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New Illinois OSFM Regulations for USTs

Illinois OSFM Regulations for USTs

Several new requirements effective October 13, 2018 will have a big impact on UST owner and operators.

  1. Requirement to test ALL spill buckets.

  2. Requirement to test ANY containment sumps USED FOR INTERSTITIAL MONITORING of PIPING.

  3. Requirement to inspect ALL overfill prevention equipment.

  4. Requirement to complete Annual Leak Detection Certification.

  5. Requirement to document compatibility for ALL blended fuel USTs throughout the UST system.

  6. Requirement for A/B OPERATORS and or CONTRACTORS to conduct Periodic Operation & Maintenance Walkthrough Inspections at ALL Regulated facilities: 30 day and annual.

Requirement to test all Spill Buckets and any Containment Sumps used for Interstitial Monitoring of Piping. The options are “either/or.”

OPTION 2: 175.405(b)(2): Equipment (spills/sumps) must be tested every 3 years. Test may be a hydrostatic test, a vacuum test, a pressure test or a low level positive shutdown test (for qualifying piping sump installations only).

Testing must follow either manufacturer’s instructions or requirements as defined by the implementing agency.

The first tests must be done by 10/13/2018.

For systems installed after 10/13/2015, requirements already apply. OSFM has required the containment test to be done at installation of new sumps for years.

OPTION 1: 175.405(b)(1): Alternative to 3 year testing if done correctly.

Equipment (spills/sumps) must be double walled.

This option requires monitoring of the equipment interstice, and there must be a record of the interstice being monitored every 30 days.

The records of that monitoring must be kept and be available for inspection for 3 years.

Failure to have complete documentation will result in performing a containment test.

Requirement to Test ALL Spill Buckets (175.405)

  • Illinois has over 19,000 regulated USTs at nearly 7,000 active facilities.

  • Each of these tanks has spill containment, usually and preferably a spill bucket.

  • Failure rates > 65% were experienced in CA when sump testing was first required 10 years ago.

  • We could see over 12,000 spill bucket failures in the next 2 years.

  • On the plus side, Spill Buckets will be comparatively easy to test and replace if necessary.

  • Hydrostatic testing will require significantly less water for spill buckets compared to piping sumps.

  • Penetrations are minimal.

  • Some contractors offer vacuum testing as an alternative to hydrostatic testing.

  • We will now allow stainless steel “drop-in” spill buckets, and allow them to be as small as 3.5 gallon capacity. This is being done to allow an additional option we can live with. 3.5 gallons will fit inside of 90%+ of existing models, per one manufacturer.

  • “Multiport” Fills may have sensors in the containment. These are not interstitial sensors, since there is a drop tube and a vapor port in the containment, not pressurized, double wall product piping.

  • Only the spill bucket in the multiport containment gets tested if the vapor port and drop tube each has its own individual bucket.

  • However, if both the vapor port & the drop tube are in a single containment, the containment is the spill bucket, and it must be tested.

  • Note: A spill bucket inside of another containment is not a double wall spill bucket, although technically it is secondarily contained.


Illinois OSFM Regulations for USTs















Bad Spill Bucket














175.410: Requirement to Test ANY Containment Sumps USED FOR INTERSTITIAL MONITORING of PIPING: What Qualifies for Testing?

  • Single wall piping in a sump, whether there is a sensor there or not, does not qualify. There is no interstice to monitor. Therefore the sensor is not an interstitial monitoring sensor. These can be changed in our equipment list to “Sump Sensor — Nonregulated” (available soon). Making this change will require an UPG permit.

  • Double wall piping in a sump which was installed prior to 2/1/2008 without any sensors in the sumps does not qualify for 3 year testing, and is legally grandfathered.

  • Double wall piping in a sump which was installed prior to 2/1/2008 with a sensor in the sump does qualify for 3 year testing in Illinois.

  • Any double wall piping in a sump which was installed after 2/1/2008 must have a sensor in the sump and obviously does qualify.

  • Note: Single wall piping run inside a chase may be secondarily contained, but it is not double wall piping. These entries will be corrected as they are encountered.

Requirement to Test ANY Containment Sumps USED FOR INTERSTITIAL MONITORING of PIPING: Testing Options (175.410(l))

  • Hydrostatic Test for Spill Buckets and Piping Containment Sumps

  • This is the test done now.

