Tank Bulletin - Autumn 1998


The Tank Bulletin is produced quarterly by the Department of Ecology's Toxics Cleanup Program. The purpose of the Bulletin is to provide information to registered underground storage tank owners and operators and others who need to be kept current on underground storage tank (UST) issues. Web users are encouraged to contact the Editor and request to have their names removed from the mailing list to conserve precious resources.

Texaco Given Environmental Excellence Award for Ballard Cleanup

Texaco recently received a state Environmental Excellence Award for going above and beyond the call of duty when it cleaned up gasoline that had seeped into a Ballard restaurant and forced it to close. The award was presented to Texaco staff at its retailer trade fair on October 9.

In November 1993, a Burger King restaurant at 5500 Market Street in Ballard was filled with dangerous fumes when gasoline seeped into an underground sump that drains water from the building’s foundation. The Seattle Fire Department temporarily closed the restaurant to protect workers and customers.

A Texaco service station uphill from the restaurant appeared to be the most likely source of the problem. Investigation and initial cleanup work, however, revealed no direct link between the service station and the fumes in the restaurant. In fact, a clear connection to a responsible party was never found.

Texaco followed through with a full cleanup despite the lack of proof that it was responsible. The company installed a state-of-the-art soil-vapor/ground water extraction system that, after five years of operation, has substantially cleaned up the soil and groundwater in the area. The cleanup has cost Texaco about $350,000. Most leaking underground storage tank cleanups cost less than $100,000.

"This is a fine example of good corporate citizenship," said Mike Rundlett, director of Ecology’s northwest regional office. "The Texaco folks didn’t have to step forward and do this cleanup, but they did the right thing anyway. If Texaco had not taken on the task, cleanup would have been delayed while the state went through an expensive search for a responsible party."

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Did Ecology Send You a Leaking Underground Storage Tank (LUST ) Letter

Certified letters were recently sent to some owners and operators of leaking underground storage tank sites. The purpose of the mailing was twofold: first, the mailing was done in an effort to ensure Ecology’s database accurately reflects the current status of these sites, and second, the mailing was an attempt to qualify for federal funding.

Federal funding pays for Ecology’s LUST staff, who in turn provide technical assistance on LUST sites and review independent cleanup reports, among other things.

The process turned out to be very helpful – both to Ecology and to site owners and operators. Many owners and operators of LUST sites were unaware that their site may still be "considered" contaminated or were unsure of the reporting requirements.

As for Ecology, according to Guy Barrett, Ecology’s LUST Coordinator "As a result of the LUST letters, we have received information to close out many LUST sites, thereby making us eligible for additional federal assistance."

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Tank Tagging is a Reality

This month, Ecology started issuing facility compliance tags to owners and operators of underground storage tanks whose sites meet the overfill, spill and corrosion protection standards set ten years ago by the Environmental Protection Agency. Owners of these tanks also have pollution liability insurance and have paid their $100 per tank permit fee. Ecology is issuing only one tag per site.

The intent of compliance tagging is to make it easy for people delivering fuel, Ecology inspectors, and the public to tell which operating tanks have met the requirements mentioned above.

"Currently, about 2,500 of the existing 5,000 sites in the state are fully upgraded and will receive a compliance tag," said Barry Rogowski, Underground Storage Tank Coordinator for the Department of Ecology. He noted, "The other half have received a warning letter and will get a final warning letter at the end of this month."

"We got a huge response from the first warning letter that went out. Tank owners are sending in so much information about upgrades and closures -- we can barely keep up!" added Rogowski.

Facility compliance tags will become effective December 22, 1998. Any underground storage tank site that doesn’t have a tag after that date can’t legally receive fuel. Truck drivers delivering fuel should check for a compliance tag at the emergency shutoff switch or some other visible location before delivering the fuel. The penalty for delivering fuel to an untagged tank site can be as much as $1,500 per tank. . In addition, you may have the expense of pumping the gas from your tank and having it disposed.

Starting in January 1999, Ecology will house an underground storage tank violation hotline. Anyone who sees an untagged site or sees product being delivered to an untagged site should report the information via the hotline. An UST inspector will then investigate the site.

**Ecology will issue compliance tags until close of business on December 22, 1998, and thereafter for any newly constructed site or site that attains compliance after that date.

