Under Storage Tank

7/27/2019 Under Storage Tank

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EPA 510-R-04-001

UndergroundStorage

Tanks:

Building

On The Past

To Protect

The Future


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Word From The Assistant Administrat

T

wenty years ago hundreds of thousands of un

age tanks leaking petroleum were contamina

drinking water supplies. Since then, EPAs unde

tank program has contributed to a remarkable national

protecting our nation's soil and groundwater from leaki

Partnerships have been the cornerstone of the program

intergovernmental and private partnerships involving

have resulted in closing over 1.5 million substandard ta

over 300,000 releases of environmental contaminants, anumber of new releases.

In fact, over 18,500 cleanups were completed in Fisca

represents a 17 percent increase in the number of cleanups completed over the prev

also has been an improvement in preventing releases and detecting leaks. Approxim

releases were reported in Fiscal Year 2003 - about 60 percent lower than the annua

age of approximately 27,000.

But we cannot rest on this record. There is still more we can do by working with fac

operators in preventing releases and detecting them more quickly when they occu

commitment and strong partnerships, we will continue to identify solutions to both o

lenges related to underground storage tanks.

Marianne L

Assista

Office of Solid Waste and Eme

Underground Storage Tanks: Building On The Past To Protect The Future


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Executive Summary ..........................................................................................................................

Milestones In The Underground Tank Program .................................................................

Underground Storage Tanks - A Program Of Partnership, Innovation, And Res

Creating A Program To Implement The New Law ..................................................................

EPAs Regulatory Program............................................................................................................

Strong Emphasis On Approving State Programs .....................................................................

Fulfilling EPAs Responsibilties In Indian Country...................................................................

Compliance Assistance And Outreach Make A Difference ....................................................

A Measure Of Our Success............................................................................................................

Commitment To Finding Innovative Solutions ..................................................................

Pay For Performance......................................................................................................................Risk-Based Corrective Action.......................................................................................................

State Trust Funds............................................................................................................................

Continuing Challenges ...................................................................................................................

Improving Operational Compliance ............................................................................................

Completing Cleanups .....................................................................................................................

Minimizing Leaks From New And Upgraded Tank Systems..................................................

Cleaning Up And Reusing Petroleum Brownfields...................................................................

Meeting New Challenges


Contents


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This year, the national underground storage tank program celebrates its 20th anniver

of this report is to celebrate 20 years of strong partnerships, highlight some of

accomplishments, and offer a short program history, so that as we look to the futu

ue in the strong tradition of our past.

In 1983, the CBS program 60 Minutesaired a story called Check the Water. The reportattention to families suffering from the effects of gasoline leaking from underground storag

a year later, Congress passed and the President signed a new law designed to protect the

and other petroleum releases.

With this new law in place, the U. S. Environmental Protection Agency (EPA) faced the daunt

ing the nations two million underground tanks storing petroleum and certain hazardous subst

responded quickly and creatively. Because of the number of tanks, the diversity of ownership

strong state involvement, EPA designed a program that was unlike any other regulatory prog

less than four years, EPA built a new federal program one noteworthy for its protective bu

ance-based regulations; its aggressive approval of qualified state programs; its vigorous outre

and its strong partnerships with states, tribes, industry, and many other partners still involved t

Through these partnerships, we have found new ways to tackle

old problems. And because of this innovative spirit, we have suc-

cessfully met many of the expectations Congress and thePresident had in 1984 when the program was created. Together,

EPA, states, tribes, and industry have closed 1.5 million old,

unsafe tanks and have upgraded or replaced nearly all other

underground storage tanks. Of the 400,000 plus known leaks,

nearly 70 percent have been cleaned up; the number of new leaks

being discovered each year has dropped dramatically, from a high

of over 66,000 in 1990 to roughly 12,000 last year.

