Underground tanks

UST release detection: methods, schedules, and records

Every underground storage tank needs release detection that covers the tank and any underground piping that routinely holds product. Most tanks are monitored at least every 30 days, and pressurized piping also needs an automatic line leak detector. Since October 13, 2018, the equipment has to be tested for proper operation at least once a year (40 CFR 280.40; 280.41).

On this page
  1. Tanks: what's required depends on when it was installed
  2. The release detection methods
  3. Piping
  4. The yearly equipment test
  5. When release detection alarms
  6. Records to keep
  7. FAQ
  8. Sources

Whatever method you use has to be installed and calibrated to the manufacturer's instructions and meet the performance standards in the rule (40 CFR 280.40(a)). A system that can't use any method that complies has to be closed (40 CFR 280.40(c)).

Tanks: what's required depends on when it was installed

Tank installedRequirement
On or before April 11, 2016Monitor at least every 30 days with one of the monthly methods: automatic tank gauging, vapor monitoring, groundwater monitoring, interstitial monitoring, statistical inventory reconciliation, or another approved method. Limited exceptions for tank tightness testing and manual tank gauging, below
After April 11, 2016Interstitial monitoring at least every 30 days. New tanks have to be secondarily contained, such as double-walled

Sources: 40 CFR 280.41(a), 280.42.

The release detection methods

MethodHow it worksPerformance standard and limits
Automatic tank gauging (ATG)A probe in the tank measures product level and runs a leak testDetects 0.2 gallon per hour; tests at least every 30 days, static or continuous; must also meet inventory control
Interstitial monitoringChecks the space between the tank and its secondary barrier, such as between the walls of a double-walled tankMust detect a leak through the inner wall from any part of the tank that holds product. Required for tanks installed after April 11, 2016
Statistical inventory reconciliation (SIR)Statistical analysis of your daily inventory recordsReports a calculated leak rate; detects 0.2 gallon per hour or 150 gallons within 30 days
Vapor monitoringWells in the backfill detect fuel vaporsNeeds porous backfill and a product volatile enough to detect, such as gasoline, or a tracer added to the tank
Groundwater monitoringWells detect product floating on groundwaterGroundwater can never be more than 20 feet below the surface, and the soil has to be permeable
Tank tightness testing plus inventory controlA tightness test that detects 0.1 gallon per hour, plus monthly inventory controlAllowed only for older tanks that meet the equipment standards, every 5 years, until 10 years after installation
Manual tank gaugingStick readings at the start and end of a period with no fuel added or removedSmall tanks only; see the table below. Not allowed over 2,000 gallons

Field note: The sites I service use both automatic tank gauges and interstitial monitoring.

Source: 40 CFR 280.43 and 280.41. Inventory control on its own has to catch a loss of 1.0% of flow-through plus 130 gallons a month, with daily records and a monthly water check to the nearest 1/8 inch.

Manual tank gauging limits

Tank sizeTest lengthWeekly limit (one test)Monthly limit (4-test average)
550 gallons or less36 hours10 gallons5 gallons
551–1,000 gallons, 64-inch diameter44 hours9 gallons4 gallons
551–1,000 gallons, 48-inch diameter58 hours12 gallons6 gallons
551–1,000 gallons, other (plus tightness testing)36 hours13 gallons7 gallons
1,001–2,000 gallons (plus tightness testing)36 hours26 gallons13 gallons

Source: 40 CFR 280.43(b). Each reading is the average of two consecutive stick readings, measured to the nearest 1/8 inch. Manual gauging can be the only method for tanks of 550 gallons or less and for 551–1,000 gallon tanks that meet the diameter criteria.

Piping

PipingInstalled on or before April 11, 2016Installed or replaced after April 11, 2016
PressurizedAutomatic line leak detector, plus an annual line tightness test or monthly monitoringInterstitial monitoring every 30 days, plus an automatic line leak detector
SuctionLine tightness test every 3 years, or monthly monitoringInterstitial monitoring every 30 days

Source: 40 CFR 280.41(b).

  • Line leak detectors have to catch a 3 gallon per hour leak at 10 psi within an hour, and line tightness tests have to detect 0.1 gallon per hour at 1.5 times operating pressure (40 CFR 280.44). See line leak detectors.
  • "Safe suction" piping needs no release detection if all of these are true: it runs below atmospheric pressure, slopes back to the tank so it drains if suction is lost, has only one check valve per line, located directly below and as close as practical to the pump, and there's a way to verify all of that (40 CFR 280.41(b)).

The yearly equipment test

Electronic and mechanical release detection components have to be tested for proper operation at least once a year, following the manufacturer's instructions, a code of practice such as PEI RP1200, or your state's requirements (40 CFR 280.40(a)(3)). As applicable, the test covers:

  • Automatic tank gauge and other controllers: test the alarm, verify the system configuration, and test the battery backup
  • Probes and sensors: inspect for buildup, make sure floats move freely, check that the shaft isn't damaged and cables are free of kinks and breaks, and test alarms and communication with the controller
  • Automatic line leak detectors: simulate a leak to show it meets the 3 gallon per hour standard
  • Vacuum pumps and pressure gauges: make sure they communicate with sensors and the controller
  • Hand-held electronic sampling equipment for groundwater and vapor monitoring: make sure it works

Field note: On yearly tests I find failures in every one of these: sensors, floats, backup batteries, and line leak detectors.

Between yearly tests, the 30-day walkthrough checks that release detection is running with no alarms and that records are current. See the walkthrough checklist.

When release detection alarms

Report a suspected release to your state within 24 hours, unless your state sets another period (40 CFR 280.50). That includes monitoring results or an alarm that indicate a release may have occurred. You don't have to report if you find the monitoring device was defective, fix or replace it right away, and further monitoring doesn't confirm the first result (40 CFR 280.50(c)).

Unusual operating conditions also count, such as erratic dispensing, a sudden loss of product, unexplained water in the tank, or liquid between the walls of a double-walled system, unless you find the equipment isn't releasing and fix it immediately (40 CFR 280.50(b)).

Field note: I do see alarms get silenced instead of investigated. Silencing an alarm doesn't clear it; find out what triggered it.

Records to keep

RecordKeep for
Monitoring, sampling, and test resultsAt least 1 year
Yearly operation test results: each component, pass or action needed, and what was done3 years
Tank tightness test resultsUntil the next test
Calibration, maintenance, and repair of on-site release detection equipmentAt least 1 year after the work
Manufacturer performance claims and calibration and maintenance schedules5 years from installation

Source: 40 CFR 280.45. Your state can set different periods.

FAQ

Is an automatic tank gauge enough by itself?

It can be, for the tank. The gauge has to detect a 0.2 gallon per hour leak at least every 30 days, and you also have to meet the monthly inventory control requirements (40 CFR 280.43(d)). Tanks installed after April 11, 2016 have to use interstitial monitoring instead (40 CFR 280.41). Piping needs its own release detection.

What counts as a suspected release?

Spilled product at the site, unusual operating conditions like erratic dispensing, a sudden loss of product, unexplained water in the tank, or liquid between the walls, and monitoring results or alarms that indicate a release (40 CFR 280.50). Report within 24 hours unless your state sets another period, or unless you find a defective part and fix it right away.

Do farm tanks need release detection?

Not if they're 1,100 gallons or less and hold motor fuel for noncommercial use; those aren't USTs under the federal rule (40 CFR 280.12). Your state may still regulate them.

Sources

This guide is general information. Your state UST program decides what's required at your site.