Files
Files
Purpose:
To revise GSA’s policy for managing Fuel Storage Tanks and establish GSA’s policy for
managing regulated substance storage tanks.
Background:
Federal, state, and local laws establish standards for the management of storage
tanks (aboveground [ASTs] or underground [USTs]) used or previously used to store
regulated substances, including petroleum. Tanks used to store petroleum are hereafter
referred to as fuel storage tanks (FSTs). Tanks used to store other regulated substances
are referred to as hazardous substance storage tanks (HSTs). Collectively, these tanks
are referred to as regulated substance tanks (RSTs). Owners and operators must
install, operate, and maintain all storage tanks that contain regulated substances in a
manner that prevents or reduces the potential for release of their contents into the
environment. Various laws further mandate requirements for training, emergency
planning, release reporting, and closure procedures.
Per 33 U.S.C. 1323 of the Clean Water Act (CWA), and 42 U.S.C. 6991f of the
Resource Conservation and Recovery Act (RCRA), federal facilities must comply with
Federal, state and local requirements. In addition, consistent with the specific language
in each statute, Federal agencies may be subject to civil penalties for non-compliance.
Consult with the Office of the General Counsel to determine applicability. States are the
primary authority for implementing AST programs. They may also be granted the
primary authority to implement the UST program within their boundaries. The governing
standards of authorized state programs must be no less stringent than Federal laws. In
states that have not been delegated authority, UST systems must comply with the
Federal minimum standards.
One of the greatest risks associated with regulated substances storage is the potential
for releases that can contaminate surface water, groundwater and soil. Releases can
also pose other risks to the environment, human health and safety, as well as the
potential for fire, explosions, property damage, and financial liability.
Applicability:
This order and the companion desk guide apply to Federally owned facilities under the
jurisdiction, custody, and control of the GSA. Limited aspects of this order apply to
facilities operating under a GSA delegation of operation and maintenance authority and
space leased by GSA, as dictated by the provisions of the delegation or lease. This
order is not applicable to RSTs associated with property reported excess for disposal
through the PBS Office of Real Property Disposition.
This order applies to all GSA employees and contractors as they perform their duties.
The following are exceptions:
   1. The Office of Inspector General (OIG), given its independence under the
       Inspector General Reform Act of 2008 (5 U.S.C. §§ 401-424).
   2. The Civilian Board of Contract Appeals, due to its independent authorities.
Cancellation:
This Order supersedes GSA Order PBS 1095.2, Fuel Storage Tank Management.
Summary of Changes:
   1. Broadened the scope of the existing policy to include regulated substance
       storage tanks and changed the title of the Order to align with the expanded
       scope.
   2. Established the National Computerized Maintenance Management System
       (NCMMS) as the mandatory repository of record for the PBS RST inventory.
   3. Enhanced the roles and responsibilities discussion.
   4. Defined the minimum attributes that must be included in the tank inventory.
Signature
/S/______________________                                 3/11/2025__________
Michael P. Peters                                       Date
Commissioner
Public Buildings Service
Appendix A: Desk Guide for Regulated Substances Storage Tank
                        Management 
                           
March 2025
                                                               1
Appendix A: Desk Guide for Regulated Substances Storage Tank Management................1
1. Introduction..............................................................................................................................3
2. Authority...................................................................................................................................3
3. Applicability............................................................................................................................. 3
4. Acronyms and Definitions...................................................................................................... 4
5. Policy........................................................................................................................................ 7
6. Roles and Responsibilities................................................................................................... 10
    6.1. Office of Facilities Management (OFM) Facilities Risk Management Division............... 10
    6.2. OFM Office of Technology & Innovation..........................................................................11
    6.3. OFM Office of Facilities Operations................................................................................ 11
    6.4. Office of Architecture and Engineering........................................................................... 11
    6.5. Environmental, Health, Safety & Fire Community.......................................................... 12
    6.6. Building Operations / Property Management Community...............................................12
    6.7. O&M Contractors............................................................................................................ 13
    6.8. Acquisitions Teams......................................................................................................... 14
    6.9. Portfolio Management and Customer Engagement........................................................14
    6.10. Office of Leasing........................................................................................................... 15
    6.11. Office of the General Counsel.......................................................................................15
    6.12. Leadership.................................................................................................................... 15
7. Contracting for RST Services...............................................................................................15
8. RSTs at GSA Leased and Delegated Properties................................................................. 16
9. Notifications for Planned RST Activities............................................................................. 16
10. Installation and Operations & Maintenance Requirements............................................. 16
    10.1. ASTs............................................................................................................................. 17
    10.2. USTs............................................................................................................................. 19
11. Emergency Planning and Reporting.................................................................................. 24
    11.1. Spill, Prevention, Control, and Countermeasure (SPCC) Plans................................... 24
    11.2. Release Reporting........................................................................................................ 25
12. Tank Closure Requirements............................................................................................... 26
    12.1. AST Closure Requirements.......................................................................................... 26
    12.2. UST Temporary and Permanent Closure Requirements.............................................. 26
13. Administrative and Recordkeeping Requirements.......................................................... 27
    13.1. National Computerized Maintenance Management System Records.......................... 27
    13.2. Training......................................................................................................................... 28
    13.3. Maintenance Records and Guides............................................................................... 29
    13.4. Tank Inventory.............................................................................................................. 29
    13.5. Records Retention....................................................................................................... 31
Resources.................................................................................................................................. 32
Related Publications................................................................................................................. 33
                                                                                                                                             A-2
1.   Introduction
  This Desk Guide provides supplemental information to PBS Order 1095.2A “Regulated
  Substances Storage Tank (RST) Management. (“Policy” or “PBS Order 1095.2A”).
  This Desk Guide contains general information on regulatory requirements but the
  information provided is not all inclusive. Users must also consult Federal, state, local
  and jurisdictional governing standards for full requirements.
  In accordance with statutory requirements, federal facilities are required to comply with
  all Federal, state, and local laws and regulations. Where the laws or regulations differ
  from GSA Policy, the more stringent requirement shall be applied. While this document
  does not contain a listing of all Federal, state, and local regulatory requirements
  required for compliance, it incorporates the aspects of the Federal regulations by
  reference, and states GSA specific requirements that may be more stringent than some
  regulations.
