This document provides an overview of underground storage tanks (USTs) and UST regulations. It discusses why UST enforcement has increased, UST system components, exemptions, leak detection requirements, corrosion protection requirements, and MKO codes related to UST compliance. The goal is to help users better understand UST systems, address client issues, and use appropriate codes.

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Understanding Underground Storage Tanks

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Understanding Underground Storage Tanks
Underground Storage Tanks

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Understanding Underground Storage Tanks
Underground Storage Tanks
After completing this training you should be able to:
•Have a better understanding of UST Systems and their components.
•Feel more comfortable addressing UST issues with your clients.
•Increase your use of the appropriate UST Codes in MKO.

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Increased UST Enforcement!
Underground Storage Tanks

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Why Increased UST Enforcement?
Underground Storage Tanks
RECENT HEADLINES

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Why Increased UST Enforcement?
Underground Storage Tanks
RECENT UST REGULATION CHANGES
August 8, 2009
States must develop UST Operator Training
Requirements and Guidelines
August 8, 2010
States must have completed inspections of All USTs
(and continue to repeat this at least every 3 years).
August 8, 2012
All UST Operators must pass UST Operator Test.

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Why Increased UST Enforcement?
Underground Storage Tanks
American Recovery and Reinvestment Act of 2009
•Allocated $200 Million to the EPA UST Program
•$190 Million Sent to State & Local UST Programs

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Underground Storage Tanks
An EPA Regulated
UST System Must:
• be 110 gallons or more
• have 10% or more of the
volume underground
• storing petroleum or
hazardous substances
• always include the tank and
piping

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Underground Storage Tanks
Tanks that are exempt from EPA UST Regulations:
• Tanks on or above the floor of underground areas
(Dealership Quick Lube Pits)
•Tanks storing heating oil used on the premises
(some states differ on this)
•Tanks less than 110 gallons
•Other exemptions do exist

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UST – LEAKING USTs
LEAKING UST

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UST – LEAKING USTs
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UST – Regulations

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UST – Regulations
RCRA Subtitles 40 CFR 260-270
A - General Provisions
B - Solid Waste
C - Hazardous Waste
D - State or Regional Plans
E - Commerce Responsibilities
F - Federal Responsibilities
G - Miscellaneous Provisions
H - Research, development, info
I - Underground Storage Tanks

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UST – Regulations
RCRA Subtitle I –Underground Storage Tanks
Regulations Published in 1988
Compliance Date set for December 22, 1998

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UST – Regulations
States with Approved UST Programs
(in green)

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UST – Regulations
Why are USTs so
complicated?

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UST – Regulations
1. The applicable regulations vary depending
upon what kind of equipment the client has.

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UST – Regulations
Types of Underground Storage Tanks
•Protected Steel
Steel tank coated at the factory and built with sacrificial (galvanic) anodes.
•Steel with Impressed Current
Steel tanks that have been retrofitted with an impressed current system.
•Fiberglass-Reinforced Plastic
Commonly referred to as fiberglass tanks.
•Polyethylene-Jacketed Steel Tank
Double-wall tank with a steel inner wall and a plastic outer wall.
•Fiberglass-Jacketed Steel Tank
Double-wall steel tank with a fiberglass reinforced plastic outer wall.
•Clad Steel Tank
Steel tank that has a thick layer of non-corrodible material that is
mechanically bonded (clad) to the outer wall of the steel tank.
•Protected Steel Fiberglass Lined
Cathodically protected steel tank lined with fiberglass.

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UST – Regulations
2. Your client’s often don’t know what kind
of UST equipment they have.

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UST – Regulations
3. You can’t see what kind of UST
equipment they have.

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UST – Regulations
1. The regulations vary depending
upon what kind of equipment the
client has.
2. Your client’s often don’t know
what they have.
3. You can’t see what they have.

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UST – MKO Codes

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UST – MKO Codes
UST00 UST Reg/Permit
•UST Registration/Permit is
not Current or Posted
•Post the UST Registration
and or permit issued by
local agency or state on site

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UST – MKO Codes
UST01 Cert Finance Resp
•Certification of Financial
Responsibility is unavailable.
•Complete the Certification of
Financial Responsibility and
file it with the appropriate
local or state agency.

