Draft ADEM Guidance Proposed Additions to the Alabama UST Regulations

Transcription

1 Draft ADEM Guidance Prpsed Additins t the Alabama UST Regulatins Yu may have heard abut upcming changes t the undergrund strage tank regulatins (UST regulatins). On Octber 13, 2015 EPA finalized the first significant changes t the federal UST regulatins since All states will have t update their UST regulatins t be n less prtective than EPA s regulatins. EPA requires states t implement tw f these changes immediately when a state s regulatins are final (the requirement t demnstrate UST cmpnents are cmpatible w/ certain bifuels and the prhibiting f ball flat valves frm being used in new installatins r replacements), and is allwing states t delay implementatin f the ther changes until Octber 13, Alabama s UST regulatins are expected t be final later in Alabama s prpsed regulatins will be equivalent t the EPA requirements. Alabama has already made many f the required changes t its regulatins as required earlier by the Energy Plicy Act f These include secndary cntainment fr newly installed UST systems, spill basin testing, delivery prhibitin, and peratr training. There will be nly very minr changes relative t these existing rules. The mst significant prpsed additins t the Alabama regulatins are utlined belw. If yu have any questins abut these prpsed regulatins, r any ther questins abut the prpsed revisins t the regulatins please cntact us at

2 Walkthrugh Inspectins By Octber 13, 2018, wners and peratrs must cnduct walkthrugh inspectins at their UST facility. The walkthrugh inspectin must meet the fllwing: Mnthly Walkthrugh Inspectins Every 30 days, check yur spill preventin equipment and release detectin equipment. When cnducting the mnthly walkthrugh inspectin, check the fllwing: Spill preventin equipment Check fr damage. Remve any liquid r debris. Check fr and remve any bstructins in the fill pipe. Check the fill cap t make sure it is securely n the fill pipe. If yu have duble walled spill preventin equipment with interstitial mnitring check fr a leak in the interstitial space. Nte if yu have duble walled spill preventin equipment and maintain recrds f checking fr leaks in the spill preventin equipment interstitial areas every mnth, yu are nt required t test them every three years. Release detectin equipment Ensure it is perating with n alarms r ther unusual perating cnditins present. Ensure recrds f release detectin testing are reviewed, passing and current. Annual Walkthrugh Inspectins Annually, check yur cntainment sumps and any hand held release detectin equipment. When cnducting the annual walkthrugh inspectin, check the fllwing: Cntainment sumps (submersible pump, intermediate, under dispenser) Visually check fr damage, leaks int the cntainment area, r releases t the envirnment. Remve any liquid r debris. Fr duble walled cntainment sumps with interstitial mnitring, check fr a leak in the interstitial area. Hand held release detectin equipment (fr example tank gauge sticks r grundwater bailers) Check fr perability and serviceability. Owners and peratrs must maintain the mst recent walkthrugh inspectin recrds fr ne year after the date f the inspectin. Recrds need t include a list f each area checked, whether each area checked was acceptable r needed actin taken, and a descriptin f any actins taken t crrect issues.