2.   Authority
      ● 33 U.S.C.§ 1323, Clean Water Act (CWA), Federal facilities pollution control
      ● 42 U.S.C.§6991 et seq. Regulation of Underground Storage Tanks
      ● International Fire Code (IFC) (provisions pertaining to underground and above
         ground fuel storage tanks)
      ● 40 C.F.R.§112 Oil Pollution Prevention
      ● 40 C.F.R.§280 Technical Standards and Corrective Action Requirements for
         Owners and Operators of Underground Storage Tanks (USTs)
      ● 40 C.F.R.§355 Emergency Planning and Notification
      ● 40 C.F.R.§370 Hazardous Chemical Report; Community Right-To-Know
      ● 41 C.F.R. §102-80 Federal Management Regulations, Safety and Environmental
         Management
      ● National Fire Protection Association (NFPA) codes and standards
3.   Applicability
  This Policy is applicable to aboveground storage tanks (ASTs) and underground storage
  tanks (USTs) of all types, used or previously used, to store regulated substances,
  collectively known as RSTs, as follows:
      ● RSTs installed on GSA controlled Federally owned property where GSA has
         O&M responsibilities. The GSA RST Policy and Desk Guide apply in their
         entirety;
      ● RSTs installed on GSA controlled Federally owned property where GSA does not
         have O&M responsibilities. The GSA RST Policy and Desk Guide apply only to
         the extent that the tanks must meet all applicable Federal, state, and local
         requirements for installation and operation;
      ● RSTs at delegated Federally owned property. The GSA RST Policy and Desk
         Guide apply only to the extent that the tanks must meet all applicable Federal,
         state, and local requirements for installation and operation. Maintenance records
         of these tanks do not have to be stored in the NCMMS;
                                                                                        A-3
      ● RSTs at leased facilities. The GSA RST Policy and Desk Guide do not apply to
         leases unless GSA operates or maintains the RST or it is a requirement per the
         terms of the lease.
  1
   The terms defined herein are for GSA-specific applicability. Refer to listed references for comprehensive lists of
  EPA definitions.
                                                                                                                    A-4
         regulation or related requirements documents issued by a Federal, state, or
         local regulator, GSA, or codes of practice developed by a nationally
         recognized association or organization (e.g. NFPA, IFC), GSA design,
         installation, and operational criteria (e.g. GSA policies and scopes of work, or
         IFC and NFPA codes and standards).
 4.9.   Hazardous Materials. Federal statutes and regulations define this term
         differently. For the purpose of this Order, it is defined as any item that is
         required to have a Safety Data Sheet or is regulated by the Department of
         Transportation (Table 172.101 Hazardous Materials Table, 40 CFR Part 172).
4.10.   Hazardous Substance. Classified as listed and unlisted; (1) listed hazardous
         substances are elements and compounds, and hazardous wastes appearing
         in the table in 40 CFR Part 302.4; and (2) unlisted hazardous substances are
         solid waste, as defined in 40 CFR 261.2, which is not excluded from
         regulation as a hazardous waste under 40 CFR 261.4(b) if it exhibits any of
         the following characteristics: toxicity, ignitability, reactivity, and corrosivity. For
         the purpose of this policy, the term does not include hazardous waste, natural
         gas, natural gas liquids, liquefied natural gas, or synthetic gas usable for fuel
         (or mixtures of natural gas and such synthetic gas).
4.11.   Hazardous Substances Tank System (HST). A storage tank system used or
         previously used to store certain hazardous substances as defined in 42 USC
         § 9601(14). This does not include any substance regulated as a hazardous
         waste under subtitle C of RCRA, or any mixture of hazardous waste and
         petroleum, or petroleum storage tanks.
4.12.   Hazardous Waste. A solid waste, as defined in 40 CFR 261.2 that also meets
         the criteria listed in 40 CFR 260.13.
4.13.   Heating Oil. Petroleum that is No. 1, No. 2, No. 4-light, No.4-heavy, No.
         5-light, No. 5-heavy, and No. 6 technical grades of fuel oil; other residual fuel
         oils; and other fuels when used as substitutes for one of these fuel oils.
         Heating oil is typically used in the operation of heating equipment, boilers or
         furnaces.
4.14.   Owner and Operator. The Federal agency that funded (directly or via RWA)
         the installation and/or operation of a particular RST. The term “operator”
         refers generically to any Federal agency employee(s) or contractor assigned
         the responsibility for the management and operations of a federally owned
         storage tank. Ownership and operatorship are established based on the
         terms of the applicable purchase and occupancy or use agreement.
4.15.   Petroleum. Petroleum, including crude oil or any fraction thereof that is liquid
         at standard conditions of temperature and pressure (60 degrees Fahrenheit
         and 14.7 pounds per square inch absolute). Regulated substance petroleum
         includes but is not limited to petroleum and petroleum-based substances such
         as heating oil, motor fuels, jet fuels, distillate fuel oils, residual fuel oils,
                                                                                            A-5
         lubricants, petroleum solvents, and used oils.
4.16.   Regulated Substance. Any substance defined as a hazardous substance in
         42 USC § 9601(14) and for the purpose of this policy, petroleum.
4.21.   Spill Prevention, Control, and Countermeasures (SPCC) Plan. A written plan
         that details the resources, personnel and procedures in place to prevent and
         control oil spills. An SPCC Plan is required for facilities that store, use, or
         consume oil and have a total aboveground oil storage capacity of more than
         1,320 gallons, or a total UST oil storage capacity of more than 42,000 gallons.
         When calculating SPCC Plan determinations, all aboveground oil storage
         containers with a capacity of 55 gallons or greater should be included.
                                                                                        A-6
                secondarily contained systems, except as provided in 40 CFR
                280.43(g)(2)(iv), any liquid found in the interstitial space not used as part of
                the interstitial monitoring method is immediately removed.
5.    Policy
  GSA owned, installed, or operated RSTs must comply with the latest editions of all
  applicable Governing Standards (i.e., laws, regulations, manufacturers’ manuals,
  national codes and industry standards), and the procedures set forth herein. Where
  laws and regulations differ from the GSA policy, the more stringent requirement must be
  applied.
                                                                                               A-7
5.1.2.   For federally owned space, incorporate in all Occupancy Agreements
          (OA), delegations of authority, or other interagency agreements
          language that requires occupants, delegated agencies, or customers
          to comply with all applicable GSA policies. By reference these
          policies may include applicable Federal, state, and local regulatory
          requirements and the responsibility for the cost of compliance in
          accordance with the Federal Management Regulations (FMR) 41
          CFR part 102-80.40.
