Tanks

Aboveground and underground storage tanks are often found in wellhead protection (WHP) areas. Leaks from storage tanks can result in contamination of city and private water supplies. The MPCA estimates that there are more than 50,000 above- and underground storage tanks in Minnesota. The MPCA regulates most underground and aboveground storage tanks, as discussed below. The general exception to MPCA regulation are agricultural chemical tanks (regulated by the Minnesota Department of Agriculture). 

Aboveground Tanks

Aboveground tanks are used for storing crude oil and petroleum products, chemicals, and food products such as molasses and vegetable oil.

For aboveground tanks, the MPCA regulates tanks of 110 gallons or more, except for compressed gas tanks, agricultural chemical tanks, and farm and residence tanks smaller than 1,100 gallons. All tanks regulated by the MPCA must be registered with the MPCA. In addition, regulated aboveground tanks greater than 1,100 gallons and all tanks within 500 feet of a surface water must have secondary containment to contain leaks and spills. Tanks not required to have secondary containment must have reasonable safeguards to prevent leaks or spills (sorbent material on site, concrete pad or other methods). 

Underground Tanks

Underground tanks most commonly store petroleum products and hazardous substances. Underground storage tanks (USTs) must meet certain requirements based on the type of product stored and the size of the UST. Petroleum and hazardous materials USTs are regulated as follows: 

Non-MPCA-regulated USTs: USTs which hold 110 gallons or less, hold 1,100 gallons or less of heating oil, and residential or farm USTs that hold 1,100 gallons or less containing motor fuel used for non-commercial purposes do not need to meet state or federal UST regulations. However, other requirements may apply.  

Heating-oil USTs which hold more than 1,100 gallons used to heat the premises must meet state UST requirements. State requirements are: tank registration; MPCA-notification of tank removal and installation; contractor certification for tank removal, installation and repair; and corrosion protection for new installations. 

All other petroleum and hazardous material USTs must meet both federal and state UST requirements. In addition to the state requirements listed above, federal requirements are: leak detection; corrosion protection; spill and overfill prevention; and sampling requirements during tank removal. Many of these requirements are dependent upon when the UST was installed. All state and federally-regulated USTs must have spill and overfill prevention and corrosion protection by 1998. USTs containing hazardous materials are required to have secondary containment (e.g., a double-walled tank or excavation liner).

In addition to the MPCA, the State Fire Marshal also regulates underground and aboveground tanks of 60 gallons or greater containing flammable materials. When working on tank issues, public water suppliers should work closely with their local fire marshals.

The following is a list and discussion of activities a public water supplier could choose to include in plans to manage above and underground tanks in a wellhead protection area. These activities are not required of public water suppliers, but provide a menu of choices -- the methods chosen will depend on the local situation. 

Education:

If a public water supplier chooses to focus on managing tanks in the wellhead protection area, education should be included as a component of the management plan. Messages to highlight in an educational program for underground and aboveground tank owners include:

· importance of preventing leaks from storage tanks in the wellhead protection area (making the
  connection between personal actions and the water supply)

· upgrading regulated tanks to prevent leaks, spills and overfills

· using a certified tank installer

· proper tank closure

· early detection of leaks to prevent ground water contamination

· reporting leaks and spills to the MPCA

Listed below are a variety of educational activities that public water suppliers can undertake. These can be used as stand-alone educational activities or paired with voluntary practices or regulatory activities to help manage tanks. To reach a large number of people, a variety of educational activities should be employed.

Educational activities recommended for managing septic systems include:

Workshops/Training: Public water suppliers can encourage regulated tank owners in wellhead protection areas to attend training workshops. The MPCA offers workshops around the state for tank owners, focusing on preventing and detecting leaks. Methods to use to encourage attendance include mailing or hand-delivering training schedules to tanks owners; providing a reduction in utility bills for attending training; providing scholarships for attending training; and establishing a city-sponsored recognition program for tank owners attending training. In addition, public water suppliers could work with the MPCA to sponsor a training session locally for tank owners in the area.  

Information packets: Public water suppliers can use information packets to educate tank owners on the importance of preventing leaks from tanks. Examples of print information are listed below for use in wellhead protection areas. The listings below include information for owners of regulated underground tanks, regulated aboveground tanks and unregulated underground and aboveground tanks. Appendix A contains comprehensive lists of fact sheets available from the MPCA.

Information packets can be distributed in a number of ways. For wellhead areas with a small number of tanks, personal visits may be the most effective. Direct mail and passive distribution methods such as making print information available at city halls, fire halls, libraries, community bulletin boards and special events can also be used. When distributing information to tank owners in the wellhead area, public water suppliers may want to use existing organized groups to assist in the task, such as lake associations, homeowners groups, or senior citizen groups.

