Ecology's Toxics Cleanup Program has adopted the goal of having all regulated underground storage tanks fully upgraded and in compliance with the regulations by the deadline of December 22, 1998. This means the Department of Ecology does not intend to allow an extension of the upgrade deadline. Tanks will not be able to get an operating permit after that date, unless the tank meets all applicable standards.
Most tank owners are proceeding with upgrading tanks, and the state of Washington seems to be somewhat ahead of most of the nation in tanks being upgraded. A great deal of credit must be given to tank owners in Washington, who have individually struggled to meet the new tank operation standards. This has been a significant investment of time and money. But the payoff will be a safer, cleaner environment for Washington's citizens, and the long-term protection of land values through the elimination of contaminated properties. Those of you who have worked to make this possible can be proud of the success.
You may not know this, but unpaid UST permit fees can jeopardize your business license. Nonpayment of fees can delay the renewal of your liquor, cigarette, or other licenses issued through the Department of Licensing's Master License Service.
There is an exception. Example: A retailer retains ownership of the tanks at a site, but a franchisee is operating the mini-mart and holds the liquor license at the site. The franchisee can continue to receive his/her licenses even if the company owning the tanks fails to renew the tank permits, since these are two separate businesses.
Perhaps you "slipped through the cracks" during the permit conversion process from Ecology to the Department of Licensing last spring, and never purchased your UST permit--although you're receiving product. Here's another scenario: You own a convenience store that sells cigarettes, liquor, and at one time--gasoline. If you sold gasoline, then there's a pretty good chance that an underground storage tank (UST) is still in the ground. If it is, unless it's been properly closed, you are still responsible for paying the UST permit fees.
It is a state law that annual tank fees be paid by every person who owns an underground storage tank (WAC 173-360-190). Unless your UST has been properly closed by the time of your billing date, you're responsible for paying your fees.
If you're not sure how to properly close an unused tank, call an Ecology inspector. Although you will have to purchase your UST permit, you will not be fined. Instead, Ecology will put you on a compliance schedule to get your tanks closed.
For more information, please call the Ecology inspector for your area. You can also receive a packet of information on tank closure by calling 1-800-826-7716.
We have some exciting news for you! The Underground Storage Tank (UST) List and Leaking Underground Storage Tank (LUST) List are now available to download from the internet.
As mentioned in the Winter 1996 Tank Bulletin, both lists are also available on disk. The disk price for each list is $22.14. Hard copies are still available for $.15 a page. You can order a disk or hard copy by calling (360) 407-7170.
Whether removing, upgrading, or replacing tanks-- advanced, detailed planning of your project can result in a cost savings to you, as well as reduce your frustrations.
The most important part of tank work is having, in writing, a detailed list of the work to be performed and a firm estimate of the costs involved. Specify to your contractor that you wish to be notified if costs exceed what you have in writing. It is sometimes too easy to simply keep digging, running up a huge tab on soil disposal costs, or performing other work that may or may not be needed. If you want to act as your own general contractor it can save you money and give you a greater feeling of control over the project--but only if you cover all the bases in advance and have a well thought-out plan.
All legal regulations for tank work are in writing. You may have a copy and explanation of what they mean by calling your local Ecology office. Talking to government regulators may seem somewhat like going to the dentist: there is a chance that you will only get more bad news. But many of the same rules apply when talking to regulators as when talking to contractors. Always get specific details and ask what, where, and why. In all cases, knowing the details of what you are getting involved in can only be to your benefit.
Going beyond what is required in the regulations is sometimes a good idea, because the regulations are only minimum standards. But you should know exactly what and why you are doing something that is not required by regulation, and what the benefit and payoff will be to you.
There are guidance documents available from the Department of Ecology which discuss both the requirements of closing tanks and provide insight into the contracting of tank work. You may request these documents from your local regional office or by sending an e-mail request to shan461@ecy.wa.gov. The document are:
In partnership with the Duwamish Coalition, the Department of Ecology has an initiative to determine site specific cleanup levels for total petroleum hydrocarbons (TPH) compatible with the Model Toxics Control Act (MTCA). The initiative will develop TPH cleanup standards that will measure potential environmental and health impacts for all TPH contaminated sites.
The developing framework for TPH cleanup standards is based on the ASTM Risk Based Corrective Action (RBCA) model with emphasis on compatibility with existing MTCA methods. Additional components being considered are for a pre-Tier 1 assessment and for the inclusion of ecological and aesthetic considerations.
