Underground Tank Inspections

Tank Inspections / Regulatory Requirements

A tank inspection is normally the first step in evaluating and addressing a petroleum storage tank. Aboveground storage tanks (ASTs) are easy to inspect and leakage is usually visible. Underground Storage Tank (UST) inspections, however, are more challenging, and the importance of having a professional perform such inspections cannot be overemphasized. A UST inspection normally determines the location, size, orientation, contents, and status of the tank with regard to leakage. Leakage is evaluated via borings below the depth of the tank with recovery of soil for testing.

Reporting Requirements

If a petroleum release to the environment is detected, State Water Control Law (SWCL) requires reporting of the release to Virginia Department of Environmental Quality (VDEQ). As part of our inspection process, Pollard performs the required reporting.

Environmental Corrective Action

Once a petroleum release from a tank is reported, VDEQ determines the corrective action, if any, required to remedy the problem. The first priority is to stop the leakage by removing the remaining petroleum from the tank. In some instances, natural processes may satisfactorily remediate the contamination over time. More serious leaks posing risks to groundwater, water wells, basements, creeks, and/or other receptors often require more aggressive action such as excavation and proper treatment/disposal of contaminated soils. If environmental corrective action is necessary, financial assistance is normally available from the Virginia Petroleum Storage Tank Fund (VPSTF). VPSTF assistance requires pre-approval of activities and accurate claim submittal, so it is important to have an experienced consultant, such as Pollard, handle this process.

Responsibility for Corrective Action

The party owning the real estate when a petroleum release is reported to the VDEQ will generally be responsible for corrective action, if any, as required by VDEQ. If it is determined that a previous owner or person responsible for the property knew or should have known about leakage, but failed to report it, that person/entity may be liable for clean-up and/or fines pursuant to SWCL.

Closure

Once a petroleum release has been addressed to the satisfaction of the VDEQ, they will issue the RP a closure letter.

Building/Fire Code Requirements

In addition to SWCL, both the Uniform Statewide Building Code (USBC) and the Statewide Fire Prevention Code (SFPC) have requirements for abandoned or leaking petroleum USTs.  Enforcement of the code is the responsibility of local building or fire officials. Both USBC and SFPC refer to the 2009 International Fire Code (IFC) section 3404.2.13.1, which states that abandoned or leaking USTs shall be emptied of flammable or combustible liquids and either removed from the ground or filled with an approved inert solid. Flowable fill cement is normally an acceptable inert solid, and some localities may allow smaller tanks to be filled with foam. Sand may be an approved inert solid, but it is a difficult process to completely fill an underground tank with sand. There is no financial assistance (VPSTF or other) for Building/Fire Code compliance.