GAPS Guidelines GAP.16.5.

A Publication of Global Asset Protection Services LLC

LEAKING UNDERGROUND STORAGE TANKS

INTRODUCTION
Studies show the three major causes of underground storage system release incidents are corrosion,
improper installation, and piping failure.
This section discusses an effective on-site tank management program that will reduce the risk of an
undetected leaking tank incident.

POSITION
Managing underground storage tanks (UST) can best be handled through an organized, documented
program. The program complexity depends on the number of tanks a facility owns or operates, the
site conditions and the products stored or handled.
Consider the following when developing a program:
• Establish an inventory of existing tanks.
• Establish a computerized information management program that sorts tank characteristics.
• Collect information including installation drawings or sketches showing:

° tank location.

° capacity.

° age.

° construction.

° connected piping location and length.

° soil type and conditions including porosity, permeability and depth of water table.

° corrosion protection.

° fluid stored.

° inventory control technique.

° testing or leak detection.

° maintenance records.
• Evaluate tank characteristics including age, construction material, design, and soil conditions. Age
alone is a criteria for underground storage tanks that need immediate leakage testing. Uncoated
steel tanks may need to be tested immediately because of their construction. Single wall steel
tanks with cathodic protection may need immediate testing if their protection systems have not

100 Constitution Plaza, Hartford, Connecticut 06103 Copyright 2015, Global Asset Protection Services LLC

Global Asset Protection Services LLC and its affiliated organizations provide loss prevention surveys and other risk management, business continuity and facility asset
management services. Unless otherwise stated in writing, our personnel, publications, services, and surveys do not address life safety or third party liability issues. The
provision of any service is not meant to imply that every possible hazard has been identified at a facility or that no other hazards exist. Global Asset Protection Services LLC
and its affiliated organizations do not assume, and shall have no liability for the control, correction, continuation or modification of any existing conditions or operations. We
specifically disclaim any warranty or representation that compliance with any advice or recommendation in any document or other communication will make a facility or
operation safe or healthful, or put it in compliance with any law, rule or regulation. If there are any questions concerning any recommendations, or if you have alternative
solutions, please contact us.
 GAP.16.5.2

been monitored and maintained. Coated steel tanks may leak where the protective coating was
scraped or damaged. Internal testing for tank tightness is needed for existing tanks. Geotechnical
conditions of the soil and a high water table at the site may signal the need for immediate testing.
• Recordkeeping also includes maintaining a record of detection system performance; recording
results of sampling, testing or monitoring; and documenting calibration, maintenance and repair of
the equipment.
• Prior to the installation of a new tank, sample the site to establish “clean site” background data. A
“clean site” has a level of contamination that the U.S. Environmental Protection Agency (EPA), in
the Code of Federal Register ( 40 CFR Parts 280 and 281 Underground Storage Tanks) regards
as environmentally safe. An existing storage tank location may require a more thorough
investigation to establish background levels and variations in, around and below the storage tank
site.
• Design, construct and install underground storage tank systems in accordance with current codes,
standards and practices. The EPA specifies applicable codes and standards of organizations such
as the National Association of Corrosion Engineers (NACE), American National Standards Institute
(ANSI), American Petroleum Institute (API), Petroleum Equipment Institute (PEI), ASTM
International (ASTM), National Fire Protection Association (NFPA), and Underwriters Laboratories
(UL). The EPA also recognizes guidelines established by some of these organizations for
operating, maintaining, and repairing tank storage systems and reconciling inventories. Be
prepared to meet these guidelines and those of the manufacturers. (See GAP.16.5.2.A.)
• Provide cathodic protection for all steel underground storage systems. In corrosion-resistant
construction, such as glass-fiber-reinforced plastic, the piping and fittings, if made of steel, must
have cathodic protection. Keep records of the protection system operation, inspection, service and
maintenance where corrosion protection systems are provided.
• Provide secondary containment. Newer design double wall steel tanks and double wall piping are
“packaged” containment systems, but cathodic protection is still required. Inspection and
monitoring the secondary containment space is simplified in double wall tanks. An access port is
usually provided to the void space. Installing an impervious liner, such as geotextile fabric, in the
tank excavation or the multiple buried tank zone is also a workable method of containing potential
leaks. Tank hole liners of this type must be protected from puncture. Observation wells for
monitoring and sump pumps for recovery can be conveniently installed.
• Control spills and overfills by using proper procedures and providing at least one spill or overfill
prevention device.
• Use two or more methods to detect leaks. Leaks can be detected efficiently, and the EPA will more
readily accept the results if two or more methods are used. No single test can provide a final
answer. A release detection system must also be provided for the underground piping connected
to each tank being regulated.
• Take corrective action for releases from underground storage systems containing petroleum
products. Consider the potential fire and explosion hazard at the site. Be especially aware of vapor
collection points in the release zone. Excavation trenches and pockets or spaces under the
pavement may allow vapors to collect into flammable or explosive concentrations.

DISCUSSION
Corrosion
Galvanic corrosion is the leading cause of leaks from bare steel underground tanks. Because a great
number of existing underground tanks are constructed of unprotected steel, galvanic corrosion is
believed to be the main cause of underground releases.
Soil composition and dielectric properties, groundwater and moisture content, stray current flow,
debris content of earth fill and other local environment features may affect the corrosion rate.

