UST Compliance Handbook and Documenta/on Toolkit Underground Storage Tank Owners and Operators State of Nevada

Transcription

1 UST Compliance Handbook and Documenta/on Toolkit Underground Storage Tank Owners and Operators State of Nevada

2 ARC Nevada Edi/on 1.0 Nicole Haynes McCoy, PhD COPYRIGHT 2012 All Rights Reserved

3 CONTENTS Chapter 1: Introduc1on to Underground Storage Tank Compliance 1 Chapter Overview 1 Environmental and Regulatory Context 1 Regulated Substances 2 Petroleum Products 2 Hazardous Substances 3 Purpose of This Handbook 3 Organiza1on 4 Chapter 2: UST Program Rules and Regula1ons 5 Chapter Overview 5 UST Regulatory Status 5 Provisions of the Energy Act of Regula/ons for Compliance 6 Owning or Opera1ng a UST in Nevada 7 Permits and Fees 7 Financial Responsibility 7 Delivery Prohibi/on 8 Secondary Containment 9 No/fica/on 11 Record keeping 11 Requirements for Tank Closure 12 Temporary Closure 12 Permanent Closure 13 Chapter 3: ABC Operator Requirements 15 Chapter Overview 15 Operator Requirements 15 Class A Operator 15 Class B Operator 15 Class C Operator 16 Unmanned Facili/es 16 Training and Registra1on 17 Class A and B Operators 17 Class C Operators 17 Retraining for Non Compliance 17 Chapter 4: UST System Components 19 Chapter Overview 19 UST System 19 UST System Components 19 UST System Func1on 21 Chapter 5: Spill and Overfill Preven1on 23 Chapter Overview 23 Introduc1on 23 Table 5.1 Spill and overfill preven3on: Equipment requirements 23 Spill Preven1on 24 Spill Buckets 24 Overfill Preven1on 25 Overfill Preven/on Equipment 26 Table 5.2. Overfill preven3on devices: Func3onal requirements 30 Owner/Operator Responsibili1es in Preven1ng Overfills 30 Table 5.3 Spill and overfill preven3on devices: Operator inspec3on 31 Chapter 6: Release Detec1on for Tanks 33 Chapter Overview 33 Introduc1on 33 Leak Detec/on Framework 34 Table 6.1. Leak detec3on for tanks: Requirement overview 34 In Tank Monitoring (Automa1c Tank Gauging) 35 ATG Periodic (Sta/c) Tes/ng 36 ATG Con/nuous Tes/ng 37 Tank Test Limita/ons for ATGs 37 Table 6.2. In Tank Monitoring (Automa3c Tank Gauging) 38 Secondary Containment with Inters11al Monitoring 39 Manual Inters//al Monitoring 39 Con/nuous Inters//al Monitoring 40 Table 6.3. Secondary Containment with Inters33al Monitoring 41 Sta1s1cal Inventory Reconcilia1on 42 SIR Process 42 Table 6.4. Sta3s3cal Inventory Reconcilia3on (SIR) 44