5.1.3.   Ensure that RSTs at federally owned facilities comply with all
          applicable Governing Standards (i.e. statutes, and their associated
          Federal, state, and local implementing regulations,applicable IFC and
          NFPA codes and standards, and GSA design, installation, and
          operational criteria (e.g. policies and scopes of work) including but
          not limited to:
   5.1.3.1.   Make proper reporting and notifications to all appropriate
               regulators of any planned and unplanned regulated substance
               tank activities as required by law (e.g. installation, removal,
               spills).
   5.1.3.2.   Install, operate, and maintain aboveground storage tanks
               (ASTs) in accordance with all applicable codes and regulations
               including 40 CFR Part 112 Oil Pollution Prevention. Equip ASTs
               with appropriate secondary containment and when required by a
               governing standard a method of leak detection. Conduct and
               document periodic inspections (e.g., monthly, annual, third party,
               etc.).
   5.1.3.3.   Install, operate, maintain and remove existing underground
               FSTs in accordance with the general requirements for all UST
               systems and requirements for petroleum UST systems as
               published in 40 CFR Part 280 Technical Standards and
               Corrective Action Requirements for Owners and Operators of
               Underground Storage Tanks (USTs) as amended, all other
               applicable governing standards, and this Order.
   5.1.3.4.   Install, operate, maintain and remove all hazardous substance
               tanks in accordance with the general requirements for all UST
               systems, and requirements for hazardous substance UST
               systems as published in 40 CFR Part 280 Technical Standards
               and Corrective Action Requirements for Owners and Operators
               of Underground Storage Tanks (USTs) as amended, all other
               applicable governing standards, and this Order.
   5.1.3.5.   Equip all new and existing underground RSTs with (1) an
               authorized method of continuous leak detection (e.g. automated
               tank gauge, interstitial monitoring, etc.) that can detect a release
               from any portion of the tank and the connected underground
               piping that routinely contains product and (2) spill prevention
               systems that will prevent releases of product into the
                                                                               A-8
             environment due to corrosion, spills, or overfills as authorized by
             a governing standard. See 40 CFR Part 280 subpart D for
             detection options for USTs.
 5.1.3.6.   Calibrate, operate, inspect, test, repair, maintain, and close tank
             systems in accordance with applicable current regulatory
             requirements, manufacturer's instructions, or codes of practice
             developed by a nationally recognized association or
             independent laboratory. Where GSA Preventive Maintenance
             (PM) Guides are the standard, they must be no less protective
             than the standards listed here.
 5.1.3.7.   Upgrade or implement closure procedures for any UST system
             that does not meet the standards of 40 CFR Part 280 Technical
             Standards and Corrective Action Requirements for Owners and
             Operators of Underground Storage Tanks (USTs), as amended,
             and this Order.
 5.1.3.8.   Perform tank repairs, removal, abandonment, or closure by
             qualified licensed contractors.
 5.1.3.9.   Maintain a current inventory and management program that
             encompasses all RSTs located at all GSA-controlled federally
             owned space. For tank systems operated and maintained by
             GSA, the inventory must include pertinent information needed to
             ensure that regulatory compliance elements are properly
             performed and documented. For tank systems in
             GSA-controlled federally owned space that is under an O&M
             delegation, the delegated agency shall maintain tank identifying,
             operational and maintenance information and provide this
             information to GSA on an annual basis as requested.
5.1.3.10.   For GSA operated facilities, maintain all tank operating and
             maintenance records (i.e., tank inventory, reports, monitoring
             records, work orders, and internal and regulatory inspection
             reports, tank registrations, operator training records, etc.) in the
             National Computerized Maintenance Management System
             (NCMMS). Establish and assign job plans and schedules in
             NCMMS to facilitate the performance and tracking of regulatory
             environmental compliance requirements and activities (i.e.
             registration renewal, operator training records, tightness tests,
             repairs, detailed installation and closure records, etc.). To
             provide greater protection against future potential environmental
             liabilities, RST records must be maintained for the life of the
             facility.
5.1.3.11.   Ensure that each GSA-controlled federally owned space
             containing an UST or AST (or both) has GSA and O&M
             personnel designated and trained for each class of UST
             Operator, and who are trained on both UST and AST operations
             and response procedures as required by Federal, state, and
             local regulation, the national Operations and Maintenance
                                                                             A-9
                             (O&M) specification, and GSA policies. Training required for
                             GSA and vendor personnel is the responsibility of the respective
                             employing entity.
                5.1.3.12.   Develop, document, and maintain the appropriate level of
                             site-specific spill prevention and control procedures in
                             accordance with Federal, state, and local regulation and as
                             required in the national O&M specification or this Order,
                             whichever is more stringent.
                5.1.3.13.   Make reasonable accommodations to comply with Federal,
                             state, or local regulators requests for tank related information or
                             to access GSA-controlled space for the purpose of conducting
                             compliance inspections.
                5.1.3.14.   Complete Emergency Planning and Community Right-to-Know
                             Act (EPCRA) notifications and reporting requirements in
                             accordance with applicable sections of Title 40 CFR, Parts 68,
                             350, 355, 370 and 372.
                5.1.3.15.   Upon discovery, clean up spills and report releases to
                             appropriate authorities as required by Federal, state and local
                             regulators.
                5.1.3.16.   Make internal and external notification of releases and other
                             RST-related events in accordance with the GSA Risk
                             Management Notification Policy (PBS 2400.1) and as required
                             by the Office of Mission Assurance (OMA)/PBS managed
                             Facility Event Notification System (FENS) [OMA Order 2400.2
                             as amended].
  This desk guide and associated Policy (PBS 1095.2A) highlight some of the key
  functions necessary to ensure compliance with Federal RST requirements. As state
  and local regulations can be more stringent than the Federal requirements, it is the
  responsibility of staff to determine all requirements applicable to their facilities. While
  many of the operational functions are performed by O&M Contractors, it is ultimately
  GSA’s responsibility to ensure that operations are compliant. The listed office names
  and roles for the respective responsibilities are meant to serve as guidance and may
  vary by office.
      6.1.   Office of Facilities Management (OFM) Facilities Risk Management Division
              6.1.1.   Develop, issue, and provide updates to the regulated storage tank
                        (RST) management policy and procedures.
