Industrial Hygiene Associates
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359 DRESHER ROAD HORSHAM, PA 19044 (215)672-6088 (215)443-0899 FAX kcrawford@eagleih.com |
Underground Storage Tanks
“Out of sight, not out of mind”
What is a "UST"?
An underground storage tank system (UST) is a tank and associated underground piping with at least 10 percent of its cumulative volume underground. The federal and state UST regulations only apply to tanks of this type which store either petroleum or certain regulated hazardous substances.
What are the concerns about USTs?
Prior to the mid-1980s, almost all USTs were constructed of mild steel, and installed without any additional corrosion protection. These tanks were prone to corrosion over time and allowed the tank’s contents to leak into the surrounding environmental media, usually soils and groundwater. In addition to corrosion, faulty installation or inadequate operating and maintenance procedures also contributed to releases into the environment.
By far, the greatest potential hazard from a leaking UST is the seeping of its contents (petroleum or other hazardous substance) into the soil, and subsequently groundwater; contaminating the primary source of drinking water for nearly half of our population. Additionally, there other risks to human health and environment and, in some cases, a potential for fire and explosion.
How have Congress and EPA responded to concerns about USTs?
In 1984, Congress authorized the development of a comprehensive regulatory program to be added to the Resource Conservation and Recovery Act (RCRA) covering USTs storing petroleum or certain hazardous substances. These regulations specified measures for leak prevention, detection and cleanup by owners and operators of underground storage tanks. At the same time, the installation of unprotected steel tanks and piping was banned beginning in 1985. Amendments passed in 1986 required UST owners and operators to provide evidence of financial responsibility sufficient to clean up releases and compensate third parties for resulting damages.
Are all USTs required to meet federal EPA regulations?
No, the following USTs are exempt from federal requirements for USTs, but are subject to follow all required cleanup measures in the event of a discharge
- Farm and residential tanks of 1,100 gallons or less capacity holding motor fuel fuel oil used for noncommercial purposes;
- Tanks storing heating oil used on the premises where it is stored;
- Tanks on or above the floor of underground areas, such as basements or tunnels;
- Septic tanks and systems for collecting storm water and wastewater;
- Flow-through process tanks;
- Tanks of 110 gallons or less capacity;
- Emergency spill and overfill tanks.
Some of the above-referenced tanks may be subject to state or local regulations. Be sure you check with your state and local authorities.
How are USTs regulated by the Federal Government?
In 1988, as a means of providing a baseline set of overall standards governing UST’s, the EPA issued regulations that were divided into three sections:
Technical Requirements
The technical requirements consist of methods and practices designed to address the factors and circumstances that can lead to a UST product release. These requirements include detection of leaks and spills, reporting of discharges, and accepted cleanup practices. Additional information can be obtained at the following links: Preventing Releases, Detecting Releases, and Cleaning Up Releases.
Financial Responsibility
The financial responsibility regulations are designed to ensure that owners and operators of USTs will have the resources to pay the costs associated with the cleanup of a release, as well as compensating a third-party for damages.
State Program Approval Objectives
The EPA has set forth a minimum set of objectives that must be met by individual states as a condition of primacy in the enforcement of UST regulations. Each state must enact regulations that are at least as stringent as the Federal regulations.
How do I tell if there is a UST problem?
- You experience an unexpected increase in fuel consumption.
- There is water in the tank causing problems with your oil burner.
- Changes in vegetation in the area over and around the tank installation.
- Strong oil odors in the basement.
- Tastes and odors in your well water.
- Staining of basement walls or floors adjacent to the tank.
- An oily sheen on the surface of water in sumps, French drains and nearby culverts and drainage ditches.
In the instance of items 1 and 2 above, contact the company that services your heating system to rule out a maintenance problem. For the remaining items, contact an environmental contractor.
What should I do if a discharge is found?
If a leak or discharge is confirmed, regardless of quantity, it must be reported to the appropriate state agency (in New Jersey and Pennsylvania, contact the Department of Environmental Protection. There are similarly-titled agencies in other states). Next, contact your fuel oil dealer and arrange to have the contents of the tank pumped out as quickly as possible.
How do I select an environmental contractor?
Environmental contractors are listed in the Yellow Pages under “Environmental Services”. As with any contract work, you should ensure that a prospective contractor has complete knowledge of State and Federal regulations, and they hold the appropriate professional licenses. It would also be in your best interest to get two or more cost estimates for the work, although the extent of cleanup activities required can be very difficult to predict. It is advisable to have your attorney review any contract you consider signing.
What are the steps in a UST cleanup?
Most leaking underground storage tank cleanups involve the following steps:
- Removal of product from the tank, cleaning of the interior, cutting and disposal of the tank as scrap metal in accordance with local codes and the American Petroleum Institute's recommended practices.
- Delineation of the extent of contaminated soils and the possible impact to groundwater.
- Excavation and disposal of contaminated soils surrounding the tank.
- Groundwater remediation as required.
- Sampling of remaining soils and/or groundwater to confirm that any remaining contamination is within mandated limits.
- Submission of a cleanup report to the appropriate state environmental agency.
Eagle Industrial Hygiene Associates offers a variety of services associated with the cleanup of underground storage tank discharges. In Pennsylvania and New Jersey, Eagle is permitted to perform tank removals and address subsurface contamination. In other states, Eagle will act as your consultant in the choice and supervision of an environmental contractor, and act as your representative through the successful culmination of the project. Please contact us for further information.
This document is offered as a general overview to homeowners and tank owners and operators. It does not address, nor is it intended to, any and all possible discharge scenarios and the requirements imposed by individual state environmental agencies. For more definitive information, contact your appropriate state agency.