PENNSYLVANIA ABOVE GROUND STORAGE TANKS

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1 PENNSYLVANIA ABOVE GROUND STORAGE TANKS GZA GeoEnvironmental Inc. by Jeffrey Knepper, LRS, CPG July 27, 2017

2 PA CODE Chapter 245. Administration of the Storage Tank & Spill Prevention Program AST Definition One or a combination of stationary tanks with a capacity in excess of 250 gallons, including the underground pipes and dispensing systems connected within the emergency containment area, which is used, will be used or was used to contain an accumulation of regulated substances, and the volume of which, including the volume of piping within the storage tank facility, is greater than 90% above the surface of the ground. The term includes tanks which can be visually inspected from the exterior, in an underground area and tanks being constructed or installed for regulated use.

3 PA AST S Exclusions A pipeline facility, including gathering lines, regulated under: The Natural Gas Pipeline Safety Act of 1968, The Hazardous Liquid Pipeline Safety Act of 1979 or an interstate/intrastate pipeline facility regulated under State Laws comparable to the first two acts. A stormwater or wastewater collection system. A flow-through process tank, including pressure vessels or oil and water separators.

4 PA AST S Exclusions Cont d A nonstationary tank liquid trap or associated gathering lines directly related to oil and gas production or gathering operations. Tanks used to store brines, crude oil, drilling or frac fluids and similar substances or materials directly related to the exploration, development or production of crude oil or natural gas regulated under the Oil and Gas Act.

5 HOW ARE OIL & GAS AST S REGULATED Chapter 78a Unconventional Wells 78a.56 Temporary Storage regulated substances or wastes generated at a well site must be contained in a tank or series of tanks. Modular Tanks may be used with approval from the PADEP Open Tanks or Storage Structures may also be used as long as 2 ft. of freeboard remain at all times. Tanks must be equipped with protection devices to prevent unauthorized access. Signage must be installed identifying contents and warning signs.

6 HOW ARE OIL & GAS AST S REGULATED 78a.56 Temporary Storage Cont d Tanks containing regulated substances or fluids must be impermeable. Condensate at a concentration greater than 1% by volume may not be stored in any open top structure. Tanks used to store condensate shall be monitored and have controls to prevent vapors exceeding the L.E.L. Tanks storing condensate must be grounded.

7 HOW ARE OIL & GAS AST S REGULATED 78a.57 Control, Storage and Disposal of Production Fluids Brine and other fluids produced during operation of a well must be stored in a tank or series of tanks. Open top structures and pits are prohibited. Secondary containment is required for these tanks. These tanks must comply with the corrosion control requirements in These tanks must be protected from unauthorized acts of third parties.

8 HOW ARE OIL & GAS AST S REGULATED 78a.57 Control, Storage and Disposal of Production Fluids Tanks must be inspected by the operator at least once per calendar month and documented. Deficiencies noted during inspection shall be reported to the PADEP electronically through their website within 3 days of inspection. Inspection Records shall be maintained for 1 year and available upon request.

9 CORROSION & DETERIORATION PREVENTION General Corrosion & Deterioration Requirements Metallic tank systems in direct contact with the soil or other electrolyte shall be evaluated by a corrosion expert to determine if cathodic protection is necessary or appropriate.

10 CORROSION & DETERIORATION PREVENTION Cathodic Protection Systems Cathodic Protection Systems shall be designed by a corrosion expert and maintained for the life of the tank. Each system should have an access point to check the adequacy of the system.

11 CORROSION & DETERIORATION PREVENTION Coating Exterior Tank and Piping Surfaces Exterior surfaces of tanks and piping shall be protected by a suitable coating that prevents corrosion and deterioration. The coating system must be maintained for the entire operational life of the tank.

12 CORROSION & DETERIORATION PREVENTION Interior Linings and Coatings Interior lining and coatings may be used to protect against corrosion. Coatings must be chemically compatible with the substance stored. Coatings used to protect the bottom of the tank shall extend 18 in. up the sides of tank.

13 CORROSION & DETERIORATION PREVENTION Interior Linings and Coatings This section also has a requirement for periodic inspections by a third-party Department-Certified inspector. This requirement has been waived per Chapter 78a.

14 PA STORAGE TANK ACT Tank Handling Activities (245.21) All tank handling activities conducted on tanks greater than 21,000 gallons must be performed by certified installer. The operation of storage tank facilities shall be inspected by a Department certified inspector.

15 TANK REGISTRATION & FEES Tank Registration & Fees ( & 42) Tank owners must register each storage tank regardless of size. Tanks may not be put into service until it has been properly registered. The registration also serves as the operating permit. Annual registration fees for ASTs: $50 for a tank </= 5,000 gal. $125 for a tank between 5,000 and 50,000 gal. $300 for a tank greater than 50,000 gallons.

16 OPERATIONS AND MAINTENANCE Spill Prevention Response Plan ( ) SPRP shall be submitted to the PADEP for above ground storage tank facilities with an aggregate capacity greater than 21,000 gallons A current copy of the plan should be available at the facility at all times.

17 OPERATIONS AND MAINTENANCE Preventative Maintenance ( ) Owner/Operator should complete a visual inspection every 72 hours of AST system. A routine maintenance inspection should be performed once a month. Inspection records should be kept onsite.

