Abandoning Commercial & Residential Underground or Above Ground Oil Storage Tanks (UST)
Oil Tank Abandonment Procedures & Regulations

How to abandon a buried oil tank in place - How to abandon or stop using an above-ground oil storage tank; Oil tank abandonment regulations; How to avoid cave-ins at abandoned buried oil tanks; How old heating oil is removed from abandoned oil tanks; How to use up the heating oil in an oil tank before abandoning or removing it.; Notify oil company when you remove or abandon an oil storage tank; Prevent delivery of unwanted oil through abandoned oil fill piping
OIL TANK ABANDONING PROCEDURE
Questions & Answers about abandoning oil storage tanks, converting to gas fuel, etc.
References

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How to abandon use of an oil storage tank, either a buried tank or an above-ground oil storage tank. This document explains how to properly "abandon" or close an underground petroleum storage tank (UST) in place, that is, without having to excavate and remove it. This procedure is permitted if tests show that the tank has not leaked, and it can save a significant amount of the cost of oil tank removal and site repair to fill in the hole left behind. We also discuss how to cease using an above ground oil storage tank (AST). And we explain how to use-up or remove heating oil from an oil tank before abandoning it.

ABANDONMENT REGULATIONS - Oil Tank Regulations: for Underground Oil Storage Tanks and Aboveground Tanks

Proper oil storage tank abandonment requires the use of good engineering practices, including consideration of the future condition of the tank. While the original of this article focused on commercial oil storage tanks, the concerns and steps should be examined by those abandoning residential oil tanks as well. Readers of this page should see The Oil Storage Tank Website.

Our photo (left) shows an oil storage tank that was improperly "abandoned" along a stream in Dutchess County New York. The tank, empty, floated up out of the ground when the stream flooded.

In Brief: oil storage tanks which have not leaked can be abandoned by removal or by filling in-place. Oil tank leaks must be reported to the proper authorities.

The US EPA has this succinct advice about abandoning oil tanks:

Notify the regulatory authority at least 30 days before you close your UST.
Determine if contamination from your UST (underground storage tank) is present in the surrounding environment. If there is contamination, you may have to take corrective action. For at least 3 years, keep a record of the actions you take to determine if contamination is present at the site (or you can mail this record to your regulatory authority).
Either remove the UST from the ground or leave it in the ground. In both cases, the tank must be emptied and cleaned by removing all liquids, dangerous vapor levels, and accumulated sludge. These potentially very hazardous actions need to be carried out carefully by trained professionals who follow standard safety practices. If you leave the UST in the ground, have it filled with a harmless, chemically inactive solid, like sand.

(The US EPA also provides more detailed oil storage tank abandonment guidelines for both temporary and permanent abandonment of oil tanks.)

Abandoning a leaky oil tank? In New York abandoning an oil storage tank includes contacting the NYS DEC within two hours of leak discovery. Oil leaks require special cleaning and testing.

Significant costs can be involved. Buyers of buildings with buried tanks should either obtain good documentation regarding tank abandonment (and any leak tests performed) or if no documentation is available, testing for leaks is very strongly advised. See OIL TANK LEAKS & SMELLS

In other U.S. states and Canadian provinces similar regulations apply in almost all jurisdictions.

Due to the corrosive properties of the soil environment, any steel tank left in the ground will eventually corrode and collapse. See OIL TANK FAILURE RATES and also see OIL TANK FAILURE CAUSES. For this reason, storage tanks which are no longer to be used must be properly "abandoned" or "discontinued."

Abandon an oil tank without removal: Abandonment of an oil tank does not itself require that a tank be removed. If a tank has not leaked, thus is there is not a soil contamination issued, it can be opened, cleaned, inspected, and filled in-place. Actual removal of a buried tank involves the additional expense of excavation to remove the tank and then having to fill-in the hole.

Home inspectors in states or provinces where oil-fired heating equipment is used may often find indications that an old tank has been "abandoned" at the property either because of a switch to an alternative fuel or because an old leaking tank was supplanted by a new one. Safety and environmental concerns mean that an improperly abandoned tank may become a significant future cost to the homeowner.

Portions of this article are from the first half of a New York DEC article printed in the NYSBOC Building Log newsletter in 1992. While most of the present tank regulations exclude the mere presence of residential heating oil storage tanks under 1100 gallons from having to be reported, inspectors should watch for changes: increasing public concern is leading to increased regulation of residential tanks. Original author - Russ Brauksieck. Extensive edits & additions: D J Friedman.

