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Some underground storage tank (UST) owners or operators mistakenly think they can avoid environmental and safety requirements by changing to aboveground storage tanks (ASTs). However, ASTs are subject to both Federal regulations and State/local regulations. Before choosing an AST option, UST owners and operators should keep the following in mind:

• Replacing an existing UST with an AST still requires closing the existing UST properly— proper closure includes notifying your regulatory authority at least 30 days before you close your UST, conducting any necessary site assessment and remedial action, having the tank emptied and cleaned safely, and either removing the tank or leaving it buried but filled with an inactive solid, such as sand.

  Most ASTs need to meet U.S. EPA’s Spill, Prevention, Control, and Countermeasure (SPCC) requirements (40 CFR, Part 112). SPCC applies to facilities with a single AST with a storage capacity greater than 660 gallons, or multiple tanks with a combined capacity greater than 1,320 gallons. SPCC requires procedural and contingency plans, as well as various technical requirements, such as corrosion protection. For more information on SPCC requirements call EPA’s Hotline at 800-424-9346, or contact EPA’s Hugo Fleischman by telephone at 703-603-8769 or by email at fleischman.hugo@epa.gov.

  ASTs can increase the risk of fire and hazards resulting from damage caused by vehicles or vandals. AST owners should install AST systems that have adequate safeguards against fire, overfills, and damage.

  At a minimum, most ASTs need to meet state and local fire codes, which usually have some mix of construction, installation, operation and maintenance requirements that are intended to prevent fires and other hazards that can come from mismanaged or substandard ASTs. For more information, check with your local authority having jurisdiction, such as your local fire marshal.

• Some ASTs may need to meet additional state or local regulatory requirements that safeguard human health and the environment from potential threats posed by ASTs. You should check with your state agency in charge of oil pollution control activities for information on state and local requirements

Copyright @August,2004 Prepared by Transportation Environmental Resource Center (TERC)