State Underground Storage Tank Program
Seeks Reauthorization
The Department of Ecology’s Underground Storage Tank Inspection Program will end on July 1, 1999, based on a sunset provision in the law. Without the state law in place, it would be up to the federal Environmental Protection Agency to enforce the tank requirements.
Washington’s law, passed in 1989, mirrors the federal requirements. The goal of the tank law is to prevent releases from tanks by ensuring they are installed and managed safely. To meet this goal, all tanks must currently have leak detection and insurance, corrosion protection and spill and overfill protection by December 22, 1998.
Last year, Ecology began looking at options to either sunset the program, transition it to another government agency or reauthorize the existing state program. The process included working with a large and diverse group of people who either own, manage or regulate underground storage tanks. The group consisted of representatives from the private sector, small business and government.
The group’s recommendation to Ecology is to reauthorize the tank program. This recommendation was made after the group looked at various alternatives to having a state program, including:
The group felt that the state is doing a good job managing the tank program and that giving it to another agency may degrade the quality of service the program provides.
Ecology’s Underground Storage Tank Program has made tremendous progress since 1989. Over 27,000 old USTs have been removed, replaced or closed in Washington state. Of the remaining 14,600 operational USTs statewide, more than half are entirely upgraded to prevent releases. In addition, 73 percent are operating leak detection properly. The result is that the number of releases from tank systems annually is less than one-third of what the number of releases was in 1990.
Ecology has a technical assistance program which provides penalty-free inspections and advice about how to best meet tank requirements. If an inspection is passed, it has led to an insurance reduction for some tank owners. A handful of UST inspectors conducted almost 1000 inspections over the last two years to ensure tank owners were meeting tank standards.
"What we heard from the business community after conducting a number of meetings was that they have been pleased with the program," stated Barry Rogowski, Ecology’s Underground Storage Tank Program Coordinator. "Most tank owners say they like the Ecology program, because it supports a business climate where everyone has to play by the same rules. That way no one has an unfair economic advantage."
Ecology is continuing to ask for recommendations for program
improvements. To get more involved or to obtain information, call Barry
Rogowski, Underground Storage Tank Program Coordinator for the Department of
Ecology, at (360) 407-7236 or e-mail:
brog461@ecy.wa.gov.
Starting October 1, 1997, Ecology will provide site-specific technical and administrative consultations on independent cleanups. Assistance may be requested during any phase of an investigation and cleanup –before, during or after. Ecology may review site-specific work plans, sampling plans, feasibility studies, remedy selection, draft and final cleanup reports and provide detailed written opinions.
In the past, Ecology provided review of final independent cleanup reports under the Independent Remedial Action Program (IRAP). This type of review is still being offered, the only change is its name. In effect, the IRAP program is expanding and the name has changed. IRAP reviews will now be conducted as a Technical Consultation under Ecology’s Voluntary Cleanup Program. The new service allows you to get Ecology’s help earlier in your cleanup.
Who Benefits:
Site owners, operators and consultants – receive Ecology advice early in the cleanup process. This can translate into improved compliance with state standards, quicker and better cleanups and can make it easier to sell property or get bank loans.
The state and citizens – will see an increase in the number and quality of cleanups. Environmental quality is improved and public health is protected.
What Does It Cost:
Ecology has always provided free consultation on issues related to carrying out the requirements of the Model Toxics Control Act. Free consultations are usually limited to an hour either on the phone or in person. Ecology will continue to offer this type of assistance.
For many sites, more detailed and time-consuming assistance will be required. Ecology may recover its costs of providing enhanced technical consultations, including the review of final independent cleanup reports. Services will be provided on a first-come-first-served basis. A $500 deposit will be required to secure your place in line. The deposit will cover approximately eight hours of Ecology’s time. If review costs exceed the amount of your deposit, you will be billed at the established hourly rate -- typically ranging from $60 to $80 per hour -- depending upon the type of expertise required. Unused portions of your deposit will be refunded to you.
