion pits, mechanical damage, dents, mill 

defects, wrinkle bends, hard spots, and hydrogen blisters. Magnetic flux is sent into the pipe by 

the pig, and anomalies cause leakage of the magnetic flux into the ground. Data is recorded for 

future review and processing. 

Use: These systems are only used for piping systems which are made of steel or cast iron. 

Anomalies can be located with an accuracy of + 0.1% of the distance measured, and the 

minimum detectable pit ranges from 5 to 10% of the pipe wall thickness. 

Installation: These systems are used for surveys only. The magnetic tape produced by the pig is 

examined for conditions associated with leaks. 

Advantages: The advantages of this system are that it can be used to scan large areas at a time 

and does not require any excavation. 
A4 

Disadvantages: A pig must be launched with the pipeline completely evacuated and requires 

special launch and recovery stations. Pipeline diameters and bend radii must be large enough to 

accommodate the pig. 

6. Temperature Compensated Volumetric Testing

Technology: Temperature compensated volumetric testing systems measure the volume of liquid 

that must be added to a piping system to maintain a constant pressure, thus providing the flow 

rate of a leak (or leaks) in gallons per hour. The temperature compensation is important, because 

thermally induced volume changes can either mask a small leak (causing missed detection) or be 

mistaken for a small leak (causing a false alarm). Thus, this type of testing must not be confused 

as being the same as conventional pressure testing. 

Use: This type of testing can be applied to any piping system, made of any material. It is also 

applicable to any type of liquid, be it aqueous or petroleum based. 

Installation: The equipment must be plumbed into the piping system under test. 

Advantages: The measurement is highly accurate, capable of finding leak rates of less than the 

regulatory limit of 0.1 gallon per hour. 

Disadvantages: The measurement takes 2 hours to complete, and the piping system must be 

taken out of service during the measuring period. Also, there is no way to determine the location 

of the leak 

7. Pressure Point Analysis

Technology: Pressure point analysis systems detect pressure waves caused by the sudden onset 

of a leak in a pipeline. Since this systems deals with the internal liquid, external factors such as 

ground water, previous contamination, or location of the pipeline (above or below ground) have 

no effect on performance. 

Use: This system can be applied to pressurized pipelines ranging from 3 to 42 inches in diameter, 

regardless of material of construction. It is also applicable to any type of liquid, be it aqueous or 

petroleum based. 

Installation: The pressure detectors are plumbed directly into the pipeline. 

Advantages: The sensors can be spaced miles apart, unless special conditions like steep hills 

exist, when a sensor must be placed at the top of the hill. 

Disadvantages: Flow noise can mask a leak indication (leak detection limited to 0.5 to 2% of the 

flow), and normal operation (such a valve movement) can also imitate leaks. The size of the leak 

which can be detected also depends upon pipeline volume (0.05 gph leaks detectable in 5,000 

gallon systems, 0.1 gph leaks detectable in 17,000 gallon systems, and 3.0 gph leaks detectable 

in 116,000 gallon systems). 
A5 

8. SCADA Systems

Technology: Supervisory Control and Data Acquisition (SCADA) systems use sensors to 

convert physical phenomena (such as pressure, temperature, flow rates, and density) into 

electronic signals which can be interpreted by the control system. SCADA systems rely on the 

combination of sensor inputs to determine the state of the system, which is then used to modify 

the control inputs to bring the system (heat distribution, petroleum delivery, etc.) to the desired 

state. Complete information about the liquid system is precisely determined at the sensor 

locations. 

Use: SCADA systems control large networks of piping systems for the delivery of value-added 

liquids. These systems are monitored by a central processor, which uses the inputs from remote 

monitoring locations to account for the total volume of liquid. SCADA is applicable to potable 

water distribution systems as well as hot water heat distribution and Heating Ventilation and Air 

Conditioning (HVAC) systems. The nature of the monitoring system allows the incorporation of 

volumetric leak detection, as well as energy leak detection, over the entire piping network. 

Installation: The multiplicity of the sensors required for an effective leak detecting SCADA 

system is easily implemented into new construction. Post-construction installation of a SCADA 

system limits sensor placement to accessible locations, when some, if not all, of the 

aforementioned sensors can be incorporated into the leak detection system, depending upon the 

particular installation requirements of each sensor. The sensors are then linked through telemetry 

to a central monitoring location and supervised by a host computer. 

Advantages: The sensor inputs at adjacent measurement locations can be used to determine leak 

locations as well as leak rates. The time frame required to detect and locate a leak in the system 

is dependent on the frequency with which the system is sampled. 

Disadvantages: The cost of sensors and data communication equipment necessary for 

implementing a SCADA system on a large piping system is prohibitive. 

9. Level Monitoring (SCADA sensor)

Technology: Level monitoring uses high precision storage tank liquid level measurements to 

determine the volume of liquid contained in each tank of the system. In a closed system, the 

volume should be constant for a given pressure and temperature when there is no leak present in 

the system. Any variation in the level generates an alarm that something is out of specification 

for the system. Sensors can be float switches, of either capacitance or continuity type. 

Use: Recirculating heating water distribution systems can recover and reuse water used to carry 

heat energy to the various distribution points. Also, any petroleum distribution system which 

goes to a static state for suitable length of time would be a candidate for liquid level monitoring 

for leak detection. In general, any liquid piping system which can be held in a static state for a 

sufficiently long period of time (based on total system volume), is a candidate for liquid level 

monitoring. 
A6 

Installation: These systems can be designed into the construction of the system or added at a 

later time. The installation of a level monitoring system requires either a continuous reading 

probe or discrete level probe to be installed in each tank within the closed system, as well as the 

necessary monitoring wiring. 

Advantages: The implementation of this system for leak detection is relatively inexpensive. Cost 

of implementation is directly related to the accuracy required for the particular system to detect 

leaks of a specific rate. 

Disadvantages: Liquid level monitoring requires the system to be in a static state for a period of 

time which is dictated by the resolution of the sensors and the volume of the system. A large 

volume system would require extremely precise measurement sensors which would be subject to 

noise, or an excessively lengthy static state holding period to detect small leaks in the system. 

10. Magnetic Induction Flow Meters (SCADA sensor)

Technology: Magnetic induction flow meters rely on the conductive properties of the liquid. The 

flow passes through a magnetic field and this produces a voltage difference over the crosssection of the flow area. This voltage is proportional to the (average) flow velocity. By knowing 

the conductivity of the liquid, the strength of the magnetic field, and the cross-sectional area, the 

flow velocity can then be determined by measuring the potential. 

Use: Can be used for all liquids flowing in pipes, providing that the conductivity of the liquid is 

known. These sensors, as with all mass flow sensors, are generally used as an accounting system 

to detect the loss of material between monitoring locations. These sensors can only identify the 

section of piping in which there is a leak. 

Installation: These sensors rely on precise flow measurements for determining mass flow rates. 

The sensors are housed in a short section of pipe which is installed in the piping system at 

locations where the system will maintain a positive pressure and flow continuity. For postconstruction installation, a section must be cut from the existing pipe, the exposed ends flanged, 

and the magnetic inductive monitoring section installed. 

Advantages: The sensors are relatively inexpensive and are very accurate. 

Disadvantages: There are velocity restrictions which depend on the liquid being pumped. 

11. Calorimetric Flow Meters (SCADA sensor)

Technology: These flow sensors utilize the calorimetric principal to determine flow velocity at a 

certain point in the flow field. The flow is locally heated and then the temperature is sensed a 

short distance downstream. Based on the thermal permitivity (the temperature dependent rate at 

which thermal energy propagates through a given medium) of the material, the temperature 

differential indicates the flow velocity. Assumptions on flow field profile are then used to 

calculate the volumetric flow rate from which the mass flow rate can be determined for a liquid 

of known density. 
A7 

Use: Can be used for a wide range of viscosities and for high solids content, as in sanitary 

applications. 

Installation: These sensors operate using assumptions about the profile of the flow in the piping 

system, which are similar to the assumptions made for the magnetic inductive mass flow sensors. 

They are similarly housed to magnetic inductive sensors and must be installed in the same 

fashion. Because the temperature must be measured at at least one location, there are components 

which are intrusive to the local flow field. 

Advantages: Highly accurate flow detection. 

Disadvantages: The main disadvantage is precisely controlling the temperature at the sensor. 

Fouling of the sensor could be a problem, depending on the liquid being transported in the 

piping. 

12. Ultrasonic Flow Meters (SCADA sensor)

Technology: By utilizing time-of-flight measurements of wave propagation or Doppler shift of 

the ultrasonic signal, the average flow velocity can be determined using two piezoelectric 

transducers, one a >sender= and the other a >receiver=. 

Use: Ultrasonic flow meters can be used for a wide range of materials from sewage to ammonia, 

nitrogen, natural gas, air, acids, heavy oils, or desalinated water. 

Installation: These systems can be attached to the exterior of the pipe in configurations which 

minimize the effects of a non-uniform flow field across the area being monitored. The location 

must correspond to a (preferably straight) section of pipe, which will maintain a consistent flow 

field during monitoring. 

Advantages: The ultrasonic sensor systems have high measuring accuracy, no pressure loss or 

flow obstructions, low power consumption, and can be purchased in intrinsically safe versions 

for explosive environments. 