4 Inventory Control and Tank Tightness Tes1ng 45 Table 6.5. Inventory Control and Tank Tightness Tes3ng 46 Manual Tank Gauging 47 Table 6.6. Manual Tank Gauging with Tank Tightness Tes3ng 48 Groundwater Monitoring 49 Vapor Monitoring 49 Table 6.7. Release detec3on for tanks: Systems compared 51 Table 6.8. Leak detec3on for tanks: Operator inspec3on 52 Chapter 7: Release Detec1on for Lines 53 Chapter Overview 53 Introduc1on 53 Table 7.1. Leak Detec3on for Piping: Requirement overview 53 Types of Suc/on Piping 54 Pressurized Piping Systems 56 Catastrophic Release Detec/on 57 Secondary Leak Detec/on 59 Table 7.2. Line leak detec3on: Method and tes3ng requirements 63 Table 7.3. Leak Detec3on for Piping: Operator inspec3on 64 Containment Sumps 64 Sump Components 65 Table 7.4. Sumps and Dispensers: Operator inspec3on 66 Chapter 8: Corrosion Protec1on 67 Chapter Overview 67 Table 8.1. Corrosion Protec3on: Requirement overview 67 Introduc1on to Corrosion 68 Cathodic Protec1on 68 Corrosion Protec1on Requirements by UST System Material 70 Tank Materials 70 Piping Materials 71 Table 8.2. Corrosion protec3on summary by material 72 Tes1ng CP Systems 72 Table 8.3. Cathodic protec3on: Operator inspec3on 73 Chapter 9: Compa1bility 75 Chapter Overview 75 Compa1bility 75 Table 9.1. Compa3bility overview 75 Alterna1ve Fuels 76 Ethanol 77 Biodiesel 78 Chapter 10: Emergency Response 79 Chapter Overview 79 Introduc1on 79 Table Emergency response: Requirement overview 79 Alarms or Unusual Condi1ons 80 Alarm Response 80 Unusual Condi/ons 80 Suspected Release Inves1ga1on 81 Inves/ga/on Steps 81 Release/Spill Response 82 Emergency Planning 82 Chapter 11: Marina USTs 83 Chapter Overview 83 Introduc1on 83 Table Marinas: Requirement Overview 83 Owning or Opera1ng a Marina UST in Nevada 84 Tank Requirements 85 Secondary Containment 85 Tank filling equipment 86 Monitoring 86 Piping and Valve Requirements 86 Emergency Shutoff 86 Secondary Containment (for piping) 86 Piping at Floa/ng Marinas 87 Dispensing Equipment 87 Required Daily Inspec/on 87 Required Monthly Inspec/on 87 Corrosion Protec1on 88 Defini1ons 89

5 Chapter 5: Spill and Overfill Prevention Chapter Overview This chapter focuses on spill and overfill prevention during deliveries. Topics covered include: Spill and overfill protection equipment such as spill buckets, automatic shutoff devices, ball float valves, and overfill alarms; Owner/operator responsibilities in preventing overfills; Operator inspection of spill and overfill prevention equipment. Introduction Recall that prevention of spills and overfills is a critical component of the prevention and detection requirements for UST owners and operators. The U.S. Environmental Protection Agency (EPA) designed part of the technical regulations for underground storage tank (UST) systems to prevent Spill or overfill means any release of a regulated substance that occurs: (a) Above the surface of the ground at a facility where a storage tank is located; (b) From a dispenser for motor fuel above the sheer valve for the dispenser; or c) From any ancillary equipment for the tank system that: (1) Is not included in any system for the detection of a leak; and (2) Is accessible to visual inspection (from NAC ) releases from USTs. The regulations require USTs to be protected from spills, overfills, and corrosion. TABLE 5.1 SPILL AND OVERFILL PREVENTION: EQUIPMENT REQUIREMENTS SPILL AND OVERFILL PREVENTION EQUIPMENT REQUIREMENTS What Ensure your UST is properly equipped with spill and overfill prevention equipment. How Spill prevention: spill buckets properly installed, sized, kept clean, dry and in good condition Overfill prevention: automatic shutoff devices, ball float valves,or overfill alarms. When Devices installed at installa/on; ongoing maintenance item. Why Federal 40 CFR Performance standards for new UST systems. (c) Spill and overfill prevention equipment. 40 CFR Upgrading of existing UST systems. (d) Spill and overfill prevention equipment. 40 CFR Spill and overfill control. Who Owner/Operator responsible for having proper, functional equipment. NOTE If an UST never receives more than 25 gallons at a 3me, the UST does not have to meet the spill protec3on requirements. Many small used oil tanks fall into this category. 23