As we celebrate the 20th anniversary and enter the third decade

of our program, new challenges lie ahead. These challenges

include cleaning up and encouraging reuse at 200,000 or more

abandoned gas stations and petroleum brownfield sites littering

our cities and countryside; cleaning up more than 100 000

Underground Storage Tanks: Building On The Past To Pro

Executive Summary


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EPA

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EPA

launches

initiatives

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accelerate

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improvecompliance

recycle gasstations

evaluatetanksystems

EPA establishes

first partnership

to promote risk-

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Final deadline

for owners to

close, upgrade,

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tanks

300,000

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initiated

200,000

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completed

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completed

U. S. space

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At 77, John

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America Onlineagrees to buy

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The Hatfields, an average American family, lived in Canob

Park, Rhode Island about 12 miles from Providence. In

1980, this family had a big problem they could not use

their tap water. They couldnt drink it, bathe in it, or cook with it.

Their well was contaminated with gasoline that migrated from the

neighborhood gas station, just a quarter of a mile from their house.

In December 1983, their story aired on the CBS show, 60 Minutes.

Buried gasoline tanks gained the national spotlight when 60

Minutes released its investigative report, Check the Water.

That report revealed other neighbors in Canob Park were in

the same situation gasoline leaking from underground stor-

age tanks was contaminating their drinking water.

That report and similar stories

prompted Congress to swiftly enact

legislation to create federal standards

to regulate these tanks. In November

1984, a year after the 60 Minutes

report aired, President Reagan signed

into law Subtitle I of the ResourceConservation and Recovery Act

(RCRA). The new subtitle required

the U. S. Environmental Protection

Agency (EPA) to develop a com-

prehensive regulatory program for

underground storage tanks (USTs)

storing petroleum and certain hazardous substances. In 1986,Congress and the President went one step further and created

the Leaking Underground Storage Tank (LUST) Trust Fund

to pay for the cleanup of releases from these tanks.

Creating A Program To Implement The

Underground Storage Tanks - A Progr

Of Partnership, Innovation, And Resul

With the right balance between

industry, federal, state, private a

forces, you can get a lot done. T

program is an example where wthe right balance. Im very prou

a role in it.

Senator David Durenberger, MinnesotaIntroduced UST legislation in the U.S. Senat


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the exact numberground storage tankthe federal law. Estimthe millions, and thlocated in every Zip

United States. Whthese tanks were alred by local and staand health standard

tions were often incincomplete. The newulatory program w

regulatory gaps anding programs that Etered.

EPA knew there woenough resources a

level to fully implement the program, to inspecand to oversee the cleanup of every release. To s

needed to heavily involve states in implementing EPA and states would have to become close par

To understand the technical problems with undeage tanks, EPA reached out to a wide range of eand local officials, leaders from environmental manufacturers, equipment installers, environme

ants, gas station owners and operators, and many

sought their ideas and welcomed their input. EPAregulations to address the real problems with storage tanks, be easily implemented by statesstood by tank owners.

EPA didnt stop there. Perhaps one of the mosi ll 20 h


The UST regulated community is a very

diverse group. They range from small, one-

station operations to big oil companies.

Large companies have many resources andunderstand that environmental compliance

is one of the costs of doing business. EPA

understood that smaller operations needed

more environmental compliance assistance

and technical support.Lee Thomas

EPA Administrator, 1985-89


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and standards to ensure product consistency and the samelevel of service, regardless of where stores were located. Atthe same time it gave individual stores flexibility to developand implement marketing strategies tailored to their specificneeds. It was clear to these companies this approach worked

because it used the strengths and knowledge of both the fran-chisees, who ran the businesses daily, and the franchiser, whoprovided national policy, crucial support services, and technicalassistance.

EPA was convinced a franchise approach would work for theunderground storage tank program because we faced issues sim-ilar to Century 21 the need to develop a national program with

a consistent set of standards that could be implemented by all50 states. So, EPA set out to develop a national program based

on the franchise approach, with the Office of UndergroundStorage Tanks (OUST) being the national franchiser and EPAregional offices working directly with states, the franchisees.

As the national franchiser, EPAs recipe for success includedfour key ingredients: promulgating performance-based federal

regulations; aggressively approving qualified state under-ground storage tank programs; fullfilling EPAs responsibilitiesin Indian Country; and providing vigorous compliance assis-

tance and outreach.

EPAs Regulatory Program

In 1985, when EPA began developing its new regulatory pro-

gram for underground storage tanks, the stakes were veryhigh. The Agency had to quickly promulgate effective andworkable regulations that would prevent underground storagetanks from leaking and clean up leaks that had occurred.

