Illinois UST Regulations 2026: OSFM & IEPA LUST Program Guide

Key Compliance Requirements

To remain compliant in 2026, owners must perform and document regular inspections with specific requirements:

• 30-Day Walkthrough Inspections: Mandatory checks of release detection equipment, spill prevention measures, and other visible components
• Annual Inspections: All containment sumps must be inspected annually to ensure they are free of damage, water, and debris
• Double-Wall Piping: Any new or replacement tank installations must utilize double-wall piping to enhance containment capabilities
• Licensed Contractors: Always engage OSFM-licensed contractors for any tank work, from testing to removal

Leak Detection and Reporting Rules

UST systems must be equipped with approved leak detection methods:

• Automatic Tank Gauging (ATG): Continuous monitoring systems that can automatically detect leaks
• Interstitial Monitoring: For double-walled systems, monitoring the space between walls for leaks
• Statistical Inventory Reconciliation: Analysis of inventory data to identify potential leaks

Upon discovering a suspected or confirmed release, owners or operators must report it immediately to the Illinois Emergency Management Agency (IEMA) at 1-800-782-7860. Prompt reporting is the first step in the corrective action process and is crucial for accessing cleanup funds.

Financial Responsibility Requirements

Owners must demonstrate financial responsibility to cover the initial costs of potential cleanup and third-party damages. Illinois has specific requirements:

• Required Amount: $20,000 total ($10,000 for corrective action + $10,000 for third-party liability)
• Applies: Regardless of the number of tanks owned
• Acceptable Mechanisms: Commercial environmental liability insurance or self-insurance for eligible entities
• Proof of financial responsibility must be current and readily accessible for OSFM inspectors

Illinois LUST Cleanup Fund

For cleanups exceeding the owner's financial responsibility, the Illinois LUST Fund offers significant assistance:

• Coverage: Up to $1.5 million per occurrence for eligible costs related to site investigation and remediation
• Financing: Funded by a state motor fuel tax
• Deductible: Typically $5,000 for recent releases
• Requirements: Strict adherence to IEPA procedures for fund access

Recent Regulatory Changes

While major federal updates were integrated in 2018, legislative attention continues:

• Proposed Legislation: Bills (HB 5317/SB 4021) for the 2025-2026 session would empower municipalities to address "orphan" USTs
• Orphan UST Program: Would allow cleanup of abandoned tanks with no identifiable owner and seek reimbursement from the UST Fund
• Continued focus on compliance with federal standards and enhanced state oversight

Practical Tips for UST Owners

• Maintain Meticulous Records: Keep detailed logs of all inspections, maintenance, and leak detection results.
• Verify Financial Documents: Ensure your proof of financial responsibility is current and readily accessible for OSFM inspectors.
• Use Licensed Contractors: Always engage OSFM-licensed contractors for any tank work, from testing to removal.
• Stay Informed: Regularly check the OSFM and IEPA websites for any updates to forms, procedures, or regulations.
• Emergency Preparedness: Have immediate access to emergency contact numbers and spill response procedures.
• Schedule Inspections: Don't wait until deadlines—schedule required inspections well in advance.