6 Spill Prevention Many releases at UST sites come from spills. Spills often occur at the fill pipe when the delivery truck s hose is disconnected. Although these spills are usually small, repeated small releases can cause significant environmental problems. Human error causes most spills. These mistakes can be avoided by following industry standard practices for tank filling. If you and the delivery driver follow standard practices, nearly all spills can be prevented. For this reason, federal UST regulations require that you follow industry standard practices for tank filling. Spill Buckets EPA requires that all fill pipes have a spill prevention device installed around them. Only UST systems that are filled by 25 gallons or less are exempted from this requirement. Spill buckets, also called catchment basins, are contained sumps at the fill and/or vapor recovery connection points. The spill bucket should be large enough to contain what may spill when the delivery hose is uncoupled from the fill pipe. A typical delivery hose can hold about 14 gallons of fuel. Spill buckets are normally located on top of the tank and are positioned below grade. The top of a well constructed spill bucket is slightly above grade to help drain rain and surface water away from the spill bucket opening. That prevents unwanted liquid from getting into the spill bucket on its way to your tank. There is no capacity requirement for spill buckets and most range in size from 5 to 25 gallons, with lids 1 2 feet in diameter. Some/mes spill bucket lids will be colorcoded to help the driver put the right product into the right tank. Spill buckets must be liquid /ght in order for them to func/on as intended (and as required by EPA) to keep small spills at the end of a delivery from gefng into the soil. As shown in the diagrams that follow, spill buckets may come equipped with either a pump or drain to remove fuel. Drain valves allow excess fuel to be drained directly back into the tank. As long as the drain valve is /ght, this device shouldn t pose a problem to opera/ons. In addi/on to spilled fuel (and perhaps even more frequently), water and sediment can get into spill buckets. If your spill bucket Federal regulations (40 CFR (c)) require UST systems to be equipped with both spill prevention and overfill prevention equipment. Federal regulation 40 CFR (c)(i) requires spill prevention equipment that prevents a release of product to the environment when the transfer hose is detached from the fill pipe (for example, a spill catchment basin). 24 Spill buckets, also called catchment basins, come in many different designs and sizes. Be sure to select one that is appropriate for your UST. Copyrighted Material ARC Nevada, LLC

7 comes with a drain A that flows directly into the tank, you don t want to drain water into your tank. Water in the tank is a fuel quality issue, but an even greater concern is that water can rust steel tanks from the inside out, and, in excess, can impact your ability to detect leaks. If your spill bucket didn t come equipped with a pump, you can purchase a spark free hand pump to draw the water and sediment out of the spill bucket. Note: If this mixture contains fuel or chemicals, make sure you dispose of it properly, as it may be considered hazardous waste. Spill buckets take a lot of abuse from weather, spilled fuel, drivers, snowplows and other factors. They age quickly compared to other parts of the UST. Check them regularly and be prepared to replace them periodically. Spill buckets don t keep the fuel out of the ground if they are not liquid tight. Monitor them for cracks or holes in the bottom, keep an eye on the seal around the fill pipe, Spill bucket containing spilled fuel. Spill bucket equipped with drain (A) and a spill bucket equipped with a pump (B). and look for cracks in the bellows. Don t leave fuel in them; it degrades the plastic and can seep out the seal or threads over time. Keep them clean so you can drain excess fuel into the tank without contaminating your fuel. If a spill bucket is full of water it cannot contain a spill. What should you look for? Any one of the following: water or fuel in the bottom remove it; debris of any kind that doesn t belong there remove it; broken or damaged drain valve repair it; and any holes or cracks in side walls or bottom replace the spill bucket. B Overfill Prevention If delivery drivers or UST owners make fuel delivery mistakes, a tank can be overfilled quickly and large volumes can be released at the fill pipe and through loose fittings on the top of the tank or a loose vent pipe. Overfills usually result from human error and can be avoided if everyone involved in the fuel delivery follows industry standard practices for tank filling. 25

