There are 4,071 underground storage tanks (USTs) in the state of Utah. Over 66 percent of these tanks utilize the Petroleum Storage Tank Trust Fund as their financial assurance mechanism for the assessment and cleanup of releases. The UST program focuses on prevention through inspection and compliance follow-up. In the event of a release, DERR oversees the cleanups to ensure that state standards are met. The Division also conducts UST cleanups where the responsible party is unknown, unwilling, or unable to conduct the cleanup themselves to assure that the public health is protected and contaminated sites are ultimately cleaned up.
In 2018, DERR UST staff conducted over 871 compliance inspections. UST owners/operators in the state have a 92 percent compliance rate within 60 days of the time of inspection. While more than 80 new release sites were reported this year, over 123 reported release sites were remediated and closed, paving the way for some properties to be developed for a better and higher use.
Success Story: UST State Program Approval
The process of preparing for SPA review began in earnest in early 2016 and focused on updating Utah UST rules to incorporate the 2015 changes. At the same time, DERR’s UST branch began work on the required SPA documents. These documents included the following:
- A detailed description of the state program
- A description of the state’s enforcement process
- A detailed comparison of the state and federal rules to ensure that the state program is “no less stringent” than the federal rules.
The process requires significant input from the Utah Attorney General’s Office, including a letter from the Attorney General certifying the “no less stringent” determination. The Environmental Protection Agency (EPA) also required examples of forms, letters, process descriptions, and guidance documents.
The official application for State Program approval was submitted to EPA on February 21, 2018. After a comprehensive review of the application, it was approved by the EPA Region 8 Regional Administrator and published in the Federal Register on November 5, 2018. This initiated a 30-day public comment period. At the close of the comment period, no adverse comments had been received. Final approval will be effective January 5, 2019.
UST Advisory Task Force
DERR utilizes an advisory task force to provide an avenue for UST program stakeholders to offer suggestions and feedback regarding program operation and development. The Task Force is comprised of representatives of various sectors of the industry, including retail gas stations, the Utah State Fuel network, UST installation and service companies, and remediation consultants.
Meetings are held four times a year. Topics include potential changes to statutes or rules, ways to implement various aspects of the program effectively, and areas of emerging concern. The Task Force provides invaluable input to the UST program and allows DERR to work closely with affected stakeholders to improve the program.
UST Revised Rules Implementation
Changes to the Federal UST regulations have required some additional requirements for owner and operators of underground storage tanks. The deadline for compliance with these new UST regulations was October 13, 2018. The revisions to the rules included new testing requirements for tank systems, along with the removal of regulatory deferrals for emergency generator tanks. To assist facility operators with meeting the compliance deadline, the UST Compliance Section conducted outreach that included workshops, targeted mailings, newsletter articles, monthly emailed tank tips, and facility-specific letters that identified compliance requirements. Workshop attendees alone accounted for more than half of the tank facilities in the state. There is still much to be done to bring every facility into compliance, and the outreach effort will continue well into 2019.
Success Story: Cleanup of Catastrophic UST Gasoline Leak at the Provo Stadium Chevron
On March 13, 2018, a catastrophic leak from an underground storage tank (UST) at a gas station across the street from Lavell Edwards Stadium resulted in the release of 55,000 gallons of gasoline into the subsurface soils and groundwater.
Initial clean-up work included delineating the extent of the soil and groundwater contamination and the removal of free product (gasoline). The gasoline migrated down to the groundwater table (about 35 feet below the surface) and extended laterally about 300 feet in diameter. Terracon, the project’s environmental consultant, installed 23 soil-gas sampling wells to determine if gasoline vapors were migrating upward into overlying buildings, including the nearby Super 8 Motel, Wells Fargo Bank, and Riviera Apartments. In July and August 2018, soil-gas samples were collected from all of the wells; results indicated that no vapor intrusion had occurred in these buildings.
As of October 28, 2018, about 38,212 gallons of gasoline have been removed from the subsurface using soil vapor extraction (1.5 MB). Under this process, extracted gasoline vapors are treated using thermal and catalytic oxidation. The leaking tanks have since been replaced. DERR and Terracon continue to work to clean up this large gasoline release.
Whenever a release occurs, the Division examines the factors that may have contributed to the release and what, if anything, could have been done to prevent or minimize it. Conclusions from DERR’s evaluation of the Stadium Chevron release include:
- The installation process may have contributed to the leak. The underground storage tanks were installed several years before the establishment of state inspection requirements. The burial depth and compaction of fill material may have led to stresses on the fiberglass tank, which eventually cracked.
- Onsite personnel failed to understand the results of leak-detection monitoring. Although the system was able to return a passing leak-detection result, it also returned results that suggested there may be a problem with the tank or the leak-detection equipment.
- Daily inventory reconciliation was typically conducted for the facility, but it was interrupted when the employee responsible was on vacation. Had this inventory reconciliation been done daily, the catastrophic failure would have been caught more quickly, resulting in less fuel loss.
- The facility was reportedly set up on an automatic fuel-delivery schedule. The fuel level was reported to the distributor, who would send a load when a certain fuel level was reached in the tank. If an employee had been involved in the fuel order, it would have been apparent that the fuel sales did not warrant a delivery and led the employee to investigate the discrepancy. This investigation would have immediately shown a large loss of fuel from a leak.
DERR uses these “lessons learned” from tank leaks to provide outreach to tank owners so they can avoid similar problems at their own facilities.