An Introduction to Leaking Underground Storage Tanks
Leaking underground storage tanks (USTs) are a significant source of environmental contamination and may
pose the following threats to human health and safety:
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- fire and explosion;
- inhalation of dangerous vapors;
- contamination of soil and groundwater;
- contamination of drinking water;
- contamination of streams, rivers, and lakes.
These threats are minimized when responsible parties respond quickly and efficiently after a tank release.
State agencies and environmental consultants are ready to assist UST owners and operators in responding
to leaking USTs.
Agencies that Deal with USTs and Leaking USTs
The Illinois Office of the State Fire Marshal (OSFM) regulates the daily operation and maintenance of
UST systems. If a release occurs, tank owners or operators, or their designated representatives, must
notify the Illinois Emergency Management Agency (IEMA), which then notifies the Illinois Environmental
Protection Agency (Illinois EPA). The Illinois EPA's Leaking Underground Storage Tank Section begins
oversight of remedial activities only after the tank release has been reported to the IEMA.
The OSFM is authorized to:
Certify tank installation and removal contractors. Monitor compliance regarding leak prevention and detection requirements. Issue permits for tank installations, repairs, upgrades, closures, and removals. Administer financial responsibility requirements. Determine whether tank owners and operators meet eligibility requirements and, if so, the appropriate
deductible amount for payment from the UST Fund. Order tank owners or operators to remove the USTs and perform initial abatement measures when UST
releases threaten human health or the environment.
The Illinois EPA is authorized to:
Review and evaluate technical plans and reports to determine if tank owners or operators are complying
with environmental laws and regulations governing leaking UST site investigations and cleanups. Require tank owners or operators to perform corrective action when UST releases threaten human health or
the environment. Review and evaluate tank owners' and operators' budgets and claims for payment from the UST Fund. Issue No Further Remediation (NFR) Letters to tank owners or operators once the Leaking UST Program
requirements and cleanup objectives have been met.
Act Immediately if You Suspect a Tank Release
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If a release has not been confirmed but you believe free product (petroleum not dissolved in water) or
product vapors pose a serious threat, take the following steps as appropriate:
Extinguish all smoking materials or open flames that could ignite explosive vapors. Call the local fire department. Take care not to activate electrical switches or equipment that could cause sparks and ignite explosive vapors. Evacuate the area. Follow the environmental regulations, as required of tank owners or operators or their designated
representatives, including:
Call IEMA immediately whenever a release causes a sheen on nearby surface waters, or Call IEMA within 24 hours of any other release, and Stop the leak and contain the spill.
The IEMA maintains a 24-hour hotline. In Illinois, call 800-782-7860. Out of state, call 217-782-7860.
Environmental Consultants Offer Technical Expertise
Environmental consultants, including removal contractors and professional engineers and professional
geologists, offer many services to help you handle your UST release in a timely and efficient manner.
You will find consultants listed in the Yellow Pages of your local phone book. The Illinois EPA does
not endorse or recommend consultants. Before signing a contract, make sure the consultant can perform
the following activities:
Determine the appropriate regulations to which a particular incident is subject, and conduct remediation
and/or pursue closure accordingly. Conduct a site investigation or classification to determine if remedial actions are required. Follow proper sample collection protocols to assure valid and reliable results. (Deviations may result
in additional sampling and expense.) Assure that laboratory samples are analyzed according to proper methods and procedures by an
accredited laboratory to avoid costly retesting. Interpret laboratory results and organize this data into reports for review by the Illinois EPA's
Leaking UST Section. Provide equipment and personnel to conduct the required remedial activities or hire subcontractors to
perform such work. Arrange for safe and proper handling of contaminated soil and groundwater. Evaluate cost and liability factors resulting from interim measures, as well as from final disposal or
treatment options, for contaminated soil and groundwater. Obtain all necessary manifests and permits before moving or disposing of contaminated materials. Prepare reports and provide certifications by Licensed Professional Engineers or Licensed Professional
Geologists as required by environmental laws and regulations. Prepare budgets and submit claims for payment from the UST Fund. An Illinois Licensed Professional
Engineer or Licensed Professional Geologist must certify that all regulatory requirements have been met
before any budgets or claims can be reviewed. The Illinois EPA will not authorize payment of ineligible
or unreasonable costs, costs from work that deviates from approved plans, or costs for site investigation
or corrective action activities that exceed the minimum requirements stated in the environmental laws and
regulations.
Tank Owner or Operator Requirements
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Owners or operators required to report leaking UST releases to the IEMA must also meet the requirements
of the Environmental Protection Act and 35 Illinois Administrative Code 731, 732, or 734. Once notified
of the release by the IEMA, the Leaking UST Section mails a letter requiring compliance with Leaking UST
Program regulations and the submittal of applicable
technical forms.
Tiered Approach to Corrective Action Objectives (TACO)
Based on Site Conditions and Exposure Risks
TACO is the Illinois EPA's method for developing cleanup objectives for contaminated soil and groundwater.
These cleanup objectives protect human health while taking into account site conditions and land use.
TACO offers tank owners and operators the following choices:
Exclusion of exposure routes (inhalation, soil ingestion, and groundwater ingestion), Use of area background concentrations as screening tools or remediation objectives, and Three tiers for selecting remediation objectives.
In Tier 1, the tank owner or operator compares site sample analytical results to baseline cleanup
objectives contained in "look-up" tables. Under Tier 2, a tank owner or operator considers data
previously gathered for Tier 1, the physical and chemical properties of the contaminants, the
site-specific soil and groundwater parameters, and the application of institutional controls and
engineered barriers. Tank owners and operators can use Tier 3 for sites where physical barriers limit
remediation, a full-scale risk assessment is performed, alternative mathematical modeling is applied, or
a common-sense solution is warranted.
After establishing cleanup objectives under TACO, a tank owner or operator may:
Reduce contaminant concentrations to meet the established objectives through active remediation (e.g.,
dig and haul or treatment in place), Restrict exposure to contaminated soil or groundwater or both by using engineered barriers or
institutional controls, Take no action, if contaminant concentrations present at the site do not exceed remediation objectives, or Use any combination of the options above.
An engineered barrier, such as asphalt paving, clean soil, or a permanent structure, controls migration
of and access to contamination. An institutional control imposes restrictions and conditions on land use.
For example, a tank owner or operator may choose to limit the site to industrial/commercial use. When
the property owner and the tank owner or operator are separate entities, the property owner must agree
to any type of land use limitation.
A leaking UST site qualifies to receive an NFR Letter once the tank owner or operator meets all Leaking
UST Program requirements and the applicable TACO cleanup objectives. Within 45 days, the tank owner or
operator must file the NFR Letter with the county recorder of the county in which the site is located to
ensure that current and future users of the property will be informed of any conditions such as
engineered barriers and institutional controls that were relied upon to address contamination caused by
an UST release.
Where to Direct Your UST and Leaking UST Questions
If you have questions concerning permits required for tank installations, upgrades or removals; leak
prevention or detection requirements; financial responsibility requirements; or eligibility and
deductible determinations for the UST Fund, contact:
Office of the State Fire Marshal
If you have questions concerning the review of budget plans and technical reports, or the status of
applications for payment from the UST Fund, contact:
Illinois Environmental Protection Agency
This publication is for general information only and is not intended to replace, interpret, or modify
laws, rules, or regulations.
Last Updated: May 2008
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