PURPOSE RESPONSIBILITY

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1 PAGE 1 OF 6 PURPOSE This Standard Operating Procedure (SOP) provides guidance and methods for Underground Storage Tank (UST) inventory control at Massachusetts Department of Transportation, Highway Division fueling stations as required by 527 CMR 9.00 and 40 CFR (a) RESPONSIBILITY It is the responsibility of Highway Operations and each District to ensure that daily inventory records are on file and that monthly inventory reconciliation of gasoline and diesel USTs is being conducted properly in accordance with this SOP and the applicable DEP regulations. Consumptive use fuel oil (those used for heating) tanks and non-hazardous industrial waste water tanks are exempt from tank reconciliation and this SOP. The District Highway Director (DHD) is responsible for designating personnel responsible for maintaining the correct inventory control procedures outlined in this SOP. The DHD shall designate a person(s) responsible for obtaining the daily inventory records and conducting monthly inventory fuel reconciliation the District Fuel Inventory Reconciliation Designee (DFIRD). The DHD shall also designate a person(s) at the facility level to obtain fuel inventory data for the District designee conducting fuel inventory reconciliation if the data is not available via remote connection, the District Facility Fuel Designee (DFFD). The DHD or their designee shall designate a person to ensure that the appropriate data for each fuel tank at every site is collected and that inventory control on each UST at every site in the District is completed on a monthly basis. The District designee shall obtain the required information (tank readings and fuel pumped) electronically via from Highway Operations or from the individual fueling sites. If the information is not available through remote communication with the tank systems for a period greater than 48 hours, the designated person at the facility shall obtain the information daily from the onsite tank monitoring system (currently the Veeder Root TLS 350 Monitor, Incon, or equivalent) and the fuel management system (currently the Petrovend System 2, EJ Ward, or equivalent) and forward the information to the designated person responsible for performing fuel inventory reconciliation. In the event monthly tank reconciliation indicates an abnormal loss, as defined in the Definitions and Section B of this SOP, the DHD or their designee shall be notified immediately (verbally and via ). The DHD or their designee shall immediately initiate the process in Section C of this SOP to account for the discrepancy. The person designated for fuel inventory reconciliation shall maintain all fuel inventory records for all fueling facilities for the District for the previous twelve months. All inventory records must be readily available for review.

2 PAGE 2 OF 6 Environmental Services staff (i.e. EMS Compliance Coordinators) shall perform a monthly review of the District s fuel inventory reconciliation records. If the ECC inspection finds noncompliance with this SOP, it is the responsibility of the ECC to notify (verbally and via ) the DHD or their designee and Highway Operations (or designee) regarding the compliance issue. Any procedural changes as a result of regulation or fuel system equipment changes will supersede this SOP until such time that this SOP can be updated. Environmental Services will review regulation changes on a regular basis and submit the appropriate changes to this SOP to Highway Operations. DEFINITIONS Abnormal Loss of product for any tank or combination shall mean a loss of product not explained by spillage, temperature variation or other causes, in excess of 1.0% of the volume of product dispensed over a period of a calendar month (throughput) plus 130 gallons. See 40 CFR280.43(a). District Fuel Inventory Reconciliation Designee (DFIRD) - This person(s) is responsible for following this SOP by collecting District fuel inventory records and reconciling monthly fuel inventory. This person shall make the DHD or their designee and Highway Operations aware of any abnormalities found under this SOP. The DHD or their designee shall also designate at least one backup person(s) for this position. District Facility Fuel Designee (DFFD) - This person is responsible for following this SOP by collecting daily facility fuel inventory records using the electronic methods (current inventory monitoring system & current fuel management system) or in the event that the electronic equipment on site is inoperable manually (dipstick gauging device), and submitting the records to the District Fuel Inventory Reconciliation Designee. The DHD or their designee shall also designate at least one backup person(s) for this position. Monthly Inventory Reconciliation - is a process to ensure the tank is functioning properly and assess if an inventory discrepancy exists(prompting implementation of necessary steps). The process ensures that fuel in the tank is reconciled with the fuel dispensed, added or removed to determine if any fuel is unaccounted for. The tank reconciliation procedure is described in the Federal regulation 40 CFR (a). Monthly inventory reconciliation will be conducted electronically using a District specific version of the sample spreadsheet (attached). The fuel management system (currently Petrovend System, EJ Ward system or an equivalent fuel management system is in use at most MassDOT fueling sites) tracks fuel pumped at each site. The system is capable of providing gallons pumped through the dispensers and gallons remaining in the tanks. The electronic inventory system equipment (currently VeederRoot Controller (TLS 350 Monitor), Incon, or

