Tank Tour
~
Your Guide to the Federal
Underground Storage Tank Program
U.S. Environmental Protection Agency
Office of Underground Storage Tanks
March 1989
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ACKNOWLEDGEMENTS
This document was prepared under the direction of Sandra Strauss and Steve Vineski of EPA's Office of Underground
Storage Tanks (OUST) under contract No. 68-01-7385 with ICF Incorporated.
The ICF Project Director was Tom Ingersoll and the Project Manager was Tony Bansal. The principal author was
Ken Rock. Portions of the report were written by Bill Finan, Ed Meyer, and Susan Hughes. Graphics were prepared
by Vernon Dunning and Walter Taylor, and Trish Conroy assisted in the cover design. Camera-ready copy was
prepared by Marina Miguele.
Additional technical review and comments were provided by Ron Brand, Helga Butler, Sammy Ng, Pam McClellan,
and JetTy Parker of OUST.
Many of the publications referred to in this document can be ordered by calling
the U.S. EPA Region-10 Public Information Center
' at 206/553-4973
or 800/424-4EPA within Region 10
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Page 1
CHAPTER 1
INTRODUCTION
If you are working in an underground storage
tank program and would like to broaden your
perspective, this manual is for you. It is an
introduction to the world of underground storage
tanks, known as USTs, and the Federal program
that guides them. The manual explains why
tanks leak and why they are a potential threat to
human health and the environment. It addresses
the following questions:
~ Who owns and operates USTs?
~ What is stored in the tanks and where are
they commonly found?
~ Why regulate USTs?
~ Whq is being affected by UST
regulations?
~ What do the regulations require and how
are they being implemented?
The manual also examines the development of
the Federal UST program and explains the roles
State and local governments and the U.S.
Environmental Protection Agency (EPA) play in
solving the problems posed by leaking
underground storage tanks. We suggest that you
read one or two chapters at a time, then discuss
the information with people who work on related
issues. This will bring some "real life"
perspective and experience to the information
presented in this manual.
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Page 2
CHAPTER 2
OVERVIEW OF LEAKING UNDERGROUND STORAGE TANKS
WHAT IS THE PROBLEM?
During the 1970s, Federal and State
environmental regulations focused on the
problems of air and surface water pollution. In
the 1980s, however, there has been a growing
recognition that the nation's ground water is also
being contaminated and needs to be protected as
well. This is particularly important because
more than 116 million people-half the
population of the United States-rely on ground
water as a source of drinking water.
Since the early 1900s, petroleum and chemicals
have been stored in bare steel underground tank
systems that are very vulnerable to corrosion.
Until recently, little has been done to protect
these tanks from corrosion, or to emphasize the
use of methods to detect leaks as early as
possible.
Leaking underground storage tanks (USTs) pose
a major threat to ground water. Releases from
USTs into water supplies used for drinking and
other household purposes may pose risks to
public health. Even small quantities of released
petroleum are sufficient to contaminate drinking
water. Two components of gasoline, benzene
and ethyl dibromide, are suspected cancer
causing agents.
The threat from leaking tanks is not limited to
ground water. Leaking petroleum and chemicals
can contaminate surface waters, cause fires and
explosions, and generate toxic fumes that can
seep into homes and businesses. This problem
is described in greater detail in the
brochure "Here Lies the Problem".
HOW SERIOUS IS THE PROBLEM?
EPA estimates that there are approximately two
million USTs in the U.S. subject to the new
Federal regulations. According to recent (1988)
EPA estimates, 84 percent of USTs at gasoline
service stations are made of bare (unprotected)
steel and are highly susceptible to corrosion and
leaks. Of the remaining "protected" tanks, 5
percent are steel tanks that are cathodically
protected from corrosion, and the remaining 11
percent are constructed of fiberglass reinforced
plastic (see Exhibit 2).
According to recent EPA estimates, as many as
Fifteen to twenty percent of petroleum USTs may
be leaking. If this percentage holds true for all
regulated mderground storage tanks, hundreds
of thousands of underground storage tank
systems nationwide may be leaking. One study,
based on information compiled by States,
identifies more than twelve-thousand documented
reports of releases from underground storage
tanks.
WHY DO RELEASES OCCUR?
Piping failure, spills and overfills, and tank
corrosion are the three main causes of releases
from underground storage tank systems.
Piping Failure
EPA studies estimate that eighty percent of all
releases from underground storage tanks are the
result of failures in the piping system that
connects the tanks to the gasoline dispensers or
in the fittings on the top of the tank. Many of
these failures occur because of improper
installation. As Exhibit 3 illustrates, service
stations with several dispensers and several
blends of gasoline have extensive piping systems.
There are two types of piping systems; pressure
and suction. Pressure systems rely on a pressure
pump in the tank to push petroleum through the
piping, whereas suction systems use a suction
pump at the dispenser to pull the petroleum
through the piping.
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Exhibit 2
Distribution of Tank Types
at Gasoline Service Stations
Cathodically Protected
Bare Steel,
(84%)
NOT
PROTECTED
AGAINST
LEAKS
PROTECTED
AGAINST
LEAKS
Fiberglass-Reinforced
Plastic (11%)
Source: Regulatory Impact Analysis. August 24,1988.
f91020-2
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Exhibit 3
Piping Configuration at a Typical Four-Tank Station
Tank Truck
Delivery Hose
Submerged Pump
Assembly
Vent Pipes
Line Leak
Detector
Submerged Pump
Assembly
Product Dispensers
Product Delivery Line
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Pressure systems pose the greater threat of
uncontrolled releases. When a leak occurs in a
pressure system, the pump continues to push
petroleum through the hole in the pipe and into
the ground (see Exhibit 4). With a suction
system, however, the vacuum necessary for
suction is destroyed once a leak occurs, the
system starts pulling air through the hole, and
petroleum in the piping flows back into the tank.
Spills and Overfills
Spills and overfills are the most common cause
of underground storage tank releases into the
environment; however, most incidents probably
go unreported because of the small volume of
petroleum lost, less than twenty gallons in most
instances.
Spills often occur when a delivery hose is
disconnected from the tank fill tube, when a
delivery hose has not been drained properly, or
when the disconnect stop valve on the 'delivery
truck's fill tube has not been completely closed.
Overfills occur when more petroleum is pumped
into the tank than the tank can hold and the
petroleum overflows into the surrounding soil
through the vent pipe or loose fittings on the top
of the tank. Overfills can result from an
incorrect estimate of how much petroleum is
needed to fill a tank or from simple carelessness.
