Think Tank

July 1, 1998
According to the Environmental Protection Agency (EPA), there are approximately two million underground storage tanks (USTs) that are affected by regulations

According to the Environmental Protection Agency (EPA), there are approximately two million underground storage tanks (USTs) that are affected by regulations in the United States. These regulations were enacted to prevent or reduce the frequency and severity of a release of the contents of a tank. Because leaks have caused extensive soil and groundwater pollution throughout the country, the EPA is serious about pursuing violators.

A UST is any tank and piping system that contains a regulated substance (e.g., petroleum) and is 10 percent or more, by volume, beneath the surface of the ground. The EPA regulates USTs and enforces compliance through the Resource Conservation and Recovery Act (RCRA) Part 280 of Title 40 of the Code of Federal Regulations. As of Dec. 22, 1998, all USTs must meet upgrade requirements. It is not enough to have the required paperwork submitted or to have started work by this date; the work must be completed by Dec. 22 to avoid fines. Failure to comply can cost up to $25,000 per day in penalties.

The state in which your facility is located also may regulate USTs, and often may have even more stringent regulations than the federal government. To make matters more complicated, many localities also have requirements that are stiffer than federal or state regulations. For example, one township in Missouri does not allow facilities to close USTs in-place or remove them to be cleaned on-site, and it regulates heating-oil tanks, although the EPA and most state agencies do not.

Not all USTs are regulated, however. For example, heating-oil tanks that store fuel strictly for on-site consumption in boilers are non-regulated under RCRA. Other examples of non-RCRA-regulated USTs include those that are necessary for the operation of elevators, electrical equipment or hydraulic lifts. To determine if your tanks need to be upgraded, check with state and local agencies for the definition of regulated tanks.

Also, tanks installed after Dec. 22, 1988, should have been installed according to new tank performance standards, and therefore should not require upgrading. Contact the tank installer to ensure that the new tank performance standards were followed.

Upgrading an existing tank Upgrading a tank means the addition or retrofit of systems such as cathodic protection, lining, and spill and overfill controls designed to improve the performance of a UST system in order to prevent release. To meet upgrade requirements, a tank and associated piping must be equipped with corrosion protection or be constructed of a non-corrodible material. The tank also must be equipped with spill and overfill protection.

Corrosion protection has three options: Adding cathodic protection, lining the interior of the tank, or both. In some instances, a corrosion-control expert can certify that the subsurface conditions are non-corrosive and will prevent a release due to corrosion, thereby eliminating the need for corrosion protection. Cathodic protection uses sacrificial zinc and/or magnesium anodes to protect the steel against rust wherever steel is directly exposed to the soil.

Prior to installing cathodic protection and/or an interior lining, the tank system must be inspected to ensure its integrity has not been jeopardized. This can be accomplished by performing tank and line tightness tests, conducting a visual inspection of the tank interior, or by sampling the surrounding soil and groundwater.

Usually less costly than installing a new tank, cathodic protection and internal lining allow for the structural integrity of the tank to be inspected. If installed properly, this protection prevents releases. However, in the event the tank is not structurally sound, contamination may exist beneath the tank, and a temporary fuel source may be needed for the duration of the upgrading process. Also, periodic inspections must be performed after adding cathodic protection. Spill protection is as easy as installing a spill bucket around the fill pipe to catch product that misses the fill port during the filling operation. The EPA has determined that overfilling and spills have created numerous environmental problems.

Overfill protection is an automatic device that shuts off the flow once a tank is full. Once the device detects that the tank is full, an alarm goes off to alert the operator to stop the filling operation, or the device restricts product flow into the tank.

Upgrading existing tank systems is usually a less expensive alternative to removal and replacement. However, if the integrity of the tank system has been jeopardized, or if subsurface contamination exists due to a release or constant overfilling, upgrading may not be feasible. The tank may need to be removed to address contamination, and a new tank may need to be installed if the integrity of the existing tank cannot be restored.

Replacing the tank Although upgrading an existing tank generally costs less than removal or replacement, the value associated with installing a new tank may be worth the additional upfront expense. If tanks are upgraded by installing cathodic protection or an internal lining, periodic inspections are required, adding yet another expense. Also, should a problem occur with the lining or cathodic protection, repairs will be required and releases may occur.

New tanks are designed to comply with federal performance standards and have an extended operational life. They are generally constructed of fiberglass, which is not susceptible to corrosion. Consequently, removing existing tanks and replacing them with new tanks-USTs or aboveground storage tanks (ASTs)-may be the best option. (Always check local ordinances before installing ASTs.)

Tank removal or closure Sometimes it is more feasible for a facility to permanently close an existing tank rather than upgrade or replace the tank. Closure may be the preferred choice when meeting upgrade requirements is too costly, if the tank is no longer in use, or if there is evidence of a release.

Tanks may be permanently closed in-place or may be removed from the ground. Also, a change-in-service may be performed, which involves converting the tank from storage of a regulated substance to storage of a non-regulated substance, such as water. It is important to check state and local regulations prior to performing tank-closure activities. Some localities do not allow in-place closures, and may require additional permitting.

Closing a tank in-place requires the tank to be emptied, cleaned and filled with an acceptable inert material (e.g., sand). All piping associated with the tank system must be drained of product and sealed with cement or concrete grout. Beyond these steps, the owner of the tank also must demonstrate that a release has not occurred from the tank or piping. Methods for demonstrating this vary from state to state.

Tank removal is the most common and preferred method of closure. Removing the tank altogether eliminates concern over changing regulations. Once a tank is removed from the ground, it must be cleaned and disposed of properly. The school also must demonstrate that a release has not occurred.

Many states now offer reimbursement funds for eligible facilities that have contamination due to releases. Usually the owner is responsible for the cost of removing the tanks and paying a predetermined deductible (normally $10,000 to $100,000). The reimbursement fund is responsible for costs associated with remediation above the deductible to a predetermined maximum (usually $1 million). Check with your state agency for information concerning reimbursement funds and eligibility requirements.

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