8 Overfills usually release much larger volumes than spills. When a tank is overfilled, large volumes can be released at the fill pipe and through loose fittings on the top of the tank or a loose vent pipe. Note: The tightness of these fittings normally is not a problem if the tank is not filled beyond its capacity. Accidentally overfilling an underground storage tank can happen very quickly if the proper overfill protection measures are not followed. Think about the filling process: A hose from a 10,000 gallon tanker truck is connected to a fill pipe. If the fill process is gravitydriven (and most are), the driver turns a valve to open a hose and the fuel flows in at about 300 gallons a minute. Now imagine if there s not enough room in the tank someone didn t measure the correct liquid level, or the wrong tank is being filled: in either situation, an overfill will occur at about 300 gallons a minute! Owners and operators can prevent the potential for overfill problems by: ensuring there is enough room in the tank for the The delivery before water tap on the delivery is a bathtub flows made; at approximately 5 gallons per minute. watching the Filling the average entire delivery American bathtub at 300 gallons per to prevent minute would take overfilling or less than 10 spilling; and seconds! using overfill protection devices. Overfill Prevention Equipment Your UST must have overfill protection. New USTs must have overfill protection devices when they are installed. Older USTs should have been upgraded by 1998 with spill and overfill prevention devices. Overfill prevention devices work in one of three ways: Placed in the fill pipe, they stop the flow of fuel. Installed in the vent pipe, they slow or restrict the flow of fuel (but do not stop it entirely). Alarms neither stop nor restrict flow in and of themselves, but alert the driver (and potentially the operator) that the tank is nearly full. The three main types of overfill protection devices are: 1. Automatic shutoff devices (stops the flow of fuel) 2. Ball float valves (slows the flow of fuel) 3. Overfill alarms (alerts the driver). Federal regulation 40 CFR (c)(ii) requires overfill prevention equipment that will: Automatically shut off flow into the tank when the tank is no more than 95 percent full; or Alert the transfer operator when the tank is no more than 90 percent full by restricting the flow into the tank or triggering a high level alarm; or Restrict flow 30 minutes prior to overfilling, alert the operator with a high level alarm 1 minute before overfilling, or automatically shut off flow into the tank so that none of the fittings located on top of the tank are exposed to product due to overfilling. AutomaRc Shutoff Devices Of the three types of overfill protection devices, the automatic shutoff device (ASD) is the only one capable of completely stopping the flow of fuel. Depending on the type of ASD installed, it may slow the flow of fuel before stopping it or be set to trip, stopping the flow abruptly. 26

9 Overfill alarm. Ball float valve. Automa/c shutoff devices. Built into the fill pipe, the ASD is essentially a tube inside of which is a valve (often called a flapper valve) connected to a float. As the fuel level rises, it lifts the float from a vertical to horizontal position. When the tank is nearly full (in Nevada, the required setting is at a maximum of 95% capacity), the float arm is at full height, and the shutoff valve is completely closed. If you have an ASD installed on your tank, look down the fill opening and see if you can spot the mechanism. If you have a two valve system, after the main valve closes, a bypass valve allows a small amount of product to flow (5 to 10 A An open automa/c shutoff valve (A), and closed (B). gallons per minute) so that the hose can be drained. If the delivery continues beyond a certain level, the bypass valve also closes. B Once the bypass valve closes (on a twovalve system) or the main valve shuts (on a one valve system), fuel is trapped in the hose. This prevents an overfill, but the backup of fuel up the hose means there is no place for the fuel to go (recall that most tanks are gravity filled and fuel can t be pumped back into the truck). As a result, the hose must remain connected Automatic shutoff devices are commonly referred to as drop-tube devices or flapper valves. to the tank until fuel levels in the tank drop enough for the float to relax, releasing the shutoff valve and allowing the remainder of the fuel to flow into the tank. If an overfill does occur, so long as the delivery hose is tight, there shouldn t be a spill on the ground at least until the hose is disconnected. Be aware that there is a lot more fuel in the hose than will fit in the spill bucket. Having an ASD doesn t guarantee that an overfill won t happen. Common sources of failure include: Broken device; Device bypassed by stick or other object; and 27