TPH contamination is an important issue because many sites are contaminated with this complex chemical mixture and there is no consensus on how to evaluate the environmental or health impacts. In some places, 85 - 90% of contaminated industrial real estate in Washington is contaminated with some form of petroleum hydrocarbons. As a complex chemical mixture composed of hundreds of different hydrocarbons, TPH presents many formidable technical problems. Not only do the hydrocarbons differ in their original constituent types, toxicities, and concentrations but the hydrocarbon mixtures are subject to volatilization, dissolution and naturally occurring biodegradation. The composition of the constituents changes with time and further complicates analysis and evaluations of the mixtures.
The objectives of this initiative are to review, develop, and implement methods to evaluate all TPH contaminated sites in the areas of: 1) human health and environmental effects; 2) chemical fate and transport models; and 3) risk management tools.
Ecology is working with the Duwamish Coalition (local business, City of Seattle, King County, Port of Seattle, City of Tukwila, and state and federal government) utilizing an EPA Brownfields/UST grant.
For additional information or any questions, contact Steve Robb at (360) 407-7188 or e-mail at srob461@ecy.wa.gov.
Do you have questions about the impending tank upgrades we still haven't answered? Do you have opinions about certain UST policies or issues that you think should be heard -- not only by Ecology but by the general public?
Well, here's your chance. Beginning with the Summer 1996 issue of the Tank Bulletin, a section will be set aside to answer your questions and to present your views.
Just send your question/view to Sherrie Minnick - Tank Bulletin, Toxics Cleanup Program, Department of Ecology, P.O. Box 47600, Olympia WA 98504-7600 or e-mail shan461@ecy.wa.gov. Please specify if you do not want your name published.
Corrosion results when bare metal and soil and moisture conditions combine to produce an underground electric current that destroys hard metal. Over time, corrosion creates holes and leaks develop.
What does this mean to you as an owner of an underground storage tank? If your tank leaks as a result of corrosion, not only could the release of petroleum cause a threat to human health and the environment, but you, as owner, would be liable.
To prevent such mishap, the EPA established a deadline of December 22, 1998 for all USTs installed before December 22, 1988 to either be replaced or have corrosion protection installed on their tanks (tanks installed after that date have already had to meet the requirements).
Existing tanks, those installed before 1988, can be upgraded by adding an interior lining to the tank, by adding a cathodic protection method to the tank (such as an impressed current system or sacrificial anodes), or by adding both.
If you haven't upgraded your tank yet, here are a few items to think about.
Interior Lining Cathodic Protection
Warranties 10 years against No corrosion-induced leakage
corrosion-induced warranty; 1 year for materials
leakage; 1 year for and workmanship; no structural
materials and workman warranty
ship; no structural
warranty
Piping Does not address Upgrades piping as well
piping
Internal/ Does not address Does not address internal
External external corrosion corrosion
Corrosion
Time Process takes about 1 No interruption of use of tanks
day per tank
Costs Average cost per 8,000 Average cost for "typical"
gallon tank is $5,500; 3-tank facility is between
"typical" 3 tank $9,000 and $16,000; cost does
facility cost is not change much with size or
$16,500; cost does not number of tanks
change much with size
of tank; cost varies
directly with number of
tanks
Monitoring Tank is to be Rectifier is to be checked
internally inspected every 60 days for proper
after 10 years and operation; cathodic protection
every 5 years system is to be checked every 3
thereafter years for adequate protection
Keep in mind that these are "approximate" costs -- they will vary. Also be aware that insurance companies are likely to charge higher premiums for tanks that have been upgraded, as opposed to those that have been replaced with brand new systems. If you are planning on keeping your tank for a while, it may be worth investigating your long-term insurance costs to see if upgrading is really the most cost-effective way for you to do business.
Adapted From L.U.S.T.LINE, courtesy of Marcel Moreau
In June 1995, underground storage tank (UST) permits were replaced by an endorsement on an owner's Registration and Licenses document (Master Business License) issued by the Department of Licensing. The Master Business License lists the number and identifies the names of the tanks at the site.
When delivering product, it is important for the petroleum distributor to make sure the owner has a tank endorsement on his/her Master Business License and that it hasn't been revoked due to the tank being out of compliance with state standards. It is also important for the distributor to examine the expiration date of the endorsement to make sure it hasn't expired.
Please be aware that it is illegal to deliver product, as well as receive product or have a tank in operation, if the tank has not been endorsed. Violation of the law may result in penalties and/or fines to the owner and distributor.
