Key Definitions
- TIUGA: Tank In an UnderGround Area
- SPCC Plan: Spill Prevention, Control, & Countermeasure Plan
- APSA: California Aboveground Petroleum Storage Act
- CERS: California Environmental Reporting System
Do I have a TIUGA?
- Under APSA, a TIUGA applies to tanks or other containers with a volume of 55 gallons or more.
- These tanks or containers are used to store petroleum or other regulated liquids. See below for regulated liquids.
- The storage tanks or containers are located on a floor and in a structure with at least 10 percent of that floor height below the ground surface.
- Below ground surfaces include, but are not limited to, a basement, cellar, shaft, pit or vault.
What type of liquids are regulated under TIUGA?
- Petroleum Fuel (gasoline, diesel, fuel oil, kerosene, etc)
- Hazardous Waste
- Lubricant (new or used motor oil, automatic transmission fluid, hydraulic fluid)
- Petroleum based Coolant (new or used)
Aboveground Petroleum Storage Act Program
- Effective July 1, 2018, tanks in an underground area (TIUGA) are subject to APSA.
Examples of TIUGA:
- Emergency Generator with a Diesel Day Tank or Diesel Subbase (Belly) Tank that is below grade.
- Emergency Generator with a Diesel Day Tank or Diesel Subbase (Belly) Tank that is below grade and has a AST supply tank located at any level.
- Fire Pump with a Diesel Day Tank
- Oil-filled Operational or Manufacturing Equipment (Hydraulic Lift Elevator with a Hydraulic Oil Storage Tank, oil-cooled transformer, etc.)
- Service Station with underground fuel tanks in a concrete vault
- Partially buried tank system that is less than 10 percent below the ground surface and situated on or above the surface of the floor. Note: a buried tank and piping system that is at least 10 percent below the ground surface is regulated as a UST.
- A TIUGA with less than 55 gallons of petroleum capacity may be regulated under APSA. See Exempt from TIUGA for more details.
Exempt from TIUGA:
- Emergency Generator with a day tank below grade that has a UST supply tank.
- A tank facility with a TIUGA with less than 55 gallons of storage capacity of petroleum, has secondary containment, is inspected monthly, and the owner or operator maintains a log of inspection records for review by the UPA upon request.
Converting from a UST to a TIUGA:
- A previously designated UST that is now designated as a TIUGA can be closed in CERS by selecting ‘Permanent Closure Onsite’. Note in CERS ‘This tank has been determined to be a Tank in Underground Area (TIUGA). According to APSA this tank will no longer will be regulated as a UST effective with the date of this submittal.’
What must I do?
- Obtain applicable permits
- Allow for direct viewing of the exterior of the tank except for the part of the tank in contact with the surface of the floor.
- Provide sufficient secondary containment for the volume of the contents of the tank, piping, and ancillary equipment.
- Provide applicable reporting to California Environmental Reporting System (CERS)
- Satisfy the requirements for a Spill Prevention, Control, and Countermeasure (SPCC) Plan
- Conduct periodic inspections of each TIUGA
- Comply with current Federal SPCC regulations found in 40 CFR 112
How often should I perform a TIUGA inspection?
- Written inspections need to be performed monthly.
- A comprehensive written inspection needs to be performed annually.
What should look for during a typical TIUGA monthly inspection?
- Are they any visible leaks around the tank and piping system?
- Is there a visible leak inside the tank interstitial in any other other containment areas?
- Does the tank level gauge work properly?
- Is overfill prevention equipment (overfill mechanical valves, solenoid valves, visual and audible alarms, etc.) working correctly?
- Is there any sign of corrosion or damage to the tank and piping system?
- Is the spill containment clean, free of any liquids and appear to be liquid-tight?
- Are drain valves closed?
For additional support you can contact our Professional Engineering consulting staff at Pacific Petroleum.