10 Copyrighted Material ARC Nevada, LLC Device installed wrong or at incorrect tank from the vent opening. Typically a wire cage containing a hollow ball is fastened to the lower end of the pipe. The ball sits below the end of the pipe within the wire cage. As long as the product is below that of the ball, the tank vent pipe remains open and the tank can breathe. height. Sometimes attempts are made to override the overfill device by using a stick or other object to force the float mechanism down and keep the valve open. This can occur if the valve has activated and delivery personnel are forced to wait until the fuel clears the hose, or if the valve hasn t shut off the flow of fuel, but is slowing down a normal delivery. If the fuel level is too high, the ball floats up and blocks the vent opening (in Nevada, the ball float valve must ac/vate PL E A bypassed or broken device increases the chances of an overfill that results in a significant spill. Be aware that owners (not drivers) are liable for spills and overfills that occur during delivery. M EPAs proposed regulations require that you have the automatic shutoff checked for proper product level height setting at least once, and then once a year have a technician or third party inspector visually inspect the device. Keep a copy of your test results and correct any problems. when the tank is no more than 90% full). SA EPA also proposes to require that UST owners and operators inspect overfill prevention equipment for function and fill pipes for potential obstructions every 30 days. Ball Float Valves Illustra/on of how a ball float vent valve operates. With the tank being unable to exhale as it normally does, it becomes more difficult to fill the tank, which should alert the driver to close the truck s shutoff valve. When you rely on a ball float vent valve, you want to watch out for the following: Ball float valves are also known as float-vent valves. Recall that all tanks are vented and that the vent pipes prevent the buildup of pressure in the tank by allowing petroleum vapors to escape. During a fuel delivery, the tank exhales out the vent as the fuel coming into the tank displaces the petroleum vapors and pushes them out. The ball is missing. The cage can rust out or become bent out of shape; The ball won t float. It can rust onto the cage or corrode through and fill with product; The valve is installed wrong or at incorrect height; A remote fill opening or other tank top riser is not liquid /ght. This allows the tank to exhale even auer the fuel level Ball floats consist of a short length of pipe that extends down into the top of the 28

11 pushes the ball into the vent opening, preven/ng a pressure buildup from signaling that the tank is full. Ball floats are incompa/ble with: Suction piping product can be forced out the air eliminator, Pressurized deliveries it could blow your tank out at the seams, Stage 1 coaxial drop tube it can push fuel up the vapor return interstice and back into the truck. If your facility has two point vapor recovery with a ball float, ensure that the vapor recovery poppet remains free of rocks or other obstructions as these disable the ball float device and can be an air quality violation. We suggest that you have the ball float vent valve checked for proper product level height sefng at least once, and then once a year have a technician or third party inspector visually inspect the device to make sure the ball is s/ll doing what it s supposed to do. Keep a copy of your test results and correct any problems. Overfill Alarms Overfill alarms don t stop fuel from flowing, but they do alert the driver that an overfill incident is about to occur. Of the three overfill prevention technologies, they are the most versatile in that they can be used with either gravity or pumped deliveries and with tight or loose connections. Overfill alarms use probes installed in the tank (see illustration) to activate an alarm when the tank is either 90 percent full or within 1 minute of being overfilled. Typically overfill alarms are tied into an automatic tank gauging system (ATG). The alarm may be either a blinking red light, a siren (most common), or both. Make sure the alarm is located where the driver can see or hear it easily. Although not required, some overfill alarms are set to activate at multiple levels: 90% full: High product alarm (required minimum setting you have about a minute); 95% full: High high product alarm (you have less than 1 minute); and 100% full: Max product alarm (it s too late). Overfill alarms work only if they alert the driver at the right time and the driver responds quickly. Problems with overfill alarms can include: Overfill setting incorrectly programmed so the alarm goes off too late. Communication to the tank gauge isn t working. Alarm box malfunctioning or broken. Driver isn t nearby to hear/see alarm and respond. Overfill alarm activates but no one responds. Overfill alarm connected to an electrical circuit that can be turned off or that does not alert if a circuit breaker is tripped. We suggest that you have the overfill alarm checked for proper product level height setting at least once, and then once a year have a technician or third party inspector function test the alarm box, the wiring, and the float. Keep a copy of your test results and correct any problems. 29

