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Underground Storage Tanks (USTs)

Alternative Fuels and Underground Storage Tanks (USTs)

Introduction

EPA’s underground storage tank (UST) regulations require that tank systems are compatible with the substances stored in them. The use of alternative fuels in the United States is growing, and federal mandates require a significant increase in biofuels production. Many retail facilities, such as gas stations, and private fueling facilities already store and dispense ethanol and biodiesel in their UST systems. Ethanol and biodiesel are commonly blended with gasoline and diesel, respectively, and are referred to by their biofuel percentage of the blend: E10, E15, or B20. These fuels are also available in some retail markets as non-blended biofuels E98 or B100. The development and availability of other alternative fuels, such as isobutanol, are growing rapidly. 

Each alternative fuel or alternative fuel blend has unique chemical characteristics that may be different from those of purely petroleum derived gasoline or diesel fuel. Those chemical characteristics may affect how the fuel interacts with UST system materials. Some materials in some USTs may actually not perform as intended if storing certain fuels or blends and may be incompatible with those fuels. If UST materials are not compatible with substances stored in USTs, releases to the environment can occur. Prior to storing alternative fuels, UST owners and operators should be aware of potential issues and regulations to ensure fuels are stored safely in USTs. 

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2015 Compatibility Requirements

In 2015, EPA revised the underground storage tank (UST) regulations. See below for the 2015 requirements.

Owners and operators must use an UST system made of or lined with materials that are compatible with the substance stored in the UST system.

Compatibility is the ability of two or more substances (for example the tank or piping material and petroleum) to maintain their respective physical and chemical properties upon contact with one another. These substances need to remain compatible for the design life of the tank and under conditions likely to be encountered in the UST.

Beginning on October 13, 2015 owners and operators must notify their implementing agency at least 30 days prior to switching to one of the following:

  • Regulated substances containing greater than 10 percent ethanol;
  • Regulated substances containing greater than 20 percent biodiesel; or
  • Any other regulated substance identified by the implementing agency.

This notification gives the implementing agency an opportunity to inquire about the compatibility of the UST system before the owner and operator begins storing the regulated substance.

In addition, owners and operators storing one of these regulated substances must meet one of the following:

  • Demonstrate compatibility of the UST system (this includes the tank, piping, containment sumps, pumping equipment, release detection equipment, spill equipment, and overfill equipment) by using one of the following options:
    • Certification or listing of UST system equipment or components by a nationally recognized, independent testing laboratory for use with the regulated substance stored
    • Equipment or component manufacturer approval – this approval must be in writing, indicate an affirmative statement of compatibility, specify the range of biofuel blends the equipment or component is compatible with, and be from the equipment or component manufacturer
  • Use another option determined by the implementing agency to be no less protective of human health and the environment than the two options above.

Owners and operators must maintain records that document compliance with the compatibility requirement if they store regulated substances containing greater than 10 percent ethanol, greater than 20 percent biodiesel, or any other regulated substance identified by the implementing agency. These records must be maintained for as long as the UST system is used to store one of these regulated substances.


2011 Guidance on Demonstrating Compatibility

EPA's 2011 guidance provides options for UST owners and operators to use in complying with the federal compatibility requirement for UST systems storing gasoline containing greater than 10 percent ethanol or diesel containing greater than 20 percent biodiesel.

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For more information, contact Ryan Haerer at haerer.ryan@epa.gov or 202-564-0762.