This is a two-part series on the life cycle of an Underground Storage Tank (UST). Part 1 lays out the “5 reasons to remove or replace a UST at a gas station”. Part 2 explores the criteria that determine the end-of-life of a UST and tries to answer the question: “When should a UST be removed or replaced?”
The 5 general reasons a gas station owner will have to remove and/or replace a UST:
1. UST Failure
3. Business Interests
5. Financial Responsibility
If a UST leaks, should it be removed/replaced? It depends…
- Can the leak be repaired? Does the state allow repairs to a UST?
- Is it a single-walled (SW) UST? Does the state allow SW USTs to be repaired?
- Is it a double-walled (DW) UST? Is the leaking area located on the primary or secondary wall of the UST? Does the state allow repairs to fix those leaks? Can the UST be removed or replaced?
If a UST leaks and you cannot repair it, you must remove it.
Some states have regulations requiring USTs over “X” amount of years to be removed by “Y” date. A few examples:
- Florida, all SW UST had to be replaced by 2010
- Rhode Island, SW USTs had to be removed and permanently closed prior to December 22, 2017, or 32 years from the date of installation, whichever is sooner
- South Carolina, SW USTs must be replaced by 2019 IF w/in 100’ of a water supply or surface water
- California, SW USTs must be replaced by 2026
- Hawaii, SW USTs must be replaced by July 2028
- Connecticut, USTs must be replaced 40 years after installation
Clearly, there is no consensus amongst states on the lifespan of a UST.
If the state the UST is in says the UST must be removed then Owners have to comply with the regulations in effect in their state.
There are times where the owner of the UST decides to replace or remove USTs due to internal business decisions. Examples: to increase the amount of product stored to meet customer demand, meet consumer demand for newer products, remodeling, or relocating a store to a more profitable location.
Remove/replace a UST if it increases the profitability of the location for the business owner.
This combines the previous 2 categories. EPA regulations require the UST to be compatible with the product stored. If a business decides to store a product not compatible with the existing UST then they will have to replace the UST to meet the compatibility requirement.
Some Insurers have made a blanket decision not to sell insurance for USTs over 20 years of age, and even more importantly, not to renew any policies with USTs in excess of 26 years of age. Other insurers may not expressly prohibit placing or renewing coverage on these older USTs but will price the insurance so as not to be competitive. (2011 ASTSWMO Guide to UST Insurance)
If your UST is too expensive to insure or there is no insurance company willing to cover the UST the only choice may be to remove/replace the existing UST or the site will be in violation of Subpart H of 40 CFR Part 280.
Part I Summary: When should an underground storage UST (UST) be removed or replaced?
Does the UST still function as designed?
Does the UST meet regulations?
Is the UST profitable?
Is the UST compatible with the product stored?
Is the UST insurable?
If all of the answers to all of these questions is “YES” then there is no reason to remove or replace the UST.
About the Guest Author:
This article was originally posted on LinkedIn by Robert Largent, CHMM , an Environmental Engineer @ AAFES (The Exchange).
Robert Largent is experienced in most environmental media and an active member of the gas station and UST communities. His introduction to UST systems in 2002 has led to an extensive career in UST gas station compliance. This includes 12 years of assisting the Cherokee Nation and several Intertribal organizations. He has provided compliance assistance, training, regulatory guidance, installation, removals, remediations and every aspect of building, operating, and decommissioning gas stations. He has earned multiple certifications/licenses related to gas stations including NACE CP tester, CHMM, Sanitarian, as well as Installations, Removals, and Remediation certifications. He has also presented at industry events on UST topics including operator training, installations, removals, remediation, inspections, cathodic protection, and vapor recovery. As an active contributing member of the industry, he also participated in drafting and commenting on parts of the 2005 Energy Policy Act pertaining to UST’s and the 2015 40 CFR 280 update as well as several state UST regulatory updates.