Tank Corrosion
The rapid population expansion that began
during the 1950s led to the growth of suburban
communities across the United States. This
growth, in turn, led to the proliferation of retail
gasoline stations to serve the growing number of
suburban automobiles. Hundreds of thousands
of USTs were installed from the 1950s to the
present, but until recently, little was done to
protect the tanks from corrosion, a natural decay
process that occurs in steel tanks unless
protective measures are taken. Little attention
was paid to the potential damage that could
result from leaks. As a result, many tanks
currently in the ground are corroded and
leaking.
WHAT HAPPENS WHEN A RELEASE
OCCURS?
Once a leak occurs, petroleum can — under
certain circumstances — seep through the
surrounding soil into ground water (see Exhibit
5). Because petroleum does not easily mix with
water, most of the leaking petroleum forms a
plume that floats on top of the water, table.
Some of the petroleum, however, dissolves in the
ground water and may be discharged into wells
or surface water.
WHO OWNS AND OPERATES
UNDERGROUND STORAGE TANKS?
Underground storage tanks are owned and
operated by businesses to store retail motor
fuels, non-retail motor fuels, used oil, and
chemicals (see Exhibit 6). The retail motor fuel
sector accounts for the largest group, comprising
thirty-nine percent of the regulated USTs. From
600,000 to 700,000 underground storage tanks are
located at more than 200,000 retail gasoline
stations across the nation. About one-quarter of
these tanks are owned by major oil companies;
the rest are part of smaller operations. It is
unusual for facilities in the latter group to be
owned and operated by a single company or
individual. For example, one company or person
may lease a tract of land from another on a
long-term basis for use as a retail gasoline
facility. A third party, a wholesaler, may own
the tanks at the facility, and a fourth party may
lease the concession and manage the day-to-day
operations.
The second largest user of underground storage
tanks, thirty-eight percent, is the non-retail motor
fuel sector, which includes petroleum
wholesalers, agriculture, manufacturing,
government, and transportation. Non-retail users
of USTs include automobile and truck rental
companies; truck and taxi fleets; the Federal
Government (military bases, U.S. Postal Service
facilities, and a variety of Federal buildings);
State, county, and local governments (police, fire,
highway, and transportation departments); public
and municipal authorities (airports and
shipyards); and hospitals.
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Exhibit 4
Typical UST Configuration with
Pressure Piping Delivery System
Gas Pump
Gas Pump
mL.
•D
era
m
o\
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Exhibit 5
Schematic of Subsurface Environment
Water Table
Aquifer
Impermeable Boundary
Source: ICF Incorporated.
f91020-6
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Exhibit 6
Uses of Regulated USTs
Used Oil
(20%)
Chemical Storage
Non-Retail
Motor Fuels (38%)
Retail Motor Fuels
(39%)
Source: Regulatory Impact Analysis of Technical Standards Rule for USTs.
f91020-1
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Page 9
Businesses in the non-retail sector own an
average of two underground storage tanks per
facility, in comparison with retail motor fuel
companies, which own an average of three or
four tanks per facility. Twenty percent of
regulated USTs are used to store used oil, and
three percent contain chemicals.
Exhibit 7 illustrates ownership of USTs used to
store petroleum.
More than three-fourths of the petroleum USTs
are owned by gas stations and industry,
paralleling the retail and non-retail uses shown
in Exhibit 6. Government and farmers each own
about half of the remaining petroleum USTs.
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Exhibit 7
Ownership of USTs Used to Store Petroleum
Government
(11%)
Industry
(39%)
Farmers
(11%)
Gas Stations
(39%)
Source: US. Conference of Mayors Report on Underground Storage Tanks (Draft),
August, 1988.
(91020-3
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Page 11
CHAPTER 3
THE HISTORY OF UNDERGROUND STORAGE TANK REGULATION
THE HOLE IN FEDERAL ENVIRONMENTAL
REGULATIONS
Except in a few instances, Federal regulation
prior to 1984 did not address USTs. The
Resource Conservation and Recovery Act of
1976 (RCRA) only regulated tanks containing
hazardous wastes, not tanks storing petroleum or
hazardous products. The Clean Water Act of
1972 required owners of very large underground
tanks (those with a capacity greater than 42,000
gallons) to take certain measures to prevent
corrosion and to test tanks periodically.
However, these requirements applied only to
those tanks that were potentially direct sources
of pollution into navigable waters. Because
underground tanks generally damage only ground
water and usuklly affect surface water only
indirectly, the Clean Water Act could not be
used as a general basis for regulating most
underground storage tanks.
The Comprehensive Environmental Response,
Compensation, and Liability Act of 1980
(CERCLA), commonly known as Superfund,
authorizes EPA to respond whenever a
hazardous substance is released into the
environment. However, Superfund cannot be
used to respond to leaks from petroleum tanks
because petroleum is specifically excluded from
the list of hazardous substances defined under
the AcL
CLOSING THE GAP: FEDERAL REGULATION
OF USTs
In 1984, Congress was preparing to pass
environmental legislation pertaining to
management of hazardous substances. The UST
problem, which was already a subject of political
debate, became more visible because television
news shows, such as "60 Minutes" and "Good
Morning America", featured stories that
highlighted the dangers of leaking USTs.
In February 1984, Senator David Durenberger of
Minnesota'(a State in which ground water is an
important resource) and Congressman Don
Ritter of Pennsylvania (in whose district an UST
leak had contaminated wells for over three
years) each introduced a bill to address the
problem of leaking USTs. Both bills sought to
establish a comprehensive Federal regulatory
program requiring registration of all tanks,
technical standards for new tanks, reporting and
cleanup of releases, and some mechanism for
owners and operators to demonstrate financial
responsibility for damages in the event of a leak.
In Octoher 1984, a final version of the
Hazardous and Solid Waste Amendments to
RCRA (HSWA) was passed by both houses of
Congress. In November 1984, President Reagan
signed the amendments into law. Title VI of the
Amendments added Subtitle I (sections 9001 to
9010) which specifically provided for regulation
of underground storage tanks.
At the request of Congress, EPA is also studying
the threat posed by underground tanks used to
store products other than those covered by .
current UST regulations, such as heating-oil tank
systems, to determine if additional regulations
are needed. This study is now underway and a
report is expected to be completed in 1989.
Key Provisions of HSWA Subtitle I •
Subtitle I includes requirements for tank
notification, interim prohibition, new tank
standards, monitoring and reporting standards
for existing tanks, corrective action, financial
responsibility, compliance monitoring and
enforcement, and approval of State programs.
(Refer to HSWA Subtitle I for specific
requirements in each of these areas outlined in
the legislation.) The law also requires EPA to
develop a comprehensive program for the
regulation of USTs "as may be necessary to
protect human health and the environment"
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(section 9003(a)). More specifically, the law
requires EPA to develop regulations for USTs in
the areas of:
~ Technical standards for tanks (e.g.,
construction materials, required methods
of detecting leaks);
~ Financial responsibility, and
~ State program approval (i.e., requirements
for approving States to run the program).
