Article XV: Tanks inspections (gasoline/fueling stations)

State: NY Type: Promising Practice Year: 2020

Located in Mineola, New York the Nassau County Department of Health (NCDOH) serves Nassau County on Long Island and its' population of approximately 1.36 million. The population is dense with over 4,700 constituents per square mile to a land area of approximately 284 square miles. A town such as Levittown, the first truly mass-produced suburb, has a land area of just 7 square miles but holds over 16,000 residential homes for its' population of approximately 51,000.

The county has over 470,000 housing units or residences. Many residences were constructed in the mid-1900s with steel underground fuel oil storage tanks (USTs) to heat the residence. Over time these tanks were found to corrode in the ground and leak, impacting the groundwater and surrounding environment. In 1986, Article XI of Nassau County Public Health Ordinance Article XI was adopted. It regulates the storage of toxic and hazardous materials, including petroleum, to protect the groundwater. It states, [New York State] designated best use of all groundwaters of Nassau County is as a source of drinking water. The federal government…officially designated Nassau County groundwaters as sole source aquifers for water supply.” This article included regulations for petroleum tanks with capacities over 1,100 gallons and was amended in 1990 to include requirements for the thousands of tanks (USTs and aboveground tanks or ASTs) with smaller capacities typically found at residences. These provisions provided homeowners with guidance for proper closure of these tanks, either through removal or closure in place, to prevent leaks from impacting groundwater. The NCDOH also started maintaining a registry of these tank closures, with over 87,000 recorded entries as of December 2019. In 2005, the original Small Heating Oil Tank Abandonment Program was awarded a NACCHO Model Practice.

The success of the program, and staff reductions due to retirements, necessitated program updates to improve efficiency. In 2017 and 2018, a respective 3,076 and 3,162 tank closures were completed, an average of 60 closures per week. Documentation was required from homeowners/contractors, and department staff would then review the documentation, and enter information before and after the tank closure job. Proper information on tank closure procedures was also tough for the public to access, adding to already large call volumes regarding closures.

The online small petroleum tank closure application was implemented in 2018 to remedy these issues. Department supervisors and an IT specialist designed and held trainings to familiarize staff with the program. The goals and objectives of the application are to streamline the tank closure process for the public and increase the efficiency of the departments' sanitarians. The public can now schedule and pay for jobs online and obtain tank closure completion certificates once inspected by the department. Information on proper closure procedures is readily available through an FAQ page. Staff fill out their inspection forms in the field electronically through use of iPads and move the tank closure information to a public database where the completion certificates can be accessed by the public. Staff spends less time processing paperwork, performing data entry, mailing tank closure documents and answering phone calls.

As intended, the online small petroleum tank closure application has streamlined the tank closure process for the public and increased efficiency for department staff. Of the 2,911 small tank closures so far in 2019, 838 were created by the public through the online application (28.8% of all to-date 2019 closure jobs). A count of public searches on the application maintained since September 2019 shows approximately 6,200 searches (primarily to look-up/obtain tank closure certificates) have been conducted through December 9th, 2019. For 2020, each inspector is estimated to save at a minimum 1 hour and 15 minutes per week. Clerical staff will also see significant time savings. 

All the online application goals have been met, as the tank closure process has been streamlined for the public and made staff more efficient. This is evidenced by the high amount of job creation/scheduling by the public and the time savings for staff through significantly reduced paperwork, data entry, mailings and phone responsibilities.

The significance for public health is that tank closures will continue yet allow inspectors more time to conduct important field work and inspections related to regulated toxic and hazardous materials, including petroleum. The public also has a direct hand in public health, as 48 of the 838 jobs scheduled by the public were assigned NYSDEC spill numbers. Removing old tanks significantly decreases the risk of the county's drinking water supply from becoming contaminated with petroleum.

The department's website is

Nassau County's groundwater is at risk for contamination due to the release of toxic and hazardous materials, including petroleum, into the environment. All the county's approximately 1.36 million constituents are impacted by problem of groundwater contamination, as both New York State and the federal government took measures designating the best use of the county's groundwater is to supply the drinking water. Since Article XI was amended in 1990 to include small tank closures, the Nassau County Department of Health registry has over 87,000 recorded closures to date. The addition of the online application system to the NCDOH's small petroleum tank closure program has improved the program to the benefit of the public (residents, contractors, realtors, etc.) and the department, key community stakeholders in public health, and allows both to directly address the threat of contamination to the county's groundwater/drinking water supply.

