To The Department of Environmental Protection
May 16, 1996

The Honorable James M. Seif, Chairman

Environmental Quality Board

Department of Environmental Protection

P.O. Box 2063

Harrisburg, PA 17105-2063

Dear Secretary Seif:

The members of the Agricultural Advisory Board to the Department
of Environmental Protection discussed the issue of removal of regulated
underground storage tanks at its February 21 and April 24 meetings.
The Board voted unanimously to recommend that the Chapter 245
Regulations be amended to allow the Department to place a one year
moratorium on the requirement that regulated underground storage tanks
only be removed by a certified installer.

The Board believes that this moratorium would permit the
agricultural community to remove underground storage tanks without
incurring excessive and unnecessary expenses. The Board also believes
that this moratorium will result in a greater number of underground
storage tanks being removed, thus reducing the potential for
groundwater pollution due to leaking and aging tanks. The one year
moratorium on the requirement to use only a certified installer for the
removal of underground storage tanks would entice more owners of
underground storage tanks to remove the tanks, rather than simply
abandoning the tanks to avoid the high costs of removal by a certified
installer. This moratorium would not relieve underground storage tank
owners of responsibilities regarding health and safety issues during
tank removal operations. Proper closure and removal procedures should
be followed by tank owners or their contractors, to include clean up of
the site and the proper disposal of any substances stored in the tanks.

As Karl Sheaffer, DEP, Chief of the Division of Storage Tanks,
stated at the Board's April 24 meeting, Pennsylvania's largest source
of groundwater pollution (and the Nation's) is from leaking underground
storage tanks. The Board strongly endorses the use of this moratorium
to provide the opportunity to allow for the removal of more underground
storage tanks, to reduce the number of these significant potential
pollution sources. The Board respectfully requests that you give this
recommendation your thoughtful consideration as you consider amendments
to the Chapter 245 Regulations, Storage Tank Certification final
rulemaking.

If I may be of further assistance please contact me at
717-561-7200.

Sincerely,

Robert Junk

Chairperson

Agricultural Advisory Board