Disadvantages: The initial cost of the signal processing equipment can be prohibitive. 
Table A-I. Performance Characteristics of LDL Technologies

(from Ref. 4, Lefave and Karr)Parameter 

Temperature Compensated Pressure Test 

Tracers Pigging Sensitive Cable Fiber Optic Cable Acoustic Emission 

Soil Conditions 

No Effect on LDL Performance 

Works Best in Highly Permeable Soils 

No Effect on LDL Performance 

No Effect on LDL Performance 

No Effect on LDL Performance 

Sensitive to the Acoustic Properties of the Surrounding Soil 

Water Table No Effect on LDL 

Performance 

High Water Table and Saturated Soils Reduce Effectiveness 

No Effect on LDL Performance 

Sensitive to Water Intrusion to Cable 

Sensitive to Water Intrusion to Cable 

Sensitive Soil Moisture Content 

Condition of Pipeline 

Leaking Valves Prevent Accurate Testing 

No Effect on LDL Performance 

No Effect on LDL Performance 

No Effect on LDL Performance 

No Effect on LDL Performance 

No Effect on LDL Performance 

Operations Sensitive to 

Fueling Operations 

Tracer Gas Must Be Dissolved in Fuel Throughout Pipeline 

No Effect on LDL Performance 

No Effect on LDL Performance 

No Effect on LDL Performance 

Sensitive to Noise Generated by Facility Operations 

Time Monitoring 

Snap Shot Snap Shot Snap Shot Continuous Continuous Snap Shot 

Spatial Resolution 

Poor Dependent Upon 

Sample Spacing 

Good Good Good Good 

Leak Rate Resolution 

Good Low Low Low Low Low 

Ease of Retrofit 

Easy Moderate Depends on 

Configuration of Pipeline 

Difficult Difficult Moderate 
B1 

APPENDIX B 

Field Survey Results 

Field Survey Results

Site visits resulted in the accumulation of a great deal of useful information on the installation 

and operation of several commonly used leak detection and location systems. The most common 

systems encountered were the gas sniffing systems, configured either to detect hydrocarbons 

directly or to detect the presence of trace levels of a marker gas. The other systems surveyed 

consisted of cable systems and volumetric SCADA type systems. To date, CERL has performed 

8 site surveys: 

1. Pensacola NAS [14 inch JP5 line monitored by an Arizona Instruments hydrocarbon 

vapor detector], 

2. Anchorage Airport [10 inch JP8 line monitored by a Hansa Consult pressure step 

system], 

3. Elmendorf AFB [2 inch mogas and diesel lines monitored by Permalert cable systems], 

4. North Island NAS [8 inch diesel line used in verification of a Vista Reasearch volumetric 

temperature compensation system], 

5. Travis AFB [14 inch JP8 line monitored by an Argus Technologies hydrocarbon vapor 

detection system], 

6. Ft. McCoy ANG [4 inch and 8 inch JP8 lines in a single conduit monitored by a Raychem 

cable system], 

7. Whiteman AFB [18 inch JP8 line monitored by a Tracer Research marker gas system], 

and 

8. Ellsworth AFB [18 inch JP8 line monitored by an Arizona Instruments hydrocarbon 

vapor detector]. 

Two leak detection systems manufactured by Argus Technologies were surveyed, and neither 

was functional. The system at Whiteman was abandoned in favor of the Tracer Research system 

when the quoted repair price of the Argus system exceeded the installation cost of the new 

Tracer Research system. The system installed at Travis AFB was installed concurrently with the 

pipeline to specifications by the pipeline construction contractor. MSgt. Torres indicated the 

system had yet to perform to the manufacturer=s specifications. The literature received from the 

company contained several performance evaluation documents from both foreign and domestic 

organizations. The system is based on sound scientific principals, however the system cannot be 

recommended due to two factors; 1) The time required for a given minimum leak to diffuse into 

the sensor requires the system to remain idle for so long that a leak of dangerous magnitude 

could remain undetected long enough to create a significant spill and 2) the system=s apparently 

unreliable performance. 

AZI systems were surveyed at two sites, Pensacola NAS and Ellsworth AFB. This system has 

proven itself in the field, with its major drawback being the susceptibility of the system to water 
 

invasion and the resulting inability to monitor some sections of the piping system. In addition, 

experience has shown that the remote operation capabilities of the system can be a liability.

Specifically, a lightning strike at the Pensacola NAS disabled several monitoring stations for 

several days. Another drawback to the AZI system is locating the leak source. At the Pensacola

installation, the sensor tubes cover 20 ft. of pipeline per sensor well - see Figure B-1. This means

that a leak indication can be located to within only 20 ft. of its source. The detection levels for a

given leak rate are also dependent on the installation of the system, particularly the backfill 

surrounding the sensor tubing and pipeline. AZI recommends a minimum percolation value that 

must be obtained by the backfill in order for the system to perform to its minimum concentration

detection levels. AZI claims a lower detection limit for gasoline of 150 ppm and 60 ppm for JP4, 

but does not give levels for either JP5 or JP8. Depending on soil types and ground water 

conditions, the system may be a viable solution for detection of fuel leaks, however, it is not 

applicable to water or energy pipe systems. 

Figure B-1. AZI Model Twelve-X installation schematic

The Tracer Research system was used at Travis AFB before the installation of the Argus

Technologies system. The Tracer system was considered too maintenance intensive after several 

of the probe wells were damaged by construction and grounds maintenance equipment. 

However, the same type of wells are used at Whiteman AFB and have not experienced the same

rate of attrition. The 20 ft. well spacing of the Tracer Research system allows leak location to 

within 10 ft. of the source by comparison of relative concentration levels. The deficiency of the

Tracer Research system is similar to that of the Argus Technologies system, in that it is not a 

B2 
 

continuous monitoring system. Leaks of dangerous magnitude can exist undetected until the next 

scheduled testing date. 

Two volumetric systems were surveyed - a pressure differential system by Hansa Consult and a 

temperature compensated volumetric system from Vista Research. The pressure differential 

system samples the pressurized pipe 75 times during a 20 minute test and then repeats at a higher 

pressure. The data is analyzed by a PC and the leak rate is calculated. The system is able to

detect a leak rate of 1.5 gal/hour. The temperature compensated volumetric leak detection system

from Vista Research utilizes a reservoir tank and precision measurements of the tank level to 

produce a temperature compensated volumetric curve at two different pressures. The testing

protocol requires about 2 hours to complete and is capable of detecting leaks of 0.01 gal/hour. 

Figure B-2. A temperature compensated volumetric leak detection system

Two cable systems were also surveyed, one by Permalert and one by Raychem. Both cable 

systems were performing as advertised and one was indicating a water leak condition. The 

disadvantage of the cable systems is that they require replacement of any length of cabling which 

comes in contact with liquid. Also, they must be installed in a conduit pipe, effectively negating 

their applicability for an existing system and increasing the installation cost of a new system. The

cable systems are ranked lowest in performance and cost. Water intrusion is a major problem for 

B3 
 

cable systems and since the cables must be protected, their use is limited to double-walled piping 

systems, which increases the initial cost of system installation and prevents retro-fitting existing

systems. 

Figure B-3. Raychem TraceTek cable, typical of those used in a cable leak detection 

system

B4 
Appendix B 
1

MEMORANDUM 

Date: August 26, 2008 

To: Cho Yi Kwan, EPA/OUST 

 Cindy Manson, Industrial Economics, Inc. 

From: Dave Gustafson, Donovan Hannu, and Mary Blel, DPRA Incorporated 

Re: Draft Preliminary Assessment of Baseline Conditions and Cost Impacts 

 Associated with Regulating Spill Buckets and Sumps for UST Systems; 

 DPRA WA 3971.0001.0025, Task 3 

____________________________________________________________________________ 

INTRODUCTION

In 1984, Congress responded to the increasing threat to groundwater posed by leaking 

underground storage tanks (LUSTs) by adding Subtitle I to the Resource Conservation and 

Recovery Act (RCRA). Subtitle I required EPA to develop a comprehensive regulatory program 

for underground storage tanks (USTs) storing petroleum or certain hazardous substances. In 

1988, EPA issued UST regulations covering three sections: technical requirements, financial 

responsibility requirements, and state program approval objectives (see 40 CFR Parts 280 and 

281). 

EPA is currently exploring potential revisions to the existing UST regulations. Specifically, the 

Agency is considering amending current UST requirements to address four issues: (1) 

technical/administrative fixes; (2) deferred UST systems; (3) existing regulatory gaps; and (4) 

potential deregulatory options. This memorandum presents a preliminary analysis that identifies 

and assesses potential cost impacts associated with implementing testing and leak detection 

requirements for spill buckets and sumps. 

EPA is considering requiring periodic tightness testing for UST spill buckets and sumps, as well 

as requiring release detection (i.e., vapor monitoring) and recordkeeping for these pieces of 

equipment. This cost impact analysis estimates the universe of USTs that will likely be affected, 

including estimating the associated number of spill buckets and sumps, assesses the potential 

costs to UST owners/operators as a result of requiring tightness testing and recordkeeping for 

spill buckets and sumps, and assesses the potential costs of vapor monitoring and recordkeeping 

for six and twelve months. 

UNIVERSE OF POTENTIALLY AFFECTED USTS

A total of 629,866 USTs were active according to EPA information sources. The most recent 

data on the number of active USTs were obtained from the U.S. EPA, FY 2007 End of Year 

Activity Report, memorandum from Cliff Rothenstein, Director Office of Underground Storage 

Tanks, to UST/LUST Regional Directors, Regions 1-10, December 5, 2007. The middle column 

of Table 1 presents the number of active USTs by state, territory, and in Indian Country. 
2

Model Site 

The total cost estimated for the potential regulation of UST spill buckets, turbine sumps 

(sometimes referred to as tank sumps) and dispenser pans (sometimes referred to as sumps) is 

estimated using a model of a typical gasoline station. The model site is assumed to have 2.65 

underground storage tanks per station. These tanks would be a combination of tanks holding 

high-grade gasoline, medium-grade gasoline, and low-grade gasoline.1 Truck stops may have 

many more tanks and “ma and pa” gasoline stations may have fewer tanks. 

The number of sumps for each UST can vary based on the type of tank that was installed and the 

type of product dispensed. For example, if the tank is double-walled, there will be a separate 

sump for the interstitial sensor for the interstitial space and if the tank contains gasoline and is in 

a State that requires stage I vapor recovery, there may be a separate port for the state I vapor 

recovery poppet valve. In some cases, there isn’t a separate sump for the stage I vapor recovery 

because the tank has “coaxial” stage I vapor recovery which means the vapor is recovered 

through the fill pipe rather than a separate port. The automatic tank gauging system sensor may 

be in the large piping sump or it may be in its own separate sump. 

All USTs will have at least the following: 

1. Fill port sump with catch basin or “spill bucket.” 

2. Piping sump (a.k.a. tank top sump or turbine sump): these sumps are typically contained 

but not always. 

Some USTs might also have the following sumps: 

1. A separate sump for the automatic tank gauging system (if it is not in the piping sump). 

These sumps may or may not be contained. 

2. A stage I recovery port sump (for gasoline tanks and only in states where stage I vapor 

recovery is required. These may or may not be contained. 

3. Tank interstitial sensor sumps. Only for tanks that are double-walled. These may or may 

not be contained. 

4. Miscellaneous – some sites may have miscellaneous tank top openings (sumps) with 

components that have been capped off and are no longer used or are just “extra” openings 

for potential future use. 

It is assumed that only those sumps that may contain gasoline/fuel will incur costs associated 

with tightness testing and vapor monitoring under the potential revisions to UST regulations. 

Those sumps include spill buckets and turbine sumps. The model site is assumed to have 2.65 

spill buckets (one per tank fill pipe). A few large sites may have a manifold system for filling 

tanks and fewer fill pipes than the model site, but, this is not common. The model site also is 

assumed to have 2.65 turbine sumps (one per tank) for the piping system associated with the 

tanks. 

