Storage Tank Program
The University’s EHRS manages the Storage Tank (AST and UST operations) program with FRES support. The Storage Tank management program includes registration of regulated storage tanks, determining the application of regulations to the University, Health System, Morris Arboretum and New Bolton Center, developing the written response plans and any liaison with the Pennsylvania Department of Environmental Protection (PADEP).
Aboveground Storage Tanks
In Philadelphia, aboveground storage tanks (ASTs) are usually the logical option for fuel supply due to the regulatory requirements and risk associated with operating underground storage tanks (USTs). The University’s ASTs are commonly used for the purposes of supplying fuel to emergency generators and fire pumps. The University’s Philadelphia campus, New Bolton Center, Health System and Morris Arboretum currently own and operate over 100 aboveground storage tanks. Due to their storage capacity, several of these ASTs are registered with the PADEP.
The federal and state environmental regulations for operating ASTs are different from many of the underground storage requirements. From 1985 to 1995, the U.S. EPA implemented a series of regulations to establish clear standards on how to properly replace, install, remove and operate ASTs. The objective of these regulations was to also establish inspection protocols to prevent hazardous materials from coming into contact with groundwater systems.
EHRS performs routine inspections for all University, Health System, New Bolton Center and Morris Arboretum ASTs. The main emphasis of these inspections is to evaluate tank condition and integrity. The visual checklist includes:
- Any damage to the tank;
- Evidence of drips or overspills;
- Condition of secondary containment;
- Nearby vegetation showing any evidence of soil contamination;
- Condition of all transfer piping.
In situations where deficiencies are identified, EHRS works with FRES to see that the necessary repairs are made to ensure safety and compliance with the regulations. If anyone from the University community notices a problem with an AST system, they should immediately contact EHRS.
Underground Storage Tanks
Underground storage tanks (USTs) are tanks that have at least 10% of its volume underground. The University USTs are typically buried 2-4 feet below surface level. Twenty years ago, there were over 25 USTs on the Philadelphia campus. The University has since removed the majority of these USTs from the ground. The remaining University USTs are used to store fuel for emergency generators.
The Federal and State regulatory requirements for owning and operating USTs are extensive, restrictive and costly if they are not followed. Since 1988, the EPA, PADEP and City of Philadelphia Licenses &Inspections have steadily increased requirements on existing USTs and new installations. Among the current requirements include:
- Spill protection in the form of a catchment basin which must contain all spillage when the delivery hose is uncoupled from the fill pipe;
- Overfill protection which will shut off product flow, restrict flow or alert the operator when the UST is close to being full;
- Corrosion protection for all fuel transfer lines;
- Release detection alarms;
- Training for owners and University operators;
- Development of an emergency response plan;
- Registration and payment of fees to PADEP for UST systems.
Any UST scheduled for removal must follow a regulatory protocol established by the PADEP. Only Pennsylvania Certified UST Contractors are legally permitted to remove USTs. The regulations for UST removals are designed to ensure any potential or real source of contamination is properly managed to prevent environmental damage. The essential requirements for properly removing USTs include these and additional tasks:
- Proper removal of soil and fill material;
- Tracking the disposal of contaminated soil;
- Sampling underneath the former tank area to verify removal of all contaminated materials;
- Decontamination and disposal of the tank;
- Develop closure documents and submit to PADEP.
If you need any additional information or have any questions, contact Kyle Rosato, EHRS at 215-898-0766.