18 OPERATIONS AND MAINTENANCE Security & Signage ( & 515) Owner/Operator must take appropriate security measures to protect the public and environment. Tanks should be labelled/marked in accordance with industry standards

19 OPERATIONS AND MAINTENANCE Record Keeping Requirements ( ) Permanent records should be maintained for the operational life of the tank and retained for a minimum of 1 year after the system has been closed. Records include: inspections, modifications, permits, registrations, closures, etc.

20 CORROSION & DETERIORATION PREVENTION Coating Exterior Tank and Piping Surfaces ( ) Exterior surfaces of tanks and piping shall be protected by a suitable coating that prevents corrosion and deterioration. The coating system must be maintained for the entire operational life of the tank.

21 RELEASE PREVENTION & LEAK DETECTION Overfill Prevention Requirements ( ) Tanks must be installed with a gauge or monitoring device that accurately reads the volume in tank and is visible during product transfer. Must also have a high-level alarm with an automatic shut off or alarm with manual shutoff.

22 RELEASE PREVENTION & LEAK DETECTION Leak Detection Requirements ( ) ASTs shall be monitored for leakage by visual, mechanical or electronic methods. The leak detection method shall be monitored at least monthly and logged. Observation wells outside of secondary containment structure do not satisfy the leak detection requirements. Monthly visual inspections are an acceptable method. Leak tests must be performed by a third party inspector at every in-service inspection until tank is upgraded. Aboveground piping must be visually inspected in accordance with the facility and operations plan.

23 ABOVEGROUND STORAGE TANK INSPECTIONS General Requirements ( ) AST owners must have their storage tank systems inspected by a Department certified inspector at the appropriate frequency based on the type of inspection required: In-service, Out-of-service or Installation/Modification.

24 ABOVEGROUND STORAGE TANK INSPECTIONS In-Service Inspections ( ) In-Service Inspections evaluate: - Containment Areas - Foundation - Tank Shell, Tank Roof - Ancillary Equipment; piping - Leak Detection; Cathodic Prot. - System Integrity, Suitability Inspections must be submitted on PADEP supplied forms with calculations of corrosion rates and life remaining in tank shell and piping. The next inspection interval is based on corrosion with a maximum of 5 years between inspections.

25 ABOVEGROUND STORAGE TANK INSPECTIONS Out-of-Service Inspections ( ) Out-of-Service Inspections evaluate same components as In- Service with addition of: - Tank Bottom - Internal linings/coatings The tank bottom evaluation must be based on ultrasonic testing and one other of nondestructive testing. Inspections must be submitted on PADEP supplied forms with calculations of corrosion rates and life remaining in tank shell and piping. The next inspection interval is based on corrosion with a maximum of 20 years between inspections.

26 CLOSURE & REMOVAL FROM SERVICE REQUIREMENTS Permanent Closure/Change in Service ( ) Owner/operator must submit a 30- day notice of intent to close or change in service. Submit an amended registration form indicating change in tank status. Complete a site assessment to measure for presence of any release from storage tank system. PADEP has a closure guidance document available (July 2017). Submit a closure report documenting closure activities and release results, if any. Any visual or analytical indications of release will trigger remediation Tanks may be closed and removed or left on-site with appropriate signage.

27 SUBCHAPTER G SIMPLIFIED PROGRAM FOR SMALL ASTs Inspection Requirements ( ) Establishes a simplified program for tanks not exceeding 21,000 gallons containing regulated substances. Tank owners/operators storing regulated substances greater than 5,000 gallons or hazardous substances greater than 1,100 gallons shall have in-service inspections conducted at least every 10 yrs.

28 PA STORAGE TANK PROGRAM Updates The PADEP has some changes coming to their Storage Tank Program. December 2017 the changes will be out for public comment. Involves inspections, installations and compliance requirements.

29 WEST VIRGINIA ABOVE GROUND STORAGE TANKS GZA GeoEnvironmental Inc. by Jeffrey Knepper, LRS, CPG July 27, 2017

30 WV AST PROGRAM Recent Changes (HB 2811) Exempt: Tanks having a capacity of 8,820 gallons or less containing brine water or other fluids produced in connection with hydrocarbon production activities, that are not located in a zone of critical concern. Exempt: Tanks having a capacity of 10,000 gallons or less containing sodium chloride or calcium chloride water for roadway snow and ice pretreatment, that are not located in a zone of critical concern. Must all be registered and display proper signage.

31 WV AST PROGRAM Closure Requirements 30 days prior to beginning permanent closure the owner/operator must notify the WVDEP. Closure activities must be supervised by a WV Eng or an API, STI Certified Inspector. The owner/operator must submit a closure plan for review and approval prior to closure. 6 samples must be taken to determine if a release has occurred. Tanks may be cleaned, left onsite and marked closed without being rendered unusable. If tank is in good condition it may be used again but would be considered a new installation.

32 WV AST PROGRAM Closure Requirements Cont d If the intent is to permanently close the tank it shall be cleaned and removed or closed in place by rendering it unusable. A Closure Report must be submitted to the WVDEP no later than 60 days after closure activities are complete.

33 QUESTIONS?

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