  • We adapted the PEI RP1200 method to our new requirements:

  • Spill Buckets are filled to within 1.5” of the top

  • Piping Containment Sumps are filled to a height that covers the highest penetration or sidewall seam by 4”.

  • Duration of test is ½ hour, with a drop of less than 1/8” considered passing.

  • Vacuum Testing and Pressure Testing will also be accepted, although these will be unlikely to be practicable for piping containment sumps.

  • And then there’s the Low Level Positive Shutoff Test.

  • This is not for installs or repairs or NOVs – those all require hydrostatic testing.

  • There are listed conditions which must be met:

  • Positive STP shutdown must be there and be verified as working.

  • Sumps must pass visual inspection by contractor for structural soundness and integrity.

  • Sumps cannot be found to be full of water/debris or with sensors in alarm or with sensors pulled up.

  • Testing must be performed following sensor manufacturer’s specifications.

  • Discriminating Sensors must be tested in manufacturer specified “test liquid” and must shut down the STP on activation. Discriminating Sensors with water alarms must shut down the dispenser or the STP.

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What Must You Do About a UST Release?

UST ReleaseWarning Signals indicate that your UST may be leaking and creating problems for the environment and your business. You can minimize these problems by paying careful attention to early warning signals and reacting quickly before major problems develop.

In dealing with a suspected UST Release, you should observe these warning signals:

  • Unusual operating conditions. Check first to see if the problem results from equipment failure that can be repaired.  Remember to remove any liquid not used for interstitial monitoring from the interstitial space of the secondarily contained systems.

  • Results from release detection monitoring and testing that indicate a release.  What at first appears to be a release may be a result of faulty equipment that is part of your UST system or its release detection.  Check this equipment carefully for failures.

If you investigate an unusual operating condition or release detection alarm and determine a release has not occurred, you do not need to report a suspected release as long as you immediately fix the problem.  Otherwise, you need to call your implementing agency and report the suspected release.  In the state of Illinois the two agencies that have to be notified are the Office of the State Fire Marshal and the Illinois EPA.  Then find out quickly if the suspected release is an actual release.  Use these investigative steps:

  • Conduct tightness testing or interstitial integrity testing of the entire UST system.

  • Check the site for additional information on the presence and source of contamination.

If the system tests and site checks confirm that a release has occurred, follow the actions for responding to confirmed releases described below.

You must also respond quickly to any evidence of released petroleum that appears at or near your site.  For example, neighbors might tell you they smell petroleum vapors in their basements or taste petroleum in their drinking water.  If evidence of this type is discovered, you must report this discovery immediately to your implementing agency and take the investigative steps and follow up actions noted above.

Your action action to confirmed releases comes in two stages: short term and long term.

Short-Term Actions for a UST Release

  • Take immediate action to stop and contain the release.

  • Report the release to your implementing agency within 24 hours or the time frame required by your implementing agency.  However, petroleum spills and overfills of less than 25 gallons do not have to be reported if you immediately contain and clean up the releases.

  • Make sure the release poses no immediate hazard to human health and safety by removing explosive vapors and fire hazards.  Your fire department should be able to help or advise you with this task.  You must also make sure you handle contaminated soil properly so that is poses no hazard, for example, from vapors or direct contact.

  • If necessary, remove petroleum from UST system to prevent further release into the environment.  How do I remove petroleum from my UST system? Hiring a qualified and experienced environmental consultant is the first step.

  • Find out how far the petroleum has moved and begin to recover the released petroleum, such as product floating on the water table. Report your progress and any information you collect to your implementing agency no later than 20 days after confirming a release.

  • Investigate to determine if the release has damaged or might damage the environment.  This investigation must determine the extent of contamination both in soils and groundwater. You must report to your implementing agency what you have learned from an investigation of your site according to the schedule established by your implementing agency. At the same time, you must also submit a report explaining how you plan to clean up the site.  Additional site studies may be required.

Long-Term Actions for a UST Release

Based on the information you provide, your implementing agency will decide if you must take further action at your site.  You may need to take two more actions:

  • Develop and submit a corrective action plan that shows how you will meet requirements established for your site by your implementing agency.

  • Make sure you implement the actions approved by your implementing agency for your site.

Suspected UST Release
Soil Borings to determine if there is a UST Release










Hiring the correct company to assess your situation is very important.  In many cases preforming a environmental site assessment is the next course of action.