Fuel Storage Tank Regulations: Key Requirements

Jackson Haskell
6 days ago
11 min read

Fuel storage tank regulations are designed to protect public health, property, and natural resources by preventing leaks, contamination, and fire risks. Here's a quick breakdown of what you need to know:

Underground Storage Tanks (USTs): Must meet EPA standards, including secondary containment, spill/overfill prevention, and corrosion protection. Regular inspections (e.g., every 30 days for spill buckets) and operator training are mandatory.
Aboveground Storage Tanks (ASTs): Focus on fire safety and containment. Compliance with OSHA and industry codes (API, PEI, STI) is required.
Spill Prevention (SPCC): Facilities storing over 1,320 gallons must have a spill plan, including containment systems and emergency response protocols.
State and Local Rules: States like California enforce stricter guidelines, such as increased inspections and licensing requirements.
Maintenance: Regular testing for leak detection, corrosion prevention, and overfill equipment is critical. Proper recordkeeping ensures compliance and avoids penalties.
Financial Responsibility: Tank owners must demonstrate the ability to cover cleanup costs and damages from leaks.

Compliance protects drinking water, reduces costly fines, and ensures safe operations. Staying on top of inspections, training, and recordkeeping is key.

How to comply with the new UST regulations (40 CFR 280)

Federal Regulations for Fuel Storage Tanks

UST vs AST Fuel Storage Tank Requirements Comparison

Federal regulations for fuel storage tanks involve oversight by the EPA for environmental concerns and OSHA for workplace safety. The requirements differ depending on whether the tanks are underground or aboveground.

Underground Storage Tank (UST) Requirements

The EPA regulates USTs under 40 CFR Part 280, with the most recent updates made in 2015 - the first major changes since 1988. A UST system includes any tank and connected piping where at least 10% of the system's total volume is underground.

Design and installation standards mandate that UST systems installed or replaced after April 11, 2016, must include secondary containment with interstitial monitoring. Materials used must resist corrosion, such as fiberglass, steel with protective coatings and cathodic protection, or steel clad with noncorrodible materials. Additionally, under-dispenser containment (UDC) is required for all new dispenser systems.

To prevent spills and overfills, all UST systems must have spill prevention and overfill protection equipment. Spill buckets (or catchment basins) are used to catch drips from delivery hoses, which can hold up to 14 gallons of fuel. Overfill prevention tools include automatic shutoff valves (stopping flow at 95% capacity), alarms (triggering at 90% capacity or just before an overfill), and ball float valves (restricting flow at 90% capacity).

Maintenance requirements ensure UST systems remain safe and functional. Here's a breakdown of key inspection and testing timelines:

Requirement	Frequency	Compliance Action
Walkthrough Inspections	Every 30 days	Check spill buckets, remove debris, and verify detection systems
Spill/Overfill Equipment	Every 3 years	Test for liquid tightness or monitor double-walled systems
Cathodic Protection Testing	Every 3 years	Confirm adequate corrosion protection
Impressed Current Systems	Every 60 days	Inspect system functionality
Release Detection Equipment	Annually	Test electronic and mechanical components

Facilities must keep records of the two most recent cathodic protection tests and three 60-day inspections. These steps help protect both the environment and the operational reliability of the system.

Operator training is essential for maintaining compliance and preventing safety incidents. Facilities must designate and train Class A, B, and C operators, each responsible for different levels of compliance and emergency response. Before switching to biofuels with more than 10% ethanol or 20% biodiesel, operators must notify the appropriate agency 30 days in advance and confirm that the UST system is compatible with the new fuel.

While USTs require robust underground protections, aboveground storage tanks operate under a different set of rules, focusing on fire safety and containment.

Aboveground Storage Tank (AST) Regulations

Aboveground storage tanks (ASTs) are primarily regulated to ensure fire safety and environmental protection. OSHA standards address fire hazards, handling of dangerous materials, and worker safety equipment. Tanks must meet industry codes established by organizations like the American Petroleum Institute (API), Petroleum Equipment Institute (PEI), and Steel Tank Institute (STI).