 The direct improvement to the department is increased efficiency of department staff. Inspectors can better use their time to perform critically important fieldwork such as physical verification of small tank closures and inspections of toxic and hazardous materials storage facilities, as opposed to time consuming and inefficient paperwork, data entry and phone duties. Each inspector is estimated to save at least 1 hour and 15 minutes per week as a result. Clerical staff will also save significant amounts of time.

The program is innovative because it gives key community stakeholders, such as county residents, a streamlined method to close potentially hazardous tanks and directly participate in public health. To date, nearly 30% of all completed closure jobs in 2019 were scheduled by the public – a total of 838 jobs. 48 of these 838 closure jobs were assigned spill numbers by the New York State Department of Environmental Conservation (NYSDEC), indicating that some amount of oil leaked from the tanks. Closure certificates for respective properties are obtained from the online small petroleum tank closure database, and nearly 6,200 searches have been conducted by the public since September 2019. This data illustrates public participation in a public health program, and success in job scheduling and certificate searches encourages further and future participation.

Along with improved efficiency of department staff, a goal of the online application was to streamline the tank closure process for the public, namely homeowners, contractors and prospective home buyers and sellers. The public is now able to look-up small tank closure completion certificates and schedule tank closure jobs, all through use of the internet.

Department supervisors worked with county IT specialists to determine the necessary components of, existing databases to merge into and final implementation of the program. Supervisors and IT personnel then held multiple trainings with staff, and supervisors did field training and practice inspections with individual staff. This included creating and accessing tank closure jobs and the use of iPads to conduct and complete field inspections of tank closures. This familiarized staff with the program ahead of finalization and making it accessible to the public. Upon implementation of the program, staff instructed public callers and walk-in tank closure jobs on how to schedule such jobs and obtain completion certificates. This provided stakeholders, the public, with knowledge of the new program and helped spread awareness of its' existence.

Supervisors welcomed in a reputable local contractor who has been performing small tank closures for years to familiarize him with and receive feedback on the online small petroleum tank closure application. Educating homeowners and contractors on the program fosters collaboration with community stakeholders, allowing them to actively participate in and assist their local health department with improving public health by continuing to properly close small oil tanks and protect the county's groundwater. This also improves the efficiency of department staff, as the public using the online application saves time staff spends processing paperwork, performing data entry, mailing tank closure documents and answering phone calls.

The department had a Master of Public Health student intern develop a Frequently Asked Questions” page online for the small tank closure program. The intern also collected, analyzed and graphically represented data newly accessible through the online program, such as the amount of residential closures by town over periods of time. She was able to complete this due to the successful merging of the existing small tank closure registry with the online application. Future interns and summer aides will be easily trained by department staff on the basic functions of the application and use of the iPads to complete field inspections.

The small petroleum tank closure program director, who worked with the county IT specialist to develop the online application, provided estimates of the program's costs and budget breakdown. Over the course of 4 years, she estimated that 15% of her time and 25% of the IT specialist's time were dedicated to the design, production and testing of the application. Those percentages extrapolated from their respective work hours and salaries was estimated to cost between $100,000 and $150,000 over the 4 years, or between $25,000 and $37,500 per year. For reference, the small tank closures program revenue for 2017 and 2018 were $251,360 and $259,560, respectively and through 12/24/19 the 2019 revenue was $278,700. These figures were taken directly from an online application page not available to the public and do not include significant additional program revenue sources, including those generated from regulated USTs and ASTs.

The objectives of the online application integrated into the small tank closures program have been met, as the application has streamlined the small tank closure process for the public and improved efficiency for department staff. The practice has been evaluated using both process and outcome evaluation measures.

The process evaluation measures used to evaluate the practice include supervisors holding staff trainings on the application and conducting practice and field inspections using iPads. Staff were familiarized with the program, using iPads and the electronic field inspection form. By the time the program was made available to the public, staff was adequately trained in the program and ready and able to assist and guide the public in navigating the application. A reputable small tank closure contractor was also invited to the department to receive training and provide his own feedback on the practice. These process evaluation measures have been a success, as shown by data collected on public use of the online application.

Much of the data used for outcome evaluation measures for the application came directly from the program itself. The program allows staff to sort by who created the job, whether it be an individual inspector or the public. The public job creation sort returned 838 results, and the total small tank closures listed under the completed sort gave 2,911 results. Dividing the public job creation results by the total completed closures (838/2,911) shows that 28.8% of all completed 2019 small tank closure jobs were created by the public. Of these 838 tank closures created by the public, a further sort showing only jobs with assigned NYSDEC spill numbers returned 48 results. As indicated by assignment of  DEC spill numbers, some amount of petroleum leaked from each of these 48 closed small petroleum tanks. A count of public searches available through the program maintained since September 2019 shows approximately 6,200 searches have been conducted through December 9th, 2019. These public tank closure job creation and search data evaluation outcome measures demonstrate a high volume of public use of the program, showing stakeholders having direct participation in public health and groundwater protection.