Congress had laid out its expectations less than a year earlier.



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nation is low. Eight months later on OctoCongressman Jim Florio, one of the key sponsoislation in the U.S. House of Representatives, avision stating that, implementation of these safegu

next decade and removal of leaking tanks will, in my vie

toward preserving Americas most precious natural resourcaquifers.

With these expe

mind, the Agency wly to develop andnew underground regulations. In les

years from start tomet the challenge. IEPA knew that bemagnitude of the

storage tank probtional regulatory prnot work. With ove

petroleum and hastance tanks in the ground most of which wsteel tanks, many already corroding and causinAgency knew a prescriptive one-size-fits-all regunot work.

Instead, the Agencpath to craft reg

were flexible, pbased, technology perhaps most reflected the needwho would be timplementors of t


We wanted to be sure that the regulations

were practical. When OUST was developing

the regulations we always thought of the

16-year old gas station worker measuringthe tanks at 6 a.m.on a cold day. Will he do

what we are asking him?

Ron Brand

First Director, Office of Underground Storage Tanks

EPA sought industry out and industry

made attempts to provide accurate andcomprehensive information.

Jeff Leiter

Former Co-chair of the Tank Coalition


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community needed flexibility to choose among effectiverelease prevention and leak detection equipment. At the sametime, the federal regulations needed to ensure flexibility didntcome at the expense of protectiveness for all Americans. Theregulations had to assure a basic level of protection for every-

one regardless of where the tanks were located.

Following hundreds of meetings, information gatheringefforts, and countless hours of writing, EPA promulgated itsregulations in the fall of 1988. The preamble and the regula-tions, covering 165 pages in the Federal Register, spelled out therationale for the regulations, requirements, deadlines, options,and areas of flexibility available to the regulated community.

The regulations required tank owners to cathodically protector otherwise close, upgrade, or replace their tanks within tenyears and put in place one of several leak detection methodswithin five years. For leaks that had occurred, the regulationsrequired owners to report them and clean them up accordingto state-specific standards that are protective of human healthand the environment. Owners also had to choose one of sev-

eral financial assurance mechanisms to demonstrate they hadthe financial resources to pay for the cleanups.

As comprehensive and technical as these regulations were fortank owners, the regulations were designed to achieve threesimple goals:

O Prevent leaks by requiring owners to close or upgradeold substandard tanks or install new, better, and safer

tanks that wont easily corrode and leak.

O Detect leaks quickly by requiring owners to replace orsupplement wooden dip sticks and other old, outdated

leak detection methods.



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Strong Emphasis On Approving Sta

Programs

As sound as EPAs new regulations were, the Agthat aggressive implementation of the program

to success. With olion regulated st

buried all across Aclear that the job wthe federal govimplement alone. Isame February 29,

(quoted earlierDurenberger laid otations on the flooSenate. It is my ex

said that this program will be run by the State governlittle Federal involvement.

It was clear 20 years ago states had to play th

implementing the underground storage tank overseeing and enforcing the regulations. EPAsucceed in implementing the program if states meet Congress expectations and EPAs desire


Currently 33 states, the District of Columbia and the Comm

Puerto Rico have EPA approved UST programs.

Having our own state program allowed us

to come up with innovative solutions to solve

UST problems that were unique to our state.

Michael Kanner

UST Manager

Minnesota Pollution Control Agency


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implementation, the Agency had to develop rules that wouldencourage states to seek formal approval to run their stateunderground storage tank program in lieu of the federal pro-gram. With so many corroding tanks and so many known andyet-to-be-discovered releases, the Agency had to design a

process to get qualified states approved quickly and with min-imal disruption to their existing work.

Just as the Agency had done with the technical regulations,EPA took a different approach for approving state under-ground storage tank programs. Because of the nature andmagnitude of the tank problem and the importance of gettingqualified states approved quickly, the Agency designed a

streamlined process for approving qualified state programs.Instead of requiring a burdensome and time-consuming line-by-line comparison between federal and state tank regulations,the Agency would review a state program against eight pro-gram specific objectives related to leak prevention, leak detec-tion, cleanup, and financial assurance. States demonstratingthat their standards in the eight areas were no less stringent

than the federal regulations would be approved, providedtheir programs regulate the same universe of federally regu-lated tanks, and they had adequate enforcement.

