A leaking underground storage tank (LUST) is a buried fuel tank that has released petroleum into the soil or groundwater, and Illinois had 5,544 open LUST incidents on the Illinois EPA’s list as of February 1, 2022. The problem is chronic, not acute. Most cases stay local to the tank pit, few reach drinking water, and the oldest open incident dates to January 21, 1984. A3 Environmental Consultants (A3E) reads that list every week. This guide covers how big the leaking underground storage tank problem is, who is responsible for it and why the open count is probably too high.
Diagram of a leaking underground storage tank with petroleum plume floating on the water table
What Is a Leaking Underground Storage Tank?
A leaking underground storage tank is a buried tank that holds petroleum, such as gasoline, diesel, fuel oil or used oil, and has released some of it into the ground. Once a release reaches groundwater it can travel sideways, sometimes toward the drinking water wells of nearby homes. That is why researchers study the health effects of leaking tanks and why the government has a direct interest in preventing and cleaning up releases.
How the Illinois LUST Program and Trust Fund Work
Illinois set up the LUST Trust Fund to pay for cleanup where leaking tanks have been found. It is funded by a charge on fuel and is administered by two agencies:
- Illinois Environmental Protection Agency (IEPA): runs the cleanup program and keeps the Leaking Underground Storage Tank database.
- Office of the State Fire Marshal (OSFM): responds to the fire and explosion risk from a leaking tank. The OSFM reports the release to the Illinois Emergency Management Agency (IEMA) and the IEPA and may issue a Red Tag. After that its role at the site is finished.
The US EPA also treats leaking tanks as a major concern, but it works through the state program. Our UST and LUST services page explains where A3E fits in.
How Big Is the Leaking Underground Storage Tank Problem in Illinois?
It depends on what you count. The answer is different for people, for nature and for the agencies.
For People
Actual cases of contaminated drinking water appear to be low. When a drinking water well is affected, several agencies get involved and the problem is addressed quickly. When a city connects a house to the public water supply, the state and county health departments can require residents to abandon their private wells.
For the Environment
If you count rivers, lakes, aquatic life and wetlands, the problem is bigger but not massive. Three things limit the damage:
- Geology: in many (but not all) parts of Illinois, tightly packed glacial clay lets liquid move through it poorly, so a petroleum release tends to stay near the tank cavity. Sand and fractured limestone exist in other places, and they are less forgiving.
- Chemistry: petroleum floats on water. Consultants call it a Light Non-Aqueous Phase Liquid (LNAPL), and the water table limits how far down it goes. Dry cleaning fluid is a Dense Non-Aqueous Phase Liquid (DNAPL), which sinks, so it keeps going down.
- Geography: tank operators sit where the people are, and people in cities usually drink from municipal wells rather than private ones.
For Politics
A leaking underground storage tank is a chronic problem, not an acute one. Chronic problems hurt all the time, so the tendency is to forget them. Few voters hear about LUST incidents, and the fuel charge that funds cleanup applies to every tank operator equally, so there is no loud constituency pushing for change.
For the Agencies
The IEPA has a whole division dedicated to LUST incidents, which tells you it is a real concern. Its data tells you how big the backlog is.
Illinois LUST Numbers: February 1, 2022
These figures come from A3E’s own queries against the IEPA database as of February 1, 2022:
- Total open LUST incidents, for any reason: 5,544 (oldest opened January 21, 1984)
- Open cases with free product (liquid petroleum on site, the worst of the worst): 51 (oldest April 18, 1986)
- Most open LUST incidents on the same property: 17
- Open incidents with no IEPA project manager assigned: 1,333 (oldest December 28, 1987)
- Open leaking gas tanks: 3,907
- Open leaking diesel tanks: 1,390
- Open leaking fuel oil: 302
- Open leaking jet fuel: 29
- Open leaking used oil: 470
- Open leaking other oil: 757
- Open leaking non-petroleum: 160
Open incidents from 1984 are still on the list, so cases clearly do not close on their own.
Why the Open LUST Count Is Probably Wrong
Take those numbers with a grain of salt. The IEPA database holds about 29,000 records and not one of them has a field that says “open” or “closed.” You have to infer it from the NFR, Pre-74, heating oil and non-LUST date fields, and when all of those are blank you assume the incident is open. That assumption is often wrong:
- The SRP route: tanks that weren’t part of a retail fuel operation aren’t eligible for the LUST Fund, so they get cleaned up through the Site Remediation Program (SRP). An NFR letter issued through the SRP doesn’t necessarily get reported back to the LUST database, so the record stays open. About 50 records have “SRP” typed into the project manager field as a workaround.
- Wrong responsible party: the Village of Wilmette was once tagged as the responsible party for a tank found in its right-of-way. The village said it wasn’t, the tank came out, and the incident is still open.
- Bad contact and location data: wrong addresses, wrong phone numbers, even the wrong county. If the IEPA can’t reach the responsible party or find the site, the case just gets older.
- Owners who are gone: responsible parties die, go bankrupt or sell, and sites get foreclosed or redeveloped with the incident still open on paper.
Until the IEPA decides which of these records will never close, the open LUST total is overstated. We cover the record problems in more detail in Illinois underground storage tank database errors.
LUST Program or SRP: Which Cleanup Route?
If the tank served a retail fuel operation, the LUST program and its trust fund may apply. If it did not, the Site Remediation Program is the usual route. Our comparison, SRP program or LUST program: which one is right for you, walks through the choice. For the tank itself, see leaking underground storage tank removal and closure.
A3E has worked through both routes. Read how we recovered $22,000 unpaid from the Illinois UST program, or see the Lake Villa School District UST remediation and Rand River Auto UST removal project profiles.
Project Example: Closing Out Missed LUST Reports in Central Illinois
Four tanks holding used oil, diesel and gasoline were removed from a large federal institutional campus in central Illinois. The State Fire Marshal then ruled that the used-oil tank had leaked, but the required Illinois EPA LUST reports had never been filed. A3E pulled the removal records together and filed the 20-day and 45-day / corrective-action-completion reports. The Illinois EPA issued a No Further Remediation letter in March 2023.
- Project: LUST reporting after tank removal (2022 to 2023)
- Location: federal institutional campus, central Illinois
- Outcome: No Further Remediation letter, March 2023
Frequently Asked Questions
What is a leaking underground storage tank?
It is a buried tank holding petroleum that has released product into the soil or groundwater. In Illinois the release is reported to the IEMA and the IEPA and tracked as a LUST incident.
How many leaking underground storage tanks are open in Illinois?
The IEPA database showed 5,544 open LUST incidents as of February 1, 2022. The database has no open or closed field, so the true number is probably lower.
Who pays to clean up a leaking underground storage tank in Illinois?
The LUST Trust Fund, funded by a fuel charge and administered by the IEPA and the OSFM, pays for cleanup at eligible sites. Tanks that were not part of a retail fuel operation are not eligible and are usually cleaned up through the Site Remediation Program.
Are leaking underground storage tanks a danger to drinking water?
They can be, because petroleum can travel through groundwater to nearby wells. Confirmed cases of contaminated drinking water appear to be low in Illinois, and agencies act quickly when one is found.
Talk to A3E About a Leaking Underground Storage Tank
If you own or are buying a property with a leaking underground storage tank, or you have an open LUST incident you think is wrong, A3E can help. Request a UST and LUST consultation or call (888) 405-1742.
Reviewed by Dave McCoy, P.G., Director of Operations, A3 Environmental Consultants.
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