Developing effective regulations to implement
this legislative mandate was a top priority for
EPA's Office of Underground Storage Tanks
(OUST). On April 17, 1987, the Agency
promulgated proposed regulations, along with an
invitation'for public comments.
Over the next ninety days, EPA received
comments and new information on the proposed
regulations. A Supplemental Notice to Proposed
Rulemaking was published in the Federal
Register on December 23, 1987 and OUST
received comments on the changes. After
considering all completed research and carefully
reviewing all comments, EPA published the final
UST technical regulations on September 23,
1988. The technical standards regulations are
summarized in a brochure called "Musts for
USTs" Shortly afterward, on
October 26, 1988, EPA published its financial
responsibility regulations, indicating minimum
levels of insurance UST owners and operators
need to ensure they can take "corrective action"
in response to any leaks that occur from their
tanks and compensate anyone who is harmed by
a leak. Corrective action includes assessing the
leak and the extent of damage or danger to
human health and the environment, determining
what action is needed to repair any damage and
remove contaminants, and taking the necessary
action.
CORRECTIVE ACTION FOR LEAKS: THE
LEAKING UST TRUST FUND
Although the 1984 Hazardous and Solid Waste
Amendments amended the Resource
Conservation and Recovery Act to regulate
USTs, there were no provisions for taking
corrective action on releases from leaking
underground storage tanks in cases where tank
owners or operators (1) were either not willing
or not able to conduct the corrective action, or
(2) could not be found (e.g., abandoned tanks).
Many owners and operators simply may not be
able to conduct corrective actions, and may not
have environmental impairment liability insurance
for USTs. If a leaking tank was abandoned or if
a tank leaked and the owner or operator could
not or would not take the necessary steps to
correct the situation, the only recourse left was
for the injured party to sue the responsible
party. These cases often resulted in lengthy
court delays which achieved no reduction in the
threat to human health and ground water.
In 1986, Congress responded to public concerns
a"bout the need to take action on releases from
leaking USTs by passing into law the Superfund
Amendments and Reauthorization Act (SARA).
Section 205 of SARA amended Subtitle I of the
Resource Conservation and Recovery Act
(RCRA) to provide Federal funds for corrective
actions on petroleum leaks and spills from USTs.
This amendment to RCRA established a $500
million "Leaking Underground Storage Tank
Trust Fund," paid for over five years by a tax
on each gallon of gasoline sold. According to
these amendments, priority for corrective actions
is to be given to those USTs that present the
greatest threat to human health and the
environment.
KEY UST REQUIREMENTS UNDER THE
SARA AMENDMENTS TO RCRA
Congress authorized EPA to use the Trust Fund
for corrective actions on petroleum leaks and
spills and to make these funds available to the
States (which include U.S. territories) as soon as
possible. States are expected to play a key role
in Trust Fund corrective actions because State
officials are generally closer to the scene and
know more about tanks in their States and about
local site conditions than Federal officials.
Consequently, using the Trust Fund quickly and
effectively is one of OUST's top priorities. This
was to be accomplished through cooperative
agreements with the States. Cooperative
agreements are signed contracts between States
and EPA that allow them to use the LUST
Trust Fund to pay for corrective actions on
releases from underground storage tank systems.
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EPA is encouraging States to enter into
cooperative agreements that specify how the
States will use the funds. Until cooperative
agreements are in place, States cannot use the
Trust Fund to cleanup leaking USTs.
Financial Responsibility
The Trust Fund for leaking USTs was never
intended to fund cleanups for all, or even most,
releases. In most cases, the State will order the
tank owner or operator (the responsible party)
to undertake the cleanup. Under the SARA
Amendments to RCRA, the State can compel
the tank owners and operators to undertake, or
pay for, any of the following actions:
~ Tank tests for suspected leaks;
~ Site excavation to investigate the extent of
contamination;
~ Assessments of how many individuals may
have been exposed to petroleum
contaminants and the severity of the
exposure;
~ Removal of contaminants from soil and
water;
~ Provision of safe drinking water to
residents whose supplies have been
contaminated by a tank leak; and
~ If necessary, temporary or permanent
relocation of residents affected by a
release.
Because of concerns that tank owners and
operators would not have the financial resources
to cover the cost of these activities, Congress
required that tank owners and operators be able
to demonstrate financial responsibility. This
means that tank owners and operators must be
able to pay for cleanups and, if necessary, to
compensate people or businesses for damages
resulting from leaks. Cleanup costs and
compensation can be very expensive; therefore,
Congress set the minimum coverage for financial
responsibility at $1 million per occurrence for
tanks at facilities that produce, refine, or market
petroleum ("per occurrence" means the amount
of money that must be available to pay the costs
of one leak). If necessary, EPA may temporarily
suspend the enforcement of financial
responsibility requirements if insurance or other
types of financial assurance are not available to
certain groups of tank owners. The brochure
on the financial responsibility requirements,
"Dollars and Sense," is available from EPA.
Priority Trust Fund Uses
Congress intended that EPA or the State
management agency use the Trust Fund only at
sites where;
~ The costs of the cleanup exceed the
minimum insurance coverage that an
owner or operator is required to maintain,
and such expenditures are necessary to
ensure an effective corrective action;
~ A solvent owner or operator cannot be
found; or.
~ The owner or operator fails to comply
with a cleanup order.
Tank owners and operators will be liable to
EPA or the State for the costs incurred in
cleaning up leaks or spills from their tanks.
EPA or the State can take action against the
owner or operator to recover these costs, a
process referred to as "cost recovery."
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CHAPTER 4
PARTIES AFFECTED BY UST REGULATIONS AND CLEANUPS
The UST legislation and regulatory program to
cleanup currently leaking USTs and prevent new
leaks directly affects several groups, including
small businesses, major oil companies, and the
insurance industry.
SMALL BUSINESSES
Every effort has been made in the regulations to
provide tank owners and operators with choices
about how to satisfy the requirements.
Nonetheless, the cost of ensuring that their tank
systems do not leak will be a burden to some
owners and operators.
Small businesses are deeply concerned about the
costs of complying with the UST regulations as
well as their ability to understand what exactly
they are required to do. To assist owner? and
operators of USTs, EPA is preparing a variety
of brochures and other materials that address
some of the concerns expressed by small
businesses. "Leak Lookout," and
"Oh No!," are examples of brochures,
designed primarily for small businesses which
describe specific actions that need to be taken by
UST owners and operators with regard to leak
detection and in responding to a leak or spilL
Many small businesses feel they may have
difficulty raising the capital needed to comply
with new regulations. For example, some leak
detection systems are expensive, required tank
testing could close a business for one or two
days, and new tank standards could require
upgrading or replacing tanks—all at a significant
cost Yet the financial impact and potential
liability associated with a corrective action could
be far more burdensome than complying with
the regulations for USTs.