Many localities across the country are allowing underground petroleum tanks to be filled with water if the tank is to be closed in-place. This is not a good engineering practice because the water will accelerate the ultimate corrosion of the tank. Subsequently, the water, now contaminated by the residues in the tank, will escape to the soil and eventually contaminate the ground water.

Note: Long Island NY requires that residential heating oil tanks be registered with the State Department of Environmental Conservation. (C)Trap DJ Friedman

In addition, the tank, now empty, is likely to cave-in along with the ground around it. The need to require that good engineering practices be used in underground storage tanks has prompted the development of much legislation across the country. Abandoned buried storage tank cave-in prevention is discussed in the next section of this article.

Note: Regulations for proper closure of underground petroleum storage tanks in New York State [and almost certainly in other oil-using states as well] have been promulgated by the NYS Uniform Fire Prevention and Building Code (UFPBC), the U.S. EPA, the NYS Department of Environmental Conservation (DEC).

When the Oil Tank must be emptied: Also see NFPA 31, section 2-8 which provides "If a tank and its related piping is abandoned for whatever reason, the tank and all piping connected to it, including the outside fill and vent piping and any piping connected to the appliance, shall be emptied of all contents, cleaned, removed from the premises or property, and disposed of in accordance with all applicable local, state, and federal rules and regulations."

Other New York oil storage tank regulations include the following:

New York State Fire Code: 3404.2.13.1 (old NY CRR 1164.5) requires that an oil tank which is no longer going to be used (a discontinued oil storage tank) shall be opened, cleaned, and abandoned (filled in-place or removed) within ninety days of the day on which it is no longer used. Piping is also removed (Avoid accidental filling of empty abandoned tanks or leaks from pipes no longer connected to tanks!).
1164.5 of the UFPBC, in section 40
CFR part 280.7 of the federal Underground Storage Tank (UST) regulations
subdivision 6 NYCRR Part 613.9 (b) of the DEC's Petroleum Bulk Storage (PBS) regulations.
Other states using significant amounts of oil for residential heating may have similar regulations. See TANK REGULATIONS.

Regulations addressing reporting of oil tank leaks and oil tank abandonment of oil tanks written various state and federal authorities are discussed in more detail at OIL TANK REGULATIONS - "Buried Tank and Above Ground Oil Tank Leak Reporting & Tank Abandonment Regulations"

AVOIDING Oil Storage Tank CAVE-INs When Abandoning Oil Tanks

In order to avoid cave-ins, all of these regulations require that tanks either be removed or filled in-place with a solid, inert material, using good engineering practices.

Such fill material is also required to prevent the tank from surfacing after closure, should the ground water table rise, and to completely seal the tank and associated piping from future use as a tank system.

Acceptable solid, inert materials for closing a tank include sand, concrete slurry, and even some foams. When the tank eventually corrodes and collapses, this solid material inside the tank will keep the ground from caving in.

Removing old fuel from underground oil tanks

The UFPBC also requires that underground petroleum tanks to be closed in-place shall be made safe by removing flammable or combustible liquids from the tank and connecting lines; disconnecting the suction inlet, gauge and vent lines; and capping the remaining piping.

All storage tanks removed from their location must also have flammable or combustible liquids removed, have the same lines disconnected; have sections of connecting lines not to be used further removed, and have inlets, outlets, and any leaks capped or plugged. The basic procedures for meeting these requirements are defined in the State and federal regulatory programs.

In addition to requiring the same basic procedures as the State regulations, the federal UST regulations require that a site assessment be performed by the owner/operator when a tank is closed. (Heating oil tanks, and farm and residential tanks storing less than 1,100 gallons of motor fuel are exempt from these regulations.)

See INDOOR OIL TANK ABANDONMENT for some suggestions for using up heating oil or removing it from an oil tank to be abandoned.

For a detailed description of the steps required for proper tank abandonment or for more information on site assessments and permanent tank closure, contact your state department of environmental conservation. In New York inspectors can contact the author or the Bulk-Storage help-line 800-242-3451.

