Strike Oil?

UST Deadline A Year Away

by Mark Volatile

Owners of underground petroleum storage systems have faced many changes in the last ten years. Regulations regarding all aspects of underground petroleum storage, including regulations pertaining to preventing petroleum releases or the assessment and remediation following a release, have been established to protect human health and environmental resources. These requirements for Underground Storage Tank (UST) owners and orperators are about to change in a substantial way. UST operations as usual will not be an option. With about a year remaining, by December 22, 1998, owners or operators will have to upgrade their tanks for protection from spills, overfill and corrosion or take their tanks out of service. The EPA having just issued notice that no extensions will be granted, tank owners who have not begun the process must soon evaluate their situation or run the risk of regulatory trouble.

Multi-facility UST owners/operators are especially in need of a well-planned 2998 UST Management Strategy. The primary focal points in the evaluation of UST management are:

Upgrades to storage tank hardware for the detection and prevention of future releases.
More efficient management plans for site cleanups based on relative risk to public health and the environment.
More efficient technologies for site remediation.

Limited resources must be strategically applied to prioritize and address potentially high-risk sites. A little planning and strategy development now will help ensure a smooth and cost effective transition for UST owners/operators responsible for meeting the December, 1998 deadline. In a worst case scenario, a replacement or major retrofit may take six months or longer, depending on the availability of contractors, presence of leaks from the old tanks, and the need for preconstruction permits or approvals.

The regulations contain requirements for every stage of operation of an UST and associated piping, including tank registration and installation, performance and design standards, operating and monitoring requirements, financial responsibility demonstrations, tank upgrades, release or leak detection, release reporting, site investigations, corrective actions, and tank closures. Of utmost concern to UST owners, however, is the looming December, 1998 deadline by which they will have to either upgrade, replace or close their tanks.

The regulations require existing UST's either to be upgraded for protection from spills, overfills and corrosion or be closed. To meet the spill/overfill prevention requirements, all UST's must have catchment basins to contain spills and have overfill protection devices installed. Acceptable overfill protection devices include automatic shutoff devices, overfill alarms, and ball-bloat valves.

To meet the corrosion protection requirements, UST owners must either meet the corrosion protection performance standards for new UST's (i.e., purchase new tanks) or add corrosion protection to existing steel tanks and pipes. Corrosion protection performance standards for new tanks include:

Tank and piping made of non-corrodible material such as fiberglass.
Tank and piping made of steel having a corrosion - resistant and having catholic protection.
Tanks made of steel clad with a thick layer of noncorrodible material.

Cathodic protection methods include impressed current or sacrificial and systems. Acceptable methods for adding corrosion protection to existing steel tanks include:

Adding cathodic protection.
Adding interior lining to the tank.
Combining protection and interior lining.

The primary drivers for UST owners seeking to meet the December, 1998 deadline are:

Avoiding potentially substantial cost associated with investigation and Cleanup of contaminated sites.
Avoiding regulatory fines and penalties associated with non-compliance.
Avoiding potential criminal enforcement actions or civil suits for damages.

In addition to the above reasons to comply, failure to comply with the UST regulations may reduce or eliminate commercial insurance coverage or state agency reimbursement of cleanup costs.

While the decision to upgrade or close should be relatively straightforward, the strategy for closing an UST is more complex. There are several advantages to upgrading a system, including the fact that the work can often be done without disrupting the use of the tank. Upgrading can cost less than closing the tank. The biggest potential disadvantage of taking the upgrade approach is finding that the tanks will have to be removed anyway. This condition might develop if the upgrade is unsuccessful or impractical (i.e., holes are observed or contamination is present).

Management of the underground petroleum storage system can be a procedure that is full of many pitfalls and confusing strategies. The right type of coordination between owner/operator, regulatory agencies and contractors, is very important to create a smooth running operation with little or no disruption to be operation of the facility. It is important for the UST owners to take a proactive approach in managing the UST systems to void any fines or penalties if they fail to comply with the December, 1998 deadline.

If you have any questions regarding the management of your UST's, please feel fee to call Mark Volatile at (215) 244-1300 extension 28 or contact us via e-mail at:

Criterion Labs CRITERION Laboratories, Inc.
Environmental Consulting, Testing, and Training