Oregon Fuel Tank Compliance: UST, AST & DEQ Regulations Explained

Oregon’s fuel tank regulatory structure is deceptively straightforward — until you start reading the details.

On the surface, the Oregon Department of Environmental Quality (DEQ) administers an EPA-approved state UST program under OAR Chapter 340, Division 150. The testing requirements closely mirror federal standards. If you’re familiar with EPA 40 CFR 280, you’ll recognize most of the tests.

But Oregon adds layers that catch facility owners off guard: a mandatory licensed tester requirement, $325 per tank annual fees, 24-hour failure reporting, and an AST permit threshold that’s lower than the federal SPCC trigger. Miss any of these, and you’re looking at penalties up to $12,000 per violation — or worse, a pulled registration certificate that shuts down fuel delivery to your facility.

This guide breaks down every Oregon-specific fuel tank regulation, explains where Oregon exceeds federal requirements, and maps out the testing calendar your facility needs to follow. If you want the short version, run your facility through Compliance Genius — select Oregon as your state and get a personalized compliance map in under 2 minutes.


Federal Regulations Apply First

Before getting into Oregon-specific requirements, remember: federal regulations form the floor. Oregon adds requirements on top.

For Oregon facilities with fuel storage, the primary federal regulation is EPA 40 CFR 112 — the SPCC Rule. It applies to any facility with:

  • Total above-ground storage (AST) capacity greater than 1,320 gallons

  • Total underground storage (UST) capacity greater than 42,000 gallons

If SPCC applies, you need:

  • A written SPCC Plan (PE-certified if total capacity exceeds 10,000 gallons)

  • 5-year plan review and update cycle

  • Annual personnel training on oil-handling and spill response

  • Secondary containment, tank inspections, and spill reporting

For facilities with generators, NFPA 110 also applies — monthly load testing, fuel quality, transfer switch tests. The Oregon State Fire Marshal (OSFM) enforces NFPA 110 through the Oregon Fire Code (currently OFC 2022, transitioning to OFC 2025). See our complete regulation guide for the full federal breakdown.

Oregon’s state programs sit on top of these federal requirements. Your facility must comply with both.

For more on federal SPCC specifically, see: Do You Need an SPCC Plan? What Every Fuel Storage Facility Owner Should Know.


Oregon DEQ: The UST Program

Registration and the “Green Tag”

Every regulated underground storage tank in Oregon must be registered with DEQ and issued a Registration Certificate — commonly called the “green tag” (OAR 340-150-0020). This is Oregon’s general permit system, and it’s mandatory.

Without a current green tag, fuel distributors should not deliver product to your facility. Registration must be renewed annually.

Annual compliance fee: $325 per tank per year (OAR 340-150-0110). Multi-compartment tanks are charged per compartment. Initial registration costs $400 per tank.

As of January 2025, all registration, reporting, and payments must go through Your DEQ Online (YDO) — Oregon’s mandatory online compliance platform.

Who’s Exempt?

Oregon exempts the following from OAR Division 150:

  • Heating oil tanks — governed separately under OAR Division 177 (this is a significant structural difference from many states)

  • Farm/residential motor fuel tanks of 1,100 gallons or less for noncommercial use

  • Tanks of 110 gallons or less

  • Septic tanks, stormwater systems, and flow-through process tanks

  • Hazardous waste systems regulated under RCRA Subtitle C

Important: Heating oil tanks are completely separate in Oregon. If your facility has heating oil USTs, they’re governed by ORS 466.858-466.882 and OAR Division 177 — not the main UST rules. Don’t assume your heating oil tanks are covered by your UST compliance program.


Oregon UST Testing Requirements

Oregon’s testing requirements align closely with the federal baseline, organized by cycle. DEQ conducts compliance inspections at least once every three years per the federal Energy Policy Act.

