Temporary Closure of UST Systems

Written by: Brian Pottebaum, Director of Training Services

Many facilities consider temporary or even permanent closure of their petroleum storage tanks for various reasons. The two most notable deciding factors are tank contents and time out of service. The regulations are generally written in a way to allow temporary closure for up to 12 months, however there are exceptions to the rule if proper procedure is followed.

Facilities have the option to initially take the UST system out of service for up to 3 months without filing a notice of temporary closure. If they plan to stay closed any longer, they must file a notice of closure with the authority having jurisdiction, such as the Department of Natural Resources.

During this time of temporary closure, the facility must maintain compliance with all the following items:

  • Continued operation/maintenance of Cathodic Protection (if applicable).
  • Continued operation/maintenance of Tank and Line Release Detection (unless emptied to less than 1” of product or residue on the bottom of the tank).
  • Comply with suspected/confirmed release requirements.
  • Maintain Financial Responsibility (i.e. PMMIC Tank Insurance).
  • Continue to maintain regulatory registration and associated fees (i.e. tank tags).
  • Continue to have periodic regulatory compliance inspections.
  • Continue to maintain trained and designated A/B operators.

Additionally, if the tanks are NOT emptied to less than 1” of product or residue, the facility must also comply with the following items:

  • Perform monthly walkthrough inspections of release detection (does not include spill buckets)
  • Perform annual inspections and testing of release detection equipment.
  • Perform 3-year containment sump testing if using the containment sump for interstitial monitoring of the piping.
  • If a release is discovered, quickly stop the release, notify your regulatory authority, and take appropriate action to clean up the site.
  • If the UST remains temporarily closed for more than 3 months, leave vent lines open, but cap and secure all other lines, pumps, manways, and ancillary equipment.

USTs in temporary closure (less than 1” of product or residue) are NOT REQUIRED to meet the following requirements:

  • 3 Year Spill Bucket Testing
  • 3 Year Overfill Prevention Equipment Testing
  • Monthly Tank and Line Release Detection
  • Annual Release Detection Functionality Testing
  • Monthly/Annual Walkthrough Inspections
  • 3 Year Containment Sump Testing

Regulators keep a close eye on temporarily closed facilities to ensure they are not abandoned and lose sight of environmental responsibility. Therefore, after 12 months of temporary closure, you have three options.

Option 1: You must permanently close your UST if it does not meet the applicable requirements for new or upgraded USTs (except for spill and overfill).

Option 2: You can ask your implementing agency for an extension beyond 12 months, if you provide an assessment (i.e. site check) that determines whether contamination is present at your site.

Option 3: Your UST can be returned to service if fully compliant with regulations. In some states, such as Iowa, you are required to file a “return to service” notice and receive approval from the agency prior to returning the UST system to service. This may also require additional inspections and testing to ensure that the system is tight and not at risk of releasing product to the environment.

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