Voluntary Cleanup Program Services:
The Voluntary Cleanup Program includes a range of opportunity for assistance from a simple telephone consultation on a completely independent cleanup to full Ecology oversight with a signed legal agreement. Depending on your needs, you may request any of the following services:
An Ecology Focus sheet is being developed to describe the Voluntary Cleanup Program in more detail. For more information about enhanced technical assistance or Ecology’s Voluntary Cleanup Program, please contact Sherrie Minnick at (360) 407-7200 or 1-800-826-7716 or e-mail: shan461@ecy.wa.gov.
Return to Table of ContentsRemoval or Closure-In-Place
Requirements for Regulated Underground Storage Tanks
If you have a regulated underground storage tank and you want to close it, there are certain requirements that you will have to meet. They are:
These requirements do not apply to non-regulated UST systems, such as heating oil tanks and farm/residential UST systems of fewer than 100 gallons capacity.
For more information, please contact the regional office in which your site resides. Names and phone numbers of Ecology staff are listed on the back of this newsletter.
Return to Table of ContentsWashington State Tank Owners: How Do
You Compare?
More underground storage tanks are in compliance with state and federal requirements in Washington than any other Northwest state -- based on a recent enforcement sweep conducted nationwide by states and the U.S. Environmental Protection Agency.
As part of a national effort in May to check that tank owners were meeting leak detection requirements, Ecology inspected 120 facilities across the state including gasoline stations, school districts and fuel facilities. 9,000 facilities were inspected nationwide.
Of the 120 facilities Ecology inspected, tank owners at 18 facilities received warning letters for being in violation of leak detection requirements, and 5 received a field citation with fines totaling $1,400. Nationwide, 2,600 violations were noted with fines totaling $900,000.
Results from other Northwest states are: Alaska conducted 16 inspections, found 4 facilities in violation, and issued 4 citations totaling $1,650 in fines; Idaho conducted 54 inspections, found 12 facilities in violation, and issued 3 citations totaling $900 in fines; Oregon conducted 98 inspections, found 47 violations, and issued one department order totaling $4,200 in fines.
"Washington State tank owners are doing a good job at meeting current requirements," said Lauris Davies, Underground Storage Tank Program Manager at the U.S. Environmental Protection Agency in Seattle.
Return to Table of ContentsOwners and operators of underground storage tanks and certified services providers are thinking about tank upgrades and retrofits with the December 22, 1998 upgrade deadline just 15 months away. If you are planning an upgrade or have finished a project including installing or retrofitting; conducting tightness testing; adding or testing cathodic protection; decommissioning or conducting a site assessment for tank closure, please remember to complete an Ecology checklist(s).
A completed checklist is your document of the work performed on an underground storage tank system. A checklist must be completed for each regulated activity within 30 days of the end of project, signed by both the certified supervisor and the owner, and submitted to the Department of
Ecology. Using the checklist provides owners and operators the opportunity to verify tank system upgrades and test results. In many cases, the data collected on a checklist proves a system to be in compliance with 1998 upgrade standards. When Ecology receives the information included in the checklist, it is entered into the UST/LUST database.
It is the owner’s responsibility to ensure that checklists are signed and submitted to Ecology.
If you have questions regarding the use of checklists, please call your local regional office. Names and phone numbers of Ecology staff available to assist you are listed on the last page of this Tank Bulletin.
Return to Table of Contents"Technical assistance" is the title we give the assistance we offer to tank owners/operators and others. This may involve answering questions about compliance with state and federal requirements or answering questions in general about underground storage tank systems. The key to this process is that the assistance
requested is by you, our customers. By requesting assistance, you’re creating a window for yourself where we can assist you in coming into compliance or solving problems with your system – without the fear of dealing with enforced compliance. The thought behind this idea is that if you’re concerned enough to ask for our help, it would be counterproductive for us to enforce against you. You’re trying to "do the right thing."
From an inspector’s point-of-view, technical assistance (when compared to enforced compliance) is always the preferred option. Technical assistance allows us to get to know you and your situation so that we can deal with each other affably, rather than in the strained atmosphere that is often the product of unrequested compliance inspections and enforcement actions. Under the umbrella of technical assistance, we can look at a situation and tell you how we would solve the problem. We often offer more than one solution, so that you can pick what best suits your personal situation and creates the least impact on your life and business. On the other hand, when faced with an enforcement situation, we may not be able to give you options and may be forced to put other constraints (deadlines) on you to ensure that the situation is resolved.