In July 1990, EPA approved Mississippi as the first state to runits own underground storage tank program in lieu of the fed-eral program. Today, 33 states, the District of Columbia, andthe Commonwealth of Puerto Rico have EPA approved pro-

grams. With rare exceptions, all other states are implementingtheir own tank programs under EPA cooperative agreements.

Fulfilling EPAs Responsibilities In Indian

Country



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parison to todays nearly 700,000 tanks nationapproaching its responsibility in the same manthe same purpose.

As the Agency did with states, EPA built strong

with tribes and tribal consortia, and continues these partnerships. Through these partnerships, Eand still provides technical support, financial r

compliance assistance. Over the last decade, EPA $9 million to tribes and tribal consortia to train thand to develop and manage their own undergrounprograms. And to further support tribes, EPA conimately 200 tank site inspections annually, ove

activities, and where appropriate undertakes clean

Through these partand tribes have m

able progress durinyears. Almost 5,20storage tanks in Inhave been perman

most leaks are promand almost 60 pknown releases haveup. Today, nearly gas stations and ot

sites in Indian Courequired equipment

most operate it prop

Compliance Assistance And Outrea

A Difference

By developing and implementing the technical a

EPA provides real support to tribal tank

compliance problems the Agencys assis-

tance is part of the solution, not a barrier

to success. EPA approaches new and inno-

vative tribal programs with an open mind

and willingness to turn ideas into reality.

Bobby Short

Environmental Programs,

Inter-Tribal Environmental Council


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storage tanks had to be educated about the new regulations.Tank owners spanned the spectrum from the largest oil

companies to the smallest mom-and-pop gas stations. As isstill the case, the federal government also owned tanks, asdid state, local, and tribal governments, convenience stores,

taxicab companies, bus companies, state transportationauthorities, fire departments and many others. Some werelarge, sophisticated companies and organizations withlegions of lawyers and environmental engineers on staff.Others were one-person operations with little or no knowl-edge of environmental regulations. EPA had to reach all of

these owners and provide them with the tools to understand

the regulations so they could comply.EPA began by writing the regulations in plain language beforethat concept was well known or generally accepted. Thatalone was a big step, but EPA did more. TheAgency produced dozens of documents thatexplained the regulations in language so simplethat a large and diverse audience could read and

understand the requirements. EPA also developeddocuments explaining how to do things correctlylike inventory control and leak detection. In 1990,EPA published its first outreach document inSpanish in order to reach the diverse tank ownercommunity. Some of the more popular documentsincluded:

O

Musts for USTs a comprehensive, easy-to-readsummary of the federal requirements for

underground storage tanks focusing on instal-

lation, release detection, spill, overfill, and cor-

rosion protection, corrective action, closure,

ti d dk i i t


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O Dollars and Sense a booklet providing a p

summary of owner and operator financial

ties under the federal regulations.

O Straight Talk on Tanks: Leak Detection Method

USTs and Piping a booklet summarizing variotion methods for underground storage tanks

well as the regulatory requirements for leak d

EPA needed a distribution network to reach thlarge group of owners and operators. So, EPApartners in the program states, tribes, and pr

to help publicize and distribute thousands o

of these and other documents. Today, EPA is tage of the internet by making most publication the Web at http://www.epa.gov/oust/pubs/

Along with publications, EPA also organized,and continues to host with states, two annualThese national conferences provide a good opEPA, states, tribes, and others to share exp

improve the prograferences provide exchange informatechnologies andinnovations at all lernment. And thplace for stakehacross the nation t

success stories learned, which leacompliance and mcleanup.

EPA maintains an atmosphere of open

communication and encourages stakehold-

ers to voice their opinions about their

experiences. States, industry, and EPA are

encouraged to learn from each other andto share successes and challenges.