MAJOR OIL COMPANIES
Major oil companies have already begun to
voluntarily upgrade their underground tank
systems. Motivated by the need to avoid
product loss and cleanup costs and by the fear
of liability suits, many oil companies have begun
programs to replace old bare steel tanks with
new corrosion-protected tanks and to install
monitoring devices to determine if a tank is
leaking.
INSURANCE INDUSTRY
Insurers have been reluctant to provide policies
for USTs for several reasons. One reason is the
unpredictability of the risks associated with
unprotected steel tanks that have not been
subject to regular leak detection. Another
reason is court decisions about liability that
make it difficult to relate the risk associated with
a policyholder's operation to the potential
damages a policyholder will face in court. In
addition, it is unclear to insurers how the new
UST technical requirements, especially for
corrective action, may change the number and
cost of claims. This uncertainty also affects the
amount of reinsurance that is available for
insurance policies written for USTs and
therefore limits the number of policies that
insurers are able to issue. As a result, pollution
liability insurance continues to be offered only by
a limited number of specialized providers.
As old, unprotected tanks are removed or are
fitted with leak detection systems, many leaks
will be detected and corrected. These actions,
coupled with increased monitoring, should
significantly reduce both the occurrence of leaks
and their duration prior to detection. Over the
long term, implementation of the UST technical
standards should make UST risks more
predictable and, therefore, more insurers should
be more willing to provide coverage.
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CHAPTER 5
EPA'S UNDERGROUND STORAGE TANK PROGRAM
THE OFFICE OF UNDERGROUND STORAGE
TANKS
The Office of Underground Storage Tanks
(OUST) was created in the summer of 1985 as a
part of EPA's Office of Solid Waste and
Emergency Response (OSWER). Also within
OSWER is the Office of Emergency and
Remedial Response, the Office of Solid Waste,
the Office of Waste Programs Enforcement, and
a separate Emergency Preparedness staff.
OUST was created because EPA officials
believed that in order to carry out the
Congressional mandate to develop and
implement a new regulatory program for
underground storage tanks, a new organizational
unit within the Agency would be required.
OUST is organized into two divisions: the Policy
and Standards Division, and the Implementation
Division. The Policy and Standards Division has
three primary functions: (1) developing
regulations and guidance materials for EPA
Regions and States; (2) initiating and conducting
studies to help resolve technical and policy
issues; and (3) establishing standards and
procedures to ensure that UST programs are
implemented according to established objectives.
The Division is composed of two Branches: the
Standards Branch and the Regulatory Analysis
Branch. The Standards Branch is responsible
for proposing and promulgating technical
regulations for tank systems and cleanups of
releases, conducting or coordinating EPA's UST
technical studies and research, and developing
policy guidance in these areas for EPA Regions
and States. The Regulatory Analysis Branch is
responsible for conducting regulatory impact
analyses, developing regulations for financial
responsibility, formulating policy for Trust Fund
utilization, and developing guidance in these
areas for EPA Regions and States.
The Implementation Division is also composed
of two Branches: the Operations Branch and the
Planning ^nd Communications Branch. The
Operations Branch is responsible for maintaining
regular contact with EPA Regions to monitor
the status of UST program activities throughout
the country. The Branch also conducts Regional
support visits and reviews, coordinates activities
with EPA's Emergency Response Division,
prepares financial reports, and provides a variety
of additional grant management and strategic
planning services. The Planning and
Communications Branch produces outreach
materials (videos, brochures, and handbooks
aimed at improving tank management practices),
plans and implements communication activities,
develops training and technical support
programs, develops program implementation
plans, and designs enforcement strategies and
tools.
In addition to Headquarters, EPA has ten
Regional offices in major cities throughout the
country. Each of these Regional Offices have
UST staffs of four to seven people, including a
Regional UST Program Manager (see Appendix
A).
THE FRANCHISE APPROACH TO
IMPLEMENTING THE UST PROGRAM
EPA managers recognized early in the program
planning process that the UST program must be
managed differently than EPA's other regulatory
programs. Traditionally, EPA "delegated"
program responsibilities to States that had
program authorities and staffing comparable to
the Federal program. In this approach, EPA
offered grants to States as an incentive for them
to run the Federal program. Once delegated,
EPA would "oversee" the State's implementation
of the program and intervene when it did not
satisfy EPA's standards. In the absence of a
comparable delegated State program, EPA
assumed full responsibility for the
implementation of the national program.
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EPA managers realized that this traditional EPA
approach would not work for the UST program
because:
~ There are too many tanks to regulate
with too few Federal resources; EPA
would simply never have the capacity to
address directly tanks at 750,000 sites;
~ In many programs grant levels have not
kept pace with the States' costs and no
longer provide an incentive;
~ EPA's traditional claim of program
primacy is being matched by strong State
and local environmental agencies; and
~ The technologies and techniques of tank
management are evolving.
EPA managers wanted to keep the program
requirements flexible to encourage innovation
and voluntary compliance. In this way tank
owners and operators have the latitude to
experiment with new, low cost alternatives that
meet the regulatory requirements. These needs
led OUST managers to look for new approaches
to implementing the Federal UST program.
One model that has captured the attention of
OUST managers is the franchise approach.
APPLYING THE FRANCHISE APPROACH
The franchise approach, in the world of
commerce, is simply a model for organizing and
administering a service organization. A local
business meeting certain criteria (capital,
management skills, and experience) is authorized
to operate a specific activity under a national or
regional brand name. The contract between the
local business, or franchisee, and the franchisor
sets out the rules that govern this business
relationship. As incentives to franchisees to join
the franchise and pay the franchise fees, the
franchisor provides a tested franchise system,
training programs, national advertising, and its
reputation to franchisees. These products and
services reduce both the cost and the risk to the
franchisee of entering the business.
To ensure that each franchisee adheres to
national standards of quality, the franchisor
devotes substantial resources to training,
communication, and inspection. A franchisor
works closely with each individual owner to
ensure there is a focus on quality and to
continuously improve their operations.
The franchise system also encourages a balance
between maintaining uniformity and encouraging
innovation. Uniform standards and services of
the "chain* are supported and supplied by the
franchisor. Services and products creatively
tailored to a locality can be developed by an
innovative franchisee. In many cases, products
that become national standards are developed by
entrepreneurial franchisees.
MAKING THE APPROACH WORK
OUST has adopted the franchise model as its
implementation approach in managing the
national UST program. While the main goal of
businesses is to make a profit, EPA's goal is to
protect human health and the environment. This
difference is reflected in how the model is used.
