“Out of sight, out of mind” rarely works – ask anyone who’s ever worked in the environmental field. When something has been out of sight for 30 years, it might truly become “out of mind”, which could be dangerous.
Underground storage tanks (USTs) are, as their name implies, underground. And while we rely on them for heating, vehicle fueling, and powering emergency generators, we rarely celebrate the anniversaries of their installation. USTs offer many benefits (protection from the elements, protection from physical impact, and their discrete location maintains surface aesthetics), but they also raise environmental concerns. Until the mid-1980s, most USTs were made of bare steel, which is likely to corrode over time and allow UST contents to leak. As such, they require replacement on a periodic basis, depending on their design, construction, and maintenance history, as well as on the state regulations governing the tank.
In Connecticut, for example, tanks must be removed within 30 years of their installation date. However, extensions on their life expectancy may apply. To determine if a tank qualifies for a 10-year life extension, we first review the Eligibility Requirements (heating oil storage tanks and uses other than heating oil storage), and then we review the Conditions to Maintain Eligibility for years 31 through 40. If determined to be eligible, we then confirm with the CTDEEP for approval.
If a tank does not qualify for an extension of use, options include: UST closure, replacement, and/or remediation services (if a release from the UST system occurred). Tank closure includes: pre-notice, tank cleaning/washwaters disposal, tank and piping disposition, soil and groundwater (if encountered) sample collection/analysis, a written closure report, and regulatory notification filing. UST replacement includes: design (sizing/piping/ monitoring systems), installation conditions (buoyancy/surface conditions), certification of installation, startup/testing, and site restoration. We have also assisted clients by installing aboveground storage tanks (ASTs) instead. AST installation includes: design (building code review, sizing, piping-support, monitoring systems), installation conditions (pad requirements), certification of installation, startup/testing, and site restoration.
Though your UST may be out of sight, its condition is on our minds. If you have any questions or would like additional information about what to do with your aging UST, please give us a call. (800.286.2469)
About the Authors:
Deborah Denfeld, PE, CHMM, CET is a project manager providing services in the areas of hazardous waste, solid waste, oil storage, recyclables management, as well as discharges of wastewater, stormwater and air emissions. Deb also conducts regulatory environmental training at open-enrollment events and at client sites.
Adam Barbash, PE, CHMM specializes in federal and state regulations, as well as assisting clients comply with ever-changing requirements. Adam’s experience includes working with air, water, and waste programs and complying with EPCRA, DOT, and safe drinking water act programs. Adam also has experience preparing and implementing ISO 14001 programs and working with European Union programs such as REACH and RoHS.