              6.1.2.   Provide technical assistance to Building Managers.
              6.1.3.   Evaluate performance relative to RST management requirements as
                        part of the established tank program quality control process.
              6.1.4.   Support Environmental staff with matters related to RST 
                        Management.
                                                                                           A-10
        6.1.5.   Develop and provide RST training materials for use by PBS
                  employees.
        6.1.6.   Monitor the National RST Program for inventory completeness and
                  environmental compliance tracking using data collected in the
                  NCMMS.
        6.1.7.   Monitor tank program performance via analyses of tank information
                  maintained in NCMMS and gathered as part of the Risk Management
                  (RM) Program Assessments and the Facilities Management
                  Assessment Survey Program.
6.2.   OFM Office of Technology & Innovation
        6.2.1.   Deploy, maintain, and support GSA’s Smart Building technology
                  framework including the National Computerized Maintenance
                  Management System (NCMMS).
        6.2.2.   Maintain the NCMMS to accommodate storage of RST records and
                  job plans needed to meet monitor regulatory and GSA RST
                  requirements.
6.3.   OFM Office of Facilities Operations
        6.3.1.  In conjunction with the Office of Mission Assurance (OMA), develop
                 internal reporting procedures for emergency notifications.
        6.3.2. Coordinate internal release reporting with Building Operators,
                 Property Management Community, and/or Client
                 Agencies/Operators.
        6.3.3. Record and disseminate reported incident data.
        6.3.4. Ensure that O&M master specification incorporates RST
                 requirements. Owns and maintains GSA’s Service Contract Master
                 Specifications, which include NCMMS usage requirements for its
                 service Contractors.
           6.3.4.1. Owns and maintains the GSA Preventive Maintenance Guide
                       (PM Guide) process used in NCMMS to schedule and issue
                       maintenance work orders.
           6.3.4.2. Monitors NCMMS effectiveness in achieving PBS’s goals using
                       the Management Analysis Review System (MARS) which
                       includes review of NCMMS data to evaluate overall program
                       compliance and effectiveness of internal management controls.
           6.3.4.3. Ensure that all delegation agreements include language that
                       requires compliance with all applicable policies and regulations.
6.4.   Office of Architecture and Engineering
        6.4.1.   Ensure that all issued policies and guidance documents involving
                  RSTs include language that requires compliance with applicable RST
                  policies and regulations.
        6.4.2.   For projects that involve major RST activities such as installation, and
                  replacement; provide relevant subject matter expertise to support
                                                                                     A-11
                  business lines in providing quality assurance over architecture and
                  engineering related design work. Coordinate with the Office of Project
                  Delivery to ensure standardized criteria for Scopes of Work (SOWs)
                  and Independent Government Estimates (IGEs) are developed and
                  implemented to support project team activities in all phases of project
                  delivery.
6.5.   Environmental, Health, Safety & Fire Community
        6.5.1.   Provide technical support to the Building Operations and Property
                  Management Communities in determining compliance status,
                  notification and reporting requirements, and developing plans and
                  scopes of work.
        6.5.2.   Determine and communicate applicable Federal, state and local
                  requirements to staff.
        6.5.3.   Maintain comprehensive knowledge of environmentally regulated
                  RST related activities wide.
        6.5.4.   Routinely monitor tank program performance for compliance with this
                  policy and regulatory requirements. Conduct inspections and audits
                  of regulated storage tank records no less than every two years to
                  assess compliance with GSA policy and environmental regulations.
                  Monitor the RST inventory for accuracy and environmental
                  compliance tracking at least annually.
        6.5.5.   Develop and implement locality-specific training programs for staff as
                  necessary to enhance their understanding of regulatory requirements
                  and best practices related to storage tank management.
        6.5.6.   Assign and monitor RST related Conditions in the Facilities
                  Management Assessment (FMA) Module for corrective actions to be
                  taken.
        6.5.7.   Continuously assess and update procedures related to regulated
                  storage tanks to reflect changes in regulations and industry best
                  practices.
6.6.   Building Operations / Property Management Community
        6.6.1.   Comply with the GSA RST Policy and perform other RST tasks listed
                  in this section based on locally designated responsibility assignment.
        6.6.2.   Monitor the RST inventory in the NCMMS for completeness and
                  accuracy at least annually.
        6.6.3.   Coordinate with the EHSF staff and O&M to ensure proper
                  notifications are made to applicable regulatory agencies (e.g.,
                  installation, closure, release, removal/closure, and Emergency
                  Planning and Community Right-to-Know Act [EPCRA] reporting or
                  state equivalent) and maintain the documentation in accordance with
                  this desk guide.
        6.6.4.   Ensure that GSA and O&M personnel are designated and trained for
                  both operator and site-specific spill response.
                                                                                    A-12
         6.6.5.   Coordinate the development and maintenance of SPCC Plans or
                   other spill plans as appropriate to the locations’ RST risks.
         6.6.6.   Ensure that contract scopes of work and work performed by
                   contractors complies with GSA’s RST Policy and regulatory
                   requirements.
         6.6.7.   Coordinate internal GSA release reporting in accordance with the
                   Risk Notification Policy and the Facility Event Notification System
                   (FENS).
         6.6.8.   Request funds for any corrective actions needed to achieve and
                   maintain compliance with RST policies and regulations.
         6.6.9.   Monitor operators’ performance for compliance with this policy and
                   regulatory requirements.
        6.6.10.   Assign and monitor RST related risk conditions in the Facilities
                   Management Assessment (FMA) Module in the Inventory Reporting
                   Information System (IRIS) to ensure correct actions are taken.
        6.6.11.   Maintain records and documentation in accordance with this Policy
                   and desk guide.
6.7.     O&M Contractors
         6.7.1.   Comply with the terms and conditions of their contract related to tank
                   related regulatory compliance and operational requirements, and
                   applicable requirements of GSA policies and desk guides.
         6.7.2.   Develop and maintain a current RST inventory in the NCMMS for all
                   tanks located in GSA controlled space, except for buildings where the
                   O&M has been delegated to another Federal agency.
         6.7.3.   Make proper notifications to applicable regulatory agencies (e.g.,
                   installation, closure, removal, release, and Emergency Planning and
                   Community Right-to-Know Act [EPCRA] reporting or state equivalent)
                   and maintain documentation in accordance with the terms of the
                   contract, this policy and desk guide.
         6.7.4.   Ensure that O&M personnel are designated and trained for both
                   operator and site-specific spill response.
