Regulated Substances Storage Tank Management

Purpose:

To revise GSA’s policy for managing Fuel Storage Tanks and establish GSA’s policy for managing regulated substance storage tanks.

Background:

Federal, state, and local laws establish standards for the management of storage

tanks (aboveground [ASTs] or underground [USTs]) used or previously used to store regulated substances, including petroleum. Tanks used to store petroleum are hereafter referred to as fuel storage tanks (FSTs). Tanks used to store other regulated substances are referred to as hazardous substance storage tanks (HSTs). Collectively, these tanks are referred to as regulated substance tanks (RSTs).  Owners and operators must install, operate, and maintain all storage tanks that contain regulated substances in a manner that prevents or reduces the potential for release of their contents into the environment.  Various laws further mandate requirements for training, emergency planning, release reporting, and closure procedures.

Per 33 U.S.C. 1323 of the Clean Water Act (CWA), and 42 U.S.C. 6991f of the Resource Conservation and Recovery Act (RCRA), federal facilities must comply with Federal, state and local requirements.  In addition, consistent with the specific language in each statute, Federal agencies may be subject to civil penalties for non-compliance. Consult with the Office of the General Counsel to determine applicability.  States are the primary authority for implementing AST programs. They may also be granted the primary authority to implement the UST program within their boundaries.  The governing standards of authorized state programs must be no less stringent than Federal laws.  In states that have not been delegated authority, UST systems must comply with the Federal minimum standards.

One of the greatest risks associated with regulated substances storage is the potential for releases that can contaminate surface water, groundwater and soil. Releases can also pose other risks to the environment, human health and safety, as well as the potential for fire, explosions, property damage, and financial liability.

Applicability:

This order and the companion desk guide apply to Federally owned facilities under the jurisdiction, custody, and control of the GSA.  Limited aspects of this order apply to facilities operating under a GSA delegation of operation and maintenance authority and space leased by GSA, as dictated by the provisions of the delegation or lease.  This order is not applicable to RSTs associated with property reported excess for disposal through the PBS Office of Real Property Disposition.

This order applies to all GSA employees and contractors as they perform their duties. The following are exceptions:

1. The Office of Inspector General (OIG), given its independence under the Inspector General Reform Act of 2008 (5 U.S.C. §§ 401-424).
2. The Civilian Board of Contract Appeals, due to its independent authorities.

Cancellation:

This Order supersedes GSA Order PBS 1095.2, Fuel Storage Tank Management.

Summary of Changes:

1. Broadened the scope of the existing policy to include regulated substance storage tanks and changed the title of the Order to align with the expanded scope.
2. Established the National Computerized Maintenance Management System (NCMMS) as the mandatory repository of record for the PBS RST inventory.
3. Enhanced the roles and responsibilities discussion.
4. Defined the minimum attributes that must be included in the tank inventory.

Roles and Responsibilities:

1. Implementation of this policy is a shared responsibility among PBS offices who are responsible for incorporating applicable elements into operations, planning activities, management decisions, and policy development.  Assignment of roles may vary.
2. The following offices or teams have responsibility for executing the policy described in this Order: Office of Facilities Management (OFM), Office of Architecture and Engineering (OAE); Operations and Maintenance (O&M) Contractors; Office of Acquisitions Management (OAM); Portfolio Management (PT); Office of Leasing (PR); Office of the General Counsel (OGC); and PBS Leadership.
3. A list of the respective offices and responsibilities is found in Appendix A of this Policy.