Now for the problem with technical assistance. Our efforts in this area have brought mixed responses from you. We’ve gotten response rates as high as 25 percent in one county, and as low as 1 percent in another. While 25 percent is a fairly respectable response, it was only one county. Five to 10 percent seems to be the average response rate. This isn’t very good, and we can only assume that people don’t believe we’re on the level in trying to provide help while avoiding bureaucratic details that complicate everyone’s lives and livelihoods. Technical assistance is free, it’s easy to get and it’s meant to deal with problems – tough as well as easy – without creating any unnecessary stress. In order for it to work, we need tank owners/operators to help us.
Owners and operators who feel they are out of compliance or know they have problems can gain the most by requesting assistance. We know that many of you are dealing with the question of how to handle the 1998 upgrade requirements. Our feeling is that you’re avoiding us, because you don’t know how to handle this very big problem. You are the people who should be taking advantage of our help.
We see literally hundreds of sites and consequently, see many ways to deal with all kinds of problems. In addition, we know the regulations – we know what you’ll have to do to be in compliance. We can clear up misconceptions and offer innovative ways to deal with problems. All too often, we see that people have huge misconceptions of what is required of them and stress themselves needlessly about how to deal with their problems. We want to help, and we want to make your life easier – and the only way we can do that is if we have your trust and cooperation.
In short, call us and use our knowledge. You pay your tank fees and taxes – you’re entitled to all the help we can give you.
Technical assistance is not a one-time or limited-time offer. It’s always available. So if you have problems, think you might have problems or even if you’re sure you don’t have problems, take advantage of what we offer. You might be surprised at what you learn.
Return to Table of ContentsWater getting into your turbine sump area? Leak sensor alarms going off from water intrusion? Paying money to continually pump water? The Department of Ecology is in the process of gathering information on these types of problems and soliciting ideas for solutions.
Generally, there are two types of problems. One is from rainwater entering through the manway cover area. The other problem is from groundwater entering the sump area through the electrical conduit, piping or tank/collar joint.
Operators who maintain these systems point out the bolted manway covers are the hardest to access and don’t stop rainwater. The design needs to provide easy access and allow water to drain away from the cover. This can save countless hours of employees’ time in checking the sump areas, especially at large tank sites. The cheaper manway covers could end up more expensive, if you add in pumping costs and employees time involved.
For groundwater intrusion problems, there are products on the market that can be used to seal off the areas where water is coming in. Be sure the product used will work with your type of tank equipment (i.e. steel, fiberglass).
Other problems encountered include water in the spill bucket or catchment basins around the fill pipe, and water in the dispenser sump areas.
With the December 1998 upgrade deadline coming up soon, many owners are preparing to install new systems or upgrade current ones. Before deciding on a design, ask your contractor for referrals from other owners and speak with them before you sign.
Ecology is in the process of soliciting ideas for these problems. We are looking for 1) how to best design new tank installations which address rain water/groundwater intrusion, and 2) how to retrofit existing tank sites.
If you have solved these problems and would like to share your solutions with other tank owners and tank service providers, let us know. If you would be interested in either attending a forum or presenting solutions, call Annette Ademasu at Ecology’s Northwest Regional Office (425) 649-7189 or e-mail: aade461@ecy.wa.gov
Return to Table of ContentsDon’t Forget Emergency Generator Tanks
Part II: The Correction
In the last issue of the Tank Bulletin, we ran a short article on upgrading
emergency generator tanks. In that article, we failed to mention internal lining
as a corrosion protection option. Internal lining alone or internal lining
combined with cathodic protection may be added to your tank system as a form of
corrosion protection. We apologize for the error.
Leaking Underground Storage Tanks (LUST)
chart
This chart can be viewed and printed using Microsoft PowerPoint. For those Windows users that do not have PowerPoint, a viewer can be downloaded free from Microsoft.
Map of Ecology's Regional Offices
UST/LUST Information: 1-800-826-7716