Storage Tank Management Services
Regulatory compliance with changing federal and state regulations concerning registered aboveground storage tanks (ASTs) and underground storage tanks (USTs) can be challenging. Regulated tanks store regulated substances such as oil, motor fuels, chemicals, and hazardous waste. AGC/Montrose employees have direct experience managing the multiple details required by tank owners for economic and strategic operations.
Storage Tank Mangement Services:
• SPCC Plan (Spill Prevention Control and Countermeasures Plan)
• FRP Plan (Facility Response Plan)
• SWPPP Plan (Stormwater Pollution Prevention Plan)
• PPC Plan (Preparedness Prevention Contingency)
• DCCP Plan (Discharge Prevention Containment and Countermeasure Plan)
• DCR Plan (Discharge Cleanup and Removal)
• EPCRA Reports (Emergency Planning and Community Right to Know Act)
• Tier II Reports (Emergency and Hazardous Chemical Inventory)
• Tank Insurance claims
• State Financial Assurance Fund claims
• Monthly Tank Inspections
• Underground Storage Tank Operator Training
• Underground Storage Tank Removal
• Aboveground Storage Tank Operations and Spill Prevention Training
• Suspected Release Investigations
• Site Investigations
• Remedial Pilot Tests
• Remedial Action Plans
• In-Situ Groundwater Remediation
• Soil Remediation
• Monitored Natural Attenuation
• Groundwater Sampling
• Vapor Intrusion Testing
• Vapor Intrusion Mitigation Design
• Remedial Action Completion Reports
• Site Design and Permitting
• Geotechnical Investigation for Tank Siting
• Secondary Containment Design
• Stormwater Management Design
For more information, contact:
Stephen W. Kirschner, P.E.
Aboveground Storage Tanks (ASTs)
Aboveground storage tanks (ASTs) can range from shop fabricated horizontal and vertical tanks to large API-650 field constructed tanks. These tanks require a monthly inspection and periodic formal inspections. Tanks with a volume greater than a certain capacity, may require a spill response plan in accordance to specific state standards or USEPA. A Spill Prevention Control and Countermeasures (SPCC) plan helps facilities prevent a discharge of oil into stormwater systems that empty into navigable waters or adjoining shorelines. The regulations, under specific conditions, require a Professional Engineer to certify the plan. The plan requires training for those working with the tanks and may require storage of spill response materials to help prevent or mitigate an oil spill. As with all such plans, the details requiring actions should be reviewed from an operational viewpoint. Experienced engineers, with a unique understanding of the regulations, can ascertain if items in the plan are effective and are commensurate with the evaluated risk. The formal inspections, usually performed by a certified inspector, can be either an in service inspection or an out of service inspections, where the tank is emptied, cleaned, and inspected from the inside. The inspection requirements can be daunting to a tank owner, and an experienced engineer can provide insights to minimize operational efficiencies or operational disruptions.
Many ASTs have diked areas providing containment in case there is a spill. The containment dike should be evaluated for the correct containment capacity. If a dike is constructed with soil, it may need reviewed to evaluate if the correct permeability has been maintained.
Storage tank management must also include corrosion protection and the containment structure may be coated to provide a leak proof barrier. The tanks themselves are painted and the coating needs maintained. There may be older layers of paint on a tank where the paint contained lead. So any maintenance program needs to incorporate a waste management plan for potential lead hazardous waste. Some tanks may have passive or active cathodic protection systems that require periodic monitoring and testing. All the component testing and regulation compliance can be integrated with risk management and experienced engineers with operational experience can provide insight where coordinated actions can provide a more economical cost or provide a better value in total operational expense.
Underground Storage Tanks (USTs)
Underground storage tanks (USTs) are regulated by both state agencies and USEPA. There are regulations that require a trained operator to oversee the UST operations. The operators are responsible for overseeing a monthly walkthrough inspection, in addition to monthly records of proper operation of leak detection equipment. Abnormal operating conditions must be documented and issues with leak detection systems require responses that can include a suspected release investigation. A suspected release investigation is the required mechanism to determine if the regulated substance was released into the environment. UST spill prevention and leak detection components must be functionally tested by certified testing contractors. A failed component test can restrict the UST normal operation until the component is repaired or replaced. A failed component test can also trigger a suspected release investigation.
The suspected release investigation can involve soil and groundwater sampling, and may involve access to adjoining properties from the UST location. Many states require Professional Geologists, Professional Engineers, and sometimes state regulated professionals like a Licensed Site Remediation Professional (LSRP) to oversee a release investigation.
UST owners and operators are required to have financial mechanisms to fund the cost of a clean-up for a release to the environment, which is typically to the soil and groundwater. These mechanisms can include state enrollment funds, private insurance, and for municipal entities, self-funding. For most mechanisms there is a deductible amount that can range typically from $5,000 to $50,000, and coverage is usually around $1.5 million per release. Personnel experienced in insurance claims and state clean-up funds can provide direction to maximize the insurance or fund coverage and prevent rejected claim expenses.
There have been several projects where the future costs and expenses, the professionals have recommended the closure and removal of the UST and its replacement with an AST. Generally a tank owner who relies only on testers, contractors, and equipment suppliers to help solve storage tank problems, will not be presented with other options or insights that are economical and that can reduce risk. Those professional personnel, experienced in both AST and UST regulations and operations, can provide high value oversight and knowledge for the tank owner to make the best decisions.