About once a week we have someone reach out to us regarding reopening a former fueling site. They are considering buying an old store, or have inherited it, or acquired it under whatever circumstances. We have, over the years, worked with many customers to help them see their vision come true – in many cases. In other cases, not so much. What do the successes all have in common? That previously existing underground tanks and piping had been correctly removed at some point previous and that any necessary environmental remediation has taken place. These people take an old store, perhaps a community landmark, and bring that convenience back to the neighborhood.
But what about the unsuccessful sites, the projects that we look at and yet they are never built? What then? The common denominator is the existence of old underground storage tanks. Make no mistake, the existence of underground storage tanks on a property is a liability, not an asset. In worst case scenarios, the cost of dealing with the tanks far exceeds the value of the property.
Beginning with a law that went into effect in December 1988, some 35 years ago, all underground storage tanks must be registered with an authority designated by the state where they are located and meet certain requirements Owners had ten years to bring existing tanks up to a series of standards or replace or remove them. There was a scramble to
meet that requirement, but in the early months of 1999, the end of the first round of upgrades were complete. Tanks had to have some sort of corrosion protection, be equipped with spill containment and overfill prevention equipment and be subject to some sort of leak detection compliance. Individual states often had additional requirements.

 

CORROSION PROTECTION
In the 1988 requirements, tanks that were bare steel could be upgraded by way of the installation of a cathodic protection system, by interior lining, or a combination of the two methods which offered some additional benefits. Many tanks installed in the 1970s and 1980s were STIp3 tanks, meaning they were manufactured with a corrosion resistant coating and equipped with a simple sacrificial anode. The anodes were designed to last ten to thirty years.
Monthly and annual testing standards were established.

What we see today are the following scenarios:
STIp3 tanks that either have incomplete testing records, have failed anodes, or tanks with impressed current systems that either have incomplete testing records or are known to have had their impressed current turned off for an extended period of time, i.e. the store was closed and the power was turned off. In either of these circumstances, either no records available or a known absence of power to operate the impressed current system,
state environmental regulator can, and in most states do, make you replace those tanks. If you are considering buying a store, make sure you have all the records of every corrosion protection test, both the 60 day and annual tests and can demonstrate continuous protection. If valid records indicating continuous corrosion protection are not available, do not consider buying a property until the owner removes the tanks (and related piping) and receives a “no further action” notice from regulatory authorities. Don’t buy someone else’s problems.

SPILL and OVERFILL PROTECTION
Simple enough, right? Not so fast. First off, 3” sized fills were commonly installed into the 1990s. Overfill was accomplished either by ball float valves or by the 3” overfill valves that were available back then. Since that time, however, 3” overfill valves have been discontinued (almost 20 years ago) and ball floats have been outlawed. So in a situation where either exists, you are going to end up digging down to the top of the tank to make the necessary modifications. Ball float valves often cannot be removed through their extractors in the manner they were designed. Components have seized and the force to remove them will often damage the tank. In the event the ball float can be removed, if the tank has 3” fill risers you still have to dig it out and install 4” piping in order to accommodate a modern overfill valve. With two tanks for example, eliminating ball float valves and 3” fills can easily turn into a $20,000.00 ordeal.

LEAK DETECTION COMPLIANCE
Records, records, records. With leak detection, you are guilty until you prove yourself innocent. Make sure you get copies of whatever testing records exist. Usually you only have to show the most recent test (annual on some tanks and all pressurized lines and leak detectors, various newer test results on sumps, spill basins, etc., and 60 day and three year cathodic protection), but in the event of a problem you can be required to show a series of test results to demonstrate continuous compliance. We highly recommend one of the various state “UST operator certification training” courses sponsored by each state. You will have to pass the course to operate the tank system and taking the class ahead of time will make you more familiar with the requirements and therefore the documents you will need.

IF YOU ARE STILL MOVING FORWARD
Most older stations were equipped with conventional single cabinet pumps. A piece of pipe corresponds to a tank and is located to lead to a single pump. If you are thinking about installing modern MPD pumps, the underground piping will not allow this type of dispenser, the pipes are too far apart. And any site that is re-piped will have to be built to all modern standards. A typical old two-pump position country store could easily require $50,000.00 to $100,000.00 worth of modification to accommodate MPD installation.

USED MPDs – USUALLY NOT WORTH HAULING OFF
You’ve found a couple of used MPDs that you can buy cheap, your station is piped in a manner that will allow them to be installed. Now you can finally take credit cards at the pump. What could go wrong? Several years ago the card payment industry imitated standards to enhance security by requiring card acceptance devices to take the more secure EMV style chip embedded cards. EMV (European Mastercard and Visa) developed this technology
so as to better prevent fraudulent card manufacture. If you do not install EMV approved card equipment, liability for any misuse falls back on the owner of outdated equipment. Yes, you can continue to use non-EMV equipment for the time being, but the liability for any security breech comes back to you. However, what they don’t say is that no non-EMV equipment can be installed new at this point. You can’t take a non-EMV dispenser and add it to a newly established location and have it added to most networks. So how much does it cost to add EMV readers to a dispenser? In the $7,500.00 range per dispenser. Popular older units, G&B Advantages, Tokheim, Wayne Vista units often cannot be upgraded. Those free dispensers are not much of a bargain if you can’t use them…

IN GENERAL
There are no shortcuts. Petroleum marketing is one of the largest industries in this country and it is dominated today not by oil companies, as it has been historically, but by an industry we call “Big C-Store.” These companies, with huge budgets and tax incentives to continually modernize are the companies that help write these laws and regulations. The program may not have been designed to keep small time competition out, but that is certainly the
effect. We’ve worked on more small stores that most equipment dealers. We think they are important. But the reality is that only one in about twenty we look at is financially viable. We will be glad to look at your site and situation and offer up our observations, just be sure to call us BEFORE you make the purchase. Don’t get stuck with someone else’s problems.


IN CLOSING
Always check with your state authorities for specifics of their programs. This has been written in a general point of view. Each state, however, has different means of compliance, different levels of enforcement and correction and will have the latest data on requirements. Also if you are considering buying an existing site, check state registration records to find out what it shows about a site. These records are notoriously incorrect and may cause problems if you
do not have clear documentation.