GAPS Guidelines
2 A Publication of Global Asset Protection Services LLC
 GAP.16.5.2

Corrosion is generally a gradual process, and it can occur over an entire surface or be localized.
When localized, as may be the case with a scraped protective coating, corrosion may proceed more
quickly. Leakage from an underground storage system due to galvanic corrosion can occur within 2 to
3 years after the system has been installed.
Oxidation corrosion or “rusting” is not a serious cause of leakage. There have not been many reports
of internal rusting due to water in the tank and tank gage stick puncture. Although tanks constructed
entirely of noncorrosive material, such as fiberglass reinforced plastic (FRP), do not potentially
corrode, connected piping may become corroded.
Causes of Improper Installation and Piping Failure
Burying a tank requires more than digging a hole and installing a tank in the ground. Competent
craftsmen are needed for excavation, tank handling, anchoring, connecting pipe, valves, fittings,
cathodic protection, monitoring system and backfilling. Leaks in piping, for example, are more often
caused by improper installation and poor workmanship than by pipe failure. A successful installation
must be properly designed, planned and supervised. The process of installation must also be able to
adjust to changing conditions.
Tanks should not be dropped, rolled or dragged. If the protective coating is damaged in handling, it
must be repaired before the tank is buried. The excavation must be free of debris, stones and objects
that can puncture the tank or protective coating. The pit needs to be of proper size, shape and design
to support the tank ends and walls, and the pit must be backfilled properly.
Errors of installation include inadequate or improper:
• pit design.
• depth and cover of tank and piping.
• anchoring.
• tank bed preparation.
• handling of tank.
• backfill material or compaction.
• installation of attachments, fitting and piping.
Federal Regulations
Federal regulations establish standards and techniques for cleaning up a release of liquid from any
part of the underground storage system. The intent of the laws is to eliminate releases considered
hazardous to health and harmful to our water resources. Existing and new UST installations are
expected to be in compliance. The regulations contain rulings for:
• tank integrity.
• leak detection and monitoring systems.
• tightness testing.
• secondary containment.
• compatibility of content with tank construction material.
• tank system corrosion resistance.
• maintenance.
Advance Environmental Assessment
When a leak or release is suspected, it is valuable to have a history of previous site conditions and
soil characteristics. Features of the soil, such as soil profile, composition, porosity and permeability,
and depth to the watertable, are basic geotechnical criteria that should be evaluated. The excavation
site for installing the tanks and laying out the pipes also should be identified. The porosity,
permeability and composition of the area soils and backfill material and, if provided, the presence of
an impermeable liner should be recorded.

GAPS Guidelines
3 A Publication of Global Asset Protection Services LLC
 GAP.16.5.2

When soil is analyzed, soil features are observed in a test sample and recorded. If a contaminating
substance is found, it is important to quantify it for two reasons. First, if a suspected contaminant
release occurs in the future, the contaminant can be compared to the established background
quantity. Second, if a deleterious substance is detected in the future and no form of that substance
has ever been stored at the site, other release sources should be sought.
As part of this analysis, the presence of nearby sewers, conduits, walls or other unusual obstacles or
pathways which could influence liquid or vapor movement should also be recorded as a site
condition. Neighboring installations can become sources of product or vapor contamination. This too
is an important consideration.
In the event of a release, gather data on the estimated quantity of the release; sample and analyze
surface and subsurface soils, ground water and surface water. These evaluations are critical; whether
the substance released is a petroleum product or a hazardous substance. Compare the results with
background data to determine how much cleanup will be necessary. Cleanup includes removing
contamination absorbed by soils or dissolved in ground and surface water; it also includes removing
vapors found in the soil gas, and free liquid found in the soils or on the surface of water. Use
creditable sources to assist in site investigation and cleanup activities.
Tightness Testing
Tightness testing is used periodically to meet requirements of the regulations, if this testing is
combined with another release detection test. Although no specific technique for tightness testing is
approved, nor is an approval intended by EPA, the best way to get reliable tests is to use a method
with established written procedures and trained and experienced crews. Connected piping of the tank
installation should also be tested.
Leak Detection
Most methods for detecting external leaks involve testing the soils and groundwater in and around the
tank excavation. No matter which method is used, the area around all components of the storage
system must be scrutinized. Present technology does not identify any one method as infallible, so
combined testing is encouraged. Monitoring the soil between the underground storage tank system
and a secondary impervious barrier is the preferred method. The space between the walls of double
wall tanks also needs to be monitored.
Requirements for leak detection must be met by methods found acceptable to the regulating agency.
Among these methods, testing for vapors in the soil gas, sampling for contaminants in the soil or
ground water, using a monitoring well, and making inventory reconciliation are all used. The selection
of a monitoring system must take into account the environmental setting as well as the product
characteristics.
An observer can readily see surface spill and overfill releases by observing the site and equipment.
These releases are limited in volume and are immediately obvious. They are frequently caused by
human error and often occur when the material is dispensed from the delivery truck to the storage
tank. Although a single spill may be insignificant, repeated occurrences eventually cause
contamination. A spill can occur at the fill pipe when the couplings of the discharge hose are
disconnected. A spill from overfilling can occur at the fill pipe or at the vent pipe opening. Proper
operational procedures, maintenance and good housekeeping can prevent releases of this type. An
operational requirement by EPA is the use of release prevention devices, such as automatic control
interlock.

GAPS Guidelines
4 A Publication of Global Asset Protection Services LLC