Kathy Stiller Banning

Delaware UST Manager and Co-Chair of the Association of

S d T i i l S lid W M Offi i l T k


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In 1984, the Congressional Research Service (CRS) pub-

lished a study about the enormous regulatory task EPAand states faced. CRS noted in its study:

An estimated 1.4 million underground tanks in the United States store

gasoline. An unknown additional number of tanks store a variety of petro-

leum products .... Of the 1.4 million underground tanks storing gasoline,

approximately 85 percent are made of steel with no corrosion protection and

were buried over 20 years ago. Although few data exist, some petroleum indus-

try experts estimate that 75,000 - 100,000 of these underground gasoline

tanks may currently be leaking ... into the ground and groundwater supplies

and perhaps up to 350,000 tanks may be leaking within the next five years.

Twenty years later, the accuracy of the CRS estimates isremarkable. EPA now knows there were over 2.1 million

underground storage tanks and over 400,000 releases havesince occurred. As a result of the federal regu-lations, strong state and tribal partners, aggres-

sive outreach, and the combined efforts of ourpublic and private partners, we have made

tremendous progress in tackling the problems

described by CRS in 1984.Working together, EPA and its partners haveclosed over 1.5 million old, substandard tanks

and cleaned up over 300,000 petroleum leaks,almost 70 percent of all releases. Through our

combined efforts, we have averaged almost19,000 completed cleanups annually. This has

not been easy. Cleaning up BTEX (benzene,toluene, ethylbenzene, and xylene the basic

contaminants in gasoline) is tough enough; butin the mid-1990s states began to discover

MTBE (methyl tertiary butyl ether a gasolineadditive) in the nations groundwater.

A Measure Of Our Success

Confirmed Releases: Historical Aver

Cleanups Completed: Historical Ave

All numbers rounded to nearest thousand.


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affecting large popu300,000 residents w

Santa Monica and 2ple were affected in

Like many other cha

program faced, by wand relying on e

strengths, we are bega difference in the

areas. EPAs financiaassistance had a great impact in Santa Monica whe

MTBE settlement was reached last year between the al major oil companies. In the words of Wayne N

Administrator of EPA Region 9, The Santa Monicathat when all levels of government local, state and federal work

the common good and produce a comprehensive solution to a diff

On the prevention side, the results are

sive. Through combined efforts, neardard tanks have been closed, replaced

And because of these improvements, o

seen a dramatic drop in new releasestory of the underground storage tank and states have discovered just overeleases a year and as many as 66,000 in

we discovered approximately 12,00releases, about 60 percent less than the

age. This dramatic reduction in the numproves the tank program is making a d

Much of this reduction is due to btanks and improved compliance on t

regulated community. Twenty years agothat 85 percent of the buried tanks

bare steel without any corrosion pro

Decreasing UST National Cleanup Backlog, 1999-2003

National UST Cleanups Completed, 1992-2003

All numbers rounded to nearest thousand.

Twenty years later, the unconventional

programs developed by EPAs UST program

have proven to be effective at protecting

public health and the environment.Tom Dunne

EPA Office of Solid Waste and Emergency Response

Associate Administrator


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Statistics alone cannot fully cap-ture the collective success of theunderground storage tank pro-

gram. The performance-based tankregulations were technology-forcing,

encouraging industry to developnewer and better methods to prevent,detect, and clean up leaks. In the same

vein, EPA encourages and supportsstates, tribes, and local partners to con-tinuously look for new and better waysto prevent leaks and clean them up quickly and effectively. This

proactive attitude has paid off in keeping the tank programfresh with new ideas even after 20 years. And while programinnovations came from many sources, states have been at theforefront in developing new approaches. Pay for performance

contracting, risk-based corrective action, and state trust fundsare three of the most innovative and noteworthy solutions.

Pay For PerformanceIn the programs early years, many state officials were look-ing for a faster, streamlined approach for completing

cleanups. After attending the annual national tank confer-ence, a manager from New Mexicos tank program came upwith a new idea of paying contractors for their performancerather than for their time and materials. Following the con-ference, pay for performance contracting, more popularly

known as PFP, was born. Other states have adopted andexpanded that concept for their own use.

PFP contracting holds the contractor account-

able by tying contractor payments to meetingfirm, measurable cleanup goals. By doing so,


Commitment To Finding Innovative S

In pay for performance cle

tractors are paid a set amo

The UST regulations ensured a m

which provided incentives for tho

facturing tanks, piping and leak

systems to develop new and bette

Sullivan Curran P.E.

