What happens if you inspect an AST

and find contamination?

Oil Tank Inspections

Aboveground Storage Tank (AST) Inspections

Let's agree the tank below looks in pretty good condition. But it is an old tank and a hole formed and as you can see oil leaked.  Cleanup is estimated at over $50,000.00.   

An inspection of this tank would have informed the owner that the tank needed to be replaced.  Why?   Well the tank is old also because the tank has crimped end (end is also called the head of the tank).    Crimped ends are weak welds and are susceptible to tank rupture, they are also usually an indicator that the tank may be from 1999 or prior, as this type of weld was no longer approved following a July 1999 update to the UL 80 Standard for Steel Tanks for Oil-Burner Fuels and Other Combustible Liquids.   So the tank is at least 24 years old more like 40 years old and can we agree if you had a 40 year old roof you would replace it?

Learn about AST Inspections at this link 

Heating Oil AST Inspections

What happens if you inspect a tank and find oil in the ground from the AST but nothing is visible?  

Unfortunately, the regulations don’t really address the type of situation t which is no obvious contamination, but you get an EPH (oil levels) detection in a screening sample.  We do AST inspections in PA, DE & NJ so to be brief let me go over New Jersey's approach.  New Jersey regulations specifically regs at 7:26F-3.4(a)3. This is how it reads

“For a discharge from a residential above ground heating oil tank system or a small, non-residential above ground heating oil tank system, collect post-excavation soil samples on the same day as the excavation of the contaminated soil, as follows:   So the regulations are presuming that you find oil levels above what is permissible and must do the following:

1. If the perimeter of the excavation is 30 feet or less, then collect at least one sample from the bottom of the excavation and one surface sidewall sample (zero to six inches below the ground surface) from the sidewall of the excavation, each of which shall be biased in the direction of water runoff over the ground surface; 

2. If the perimeter of the excavation is greater than 30 feet, then collect at least one additional surface sidewall sample for every 30 linear feet of perimeter, or fraction thereof, and one additional sample from the bottom of the excavation for every 100 square feet of bottom area, or fraction thereof; 

• For an excavation that is three feet in depth or greater, collect at least one additional sample from the bottom of each sidewall for every 30 linear feet of perimeter, or fraction thereof; and 

4. If the excavation extends to within two feet of either bedrock or ground water, then collect a ground water sample pursuant to N.J.A.C. 7:26F-4.2.”

Sound like a lot, well it is, so when an AST leaks you have to do what you have to do.

Now on the flipside all states have PERMISSABLE limits of oil, so when you inspect an AST and soil sampling is performed. Again, this would be an inspection where no obvious contamination is present (meaning no visible dripping oil, no staining of oil on the ground around the tank.) but you find oil levels in the soil sample and maybe those levels are within standard.  So you have one (1) sample and it shows oil so some leak, spill, discharge had to have occurred at some point in time.  You now have to go take additional soil samples?  Why, because you think hey the soil sample was pretty clean?   Well I agree but the flip side of the coin is that may be your best sample because again when you sampled everything looked clean.  So you are tasked with collecting additional soil samples to prove you have low levels, a minor release occurred at some point in time, you simple have to do further testing to prove that.  Think of the one semi clean samples as possible the tip of the iceberg.  

Our point being is that old heating oil AST's carry risk and should be inspected.

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