         6.7.5.   Coordinate the development and maintenance of the SPCC Plan or
                   other spill plans as appropriate to the facility’s RST risks.
         6.7.6.   Ensure work performed complies with GSA’s RST Policy and
                   regulatory requirements.
         6.7.7.   Coordinate internal GSA release reporting in accordance with
                   protocol, the Risk Notification Policy and the Facility Event
                   Notification System (FENS).
         6.7.8.   Inform the COR and Building Manager of projects or any corrective
                   actions needed to achieve and maintain compliance with RST
                   policies and regulations.
         6.7.9.   Take appropriate corrective actions when assigned to mitigate RST
                   related Risk Conditions in the FMA Module of IRIS.
        6.7.10.   Maintain records and documentation in accordance with this Policy
                   and desk guide.
                                                                                    A-13
6.8.   Acquisitions Teams
        6.8.1.   Operations Division/Service Center Division, in conjunction with the
                  Building Management Team and Environmental Staff: Ensure that all
                  tank related performance, training and other deliverables are
                  included in the O&M contract statement of work (SOW).
        6.8.2. Office of Project Delivery
           6.8.2.1. The Center for Cost, Schedule, and Tools develops policies and
                     best practices for all independent government estimates and
                     scheduling activities.
           6.8.2.2. The Center for Construction Excellence provides guidance
                     and/or policy on SOW development, project management best
                     practices, and Risk Management for projects to ensure
                     compliance and effective execution.
                                                                                    A-14
                6.9.2.   Facilitate communications as necessary between GSA and client
                          agencies relative to RST concerns.
                6.9.3.   Coordinate with Building Managers and individuals who manage the
                          RST program to identify and prioritize large, tank-related projects that
                          should be included in long term asset planning discussions.
                6.9.4.   Engage with the EHSF community as needed to review proposed
                          RST related projects for priority consideration and EHSF regulatory
                          compliance.
      6.10.     Office of Leasing
               6.10.1.   Ensure that the terms and conditions of all new agreements (Leases
                          and OAs) include language that requires compliance with all
                          applicable GSA policies.
                                                                                             A-15
 8.   RSTs at GSA Leased and Delegated Properties
   Lessors and agencies with delegated O&M authority are required to comply with all
   applicable RST Federal, state, and local jurisdictions’ regulatory requirements. GSA
   shall ensure that language mandating compliance with regulatory requirements is
   included in leases and delegation agreements. If language in the agreement is not
   specific to RSTs, it must clearly state that operations will be conducted in compliance
   with all applicable regulations and GSA policies.
                                                                                                     A-16
          ○ When a new non-petroleum HST is needed and where regulations allow,
             and based on the intended use, preference should be given to
             replacements in the following order (1) double walled AST; concrete
             vaulted AST or subterranean AST; and (2) UST (double-walled fiberglass
             reinforced plastic).
10.1.    ASTs
         10.1.1.   Installation
 AST design, installation and operation shall be conducted in accordance with 40
 CFR 112.12 (a)-(c) and all applicable industry standards and local codes, including
 applicable rules set forth in the following publications: Occupations Safety and
 Health regulations (29 CFR 1926.152(i)), National Fire Protection Association
 (NFPA) 30, 30A, 31 and 704, International Fire Code (IFC) and other applicable
 standards; see the Related Publications listed in this Desk Guide for additional
 applicable standards and codes. NFPA rules cover installation and operation
 standards for storage tanks, oil handling systems, and oil burning equipment.
 Installed ASTs must be certified to meet Underwriters Laboratory (UL) Standard
 2085 and include a manufacturer’s warranty. State and local regulatory agencies
 may have specific installation requirements; consult with these agencies to
 determine additional requirements, if any.
                                                                                   A-17
     10.1.2.     Operations and Maintenance
ASTs are required by GSA to include spill and overfill protection, release detection,
secondary containment protection and corrosion protection as needed. Written
procedures must also be in place for testing and inspecting ASTs and conducting
tank repairs. Consult the state agency for specific AST O&M requirements.
        10.1.2.1.     Designated point of contact. Someone at each facility must be
                       designated in writing who is responsible for discharge
                       prevention.
        10.1.2.2.     Spill and Overfill Protection. Follow tank management standards
                       (e.g., American Petroleum Institute) and include a secondary
                       containment area for visual detection of spills and leaks. Where
                       dictated by oil storage capacity, the facility must have a SPCC
                       Plan prepared.
        10.1.2.3.     Secondary Containment. At a minimum, one of the following
                       prevention systems, or its equivalent, must be used as a means
                       of secondary containment:
                       ● Open secondary containment walls;
                       ● Closed secondary containment (for double-walled tanks);
                       ● Dikes, berms, or retaining walls sufficiently impervious to
                           contain oil;
                       ● Curbing or drip pans;
                       ● Sumps and collection systems (only with Professional
                           Engineer approval);
                       ● Culverting, gutters, or other drainage system (only with
                           Professional Engineer approval);
                       ● Spill diversion ponds or retention ponds (only allowed with
                           Professional Engineer approval).
        10.1.2.4.     Testing and Inspections. Test and inspect aboveground RSTs
                       on a routine basis and when repairs are made. The frequency
                       is commonly defined by the state and local governing authority
                       or the SPCC Plan. In the absence of an established frequency,
                       Tanks shall be tested or inspected by a third-party at least every
                       three (3) years.
                       Per 40 CFR 112.8(c)(6), examples of integrity tests include, but
                       are not limited to: visual inspection, hydrostatic testing,
                       radiographic testing, ultrasonic testing, acoustic emissions
                       testing, or other systems of non-destructive testing.
                10.1.2.4.1.   Industry standards must be used to determine the
                               qualifications of persons performing the test and type of
                               test or inspection. Third-party inspectors must be trained
                               in the state-specific inspection protocols and perform
                               inspections that meet these standards. Where a state
                                                                                     A-18
                               third-party program exists, training must be comparable
                               to the training required for state inspectors.
                               Possible sources of training and certification may include
                               Standards Developing Organizations such as the
                               American Petroleum Institute, Petroleum Equipment
                               Institute, Steel Tank Institute, state regulatory agencies,
                               and state sanctioned third-party private sector inspection
                               companies.
                10.1.2.4.2.   In-house visual inspections
                               are required to be conducted
                               and documented by O&M
                               contractors for all RSTs
                               monthly (i.e. every 30-days).