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UST – MKO Codes
UST02 Spills Rptd 24 Hr
•Unreported Releases, Spills or Overfills
•Report all unauthorized releases, spills, or overfills
have been reported to the local agency hours within 24
hours.

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UST – MKO Codes
UST03 UST Repair Notification
•Agency Not Notified of UST Change
•Notify a local environmental agency
of all planned and/or completed
repairs, upgrades or changes to the
UST system. Ensure records are
available for review.

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UST – MKO Codes
UST04 UST Closure
•Records of tank closures or
change of service are not
maintained onsite (including site
investigation).
•Remove all product from the tank
•Notify local EPA
•Test for contamination
•Fill or remove the tank.

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UST – MKO Codes
UST05 Cathodic Prot Dox
•Cathodic Protection
Documentation Missing.
•Ensure documentation of
operation of cathodic protection
equipment is available on site. The
last two inspections are required
unless impressed current is used;
then the last three inspections are
required.

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UST – MKO Codes
Fe + O2 + H2O → Fe2O3
Iron + Oxygen + Water → Iron Oxide (aka Rust)

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UST – MKO Codes

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UST – MKO Codes

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UST – MKO Codes
IMPRESSED CURRENT
CATHODIC PROTECTION SYSTEM
•Electrical current run through
anodes into the ground
SACRIFICIAL/GALVANIC
CATHODIC PROTECTION SYSTEM
•SACRIFICIAL ANODES ATTACHED
TO THE TANKS PROVIDE THE
CURRENT

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UST – MKO Codes
•UST05 Cathodic Prot Dox
•Documentation of operation of
cathodic protection equipment
was not observed on site.
•Ensure documentation of
operation of cathodic protection
equipment is available on site. The
last two inspections are required
unless impressed current is used;
then the last three inspections are
required.

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UST – MKO Codes
UST05 Cathodic Prot Dox
•Documentation of operation of cathodic protection
equipment was not observed on site.
UST11 UST Corrosion Prot
•The Underground Storage Tank onsite was observed to
have inadequate corrosion protection as required by the
regulations.
UST12 Pipe Corrosion Prot
•Inadequate Underground Storage Tank pipe corrosion
protection was observed.

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UST – MKO Codes
UST06 Leak Detect Dox
•Records from
testing, sampling, monitoring, cali
bration or maintenance were not
available for the tank leak
detection method.
•All records must be retained for at
least one year and tank tightness
results must be maintained until
the next test is conducted.

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UST – MKO Codes
UST13 UST Leak Detect
•Inadequate underground storage tank leak detection was observed.
•Ensure all underground storage tanks use at least one of the following leak
detection methods:
•Inventory control,
•Manual tank gauging,
•Automatic tank gauging,
•Interstitial monitoring,
•Vapor monitoring,
•Tank tightness testing,
•Ground water monitoring

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UST – MKO Codes
UST07 - Pipe Leak Detection Dox
UST14 UST Pipe Leak Detect
•Inadequate underground storage tank pipe leak detection was
observed.
•Piping Leak detection methods very similar to the Tank methods.
Pressurized Piping:
•Automatic line leak detectors are required for pressurized piping and one other
leak detection method.
•If using line tightness test for pressurized piping, the test must be completed
annually.
Suction Piping:
•Line tightness test is used as a leak detection method for suction piping, the test
must be completed every three years.
•Does not require leak detection if there is only one check value and it is located as
close to the dispenser as possible).

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UST – MKO Codes
Pressurized Piping:
•Pumps on top of tanks use pressure to
move the product up to the dispenser
aboveground.
•Pipes are continuously filled with product.
Suction Piping:
•Pumps located aboveground inside the
dispenser pull the product up through the
piping.
•Once dispensing is completed, the pump
shuts off and all of the pressure is
released, so all of the product drains back
into the tank.

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UST – MKO Codes
UST09 Ovrfll Eqpmnt
UST10 Ovrfll Eqpmnt Calibration
•Underground Storage Tank overfill prevention
equipment was inadequate or not present.

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UST – MKO Codes
UST08 Spill Prev Equpmnt
Ensure spill prevention equipment for an
underground storage tank is present
that will prevent the release of contents
to the environment when a transfer hose
is detached from the fill pipe (i.e. spill
catchment basin).