Annual Tests (Every 12 Months)

Test Code What It Covers
Electronic Monitoring System (EMS) EMS Full functional test of automatic tank gauging systems. Verifies alarms, leak detection, inventory monitoring. If probes trigger fuel shutdown, system may need to go offline temporarily.
Line Leak Detector (LLD) LLD Tests mechanical and electronic line leak detectors on pressurized piping. Not required for safe suction (European) piping systems.

Triennial Tests (Every 36 Months)

Test Code What It Covers
Cathodic Protection Testing (CPT) CPT Tests corrosion protection systems on steel tanks, lines, and flex connectors. Required for steel/metal — not required for fiberglass tanks.
Line Tightness Testing (LTT) LTT Pressure/vacuum testing of product piping. Exceptions for safe suction piping, secondary containment with interstitial monitoring, and electronic line leak detectors performing 0.2 GPH monthly tests.
Overfill Protection Testing (OFT) OFT Inspects overfill prevention equipment — auto shut-off at 95% capacity or alarm at 90%. Flow restrictors in vent lines are prohibited in Oregon.
Secondary Containment Testing (SCT) SCT Hydrostatic testing of sumps and under-dispenser containment. Required for all containment systems associated with product piping.
Spill Bucket Testing (SBC) SBC Fill testing of spill containment buckets at fill points. Tests for leaks and proper sealing.

Spill and overfill equipment must be tested every three years per OAR 340-150-0310. Alternative: monthly integrity monitoring of double-walled equipment.

5-Year Tests (Every 60 Months)

Test Code What It Covers
Tank Tightness Test (Precision Test) TTT Precision volumetric test of the tank shell. Must detect 0.1 gal/hr leak rate at 95% probability, 5% or less false alarm rate.

Monthly Requirements

Walkthrough inspections are required at least every 30 days per OAR 340-150-0315:

  • Inspect spill prevention equipment for damage, obstructions, and proper sealing

  • Verify release detection equipment is operating with no alarms or unusual conditions

  • Records must be maintained for at least one year

Operators may follow DEQ procedures, PEI Recommended Practice RP 900, or other nationally recognized standards.


Where Oregon Exceeds Federal Requirements

Oregon’s UST program was granted EPA approval in 2019. That means Oregon meets or exceeds every federal standard. Here’s where it goes further:

1. Licensed Testers Required

All UST testing in Oregon must be performed by a DEQ-licensed service provider or supervisor under OAR 340, Division 160. This was updated in July 2025 with enhanced oversight requirements. You cannot use an unlicensed contractor — and if you do, both you and the contractor face penalties.

Verify your testing provider’s license through DEQ’s service provider directory before scheduling work.

2. $325 Annual Fee Per Tank

Oregon charges $325 per tank per year for the general permit — one of the higher state UST fees in the region. This is in addition to any testing costs. A facility with 4 underground tanks pays $1,300/year just in registration fees before a single test is performed.

3. 24-Hour Failure Reporting

When a test fails, Oregon requires you to report the failure to DEQ within 24 hours of receiving results. This is more specific than the general federal release reporting requirement. The clock starts when your testing provider gives you the results — not when you get around to reading them.

4. Retraining After Failed Inspection

If your facility fails a DEQ compliance inspection, Class A and B operators must complete retraining within 30 days covering the non-compliant areas (OAR 340-150-0210). DEQ may grant waivers in limited circumstances, but the default is a tight 30-day window.

5. AST Permit Threshold: 1,000 Gallons

The Oregon State Fire Marshal (OSFM) requires plan review and a permit for any above-ground storage tank exceeding 1,000 gallons (single or aggregate capacity). The federal SPCC rule doesn’t kick in until 1,320 gallons.

This creates a 320-gallon regulatory gap that catches multi-state operators off guard. A facility with a 1,200-gallon AST in Washington needs no state permit — the same tank in Oregon requires OSFM approval before it can be filled. If you’re expanding into Oregon or moving equipment between states, verify the threshold before installation. For more on the federal SPCC side, see our SPCC requirements guide.

