Compliance Through Facility Testing
Testing UST systems and components is required by the UST Rules. Doing so keeps UST facilities in compliance, and it confirms whether their systems are functioning as designed and containing regulated substances. UST owners/operators should know that they are responsible for submitting test results when they are due to the Storage Tanks Section; this is not the responsibility of the contractor that conducted the testing. Refer to the list below to access testing forms developed by the Storage Tanks Section, and note that the required testing interval is listed for each test type.
Note: Failed tests (those tests listed below and/or cathodic protection (CP) tests) must be reported immediately to the Storage Tanks Section; passing test results must be submitted within 30 days of the date of the test.
Testing Forms
A completed cover page must be submitted with any testing form(s) listed below:
Cover Page for UST Testing Forms (required)
- Line Leak Detector - annual
- Tank Top Sump Tightness - every three years (if not double-walled)
- Dispenser Sump Tightness - every three years (if not double-walled)
- Spill Bucket Containment - every three years (if not double-walled)
- Transition Sump Tightness - every three years (if not double-walled) for pressurized piping systems
- Overfill Prevention Equipment - every three years
- Piping Tightness - only required for new installations, or when requested by the Storage Tanks Section.
Testing for Cathodic Protection (CP)
Steel tanks, steel piping, flexible connectors attached to fiberglass piping, and any ancillary equipment containing product that is in contact with the ground must be protected against corrosion according to the UST Rules. Owners/operators that utilize a cathodic protection (CP) system to meet the corrosion protection requirements must ensure that testing is completed according to the standards and intervals established in the UST Rules. The Storage Tanks Section does not provide a form for CP testing, and the Section will accept CP testers' forms from UST owners/operators so long as all necessary information is documented. The required intervals for CP testing are as follows:
- Factory-installed CP systems - every three years
- Field-installed CP systems - annually
Compliance Through Inspections
Federal regulations require that all regulated UST facilities are inspected at least once every three years. This is required for all states. In Vermont, inspectors from the Storage Tanks Section of the Hazardous Materials Program conduct these inspections. The main purpose of inspecting UST facilities is to evaluate compliance with the UST Rules. The rules are “no less stringent” than the federal UST regulations, and the Program is federally authorized to implement them in lieu of federal regulations.
The Storage Tanks Section inspects between 250 and 300 facilities each year. The list of facilities to be inspected each year is updated annually (see below). Inspectors typically schedule inspections with facility operators roughly one week prior to coming onsite so the inspector is able to meet with the UST operator, review records, and inspect UST systems during their visit. While there is wide variability in the age, design, and operation of UST systems throughout Vermont, most inspections involve observing tank top equipment like piping sumps, fill port spill containment (i.e., spill buckets), overfill prevention devices, and sensors; and reviewing recordkeeping documentation including weekly leak detection records, monthly operator inspection checklists, list of trained C operators, tank diagrams, and permit postings.
If violations are found during the UST inspection, the tank owner will receive a certified letter referred to as a Notice of Alleged Violation (NOAV). The notice will document the rules violation(s), including a brief description of what the inspector observed. The notice will also give compliance directives that must be addressed by the dates specified in the notice. Documentation of the corrected violations may be required. In some cases, significant or repeat violations will warrant monetary fines.
Resources for UST Owners/Operators
Monthly Walkthrough Inspections
UST Facility Monthly Inspection Sample Checklist
Inventory Monitoring
Inventory Monitoring and Weekly Water Checks
Monthly Inventory Log Sheets
Daily Inventory Log Sheets
Templates for Logging Leak Detection
Leak Detection Log for Electronic Monitoring Systems (e.g., Veeder Root, etc.)
Leak Detection Log for Manual Monitoring Systems
Leak Detection Log for Weekly Electronic Leak Test Monitoring Systems (i.e., tanks without interstitials that have electronic in-tank monitoring)
UST Compliance Inspections
UST Compliance Inspections Guide
List of 2023-2024 Facility Inspections
UST NOAV Response Form
Other Resources
Vermont UST Newsletter
Contact Information
Storage Tanks Section
Hazardous Materials Program
Waste Management and Prevention Division
Vermont Department of Environmental Conservation
1 National Life Drive – Davis 1
Montpelier, VT 05620-3704
802-828-1138