 

2 U.S. EPA, Supporting Statement for EPA Information Collection Request Number 1360.08, "Underground Storage 

Tanks: Technical and Financial Requirements, and State Program Approval Procedures, October 24, 2007, Table 4. 
3

The number of dispensers at a site can vary greatly as well. Many dispensers are contained using 

dispenser pans; however, some may not have a pan/sump. In the past, dispenser pans have not 

been a design requirement; however, this is becoming a more common requirement when 

installing/upgrading a dispenser. The model site is assumed to have 5.30 dispenser pans (two 

dispenser pans per tank) per model site.2

Table 1 presents the estimated number of model UST sites, spill buckets, turbine sumps, and 

dispenser pans by state, territory, and in Indian Country. The estimated nationwide number of 

model UST sites is 237,685. 

Baseline Conditions 

Table 2 identifies states, territories and Tribal Nations that require tightness testing for spill 

buckets, sumps, and pans under current state (baseline) regulations. Five states have been 

identified as requiring tightness testing every year or every three years for spill buckets. Four 

states have been identified as requiring tightness testing every three or five years for turbine 

sumps. Three states have been identified as requiring tightness testing every three or five years 

for dispenser pans. Upon further analysis, other states and territories may be determined to 

require tightness testing under current state regulations. If such states are identified, baseline 

cost estimates will be higher and incremental cost estimates will be lower. 

 

Contacts from a national tightness testing contractor, Tanknology, stated that approximately 4% 

of their clients conduct sump testing in states where they are not currently required to.3

 The 

primary driver of this is that these clients have a majority of their sites within states that require 

sump testing, so they conduct sump testing at all of their sites throughout the U.S. DPRA’s 

opinion is that clients of national tightness testing companies like Crompco and Tanknology may 

have less risk tolerance than the average UST operator, so the actual percentage of sumps that 

fail is likely larger than presented and the percentage of tank owners conducting testing in states 

where it is not required may be less than 4%, and is probably closer to 2%. It is assumed they 

are conducting these tests on an annual basis as part of their corporate best management practice 

program. 

POTENTIAL NEW FEDERAL UST REGULATORY REQUIREMENTS

Potential new federal UST regulatory requirements include periodic tightness testing for UST 

spill buckets, sumps and pans, leak detection (i.e., vapor monitoring), and recordkeeping. This 

memorandum presents cost impacts associated with reading the new regulations, conducting 

tightness testing on spill buckets, turbine sumps, and dispenser pans, the cost to repair spill 

buckets, sumps and pans that fail tightness tests, installation and operation of a vapor monitoring 

system, and recordkeeping for tightness testing and vapor monitoring. 

 

2

 United States District Court for the Western District of Wisconsin, United States of America v. Franklin Electric 

Co., Inc., United Dominion Industries Limited, and United Dominion Industries, Inc., Filed May 31, 2000. 3 Ferguson, Todd, Tanknology, June 18, 2008. Personal Communication with Donovan Hannu, DPRA. 
4

UNIT COST ESTIMATES

In order to assess the cost impacts associated with the potential new UST regulatory 

requirements, unit cost estimates were developed for reading the regulations, tightness testing, 

vapor monitoring and recordkeeping. Unit costs were developed based on previously published 

EPA documents, U.S. Department of Labor statistics, and vendor quotes. 

Reading the Regulations

Newly regulated sites will need to read the regulations on general operating requirements for 

conducting tightness testing and release detection for conducting vapor monitoring. The U.S. 

EPA, Supporting Statement for EPA Information Collection Request Number 1360.08, 

"Underground Storage Tanks: Technical and Financial Requirements, and State Program 

Approval Procedures, (ICR 1360.08) October 24, 2007, provides burden estimates for reading 

regulations on general operating requirements and release detection. Assuming tank tightness 

general operating labor burden requirements specified in ICR 1360.08 are similar to spill bucket 

and sump general operating requirements, the labor burden requirements for reading regulations 

on tightness testing general operating requirements include 0.25 hours of legal, 0.25 hours of 

managerial, and 0.5 hours of technical labor. Assuming tank vapor monitoring release detection 

labor burden requirements specified in ICR 1360.08 are similar to spill bucket and sump release 

detection requirements, the labor burden requirements for reading regulations on vapor 

monitoring release detection requirements include 0.50 hours of legal, 0.50 hours of managerial, 

and 1.0 hours of technical labor. Total labor burden requirements are estimated to include 0.75 

hours of legal, 0.75 hours of managerial, and 1.5 hours of technical labor.4 Using the labor rate 

estimates described below, the average one-time cost per site to read and understand the 

regulations is $194.25 (0.75 hours x $95/hour + 0.75 hours x $60/hour + 1.5 x $52/hour). From 

Table 1, there are an estimated 237,685 sites. The total one-time cost for reading the new UST 

regulatory requirements is estimated at $46.2 million ($194.25/site x 237,685 sites). Of this 

amount, $15.4 million ($64.75/site x 237,685 sites) is the one-time cost for reading tightness 

testing general operating requirements and $30.8 million ($129.75/site x 237,685 sites) is for 

reading release detection requirements for a vapor monitoring system. These costs would be 

incurred upon any change in key personnel at the site. They have not been annualized in this 

preliminary assessment. 

Tightness Testing

One of the primary requirements under potential new regulatory requirements is to conduct 

tightness testing on the spill buckets and sumps on either a one-year or three-year frequency. 

This section presents estimated costs for tightness testing of spill bucket sumps, tank turbine 

sumps, and dispenser pans, along with approximate repair costs if these tightness tests fail. We 

 

4 For this preliminary analysis we did not estimate the labor costs for States to submit documents to EPA or 

administer the additional regulatory requirements. In addition, labor costs for contractors to read and understand the 

regulations are assumed to be included in their overhead rates and incorporated into the unit cost estimates obtained 

from vendors for conducting tightness tests and vapor monitoring. 
5

will also discuss the percentage of tests that fail and the percentage of tank owners that are 

already conducting these tests in states where they are not required to do so. Todd Ferguson and 

Mark Lindsey of Tanknology, a national tightness testing firm, were the primary source of the 

cost estimates. Ed Kubinsky of Crompco’s presentation regarding Secondary Containment 

Testing at the 20th Annual Storage Tanks Conference in March 2008 was the primary source of 

pass/fail percentages. Mr. Lindsey of Tanknology also discussed pass/fail percentages, including 

comparisons between typical regulated and non-regulated sites.5

Repair costs are included in the cost estimate because we believe that UST operators are 

conducting a different type of maintenance under baseline compared to the new regulatory 

requirements being considered. Typically, states require that spill buckets must be kept clean of 

water and debris such that the buckets’ full capacity is maintained and available to catch 

overfills. In addition, turbine sumps and dispenser pans must remain free of water, regulated 

substance and debris. Maintenance operations typically involve the removal of water, regulated 

substances, and debris and may involve conducting simple tightening of pipe connections, etc. 

under baseline. These "baseline" maintenance costs are not what we are pricing in our repair 

cost estimates. These same costs would be incurred under the potential new regulatory 

requirements; therefore, incremental costs are zero. Repair cost estimates cover a range of 

activities from replacement of gaskets at the low end to installation of new buckets/sumps/pans 

at the high end. 

 Spill Bucket Sumps 

Spill bucket sumps are located around points where the delivery driver connects hoses to the 

UST. While the costs for spill bucket testing may slightly vary depending upon the number of 

buckets at a site, the average cost to conduct tightness testing on spill buckets by vacuum is $125 

per spill bucket.6 

At sites in states where testing is required, approximately 13.5% of spill bucket tightness tests 

fail.7 Repair costs may range from $200 to $2,000, depending upon the severity of the failure. 

The typical repair cost is $400.8

 

At sites in states where testing is not required or at a site that has not been tested before, at least 

30% of spill bucket tests fail.9

 The estimated average test failure percentage over the 20-year life 

of a gasoline service station is 15.6%.10, 11 The typical repair cost for failures at these sites is 

 

5 Mr. Lindsey has never had to conduct sump testing in a cold-weather environment. He said that all of our pass/fail 

percentages seem very appropriate for warm-weather states, but he is fairly certain that the failure percentages 

would be higher if testing was required in the cold-weather states, due to freeze/thaw cycles, upheaving, snowplowing, and other related issues. Lindsey, Mark, Tanknology, July 2, 2008. Personal Communication with 

Donovan Hannu, DPRA. 

6 Ferguson, Todd, Tanknology, June 18, 2008. Personal Communication with Donovan Hannu, DPRA. 

7 Kubinsky, Edward, Jr., Special Projects Manager, Crompco, LLC, Secondary Containment Testing, 20th Annual 

National Storage Tanks Conference, Atlanta, GA, March 17, 2008. 

8 Lindsey, Mark, Tanknology, July 2, 2008. Personal Communication with Donovan Hannu, DPRA. 

9 Lindsey, Mark, Tanknology, July 2, 2008. Personal Communication with Donovan Hannu, DPRA. 

10 The Internal Revenue Service estimates the life of a service station building to be 20 years (asset class 57.1 - 

http://www.irs.gov/publications/p946/13081f40.html). 
6

$1,000.12 Using a similar approach to the estimated average test failure percentage, the typical 

repair cost over the 20-year life of a gasoline service station is $475.13

 Turbine Sumps 

Turbine sumps may house the submersible turbine pump head, piping, leak detectors, wiring, and 

other equipment. While the costs for turbine testing may slightly vary depending upon the 

number of sumps at a site, the average cost to conduct tightness testing on turbine sumps by 

vacuum is $150 per sump.14 

At sites in states where testing is required, approximately 22% of turbine sump tightness tests 

fail.15 Repair costs may range from $200 to $3,000, depending upon the severity of the failure. 

The typical cost of repairs at these sites is $600.16 

At sites in states where testing is not required or at a site that has not been tested before, 

approximately 45% of turbine sump tests fail.17 The estimated average test failure percentage 

over the 20-year life of a gasoline service station is 24.9%.18,19 The typical repair cost for 

failures at these sites is $1,200.20 Using a similar approach to the estimated average test failure 

percentage, the typical repair cost over the 20-year life of a gasoline service station is $675.21

 11 The 30% spill bucket test failure rate is an approximation for when state tightness testing programs are initially 

created. After the first few years (and tightness tests) all parts that might fail or are weakened at the initiation of the 

state tightness testing program will be replaced. A fully established state program is estimated to have 13.5% of the 

tests fail. For cost estimation purposes, we assume that over a five year period the test failure rate will steadily 

decline from 30% to 13.5% and the test failure rate will remain constant at 13.5% for years 5 through 20. 

12 Lindsey, Mark, Tanknology, July 2, 2008. Personal Communication with Donovan Hannu, DPRA. 13 The $1,000 spill bucket repair cost is an approximation for when state tightness testing programs are initially 

created. After the first few years (and tightness tests) all parts that might fail or are weakened at the initiation of the 

state tightness testing program will be replaced. A fully established state program is estimated to have $400 for a 

typical spill bucket repair cost. For cost estimation purposes, we assume that over a five year period the spill bucket 

repair cost will steadily decline from $1,000 to $400 and the typical repair cost will remain constant at $400 for 

years 5 through 20. 

