Policy Guidance

When discussing ASTs, consider and discuss the following risk factors:

  • contents of tank,
  • age of tank,
  • housekeeping,
  • staining (evidence of spills), and
  • is secondary containment present?

Keep in mind that staining beneath ASTs in paved areas is not as significant a concern as staining in unpaved areas. Also note that waste oil may be more of a concern than product oil due to its potential to contain heavy metals and VOCs.

Sample Write-Ups

  • Sample write up language One AST containing XXX and totaling approximately ### gallons in capacity was observed in association with the emergency generator located in the XXX portion of the property. According to /Ms. First Last Name, the subject property representative, the AST was installed in XXX. The AST is equipped with a steel secondary containment structure. No staining or spills were observed in the vicinity of the AST. Based on the presence of secondary containment and lack of staining or other evidence of a release, the presence of the AST is not expected to represent a significant environmental concern.
  • No secondary containment (Other Environmental Consideration) One 3,000-gallon AST stored on concrete was observed on site. According to /Ms. First Last Name, Operations Manager for the subject property for five years, the AST is used for the storage of gasoline. The AST was observed to be in good condition, but with no secondary containment measures in place. Mr./Ms. Last Name stated there have been no releases or problems with the AST. No stains, drains or damage to the concrete was observed in the vicinity of the AST. Based on the good condition of the equipment and the absence of staining or conduits to the subsurface, the presence of this AST is not expected to represent a significant environmental concern. However, as a best management practice, secondary containment should be provided for fuel ASTs.
  • Staining from nozzle and no secondary containment (Other Environmental Consideration) A 500-gallon AST used for the storage of diesel fuel was observed on the XXX portion of the subject property. The dispenser nozzle appeared to be stored on the side of the AST. Surficial staining was observed to the concrete beneath the nozzle, presumably from drainage of the nozzle following its use. No secondary containment was in place. Based on the amount and nature of staining, the diesel AST is not expected to represent a significant environmental concern; however, housekeeping should be improved to prevent further leakage of the diesel fuel from the nozzle. In addition, as a best management practice, secondary containment should be provided for fuel ASTs.
  • With secondary containment/minor staining One approximately 300-gallon waste oil AST was stored in a covered, concrete slab area located south of the fabrication building on site. The waste oil is reportedly picked up on a regular basis by a licensed waste hauler. Surficial staining was observed beneath the waste oil AST during AEI’s site reconnaissance. A concrete berm was observed around the waste oil storage area. In addition, no conduits to the subsurface were observed in the vicinity of the waste oil storage area. Based on the surficial nature of the staining observed, the lack of conduits to the subsurface, and the presence of a concrete berm around the area, the waste oil AST is not expected to represent a significant environmental concern.
  • With significant staining and on unpaved area = REC One approximately 300-gallon waste oil AST was stored in an unpaved area south of the subject property building. The waste oil is reportedly picked up on a regular basis by a licensed waste hauler. Surficial staining was observed underneath the waste oil AST during AEI’s site reconnaissance. According to /Ms. First Last Name, the AST has been present in this area of the property since year. Based on the presence of the staining, the length of time that the AST has been present on site, and the lack of paving or secondary containment beneath the AST, AEI is unable to rule out the potential that release to the subsurface may have occurred in this area.
  • Abandoned AST (possible Other Environmental Consideration) One abandoned propane AST was located adjacent to the railroad spur on the southern portion of the subject property. According to /Ms. First Last Name, the AST is no longer in service and is currently empty. Mr./Ms. Last Name is currently in the process of selling the AST for scrap metal. Therefore, the AST is not expected to represent an environmental concern; however, as a best management practice, the abandoned AST should be removed from the subject property.