State and Local Governments
The State and/or local regulatory agency is the
"franchisee" in the UST franchise, operates
independently, under a signed agreement with
EPA, to operate the UST program. For the
national program to work, these State and local
franchisees must convince their customers to
prevent and undertake corrective actions in
response to releases from underground storage
tanks. The methods used by the franchisees to
stimulate the customer to comply with the
regulations will vary. Some customers may need
a hard sell (e.g^ the threat of enforcement),
whereas others may simply need to know what
the product and service is and how it will benefit
them.
For the national franchise system to continue to
improve, franchisees need to develop and test
new tank management practices and
technologies, and share their experiences with
others.
The Regions
The role of the Regional Offices is analogous to
that of the field representatives in the franchise
model. The Regions serve as liaisons between
EPA Headquarters and the State and local
franchisees to relay ideas, needs, and information
-------
Page 17
as efficiently as possible. The Regjons' primary
role is to help State and local governments build
and improve their UST programs. They do this
by:
~ Promoting the Federal program with State
and local officials;
~ Understanding the work performed by
franchisees;
~ Identifying the support services franchisees
need to improve their programs;
~ Providing assistance, training, funding, and
expertise to franchisees; and
~ Identifying emerging trends and needs
that require the attention of the national
programs (e.g., research, improved
systems, new guidelines to ensure quality).
EPA Headquarters
Under the franchise approach, the role of EPA
Headquarters is to provide general operating
guidelines to ensure that all of the State and
local agencies are achieving the same basic
objectives in managing underground storage
tanks. OUST accomplishes its objective by
providing Regional staff with the resources
needed to understand and improve State and
local programs. Activities include:
~ Working with the Regions to learn about
franchisee UST programs;
~ Obtaining grant and travel funding needed
by the Regions;
~ Setting realistic national policies and
standards;
~ Funding and managing research directed
specifically to solving problems in field
performance;
~ Obtaining contractor and other technical
expertise required by the franchisees;
~ Providing training, handbooks, videos, and
other tools that enable franchisees to
assist tank owners and operators in
managing their tanks; and
~ Performing a clearinghouse function,
including transferring technology and
expertise, holding workshops to deal with
critical operations issues, and encouraging
frequpnt and continual dialogue between
State and Regional UST officials.
In an effort to assist the Regional offices in
helping States build their UST program
capabilities, OUST is promoting a management
system to identify waste and inefficiency in
program procedures (e.g., obtaining program
approval from EPA, issuing permits, conducting
corrective actions), eliminate it, and keep it out.
Eliminating this waste will help States and local
agencies run their programs in a way that is
tailored to meet the specific needs and demands
of their own regulated communities.
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Page 18
CHAPTER 6
PROGRESS MADE TOWARD IMPLEMENTATION
STATUS OF UST PROGRAMS IN 1984
A 1984 survey of underground tank regulations
at the State level provided an indication of the
amount of State involvement in underground
storage tank programs. The survey found only
one State with a comprehensive program to
clean up and prevent leaks from tanks containing
either petroleum or chemical products. Nine
States had regulations that covered petroleum
tanks, but not chemical tanks. Many States
regulated tanks through nationally established
fire codes, such as those published by the
National Fire Protection Association (NFPA 30)
and the Uniform Fire Code (UFC 79), although
these codes are designed to prevent fires rather
than to prevent releases.
PROGRESS SINCE 1984
Since the passage of the Hazardous and Solid
Waste Amendments (HSWA) to RCRA in 1584,
many States and localities have increased their
efforts to address the ground-water
contamination threat and cleanup problems
posed by leaking USTs. At least thirty-five
States have developed UST programs that, at a
minimum, regulate the basic elements of proper
UST system management. Other States have
enacted legislation and are developing regulatory
programs. Exhibit 14 shows the increase in
State UST regulatory activity from 1984 to 1988.
The high level of UST activity at the State level
has taken many routes. Before the Federal
program requirements were issued, some State
programs had established stringent release
detection requirements for existing USTs
(California and Florida), while others emphasize
state-of-the-art prevention technologies for new
USTs (New York, California, and New
Hampshire). Some arc phasing in the
requirement for upgrading or replacement of
existing substandard systems (Florida,
Connecticut, and Delaware). Others have
attempted to tailor their standard-setting based
on proximity to sensitive ground-water locations
(Maine and South Carolina).
Three State programs—New York, Florida, and
California-have begun to develop strong working
relationships with local UST programs, a policy
they feel is critical to the success of their State
programs. In New York, the State has delegated
UST program authority to several of the eastern
urban county governments, allowing the State
agency to focus its efforts on implementing the
UST program in the less urban counties where
local UST programs are less developed. In
Florida, county governments regulate
approximately half of the State's tank population.
California has delegated primary responsibility
for administering and enforcing the State UST
program to more than one-hundred local county
and city agencies.
THE STATE PROGRAM APPROVAL PROCESS
As an important step toward achieving the long-
range goal of developing a network of effective
State and local programs, EPA is encouraging
States to apply for formal approval of their UST
programs to operate in lieu of the Federal
program. EPA plans to approve acceptable
State UST programs as quickly as possible, and
follow up with activities that provide continual
assistance to States and localities for improving
their capabilities and performance. A list of
State UST Program Offices is provided in
Appendix B.
EPA approval of a State program means that
the requirements in the State's laws and
regulations will be in effect rather than the
Federal requirements. Program approval ensures
that a single set of requirements (the State's)
will be enforced in that State, thus eliminating
the duplication and confusion that would result
from having separate State and Federal
requirements. Once a State program is
-------
Exhibit 14
States with Underground Storage Tank
Statutes or Regulations
1984
1988
-------
Page 20
approved, the State program will operate under
a Memorandum of Agreement that clearly
delineates EPA's limited role in an approved
State and assures the State of its lead role in
administering and enforcing the UST program.
Approval of a State program also means that the
basic environmental protection afforded by the
Federal program is contained in the State
program as welL The primary focus of EPA's
approval review is to ensure that the State's
program will achieve the objectives of the
Federal regulations pertaining to the prevention,'
detection, and cleanup of UST releases and
provide for adequate enforcement of compliance.
EPA has encouraged the development of
comprehensive State UST programs and believes
that States must continue to have the flexibility
to develop and carry out their own initiatives.
While there is wide diversity in State UST
programs, the Federal regulations require that
several common elements be part of each State
program. These elements must be no less
stringent than corresponding Federal
requirements, based on a comparison of the
State's technical requirements to the Federal
objectives for each of these program elements.
States must also provide for adequate
enforcement of the requirements. EPA has
designed its approval criteria to result in as little
unnecessary disruption to ongoing State
initiatives as is possible.