6. Overfill Flow Restrictors Prohibited

Oregon explicitly prohibits using flow restrictors in vent lines as an overfill prevention method. This is a departure from common practice in other states — ball float valves and vent restrictors are widely installed elsewhere. In Oregon, you must use auto shut-off valves (at 95% capacity) or high-level alarms (at 90% capacity) instead. If your facility was built to standards from another state, check your overfill equipment before your next DEQ inspection — replacing a flow restrictor after a violation is more expensive than replacing it proactively.


Oregon vs. Washington: Key Differences

If your organization operates facilities in both Oregon and Washington, these differences matter:

Requirement Oregon Washington
Regulatory structure Single UST program under OAR 340-150 Three separate programs (Annual, Triennial, 5-Year)
Annual fee per tank $325 No annual compliance fee
Licensed tester required Yes — OAR 340-160 No state licensing requirement
Failure reporting 24 hours to DEQ Per WAC 173-360A timelines
Secondary containment deadline April 11, 2016 (federal date) October 1, 2012 (earlier)
AST permit threshold 1,000 gallons (OSFM) Varies by jurisdiction
Heating oil tanks Completely exempt from UST rules Subject to general UST rules
Online reporting Mandatory via Your DEQ Online Not required

Washington’s compliance complexity is structural — three overlapping DOE programs on different cycles. Oregon’s complexity is procedural — a single program with stricter administrative requirements. Both states layer on top of the same federal baseline. For more on Washington, see: Washington State Fuel Tank Compliance: UST, AST & Environmental Regulations Explained.


The Combined Testing Calendar

Here’s what an Oregon facility with USTs, generators, and ASTs faces across all programs:

Monthly

  • Walkthrough inspections (OAR 340-150-0315)

  • Generator load test (NFPA 110, if applicable)

  • Transfer switch test (NFPA 110, if applicable)

  • Battery test (NFPA 110, if applicable)

Weekly

  • Generator visual inspection (NFPA 110, if applicable)

Every 12 Months (Annual)

  • Electronic Monitoring System test (DEQ)

  • Line Leak Detector test (DEQ, pressurized piping)

  • Fuel quality testing — ASTM D975 (NFPA 110, if applicable)

  • SPCC personnel training (EPA, if applicable)

Every 36 Months (Triennial)

  • Cathodic Protection Testing (DEQ, steel tanks only)

  • Line Tightness Testing (DEQ, with exceptions)

  • Overfill Protection Testing (DEQ)

  • Secondary Containment Testing (DEQ)

  • Spill Bucket Testing (DEQ)

  • Generator 36-month load test (NFPA 110, if applicable)

Every 60 Months (5-Year)

  • Tank Tightness Test (DEQ)

  • SPCC Plan review and update (EPA, if applicable)

That’s up to 16 separate compliance activities across four different cycles. Oregon’s single DEQ program is simpler to track than Washington’s three programs, but the penalty for falling behind is steeper — especially with 24-hour failure reporting and the green tag system.


Oregon AST Compliance

Oregon’s AST regulatory picture is split between two agencies:

Oregon State Fire Marshal (OSFM) handles:

  • Plan review and installation permits for ASTs over 1,000 gallons

  • Pre-fill inspection requirement — no tank may be filled until OSFM approves

  • Two sets of plans required before installation

  • Installation fee: $50 per tank (ORS 480.450)

DEQ does NOT regulate ongoing AST compliance. Unlike USTs, Oregon DEQ has not adopted AST-specific testing or monitoring rules. Ongoing AST compliance in Oregon is governed by:

  • Federal EPA SPCC (if capacity exceeds 1,320 gallons)

  • Industry standards (NFPA 30, API 653)

  • Local fire marshal inspections

This means AST-only facilities in Oregon have a lighter state regulatory burden — but still face full federal SPCC requirements if they’re above the capacity threshold.


