Did you know that the EPA estimates the average cost to clean up a spill or release from an underground storage tank (UST) system is $125,000? These high costs to clean up a spill or a release can cause significant anxiety and stress on any UST owner or operator.

To reduce the likelihood of a release or a spill, UST system owners and operators can take steps to analyze their risks by establishing a risk management plan (RMP). In doing so, owners and operators can identify and prepare for the risks most common to the UST industry generally as well as unique risks that are more site-specific to an owner and operator’s facility.

An RMP has three critical components—identifying risks, assessing strengths, and minimizing or eliminating risks.

Step 1: Identifying the risks

The first step to risk management pivots on identifying potential risks such as potential releases and spills. For an owner or operator, this step would include identifying any groundwater resources or surface water sources near the property. It also includes identifying fate and transport of regulated substances (e.g., if contaminants were released from the facility, what would happen to them?). Identifying specific geological factors can help understand where the substance would end up off-site.

Additionally, owners and operators should identify particular vulnerabilities specific to the UST’s location. These vulnerabilities would include catastrophic events (e.g., earthquakes and hurricanes) as well as the likelihood and frequency of extreme weather events and human error. A common risk to explore is whether or not there have been recent enforcement actions in the geographic area or to similar sized or similar substance containing UST systems.

Step 2: Assess strengths

The second step to establishing a business risk strategy is to assess the UST systems strengths. The following are simple examples of assessing UST system strengths:

• Are all the operators appropriately trained and knowledgeable of response procedures?
• Has the UST facility conducted a practice mock spill event to assess response strengths and weaknesses?
• Do the operators communicate with each other?
• Are the facility’s records organized and up to date?
• Is the equipment on-site updated?

Step 3: Minimize and eliminate risks

The final risk management step is aimed towards minimizing and eliminating the potential risks. The following examples can help a facility minimize and eliminate potential risks:

• Post signage throughout the facility on alarm locations and list emergency response numbers.
• Conduct monthly walk-through inspections on time (i.e., every 30 days) and remain consistent and thorough with inspection observations. Use a checklist to accurately record information.
• Conduct thorough operation and maintenance tests and record information accurately.

Identifying risks is an important aspect of tank ownership. Establishing a basic RMP  can help ease the stress of an uncertain or unpredictable spill or release from any UST system. In addition, an owner and operator will be fully prepared in the event a spill or release does occur.