Example of Master Business License (220K)
By December 22, 1998, underground storage tank systems must be upgraded to meet regulatory requirements or closed. This does not apply to home heating oil tanks or farm or residential tanks of 1,100 gallons or less capacity used for non-commercial purposes.
There are three categories of standards that must be met: spill protection, overfill protection, and corrosion protection. Refer to EPA's booklet "Musts for USTs" or Ecology's "Upgrade Your Underground Storage Tank -- Don't Wait Until 1998" for more details on these requirements. Please remember, only specifically qualified professionals are allowed to do the work. Please determine that any contractor you use for upgrading activities is certified by the International Fire Code Institute, as the owner is responsible for complying with the regulations.
Question: What are the requirements?
Answer: A CATCHMENT BASIN must be sealed around the fill pipe. The basin should be large enough to contain what may spill when the delivery hose is disconnected from the fill pipe. Basins range in size from those capable of holding only a few gallons to those that are much larger. Any liquid should then be removed from the basin with either a pump or drain.
Question: What are the requirements?
Answer: Install an AUTOMATIC SHUTOFF DEVICE on the fill pipe. This can slow down and then stop the delivery when the product has reached a certain level in the tank.
OR
Install an OVERFILL ALARM. Overfill alarms use probes installed in the tank to activate an alarm when the tank is either 90 percent full or within 1 minute of being overfilled. Alarms must be located where the driver can see or hear them easily and are often part of automatic tank gauging systems.
OR
Install BALLFLOAT VALVES at the bottom of the vent line several inches below the top of the UST. The ball floats on the product and rises with product level during delivery until it restricts vapor flowing out the vent line before the tank is full. Manufacturers do not recommend using ball float valves with suction piping, pressurized delivery, or coaxial Stage 1 vapor recovery.
Question: What are the requirements?
Answer: First, if you are only adding cathodic protection, you need to assess the integrity of the tank to make sure it's structurally sound.
You can use results from one of the monthly leak detection methods (interstitial monitoring, automatic tank gauging, monitoring for vapors in the soil, monitoring for liquids in the ground water, statistical inventory reconciliation) to show the UST is not leaking
OR
You can use results from two tank tightness tests to show to show the UST is not leaking. The first test takes place before you install your corrosion protection system and the second test takes place between three and six months after installation.
You can have the tank internally inspected, tested, and assessed to make sure the tank is structurally sound and free of corrosion holes.
OR
You can one of the new alternatives described in the American Society of Testing and Materials (ASTM) Standard ES 40-94. The alternatives include statistical based analysis, using an ultrasonic robot to test tank wall thickness (this is not on the market yet), or combining a site investigation with a video camera inspection of the inside wall of the tank.
Answer: Second, install cathodic protection to your tank and piping, or interior lining to your tank or cathodic protection and interior lining to your tank and piping.
An IMPRESSED CURRENT system is a form of cathodic protection which uses a rectifier to convert alternating current to direct current. This current is sent through an insulated wire to the "anodes," which are special metal bars buried in the soil near the UST. The current then flows through the soil to the UST system, and returns to the rectifier through an insulated wire attached to the UST. The UST system is protected because the current going to the UST system overcomes the corrosion-causing current normally flowing away from it.
OR
A SACRIFICIAL ANODE OR GALVANIC SYSTEM is another form of cathodic protection that can be used. Although sacrificial anode systems work with new USTs, corrosion protection experts generally agree that sacrificial anodes do not work effectively or economically with most existing steel USTs.
OR
INTERIOR LINING can be added to the tank. The lining must be a thick layer of noncorrodible material.
OR
Combine cathodic protection and interior lining.
Answer: Third, all systems require testing and inspecting to make sure they are working properly.
Cathodic protection systems must be tested by a qualified cathodic protection tester within 6 months of installation and at least every three years thereafter. You will need to keep the results of at least the last two tests to prove that the cathodic protection system is operating properly. In addition, an impressed current system must be inspected every 60 days to verify that the system is operating. Keep results of the last three inspections to prove that the impressed current system is operating properly. Tanks using only an interior lining for corrosion protection must pass an internal reinspection 10 years after installation and every 5 years thereafter.
With a combined method of cathodic protection and interior lining, your UST will receive more corrosion protection. You are not required to have the interior lining periodically inspected (which saves you the cost of those inspections). You will still need to have the cathodic protection system tested and inspected periodically.
Adapted From L.U.S.T.LINE, courtesy of Marcel Moreau
Map of Ecology's Regional Offices
UST/LUST Information: 1-800-826-7716
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