An underground storage tank system (UST) and all its connected piping commonly contain petroleum or hazardous and regulated substances. During the 1980s, most USTs were corrosion-prone steel structures with very basic tank lining, raising concerns over the potential for leaks that could cause harmful substances to seep into the underground soil and contaminate sources of groundwater. Coupled with improper installation and lack of operating and maintenance procedures, the USTs posed a potential threat to people’s health and the environment.
Because of the concerns over possible UST leaks, the government instituted several regulations through the years, and in partnership with the Environmental Protection Agency (EPA), concerning the setup and management of USTs, as well as operators’ responsibilities in leak prevention, detection and cleanup, and the best methods to use in construction, tank lining, among others.
Federal Regulations for UST
The federal law governing USTs is covered in Subchapter IX, Chapter 82, Title 42 of the U.S. Code. Subchapter IX — “Regulation of Underground Storage Tanks” — covers guidelines on UST release detection, prevention, and correction, such as the proper tank lining application for USTs. There are subsections for inspections, monitoring, testing, and corrective actions, and the federal authority and enforcement facilities covering this legislation. This law supports Subtitle I of the Solid Waste Disposal Act with the EPA as the regulating body for USTs.
The Energy Policy Act also contains laws on USTs, focusing on hazardous substance release prevention, and tackles legitimate uses of the Leaking Underground Storage Tank (LUST) Trust Fund for inspections, operator training, delivery prohibition, secondary containment, financial responsibility, and cleanup of releases.
The EPA website has the comprehensive list of Federal Regulations concerning USTs, namely 40 CFR Part 280, 40 CFR Part 281, and 40 CFR Parts 282.50-282.105, including the listing of hazardous substances in 40 CFR Part 302.4.
Industry Codes and Standards for UST
Compliance to industry codes and standards is part of federal UST regulations, with guidelines on design and construction, corrosion-protection, and the application of quality tank lining products. Industry codes and standards are meant to encourage UST owners and operators to comply with the best practices in UST management developed by nationally recognized organizations.
The API Recommended Practice 1631, “Interior Lining of Underground Storage Tanks”, NACE Standard RP-0184 “Recommended Practice: Repair of Lining Systems”, NFPA 326 “Standard for the Safeguarding of Tanks and Containers for Entry, Cleaning, or Repair”, and NLPA Standard 631 “Entry, Cleaning, Interior Inspection, Repair, and Lining of Underground Storage Tanks”, are some of the standards that cover tank lining applications.
API Publication 1628, “A Guide to the Assessment and Remediation of Underground Petroleum Releases”, covers UST closures, while UL 1746, Standard for Safety: “External Corrosion Protection Systems for Steel Underground Storage Tanks” covers corrosion protection.
Industry Codes and Standards – Developing Organizations
Below is the list of organizations involved in the testing and development of industry codes and standards for USTs:
- – American National Standards Institute (ANSI)
- – American Water Works Association (AWWA)
- – American Petroleum Institute (API)
- – American Society for Testing and Materials (ASTM)
- – Fiberglass Tank and Pipe Institute (FTPI)
- – Ken Wilcox Associates, Inc. (KWA)
- – National Association of Corrosion Engineers (NACE)
- – National Fire Protection Association (NFPA)
- – National Leak Prevention Association (NLPA)
- – Petroleum Equipment Institute (PEI)
- – Steel Tank Institute (STI)
- – Underwriters Laboratories Inc. (UL)
- – Western Fire Chiefs Association (WFCA)