How to Use Up Heating Oil Before Removing or Replacing an Oil Tank

Oil to Gas Heat Conversion Advice - using up heating oil fuel

If you are going to convert to gas or another heating source but you first want to use up the heating oil in your oil storage tank, and provided that your oil fired heating equipment (oil fired boiler, furnace, or water heater) is good operating condition, you can choose to simply let the old, to-be-abandoned oil fired equipment keep running until you run out of oil ... almost. There are a few problems to watch out for:

If your oil tank piping lines come off of the top of the oil tank and are properly installed the lines won't pick up the sludge, water, and last few inches of oil in the tank, so you'll probably be fine just running your oil fired equipment until you run out of oil.

If your oil tank piping lines come off of the bottom of the oil tank and you run it out there is the risk of pulling sludge and crud into the oil filter, oil burner, and losing heat if those components clog. If the oil burner shuts off in that manner, it'll indeed be shut off firmly until it's repaired, so don't try this if you're still depending on the oil heat to keep working (say to avoid freezing).

Your gas heat or other new source of heating should be hooked up and ready to run. Thus you can run the oil heat until it runs out or fails on clogging without risking leaving the building with no heat source - risking frozen pipes, water damage, mold contamination, etc.

The heating service technicians will not want to remove old oil-fired heating equipment until it is completely cold. That's because they don't want to deal with hot water, burns, etc.

The old oil tank may still need to be pumped out if there's oil remaining in it - lest you get a messy leak and spill later.

Chimney safety warning on heating fuel conversion from oil to gas

If you are converting fuel from oil to gas and intend to continue to use the same chimney that vented your oil fired heating equipment be sure to have the chimney cleaned and inspected for safety. The draft characteristics of these fuels differ, so chimney repairs or changes could be needed for safety.

Be SURE that the tank filler and vent are totally removed lest you get an un-wanted oil delivery. Don't laugh, it happens.

Frequently Asked Questions (FAQs)

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Questions & answers or comments about abandoning oil storage tanks, converting to gas fuel, etc.

Question: who removes the old oil fill and vent piping on an oil-to-gas conversion?

When switching from oil heat to gas heat, who is responsible for removing the tank filler and vent? The oil company or the gas company? Or do I have to hire a additional contractor? I've heard stories about unwanted oil deliveries. They are heart breaking. - Laura

Reply: nobody wants to do the whole job - the "Peanut Butter theory of construction: just skim the cream of profit"

Laura just removing the oil tank filler and vent are simple plumbing disconnections that can be performed by a plumber or general contractor. I agree that removing the abandoned filler is critical.

It is too common that some (not all) contractors in all building trades "just do their job" and leave parts of it incomplete, pointing to you or other contractors to finish the job. I call this the "peanut butter" approach to business. "Just buy some stuff and smear it on the house and get paid" - you don't care if the actual problem is really solved or the need fulfilled, or the job is complete and functional.

At a recent building project in Dutchess County NY we hired the top, most expert, and most expensive chimney company in the Hudson Valley to install a new metal chimney for an oil fired heating boiler. For years I had recommended that company to our clients.

In my case their work was very disappointing: During installation we had to do our own framing and our own sealing of the new chimney base at the roof line. And the new chimney installation work was of poor quality: dented metal chimney sections, floppy inadequate support brackets that left the chimney wobbling side to side, a crushed leaky chimney cap, damaged roof drip edge, even a small puncture in the rubber roof where the workers dropped something.

And the chimney installation job was incomplete: the contractor left all of the old chimney and parts for us to remove separately at our own expense.The company "skimmed the cream" of profit from the job , got in and out fast, and didn't care about the success of the whole project. When I complained, my long time but disappointing friend Bill, the owner said "Dan we've always done it that way, in thousands of jobs. That's just the way we do it."

It appeared that the company felt we were just being picky. And indeed their contract spelled out quite clearly that they would not remove old components nor perform any framing. But what is often not made clear to the customer is that those tasks are absolutely necessary and that additional trouble and expense will be involved in their completion.

It's up to you the homeowner to ask about, and then discuss these details with the contractors ahead of time and be sure that all the needed tasks are done. Now after the fact you can try asking them to come back and do more work, but once paid, the contractor may be reluctant to return - for free. Don't pay for work that is unsatisfactory or incomplete. Or to have added out-of-contract-scope work performed, pay the contractor to return and do it. Or hire someone else.

