UST Regulatory Position Papers

The following regulatory position papers have been drafted to provide compliance options related to issues that may be cited during inspection:

  • Interstitial monitoring of open or closed piping systems
  • (In-Line Leak Detector) Monitoring section of piping connected to the pump head, when a mechanical line leak detector has been installed in the product piping and a portion of the piping between the pump head and the leak detector is not being monitored for the 3.0 GPH leak
  • Low Level Containment Sump Testing to comply with Section 280.35 which discusses periodic testing (3-yr) of containment sumps used for interstitial monitoring
  • Sump sensors used as an automatic line line detector for purposes of monitoring for a 3.0 GPH leak
  • Overfill Prevention Equipment Testing 
  • Dry Interstice Monitoring of Double Walled Underground Containment Sumps and acceptance to qualify for the three-year test exemption 
  • Permanently Out of Service (POS) Impressed Current systems not tested/maintained 
  • Permanently Out of Service (POS) Sacrificial Anode systems not tested/maintained 



Underground Storage Tanks (UST)