Resources for tank owners:

For aboveground tanks: 

Aboveground Storage Tanks in Minnesota, MPCA 
AST General Requirements, MPCA 
AST Secondary Containment Guidance, MPCA 
AST Using Concrete for an Impermeable Seal, MPCA 
AST Tanks 1,100 Gallons and Less Capacity, MPCA 

For regulated underground tanks: 

Do Underground Storage Tank Requirements Apply to Your Petroleum Tank?, MPCA 
About Underground Heating Oil Tank Regulations in Minnesota, MPCA 
Planning Ahead for an Underground Storage Tank Installation, MPCA 
What Do You Have To Do?, MPCA 
Planning Ahead for Underground Storage Tank Removal, MPCA 
Guidance for Selecting a Certified Contractor, MPCA 
Facts about Record Keeping Requirements for Underground Storage Tanks, MPCA 

For unregulated tanks:

Spill Prevention for Homeowners, MPCA 
Self-Inspection Checklist for Basement and Backyard Aboveground Home Heating Oil Tanks, MPCA 
Self-Inspection Checklist for Home Heating Oil Underground Storage Tanks, MPCA 
Caring for Home-Use Petroleum Storage Tanks, MPCA 

For heating-oil delivery companies:

Prevention and Preparedness for Oil Delivery Companies, MPCA

Demonstration projects: Public water suppliers can work with a tank owner (with a properly installed and maintained tank) to host an "open house" to provide guidance to other tank owners. In undertaking this effort, it will be important to choose an appropriate tank owner, one whose tank(s) comply with state requirements. This same type of demonstration project could be hosted for owners of tanks below the state’s regulatory levels. Another type of demonstration project would be a tank installation or removal using a certified contractor and demonstrating proper procedures. At the demonstration project, public water suppliers can distribute print information on proper installation, maintenance and removal.

News media: Public water suppliers can provide information on preventing leaks and proper tank maintenance to tank owners in wellhead protection areas through local newspapers and radio. Working with local cable access to produce a video on preventing leaks is also a way to reach tank owners.

Newsletters: Articles in newsletters can be useful in educating tank owners about proper tank maintenance and regulations. A number of existing newsletters can be used to provide this information: newsletters from the Chamber of Commerce, Extension, Soil and Water Conservation Districts, lake associations, water planning newsletters, rural water systems, and even church bulletins. Public water suppliers may also consider developing a newsletter specifically for landowners in the WHP area, which could highlight a variety of issues including storage tanks.

Public water suppliers can also ensure that tank owners in the wellhead protection area are receiving Tank Monitor, the MPCA’s newsletter for regulated tank owners. Public water suppliers can request addition of tank owners to this mailing list by contacting the MPCA.

Displays: Public water suppliers can set up displays on their wellhead protection program. Displays can be used in conjunction with special events or workshops or used on a longer-term basis at city halls, shopping malls, supermarkets, libraries, community centers and other places frequented by community residents. Displays should be accompanied with print information on tanks and other contaminant sources for residents to pick up. 

Services:

In addition to education, public water suppliers can provide services to help manage underground and aboveground tanks. These services go beyond education but do not involve regulation. For tanks, services can include both technical and financial assistance.

Activities undertaken by public water suppliers to assist tanks owners with installation, proper maintenance, and proper removal of storage tanks fall into the technical assistance category. Also included here are monitoring activities that may be instituted to track changed practices and potential problems.

Farm*A*Syst and Home*A*Syst: Both the Farm*A*Syst and Home*A*Syst programs, available from Minnesota Extension, include chapters which help farmers and homeowners assess the risk of underground and aboveground fuel-storage tanks on their properties. Public water suppliers could use these existing programs to help owners of smaller, unregulated tanks reduce their risk of a release or spill from their tanks. Through personal visits, public water suppliers could work through these assessment programs with farmers and homeowners in the wellhead protection area. As an alternative, public water suppliers could offer workshops on conducting a farm or home assessment for interested farmers and homeowners.

Local Information/Referral Service: For regulated tank owners, public water suppliers can act as a local source of information and assistance for meeting regulatory requirements. To do this, public water suppliers could:

• Send reminder notices to owners of new tanks about tank regulations and the importance of early leak detection
   
• Provide registration forms to tank owners, assist them in completing and mailing to MPCA
   
• Provide lists of certified tank installation and removal contractors
   
• Verify that newly-installed regulated tanks meet state requirements
   
• Verify that registration information provided to MPCA is correct (compare data from MPCA data base to what the public water supplier knows about the tanks; notify the MPCA of discrepancies)

Tank maintenance assistance: Public water suppliers can provide assistance to regulated and unregulated tank owners in properly maintaining tanks and detecting leaks. Methods for doing this include:

• For regulated underground tanks, work with tank owners on methods to use to check for leaks and how to keep records. To do this, public water suppliers or designated staff will need to become knowledgeable about requirements for leak detection and record keeping; attendance at an MPCA training course will be useful. Also note that although public water suppliers may assist regulated tank owners with leak detection and record keeping, tank owners are ultimately responsible, under the law, for these activities.
   
• For aboveground storage tanks without secondary containment, arrange for a contractor to install containment structures at tanks in the wellhead area during a specified time period. Tank owners volunteering to participate could pay the cost of this service.
   