                               During these inspections,
                               look for signs of leaks, stress fractures, stressed
                               vegetation, visible water in the secondary containment
                               area and proper tank labeling/marking (EPA, NFPA,
                               OSHA Hazard Warnings, etc.). Inspections must be
                               documented in accordance with the recordkeeping
                               requirements described below and the PM and Job Plans
                               within NCMMS.
          10.1.2.5.   Tank Repairs. All tank repairs must be performed by qualified
                       contractors who are certified to make repairs to the specific
                       equipment they are repairing, in accordance with the tank
                       warranty. Consult the state agency for specific tank repair
                       reporting requirements. Note: Reporting requirements differ for
                       facilities that are covered by a SPCC Plan.
10.2.   USTs
         10.2.1 Installation
 New UST systems must be installed in accordance with Federal, state, and local
 requirements, industry codes and standards, and manufacturer’s instructions. All
 tanks must be designed, constructed and installed by licensed and certified installers
 in accordance with all applicable parts of 40 CFR 280.20. USTs must be UL
 Certified and carry a manufacturer’s warranty. UST installation and operation must
 also comply with applicable NFPA and IFC codes and industry standards. This
 includes, but is not limited to, spill and overfill control, corrosion protection, release
 detection, and secondary containment.
 The preferred type of UST is a double-walled fiberglass reinforced plastic (FRP)
 tank. The tank and all ancillary equipment must be compatible with the substance to
 be stored in the tank (40 CFR 280 32). In addition to meeting the requirements for
 all USTs (40 CFR 280.40), FSTs must also meet the requirements of 40 CFR
 280.41, and in accordance with GSA’s RST Policy (PBS Order 1095.2A), be
                                                                                      A-19
equipped with interstitial monitoring and an automatic tank gauge (ATG) system.
Hazardous Substance Tanks must meet the additional requirements listed in 40 CFR
280.42.
USTs that were previously installed (existing tanks) must comply with one of the
upgrade options found in 40 CFR 280.21. Options for continued use of existing
USTs:
      ● Replace with a new UST that meets the performance standards under §
         280.20;
      ● Upgrade in accordance with the requirements in paragraphs (b) through
         (d) of 280.21; or
      ● Permanently Close the tank in accordance with requirements under
         subpart G of Part 280, including applicable release response and
         corrective action requirements under Subpart F of 40 CFR 280.
                                                                                     A-20
                 ● Test cathodic systems within six (6) months of installation
                    and every three (3) years thereafter by a qualified inspector;
                 ● Inspect impressed current cathodic protection system every
                    60 days; and
                 ● Maintain records to demonstrate compliance in NCMMS.
    10.2.1.3.   Release Detection (40 CFR 280 Subpart D). All tank systems
                 must meet the leak detection general requirements applicable to
                 all USTs in 40 CFR 280 Subpart D. In addition to the general
                 requirements, FSTs must meet the leak detection requirements
                 for petroleum tanks (40 CFR 280.41) and hazardous
                 substances tanks must meet the additional requirements found
                 in 40 CFR part 280.42. Any UST system that cannot comply
                 with the release detection requirements of this regulation must
                 complete the closure procedures in subpart G of this subpart.
         10.2.1.3.1.   All Regulated Substance Tanks must meet the
                        requirements of the GSA Policy and based on the
                        product to be stored, the applicable section of 40 CFR
                        280.41. Each tank system must include an ATG to
                        monitor for releases. Other methods can be used in
                        conjunction with an ATG if the method can detect a
                        release from any portion of the tank and the connected
                        underground piping. The methodology used must detect
                        releases from any portion of the UST system that
                        contains product, and must be installed, calibrated,
                        operated, and maintained as specified in the
                        manufacturer’s instructions.
                                                                               A-21
                      Table 1: UST System Release Detection Methods
                 Type of
                 Release                                                           New    Existing
Component                              Release Detection Description
                Detection                                                         Tanks    Tanks
                Monitoring
                 Inventory
                                GSA Policy requires USTs to be equipped
                  Control,
                                with ATGs. Therefore, these methods should
                Manual Tank
                                only be used in conjunction with or as backup      X         X
                Gauging, and
                                monitoring/testing or when the ATG is not
                 3 YEARS
                                performing to standard.
                  Testing
                                New and existing USTs are required to be
                                equipped with ATGs. Equipment for
                                automatic tank gauging must meet the
                                requirements in (40 CFR 280.43(d)):
                                 (1)Must detect a 0.2 gallon per hour leak
                 Automatic
                                     rate from any portion of the tank that
                   Tank                                                            X         X
                                     routinely contains product; AND
                 Gauging
                                (2)Inventory control must detect a release of
                                    at least 1.0 percent of flow through plus
                                    130 gallons monthly. AND
                                (3)Tests must be run in an approved
   USTs                             operating mode.
  (40 CFR         Vapor         Only use when testing or monitoring for
 280.41-43)                                                                        X         X
                 Monitoring     suspected releases (40 CFR 280.43(e)).
                                                                                                     A-22
              Type of
              Release                                                         New    Existing
Component                          Release Detection Description
             Detection                                                       Tanks    Tanks
             Monitoring
                           (2) Monthly monitoring methods such as
                                vapor monitoring, groundwater monitoring,
                                interstitial monitoring, or other approved
                                methods.
                            NOTE: No release detection is required for
                            suction piping if it is designed and
                            constructed to meet the requirements of 40
                            CFR 240.41(b)(II).
                                                                                                A-23
                              nationally recognized association codes or practices, or
                              independent testing laboratory;
                           ● Replace metal pipe sections and fittings that have corroded or been
                              damaged and resulting in a release (fiberglass pipes and fittings
                              may be repaired in accordance with the manufacturer's
                              specifications).
                           ● Performed tank and piping tightness testing within 30 days of
                              repairs; and
                           ● Tested cathodic protection on a repaired tank system within 6
                              months of completing repairs.
                                                                                                A-24
         11.1.3.   SPCC Plans must be reviewed and evaluated at least every five
                    years and amended to include more effective field-proven control or
                    prevention technologies if they exist at the time of the review. In
                    accordance with EPA regulations, the signed statement can be
                    placed either at the beginning or end of the Plan or in a log or an
                    appendix to the Plan. The following words will suffice, “I have
                    completed review and evaluation of the SPCC Plan for (name of
                    facility) on (date) and will (will not) amend the Plan as a result.”