14 Ferguson, Todd, Tanknology, June 18, 2008. Personal Communication with Donovan Hannu, DPRA. 15 Ferguson, Todd and Mark Lindsey, Tanknology June 2008. Personal Communication with Donovan Hannu, 

DPRA. 

16 Lindsey, Mark, Tanknology, July 2, 2008. Personal Communication with Donovan Hannu, DPRA. 17 Lindsey, Mark, Tanknology, July 2, 2008. Personal Communication with Donovan Hannu, DPRA. 18 The Internal Revenue Service estimates the life of a service station building to be 20 years (asset class 57.1 - 

http://www.irs.gov/publications/p946/13081f40.html). 

19 The 45% turbine sump test failure rate is an approximation for when state tightness testing programs are initially 

created. After the first few years (and tightness tests) all parts that might fail or are weakened at the initiation of the 

state tightness testing program will be replaced. A fully established state program is estimated to have 22% of the 

tests fail. For cost estimation purposes, we assume that over a five year period the test failure rate will steadily 

decline from 45% to 22% and the test failure rate will remain constant at 22% for years 5 through 20. 

20 Lindsey, Mark, Tanknology, July 2, 2008. Personal Communication with Donovan Hannu, DPRA. 21 The $1,200 turbine sump repair cost is an approximation for when state tightness testing programs are initially 

created. After the first few years (and tightness tests) all parts that might fail or are weakened at the initiation of the 

state tightness testing program will be replaced. A fully established state program is estimated to have $600 for a 

typical turbine sump repair cost. For cost estimation purposes, we assume that over a five year period the turbine 

sump repair cost will steadily decline from $1,200 to $600 and the typical repair cost will remain constant at $600 

for years 5 through 20. 
7

 Dispenser Pans 

Dispenser pans provide access to piping, flex connectors, shear valves, and other equipment 

directly beneath each dispenser. The average cost to conduct dispenser pan testing using 

hydrostatic methods is $180 per sump.22 This cost does not include testing water disposal, due 

to wide range of disposal options for each state. 

At sites in states where testing is required, approximately 18.5% of dispenser pan tightness tests 

fail.23 Repair costs may range from $200 to $2,000, 24 depending upon the severity of the failure. 

The most common failure involves sumps that are not water-tight. The typical cost of repairs at 

these sites is $400.25

At sites in states where testing is not required or at a site that has not been tested before, at least 

40% of dispenser pan tests fail.26 The estimated average test failure percentage over the 20-year 

life of a gasoline service station is 21.2%.27,28 The typical repair cost for failures at these sites is 

$800.29 Using a similar approach to the estimated average test failure percentage, the typical 

repair cost over the 20-year life of a gasoline service station is $450.30

Vapor Monitoring Leak Detection Systems

Another requirement under potential new regulatory requirements for USTs is to conduct vapor 

monitoring. This section presents estimated costs associated with using either continuous or 

periodic vapor monitoring as leak detection methods. For a fully continuous vapor monitoring 

system we assumed it involves using vapor monitoring points near each spill bucket, turbine 

sump and dispenser pan, installing vapor sensors in each point, connecting the sensors to an 

automatic tank gauging (ATG) system, and upgrading the ATG system to handle the additional 

vapor sensors. This system represents the highest cost leak detection method. For a periodic 

vapor monitoring system a vapor monitoring point is installed near each spill bucket, turbine 

 

22 Ferguson, Todd, Tanknology, June 18, 2008. Personal Communication with Donovan Hannu, DPRA. 23 Lindsey, Mark Lindsey, Tanknology, July 2, 2008. Personal Communication with Donovan Hannu, DPRA. 24 Ferguson, Todd, Tanknology, June 18, 2008. Personal Communication with Donovan Hannu, DPRA. 25 Lindsey, Mark, Tanknology, July 2, 2008. Personal Communication with Donovan Hannu, DPRA. 26 Lindsey, Mark, Tanknology, June 2008, 2008. Personal Communication with Donovan Hannu, DPRA. 27 The Internal Revenue Service estimates the life of a service station building to be 20 years (asset class 57.1 - 

http://www.irs.gov/publications/p946/13081f40.html). 

28 The 40% dispenser pan test failure rate is an approximation for when state tightness testing programs are initially 

created. After the first few years (and tightness tests) all parts that might fail or are weakened at the initiation of the 

state tightness testing program will be replaced. A fully established state program is estimated to have 18.5% of the 

tests fail. For cost estimation purposes, we assume that over a five year period the test failure rate will steadily 

decline from 40% to 18.5% and the test failure rate will remain constant at 18.5% for years 5 through 20. 

29 Lindsey, Mark Lindsey, Tanknology, July 2, 2008, 2008. Personal Communication with Donovan Hannu, DPRA. 30 The $800 dispenser pan sump repair cost is an approximation for when state tightness testing programs are 

initially created. After the first few years (and tightness tests) all parts that might fail or are weakened at the 

initiation of the state tightness testing program will be replaced. A fully established state program is estimated to 

have $400 for a typical dispenser pan repair cost. For cost estimation purposes, we assume that over a five year 

period the dispenser pan repair cost will steadily decline from $800 to $400 and the typical repair cost will remain 

constant at $400 for years 5 through 20. 
8

sump and dispenser pan and a soil gas sample is collected and analyzed either on a six month or 

annual basis. Attachment A presents an estimate of soil sampling costs that could be incurred to 

determine if a leak occurred resulting from a failed tightness test. This one-time investigative 

leak detection method involves collecting and analyzing a soil sample for the regulated substance 

near the bucket/sump/pan. 

It should be noted that both continuous and periodic vapor monitoring systems (and soil 

sampling) can have a high frequency of false positives from previous petroleum releases at the 

site. Numerous sites have had previous petroleum releases that have not been cleaned to more 

stringent cleanup standards. For example, they could have been cleaned to industrial or 

commercial cleanup standards that allow higher concentrations of petroleum contaminants to 

remain on the site rather than a residential cleanup standard that requires lower concentrations. 

Even contamination that remains at sites cleaned to residential standards could trigger a false 

positive “leak” detection result depending on the sensitivity of the equipment used and location 

of previous petroleum releases. 

Continuous Vapor Monitoring Leak Detection 

Information for this analysis was obtained from Scott Olson at Northland Petroleum Service. 

Mr. Olson serviced several leak detection systems using vapor monitoring approximately 15 

years ago, before his clients quit using the method due to problems associated with it. Mr. Olson 

states that vapor monitoring is nearly worthless as a leak detection method due to several 

problems inherent with the method. These problems are associated with false positives, inability 

to confirm sensor readings, and previous petroleum releases. 

Many of the UST system components and materials can falsely trigger a vapor sensor. These 

materials include resins used in fiberglass tanks, gortex membranes, and chemical solvents used 

to wash USTs before installation and/or coating. In addition, many UST sites are located on 

property where a petroleum release has previously occurred, so contamination associated with 

the previous release may trigger the vapor sensors, especially during fluctuating groundwater 

conditions. The biggest problem associated with using vapor monitoring as a leak detection 

method is the inability to confirm the existence of vapors in the sensor point. After a vapor 

sensor alarm goes off, any vapors that may have caused the alarm immediately dissipate as soon 

as the vapor monitoring point lid is opened. There is no way of documenting whether the vapor 

sensor actually detected vapors or if it was a false positive. 

In addition, Mr. Olson stated that because of the hazards associated with drilling above and 

directly adjacent to existing piping and tanks, vapor monitoring points will have to be installed 

by hand at each site. 

Mr. Olson provided the following unit costs associated with retro-fitting a typical UST system to 

use vapor monitoring as a leak detection method. 

• Install vapor monitoring points by hand near each sump: $5,000 

• Vapor sensors (10.6 sensors @ $500/sensor): $5,300 
9

• Install new cards in ATG system to handle vapor sensors (three cards @ $500/card): 

$1,500 

• Install new dedicated conduits and wiring from sumps to ATG: $7,000 

The total cost for retro-fitting a typical UST system that already has an ATG system is $18,800. 

Converting this one-time retro-fit cost into an annual cost, assuming a 7 percent discount rate 

over the 20-year life of the gasoline service station, results in an annual cost of $1,775.31 Not all 

UST systems have ATG systems. Sixty-six percent of the sites are assumed to already have an 

ATG system.32 Other sites that use other leak detection methods such as annual tightness testing 

and statistical inventory reconciliation (SIR) would require substantial additional costs for an 

ATG system. These costs may average approximately $20,000. Converting this one-time 

installation cost into an annual cost, assuming a 7 percent discount rate over the 20-year life of 

the gasoline service station, results in an annual cost of $1,888.33 In contrast, 34 percent of the 

sites are assumed to not have an ATG system incurring both the retrofit cost ($1,775 per year) 

and ATG system cost ($1,888 per year). 

Operation and maintenance of vapor monitoring systems include calibration, cleaning and 

replacement of defective sensors. Calibration and cleaning is estimated to cost $250 per year.34 

Sensors cost $500 each. They are known to fail frequently. 35 One-sixth of the 10.6 sensors are 

assumed to be replaced annually based on best professional judgment for a total cost of $883 per 

year. Total vapor monitoring operation and maintenance costs are estimated to be $1,133 per 

year. 

Periodic Vapor Monitoring Leak Detection Method 

Another leak detection method is to periodic vapor monitoring. Advancing vapor monitoring 

points by hand and collecting soil-gas samples would determine if a release impacted the 

subsurface at UST sites. The following unit costs were assumed to retro-fit a typical UST 

system to use vapor monitoring as a leak detection method: 

• Install vapor monitoring points by hand near each sump (10.6 vapor monitoring points 

per site): $5,000 

• Collect soil gas sample from each vapor monitoring point per sampling event: $30036

 

31 Capital recovery factor (i.e., the amount of each future annuity payment required to accumulate a given present 

value) based on a 7 percent real rate of return and 20-year borrowing period is 0.09439. $18,800 x 0.09439 = 

$1,775. 

32 U.S. EPA, Supporting Statement for EPA Information Collection Request Number 1360.08, "Underground 

Storage Tanks: Technical and Financial Requirements, and State Program Approval Procedures, October 24, 2007, 

Table 4. 

33 Capital recovery factor (i.e., the amount of each future annuity payment required to accumulate a given present 

value) based on a 7 percent real rate of return and 20-year borrowing period is 0.09439. $19,500 x 0.09439 = 

$1,888. 

34 Pyles, Charles, Precision Testing, White Plains, Maryland, July 3, 2008. Personal communications with Mary 

Blel, DPRA. 

