Bringing Your Underground Storage Tanks
Up To Date

By DENNIS G. WALSH
of
Klein, Thorpe and Jenkins, Ltd.

The old adage that "if it ain't broke don't fix it" is inapplicable to the underground storage tanks owned and/or operated by municipalities in the State of Illinois. Even if your tank(s) "ain't broke" (i.e., leaking), both state and federal laws and regulations require that all existing underground storage tanks either be upgraded or closed, depending on the age of the tank, by no later than December 22, 1998.

For example, under the current laws and regulations, corrosion protection and spill/overfill prevention measures must be accomplished by December 22, 1998. By that date, all existing steel underground storage tank systems must either be upgraded to comply with the new tank standards or, at a minimum, be upgraded by installing either an internal liner or by cathodic protection, or both. Metal piping that routinely contains regulated substances and is in contact with the ground must also be cathodically protected. To prevent spilling and overflowing associated with product transfer to the underground storage tank system, all existing tanks must comply with the new underground storage tank system spill and overfill protection equipment and requirements by that date.

Release detection systems, however, must be retrofitted to existing tanks by no later than December 22, 1993, and to associated pressurized piping by December 22, 1990. Owners and operators of new and existing underground storage tanks must provide a method, or a combination of methods, of release detection that:

1. Can detect a release from any portion of the tank and the connected underground piping that routinely contains product;

2. Is installed, calibrated, operated, and maintained in accordance with the manufacturer's instructions, including routine maintenance and service checks for operability or running conditions; and

3. Meets the performance requirements in 40 C.F.R. §280.43 or §280.44 and 35 Ill. Adm. Code §731.143 or §731.144, with any performance claims and their manner of determination described in writing by the equipment manufacturer or installer.

In addition, methods used after December 22, 1990, except for methods permanently installed prior to that date, must be capable of detecting the leak rate or quantity specified for that method in §280.43(b), (c) and (d) or §280.44(a) and (b) (§731.143(b), (c) and (d) or §731.144(a) and (b)) with a probability of detection of 0.95 and a probability of false alarm of 0.05. When a release detection method operated in accordance with the performance standards outlined above indicates a release may have occurred, owners and operators must notify the appropriate agencies to report the suspected releases.

The schedule for upgrading existing underground storage tank systems with the release detection requirements is phased in over the following five year period:

1. All pressurized piping — compliance by 12/22/90.

2. Tanks and suction piping:

a. With an unknown installation date, by 12/22/89.
b. Installed before 1965, by 12/22/89.
c. Installed in 1965 through 1969, by 12/22/90.
d. Installed in 1970 through 1974, by 12/22/91.
e. Installed in 1975 through 1979, by 12/22/92.
f. Installed in 1980 through 12/22/88, by 12/22/93.
g. Installed after 12/22/88, immediately upon installation.

Any existing underground storage tank systems that cannot apply a method of release detection that complies with these regulations must complete the closure procedures outlined in next month's article by the date on which release detection is required for that particular underground storage tank system. •

April 1992 / Illinois Municipal Review / Page 9