                    Plans must also be amended whenever there is a change in the
                    facility design, construction, operation, or maintenance that affects
                    the potential for an oil release (40 CFR 112.5). Completion of the
                    plan review must be documented and can be satisfied by a signed
                    statement as to whether the plan will be amended. Amendments
                    must be made within six months of either of the aforementioned
                    events. The SPCC Plan shall be tracked and maintained in the
                    Certificate Module of the NCMMS.
11.2.    Release Reporting
 When a release from an RST system occurs, GSA designated personnel or
 representatives shall implement the site-specific spill response actions and initiate
 internal notification procedures. Releases include but are not limited to suspected
 releases (40 CFR 280.50), overfills and spills (40 CFR 280.53), and confirmed
 releases (40 CFR 280.61); In addition, personnel shall refer to the GSA Risk
 Management Notification Policy (PBS 2400.1) for GSA Risk Management
 Notification requirements.
         11.2.1.   Internal Release Reporting
                    In the event of a suspected release, overfill and spill, and/or
                    confirmed release, on-site or field office personnel shall notify EHSF
                    Managers at the time of discovery. EHSF Managers shall inform the
                    GSA Risk Management Division of any releases subject to external
                    reporting within 24 hours of discovery. Additional notifications
                    include:
                       ● The appropriate regulatory authorities as described below in
                          External Release Reporting;
                       ● The Office of Mission Assurance; and
                       ● The Office of Architecture and Engineering. To aid in updates
                          to the Building Information Modeling, asset and site-specific
                          drawings, and planning for future project delivery.
         11.2.2.   External Release Reporting
              Federal, state and local authorities may need to be notified if a spill or
              release meets certain criteria, including:
                                                                                           A-25
                ● EHSF Managers are responsible for assisting in determining if a release
                   must be reported to external authorities and provide guidance on
                   appropriate response activities.
                ● If your facility releases a hazardous substance (equal to or in excess of a
                   reportable quantity (refer to 40 CFR 302.4) or an extremely hazardous
                   substance (EHS) call the National Response Center (1-800-424-8802)
                   within 24 hours. The threshold planning quantity for fuel is typically
                   10,000 pounds (40 CFR 355.30),
                ● For releases of an EHS over the threshold planning quantity, also notify
                   the state emergency response commission (SERC), local emergency
                   planning committee (LEPC), and local fire department.
                ● Facilities covered by a SPCC Plan must also report the following:
                       - If your facility releases more than 1,000 gallons of oil in a single
                           discharge, contact the Environmental Protection Agency (EPA)
                           Regional Administrator within 60 days.
                       - If your facility releases more than 42 gallons of oil in two discharges
                           within any 12-month period, contact the EPA Regional
                           Administrator within 60 days.
                       - For either of the above SPCC Plan incidents, the EPA Administrator
                           may require that the SPCC Plan be amended.
                                                                                            A-26
         below are highlights of the requirements that must be performed during temporary
         and permanent closure. Refer to the cited reference for the full list of requirements.
Initial UST Temporary Closure Activities (up to 12 Months) Permanent UST Closure
      Continue O&M of corrosion             Complete all activities required for      Permanently close the UST if it
       protection; AND                        0-3 months. AND                            does not meet the new UST
      If tank is NOT empty                  Leave vent lines open and                  system performance
       -Continue operation of release         functioning; and                           requirements; OR
        detection; and                       Cap and secure all other lines,           Upgrade the UST to new
       -Report all suspected or confirmed     pumps, manways, and ancillary              standards or replace it with
        releases.                             equipment.                                 compliant UST.
         The following are some steps that may be required to permanently close an UST:
                ● Notify appropriate regulatory authorities at least 30 days before permanent
                   closure;
                ● Assess closure site for potential contamination;
                ● Empty and clean tank of all liquids and sludge;
                ● Remove tank from ground or fill tank with an inert solid; and
                ● Maintain closure documentation.
         In addition to the administrative records and work orders that are maintained in the
         NCMMS, some records associated with SPCC Plans or other release prevention and
         response plans, transfer procedures or signage, must also be readily available
         outside of the NCMMS as necessary such as the posting of signs on tanks. The
         Building Manager and COR are required to ensure that O&M vendor performs
         maintenance tasks and develops records specific to the tanks that they manage, and
         for verifying that the required data is maintained in the NCMMS.
                                                                                                                     A-27
 13.2.   Training
   Records verifying completion of training or retraining for GSA and O&M vendor staff
   must be maintained in the NCMMS Certificates Module. The records, at a minimum,
   must identify the name of trainee, date trained, training topic, operator training class
   completed, the name of the trainer or examiner and the training company name,
   address, and telephone number. If applicable, state specific training guidelines are
   available by contacting GSA Environmental Program Managers.
   Properties with GSA owned or operated USTs must also have O&M contractor
   personnel designated for each class of UST Operator. All UST Operators must
   successfully complete the appropriate operator training for their assigned operator
   class, as prescribed by the EPA in 40 CFR 280 Subpart J. Operator training must be
   evaluated via examination or practical demonstration. Based on the operator class,
   topics may include discussions on financial responsibility, familiarity with building,
   state and local emergency response procedures. (e.g., release notification, product
   transfer, overfill, shutoff, release response, SPCC Plan, etc.), product compatibility,
   recordkeeping, and various aspects of operations and maintenance. Training must
   meet the requirements of 40 CFR 280.242 listed below:
All AST operators (typically oil-handling personnel) must be familiar with their
site-specific filling and spill response procedures including:
                                                                                      A-28
          ● General facility operations; AND
          ● If the facility is subject to the requirements of a SPCC Plan, personnel
             must be trained on release prevention topics in accordance with 40 CFR
             112.7 (f); and
                  ○ Contents of the SPCC Plan; and
                  ○ Annual briefings to ensure understanding of the SPCC Plan.
                                                                                       A-29
                     Table 3. Required Tank Inventory data points and Attributes in NCMMS
                                                                                                                     A-30
                                 Where is the tank located? Penthouse, basement,
 Location                                                                                        Asset Tab / Review Details
                                 tank room, garage, outside, etc. (pick-list)
         AST Operation Records                   State/Local Retention Requirement             PBS Records Retention Requirement
                                                                                         Destroy 30 years after the end of FY in
Corrosion Protection Equipment Operations;
                                           Dependent on state/local regulations; consult which the record was created or 10
 AST System Repairs; Tank Closure, and
                                              with appropriate governing agencies        years after the building is disposed of,
   other Operation Records as required
                                                                                         whichever date is sooner.
