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UST systems include tanks, piping, fittings and dispensers below and above grade; the source of a release isn’t always obvious when contamination is first discovered.

Are Compliant UST Sites Really Low Risk?
Passing Leak-Detection Tests Don't Always Tell the Whole Story

By Tony Rodriguez
A UST site can pass required tests, have current records, and still later discover a release.  That statement is not meant to diminish compliance testing.  Those requirements are the first line of defense.  It simply reflects an important distinction: a passing result means the system met the applicable test criteria at the time of testing and may be eligible for Trust Fund reimbursement; it does not prove petroleum has never escaped from the system or that soil and groundwater beneath the site are clean.  For convenience store owners, UST compliance has become part of routine operations.  Testing is performed, records are maintained, and inspections are completed.  But releases can still result from equipment failures, delivery incidents, intermittent problems, or older impacts that were not discovered when they occurred.
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Where Releases Actually Begin: Often, It Isn’t Obvious
Georgia EPD’s Federal Fiscal Year 2025 Public Record Report recorded 147 confirmed UST releases.  For 65 percent of those releases, the source was listed as unknown, and another 22 percent were categorized as “other.”  Smaller percentages were attributed to specific components such as tanks, dispensers, piping, submerged turbine pumps or delivery problems.  The practical lesson is not that one component is always the weak link; it is that the source may be difficult to identify when a release is first discovered.  That is why alarms, test results and unusual site conditions deserve attention even when the overall compliance record looks good.  A passing test is important, but it is not the same as proof that a release has never occurred.

When “Passing” Doesn’t Tell the Whole Story
Release-detection methods are designed to meet defined performance standards.  For example, federal requirements for pressurized piping call for an automatic line leak detector capable of detecting a leak of at least 3 gallons per hour at 10 psi within one hour, together with another approved monitoring method.  An annual line tightness test must be capable of detecting a leak of 0.1 gallon per hour at 1.5 times normal operating pressure.  Statistical Inventory Reconciliation (SIR) methods are evaluated against a 0.2 gallon-per-hour performance standard, or 150 gallons in a month, with specified probabilities of detection and false alarm.  Those numbers are performance standards, not evidence that small or intermittent product losses are impossible.  Leak-detection methods are designed to detect releases at defined performance levels, not to prove zero leakage.  A release may also result from a spill, overfill or past event that is outside the scope of a particular tank or line test.
​Georgia EPD also makes an important distinction between passing and non-passing results.  Current compliance guidance states that a failed tank or line tightness test is considered a suspected release and must be reported within 24 hours.  Failed monthly monitoring, and two consecutive inconclusive SIR results, also trigger suspected-release reporting requirements.  The point is not to second-guess a passing result; it is to understand exactly what that result does and does not establish.
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Free-phase product recovered from a monitoring well following a long-term, low-rate release that went undetected over time.
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Warning Signs Still Matter
Compliance testing is only one source of information about a UST system.  Recurring alarms, repeated inconclusive results, unexplained inventory trends, unexpected water in a tank, petroleum odors, staining around dispenser or fill areas, or product observed in a monitoring well or stormwater structure may all warrant additional attention.  Georgia EPD’s own compliance guidance reminds owners to review the test results provided by their tester rather than simply file them away.
 
The value of these observations is context.  An isolated stain does not prove a UST release, and an alarm does not automatically mean a tank or line is leaking.  But patterns matter.  When the same irregularity keeps occurring, the underlying cause should be understood rather than assumed to be harmless.

A Note About Voluntary Screening
Some owners may choose to obtain additional information about subsurface conditions even when no release has been confirmed.  Passive soil-gas sampling is one example of a relatively low-impact screening technique that can indicate whether petroleum vapors may be present beneath portions of a site.  Its purpose in that context is screening—not UST compliance testing, and not regulatory release confirmation.  Georgia EPD has specific procedures for investigating suspected and confirmed releases, and voluntary screening methods should not be considered as substitutes for those requirements.  Owners also should not assume that voluntary screening will be reimbursable through the GUST Trust Fund without prior EPD approval.  If voluntary screening identifies a potential concern, any follow-up used for regulatory decision-making should proceed under the applicable EPD requirements.

Final Thoughts
Passing leak-detection tests is good news, and maintaining compliance remains the foundation of responsible UST operation.  The caution is simply not to turn “pass” into “proof that nothing could be wrong.”  Understanding what each test measures, reviewing abnormal results, and paying attention to changing site conditions can help owners recognize when a closer look may be justified.  A compliant site can still experience a release.  Knowing that possibility exists is not a reason to distrust compliance testing; it is a reason to use the information those systems provide as effectively as possible.

Author Bio
Tony Rodriguez is a Principal Geologist with Triple Point Engineering.  His experience with UST closures, site investigations, and corrective action began in 1993.
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Georgia Association of Convenience Stores.  All Rights Reserved.
200 East Memorial Drive, #1   Dallas, GA 30132
Phone: (770) 736-9723 | [email protected] | sitemap
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