Task Order 3003, TDD #1, Standards, revised 10/27/08 1

Task Order 3003, Subtask 3003-03c – Updating Standards and Standard-Making 

Groups

TDD #1, Standards

Summary of UST Technical Standards and Standard-Making Groups

This report summarizes the methodology and findings of the review of technical 

standards and standard-making organizations in the 1988 Federal Underground Storage 

Tank (UST) regulations. The complete results of the review are presented in the 

spreadsheet that accompanies this summary, “TO 3003, TDD #1, Standards Review 

Spreadsheet, 10-16-08.xls.” The spreadsheet has four worksheets:

 “40 CFR Part 280 Organizations,” which lists the organizations in the 1988 

Federal UST Regulations, whether these organizations are still in existence, their 

total membership body, and Web site addresses for these organizations.

 “Potential Organizations,” which lists standard-making organizations that OUST 

may consider including in updated regulations, their total membership body, Web 

site addresses, and the source of each potential organization (e.g., “standards 

drawer,” state UST regulations, or Internet search).

 “40 CFR Part 280 Standards,” which lists the technical standards in the 1988 

Federal UST Regulations, the organization that publishes each standard, the 1988 

and current names and codes for these standards, if and when the standards were 

revised most recently, and the source for information on the standards.

 “Potential Standards,” which lists the names and codes of technical standards that 

OUST may consider including in updated regulations, the organization that 

publishes each standard, the latest edition, and the source of each potential 

standard (e.g., “standards drawer,” state UST regulations, or Internet search).

Methodology

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Inc. reviewed the 40 CFR Part 280 UST regulations and identified all industry

standards and associated standard-making organizations. E

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Inc. then located the

organizations’ Web sites to confirm their existence, determine their total membership 

body, and identify any updates to standards included in 40 CFR Part 280. E

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Inc. 

requested this information directly from three organizations that do not list this 

information on their Web sites: the National Leak Prevention Association (NLPA), the 

Steel Tank Institute (STI), and Underwriter’s Laboratories of Canada (ULC). 

To locate additional standards and standard-making organizations not included in 40 CFR 

Part 280, E

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Inc. reviewed the “standards drawer” document provided by OUST, 

searched UST program regulatory documents from all 50 states and the District of 

Columbia, and conducted general Internet searches. All UST standards identified in the 
Task Order 3003, TDD #1, Standards, revised 10/27/08 2

“standards drawer” document and state regulatory documents were located on the 

standard-making organizations’ Web sites to determine the most current revisions. 

Unless a standard’s title indicated that it was not relevant to USTs (e.g., it was clearly 

related to aboveground storage tanks), all standards from the “standards drawer” and state 

UST regulations were included in the deliverables. 

Summary of Findings

Determine whether each listed standard-making organization is still in existence and if

so and possible, determine the total membership body of the organizations.

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Inc. identified 13 standard-making organizations listed in 40 CFR Part 280, 12 of 

which are still in existence. One organization, the Association for Composite Tanks 

(ACT), is now defunct. Two organizations still in existence have changed their official 

names: the American Society of Testing and Materials (ASTM) is now ASTM 

International and the National Association of Corrosion Engineers (NACE) is now 

NACE International. Four of the 12 existing organizations do not have membership 

bodies. The spreadsheet that accompanies this summary reports the total membership 

body for the remaining eight organizations as described on each organization’s Web site

or as described through direct communication with the organization. 

Determine whether other applicable standard-making organizations exist, and if so and

possible, the total membership body of the organizations.

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Inc. identified 14 standard-making organizations not included in 40 CFR Part 280

through review of the “standards drawer” document, state UST regulatory documents, 

and general Internet searches. Of these 14 groups, nine were present in the “standards 

drawer” document, four were included in state UST regulations (Florida and Alaska), and 

one was found through additional Internet searches. One organization included in the 

“standards drawer” document, the Petroleum Association for Conservation of the 

Canadian Environment (PACE), no longer exists. Four of the 14 existing organizations 

do not have membership bodies. The spreadsheet that accompanies this summary reports 

the total membership body for the remaining 10 organizations as described on each 

organization’s Web site.

Determine whether industry standards have been updated and, if so, identify the latest

revision.

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Inc. identified 33 industry standards in 40 CFR Part 280. Nearly all of these standards 

have been revised or reaffirmed and have undergone name and/or code changes. Notable 

changes include: 

 Standard ACT-100 “Specification for the Fabrication of FRP Clad Underground 

Storage Tanks” is now published by the Steel Tank Institute as STI-ACT 100-U 

F961, “Specification for External Corrosion Protection of Steel Underground 

Storage Tanks.”
Task Order 3003, TDD #1, Standards, revised 10/27/08 3

 

 ASTM D4021 “Standard Specification for Glass- Fiber-Reinforced Polyester 

Underground Petroleum Storage Tanks” was withdrawn in 1999 with no 

replacement. 

 NLPA Standard 631 now includes four Chapters:

 A - “Entry, Cleaning, Interior Inspection, Repair, and Lining of Underground

Storage Tanks”

 B - “Future Internal Inspection Requirements for Lined Tanks”

 C - “Internal Inspection of Steel Tanks for Retrofit of Cathodic Protection”

 D - “Lining of Fiberglass Tanks For Compatibility & Repairs That Are

Allowed”

 American Petroleum Institute (API) RP1626, “Storing and Handling Ethanol and 

Gasoline-Ethanol Blends at Distribution Terminals and Service Stations” is listed 

as out-of-print on the “standards drawer” document, but is currently available 

from the API Web site. 

Identify other codes or standards not listed that may be used to meet regulatory

requirements.

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Inc. identified 173 potential standards not included in 40 CFR Part 280 through review 

of the “standards drawer” document, state UST regulatory documents, and general 

Internet searches. Of these 173 standards, 128 were present in the “standards drawer” 

document, 35 were found in state regulations, and 10 were found during additional 

Internet searches. Notable findings include:

 Six states include National Fire Protection Association (NFPA) 329, “Handling 

Releases of Flammable and Combustible Liquids and Gases” in their UST 

regulations. NFPA 329 is listed in the “standards drawer” document.

 Fourteen states include NFPA 30A, “Code for Motor Fuel Dispensing Facilities 

and Repair Garages” in their UST regulations. NFPA 30A is listed in the

“standards drawer” document. 

 Seven states include NACE TM0497, “Measurement Techniques Related to 

Criteria for Cathodic Protection on Underground or Submerged Metallic Tank 

Systems” in their UST regulations. NACE TM0497 is listed in the “standards 

drawer” document. 

 Seven states include API RP 1637, “Using the API Color-Symbol System to Mark 

Equipment and Vehicles for Product Identification at Service Stations and 

Distribution Terminals” in their UST regulations. API RP 1637 is listed in the 

“standards drawer” document. 
Task Order 3003, TDD #1, Standards, revised 10/27/08 4

 Six states include STI R892, “Recommended Practice for Corrosion Protection of 

Underground Piping Networks Associated with Liquid Storage and Dispensing 

Systems” in their UST regulations. STI R892 is listed in the “standards drawer” 

document. 

 Fifty-four standards listed in the “standards drawer” document (including the five 

listed above) are included in at least one state’s UST regulations. 

 Four Military standards listed in the “standards drawer” document are included in 

the “Potential Standards” worksheet but do not have associated organizations 

listed in the “Potential Organizations” worksheet.