It’s not that the individual rules are unusually strict (though some are). It’s that the runs three separate fuel tank compliance programs — overseeing more than 8,500 tanks at over 3,400 facilities statewide — each with its own testing schedule, its own regulatory basis, and its own enforcement mechanism — on top of federal regulations that also apply.
Most tank owners in Washington are aware of at least one program. Very few are tracking all three. And because the programs operate on different cycles (annual, triennial, and 5-year), it’s easy for a testing deadline to pass without anyone noticing — until an inspector or auditor flags it.
This guide breaks down Washington’s three regulatory programs, explains how they layer on top of federal requirements, and maps out every test and inspection your facility needs. If you want the short version, — it maps Washington-specific requirements to your exact equipment in under 2 minutes.
Federal Regulations Apply First
Before getting into Washington-specific programs, remember: federal regulations form the floor. State regulations add requirements on top.
For Washington facilities with fuel storage, the primary federal regulation is — the . It applies to any facility with:
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Total above-ground storage (AST) capacity greater than 1,320 gallons
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Total underground storage (UST) capacity greater than 42,000 gallons
If you trigger SPCC, you need:
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A written SPCC Plan (PE-certified if >10,000 gal total)
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5-year plan review and update cycle
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Annual personnel training on oil-handling and spill response
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Secondary containment, tank inspections, and spill reporting
For facilities with generators, also applies (monthly testing, fuel quality, transfer switch tests — see our for details).
Washington’s three programs sit on top of these federal requirements. Your facility must comply with both.
Washington’s Three Regulatory Programs
Program 1: WA DOE UST Annual Program
Authority: Regulatory Basis: (Underground Storage Tank Regulations) — see Cycle: Every 12 months
The annual program focuses on leak detection and monitoring systems — the equipment that’s supposed to catch problems early.
Annual Tests Required:
| Test | Service Code | What It Covers |
|---|---|---|
| Electronic Monitoring System (EMS) | EMS | Full functional test of automatic tank gauging (ATG) systems. Verifies alarms, leak detection, inventory monitoring. If security is enabled, password/code needed. If probes trigger fuel shutdown, system may need to be taken offline. |
| Line Leak Detector (LLD) | LLD | Tests mechanical and electronic line leak detectors. Not required for suction systems. If electronic, requires EMS access. |
Accommodations needed: EMS testing often requires security codes for the monitor, breaker access, and potentially a fuel system shutdown if probes are programmed to halt fueling on alarm. Plan for 3-4 hours of on-site time.
Key detail: If your facility uses electronic line leak detection that performs 0.2 GPH monthly tests, you may be exempt from separate line tightness testing — but you still need the annual EMS functional test.
Program 2: WA DOE UST Triennial Program
Authority: Regulatory Basis: Cycle: Every 36 months (3 years)
The triennial program covers the structural integrity of tanks, piping, containment, and overfill protection. This is the most comprehensive testing cycle and the one most commonly behind schedule.
Triennial Tests Required:
| Test | Service Code | What It Covers |
|---|---|---|
| Cathodic Protection Testing (CPT) | CPT | For steel tanks, lines, and flex connectors with cathodic protection. Tests sacrificial anode or impressed current systems. If impressed current, rectifier access needed. |
| Line Tightness Testing (LTT) | LTT | Pressure/vacuum testing of product piping. Has numerous exceptions based on piping configuration (see below). Requires breaker access and fuel system shutdown — no delivery 6 hours prior. |
| Overfill Protection Testing (OFT) | OFT | Tests overfill prevention equipment (ball floats, flapper valves, electronic high-level alarms). Not required for tanks receiving <25 gallons at a time (most waste oil tanks). |
| Secondary Containment Testing (SCT) | SCT | Hydrostatic testing of sumps and under-dispenser containment (UDCs) with product lines. Required for all containment systems associated with product piping. |
| Spill Bucket Testing (SBC) | SBC | Fill testing of spill containment buckets at fill points. Vapor spill bucket testing not required at this time. |
Line Tightness Exceptions (Washington-specific):
Line tightness testing has the most complex exception rules of any Washington test. Whether your piping needs testing depends on:
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Piping installation date — Lines installed after October 1, 2012 have different requirements
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Piping type — Single wall vs. double wall, pressurized vs. suction
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Monitoring method — Electronic 0.2 GPH monthly tests may exempt from triennial LTT
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Suction type — Safe suction (European) is exempt; non-safe suction (American) requires testing
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Secondary containment — Double-walled piping with interstitial monitoring may be exempt
The specific exception rules from Washington DOE:
| Code | Exception |
|---|---|
| ELLD | Not required on single or double walled piping with electronic line leak detector performing 0.2 GPH monthly tests |
| NSSC | Required on non-safe suction (American suction) lines every 3 years. Not required if using interstitial monitoring with sump tests |
| POST | Not required for piping installed after 10/1/2012 if system performs interstitial monitoring with secondary containment testing |
| PRES | Required for pressurized systems with lines installed before 10/1/2012, unless double-walled piping uses interstitial monitoring |
| SIR | Not required if site uses Statistical Inventory Reconciliation (SIR), but recommended |
| SSEX | Not required for safe suction (European suction) lines |
This is where Washington exceeds federal requirements. The October 2012 date threshold and the distinction between piping types create a Washington-specific compliance layer that doesn’t exist at the federal level. Many multi-state operators are caught off guard by this level of detail.