Federal objectives, contained in the Federal-State
Program Approval Standards (published in
December 1988), have been identified for the
following program elements:
~ New UST system design, construction,
installation, and notification;
~ Upgrading of existing UST systems;
~ General operating requirements;
~ Release detection;
~ Corrective action;
~ Out-of-service or closed UST systems; and
~ Financial responsibility.
To meet the "no less stringent" requirements
using this approach, the State must have
requirements that meet the Federal objectives in
each of these areas. EPA's criteria for adequate
enforcement of compliance require that a State
have in place adequate legal authorities for
inspection and compliance monitoring,
enforcement, and public participation, plus
appropriate written procedures for implementing
those authorities. EPA seeks to maintain its
flexibiltiy to approve a variety of State programs
and to encourage States to use innovative as well
as traditional approaches in achieving
compliance.
THE ROLE OF LOCAL GOVERNMENTS
In addition, more than one hundred major cities
in the U.S. have already developed local UST
ordinances and programs. Some programs are
operated independently of the State; others are
part of a wider State regulatory program. The
implementation role of local agencies in the UST
regulatory effort is being encouraged in many
States in order to use local support (e.g., Ore
marshals and building code officials) as much as
possible in order to improve overall
administrative and enforcement capabilities. In
Maryland, some counties have their own UST
regulations or enforce building and fire codes
regulating USTs generally focusing on permits
and inspections of tank installations.
Massachusetts delegates its regulatory program,
including inspections and permitting, through the
State Fire Marshal's Office to local fire
departments. California requires counties to
implement and enforce the technical
requirements of the UST program, although
cities may choose to develop their own programs
and override county authority within the city
limits.
~ Release reporting, investigation, and
confirmation;
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Page 21
CHAPTER 7
OTHER SOURCES OF INFORMATION ON THE UST PROGRAM
In addition to the materials in this manual, the
UST program also has developed handbooks,
slide shows, and video tapes on a wide range of
topics to inform States and localities, tank
owners and operators, and individuals in related
industries about the regulations and program
requirements. Many of these materials may be
of interest to you. Exhibit 15 is an order form
for OUST publications. Exhibit 16 provides
information about obtaining OUSTs video
programs.
In addition to these materials, the EPA
RCRA/Su^perfund Hotline (1-800-424-9346) can
assist you with specific questions about the UST
regulatory requirements.
-------
Exhibit 15
U.S. ENVIRONMENTAL PROTECTION AGENCY Page 22
OFFICE OF UNDERGROUND STORAGE TANKS
PUBLICATIONS LIST
General Information order no.
Notification for Underground Storage Tanks: EPA Form 7530-1 (Revised 9-68) 5
Hazardous Substance List 7
LUSTUNE Bulletin ' 10
Normas y Procedimierrtos para T.S.A.-(The Spanish version of Musts for USTs,
an overview of Federal Tecnr.ical UST standards) 26S
Volumetric Tanx Testing (Summary of Edison Study on Internal Leak Cetfr^ors) 34B
Managing Underground Storage Tanks (fcrocriuie to order a slide show) 40
"Oh No! Leaks and Spills!" - First Response ^tKocnure) 73
Leak Lookout (External Leak Detectors) . 74
Introducing REG-IN-A-BOX (ordering flier)
Regulations
Notification of Requirements for Owners of Underground Storage Tanks; Final Rule
40 CFR Part 280 (Federal Register 11/8/85) 3
Underground Storage Tanks: Technical Requirements and State Program Approval; Final Rules
40 CFR Pans 280 & 281 (Federal Register Part II 9/23/88) 4A
Underground Storage Tanks Containing Petroleum; Financial Responsibility Requirements and
State Program Approval Objective: Final Rule 40 CFR Parts 280 & 281 (Federal Register Part I110/26/88),
Underground Storage Tanks Containing Petroleum; Financial Responsibility Requirements; Interim Final
Rule 40 CFR Part 280 (Federal Register 11/9/89, 5/2/90) 4B
Hazardous Waste: Interim Prohibition Against installation of Unprotected Underground
Storage Tanks; Interpretive Rule 40 CFR Pan 280 (Federal Register 6/4/86) 17
Subtitle I. Hazardous and Solid Waste Amendments of 1984; RCRA 21
Technical Reports
Causes of Release From UST Systems
32
Tank Corrosion Study
42
Estimating Air Emissions from Petroleum UST Cleanups
88
Detecting Leaks. Successful Methods Step-by-Step
92
Order Form
Name: Title:
Organization:
Street:
City: State: Zip:
Telephone: ( )
Please send me the following publications:
3 4A 4B 5 7 10 17 21 26S
32 348 40 42 73 74 84 88 92
Please return this order form to:
U.S. Environmental Protection Agency
Office of Underground Storage Tan*s
P.O. Box 6044
Rockville, MD 20850
UST25
6/90
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Exhibit 16
AVAILABLE FROM SOURCES OTHER THAN EPA
Publications
Page 23
Musts for USTs: A Summary of the New
Regulations for Underground Storage Tank
Systems
Stock No. 055-000-00294-1 $2.50
Dollars and Sense: A Summary of the Financial
Responsibility Regulations for Underground
Storage Tank Systems
Stock No. 055-000-00293-2 $1.25
Cleanup of Releases from Petroleum USTs: Selected
Technologies
Stock No. 055-000-00272-0 S7.50
Petroleum Tank Releases Under Control: A
Compendium of Current Practices for State UST
Inspectors
Stock No. 055-000-00295-9 S8.50
Processes Affecting Subsurface Transport of Leaking
Underground Tank Fluids
Stock No. 055-000-00269-0 S3 25
Survey of Vendors of External Petroleum Leak
Monitoring Devices for Use with USTs
Stock No. 055-000-00277-1 S4 25
Purcha*« Superintendent of Documents
From: US Government Printing Office
Washington, D C. 20402
(202) 783-3238
Evaluation of Volumetric Leak Detection Methods for
Underground Fuel Storage Tanks
Volume 1. No. PB89-124333 $39.95
Volume 2. No. PB89-124341 $76.95
Purchase National Technical Information Service
From: 5265 Port Royal Road
Springfield, VA 22161
(703) 457-4600
Soil Gas Sensing for Detection and Mapping of Volatile
Organlcs
Catalog No. 49 $38.00/member; $46.75/non-member
Purchase National Water Well Association
From: P.O. Box 182039, Dept. 017
Columbus, OH 43218
(614) 761-1711
Computer Software
Reg-ln-A-Box software aid* understanding/working with Federal
UST regulations. Easy to use and available for Macintosh or PC-
companbles with hard disk drives. Not copy protected
Purchase PC-Comp«tlbl«* From:
Public Brand Software, $5.00 plus shipping and handling,
l -800-426-3475 (24 hours a day). (317) 856-7571 (in
Indiana), Visa and MasterCard accepted
Purchasa Apple Macintosh From:
Budgetbytes Software, $5.99 plus shipping and handling.