Secondary containment is a critical requirement for ASTs storing petroleum products. These containment systems must accommodate the volume of the largest tank, plus extra capacity for precipitation. Fire safety measures include proper tank spacing, sufficient ventilation, and emergency shutoff systems.

The SPCC rule further refines spill prevention measures for facilities that exceed certain storage capacity thresholds.

Spill Prevention, Control, and Countermeasure (SPCC) Planning

The SPCC rule (40 CFR Part 112) applies to facilities storing oil in aboveground containers with a total capacity exceeding 1,320 gallons. This includes only containers of 55 gallons or larger. The rule governs "oil of any kind", including petroleum products, synthetic oils, animal and vegetable oils, and more.

To determine whether SPCC rules apply, start by creating a chemical inventory. Include all containers of 55 gallons or more, review Safety Data Sheets (SDS) to identify oil content in mixtures (substances with at least 1% oil should be considered), and calculate the total volume to see if it surpasses the 1,320-gallon threshold.

The "Sheen Rule" (40 CFR 110.3) requires reporting any discharge that creates a sheen or discoloration on water surfaces. If it’s unclear whether a product is regulated, consider whether it could produce a visible sheen on water.

SPCC plans must include detailed diagrams, spill containment measures, inspection protocols, and emergency response procedures. These plans need to be prepared by a Professional Engineer and reviewed every five years. Facilities are required to implement spill containment systems, maintain inspection records, and train staff on emergency response procedures.

While natural gas is not regulated under SPCC due to its rapid volatilization in air or water, natural gas liquid condensate is regulated if stored in containers of 55 gallons or more. The EPA also exempted milk and milk products from SPCC requirements in 2011.

State and Local Compliance Standards

Federal regulations provide a baseline for fuel storage tank safety, but state and local authorities often add their own layers of requirements. Under RCRA Section 9004, states can take charge of their own underground storage tank (UST) programs, as long as their rules meet or exceed the federal standards outlined in 40 CFR Part 280. In practice, this means state agencies typically handle enforcement, while the EPA maintains the authority to inspect and intervene when necessary. Let’s break down how state and local rules build on federal guidelines.

State-Level Requirements

Many states go beyond the federal minimums with stricter regulations. California, for instance, enforces higher standards through its Health & Safety Code Chapter 6.7 and California Code of Regulations Title 23, Chapter 16. Its updated UST regulations, effective October 1, 2020, align with federal rules but also include state-specific provisions. Additionally, California requires tank testers to hold state licenses under CCR Title 23, Chapter 17.

States often introduce measures like annual per-tank fees to fund their regulatory programs and require specialized certifications for professionals involved in tank installation or repair. They may also demand more detailed soil and groundwater testing protocols than federal guidelines stipulate. California’s "Red Tag" program, approved on May 13, 2004, is another example. This program allows authorities to seal a tank’s fill pipe, effectively halting fuel deliveries to systems that aren’t in compliance.

Local Permitting and Zoning Rules

Local jurisdictions add another layer of oversight through permits and zoning codes. Fire marshals and building departments regulate tank placement, setback distances, and fire safety equipment. Federal guidelines require owners to secure all necessary local permits for "existing tank systems" before installation.

Businesses must identify their local Unified Program Agency (UPA) or equivalent oversight body. These agencies handle permit applications and enforce regulations at the municipal or county level, often requiring documentation for spill containment, overfill prevention, and secondary containment testing. Local fire departments focus on fire code compliance, while municipal planning departments ensure properties are zoned for hazardous material storage or large-capacity fuel tanks. California’s Unified Program for Hazardous Materials Management helps streamline state and local efforts, allowing local agencies to oversee hazardous materials programs under state supervision.

Operational Compliance and Maintenance Best Practices

Keeping operations compliant means staying on top of inspections, testing, and ensuring staff are ready to act. Federal rules require specific checks, like walkthrough inspections every 30 days for spill prevention equipment and release detection alarms. Other equipment, such as containment sumps and handheld detection devices, needs annual testing. Below, we’ll break down the essential actions for inspections, testing, and staff training that help maintain compliance.