Program 3: WA DOE UST 5-Year Program
Authority: Regulatory Basis: Cycle: Every 60 months (5 years)
The 5-year program covers tank integrity verification — the most intensive (and expensive) testing cycle.
5-Year Tests Required:
| Test | Service Code | What It Covers |
|---|---|---|
| Tank Tightness Test (Precision Test) | TTT | Precision volumetric test of the tank shell. Required every 5 years if using inventory control tank monitoring. Detects small leaks that don’t trigger automatic monitoring. |
Note: This test is specifically required when your primary tank monitoring method is inventory control (rather than continuous electronic monitoring). If you’re using a properly functioning EMS with continuous statistical leak detection, your tank tightness testing requirements may differ — but most facilities with older inventory control systems are on the 5-year cycle.
The Combined Testing Calendar
Here’s what a Washington facility with underground storage tanks faces when you combine all three programs plus federal requirements:
Every Month
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Generator load test (NFPA 110, if applicable)
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Transfer switch test (NFPA 110, if applicable)
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Battery test (NFPA 110, if applicable)
Every Week
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Generator visual inspection (NFPA 110, if applicable)
Every 12 Months (Annual)
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Electronic Monitoring System test (WA DOE Annual)
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Line Leak Detector test (WA DOE Annual)
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— ASTM D975-24 (NFPA 110, if applicable)
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SPCC personnel training (EPA, if applicable)
Every 36 Months (Triennial)
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Cathodic Protection Testing (WA DOE Triennial)
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Line Tightness Testing (WA DOE Triennial, with exceptions)
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Overfill Protection Testing (WA DOE Triennial)
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Secondary Containment Testing (WA DOE Triennial)
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Spill Bucket Testing (WA DOE Triennial)
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Generator 36-month load test (NFPA 110, if applicable)
Every 60 Months (5-Year)
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Tank Tightness Test (WA DOE 5-Year)
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SPCC Plan review and update (EPA, if applicable)
That’s up to 17 separate compliance activities across four different cycles from three different programs plus federal overlay. And the testing windows don’t always align neatly — if your annual EMS test is due in March, your triennial tests are due in June, and your SPCC review is due in September, you’re managing three separate compliance deadlines in a single year.
AST Requirements: Where Washington Exceeds Federal
For above-ground storage tanks, Washington adds requirements beyond the federal SPCC rule:
Spill Prevention:
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WA DOE requires spill prevention plans for facilities with ASTs, in addition to (and sometimes more detailed than) federal SPCC plans
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Spill reporting thresholds are lower in Washington than federal minimums — any release to surface water or ground must be reported
Secondary Containment:
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Washington follows federal SPCC secondary containment requirements but DOE inspections verify compliance more actively than EPA in many cases
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Local fire marshals enforce NFPA 30/30A requirements for AST design and placement
Inspection Schedules:
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Washington facilities with ASTs face both DOE inspections (environmental compliance) and fire marshal inspections (fire code compliance) — two separate inspection authorities for the same tanks
Penalties and Enforcement
Washington’s enforcement is handled primarily by the Department of Ecology, with support from local fire marshals and health departments.
DOE Enforcement
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Violation notices for testing not completed on schedule
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Compliance orders requiring specific corrective actions
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Penalties up to $5,000 per tank per day of non-compliance (per )
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Mandatory tank closure/decommissioning for tanks that cannot demonstrate compliance
In addition to state penalties, federal EPA SPCC violations can result in civil penalties per violation (inflation-adjusted under 40 CFR 19.4).
Cleanup Liability
Washington’s Model Toxics Control Act (MTCA) — WAC 173-340 — governs environmental cleanup. If a leak is discovered:
| Cleanup Scenario | Typical Cost |
|---|---|
| Minor soil contamination (small release, caught early) | $25,000 – $75,000 |
| Moderate soil and groundwater contamination | $100,000 – $500,000 |
| Major groundwater plume | $500,000 – $1,000,000+ |
| Contamination affecting drinking water | $1,000,000+ |
Financial responsibility: Washington requires UST owners to demonstrate financial responsibility for cleanup — typically through insurance, trust funds, or state fund participation. The administers Washington’s heating oil tank program and the UST Loan & Grant Program, but commercial UST operators generally need private environmental liability insurance.