    AST Release Detection Records                State/Local Retention Requirement                    GSA Policy Requirement
                                                                                                                          A-31
                                                                                       transferred, closed, or otherwise
                                                                                       disposed of. Transfer to NARA 15 years
                                                                                       after cutoff.
                                                                                       Destroy 30 years after the end of FY in
                                                                                       which the record was created or 10
Sampling, Testing, or Monitoring Results                    1 Year
                                                                                       years after the building is disposed of,
                                                                                       whichever date is sooner.
                                                                                       Destroy 30 years after the end of FY in
Calibration, Maintenance, and Repair of
                                                                                       which the record was created or 10
     Release Detection Equipment                            1 Year
                                                                                       years after the building is disposed of,
             Documentation
                                                                                       whichever date is sooner.
                                                                                       Destroy 30 years after the end of FY in
Required Calibration and Maintenance
                                                                                       which the record was created or 10
 Schedules (provided by the release                        5 Years
                                                                                       years after the building is disposed of,
 detection equipment manufacturer)
                                                                                       whichever date is sooner.
Resources
   Underground Storage Tanks (USTs); Installation and Design;   Technical Standards and Corrective Action Requirements for
   Operating Requirements; Corrosion Protection, Repair and     Owners and Operators of Underground Storage Tanks (UST)
   Release Reporting; Release Detection, Recordkeeping,
   Temporary and Permanent Closure                              (40 CFR Part 280)
                                                                                                                 A-32
Related Publications
The following list of publications includes standards applicable to the installation, operation and maintenance, and
decommissioning of RSTs.
Statutes
1. The Oil Pollution Act (OPA) of 1990; 33 U.S.C. 2702 et seq..
2. CWA; 33 U.S.C. § 1251 et seq. (1977).
3. RCRA; 42 U.S.C. § 321 et seq. (6901).
Executive Orders
1. RP 545 – Recommended Practice for Lightning Protection of Aboveground Storage Tanks for Flammable or
    Combustible Liquids.
2. RP 574 – Inspection Practices for Piping System Components.
3. RP 575 – Inspection of Atmospheric and Low Pressure Storage Tanks.
4. RP 1604 – Closure of Underground Petroleum Storage Tanks.
                                                                                                               A-33
5. RP 1615 – Installation of Underground Petroleum Storage Tanks.
6. RP 1621 – Bulk Liquid Stock Control at Retail Outlets.
7. RP 1632 – Cathodic protection of underground petroleum storage tanks and piping systems.
8. RP 2003 – Protection against Ignitions Arising out of Static, Lightning and Stray Currents.
9. RP 2350 – Overfill Protection for Storage Tanks in Petroleum Facilities.
10. STD 510 – Pressure Vessel Inspection Code (Maintenance Inspection Rating Repair and Alteration).
11. STD 650 – Welded tanks for oil storage.
12. STD 653 – Tank Inspection, Repair, Alteration, and Reconstruction.
13. STD 1631 – Interior Lining and Periodic Inspection of Underground Storage Tanks.
14. STD 2000 – Venting Atmospheric and low-pressure storage tanks.
15. STD 2015 – Requirements for Safe Entry and Cleaning of Petroleum Storage Tanks.
16. Publication 327 – Aboveground Storage Tank Standards: A Tutorial.
17. Publication 334 – A Guide to Leak Detection for Aboveground Storage Tanks.
18. Publication 910 – Digest of State Boiler, Pressure Vessel, Piping and Aboveground Storage Tank Rules and
     Regulations.
19. Publication 1571 – Diesel Fuel—Questions and Answers for Highway and Off-Highway Use.
20. Publication 1628 – A Guide to the Assessment and Remediation of Underground Petroleum Releases.
21. Publication A1632S – Cathodic Protection of Underground Petroleum Storage Tanks and Piping Systems.
22. Spec 12P – Specifications for Fiberglass Reinforced Plastic Tanks.
1. STI P3 – Specification and Manual for External Corrosion Protection of Underground Steel Storage Tanks.
2. STI F894 – Act-100® Specification for External Corrosion Protection of FRP Composite Steel USTs.
3. STI F921 – F921 Standard for Aboveground Tanks with Integral Secondary Containment.
4. STI F941 – Standards for Fireguard® Thermally Insulated Aboveground Storage Tanks.
5. STI F961 – ACT-100U Specification for External Corrosion Protection of Composite Steel Underground
    Storage Tanks.
6. STI SP001 – Standard for Inspection of In-Service Shop Fabricated Aboveground Tanks for Storage of
    Combustible and Flammable Liquids.
7. STI SP031 – Standard for Repair of In-Service Shop Fabricated Aboveground Tanks for Storage of
    Combustible & Flammable Liquids.
8. STI R821 – sti-P3 Installation Instructions.
9. STI R891 – RP for Hold Down Strap Isolation.
10. STI R892 – RP for Corrosion Protection of Underground Piping Networks Associated with Liquid Storage and
     Dispensing Systems.
11. STI R912 – Installation Instructions for Shop Fabricated Aboveground Storage Tanks for Flammable,
     Combustible Liquids.
12. STI R913 – Act-100 Installation Instructions.
13. STI R942 – Fireguard Installation & Testing Instructions for Thermally Insulated, Lightweight, Double Wall
     Fireguard Aboveground Storage Tanks.
                                                                                                              A-34
14. STI R971 – ACT-100-U® Installation Instructions.
15. STI R972 – RP for the Addition of Supplemental Anodes to sti-P3® USTs.
1. UL Standard 125 – Flow Control Valves for Anhydrous Ammonia and LP-Gas.
2. UL Standard 142 – Standard for Safety for the Aboveground Storage of Flammable and Combustible Liquids.
3. UL Standard 971 – Nonmetallic Underground Piping for Flammable Liquids.
4. UL Standard 1316 – Standard for Safety Glass-Fiber-Reinforced Plastic Underground Storage Tanks for
    Petroleum Products.
5. UL Standard 1746 – Standard for Safety: External Corrosion Protection Systems for Steel Underground
    Storage Tanks.
6. UL Standard 2085 – Standard for Safety Protected Aboveground Tanks for Flammable and Combustible
    Liquids.
A-35