1 -800-356-3551 (8 a.m. to 6 p.m., CST). Visa and
MasterCard accepted
Audiovisual Programs
VIDEOS
'Tank Closure Without Tears: An Inspector's Safety
Guide"
(Focuses on problem of explosive vapors and safe tank
removal.)
Video and booklet $30.00 prepaid
Booklet only $5 00 prepaid
"What Do We Have Here? An Inspector's
Guide to Site Assessment at Tank Closure."
(A three part video on inspecting sites for contamination
where tanks have been removed; provides a site
assessment overview [30 minules], an overview of field
instruments [14 minutes], and a brief discussion of soil and
water sampling [7 minutes].)
Video $40 00 prepaid
Booklet $5 00 prepaid
Purchasa - New England Interstate Water Pollution
From: Control Comm ssion
Attn VIDEOS
85 Memmac Street
Boston, MA 02114
Borrow Clo-
ture Video*
and Booklet*
From:
Video and booklet $5.00 prepaid
New England Regional Wastewater Institute
2 Fort Road
South Portland. ME 04106
"Doing It Right"
(Proper installation of underground tanks and piping for
installation crews )
Vtaeo $16 00 prepaid
Purchase American Petroleum Institute
From Either: 1220 I. Street, N.'.V,
Washington, D C. 20005
or: Petroleum Equipment Institute
Box 2380
Tulsa, OK 74101
"A Question of When: Tank Installation for Inspectors"
(Tank and pipe installation w.lh a checklist for inspectors.)
"In Your Own Backyard"
(What tank owners should require from installation
contractors.)
Videos $22 85 each prepaid
Purchase National Fire Protection Association
From: Attn' Jim Smalley
Battery march Park
Quincy, MA 02269
SLIDES
"Managing Underground Storage Tanks"
(Segments on all phases cf tank management from
inventory and installation to leak detection and clean up.)
185 Slides, 27 page script, $120.00
and 103 pages of graphics
Purchase National Audiovisual Center
From: Customer Services SectiorVWD
8700 Edgeworth Drive
Capitol Heights. MD 20743-3701
(301) 763-1891
UST25
6/90
-------
Appendix A
How Can You Get More Information?
Page 24
You can call the RCRA/Superfund Hotline (1-800-424-9346) or contact one of the EPA Regional UST Program
Managers listed below.
EPA Regional UST Program Managers
WA
OR
1
ID
CA
MT
WY
Ml
NV
NE
IA
UT
IL
CO
IN
OH
KS
AZ
NM
OK
MO
AR
KY
MS
LA
TX
TN
AL
r~*Y ¦
PA
VA
NC
SC
GA
HAWAII c
GUAM
AM. SAMOA
CNMI
Ft
Rl
-0E
-MO
VIRGIN IS
PUERTO RICO
U.S. EPA, Rag Ion 1
JFK Federal Bldg.
Mailcode: HPU-1
Boston, MA 02203-2211
617-573-9604
FTS 833-1604
U.S. EPA, Region 4
345 Courtland St, N.E.
Mailcode: 4WM-GP
Atlanta. GA 30365
404-347-3866
FTS 257-3866
U.S. EPA, Region 7
RCRA Branch
726 Minnesota Ave.
Kansas City, KS 66101
913-551-7651
FTS 276-7651
U.S.EPA Region 9
75 Hawthorn St.
ffeiloocte: H-2-1
San Francisco, CA 94105
415-744-1500
FIS 484-2063
U.S. EPA, Region 2
Hazardous Waste
Programs Branch
26 Federal Plaza
Mailcode: 2AWM-HWPB
New York, NY 10278
212-264-1369
FTS 264-1369
U.S. EPA, Region 3
841 Chestnut Building
Mailcode: 3HW31
Philadelphia, PA 19107
215-597-7354
FTS 597-7354
U.S. EPA, Region 5
230 S. Dearborn St.
Mailcode: 5HFKJCK-13
Chicago, IL 60604
312-886-6159
FTS 886-6159
U.S. EPA, Region 6
1445 Ross Avenue
Mailcode: 6H-A
Dallas, TX 75202-2733
214-655-6755
FTS 255-6755
U.S. EPA, Region 8
999 18th Street
Mailcode: 8-HWM-RM
Denver, CO 80202-2405
303-293-1489
FTS 564-1489
U.S. EPA, Region 10
1200 Sixth Ave.
Mailcode: WD-139
Seattle. WA 98101
206-442-0344
FTS 399-0344
10/88
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State UST Program Offices
Page 25
Appendix B
WA
OR
1
MT
NO
10
SO
WY
ME
A
NV
NE
IA
CA
UT
IL
OH
PA
m
1
Rl
CO
•OE
-MO
KS
AZ
NM
OK
6
MO
AR
LA
KY
MS
TX
TN
AL
NC 3T
SC
GA
HAWAU c
GUAM
AM. SAMOA
CNMI
FL
EPA Regional Map
VIRGIN IS.
PUERTO RICO
AL AL DepL of Environmental Mgmt
Ground Water Section/Water Division
1751 Congressman W. Dickerson Dr.
Montgomery, AL 36130
205-271-7832
AK Dept of Environmental Conservation
P.O. Box 0
Juneau. AK 99811-1800
907-465-2653
AR AR Dept. of Pollution Control & EcoL
P.O. Box 9583
Little Rock. AR 72219
501-562-7444
AZ AZ Dept. of Environmental Quality
Environmental Health Services
2005 N. Central
Phoenix, AZ 85004
602-257-6984
CA State Water Resources Control Board
OUST
P.O. Box 944212
2014 T Street
Sacramento, CA 95814
916-322-3133
CO CO Dept. of Health
Waste Mgmt Division
Underground Tank Program
4210 East 11th Avenue
Denver, CO 80220
303-331-4864
CT Hazardous Materials Mgmt Unit
Dept of Environmental Protection
State Office Building
165 Capitol Avenue
Hartford. CT 06106
203-566-4630
DC Dept. at Consumer and Regulatory
Affairs
Environmental Control Division
516 H Street, N.W.
Washington, D.C. 20001
202-783-3205
OE Oivbion of Air and Waste Mgmt.