35 Pyles, Charles, Precision Testing, White Plains, Maryland, July 3, 2008. Personal communications with Mary 

Blel, DPRA. 

36 DPRA best professional judgment. 
10

• Soil gas laboratory analysis per sample: $9037

The one-time vapor monitoring point installation cost of $5,000 converted into an annual cost, 

assuming a 7 percent discount rate over the 20-year life of the gasoline service station, results in 

an annual cost of $472.38 On a per vapor monitoring point basis the annual cost is $45 

($472/10.6 points = $45). Soil gas sampling is estimated to be $300 per sampling event for the 

entire site. On a per vapor monitoring point basis the soil gas sampling unit cost is $28 per 

sampling event ($300/10.6 points = $28). Soil gas laboratory analysis costs are $954 per 

sampling event for the entire site ($90 *10.6 points = $954). On a per vapor monitoring point 

basis the soil gas laboratory analysis unit cost is $90 per sample. Total periodic vapor 

monitoring costs are estimated to be $1,726 per year per site if annual soil gas sampling is 

conducted or $2,980 per year per site if semi-annual soil gas sampling is conducted. 

 

Recordkeeping

Newly regulated sites will need to keep records for tightness testing and vapor monitoring. The 

U.S. EPA, Supporting Statement for EPA Information Collection Request Number 1360.08, 

"Underground Storage Tanks: Technical and Financial Requirements, and State Program 

Approval Procedures, (ICR 1360.08) October 24, 2007, provides burden estimates for 

maintaining records for tightness tests under general operating requirements and monthly tank 

vapor monitoring results for release detection requirements – scenarios examine recordkeeping 

annually or twice annually (every six months). Assuming tank tightness general operating labor 

burden requirements specified in ICR 1360.08 are similar to spill bucket and sump general 

operating requirements, the labor burden requirements for maintaining records of tightness tests 

include 0.10 hours of clerical per test plus $0.10 for materials per test. Using the labor rate 

estimates described below, the average cost for maintaining tightness testing records is $3 per 

test (0.1 hours x $26/hour). 

Assuming tank vapor monitoring release detection labor burden requirements specified in ICR 

1360.08 are similar to spill bucket and sump release detection requirements, the labor burden 

requirements for maintaining records of vapor monitoring results include 1.67 hours of technical 

labor for 12 monthly recordings. A per recording event estimate of 0.14 hours is derived by 

dividing the labor burden hours by 12. In addition, capital/startup costs are estimated to be $733 

per site. Converting this one-time annual/startup cost into an annual cost, assuming a 7 percent 

discount rate over the 20-year life of the gasoline service station, results in an annual cost of 

$69.39 Using the labor rate estimates described below, the average cost to maintain vapor 

monitoring records is $15 per recordkeeping recording event (0.14 hours x $52/hour). 

 

37 DPRA best professional judgment. 38 Capital recovery factor (i.e., the amount of each future annuity payment required to accumulate a given present 

value) based on a 7 percent real rate of return and 20-year borrowing period is 0.09439. $5,000 x 0.09439 = $472. 

39 Capital recovery factor (i.e., the amount of each future annuity payment required to accumulate a given present 

value) based on a 7 percent real rate of return and 20-year borrowing period is 0.09439. $733 x 0.09439 = $69. 
11

Labor Costs 

The table below shows the estimated average hourly labor cost (including overhead and fringe), 

by labor category. These labor rates are used to calculate the labor cost for reading the 

regulations and conducting the reporting and recordkeeping activities. 

Average Hourly Labor Cost by Labor Category (2007 dollars)

 Legal Managerial Technical Clerical 

Sites $95 $60 $52 $26 

To obtain hourly labor costs (other than legal labor costs) for sites, the private industry employer 

costs (including fringe benefits for paid leave, supplemental pay, insurance, retirement and 

savings, and legally required benefits for management workers) provided by the Bureau of Labor 

Statistics (BLS) in May 2008 were used.40 To obtain hourly legal labor costs, BLS national 

occupational employment and wage estimates for May 2007 (plus an additional 44 percent of the 

base for fringe benefits) were used and then adjusted for 2008 dollars using the 3.2 percent 2008 

Employment Cost Index.41, 42 Additional administrative expenses of a business that are 

necessary for a business to function is referred to as overhead. Typical overhead costs include 

rent, utilities and property insurance. The overhead rate is estimated as 12 percent of the base 

and fringe benefit labor rate.43

 

40 U.S. Department of Labor. Bureau of Labor Statistics (BLS). Employer costs per hour worked for employee 

compensation and costs as a percent of total compensation: Private industry workers, by occupational group and 

full-time and part-time status (March 2008); available from <http://www.bls.gov/news.release/ecec.t11.htm>; 

accessed July 2, 2008. Total compensation (including fringe for paid leave, supplemental pay, insurance, retirement 

and savings, and legally required benefits) for management workers is $53.93/hour, professional workers is $46.36 

per hour, and Office workers is $23.11 per hour. Wages and salaries alone are $37.46 per hour, $32.91 per hour, 

and $15.97 per hour, respectively. 

41 U.S. Department of Labor, Bureau of Labor Statistics (BLS). Occupational employment and wages – 23-1011 

Lawyers [see “National estimates for this occupation”, “mean hourly wage”] (May 2007); available from 

<http://www.bls.gov/oes/current/oes_nat.htm>; accessed July 2, 2007. The mean hourly wage was $56.87 in 2007 

(excluding fringe). Assumed a fringe rate equivalent to the rate received by management workers noted previously 

($53.93/hour/$37.46/hour = 1.44 => 44% fringe rate). 

42 The Employment Cost Index (ECI) is 3.2 percent (wages and salaries for private industry) from March 2007 to 

March 2008. BLS. News release: Employment Cost Index (March 2008) [see Table B]; available from < 

http://www.bls.gov/news.release/eci.nr0.htm >. 43 OMB Circular No. A-76 - Table C, May 29, 2003, Summary of Standard Competition Form (SCF) line 4, 

http://www.whitehouse.gov/omb/circulars/a076/a76_incl_tech_correction.pdf 
12

SUMMARY OF COST IMPACTS

Cost impacts associated with the potential new UST regulations are estimated to range from $0.2 

billion per year if potential regulatory requirements only include tightness testing being 

conducted every three years and no vapor monitoring leak detection to $1.5 billion per year if 

potential regulatory requirements include annual tightness testing and continuous vapor 

monitoring leak detection with semi-annual recordkeeping. The table below presents a summary 

of the total incremental annual cost estimate for reading the regulations, tightness testing 

conducted either annually or every three years, repair, leak detection using either periodic or 

continuous vapor monitoring system and recordkeeping including continuous vapor monitoring 

recordkeeping every six or twelve months. These estimates incorporate no existing state 

regulations into the baseline regarding leak detection. If states currently require leak detection, 

the incremental cost estimates are overstated. 

Reading the regulation costs are estimated to range between $15 and $46 million in the first year 

for tightness testing requirements or both vapor monitoring leak detection and tightness testing 

requirements, respectively. If other leak detection methods are chosen costs for reading the 

regulations would fall within this range. Costs were not annualized in this preliminary 

assessment to account for any changes in key personnel in subsequent years. 

Tightness testing costs are estimated to range from $117 to $365 million per year depending 

whether tightness testing is conducted every three years or annually. Concurrently, spill bucket, 

turbine sump and dispenser sump repair costs are estimated to range from $64 to $231 million 

per year. Recordkeeping costs associated with tightness testing are estimated to range from $4 to 

$6 million per year.44

Two types of leak detection methods are incorporated into the cost estimates, periodic and 

continuous vapor monitoring systems. If the installation of a periodic vapor monitoring system 

is an acceptable method (even with all its associated false positive problems) to determine if a 

leak/release occurred from a bucket/sump/pan the costs are estimated to range from $409 to $708 

million per year depending whether recordkeeping is required every twelve months or six 

months. If the installation of a continuous vapor monitoring system at all UST facilities is an 

acceptable method (even with all its associated false positive and equipment problems) to 

determine if a leak/release occurred from a bucket/sump/pan the costs are estimated to cost $844 

million annually and recordkeeping is estimated to range from $20 to $26 million per year 

depending whether recordkeeping is required every twelve months or six months. 

 

44 Other options for tightness testing include varying the testing frequency. Currently, some states test spill buckets 

every one to three years, turbine sumps every three to five years, and dispenser pans every three to five years. 

Another option not presented in the table that would lower costs would be to conduct tightness testing annually for 

spill buckets and every five years for turbine sumps and dispenser pans. Tightness testing costs are estimated to be 

$68 million per year and repair costs are estimated to be $63 million per year. 
13

Total Estimated Incremental Annual Costs 

(million dollars, 2008) 

Tightness Testing (annual) Tightness Testing (every 3 years) 

Vapor 

Monitoring 

Recordkeeping 

every 6 months 

Vapor 

Monitoring 

Recordkeeping 

every 12 months 

Vapor 

Monitoring 

Recordkeeping 

every 6 months 

Vapor 

Monitoring 

Recordkeeping 

12 months 

Reading the regulations (First-year Cost) 

- Tightness Testing Only $15 $15 $15 $15 

- Vapor Monitoring & 

Tightness Testing 

 $46 $46 $46 $46 

Tightness Testing 

 Spill Buckets 

 Turbine Sumps 

 Dispenser Pans 

 Total 

$68 

$87 

$210

$365 

$68 

$87 

$210

$365 

$21 

$28 

$68

$117 

$21 

$28 

$68

$117 

Spill Bucket/Turbine Sump/Dispenser Pan Repair 

 Spill Buckets 

 Turbine Sumps 

 Dispenser Pans 

 Total 

$40 

$89 

$101

$231 

$40 

$89 

$101

$231 

$13 

$24 

$27

 $64 

$13 

$24 

$27

 $64 

Vapor Monitoring Leak Detection 

- Periodic Vapor Monitoring 

 Spill Buckets 

 Turbine Sumps 

 Dispenser Pans 

 Total 

- Continuous Vapor Monitoring 

of all buckets, sumps and pans 

$177 

$177 

$354

$708 

$844 

$102 

$102 

$205

$409 

$844 

$177 

$177 

$354

$708 

$844 

$102 

$102 

$205

$409 

$844 

Recordkeeping 

- Tightness Testing Only $6 $6 $4 $4 

- Vapor Monitoring & 

Tightness Testing 

$26 $25 $22 $20 

First-Year Total

- Tightness Testing Only $617 $617 $200 $200 

- Vapor Monitoring & 

Tightness Testing $1,376 - $1,512 $1,076 - $1,511 $957 - $1,093 $656 - $1,091 

Subsequent-Year Total

- Tightness Testing Only $602 $602 $185 $185 

- Vapor Monitoring & 

Tightness Testing $1,330 - $1,466 $1,030 - $1,465 $911 - $1,047 $610 - $1,045 
14