Penalties and Enforcement

Oregon’s penalty structure is based on violation severity under OAR 340-012-0067:

Violation Classification

Class Examples Base Penalty
Class I (most serious) Operating without permit, no leak detection, no corrosion protection, failed to investigate release Up to $12,000
Class II (moderate) Expired release detection, untrained operators, missing notifications Up to $8,000
Class III (minor) Failure to notify new owner of registration requirements $100 – $1,000

Maximum penalty: $25,000 per violation per day (ORS 466.990). Each day of non-compliance counts as a separate violation.

For intentional or reckless violations causing extreme hazard, penalties can reach $250,000 (OAR 340-012-0155).

The Green Tag: Oregon’s Enforcement Lever

Oregon’s most immediate enforcement tool isn’t a fine — it’s the registration certificate. If a DEQ inspector determines a UST system is out of compliance, they can nullify the registration certificate (pull the green tag). Without a valid green tag, fuel distributors cannot legally deliver product to the facility.

For a gas station, this means no fuel deliveries. For a hospital with emergency generators, this means no diesel. For a fleet operation, this means vehicles don’t move. The green tag system makes compliance enforcement immediate and operational — not just financial.

Cleanup Costs

When a leak is discovered, the cost of environmental cleanup often dwarfs any regulatory penalty:

Cleanup Scenario Typical Cost Range
Minor soil contamination (caught early) $25,000 – $75,000
Moderate soil and groundwater $100,000 – $500,000
Major groundwater plume $500,000 – $1,000,000+
Contamination affecting drinking water $1,000,000+

Oregon DEQ administers a Leaking UST cleanup program with financial assistance available through OAR Division 172. But qualification is limited and the process takes time — regular testing is far cheaper than remediation.

Don’t risk your green tag. If your testing schedule is overdue or you’re unsure about your compliance status, schedule Oregon-compliant testing with a DEQ-licensed provider before your next inspection — not after.


Financial Responsibility and Insurance

Oregon UST owners must demonstrate financial responsibility for cleanup costs, as required by both federal EPA regulations and state law. Options include:

  • Environmental liability insurance (most common for commercial operators)

  • State assurance funds — Oregon’s Orphan Site Account helps with abandoned and orphan sites, but eligibility is limited

  • Letters of credit, trust funds, or surety bonds (allowed under federal rules)

  • Self-insurance (large corporations meeting EPA net worth requirements)

Unlike Washington’s PLIA program (which primarily covers heating oil tanks), Oregon doesn’t have a broad-based state UST insurance fund for commercial operators. Most Oregon facility owners need private environmental liability insurance to meet financial responsibility requirements. Verify your policy covers Oregon DEQ cleanup standards and the current per-tank exposure before your next renewal.


Operator Training Requirements

Oregon requires every regulated UST facility to designate three classes of operators per OAR 340-150-0210:

Class Role Training Deadline
Class A Primary operational responsibility Within 30 days of designation
Class B Daily on-site operation Within 30 days of designation
Class C Emergency response (fueling attendants) Before dispensing or emergency duties

Training must be through DEQ-approved vendors, national UST operator exams (like ICC), or internet-based programs approved by DEQ. Records are permanent — maintain operator names, completion dates, facility ID, and trainer information.

If your facility fails a compliance inspection, the 30-day retraining clock starts immediately. See the Oregon DEQ operator training page for approved providers.


Which Oregon Programs Apply to Your Facility?

If You Have… What Applies
Underground storage tanks (UST) DEQ UST program (OAR 340-150) + Federal SPCC (if >42,000 gal UST)
Above-ground storage tanks (AST) only OSFM permit (if >1,000 gal) + Federal SPCC (if >1,320 gal)
Generators with day tanks NFPA 110 + Oregon Fire Code + Federal SPCC (if total >1,320 gal)
USTs + Generators (hospital, data center) DEQ UST + NFPA 110 + SPCC + JC/CMS (if healthcare)
Retail fuel station DEQ UST + NFPA 30 + SPCC + Fire Marshal
Heating oil tanks only OAR Division 177 (NOT Division 150)

Healthcare facilities in Oregon face the most regulatory overlap: Oregon DEQ, NFPA 110, EPA SPCC, Joint Commission, and CMS — potentially five or more overlapping programs with different cycles, different inspectors, and different documentation requirements. See our healthcare generator compliance guide for the healthcare-specific breakdown.


