Underground storage tanks, or USTs as they are commonly called, have for many years been used at facilities to store bulk quantities of liquids for on-site use or for retail storage. Materials stored in USTs commonly include heating oil and gasoline. USTs are extremely common, and continue to a preferred means of bulk liquid storage at properties where aboveground storage vessels are neither practical or desirable. However, the presence of a UST at a property represents a potential environmental concern, since the accidental release of oils or other substances to the subsurface can result in significant cleanup costs. 

In the past decade, many large oil companies have replaced their USTs at their retail gas stations with newer tanks of double walled and/or fiberglass construction. However, most smaller tanks currently still in use for oil storage in residences or commercial/industrial properties are of single-walled, steel construction, and many are greater than 20 years in age. Tanks of this type commonly undergo some degree of deterioration in the subsurface over time, due to the effects of moisture and corrosion. Small leaks can develop, which may initially be undetectable on inventory records. In such a case, significant impacts to the subsurface can occur before any inventory loss or other evidence of problems are detected. Releases can also occur through spills during filling or other operational errors. The net result of a reportable release of any kind is often an investigation and cleanup of soils and/or groundwater. These efforts can be time-consuming and expensive, and are usually subject to oversight by regulatory agencies. 

The potential for the UST-related scenarios can create significant liabilities at a site. However, there are certain tools which are used to assess the potential for release to the subsurface from a UST. These include: 

  • Tank tightness tests
  • Narrow-diameter (GEOPROBE) boring investigations in the tank area
  • Removal of out-of-use USTs 

A Federal EPA deadline, carried down to each of the state environmental regulatory agencies, has come due, requiring certain upgrading features such as leak detection, corrosion protection and secondary containment to be installed in all USTs which fall under a certain definition of use as defined by the state agency. For instance, in Pennsylvania, all regulated tanks are subject to ruling and therefore require the upgrades to be in place. This ruling states that all regulated tanks not properly upgraded by December 1998 will not be permitted for future use, and the operation of tanks not meeting the new criteria will result in significant fines. For this reason, tank owners should refer to their state UST regulations to see if their tanks fall within the qualifying criteria; if so, upgrading should be installed as soon as possible. If tanks are out of use, they should be removed from service to avoid regulatory penalties, as well as the real estate liabilities associated with them. 

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