Table 1. Universe of Potentially Affected Active USTs, UST Sites, Spill Buckets, Tank Sumps, and Dispenser 

State/ 

Territory/ 

Indian County 

Number of Active 

USTs 

Number of Model UST 

Sites 

Number of Model Spill 

Buckets 

Number of Model 

Turbine Sumps 

AK 1,151 434 1,151 1,151 AL 18,885 7,126 18,885 18,885 AR 9,455 3,568 9,455 9,455 AS 16 6 16 16 AZ 7,003 2,643 7,003 7,003 CA 37,498 14,150 37,498 37,498 CNMI 68 26 68 68 CO 7,949 3,000 7,949 7,949 CT 10,849 4,094 10,849 10,849 DC 696 263 696 696 DE 1,467 554 1,467 1,467 FL 28,862 10,891 28,862 28,862 GA 30,049 11,339 30,049 30,049 GU 267 101 267 267 HI 1,692 638 1,692 1,692 IA 7,372 2,782 7,372 7,372 ID 3,302 1,246 3,302 3,302 IL 22,574 8,518 22,574 22,574 IN 13,840 5,223 13,840 13,840 KS 6,967 2,629 6,967 6,967 KY 12,415 4,685 12,415 12,415 LA 12,601 4,755 12,601 12,601 MA 11,021 4,159 11,021 11,021 MD 9,243 3,487 9,243 9,243 ME 3,199 1,207 3,199 3,199 MI 20,155 7,606 20,155 20,155 MN 14,532 5,484 14,532 14,532 MO 10,267 3,874 10,267 10,267 
15

Table 1. Universe of Potentially Affected Active USTs, UST Sites, Spill Buckets, Tank Sumps, and Dispenser 

State/ 

Territory/ 

Indian County 

Number of Active 

USTs 

Number of Model UST 

Sites 

Number of Model Spill 

Buckets 

Number of Model 

Turbine Sumps 

MS 8,782 3,314 8,782 8,782 MT 3,290 1,242 3,290 3,290 NC 28,705 10,832 28,705 28,705 ND 2,163 816 2,163 2,163 NE 6,903 2,605 6,903 6,903 NH 3,063 1,156 3,063 3,063 NJ 16,830 6,351 16,830 16,830 NM 4,027 1,520 4,027 4,027 NV 3,669 1,385 3,669 3,669 NY 28,897 10,905 28,897 28,897 OH 22,998 8,678 22,998 22,998 OK 11,102 4,189 11,102 11,102 OR 6,112 2,306 6,112 6,112 PA 24,677 9,312 24,677 24,677 PR 4,560 1,721 4,560 4,560 RI 1,627 614 1,627 1,627 SC 11,981 4,521 11,981 11,981 SD 3,021 1,140 3,021 3,021 TN 17,105 6,455 17,105 17,105 TX 54,946 20,734 54,946 54,946 UT 4,024 1,518 4,024 4,024 VA 20,600 7,774 20,600 20,600 VI 144 54 144 144 VT 3,067 1,157 3,067 3,067 WA 10,112 3,816 10,112 10,112 WI 13,725 5,179 13,725 13,725 WV 5,696 2,149 5,696 5,696 WY 1,980 747 1,980 1,980 Indian Country 

2,665 1,006 2,665 2,665 
16

Table 1. Universe of Potentially Affected Active USTs, UST Sites, Spill Buckets, Tank Sumps, and Dispenser 

State/ 

Territory/ 

Indian County 

Number of Active 

USTs 

Number of Model UST 

Sites 

Number of Model Spill 

Buckets 

Number of Model 

Turbine Sumps 

TOTAL 629,866 237,685 629,866 629,866 
17

Table 2. Current (Baseline) State Tightness Testing Regulatory Requirements 

 Spill Buckets Tank Sumps Dispens

State/ 

Territory/ 

Indian County 

Number of 

Active USTs 

Number of 

Model UST 

Sites 

Tightness 

Testing 

Req’d. 

(Y/N) 

Tightness 

Testing 

Frequency 

Tightness 

Testing 

Req’d. 

(Y/N)

Tightness 

Testing 

Frequency 

Tightness 

Testing 

Req’d. 

(Y/N)

AK 1,151 434 N N N AL45 18,885 7,126 Y Annual N N AR 9,455 3,568 N N N AS 16 6 N N N AZ 7,003 2,643 N N N CA46 37,498 14,150 Y Annual N N CNMI 68 26 N N N CO 7,949 3,000 N N N CT 10,849 4,094 N N N DC 696 263 N N N DE47 1,467 554 Y Annual Y 3 years Y FL 28,862 10,891 N N N GA 30,049 11,339 N N N GU 267 101 N N N HI 1,692 638 N N N IA 7,372 2,782 N N N ID 3,302 1,246 N N N IL 22,574 8,518 N N N IN 13,840 5,223 N N N KS 6,967 2,629 N N N 

45 Alabama Department of Environmental Management, Water Division Water Quality Program, Administrative Code, Chapter 335-6-1

Corrective Action Requirements and Financial Responsibility for Owners and Operators Of Underground Storage Tanks, http://www.alabamaadministrativecode.state.al.us/docs/adem/McWord335-6-15.pdf

46 California Fire Code, California Health and Safety Code, Chap 6.7, Section 25284.2 47 http://www.dnrec.state.de.us/dnrec2000/Divisions/AWM/ust/pdf/2008%20UST%20Regulations.pdf
18

Table 2. Current (Baseline) State Tightness Testing Regulatory Requirements 

 Spill Buckets Tank Sumps Dispens

State/ 

Territory/ 

Indian County 

Number of 

Active USTs 

Number of 

Model UST 

Sites 

Tightness 

Testing 

Req’d. 

(Y/N) 

Tightness 

Testing 

Frequency 

Tightness 

Testing 

Req’d. 

(Y/N)

Tightness 

Testing 

Frequency 

Tightness 

Testing 

Req’d. 

(Y/N)

KY 12,415 4,685 N N N LA 12,601 4,755 N N N MA48 11,021 4,159 N Y 3 years N MD49 9,243 3,487 Y Annual Y 5 years Y ME 3,199 1,207 N N N MI 20,155 7,606 N N N MN 14,532 5,484 N N N MO 10,267 3,874 N N N MS 8,782 3,314 N N N MT 3,290 1,242 N N N NC 28,705 10,832 N N N ND 2,163 816 N N N NE 6,903 2,605 N N N NH 3,063 1,156 N N N NJ 16,830 6,351 N N N NM 4,027 1,520 N N N NV 3,669 1,385 N N N NY 28,897 10,905 N N N OH50 22,998 8,678 Y 3 years Y 3 years Y OK 11,102 4,189 N N N 

48 Massachusetts 527 CMR: Board of Fire Prevention Regulations, http://www.mass.gov/Eeops/docs/dfs/osfm/cmr/cmr_secured/5270049 Maryland Department Of The Environment, Oil Control Program, Underground Storage Tank (UST) Systems Compliance Outline, M

http://www.dsd.state.md.us/comar/subtitle_chapters/26_Chapters.htm

50 Ohio, 1301:7-9-01 Applicability, http://www.com.state.oh.us/sfm/pub/bust_1301_7-9.pdf
19

Table 2. Current (Baseline) State Tightness Testing Regulatory Requirements 

 Spill Buckets Tank Sumps Dispens

State/ 

Territory/ 

Indian County 

Number of 

Active USTs 

Number of 

Model UST 

Sites 

Tightness 

Testing 

Req’d. 

(Y/N) 

Tightness 

Testing 

Frequency 

Tightness 

Testing 

Req’d. 

(Y/N)

Tightness 

Testing 

Frequency 

Tightness 

Testing 

Req’d. 

(Y/N)

OR 6,112 2,306 N N N PA 24,677 9,312 N N N PR 4,560 1,721 N N N RI 1,627 614 N N N SC 11,981 4,521 N N N SD 3,021 1,140 N N N TN 17,105 6,455 N N N TX 54,946 20,734 N N N UT 4,024 1,518 N N N VA 20,600 7,774 N N N VI 144 54 N N N VT 3,067 1,157 N N N WA 10,112 3,816 N N N WI 13,725 5,179 N N N WV 5,696 2,149 N N N WY 1,980 747 N N N Indian Country 

2,665 1,006 N N N 

TOTAL 629,866 237,685 
20

ATTACHMENT A 

Soil Sampling as a Leak Detection Method 

Another “leak detection” method involves collecting and analyzing a soil sample for the 

regulated substance near the bucket/sump/pan to determine if a release has impacted the 

subsurface. This cost estimate represents an activity that is only conducted at sites where the 

UST sumps, spill buckets, or dispenser pans fail their tightness testing. This trigger may be 

further refined to say that soil sampling is only conducted at sites failing their tightness testing 

because of containment failure. Our full failure percentage estimates are used in developing the 

cost estimates presented in this memorandum. We assumed it will cost approximately $500 to 

collect a soil sample. In addition we assumed a laboratory analysis cost of $60 per sample for 

detection of petroleum products.51

Total Estimated Soil Sampling Incremental Annual Costs 

(million dollars, 2008) 

Tightness Testing 

(annual) 

Tightness Testing 

(every 3 years) 

- Soil Sampling by 

 Spill Buckets 

 Turbine Sumps 

 Dispenser Pans 

 Total 

$54 

$83 

$142

$279 

$21 

$29 

$49

$99 

 

51 DPRA best professional judgment. 
 DRAFT – DO NOT CITE OR QUOTE 

APPENDIX C 

Assessment of Baseline and Cost Impacts Associated with De-Regulatory Options 
 DRAFT – DO NOT CITE OR QUOTE 

2 

Preliminary Assessment of Baseline and Cost Impacts Associated with Deregulatory 

Options

Under Resource Conservation and Recovery Act (RCRA) Subtitle I, EPA promulgated technical 

and financial requirements for owners and operators of underground storage tanks (USTs).1

EPA’s Office of Underground Storage Tanks (OUST) is investigating options for removing 

certain requirements; these revisions will reduce costs and are not expected to result in decreased 

protection of human health and the environment. Under Task 4 of Work Assignment 1-25, IEc 

investigated the preliminary cost savings associated with three deregulatory options, including: 

• Reducing the length of recordkeeping time for repairs for the life of the UST systems to 

three, five, or 10 year time frames; 

• Reducing the length of recordkeeping time for leak detection results to six consecutive 

months; and 

• Removing the requirement for corrosion protection associated with safe suction steel 

piping. 