12 TABLE 5.2. OVERFILL PREVENTION DEVICES: FUNCTIONAL REQUIREMENTS OVERFILL PREVENTION DEVICES: FUNCTIONAL REQUIREMENTS What UST must have at least one device from the list below: automatically shut off flow into the tank when the tank is no more than 95 percent full; or restrict the flow into the tank or triggering a high level alarm when the tank is no more than 90 percent full; or restrict flow 30 minutes prior to overfilling, alert the operator with a highlevel alarm 1 minute before overfilling, or automatically shut off flow into the tank. How Automatic shutoff devices (must shut off flow when tank is 95% full) Ball float (vent) valves (must restrict flow when tank is 90% full) Overfill alarms (must alarm when tank is 90% full) When Required at tank installa/on for tanks installed auer 1986; Required upgrade to exis/ng tanks since 1998 Why Federal 40 CFR (c)(ii) Spill and overfill preven/on equipment 40 CFR Spill and Overfill Control (Owner s Responsibili3es) Who Owner responsible for having proper device. NOTE Manufacturers do not recommend using ball float valves with suc3on piping, pressurized delivery, or coaxial Stage I vapor recovery. Owner/Operator Responsibilities in Preventing Overfills As the person who is legally responsible for ensuring that overfills do not happen during fuel deliveries at your UST facility, develop a wriden delivery procedure that all personnel involved in the delivery process follow. This procedure should include the following measures: Ensure there is enough room in the tank before each delivery. Measure the fuel level in your tank(s) before each delivery. Know the working capacity of your tank(s). (The working capacity is the amount of fuel the tank will hold without triggering the overfill preven/on device). If you have a tank gauge, order your fuel based on the 90% ullage reading from the tank gauge. Monitor all fuel deliveries from beginning to end. Delivery drivers may be more careful if someone is watching. Use security cameras to monitor the delivery process and let the drivers know that they are on camera. Inspect your spill buckets rou1nely. If necessary, clean before and aier each product delivery. Respond to all overfill indica1ons. If a tank gauge is aler/ng to an overfill, make sure both your staff and the driver respond appropriately. Never ignore an alarm. An overfill means you have ordered 30

13 too much fuel; re evaluate the methods used to calculate how much fuel to order to prevent a future overfill (or poten/al spill). Prepare for spills that can occur despite a well func1oning overfill preven1on system. Hoses can break, a driver can disconnect a hose without realizing the tank is over filled, or a loose riser somewhere on a tank can prevent a ball float valve from func/oning. Make sure you have an emergency plan in place for what to do if an overfill occurs and that delivery drivers, operators, and other personnel are aware of the procedures and their responsibili/es in case of an overfill emergency. TABLE 5.3 SPILL AND OVERFILL PREVENTION DEVICES: OPERATOR INSPECTION SPILL AND OVERFILL PREVENTION DEVICES: OPERATOR INSPECTION What Check spill and overfill preven/on equipment for func/on and obstruc/ons. How Spill Buckets Lids are in good condition, fit tightly Shouldn t have any visible holes, cracks, or damaged areas Shouldn t be deformed or warped Basin should be clean, dry, and free from debris Overfill Prevention Equipment All fills are unobstructed Automatic shutoff valves or ball floats are present and functional Overfill alarm is properly located and clearly identified When Required: At installation (if required by manu ufacturer) Proposed: At installation (regardless of manu ufacturer s requirements) Proposed: Every 30 days Proposed: Test spill prevention equipment at t least once every 12 months Why Federal: 40 CFR (proposed) 40 CFR (proposed) Who Class B Operator or their designee. NOTE Proposed federal regula3ons will require operator walk through inspec3ons of spill and overfill preven3on equipment every 30 days and have spill preven3on equipment tested at least once every 12 months. 31