Executive Director,Fiberglass Tank and Pip


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Successes

South Carolina has been a trendsetter when it

use of PFP contracting. The state first used PF

in 1997 and quickly made it an integral part of it

cleaning up leaks from underground storage Carolina has not only seen a reduction in the am

required for cleanups, but has also been getting

higher quality work while paying less. South Ca

an average savings of $215,000 per site cleanup

staff project management time needed. The sta

set clear time lines for cleanup and to monito

progress is the key to success. South Carolina m

terly reports from contractors on contaminatio

ensures cleanup projects remain on track for com

states PFP program has been so effective that S

was awarded an Engineering Excellence A

Consulting Engineers of South Carolina Associ

Similar success has occurred throughout the c

states have used the example set by South CaroliPFP programs of their own. Florida, Ut

California, Vermont, Oklahoma, Nebraska, and

also taken the initiative and developed unique a

PFP contracting.

Risk-Based Corrective Action

During the 1980s, EPA, states, and

the daunting task of assessing and

hundreds of thousands of leaks

effectively. It became obvious that b

b f l k EPA d


Risk-Based Corrective Action (RBCA) is

a streamlined approach that integrates

exposure and risk assessment prac-


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the cleanup priority of each site based on relative

risks to human health and the environment. Today

nearly all states use risk-based decision making to

protect human health and the environment.

SuccessesThe benefits of applying risk-based decision mak-

ing to cleanups is perhaps best illustrated in a

March 2000 study, published by the American

Society for Testing and Materials. The study high-

lighted risk-based cleanup programs in Illinois,

Iowa, Texas, North Carolina, and Utah and evalu-

ated each programs performance from 1990 to1999. Astonishingly, the study showed that imme-

diately following implementation of risk-based decision

making, four of the five pilot states observed a dramatic

spike in annual number of cleanups completed and, in some

circumstances, a decline in their backlog of cleanups to be

completed. Utahs cleanup completion rate increased by 120

percent during the first year. The monetary benefits of risk-based decision making were also encouraging. Between 1994

and 1998, remediation costs in Texas dropped by 77 percent

for soil-only sites (median cost reduced to $24,000 per site

from $80,000 per site) and by 58 percent for low risk ground-

water impact sites (to $107,000 per site from $250,000 per

site).

State Trust FundsThe financial responsibility regulation EPA promulgated in

1988 required tank owners to show they have the financial

resources to clean up a site if a release occurred. The regula-

tion gave owners a variety of compliance options


Risk-Based Decision Making is

that UST implementing agenci

O Focus site assessment data g

O Categorize or classify sites.

O Determine what, if any, furtnecessary to remediate a si

O Help establish cleanup goal

O Decide on the level of oversto cleanups conducted by Uand operators.


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Successes

To create a way to pay for cleaning up known remeet the financial responsibility requirementsmost creative tools state trust funds was b

eral mandate required states to create these funofficials, seeing how their peers in other states hto the needs of their tank owners, especially smdeveloped their own funds.

While each state fund is somewhat different, thtank owners to comply with the financial requirements and provide money to clean up re

By all accounts, these funds have worked. Tohave funds that provide money to clean up undeage tank releases. States raise and spend more tannually. And, over the life of the program, statmore than $11 billion to help clean up more petroleum releases.



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Twenty years ago, the Hatfields of Canob Park, RhodeIsland and countless other Americans in other stateshad to live with the effects of leaking underground

storage tanks from nearby gasoline stations, conveniencestores, and other locations. No one knew where all of these

tanks were located, what they were made of, or whether theywere leaking. It was not uncommon in 1984 that the first andonly sign gasoline had leaked from an underground storagetank was a strong odor coming out of the shower or a badtaste from the tap water.

It took swift Congressional andPresidential action to enact federal

legislation to create a nationalunderground storage tank pro-

gram. Twenty years ago, EPAs firstmajor challenge was how to imple-ment this new legislation. Giventhe size of the regulated universe,the unknown number of leaks, and

the great diversity of owners, EPAhad to adopt new approaches,write the regulations, and imple-ment the national program. Based

on the franchise approach, EPAbuilt strong partnerships withstates, tribes, and private industryto tackle this problem. By many

measures, the program has suc-ceeded and served the nation well. Through these partner-ships, we have made great progress by designing better andsafer tanks, cleaning up two-thirds of all leaks, and cutting the

number of new leaks by 70 percent.