The Real Cost: Deferred Compliance
The most expensive outcome isn’t a fine — it’s a leak that wasn’t caught because monitoring equipment wasn’t tested, containment wasn’t verified, or tank integrity wasn’t confirmed. Washington’s three-program structure exists specifically to catch problems at different stages: monitoring (annual), structural integrity (triennial), and tank shell condition (5-year). Each program protects against a different failure mode. Skipping any one of them creates a blind spot.
Which Washington Programs Apply to Your Facility?
The answer depends on what you have:
| If You Have… | Programs That Apply |
|---|---|
| Underground storage tanks (UST) | All 3 WA DOE programs + Federal SPCC (if >42,000 gal) |
| Above-ground storage tanks (AST) only | WA DOE AST/Spill Prevention + Federal SPCC (if >1,320 gal) + Fire Marshal |
| Generators with day tanks | NFPA 110 + Federal SPCC (if total >1,320 gal) + Fire Marshal |
| UST + Generators (hospital, data center) | All 3 WA DOE programs + NFPA 110 + SPCC + JC/CMS (if healthcare) |
| Retail fuel station | All 3 WA DOE programs + NFPA 30 + SPCC + Fire Marshal |
in Washington face the most complex profile: three WA DOE programs, NFPA 110, EPA SPCC, Joint Commission, and CMS — potentially seven overlapping regulatory programs. See our for the healthcare-specific breakdown.
What Washington Facility Owners Should Do Now
1. Know Your Testing Dates
Pull your records. When was your last annual EMS test? Last triennial round? Last precision tank test? If you can’t answer immediately, you may already be behind.
2. Understand Your Piping Configuration
Washington’s line tightness exceptions depend heavily on piping type, installation date, and monitoring method. If you don’t know whether your piping was installed before or after October 1, 2012, find out — it directly affects your testing requirements.
3. Verify Your Financial Responsibility
Do you have current environmental liability insurance? Does it cover Washington’s MTCA cleanup standards? Many generic policies have exclusions that don’t align with Washington requirements.
4. Get Your Personalized Compliance Map
Our free assessment tool is built on Washington-specific compliance data. Select “Washington” 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.
Already know your compliance requirements? — our free assessment evaluates whether your fuel systems are ready when you need them most.
If your organization also operates facilities in Oregon, the regulatory picture is different — Oregon uses a single DEQ program with stricter administrative requirements (licensed testers, annual fees, 24-hour failure reporting). See our side-by-side comparison: .
For more on Washington-specific tank testing, see our detailed guide: .
Frequently Asked Questions
Q: I have underground storage tanks in Washington. Do all three DOE programs apply? A: Generally, yes. If you have registered USTs in Washington, you’ll face annual testing (EMS, line leak detectors), triennial testing (cathodic protection, line tightness, overfill, secondary containment, spill buckets), and 5-year testing (tank tightness). The specific tests within each program may vary based on your tank and piping configuration.
Q: What’s the difference between Washington’s UST program and the federal EPA UST regulations? A: The EPA sets minimum federal standards for USTs under 40 CFR 280. Washington’s WAC 173-360A meets or exceeds these federal standards. In several areas — particularly secondary containment testing for post-2012 piping and the October 2012 date threshold for line tightness — Washington is more stringent. You must comply with whichever standard is stricter.
Q: How do I know if my piping was installed before or after October 1, 2012? A: Check your facility’s tank installation records, permits, or as-built drawings. Your tank installer should have documentation. If records aren’t available, your compliance testing provider can often determine piping vintage during testing based on configuration and materials. The DOE may also have records from your tank registration.
Q: Does Washington have its own AST regulations beyond federal SPCC? A: Yes. Washington DOE has spill prevention requirements for ASTs, and spill reporting thresholds are lower than federal minimums. Additionally, local fire marshals enforce NFPA 30 for AST design and placement. An AST facility in Washington faces both environmental (DOE) and fire safety (fire marshal) compliance requirements.
Q: What happens if I’m late on a triennial test? A: Being late on required testing puts your facility out of compliance. DOE enforcement typically starts with a notice of violation and a deadline for corrective action. Repeated or prolonged non-compliance can result in penalties and mandatory corrective orders. More importantly, untested equipment creates genuine risk — a failed secondary containment system you didn’t test is a leak waiting to become a cleanup project.
Q: Is there a Washington state fund for UST cleanup? A: Washington’s administers programs primarily for heating oil tanks, plus a UST Loan & Grant Program. Commercial UST operators generally need private environmental liability insurance to meet financial responsibility requirements. Contact or your insurance broker for current options.
FuelCare provides across Washington State — from annual EMS testing to triennial integrity testing to precision tank tests. We track all three DOE programs so you don’t have to. or .