Inspection and Testing Requirements

The type of equipment determines how often and what kind of testing is necessary. For instance:

Spill prevention equipment and containment sumps used in interstitial monitoring need leak tests every three years.
Overfill prevention equipment must be checked at least once every three years to ensure it activates at the right tank level, either stopping fuel flow or alerting the operator.
Cathodic protection systems, which prevent corrosion, require testing six months after installation and every three years after that.

Detection systems - including automatic tank gauges, probes, sensors, and line leak detectors - must be tested annually to confirm they’re working correctly. Daily visual inspections are also critical. Check for signs of corrosion, leaks, or unusual conditions like wet spots or dead vegetation. Monitoring data, such as pressure gauge readings, should also be reviewed daily.

Proper recordkeeping is just as important as the inspections themselves. Walkthrough inspection records should be kept for one year, while documentation for overfill prevention, spill containment, and release detection testing must be retained for three years. For corrosion protection and system repairs, records need to be kept for the entire life of the tank.

Staff Training and Emergency Preparedness

Federal guidelines emphasize the importance of trained staff to ensure smooth operations and quick responses to system issues. Facilities must assign and train three types of operators:

Class A operators oversee overall system operations and compliance.
Class B operators focus on daily maintenance and recordkeeping.
Class C operators handle emergency responses and spill notifications.

Training documentation must be kept for the duration of each operator’s employment or designation.

Prepared staff are especially vital during emergencies. Response plans should outline clear steps for handling fuel releases - stopping the flow, removing the fuel, and minimizing environmental damage. For hazardous waste tank systems, any material that ends up in secondary containment must be removed within 24 hours. If a release is suspected, it must be reported to the implementing agency within 24 hours, with a formal report submitted to the Regional Administrator within 30 days.

To support facilities in urgent situations, Guardian Fueling Technologies offers 24/7 service technicians, helping meet tight reporting deadlines and ensuring compliance.

Additionally, before storing biofuel blends with over 10% ethanol or 20% biodiesel, it’s essential to confirm that all UST system components - like piping, gaskets, and dispensers - are compatible with the fuel.

Environmental Protection and Sustainability

Faulty fuel storage tanks can lead to serious environmental issues, including soil, groundwater, and surface water contamination. These problems often stem from corrosion breaches, delivery overfills, or spills during hose disconnection. Corrosion pits, if left unchecked, can develop into breaches that release harmful substances over time. These environmental risks add to the operational and regulatory challenges already associated with fuel storage.

Stormwater Management

Beyond spill containment, managing stormwater is essential to stop contaminants from spreading. Secondary containment systems play a key role here. They need to be properly sloped to collect and remove liquids resulting from leaks or heavy rainfall - specifically, a 25-year, 24-hour rainfall event. These systems are designed to ensure that neither waste nor accumulated precipitation reaches the soil or water.

Collected contaminants must be removed within 24 hours to prevent environmental damage. If the liquid in spill buckets or containment systems is mixed with fuel or chemicals, it may be classified as hazardous waste. This requires careful handling and testing in line with local regulations. Importantly, contaminated water should never be drained into storm drains without proper filtration or disposal processes in place.

Corrosion Prevention and Upkeep

Metal components that come into contact with the ground are especially vulnerable to corrosion and must be protected. This can be achieved through cathodic protection or by isolating the components from corrosive environments. Common solutions include using noncorrodible materials like fiberglass-reinforced plastic, steel with protective coatings, or interior linings. Interestingly, an EPA survey revealed that while 75% of tanks showed no visible external corrosion, over 80% of those tanks had moderate to severe internal corrosion.

Method	Primary Function	Maintenance Requirement
Cathodic Protection (Sacrificial Anode)	Redirects corrosion away from steel tanks	Test every 3 years
Cathodic Protection (Impressed Current)	Supplies continuous protective electric current	Test every 3 years; inspect rectifiers every 60 days
Internal Linings	Forms a barrier between fuel and tank walls	Inspect internally within 10 years of installation, then every 5 years
Noncorrodible Materials	Prevents rust entirely	Requires minimal ongoing maintenance

Spill buckets (or catchment basins) are another essential tool, designed to catch drips from delivery hoses. These buckets must be kept clean and free of debris, as any mixture of water and sediment with fuel may require disposal as hazardous waste. Companies like Guardian Fueling Technologies offer advanced services like fuel quality management and fuel polishing, helping facilities maintain cleaner systems and reduce the risk of corrosion. Regular maintenance not only extends the life of fuel storage tanks but also minimizes the chance of harmful releases.