This screening level assessment is based principally on the supporting statement for the EPA 

information collection request (ICR) Underground Storage Tanks: Technical and Financial 

Requirements, and State Program Approval Procedures, EPA ICR Number 1360.08. In 

addition, IEc examined summarized state regulatory information available in the Underground 

Storage Tank Guide published by Thomson Publishing Company, previous contractor reports 

produced by E2 Environmental, Inc., and conducted phone discussions with UST system 

installers. 

We discuss each of the deregulatory options below. For the recordkeeping requirements, we 

include brief descriptions of the deregulatory options, methodologies, results, and limitations for 

each analysis. For corrosion protection for safe suction steel piping, we provide a brief 

discussion of our finding that cost savings from deregulation are unlikely to be significant. 

Reducing Recordkeeping Time for Repairs 

Section 280.33(f) requires owners and operators to maintain records of each repair for the 

operating life of the UST system. These records must demonstrate that repairs will prevent 

releases due to structural failure or corrosion as long as the UST system is used to store regulated 

substances.2

 Under the investigated deregulatory options, we estimate the cost savings 

associated with reducing recordkeeping time for repairs from the lifetime of the UST system to 

three, five, or 10-year time frames. 

 

1

 40 CFR Part 280. 

2

Underground Storage Tanks: Technical and Financial Requirements, and State Program Approval Procedures, 

EPA ICR Number 1360.08 
 DRAFT – DO NOT CITE OR QUOTE 

3 

Methods, Assumptions, and Data Sources 

ICR 1360.08 provides cost burden information on the maintenance of records associated with 

UST system repairs. The ICR estimates a cost burden of $3.86 per repair for the life of the UST 

system; of which $3.76 is attributed to labor costs, and $0.10 is attributed to operation and 

maintenance. In addition, EPA estimates that three percent of USTs (out of 629,167) will be 

repaired each year, totaling 18,875 repairs, and one repair per facility. Exhibit 1 summaries that 

key assumptions and data sources used to estimate the cost savings associated with reducing 

recordkeeping time for UST repairs.3

Exhibit 1 

Key Assumptions and Data Sources Used to Estimate Cost Savings Associated with Reduced 

Recordkeeping Time for UST Repairs.

Assumption Data Source 

Recordkeeping costs per repair $3.86 ICR 1360.08 

Number of UST repairs per year 18,875 ICR 1360.08 

Useful life of UST system (years) 20 ICR 1360.08 

Discount rate 7% Office Management and Budget 

Circular A-94 (in ICR 1360.80) 

Total repair recordkeeping costs per year a $72,858 ICR 1360.08 

Notes: 

a Value does not match ICR due to rounding. 

The ICR does not clarify how it treats the yearly costs associated with recordkeeping for UST 

repairs. It is unclear whether the cost per repair ($3.86) is incurred during the first year or over 

the lifetime of the UST system (20 years). Because the ICR identifies only 18,875 annual repairs 

requiring record maintenance, and does not explicitly estimate the cost of maintaining records 

from previous years’ repairs for other facilities, we assume that the estimated cost represents the 

entire cost to maintain repair records for the lifetime of the UST system each time a repair is 

necessary. In addition, to simplify the analysis for this preliminary estimate, we assume that all 

repairs occur in the first year of installation.4

 

In order to estimate cost savings associated with reducing recordkeeping time, we establish the 

baseline costs of the current rule. Since recordkeeping regulations for repairs require facilities to 

maintain records for the life of the UST system, operators incur costs in the years that follow 

repairs at discounted rates. Based on the assumptions stated above, we first annuitize the cost 

per repair ($3.86) over the lifetime of an UST system, resulting in payments of approximately 

 

3

 All costs reported in 2007 dollars. 

4

 Note that we do not include the potential cost of reading the regulations in these preliminary estimates. 
 DRAFT – DO NOT CITE OR QUOTE 

4 

$0.34 per year for 20 years.5 We then discount these payments out for 20 years at the OMB 

approved 7 percent discount rate.6

 

To reflect that costs continue for the life of the UST system, we estimate the number of 

“recordkeeping events” in a given year to be the product of years away from retirement of the 

UST systems multiplied times the number of repairs in a given year. For example, in year-one, 

we assume that operators will pay for recordkeeping on all repairs that occurred in the last 20 

years, resulting in 337,500 recordkeeping events (18,875 x 20). In year-two, we assume that 

only those repairs occurring in the last 19 years will result in recordkeeping events, as one cohort 

of repaired systems (i.e., the 20-year old UST systems) is retired. 

We then multiply the number of recordkeeping events times previously estimated discounted 

payments. We then sum the yearly values to arrive a total present value of $924,102. Finally, 

we annualize this sum over 20-year period at a discount rate of 7 percent, which results in 

annualized total cost of $87,229 per year. Exhibit 2 presents the calculations employed to 

estimate the baseline. 

 

5

 Note that we calculate the annuity payments using MS Excel’s PMT function, which calculates the annuity 

payment based on constant payments and a constant interest rate. 6

 For example, we estimate the present value cost in year-one to be approximately $0.34, present value cost in yeartwo to be approximately $0.32, and the present value cost in year three to be approximately $0.30. The sum of the 

present values calculations for each year total $3.86. 
 DRAFT – DO NOT CITE OR QUOTE 

5 

To estimate the three deregulatory options present by EPA, we use the same procedure as above, 

and modify years examined and number of recordkeeping events to reflect each scenario. Under 

the three-year scenario, operators must maintain records for repairs occurring within the last 

three years. Therefore, using the three-year scenario, we estimate the number of recordkeeping 

events in year-one to be the number of annual repairs multiplied by three (56,625); in year-two 

the number of recordkeeping events totals 37,350 (2 x 18,875); and in year-three, the number of 

recordkeeping events equals 18,875. Once again, for each year, we multiply the number of 

recordkeeping events by the discounted cost payment in that year. We then sum the yearly 

values to arrive a total present value of $36,910. Finally, we annualize this sum over 20-year 

period at a discount rate of 7 percent, which results in annualized total cost of $3,484 per year. 

Attachment A presents the calculations employed to estimate the three-year, five-year, and 10-

year scenarios. 

Results 

In order to calculate the cost savings associated with each deregulatory option, we subtract the 

estimated costs of each scenario from the baseline costs. Exhibit 3 presents these results as total 

Exhibit 2 

Calculations Used to Estimate Costs of Current Recordkeeping Requirements for UST System 

Repairs (Baseline) 

Year

Year from 

End-of-Life of 

UST System 

Annuitized 

Payments 

Per UST 

Discounted 

Payments (7%) 

Per UST 

Number of 

Recordkeeping 

Events Per Year 

Costs Per 

Year 

Calculation A B C = (A x 18,875) D = (B x C) 

1 20 $0.34 $0.34 377,500 $128,546 

2 19 $0.34 $0.32 358,625 $114,130 

3 18 $0.34 $0.30 339,750 $101,050 

4 17 $0.34 $0.28 320,875 $89,192 

5 16 $0.34 $0.26 302,000 $78,454 

6 15 $0.34 $0.24 283,125 $68,739 

7 14 $0.34 $0.23 264,250 $59,959 

8 13 $0.34 $0.21 245,375 $52,034 

9 12 $0.34 $0.20 226,500 $44,889 

10 11 $0.34 $0.19 207,625 $38,456 

11 10 $0.34 $0.17 188,750 $32,673 

12 9 $0.34 $0.16 169,875 $27,482 

13 8 $0.34 $0.15 151,000 $22,830 

14 7 $0.34 $0.14 132,125 $18,670 

15 6 $0.34 $0.13 113,250 $14,956 

16 5 $0.34 $0.12 94,375 $11,648 

17 4 $0.34 $0.12 75,500 $8,709 

18 3 $0.34 $0.11 56,625 $6,104 

19 2 $0.34 $0.10 37,750 $3,803 

20 1 $0.34 $0.09 18,875 $1,777 

Total Present Value Costs 3.86 3.86 $924,102

Total Annualized Costs $87,228
 DRAFT – DO NOT CITE OR QUOTE 

6 

costs over a 20-year period, annualized costs, and annualized costs per facility (assuming 18,875 

facilities) for each of the deregulatory scenarios. Under the three-year scenario, we estimate the 

total cost savings over 20 years to be nearly $887,200, the annualized cost savings to be 

approximately $83,700, and the annualized cost savings per facility at $4.43. Under the fiveyear scenario, we estimate the total cost savings over 20 years to be approximately $835,700, the 

annualized cost savings to be nearly $78,900, and the annualized cost savings per facility at 

$4.17. Under the 10-year scenario, we estimate the total cost savings over 20 years to be nearly 

$631,700, the annualized cost savings to be approximately $59,600, and the annualized cost 

savings per facility at approximately $3.15. 

Exhibit 3 

Estimated Cost Savings Associated with Reduced Recordkeeping Requirements for Repairs 

Total (20 Years) Annualized 

Annualized Per Facility 

(18,875 Facilities) 

3-Year Option 

Baseline Costs $924,102 $87,229 $4.62

Costs under deregulation $36,910 $3,484 $0.18

Cost Savings $887,193 $83,745 $4.43

5-Year Option 

Baseline Costs $924,102 $87,229 $4.62

Costs under deregulation $88,402 $8,345 $0.44

Cost Savings $835,700 $78,884 $4.17

10-Year Option 

Baseline Costs $924,102 $87,229 $4.62

Costs under deregulation $292,422 $27,603 $1.46

Cost Savings $631,680 $59,626 $3.15
 DRAFT – DO NOT CITE OR QUOTE 

7 

Limitations 

This analysis of cost savings associated with reducing the recordkeeping time for UST system 

repairs is preliminary and is subject to several limitations, including: 

• Because the ICR does not explicitly estimate the cost of maintaining records for previous 

year repairs, we assume that the estimated cost represents the entire cost to maintain 

records for the lifetime of the UST system. If the ICR intended for the cost estimate to 

represent a yearly recordkeeping cost, this analysis has underestimated the costs 

associated with recordkeeping and likely underestimates the cost savings associated with 

each deregulatory scenario. 

• This analysis assumes that repairs occur in the first year of installation, when in fact 

repairs may occur throughout the lifetime of an UST system. As result, this analysis 

may overestimate costs associated with the baseline and deregulatory scenarios. Since 

the yearly cost depends on timing of the repair within the lifetime of the UST system, it 

is unclear how fluctuations in the timing of repairs would affect cost savings. 

• As in the ICR, this analysis assumes a constant number of yearly repairs. In practice, the 

number of repairs likely fluctuates over time. Also, as the systems replaced in the late 

1990s age, it is possible that the number of repairs will increase in the future. An 

increase in the number of repairs would result in higher cost savings associated with the 

deregulatory options. However, if improvements in technology have resulted in 

reductions in the number of annual repairs, this analysis would overestimate costs and 

cost saving attributed to the deregulatory options. 