Dept. of Natural Resources &
Environmental Control
89 Kings Highway
Dover. DE 19903
302-323-4588
FL FL Dept of Environmental Regulation
Solid Waste Section
Twin Towers Office Building
2600 Blair Stone Road
Tallahassee, FL 32399-2400
904-488-0300
GA GA Environmental Protection Division
3420 Norman Berry Drive
Hapeville, GA 30334
404-656-7404
HI DepL of Health
Hazardous Waste Program
P.O. Box 3378
645 Halekauwila Street
Honolulu, HI 96801-9984
808-548-5837
IA IA DepL of Natural Resources
Henry A. Wallace Building
900 East Grand
Des Moines, IA 50319
515-281-3779
ID ID DepL of Health & Welfare
Division of Environmental Quality
450 W. State Street
Boise, ID 83720
208-334-5347
IL Office of State Fire Marshal
3150 Executive Park Drive
Springfield. IL 62703-4599
217-785-5378
IN Underground Storage Tank Program
IN Dept. of Environmental Mgmt
105 South Meridian Street
Indianapolis, IN 46225
317-243-5055
KS KS Dept of Health & Environment
Forbes Held, Building 740
Topeka, KS 66620
913-285-1594
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KY Dept erf Environmental Protection
Hazardous Waste Branch
Fort Boone Plaza, Building *2
18 ReiiJy Road
Frankfort KY 40601
502-564-6716
La LA Dept. of Environmental Quality
P.O. Box 44274
62S North 4th Street
Baton Rouge, LA 70804
504-342-7808
MA Dept. of Public Safety
P.O. Box-490
Tewksbury, MA 01876
508-851-9813
ME Underground Tanks Program
Bureau of Oil & Hazardous Material
Control
Dept of Environmental Protection
Ray BWg. - Station 17
Augusta, ME 04333
207-289-2651
MD MO Dept. of the Environment
Hazard & Solid Waste Mgmt & Admin.
OUST and LUST Division
2500 Broening Highway
Baltimore, MO 21224
301-631-3442
Ml Fire Marshall Division
Ml Dept. of State Police
7150 Harris Drive
Lansing, Ml 48913
S17-322-1935
800-MICHUST
Underground Storage Tank Program
M.N Pollution Control Agency
520 West Lafayette Road
SL Paul, MN 55155
612-296-7743
MO MO Dept. of Natural Resources
P.O. Box 176
Jefferson City, MO 65102
314-751-7428
MS Dept. of Natural Resources
Bureau of Pollution Control
UST Section
P.O. Box 10385
Jackson. MS 39209
601-961-5171
MT Solid & Hazardous Waste Bureau
Dept of Health & Environmental ScL
Cogswell Bldg. - Room 8-201
Helena, MT 59620
406-444-2821
NC Div. of Environmental Mgmt.
Ground-Water Operations Branch
Dept of Natural Resources and
Community Development
512 N.- Salisbury, P.O. Box 27687
Raleigh. NC 27611
919-733-3221
NO Division of Waste Mgmt
ND Dept. of Health
' '1200 Missouri Avenue
Bismarck, ND 58502-5520
701-224-3498
NE NE State Fire Marshal
P.O. Box 94677
Lincoln, NE 68509-4677
402-471-9465
NH NH Dept of Environmental Services
Water Supply & Pollution Control Div.
Hazen Drive, P.O. Box 95
Concord, NH 03301
603-271-3503
NJ Dept of Environmental Protection
Div. of Water Resources (CN-029)
Trenton. NJ 08625
609-984-3156
NM UST Section (Rm. N. 2150)
NM Environmental Improvement Oiv.
H. W. Bureau
1190 St Francis Drive
Santa Fe, NM 87503
505-827-2894
NV Division of Environmental Protection
Dept of Conservation & Natural Res.
Capitol Complex 201 S. Fall St
Carson City, NV 89710
702-885-5872
NY Bulk Storage Section, Div. of Water
Dept of Environmental Conservation
50 Wolf Road, Room 326
Albany, NY 12233-0001
518-457-4351
OH State Fire Marshal's Office
Dept of Commerce
8895 E. Main Street
Reynoldsburg, OH 43068
614-864-5510
800-282-1927
OK OK Corporation Comm.
Jim Thorpe Building
Oklahoma City, OK 73105
405-521-3107
OR OR Dept of Environmental Quality
811 SW Sixth Ave.
Portland, OR 97204
503-229-5769
PA PA Dept of Environmental Resources
Bureau of Water Quality Mgmt
Non-point Source & Storage Tank
Section
9th Floor Fulton Building
Hamburg, PA 17120
717-787-8184
R1 Div. of GW and FW Wetlands
Dept of Environmental Management
291 Promenade St.
Providence, Rl 02903
401-277-2234
SC Ground-Water Protection Division
SC Dept of Health & Environ. Control
2600 Bull Street
Columbia, SC 29201
" 803-734-5332
SD Office of Water Quality
Dept of Water & Natural Resources
Joe Foss Building, mi. 217
Piene, SD 57S01-3181
605-773-3351
TN Division of Ground-Water Protection
TN Dept of Health 4 Environmental
150 9th Avenue. North
Nashville, TN 37219-5404
615-741-0690
TX UST Program
Texas Water Commission
P.O.Box 13087; Capital Station
Austin, TX 78711
512-463-8180
Page 26
UT Bureau of Solid & Hazardous Waste
UT Dept of Environmental Health
288 N. 1460 West
Salt Lake City, UT 84116-0700
801-538-6170
VA VA Water Control Board
2111 North Hamilton Street
P.O. Box 11143
Richmond, VA 23230-1143
804-367-6350
VT Dept of Environmental Conservation
Waste Management Division
103 South Main St.
Waterbury, VT 05676
802-244-8702
WA WA Dept. of Ecology, M/S PV-11
Solid & Hazardous Waste Program
Olympia, WA 98504-8711
206-459-6272
W1 Dept of Industry, Labor and Human
Relations
P.O. Box 7979
Madison, Wl 53707
608-266-7605
WV Division of Waste Management
WV Dept of Natural Resources
1260 Greenbriar Street
Charleston. WV 23505
304-348-5935
WY Water Quality Division
Dept of Environmental Quality
Herschler Building, 4th Floor West
122 West 25th Street
Cheyenne. WY 82002
307-777-7085
AS Environmental Quality Commission
Office of the Governor
American Samoan Government
Pago Pago, American Samoa 96799
684-633-2632
GU GU Environmental Protection Agency
P.O. Box 2999
Agana, Guam 96910
671-646-8863
NMI Division of Environmental Quality
P.O. Box 1304
Commonwealth of Northern Mariana
Islands
Saipan, CM 96950
607-234-6984
PR Water Quality Control Area
Environmental Quality Board
Commonwealth of Puerto Rico
Santurce, Puerto Rico
809-725-8410
V! Environmental Protection Division
Dept. of Planning and National
Resources
179 Altona and Welgunst
Charlotte Amlie, St. Thomas,
Virgin Islands 00802
809-774-3320
U.S. Environmental Protection Agency
Office of Underground Storage Tanks
Washington. O.C.
11/88
Biannual Update
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