Continuing Challenges

EPA made a sincere effort to invo

holders in developing UST regulatiAnyone who was interested and th

they had something valuable to ad

allowed to voice their suggestions.

created UST regulations that have

been understood, and substantiallyplied with.

Robert Renkes

Executive Vice President and General Couns

for the Petroleum Equipment Institute


26/32

of partnerships and innovation that were establiago and tested and strengthened over time, togcontinue to find new ways to solve the challenges

tomorrow.

Improving Operational CompliancWhile tremendous strides have been made in number of new releases, thousands of newly disstill occur each year. The lack of proper operati

tenance is one of the major causes of new releastates are working together on several major effothe challenge.

One way to improve operational compliance is to inquency of tank inspections. A few states conduct tions, but most inspect tanks on average less than onyears. To increase the number of inspections, somdeveloped innovative methods such as the use of

party inspectors or contracting with local fire and ments. We need to explore these and other method

In addition to conducting more inspectioensure inspectors are well trained. Well-tors are integral to helping owners achieve and maintain operational complthis need, EPA and states are developtraining for federal and state tank insp

cleanup managers. The on-line modules

this year, will provide basic instruction ftors and cleanup managers. EPA is plaplete more advanced modules in future y

Over the years, EPA has produced dozeance assistance documents to help own



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Completing CleanupsEPA and its partners have made enormous progress by clean-

ing up over 300,000 contaminated sites. Still, 130,000 con-taminated sites need to be cleaned up. EPA and our partners

are committed to cutting this number in half by 2007 andcontinuing the legacy of finding faster, more innovative, andless costly ways to get the job done.

EPA is helping states and tribes reach their cleanup goals bycharacterizing the types of sites that still need to be cleanedup. The Agency is also taking a targeted and intensive look

at how to move difficult cleanups forward and get them

completed. This review should help identify fresh approachesfor expediting cleanups. EPA is also encouraging multi-sitecleanup approaches and wider use of pay for performancecontracts, both of which accelerate cleanups and reducecosts and administrative burdens.

As is the case for inspectors,EPA and states have a continual needto train new staff who oversee cleanups. Well-trained staff are

integral to ensuring cleanups are initiated and completed properly.EPA and states are developing introductory, web-based training,available later this year, for federal, state, and tribal site cleanupstaff. More advanced modules are being planned for the future.

While EPA and states are focusing efforts on completingcleanups, there is still a need to ensure that sites not yet cleanedup are managed properly to protect human health and the

environment over the long-term. Tracking and enforcing insti-tutional controls that lay out limitations for using sites are keyto managing contaminated sites responsibly over time. EPAand states are continuing their partnership to develop toolswhich improve long-term site management.



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have the required leak prevention and leak deteand are less likely to corrode and leak than the of the previous generation. Nevertheless, many tems are continuing to leak. While we dont knoare leaking or all of the reasons, we are beginning

some of the problems are due to faulty equipminstallation, and lack of proper operation and mthe equipment.

Anecdotal information indicates that releases frwell as spills and overfills during delivery, are and releases from dispensers have emerged as a leof contamination. States again have been in the

addressing these problems. In addition to takprogram and regulatory steps to improve tankformance, several states have undertaken studietank system performance.

EPA is also evaluating tank system performancewith state and industry partners to determinesources and causes of problems. Once complete

ation will help EPA, states, and industry guide fefforts; identify research needs; focus inspectiand improve tank system installation methods, omaintenance procedures, and underground stortem equipment.

This effort is essential to ensure we not only reticant improvements weve made over the past

continue to move the program forward towardcleaner future. This commitment to continuous has been a hallmark of the underground storagram since its inception and continues to be a within the program.

Underground Storage Tanks Building On The Past To Pro


29/32


eyesores and blight communities.The 2002 Brownfields Law is giv-ing EPA, states, cities, entrepre-neurs, and community leaders anopportunity and new tools to clean

up and return to productive reusemany of the 200,000 abandonedpetroleum sites scattered through-

out America. Using the foundationupon which the underground stor-age tank program was built partnerships, creativity, and hardwork we can meet this new challenge.