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Tank Tagging – Where do you Stand

You’ve heard all this talk about tank tagging and certified letters going out here and there. If you are unsure of your status, in other words will you get a tank tag, take a look below. These are the steps Ecology has taken in the tagging process. They should give you a good idea of where you stand in the process and what you may still need to do to receive a facility compliance tag by the December 22, 1998, deadline.
  1. In July 1998, Ecology sent letters to UST owners and operators that cited reasons for why their site would not receive a facility compliance tag.
  2. If you DID NOT receive a letter, this means that according to Ecology’s database, you are in compliance and will receive a facility compliance tag before December 22, 1998.
  3. If you received a letter from Ecology in July and have since provided documentation to show that your UST system is in compliance, YOU WILL receive a tag by December 22, 1998.
  4. If you’ve received another letter from Ecology stating that records indicate your site is STILL NOT IN COMPLIANCE, please call your regional Ecology office immediately. We want to make sure that if you’re in compliance, you receive your tank tag and are able to sell fuel after the December 22 deadline.

It’s important to stress that an incorrect address could affect whether or not you receive your facility compliance tag. You need to have the correct address on all the paperwork you send to Ecology.

Additionally, please check the address on all the mail you’ve received from Ecology. If it’s different from where you want your tag mailed, you need to let your nearest Ecology regional office know.

We want to make sure your facility compliance tag is sent to you, and you receive it before December 22, 1998.

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The Deadline Won’t be Extended

The day is coming – the December 22, 1998, upgrade deadline will be here in less than two months.

Some people think the deadline will be extended, or that Ecology will not enforce it. The message from Ecology and the Environmental Protection Agency is the deadline will not be extended, and Ecology will enforce it.

If you haven’t upgraded your tank system, here’s some timeframes you should take a look at!

If the service provider you choose can get the upgrades completed in time, make sure you both complete a Retrofit/Repair Checklist, and send it to Ecology immediately. That way, you’ll be able to get your facility compliance tag before the December 22, 1998 and stay in business.

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Check Your Farm Tank – It May Be Regulated

There has been a lot of information and talk exchanged lately about the approaching deadline for compliance with the federal and state Underground Storage Tank laws. While most of the talk has focused on gas stations; mom and pop stores; distributors; and other common petroleum tanks, very little has been said about underground farm tanks. According to the UST regulations, a farm tank that holds more than 1100 gallons is subject to the regulations.

A "farm tank" is a tank located on a tract of land devoted to the production of crops or raising animals. The tank(s) must be located on the farm property and used for farm purposes. "Farm" includes fish hatcheries, rangeland, and nurseries with growing operations. It does not include laboratories where animals are raised, land used to grow timber, pesticide aviation operations, retail stores or garden centers where nursery products are marketed but not grown, cemeteries, golf courses, or other facilities dedicated primarily to recreation or aesthetics or other non-agricultural activities.

According to the UST regulations Chapter 173-360-110 (g), the only exemption is "farm or residential UST systems of 1,100 gallons or less capacity that are used for storing motor fuel for noncommercial purposes."

Petroleum distributors must follow the same regulations when delivering product to underground farm tanks as when delivering product to a major gas station. If the tanks are not in compliance and not permitted, product shouldn’t be delivered. Delivery to a tank out of compliance and/or not registered is a violation of the Underground Storage Tank law. It subjects the distributors and the owner or operator of the tanks to penalties and fines.

If you have questions or concerns or would like technical assistance in regards to your tank(s), please call your local regional office (refer to the map on the back of this newsletter).

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Temporary Closure – an Alternative

Owners and operators who have not yet been able to upgrade their systems or have not been able to schedule a contractor to do the work, have an alternative: temporary closure.

Tanks can be temporarily closed up to 12 months. However, you’ll still need to carry pollution liability insurance and maintain your license.

Temporary closure must be performed by a certified supervisor. Ecology must receive a temporarily closure checklist, completed and signed by the owner or operator and the certified supervisor.

If deciding to go with temporary closure, Ecology suggests that you have your tanks pumped dry so you won’t have to maintain a form of release detection.

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Piping Can’t Hide

Many owners and operators have already had their tanks upgraded to meet (and beat) the December 22 deadline. But did you know that metal piping is required to be corrosion protected too. All metal piping, including the copper lines that are often attached to emergency power generators, must be protected.

Metal piping may be protected in the following ways:

  1. Attaching a sacrificial anode (zinc, magnesium, etc.);
  2. Attaching an impressed current system designed specifically for your UST system;
  3. Contained within a non-corrodible pipe so that the piping is not in contact with soil.

If you don’t provide Ecology with documentation that your piping has been cathodically protected, you won’t receive a facility compliance tag from Ecology, and you can’t legally receive product.

If you have any questions, please call your nearest Ecology regional office.

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