By: Kip Prahl
Kip Prahl Associates
First, some background: California Underground Storage Tank Regulations came on line way back in 1984. Most will recall that, in general, these regulations obligated those with underground tanks to periodically check unit integrity. Also, anyone wanting to install a new tank after 1984 has had to put in a double wall unit.
Over the years, these regulations have been amended a number of times. Most of these amendments meant immediate change in tank installation or operating procedures. There are, however, several sleepers in the regulations. These sleepers have been in place for several years but have a compliance deadline of December 22, 1998 – two years from now. The bad news is that they deal with a series of costly tank system upgrades that tank owners/operators must complete prior to this deadline.
The objective of this article is to summarize these mandated upgrades and to briefly discuss how a dealership might address them. As a caution, however, the dealer should understand that California underground tank regulations are complicated and are not easy to explain. For example, rules vary based upon the age of a tank, the material used to construct it, even the tank contents. Consequently, this article is general in nature and should not be considered definitive guidance.
Note: This discussion does not pertain to underground hydraulic hoists. These units are exempt from California Underground Storage Tank Regulations.
Now for the details: There is one set of requirements for motor vehicle fuel tanks and another for all other underground tanks used to store hazardous materials (waste oil, waste antifreeze, lubricating oils, etc.). In all instances, however, upgrades must be completed by December 22, 1998.
A. Motor Vehicle Fuel Tank Systems:
1. Underground Tanks: A tank constructed of a corrosion resistant material (ex: fiberglass) or a steel tank that is clad with a corrosion resistant material need only be equipped with a wear plate (striker plate) under any tank opening that could be used for manual dip sticking.
As for an unprotected steel tank, in addition to requiring a wear plate (or plates) the tank must be retrofitted with an interior lining and an approved cathodic protection system.
Note: A cathodic system protects a steel tank by slowing the rate at which it corrodes.
2. Spill Containment and Overfill Prevention: Each tank must be equipped with a container capable of collecting any product spilled during delivery operations (spill containment). Minimum capacity of any such container is five gallons. Each tank must also have a device that will sound an alarm and/or shut off flow to the tank as it nears capacity (overfill protection).
3. Piping: With several exceptions (especially for installations common to auto dealerships), piping will either have to be secondarily contained or constructed of corrosion resistant materials (ex: fiberglass, cathodically protected steel). Automatic leakline detectors will also be required and, for single wall piping, any leak detection system will have to be capable of shutting down pumping operations if a leak is detected or the detection system itself fails.
B. Tanks Used to Store Hazardous Materials Other Than Motor Vehicle Fuel:
1. Underground Tank: Each such tank must be “retrofitted” with secondary containment. While this can be accomplished through installation of a membrane liner, the most common way of achieving secondary containment has been to remove the tank and put in a new double wall unit.
2. Spill Containment and Overfill Prevention: These tanks must also be equipped with spill containment and overfill prevention devices. The administering city or county, however may waive the requirement for overfill prevention equipment if transfers into the tank are no more than 25 gallons at a time. Most waste oil tanks should qualify for this potential exclusion.
3. Piping: Requirements are based on the type of installation. In some instances, piping will have to be double walled with continuous electronic monitoring. In other circumstances, it will not isn’t this terrific guidance?!
There’s more. Before upgrading an underground tank system, the owner or operator will have to satisfy the local (city or county) tank administering agency that the tank in question is structurally sound and that the upgrades will prevent a release of hazardous material for the operational life of the tank. There are over a hundred of these “local administering agencies” and many seem to take special pride in doing their own thing. Also, depending upon the work planned, consultant studies may be required along with additional approvals by the administering agency.
What to do? If your dealership has as installed one or more double walled tanks, there is a reasonable probability that no changes will be required. In some instances, however, upgrades may be necessary. To find out, you might contact your underground storage tank installation contractor and ask him for an assessment of how the tank system matches up with these upcoming requirements. If the contractor can’t be located, call another one. In any event, the contractor may have to inspect the tank and there may be a fee; but these guys do this for a living and should be able to quickly give you a good read. Another option is to contact your local administering agency. It may have in its files some valuable information about your system. An agency representative may even be able to provide a tank specific summary of required upgrades.
If your dealership operates a corrosion resistant single wall motor vehicle fuel tank, the same advice applies. In many instances, though, the tank was installed so long ago that there is little or no information on the materials used to construct it or on how it was installed. Unfortunately, getting conclusive information on such matters may prove costly and the best bet may be removal. The local administering agency, incidentally, may be the most readily available source of information.
Finally, if the dealership owns or operates a single wall, unprotected steel motor vehicle fuel tank or single wall tanks for storage of any other hazardous substance, it may want to look hard at decommissioning the tank(s) before December 22, 1998. While such tanks may be upgraded as summarized above, any such fix could be rather costly.
Amidst all this talk about underground storage tanks, a few words about aboveground storage are important. Over the past 15 years or so, hundreds of California dealers have gotten rid of their underground storage tanks and replaced them with aboveground units or just gotten along without them; on-site storage of a gasoline is a good example. As for those who concluded they still need gasoline on site, many have found that aboveground concrete vaulted tanks pass fire department muster for this use.
To summarize, if your dealership owns or operates an underground storage tank, particularly an older, single wall unit, life is going to get more complicated in about two years. The prudent dealer will take the time available to collect information on the nature of his underground storage tank system(s), to carefully consider the options (including aboveground storage), and to make decisions that best suit the dealership.
(Kip Prahl is president of Kip Prahl Associates, an environmental and safety consulting firm with offices in Fremont, CA, Cypress, CA and Denver CO. He can be reached at 800-486-0400.)
This article was written in 1997.