What Oregon Facility Owners Should Do Now

1. Verify Your Green Tag

Is your DEQ registration certificate current? Check your Your DEQ Online account. If your green tag has lapsed, fuel deliveries to your facility may be at risk.

2. Confirm Your Testing Provider Is Licensed

Oregon requires DEQ-licensed service providers for all UST testing. Verify your provider’s current license through DEQ’s service provider page. Using an unlicensed contractor puts both of you at risk.

3. Know Your Testing Schedule

Pull your records. When was your last EMS test? Last triennial round? Last tank tightness test? Oregon’s 24-hour failure reporting means you can’t afford surprises — know what’s due before the inspector does.

4. Get Your Personalized Compliance Map

Use Compliance Genius — select Oregon as your state

Our free assessment tool is built on Oregon-specific compliance data. Select “Oregon” as your state, enter your facility type and equipment, and get a personalized map of every regulation, test, and schedule that applies to your operation — in under 2 minutes.

Already know your compliance requirements? Check your Fuel Readiness Score — our free assessment evaluates whether your fuel systems are ready when you need them most.


Key Oregon DEQ Contacts

Resource Contact
UST Duty Officer 503-229-5034 / UST.DutyOfficer@deq.oregon.gov
UST Helpline 503-229-6652
Toll-Free Helpline 800-742-7878
Mailing Address Oregon DEQ, Tanks Program, 700 NE Multnomah St, Suite 600, Portland, OR 97232
Your DEQ Online oregon.gov/deq/permits/pages/ust-in-ydo.aspx

Frequently Asked Questions

Q: How is Oregon’s UST program different from the federal EPA program? A: Oregon has an EPA-approved state program, meaning it meets or exceeds all federal standards. Key additions include: mandatory annual registration ($325/tank), licensed tester requirements (OAR 340-160), 24-hour test failure reporting, and the “green tag” system that can halt fuel deliveries for non-compliant facilities. You comply with Oregon rules, which automatically satisfy federal requirements.

Q: Do I need a licensed contractor for UST testing in Oregon? A: Yes. All tightness testing and UST servicing in Oregon must be performed by a service provider or supervisor licensed by DEQ under OAR 340, Division 160. The rules were updated in July 2025 with enhanced oversight requirements.

Q: What happens if my registration certificate (green tag) expires? A: Fuel distributors should not deliver product to a facility without a current green tag. Your facility effectively can’t receive fuel. To reinstate, pay any outstanding annual fees through Your DEQ Online and resolve any outstanding compliance issues. DEQ may also require a compliance inspection.

Q: Are heating oil tanks regulated the same as fuel tanks in Oregon? A: No — this is one of Oregon’s key structural differences. Heating oil USTs are exempt from OAR Division 150 (the main UST rules) and governed separately under OAR Division 177 and ORS 466.858-466.882. If you have both petroleum and heating oil tanks, they fall under different regulatory programs.

Q: My facility has both USTs and ASTs. Who regulates what? A: Oregon DEQ regulates underground storage tanks. The Oregon State Fire Marshal regulates above-ground storage tank installation and permitting (for tanks over 1,000 gallons). For ongoing AST compliance, you follow federal EPA SPCC and industry standards (NFPA 30, API 653). DEQ has not adopted AST-specific ongoing testing rules.

Q: What are the penalties for non-compliance in Oregon? A: Class I violations (no permit, no leak detection, no corrosion protection) carry base penalties up to $12,000 per violation. The statutory maximum is $25,000 per violation per day under ORS 466.990. More immediately, DEQ can pull your registration certificate — stopping fuel deliveries to your facility.


FuelCare provides fuel tank compliance testing across Oregon and the Pacific Northwest — from annual EMS testing to triennial integrity testing to precision tank tests. All work performed by DEQ-licensed service providers. Try Compliance Genius free or contact us to schedule testing.


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