3 PAGE 3 OF 6 an equivalent electronic inventory system is in use at most MassDOT fueling sites) monitors the tanks through the use of electronic probes mounted in the gasoline and diesel tanks. It monitors the amount of fuel in the tank, measures the amount of deliveries, and performs leak detection. POLICY Procedure for Monthly Inventory Reconciliation: Section A) Highway Operations or a District Designee remotely polls the fuel management system through the electronic inventory system equipment. It is recommended that polling of the facilities be performed during periods of shutdown or low use such as the early morning hours (i.e. starting at 3:00AM for example). The readings needed shall include the amount of fuel dispensed and the amount of fuel in the tank for each day of fuel operation (e.g., if no fuel is dispensed or delivered on a Saturday, Sunday or holiday for example, no data is required for those days). The readings also include any deliveries of fuel that had taken place during the month. The fuel dispensed and fuel remaining in the tank must be obtained at approximately the same time every day (for example start 3:00PM on a Monday, it must be 3:00PM on a Tuesday and so on). The District Fuel Inventory Reconciliation Designee will receive fuel inventory readings in a Tank Reconciliation Report (throughput in gallons for the month and calculated variance) at the end of each month for each fueling facility in the District. These readings will be received remotely through electronic means (via Highway Operations or a District Designee) or in the event the electronic equipment is disabled from the designated facility fuel manager at the site. Section B) Section C) The District Fuel Inventory Reconciliation designee will enter the following information: name of the facility, throughput (or total sales) in gallons, and variance in gallons, into an electronic spreadsheet provided by Environmental Services (a sample spreadsheet is attached) that will calculate the regulatory limit of variance in gallons fuel loss/gain and percent loss/gain for each fueling facility. If the spreadsheet indicates a facility has a total inventory discrepancy [i.e., actual variance in gallons for any particular facility shows an abnormal loss/gain (is greater than 1.0% of the monthly throughput plus 130 gallons of the total dispensed (i.e., the regulatory limit of variance in gallons)], then the District Fuel Inventory Reconciliation Designee shall notify the DHD or their designee, Boston Operations, or their designee. Proper use of the fuel inventory spreadsheet will be covered in Fuel Inventory training. Upon receiving notification that an UST did not meet the threshold for inventory control and a possible abnormal loss condition exists; the DHD or their designee shall initiate the following steps until the discrepancy is addressed:

4 PAGE 4 OF 6 1. Inventory input and output records shall be checked for arithmetic errors; 2. Inventory shall be checked for errors in measurement; 3. Determine if any recent testing or equipment repair on the tank/ fuel system has occurred that may have affected the fuel inventory monitoring system. In the past this has been a common cause of inventory discrepancies; 4. If the abnormal loss is not reconcilable by steps 1, 2, or 3 the accessible parts of the system shall be checked for signs of damage or leaks; 5. Monitoring wells (if available) and leak detection systems shall be checked for signs of discharge; 6. Calibration of the dispensers and inventory system shall be checked; 7. The entire storage system excluding vents but including joints and remote fill lines shall be tank tightness tested in accordance with 527 CMR In the event this task is needed, Environmental Services shall be contacted for further guidance before performing tank testing to ensure tank testing methodology meets 527 CMR 9.00; 8. If a discharge, leak or threat of release is discovered, this must be reported to DHD or their designee, Highway Operations and Environmental Services within 2 hours and the DHD must shut down the fueling operations from this tank. Highway Operations will then confer with Environmental Services as to notifying local fire department and MA DEP; 9. Highway Operations shall be responsible for identifying the fuel tank leak, repairing the fuel leak and getting the tank system back on line. Environmental Services will perform any MGL 21-e action required. Section D) At least once a month the amount of water in the USTs shall be measured. This shall be done remotely by getting an electronic inventory system equipment tank printout or onsite manually using the dipstick gauging device and water/fuel detection paste. The water/fuel paste is a special compound made for detecting water in the gasoline/ethanol fuel that is currently used in all gasoline tanks. The water/fuel paste can also be used in diesel tanks. This paste is available at the District Stockroom or Warehouse. An abnormal gain of water shall be a gain of water level inside any tank of more than one inch in a 24-hour period. The water should be removed promptly and disposed of properly. In the event of an abnormal gain of water, Highway Operations shall arrange to have the water/fuel mixture removed from the tank and disposed of in