• For all aboveground storage tanks, take on monitoring of secondary containment structures for cracks and early detection of leaks. Notify tank owners of cracks and leaks and ensure that proper repair and cleanup occurs. As with the suggestion above, for regulated aboveground tanks, the ultimate responsibility for leak detection, repair and cleanup lies with the tank owner.
   
• For unregulated underground tanks, take on monitoring for leaks. Establish agreements with tank owners for access to the properties for monitoring on a periodic basis. If leaks are detected, work with tank owners to ensure that proper repair and cleanup occurs.

Monitoring: Monitoring can include a variety of tracking/evaluation activities. Public water suppliers could undertake any of these monitoring activities as part of a management strategy. In general, monitoring activities may require follow-up actions if monitoring indicates potential problems.

• Surveying tank owners in wellhead protection areas to determine information needs. Based on the results of the survey, public water suppliers could target educational efforts.
   
• Identifying new tanks installed in the wellhead protection area. Work with the local fire marshal or use other methods to identify new tanks and ensure that the tanks are installed to protect ground water. For regulated tanks, notify the MPCA of new tanks installed and ensure that tank owners have met the regulatory requirements.

Grants and Loans: Public water suppliers may choose to make grants or loans available for tank owners or act as an information/referral service to available grants and loans. Grants and loans are available for certain pollution prevention activities, including county Challenge grants and pollution prevention grants from the Office of Environmental Assistance. In some cases, public water suppliers may choose to establish their own grant and/or loan funds for wellhead protection activities.

Grants and loans can be used for a variety of tank-related activities:

• attending tank workshops
   
• secondary containment structures for all aboveground tanks
   
• upgrading all (regulated and unregulated) underground tanks to meet requirements of corrosion protection, leak detection and spill/overfill protection (regulated tanks are required to meet these requirements by the end of 1998)
   
• changing from underground tanks to aboveground tanks (work closely with the Fire Marshal on this)
   
• installation of concrete pads in tank-filling areas
   
• proper removal of inactive underground tanks

Regulation:

Regulation is another category of methods a public water supplier can employ to manage tanks in a wellhead protection area.

Currently, state and federal law already require certain standards for regulated tanks, as discussed on page 1. As indicated, the requirements designed to prevent leaks (corrosion protection, leak detection, spill/overfill prevention, and proper installation and removal) will apply to all regulated underground tanks by the end of 1998. To avoid duplication of effort and confusion to tank owners, public water suppliers may want to focus regulatory efforts on tanks that are not covered by state and federal regulations (heating oil tanks of less than 1,100 gallons for use on the premises and residential or farm not-for-resale motor fuel tanks of less than 1,100 gallons).

Below are listed some regulatory options which can be enacted in wellhead protection areas, depending on the local situation: 

Standards for unregulated tanks: Public water suppliers can work with the appropriate local unit of government to enact and enforce requirements for underground and aboveground tanks not regulated by the state. For the wellhead protection area, these requirements could include:

• Requiring use of certified contractors for installation and removal of unregulated underground tanks
   
• Requiring secondary containment for aboveground tanks below the state’s regulatory limits
   
• Require upgrade of existing unregulated tanks to include corrosion protection, leak detection and spill/overfill prevention
   
• Require newly-installed unregulated underground tanks to include corrosion protection, leak detection and spill/overfill prevention

Local registration of unregulated tanks: Public water suppliers can work with the appropriate local unit of government to explore requiring local registration of tanks below the state’s regulatory limits. In doing this, local governments should work closely with local fire marshals, as local fire marshals may already have a list of smaller tanks. Once local governments are aware of these smaller tanks in the wellhead area, they can work with the tank owners to ensure leaks do not occur, using educational methods, providing services or enacting other regulations. 

Leak detection and spill/overfill prevention for heating oil tanks greater than 1,100 gallons: These tanks are not required to have leak detection and spill/overfill prevention, although corrosion prevention is required. Public water suppliers could explore with the appropriate local unit of government requiring these tanks to have the added protection of leak detection and spill/overfill prevention in wellhead protection areas. 

Adopt state tank rules for regulated tanks in the wellhead protection area: In cases where a public water supplier wants to regulate tanks already regulated by the state, the preferable way to do this would be to work with the appropriate local government to adopt the state’s tank rules by local ordinance. By doing this, the local government could enforce the state’s rules locally, but not confuse tank owners and installers with differing requirements for tank installation, maintenance and removal. 

Secondary Containment for all underground tanks: To go beyond state requirements for tanks, public water suppliers could explore with the appropriate local unit of government requiring secondary containment for all underground tanks in the wellhead protection area (only required for hazardous substance tanks under state and federal rules). In considering this, public water suppliers should be aware that double-wall tanks (a common type of secondary containment) will almost double the cost of the tank installation. For example, the cost of installing four tanks and piping that meet state standards at an average-sized gas station is approximately $70,000; the same installation with double-wall tanks would cost about twice that amount. 

Prohibitive Zoning: Public water suppliers may want to explore with the appropriate local unit of government prohibiting underground tanks in wellhead protection areas. Public water suppliers should work closely with local fire marshals on this option. In certain situations, the fire marshal may prohibit aboveground tanks containing flammable materials.