Background

Underground storage tanks (USTs) are the most numerous sources of soil and groundwater contamination in the U.S. As a result, the U.S. Environmental Protection Agency has promulgated stringent regulations (40 CFR 280) controlling the design, installation, repair, and removal of UST systems. Every UST owner faces deadlines to comply with these tough new regulations. Some highlights of the regulations include:

• A new tank system installed after December 22, 1988 must have leak detection, corrosion protection, and spill/over prevention
• A tank system installed before December 22, 1988 must be upgraded/repaired to meet the requirements for leak detection and must include corrosion protection and spill/overfill prevention by
  December 22, 1998
• Regulatory authorities must be notified 30 days prior to permanent tank closure and appropriate closure procedures must be followed
  

Aboveground storage tank owners also are facing the pressures of newly enacted and proposed regulations. Some of these regulatory requirements include:

• Development and implementation of procedures (including periodic testing) for early leak detection
• Implementation of product inventory control programs
• Periodic inspection of the tank system’s structural integrity, leak detection system, and release prevention measures
• Minimum requirements for design of new tanks and removal, repair, and maintenance of existing tanks
• Stringent recordkeeping requirements with respect to periodic inspections, repairs, and maintenance activities
  
  

Approach and Experience

Davis & Floyd, Inc.’s tank management program assists tank owners in complying with the regulations in an environmentally safe and cost-effective manner. We are prepared to address the full gamut of concerns that tank owners may face such as tank testing, repair of leaking systems, and development of recordkeeping and inventory control procedures. Through a structured approach, we can address the compliance requirements of any tank owner, regardless of system size or complexity.

We offer field services, engineering services, and management services to tank owners.

Field Services

The initial phase of comprehensive tank management is the assessment of tank system integrity. Our experienced field personnel inventory and catalog tank system components so that priorities for testing, retrofitting, and/or remediation can be established as necessary.

As-built conditions of aboveground tanks are evaluated to determine if the tank had been installed according to industry standards.

Engineering Services

As a full-service engineering firm, our engineering services related to tank management are unparalleled. We maintain a core of experienced engineers knowledgeable in all aspects of underground and aboveground storage tank systems. These professionals design complete tank and piping systems, incorporating state-of-the-art equipment and meeting Federal, State, and local environmental protection, building construction, and fire prevention codes.

We also develop repair/upgrade plans to extend the life of existing tank systems. Repair or upgrade of existing systems may be more cost-effective than replacement and may be especially beneficial where access restrictions preclude complete system replacement.

For tank systems no longer intended for use, we prepare closure plans that specify closure procedures, material disposal, cleanup standards, and certification requirements. We have prepared and reviewed numerous such plans on behalf of industries and governments. In the event that remediation of groundwater or soils is necessary, our environmental services group prepares plans and specifications ranging from simple excavation and disposal to more elaborate in-situ or ex-situ methods running the gamut of currently available technologies.

Management Services

EPA’s UST regulations mandate use of more accurate and comprehensive recordkeeping procedures. To address these requirements, we can assist in maintaining and accessing up-to-date records, providing information for intelligent tank management decision-making.

We can prioritize a client’s tank management needs based on tank size and age, material compatibility, and release/exposure potential. Establishing priorities permits us to provide recommendations for directing resources to those system components requiring immediate action while deferring less critical items.