5 PAGE 5 OF 6 Training: a manner as directed by the Department of Environmental Protection (DEP). After another 24 hour period during which no fuel shall be added to the tank, the tank shall be checked the tank for water. Apart from the abnormal gain of water, for any tank in which water has accumulated to a depth of 0.5 inches or more shall be removed and disposed of in a manner as directed above. Designated District personnel capable of conducting minor repair of the tank systems shall do so. The DHD or their designee will also arrange for calibration of dispensers when needed. During the course of any discrepancy investigations, assistance may be obtained from Highway Operations. Highway Operations shall provide contractual assistance in the repair of the tank systems that is beyond the capability or means of District personnel. Highway Operations must have on-call technicians under contract to provide assistance if a dispenser, pump or electronic part needs to be replaced. The DHD or their designee should contact the local town Weights and Measures department to provide for calibration of dispensers or otherwise call Highway Operations to arrange for a contractor to provide calibration. Environmental Services can provide regulatory guidance and will be responsible for notifying the DEP and Fire Department Officials if the result of the investigation requires notification. If required, Environmental Services can arrange to have the monitoring wells investigated or sampled as needed. MassDOT Highway Division, Highway Operations is required under this SOP to develop, schedule, and deliver a state-wide UST reconciliation training program. All designated personnel in Operations and in the Districts responsible for fuel inventory reconciliation record review and inventory equipment maintenance shall attend this training. As part of the inventory control training program MassDOT Highway Division, Highway Operations shall also develop, schedule, and deliver an on-site (District) training program. Each DHD or their designee shall provide a training roster for their respective District. Each DHD or their designee shall select one person and at least one backup person that will perform fuel inventory reconciliation for all District fuel facilities. Each DHD or their designee shall select a person and at least one backup for each refueling facility to be trained in obtaining the data necessary for fuel inventory reconciliation. The designated personnel and backup staff shall be trained to perform the respective duties described within this SOP. All records of those trained shall be kept in both the District and Highway Operations Offices.

6 PAGE 6 OF 6 Annual refresher training and training of new staff or replacement staff will be provided by Highway Operations. The District EMS-Compliance Coordinators are required to attend the initial and annual refresher training. They will not be conducting fuel inventory reconciliation; however they are required to be familiar with the process. This training should be specific to the fuel inventory equipment and documentation that is required to support the program, including operating the electronic inventory system, the fuel management system, manual gauging using the dipstick gauging device, using water/fuel detection paste, emergency preparedness and response in case of an unaccountable loss of product or product surface spill. The training syllabus shall be developed using the pamphlet Doing Inventory Control Right for Underground Storage Tanks, published by the Underground Storage Tank Regulatory Compliance Unit, Executive Office of Public Safety, Department of Fire Services, Commonwealth of Massachusetts, and will use the attached electronic spreadsheet. Environmental Services will assist operations as necessary to develop the UST reconciliation training programs. All personnel that are authorized to manage UST facilities as indicated in this SOP shall be designated with a certificate to be placed in their personnel files and a notation placed on their list of job duties. Equipment Maintenance and Contract Support: Highway Operations shall support this inventory control program by providing adequate statewide maintenance resources (i.e.contractsand administrative personnel) for UST inventory control equipment and a regular inspection and maintenance program for all equipment relating to fuel inventory control and underground storage tank maintenance in general. This fuel inventory equipment includes but is not limited to the electronic inventory system (currently VeederRoot and Incon) the fuel management system (currently PetroVend and EJ Ward), the manual gauging device, water/fuel detection paste and any required personal protection equipment. Maintenance of Inventory Reconciliation Records: All records concerning inventory reconciliation shall be retained and stored at the District for a period of one year. At any one time there shall be a minimum of 12 previous month s records available for review. The records shall be made available for review by District EMS-Compliance Coordinators or any regulatory auditor at any time.

7 MassDOT Highway Division Tank Reconciliation Report (Manual Data Entry) Facility Name: Facility Address: Month/Year: Tank: Opening Volume 1 Deliveries 1 Total Sales 2 Ending Volume 1 Calculated Volume Calculated Variance Date (gallons) (gallons) (gallons) (gallons) (gallons) (gallons) Totals: as reported by the Leak Detection/Electronic Inventory System or manual stick method 2 - as reported by the Fuel Management System END OF THE MONTH CHECK FOR WATER IN UST Is there measurable water within bottom of the UST greater than 0.5 inches? If yes, did the volume increase after a 24 hours? YES/NO YES/NO If yes to either of above, CONTACT HIGHWAY OPERATIONS AND YOUR ECC!

8 MassDOT Highway Division District Tank Reconciliation Summary Report (Manual Data Entry) District: Four Month/Year: February 2012 Monthly Sales/ Throughput Calculated Variance Allowable Variance 1 Acceptable Variance Percentage Variance Facility Name Tank ID (gallons) (gallon) (gallons) (check) Chelmsford Gas Pass Reading Gas Pass Revere Gas Pass 0.33 Newbury Gas Pass Manchester Gas Pass Lawrence Gas Pass 0.44 Concord Gas Pass 0.11 Arlington Gas Pass Total Throughput Gasoline Chelmsford Diesel Pass Reading Diesel Pass Revere Diesel Pass 1.29 Newbury Diesel Pass Manchester Diesel Pass Lawrence Diesel Pass 1.03 Concord Diesel Pass 0.07 Arlington Diesel Pass 0.20 Total Throughput Diesel Use of EPA s abnormal loss calculation method per 40 CFR280.43(a) was approved by the Massachusetts Fire Marshall in a memo dated March 14, 2007, in lieu of 527 CMR 9.05(E)(2)(b). Allowable Variance = (Monthy Throughput Gallons X 0.01) gallons