I discussed the abandoned oil fill pipe question recently with a New York heating oil delivery truck driver as we recounted horror stories of oil deliveries into building basements.

The driver said if he finds a filler that has been duct-taped over he would not remove it to deliver oil. I said that I know of cases of less experienced drivers doing stunning things like removing plywood nailed over the filler pipe, turning an upside down filler right side up and pumping oil into the open basement of a home.

I claim the old oil fill and vent pipes should be removed promptly and that there is no major cost involved except in very odd cases. The risk is not worth wasting time arguing over.

You should also notify your oil company both by telephone and in writing that the oil tank has been removed and that they should remove you from automatic oil delivery immediately.

Question: oil tank abandoned long ago, missing paperwork: how do I obtain documentation & supporting testing

I have someone interested in buying my home. The oil tank on the property was abandoned properly years ago and signed off by the EPA…but this was done before records were kept on computers…the buyers just want verification that the tank was abandoned, not a soil test. I’m wondering how much this will cost me? And how this is done?

Reply:

First choice: contact the company who performed the original oil tank abandonment and any supporting inspections and testing and ask for a copy of their documentation.

By the way, I'd be careful to be very accurate in speaking to your buyer, in order to avoid any possible misunderstanding. Contrary to what you wrote, the U.S. EPA does not "sign off" on residential oil storage tank abandonments or removals nor on oil tank leak testing. Nor does your state DEP (Department of Environmental Protection) or DEC (Department of Environmental Conservation) "sign off" on oil tank abandonments.

In fact in many states residential oil tanks of smaller size, such as under 1100 gallons, are not registered with the state.

Generally, when an oil storage tank is removed or abandoned, the service company performing the work (and the property owner) are required in most U.S. states to notify their DEP or DEC if there is evidence that there has been an oil leak or spill. And the state will typically have guidelines on how an oil tank should be abandoned, such as a requirement to fill the tank.
For a heating oil tank that was abandoned (emptied, filled, left in place), it should be easy to locate the tank and perform a soil test at a depth chosen by the expert - usually at the depth of the tank bottom. If necessary, the top of the tank (that won't be deep) can be excavated and fittings opened to confirm that the tank was properly filled - avoiding a potentially dangerous future collapse at the site.
If the oil tank was actually removed years ago, once a buried oil tank is long gone, and if there is no documentation about its removal, a responsible home buyer might ask to perform a site inspection and soil testing. If evidence or concern justified further inspection for actual buried tanks, there are ground scanning radar and other methods that can be used to scan a property - a costly step that one would not ordinarily perform in the case you describe. DEP or DEC if there is evidence that there has been an oil leak or spill.
To contact a company who can perform a site inspection and soil testing you can use this link:

OIL TANK TESTING COs where we list companies offering soil and tank leak testing services - or just ask your heating oil company for a referral or check your local telephone directory.

Typically the oil tank testing company will inspect and perform one or more soil tests in the area and at the depth where the oil tank was previously located. And an astute inspector would notice the presence or absence of piping or tubing associated with buried oil tanks and that would not be expected to be present if a tank was removed, vs. abandoned in place.
But in my OPINION you should NOT have these tests performed yourself, since doing so puts you in a position of potential liability. Rather, if you agree to do so, just give the buyer an allowance and have them order and pay for the test directly - to avoid any appearance of conflict of interest.

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Technical Reviewers & References

Related Topics, found near the top of this page suggest articles closely related to this one.

Technical & Peer Reviewers for the original publication in the ASHI Technical Journal
- Stephen Gladstone, Stonehollow Inspections, CT.,
- Paul Ciminello, Ecosystems Strategies, Poughkeepsie, NY
- Daniel Friedman, ASHI Technical Journal Editor/Publisher, Poughkeepsie, NY
- Russ Brauksieck is an Environmental Engineer with the New York State Department of Environmental Conservation.
US EPA "How do you Properly Close a UST?" is summarized at epa.gov/OUST/fsprevnt.htm These details for temporary and permanent closing of underground oil storage tanks are provided by the US EPA as well.
"How do you choose the right tank testing method?", Cynthia Johnson, Fuel Oil & Oil Heat Magazine, November 1995
National Association of Oil Heat Service Managers, PO Box 380, Elmwood Park, NJ 07407
"Homeowners Guide to Fuel Storage," Agway Energy Products, Verbank, NY, November 1990

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