You should suspect a leak when you discover any of the following warning signals:
- You, your co-workers, or customers smell escaped product or see anything like an oily sheen on water near the facility.
- Your neighbors complain of vapors in their basements or about water that tastes or smells like petroleum.
- Someone reports unusual operating conditions at your facility, such as erratic behavior of the dispensing pump.
- You receive or generate results from leak detection monitoring and testing that indicate a leak.
If you suspect that a release may have occurred, you must immediately notify your state or local implementing agency. If your tank is in Indian Country, you must contact EPA’s regional UST program office. Quick action on your part can minimize the extent of environmental damage and the threat to human health and safety, and it can minimize your share of the high costs that can result from cleaning up extensive releases and responding to third-party liability claims.
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UST Leak Detection
The leak detection requirements for storage tanks containing petroleum products or hazardous chemicals are quite extensive and technical. UST systems must provide a method or combination of methods that can detect a release from any portion of the tank and any underground piping that routinely contains product. The leak detection system must be installed, calibrated, operated, and maintained in accordance with the manufacturer’s instructions.
The storage tanks must be designed and operated with spill and overfill protection systems to prevent leaks and to protect the groundwater from contamination.
Leak Detection Requirements for ASTs
There is no uniform federal program that regulates aboveground storage tanks (ASTs). A complex overlapping network of miscellaneous federal statutes and regulations directly or indirectly governs tanks as well as local requirements imposed by state and local authorities. For the most part, the applicable rules are determined by tank content, size, and location.
Owners and operators of certain ASTs used for the storage of petroleum products are required to prepare a spill prevention, control, and countermeasures (SPCC) plan, which includes provisions for secondary containment. If the owner of a facility determines that the installation of secondary containment is not practicable, a clear explanation must be provided in the SPCC plan of why secondary containment is not practicable.
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SPCC regulations do not actually use the term AST, but rather use the term “bulk storage container, which is defined as any container used to store oil. For bulk storage containers, periodic integrity testing of the containers and periodic integrity and leak testing of the valves and piping must be conducted. Also, unless the facility owner has submitted a facility response plan under 40 CFR 112.20, additional information must be addressed in the SPCC plan if secondary containment is not provided, including:
- An oil spill contingency plan following the provisions of 40 CFR 109
- A written commitment of manpower, equipment, and materials that are required to quickly control and remove any quantity of oil discharged that may be harmful
For ASTs that store hazardous waste, the key difference between a container and a tank is that a container is a portable device whereas a tank remains stationary.
See tomorrow’s Advisor for the leak detection requirements for hazardous waste tanks and containers.