Conclusion

Compliance plays a critical role in protecting groundwater, reducing remediation expenses, and maintaining operational safety. Whether you're managing underground or aboveground systems, adhering to federal, state, and local regulations requires careful attention to key areas like secondary containment, operator training, release detection, and compatibility testing for biofuel blends. These regulations establish the foundation for effective operational practices and routine maintenance.

Facilities must follow comprehensive SPCC plans and maintain detailed documentation, especially when operating under stricter state rules or surpassing SPCC thresholds. In such cases, an approved spill response plan is mandatory. States with State Program Approval may impose even more stringent standards than federal guidelines. With underground storage tank releases remaining a major source of groundwater contamination in the U.S., proactive compliance is not just about avoiding fines - it’s about protecting communities and natural resources. Meeting these standards strengthens both environmental safeguards and daily operations.

Keeping accurate records of inspections, testing, and repairs is vital for passing audits. Up-to-date documentation ensures compliance while supporting environmental protection through proactive maintenance and thorough recordkeeping.

Strong support systems make all the difference. Guardian Fueling Technologies offers expert services to seamlessly integrate compliance into your daily operations. With 24/7 access to specialists, advanced monitoring tools, and fuel quality management nationwide, they provide the resources needed to stay compliant and efficient. Their services, including fuel polishing and equipment maintenance, address modern fuel storage challenges like corrosion prevention and biofuel compatibility.

Working with experienced service providers turns compliance from a daunting task into a streamlined part of your routine, safeguarding your investment, your community, and the environment for the future.

FAQs

What are the key differences between underground and aboveground storage tank regulations?

The main distinctions between underground storage tank (UST) and aboveground storage tank (AST) regulations revolve around their focus and compliance needs. UST regulations are designed for tanks buried below the surface, with a strong emphasis on spill prevention, overfill protection, release detection, and secondary containment. These rules are primarily governed by federal standards like 40 CFR Part 280, alongside additional state-specific requirements.

In contrast, AST regulations apply to tanks situated above ground and involve a combination of federal, state, and local guidelines. These regulations focus on spill prevention, safeguarding the environment, and maintaining tank integrity. While both UST and AST regulations share the goal of protecting public health and the environment, the specific requirements differ based on the tank's location and associated risks.

What are the financial responsibility requirements for fuel tank owners to address potential leaks?

Fuel tank owners are required to prove they can handle the financial burden of potential leaks, including cleanup costs and damages to third parties. For most tanks, this means showing financial assurance of at least $500,000 per occurrence. However, if the tank is located at a petroleum marketing facility or handles more than 10,000 gallons per month, the minimum per-occurrence coverage increases to $1 million.

On top of that, annual aggregate coverage must be no less than $1 million for owners managing between 1 and 100 tanks. For those with more than 100 tanks, the required annual aggregate coverage doubles to $2 million. These measures are in place to ensure fuel tank owners are equipped to manage both environmental and financial challenges responsibly.

What are the main elements of an SPCC plan for facilities storing more than 1,320 gallons of oil?

An SPCC (Spill Prevention, Control, and Countermeasure) plan is a federal requirement for facilities storing more than 1,320 gallons of oil. Its purpose? To prevent oil spills from reaching navigable waters or shorelines. The plan revolves around several critical components:

Spill prevention measures: Strategies designed to reduce the likelihood of oil spills.
Spill containment controls: Systems in place to manage and limit the spread of spills if they happen.
Training and resources: Ensuring personnel are equipped and prepared to handle spill incidents efficiently.
Professional Engineer (PE) certification: A PE must certify the plan, unless the facility meets the criteria for a "qualified facility."

These steps not only align with federal regulations but also play a crucial role in safeguarding the environment from oil-related hazards.