EPA UST Regulations Update May 22, 2018
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Background 40 CFR 280, the regulated UST community as of October 13, 2015 is required to..
State Program Approval
Deadline Dates per EPA October 13, 2015 Fuel Compatibility greater than e10 and b20 considered alternative fuel proof of Repairs must test within 30 days ATG Alarm investigation No new ball float valves must install flapper valves or external audible alarm April 11, 2016 New UST systems must have secondary containment with interstitial monitoring Dispensers require containment and in most cases monitoring October 13, 2018 30 day Walkthrough Inspections Release Detection every 30 days Annual Sump Inspections Functionality Testing ATG(1), Spill Bucket & Overfill(3), Sumps with IM(3) EG (Emergency Generator) Tanks no longer deferred (field constructed, airport hydrant, etc.)
How Do We Do All This New Stuff?? https://www.epa.gov/ust/underground-storage-tankust-technical-compendium-about-2015-ustregulations
Tanknology Tracking Mechanism
The should be doings..
280.33 Repairs allowed (d) Repairs to secondary containment areas of tanks and piping used for interstitial monitoring and to containment sumps used for interstitial monitoring of piping must have the secondary containment tested for tightness according to the manufacturer's instructions, a code of practice developed by a nationally recognized association or independent testing laboratory, or according to requirements established by the implementing agency within 30 days following the date of completion of the repair. All other repairs to tanks and piping must be tightness tested in accordance with 280.43(c) and 280.44(b) within 30 days following the date of the completion of the repair except as provided in paragraphs (d)(1) through (3) of this section (f) Within 30 days following any repair to spill or overfill prevention equipment, the repaired spill or overfill prevention equipment must be tested or inspected, as Appropriate, in accordance with 280.35 to ensure it is operating properly
280.50 Reporting of suspected releases Alarm investigation Owners and operators of UST systems must report to the implementing agency within 24 hours, or another reasonable time period specified by the implementing agency, and follow the procedures in 280.52 for any of the following conditions: (a) The discovery by owners and operators or others of released regulated substances at the UST site or in the surrounding area (such as the presence of free product or vapors in soils, basements, sewer and utility lines, and nearby surface water). (b) Unusual operating conditions observed by owners and operators (such as the erratic behavior of product dispensing equipment, the sudden loss of product from the UST system, or an unexplained presence of water in the tank), unless system equipment is found to be defective but not leaking, and is immediately repaired or replaced; and, (c) Monitoring results from a release detection method required under 280.41 and 280.42 that indicate a release may have occurred unless: (1) The monitoring device is found to be defective, and is immediately repaired, recalibrated or replaced, and additional monitoring does not confirm the initial result; or (2) In the case of inventory control, a second month of data does not confirm the initial result.
Testing Criteria Tank Secondary PEI RP 1200 Recommended Practices Tank Annular Testing Dry Interstice FG or Steel Tank, pull 10 hg respectively, hold for one to two hours depending on tank size, zero loss and interstitial space must be dry to pass. Only required at Post-Construction or Tank Repair Unusual operating condition liquid in tank secondary not used for monitoring or does not render IM inoperative
Testing Criteria Lines and Sumps PEI RP 1200 Recommended Practices Line Annular Testing Line secondary must hold 5 psi with zero loss for one hour to pass Only required at Post-Construction or Tank Repair Sump / UDC Testing Fill Sump up 4 above the highest penetration point or sidewall seam, pass/fail criteria ~1/8 after one hour Required every 3 years for sites utilizing IM as their method of release detection
What does all this mean?
Sump Testing - Sidewall Seam
Sump Testing - Sidewall Seam
Low Level Sump Testing PEI RP 1200 not recognized, EPA does in its Compendium A liquid level sensor is mounted at the lowest point in the sump and a periodic test is performed by adding liquid to a point that will ensure activation of the sensor*; and The pump automatically shuts off when product activates the sensor, or The dispenser automatically shuts off when product activates the sensor, and the facility is always staffed when the pumps are operational. Alabama & IL have state procedures
Testing Criteria Buckets and Ancillary Equipment PEI RP 1200 Recommended Practices Spill Bucket hydro at 1.5 below top of bucket or 30 wc with vac Required every 3 years Overfill Device remove, measure and functionality test Required every 3 years Impact Valve located +/-.5, exercise lever arm, ensure no fuel flow Required annually ATG Equipment remove and functionality test in proper medium Required annually
Containment Sumps Maintenance v. Repair
Containment Sumps Repair v. Preventative Maintenance
Spill Buckets unusual? Spill/Overfill containment bucket(s) filled with water/product mixture.
Drop Tubes - Overfill Functionality Testing Proper Form Remove or not to remove? 95%? Stage I/II Pressure Decay Weep holes Vapor leaks grade or overfill device Highest cut to tank bottom Ball Float?
Drop Tube Options? Overfill prevention equipment that will: (A) Automatically shut off flow into the tank when the tank is no more than 95 percent full; or (B) 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 (C) Restrict flow 30 minutes prior to overfilling, alert the operator with a high level alarm one 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.
Impact Valves EPA considers a dispenser system new when owners and operators install both the dispenser and equipment needed to connect the dispenser to an UST system. EPA includes check valves, shear valves, unburied risers or flexible connectors, and other transitional components as equipment that connects a dispenser to an UST system. This equipment is located underneath the dispenser and typically connects underground piping to a dispenser. If an owner or operator replaces a dispenser but uses existing equipment to connect a dispenser to the UST system, then UDC is not required.
Impact Valves line test Ongoing Functionality Testing primarily NFPA 30 related Exercise v. test May or may not be required per state regulations Regulations vague, release detection equipment? Repair v. replace With secondary containment, annual line testing less likely to be performed
Interstitial Monitoring Equipment Replace v. Repair v. As Found - how to investigate 7 inches
Visual Inspection Results Example: Excessive corrosion on metallic parts in contact with soil and water. Example: Line Leak Detector Removed and Deactivated From monitoring system.
Recordkeeping the new normal Be Prepared Have the Proper Paperwork Record Keeping and Storage on-site or on-line, make it accessible and audited routinely(b operator type) Maintenance records Alarm Management and Response Required Test Results Annual and Maintenance Related UST Registration 30 Day Leak Detection, i.e. CSLD Results A/B/C Operator Training Certificates
Last word of caution We don t know what we can t see
Thank you Charles Karling 614-436-7600 ckarling@tanknology.com