Reducing Recordkeeping Time for Leak Detection Results 

Section 280.45 requires that owners and operators maintain records that contain information 

about each release detection system in place at an UST system. Operators are required to 

maintain records regarding leak detection, including: 7

• All performance claims about any leak detection system used must be kept for five years 

from the date of installation; 

• Sampling, testing, or monitoring results must be kept for one year (except for tank 

tightness testing results, which must be kept until the next test is conducted); 

• Documentation of all calibrations, maintenance, and repairs must be kept for one year 

after servicing was completed; and 

• Manufacturer calibration and maintenance schedules must be kept for five years from the 

date of installation. 

 

7 Underground Storage Tanks: Technical and Financial Requirements, and State Program Approval Procedures, 

EPA ICR Number 1360.08 
 DRAFT – DO NOT CITE OR QUOTE 

8 

Under EPA’s potential deregulatory option, we estimate the cost savings associated with 

reducing recordkeeping time for leak detection results from one year to six consecutive months. 

Methods, Assumptions, and Data Sources 

ICR1360.08 provides cost burden information on the maintenance of records for release 

detection. The ICR estimates that each facility incurs costs of $37.61 per year to maintain 

records related to release detection.8 Since the ICR consolidates the cost burden across the 

various recordkeeping requirements noted above, teasing out the specific costs associated with 

maintenance of testing results is difficult. Therefore, it is unclear how the costs differ between 

the various recordkeeping requirements. However, since most facilities have installed some 

form of leak detection equipment prior to the last five years (e.g., Section 280.40 requires that all 

tanks by December 1993 install leak detection), it is likely that relatively few facilities will be 

required to maintain records associated with performance claims and maintenance schedules 

within five years of installing leak detection. In the ICR, EPA estimates the installation of 8,500 

new USTs per year; this represents just 1.3 percent of the total UST universe (an average of 

620,667 USTs over the period covered by the ICR). As a result, this screening-level analysis 

assumes that all recordkeeping costs occur from leak detection testing, which are currently 

required to be kept for a one-year period. Exhibit 4 presents the key assumptions and data 

sources used to estimate the cost savings associated with reducing recordkeeping time for leak 

detection results.9

Exhibit 4 

Key Assumptions and Data Sources Used to Estimate Cost Savings Associated with Reduced Recordkeeping 

Time for Leak Detection. 

Assumption Data Source 

Number of facilities required to maintain leak detection records 237,533 ICR 1360.08

Leak detection recordkeeping cost per facility $37.61 ICR 1360.08 

Total leak detection recordkeeping costs per yeara $8,933,616 ICR 1360.08 

Total Leak detection cost per month $744,468 Estimated 

Notes: 

a Value does not match ICR due to rounding. 

 

Results 

Exhibit 5 presents the baseline costs, deregulatory option costs, and potential cost savings 

associated with reduced recordkeeping time for leak detection results, in aggregate and per 

facility. We estimate total cost savings for this deregulatory option to be approximately $4.5 

million dollars per year and approximately $19 per facility. 

 

8

 As in the previous analysis, the ICR does not explicitly provide estimate across multiple years of operation. As a 

result, we assume that the estimated cost represents the entire cost to maintain records entire period of time required 

in the regulations, which may vary from one to five years depending on the action. 

9 Note that we do not include the potential cost of reading the regulations in these preliminary estimates.
 DRAFT – DO NOT CITE OR QUOTE 

9 

Exhibit 5 

Estimated Cost Savings Associated with Reduced Recordkeeping Requirements for Leak Detection

Recordkeeping 

Time (months) 

Recordkeeping 

Cost Per Month 

Annualized 

Total Cost 

Annualized Cost Per 

Facility (237,533 

Facilities) 

Baseline 12 $744,468 $8,933,616 $37.61 

Deregulatory Scenario 6 $744,468 $4,466,808 $18.81 

Cost Savings $4,466,808 $18.81 

Limitations 

The major limitation of this analysis is that we were not able to separate out the costs of various 

leak detection recordkeeping requirements from the information available in ICR 1360.08. 

Because we assume all recordkeeping costs are associated with leak detection results (as some 

portion of these costs are related to other recordkeeping requirements), we may overestimate 

costs and cost savings associated with this deregulatory option. 

Removing Corrosion Protection Requirements for Safe Suction Steel Piping 

UST piping conveys product through either a pressured system or through suction.10 Section 

280.2 requires that, with a few exceptions, all steel UST piping have a corrosion-resistant coating 

and cathodic protection. EPA is investigating the cost savings associated with removing 

corrosion protection requirements for steel piping that use “safe” suction methods.11 

To investigate the costs associated with installing or repairing corrosion protection on safe 

suction steel piping, IEc referenced ICR 1360.08, Thomson Publishing Company’s Underground 

Storage Tank Guide, OUST research conducted by E2 Environmental in 2006, along with 

additional outside resources. In addition, IEc conducted phone conversations with several UST 

installers from around the country to assess the extent to which safe suction steel piping is in 

service. 

Evidence suggests that establishing a baseline for the quantity of safe suction steel piping still in 

operation is difficult and the removal of corrosion protection for these pipes is not likely to result 

in significant cost savings for operators. This evidence includes: 

• A lack of reliable estimates of the quantity of safe suction steel piping: ICR 1360.08 

does not attempt to quantify the number safe suction steel pipes existence; however EPA 

does estimate that 90 percent of all piping is pressurized, leaving the remaining 10 

percent as suction-based systems. With available resources, we were unable to locate a 

reliable estimate that indicates what percentage of this 10 percent qualifies as “safe” 

 

10 40 CFR Part 280.41(b) 

11 Safe suction piping, also known as European piping, is designed with a slope so that pipe contents will drain back 

into the tank, if the suction is released. Alaska Department of Environmental Conservation. Underground Storage 

Tank Inspector Reference Handbook. March 2002. 
 DRAFT – DO NOT CITE OR QUOTE 

10 

suction.12 Furthermore, we could not locate reliable estimates of the percentage of safe 

suction systems that employed steel piping. 

• UST equipment installers indicate that use of safe suction steel piping is rare and 

declining: Discussions with the Petroleum Equipment Institute (PEI) and member 

equipment installers suggest that most steel piping has been replaced by fiberglass or 

flexible piping. To the extent that steel pipes remain, they are most likely found in rural 

areas. The installers indicated that they rarely encounter safe suction steel piping.13 One 

installer from the Midwest remarked that he updated the corrosion protection on safe 

suction steel piping at most, twice a year. He added that he recommends that all operators 

who encounter corrosion problems with steel piping replace it with fiberglass. As the 

majority of remaining steel pipes are at small facilities with relatively short piping runs, 

the cost to upgrade to fiberglass is often competitive with restoring corrosion 

protection.14 Therefore, most operators choose to replace steel piping with non-corrosive 

materials. 

• Prevalence of secondary containment around piping: According to updated 

Underground Storage Tank Guide and recent research by E2 Environmental, at least 19 

states require some form of secondary containment around UST piping. The UST 

installers indicated that in areas where secondary containment is required, steel piping is 

virtually non-existent, as it was replaced to meet the secondary containment 

requirements. Furthermore, the installers suggest that even in states where secondary 

containment is not required, operators will typically choose to install double-walled 

piping when repairing, remodeling, or updating facilities to avoid liability (and the added 

expense of additional testing that is often required) associated with single-walled steel 

piping. 15

 

12 Regular or American suction which does not contain sloped piping, does not qualify under this deregulatory 

option. 

13 Robert Renkes. Petroleum Equipment Institute. Personal Communication. June 2008; Duanne Grippe, O'Day 

Equipment LLC. Personal Communication. July 2008; Jerry Thomas. C.E. Thomas Company. July 2008. 

14 Duanne Grippe, O'Day Equipment LLC. Personal Communication. July 2008.

15 The installers indicate that in the process of installing secondary containment around piping, operators will 

replace existing steel piping with double-walled fiberglass or flexible piping. Jerry Thomas. C.E. Thomas 

Company. July 2008.
 DRAFT – DO NOT CITE OR QUOTE 

11 

Attachment A: Calculations Used to Estimate Potential Costs of Recordkeeping 

Requirements for UST System Repairs 

Exhibit A-1 

Calculations Used to Estimate Potential Costs of Recordkeeping Requirements for UST System 

Repairs Under 3-Year Scenario 

Year

Year from 

End-of-Life of 

UST System 

Annuitized 

Payments 

Per Facility 

Discounted 

Payments (7%) 

Per Facility 

Number of 

Recordkeeping 

Events Per Year 

Costs Per 

Year 

Calculation A B C = (A x 18,875) D = (B x C) 

1 20 $0.34 $0.34 56,625 $19,282 

2 19 $0.34 $0.32 37,750 $12,014 

3 18 $0.34 $0.30 18,875 $5,614 

Total Present Value Costs $36,910

Total Annualized Costs $3,484

Exhibit A-2 

Calculations Used to Estimate Potential Costs of Recordkeeping Requirements for UST System 

Repairs Under 5-Year Scenario 

Year

Year from 

End-of-Life of 

UST System 

Annuitized 

Payments 

Per Facility 

Discounted 

Payments (7%) 

Per Facility 

Number of 

Recordkeeping 

Events Per Year 

Costs Per 

Year 

Calculation A B C = (A x 18,875) D = (B x C) 

1 20 $0.34 $0.34 94,375 $32,137 

2 19 $0.34 $0.32 75,500 $24,027 

3 18 $0.34 $0.30 56,625 $16,842 

4 17 $0.34 $0.28 37,750 $10,493 

5 16 $0.34 $0.26 18,875 $4,903 

Total Present Value Costs $88,402

Total Annualized Costs $8,345
 DRAFT – DO NOT CITE OR QUOTE 

12 

Exhibit A-3 

Calculations Used to Estimate Potential Costs of Recordkeeping Requirements for UST System 

Repairs Under 10-Year Scenario 

Year

Year from 

End-of-Life of 

UST System 

Annuitized 

Payments 

Discounted 

Payments (7%) 

Number of 

Recordkeeping 

Events Per Year 

Costs Per 

Year 

Calculation A B C = (A x 18,875) D = (B x C) 

1 20 $0.34 $0.34 188,750 $64,273 

2 19 $0.34 $0.32 169,875 $54,062 

3 18 $0.34 $0.30 151,000 $44,911 

4 17 $0.34 $0.28 132,125 $36,726 

5 16 $0.34 $0.26 113,250 $29,420 

6 15 $0.34 $0.24 94,375 $22,913 

7 14 $0.34 $0.23 75,500 $17,131 

8 13 $0.34 $0.21 56,625 $12,008 

9 12 $0.34 $0.20 37,750 $7,482 

10 11 $0.34 $0.19 18,875 $3,496 

Total Present Value Costs $292,422

Total Annualized Costs $27,602