Time savings for department staff was another outcome evaluation for the online small petroleum tank closure practice. Using the 2017 and 2018 small tank closure data, each field inspector going forward is estimated to save about 1 hour and 15 minutes of time per week, at a minimum. Of the approximately 60 closures per week (approx. 3,100 closures on average in 2017 & 2018 divided by 52 weeks), an estimated 20 were handled by inspectors, with the remaining 40 being handled by department clerical staff. Data entry, mailings and calls averaged about 15 minutes per job, leaving inspectors with a minimum 300 minutes (15 minutes multiplied by 20 closures) of work per week handling these closures in 2017 and 2018. For both of those years, the department was operating mostly with 6 field inspectors and 2 secretaries. However, only 1 secretary and 4 field inspectors were on hand for fall/winter 2019 with no additional staff expected for 2020. For fall/winter 2019 and the 2020 year, the estimated 1 hour and 15 minutes of time savings comes from dividing the estimated 300 minutes of office work by the 4 inspectors who handle tanks (300 min./4 insp. = 75 min. per inspector, 75 min./60 min per hr = 1.25 hr or 1 hr 15 min). Substituting the 40 closures per week previously handled by clerical staff in for the 20 handled by inspectors, shows 10 hours per week clerical staff spent on processing small tank closures (40 tank closures x 15 min per closure = 600 min./60 min per hour = 10 hours). Clerical staff will not save the full 10 hours of time, however, the time spent on processing paperwork, performing data entry, mailing tank closure documents and answering phone calls will be significantly reduced. No modifications have been made to the practice as the result of the data findings, however, the department supervisors are able to contact and work with the county IT specialists to make changes if deemed necessary.

A lesson learned in relation to the practice is that technologies such as the internet and iPads can be used to protect public health, in this case Nassau County's groundwater that is the drinking water supply. Public health officials can use limited available resources to build on an existing or a create a program that protects public health, streamlines and encourages stakeholder participation and improves the efficiency of an entity.

Regarding partner collaboration, a lesson learned is that stakeholders in public health want to participate in protecting their environment and are encouraged and satisfied when that process, in this case small tank closures, is streamlined. The public, namely homeowners, contractors, home buyers and sellers, and realtors, has given a great deal of positive feedback regarding the online application to department supervisors and staff/field inspectors. This also helps to improve the perception of not just the Nassau County Department of Health's work but government work overall.

Based on estimates provided by the small petroleum tanks closure program director, the department supervisor who worked with IT specialists to develop the application, design, production and testing of the application cost between $100,000 and $150,000 over 4 years of development, or between $25,000 and $37,500 per year. Data taken from the application shows that the small tank closure program brought in $251,360, $259,560 and $278,700 in 2017, 2018 and 2019, respectively. These figures do not include significant revenues generated by regulated facilities that are also part of the large tanks program at the NCDOH. The costs of developing the practice are low compared to the revenue of the small tank closure and overall tanks program, the benefit of streamlined small tank closure process for the public (significant stakeholders in public health) and time savings by department staff that can now be used for additional field inspections to protect the county's groundwater.

Sufficient stakeholder commitment exists to sustain the practice. Many of the county's 470,000-plus residences were constructed with small underground fuel oil storage tanks, and over 87,000 small tank closure jobs have been recorded since the 1990 amendment of Nassau County Public Health Ordinance Article XI to provide regulations and guidance for petroleum tanks under 1,100 gallons. Of these 87,000 closures, data collected by the department's Master of Public Health student intern shows approximately 30,000 ASTs and 5,000 USTs were installed in place of the closed small tanks. Over 45,000 small tank closures were conversions to natural gas, with no new AST or UST installed. This data indicates that tens of thousands of small petroleum tanks, at a minimum, still exist with potential for removal in Nassau County. In addition to actually closing small tanks, completion certificates are being sought by home buyers and sellers, realtors, and contractors. These certificates (over 87,000 to date) are available, upon field inspection by the department, through the online small tank closure search feature. Actual closure of small tanks and lookup of small tank closure certificates by the public shows sufficient stakeholder commitment to sustain the practice and continue groundwater protection by stakeholders in Nassau County.

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