3 Overfill Preventin Equipment Inspectins Beginning n Octber 13, 2018 wners and peratrs must have their verfill preventin equipment inspected fr prper peratin at least nce every three years. When inspecting, wners and peratrs must, at a minimum, ensure the verfill preventin equipment is set t activate at the crrect level in the tank (the level depends n the type f verfill device) and will activate when regulated substances reach that level. If an verfill device fails the inspectin it must be repaired r replaced. Nte vent restrictin verfill devices (ball flat valves) may nt be installed fr new installatins r repairs after the effective date f ADEM s new regulatins. Owners and peratrs must maintain recrds f verfill preventin equipment inspectins fr at least three years. Cntainment Sump Testing By Octber 13, 2018, wners and peratrs must meet ne f the fllwing ptins fr cntainment sumps used fr piping interstitial mnitring: Optin 1: Cntainment sumps used fr interstitial mnitring f piping are tested at least nce every three years. The test must determine the equipment is liquid tight by using either vacuum, pressure, r liquid testing. Nte - ADEM has develped a lw liquid level test methd that may be used if the sump sensr is permanently munted at the lwest level in the sump, and when activated, will shut ff the submersible pump. The test methd is described in the ADEM guidance Dcument titled Lw Level Hydrstatic Integrity Test fr UST Cntainment Sumps. Optin 2: Cntainment sump equipment is duble walled and the integrity f bth walls is mnitred annually in accrdance with the walkthrugh inspectin requirements discussed abve. If wners and peratrs discntinue this peridic mnitring, they have 30 days t cnduct the test described in Optin 1 abve. ADEM frm must be used t recrd results. Owners and peratrs must maintain recrds f cntainment sump testing fr at least three years. Fr cntainment sumps used fr interstitial mnitring f piping nt tested every three years, wners and peratrs must maintain dcumentatin shwing the equipment is duble walled and the integrity f bth walls is mnitred annually in accrdance with the walkthrugh inspectin recrdkeeping requirements discussed abve. (Optin 2).

4 Release Detectin Equipment Testing By Octber 13, 2018, wners and peratrs must test electrnic and mechanical cmpnents f their release detectin equipment fr prper peratin at least annually. When testing, check the fllwing: Autmatic tank gauge and ther cntrllers Test the alarm. Verify the system cnfiguratin. Test the battery backup. Prbes and sensrs Inspect fr residual buildup. Ensure any flats mve freely. Ensure any shafts are nt damaged. Ensure the cables are free f kinks and breaks. Test the alarm perability and cmmunicatin with the cntrller. Ensure prbes and sensrs are psitined prperly. Autmatic line leak detectr Test peratin t ensure the device activates (alarms, restricts flw, r shuts ff flw) within an hur when simulating a release equivalent t 3 gallns per hur at 10 punds per square inch. This includes mechanical and electrnic line leak detectrs, and sensrs designed t shut ff the submersed pump. Vacuum pumps and pressure gauges Ensure there is prper cmmunicatin with sensrs and the cntrller. Hand-held electrnic sampling equipment assciated with grundwater and vapr mnitring Ensure the device is calibrated and perates prperly. ADEM frm must be used t recrd results. Owners and peratrs must maintain recrds f release detectin equipment testing fr at least three years. The recrd must include each cmpnent tested, whether each cmpnent passed the test r needed t have actin taken, and any actin taken t crrect an issue.

5 Cmpatibility Demnstratin Beginning immediately after Alabama s UST regulatins becme effective, wners and peratrs string gasline cntaining greater than 10 percent ethanl r diesel cntaining greater than 20 percent bidiesel must demnstrate cmpatibility f each cmpnent f the UST system (this includes the tank, piping, cntainment sumps, pumping equipment, release detectin equipment, spill equipment, and verfill equipment) by using ne f the fllwing ptins: Certificatin r listing f UST system equipment r cmpnents by Underwriters Labratries (UL) r ther natinally recgnized, independent testing labratry fr use with the regulated substance stred, r Equipment r cmpnent manufacturer apprval this apprval must be in writing, indicate an affirmative statement f cmpatibility, specify the range f bifuel blends the equipment r cmpnent is cmpatible with, and be frm the equipment r cmpnent manufacturer. In additin, wners and peratrs must ntify ADEM at least 30 days prir t switching t regulated substances cntaining greater than 10 percent ethanl r greater than 20 percent bidiesel, and must maintain the recrds that dcument cmpliance with the cmpatibility requirement if they stre either f these substances. These recrds must be maintained fr as lng as the UST system is used t stre ne f these regulated substances. Additinal infrmatin abut the cmpatibility requirement fr UST systems string gasline cntaining greater than 10 percent ethanl r diesel cntaining greater than 20 percent bidiesel may be fund at the fllwing EPA website links: 10-percent-and-bidiesel-blends