CRG Texas was engaged to permanently remove the underground petroleum storage tank (UST) system from service at the subject site by the property owner under notice of enforcement action by the Texas Commission on Environmental Quality (TCEQ). The UST system was no longer in service and was being maintained under the TCEQ requirements for “temporary out of service” (TOS or TOOS) UST systems in Texas (see RG-475l: Temporarily Removing Petroleum Storage Tanks from Service (texas.gov)), that costed the owner to meet the requirements even when the system is not bringing in any revenue.
There are three options for permanently removing your UST from service:
- remove the tank from the ground,
- permanently fill the tank in place, or
- conduct a permanent change in service (e.g., to storage of a non-regulated substance).
Each option has benefits and disadvantages. Regardless of the chosen option, a demonstration that no prior release of a stored regulated substance has occurred from your UST system must be made in accordance with 30 TAC 334.55. 1. Removing the tank from the ground eliminates the chance of future soil contamination. However, it may not be a viable solution if the UST is under a permanent structure.
The practical solution for this property owner was to permanently remove the UST system, thus removing the requirements to:
- File an amended UST registration within 30 days of temporary removal of service using the UST Registration and Self-Certification Form (TCEQ-00724).
- Keep all vent lines open and functioning to prevent vapors building up and potentially causing an explosion.
- Cap, plug, or lock piping, pumps, manways, tank access points and ancillary equipment to prevent access, tampering, or vandalism by unauthorized persons.
- Maintain corrosion protection at all times.
- Maintain operator training requirements and continue retraining every three years.
- Unless the UST is emptied of all regulated substances, maintain an approved release detection method and financial assurance.
Other benefits to the Owner include:
- Retention of the intrinsic property value that would otherwise be reduced should the owner wish to sell or refinance the property
- Reduce liabilities associated with UST systems remaining in place and not in use presented by illegal dumping of unknown substances into the UST system and potential vapor explosion hazards
- Create additional space for customer parking and allow property improvements that would have otherwise been inhibited
- Ability to use the money for the business that would have been otherwise spent to maintain the UST system that is in TOS
Start saving money and time wasted on maintaining TCEQ TOS requirements by contacting CRG Texas today to permanently remove your UST system from service.