In 2000, building on the success of the Brownfields program,EPA created USTfields and began in earnest to focus on aban-doned petroleum sites. EPA provided almost $5 million to fund50 USTfields pilots. Three years later, EPA awarded almost $23

million for 102 new petroleum grants, under the 2002Brownfields Law. These grants are helping states and citiesassess, cleanup, and reuse petroleum brownfields. Some com-

munities are already seeing results. In Nashua, New Hampshire,New Englands largest bicycle dealer is now located on acleaned up petroleum-contaminated industrial site. In Trenton,New Jersey, the city reclaimed an abandoned gas station andbuilt a new firehouse.

In addition to the grants, EPA and states are continuing theirlegacy of developing and disseminating innovative tools to

address petroleum brownfields. Issuing a Ready-for-Reusedetermination is one such tool. It is being used in Sayre,Oklahoma and in other places to acknowledge that the site hasbeen cleaned up and is ready and available for a particular typeof reuse. Site inventories are helping bring property ownerstogether with end users who may want to use the property And

The entire petroleum brownfield

is a critically important task of

program and is a major part of

vision for the future.

Timothy Fields

Former Office of Solid Waste and Emergenc

Assistant Administrator

Located in a part of

minimal green spacOgden Pocket Park

a service station. T

eyesore and contain

building used for il

and 11 USTs that ra

from 600 to 10,000

Cooperation betwe

Department of Buil

ment of the Enviro

Department of Tran

to tank removal, sit

and restoration. In

2001, the West Ogd

Park opened, adding

green space to the

Underground Storage Tanks Building On The Past To Protect The Future


30/32


ers because of the need to include additional parerty owners, end users, bankers, cleanup contracas traditional regulatory partners. Even thougthese partnerships is time consuming, some aplace and making progress. Through a new par

Habitat for Humanity, the City of Oakland, CEPA, an old gas station with four buried tanks wNow in its place are four new homes for low inc

By expanding old partnerships, creating new oneuser-friendly tools, and taking advantage of the nities in the Brownfields Law, EPA, states andand private partners can clean up and reuse thou

abandoned gas stations.

Meeting New Challenges

Partnerships, innovative solutions, cooperatiostriving to improve.

Over the last 20 years, EPA used these principplace a framework and foundation for partnercessfully manage Americas tank systems. And th

made and used throughout the programs histsucceed.

As we enter the third decade oground storage tank program

lenges lie ahead and a greawork needs to be done. We

ted to continuing the pahave taken the tank progra

is today. And we are dedicing continued success in pnations environment and h


31/32

EPA sought technical expertise from all sources - tank owners and

vendors, state and local government agencies, and franchise operations.We sought to fully understand the operation of these tanks and find

ways to improve the process from within.

Louise WiseFormer OUST Division Director responsible for developing

the regulations

We worked towards compromises that would achieve tank standards while

being realistic about what it would mean for those actually doing the work.

Carrie Wehling

One of the original EPA lawyers who worked on the UST regulations

Outreach was of great importance in the underground storage tank pro-

gram from the very beginning, since our mission was to try to change the

tank management practices of 175,000 owners and operators with very

diverse backgrounds and education levels. To get people's attention, we creat-

ed, for example, a lively brochure called Musts for USTs that explained the

new tank management requirements in very simple and clear terms and even

used cartoons depicting comical scenes to make the text interesting to read.

Helga ButlerThe first OUST Branch Chief of Communications

Many of the principles that led to the success of the UST program (cus-

tomer orientation, continuous improvement, flexibility, partnerships) were

considered quite innovative, even rebellious, in the mid-1980s. Today, these

principles have become commonplace in many of EPA's programs.

John HeffelfingerOne of the original OUST staff members

The theme of the office was to make states successful. We appreciated

how OUST empowered states and offered tools and flexibility so that

states could find creative solutions to UST challenges.

Bill Torrey

EPA New England Regional UST Program Manager

Reflections


32/32

United States

Environmental

Protection Agency

Office of Solid Waste

and Emergency

Response

Office of

Underground

Storage Tanks

www.epa.gov/oust

March 2004

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Documents

Under Storage Tank