EPA UST Regulations Update May 22, 2018

Similar documents
SPCC Regulation Integrity and Leak Testing Methods

Lorri Grainawi Steel Tank Institute. PA NISTM April 25, 2013 Harrisburg, PA

Mark S. Morgan, Regulatory Counsel

Changes to EPA s AST & UST Rules. Mott-Smith Consulting Group, LLC

Overview of Revisions to the Federal Underground Storage Tank (UST) Regulations. Storage Tank Advisory Committee Harrisburg, PA September 1, 2015

OKLAHOMA CORPORATION COMMISSION PETROLEUM STORAGE TANK DIVISION THE ABC S OF AST S AN OVERVIEW OF ABOVEGROUND STORAGE TANK REQUIREMENTS

Changes to EPA s AST & UST Rules. Mott-Smith Consulting Group, LLC

Monthly Walkthrough Inspections

FINAL UNDERGROUND STORAGE TANK RULE CHANGES. Heather Peters UST Compliance and Technology Unit

New UST Regulations. What follows are the changes to EPA s regulations that TMS believes impacts you, the owner/operator, the most.

New Regs Get Ready for Containment Testing if You Haven t Done So Already!

Changes to Chapter , Florida Administrative Code Underground Storage Tank Systems (USTs) Effective 1/11/2017

Questions And Answers About The 2015 Underground Storage Tank Regulation As Of May 2017

(Please type or use black ink)

Operational Compliance Closure/Release Response/Corrective Action at Underground Storage Tank Facilities

P.O. Box 435 Saratoga Springs, NY 12866

Management of Underground Storage Tanks

North Carolina Department of Environment and Natural Resources Division of Waste Management Underground Storage Tank Section

PEI/RP Recommended Practices for the Inspection and Maintenance of UST Systems

Semiannual Report Of UST Performance Measures End Of Fiscal Year 2018 (October 1, 2017 September 30, 2018)

Operating And Maintaining Underground Storage Tank Systems UPDATED Practical Help And Checklists. Printed on Recycled Paper

Operating And Maintaining Underground Storage Tank Systems. Practical Help And Checklists. Printed on Recycled Paper

Test Date: 3/30/2018 Order Number: Dear Regulator, Enclosed are the results of recent testing performed at the following facility:

6. Tanks - Leak Detection. NCDENR Division of Waste Management Underground Storage Tank Section

401 KAR 42:020. UST systems: design, construction, installation, and registration.

OKLAHOMA CORPORATION COMMISSION PETROLEUM STORAGE TANK DIVISION THE ABC S OF UST S AN OVERVIEW OF UNDERGROUND STORAGE TANK REQUIREMENTS

ANNUAL UST SYSTEM INSPECTION CHECKLIST

Underground Storage Tank. City of Burbank UST Owners & Operators

Operating And Maintaining Underground Storage Tank Systems. Practical Help And Checklists. Printed on Recycled Paper

Understanding the Colorado Annual Compliance Package. William Holman & Robert Schlegel Inspectors Division of Oil and Public Safety

Compliance Strategies and Benefits

EPA REGULATORY UPDATE PEI Convention at the NACS Show October 8, 2018 Las Vegas, NV

Provide the following information: Site Address: City: Zip: Project Contact Name: Phone No.: ( ) ext.

Grant Guidelines To States For Implementing The Secondary Containment Provision Of The Energy Policy Act Of 2005

BUREAU OF UNDERGROUND STORAGE TANK REGULATIONS RELEASE PREVENTION SECTION

Overview of an Underground Storage Tank Inspection

Recommended Practices for the Testing and Verification of Spill, Overfill, Leak Detection and Secondary Containment Equipment at UST Facilities

INTEGRITY TESTING OF CONTAINMENT SUMPS AND SPILL BUCKETS PEI RP1200

Underground Storage Tank Annual Compliance Inspection (Revised 1/2015)

CONTRACTOR S SELF-INSPECTION CHECKLIST for UST INSTALLATION REPLACEMENT UPGRADE RETROFIT REPAIR

Compliance Strategies and Benefits. Brian Derge Tanknology Inc. December 6, 2012

New UST Installation Inspection Checklist

THE KEY RELATIONSHIPS BETWEEN FIRE CODES, NEW YORK AST REGULATIONS AND SPCC PLANS

Underground Oil Storage Tanks Annual Inspection Report

County of Yolo UNDERGROUND STORAGE TANK PROGRAM INSTALLATION/MODIFICATION/REPAIR APPLICATION

How a UST Site May Become Contaminated -- Even When The Leak Detection is Passing

Inspector's Initials: Tank Owner or Agent Signature: Title: Date:

UNDERGROUND STORAGE TANK INSPECTION CHECKLIST

Petroleum Storage Tank Release Detection and Inventory Control

Frequent Mishaps and Solutions with Regulated Underground Storage Tanks in Pennsylvania

UNDERGROUND STORAGE TANK (UST) INSTALLATION & MAINTENANCE

New Tank Installations. Peter Rollo

FACTS ABOUT: MARYLAND CONTAINMENT SUMP TESTING PROTOCOL WHO CAN PERFORM THE TEST

2018 UST Regulation Revision Comment Worksheet

Update for Ohio BUSTR Class A and B UST Operator Training New regulations UST operations. Robert J May PE Synergy Environmental April 2018

NCDEQ Underground Storage Tank Section

NYSDEC PBS REGULATIONS Heating Oil Tanks

UST Compliance Assistance Handbook

General information about underground storage tank (UST) fueling systems in every day language.

Seneca News - Q In Review

LEAK DETECTION INTERSTITIAL MONITORING

Notification for Underground Storage Tanks

Massachusetts Department of Environmental Protection Underground Storage Tank Program

Application for Permit to Install Underground Storage Tanks (Petroleum or Hazardous Substances) 1. Owner Information 2. Installation Site Information

Focus on the engineering & permitting requirements for installing a new fuel facility at the Port of Olympia;

NEIWPCC-Defender Spill Containment. Interstice Monitoring-Testing - Maintenance

Underground Storage Tank Certification Examinations. Presentation to ASTSWMO November 27, 2007 UST SYSTEM OPERATOR CERTIFICATION

Stage I Vapor Recovery Testing

EQUIPMENT PERFORMANCE SPILL PREVENTION AND PIPING KEVIN HENDERSON

REVISOR CKIWru. t.tz 42, section 692L et seq.; or. A. system holding: (! a mixture of such hazardous waste and other regulated substances; {!

Leak Detection for Petroleum UST and Piping

UST Program Overview. NISTM Conference June 17, Mark Barolo EPA, Office of Underground Storage Tanks

7. UST Piping Corrosion Protection. NCDENR Division of Waste Management Underground Storage Tank Section

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

DEFENDER SERIES. 5 Gallon, Double Walled, Field Replaceable Spill Container Model Series INSTALLATION, OPERATION, & MAINTENANCE

Preventing Leaks and Spills at Service Stations. A Guide for Facilities

PEI/RP Recommended Practices for Installation of Bulk Storage Plants

Defender Series. Overfill Prevention Valve. Automatic Shutoff for USTs. Installation, Operation and Maintenance Series

Changing Industry. UST Population (Ohio) Number of Tanks. Year 60,000 50,000 40,000 30,000 20,000 10,000

LOW LEVEL SUMP TESTING ORIGINS

TITLE 165. CORPORATION COMMISSION CHAPTER 25. UNDERGROUND STORAGE TANKS RM PROPOSED RULES NOVEMBER 30, 2015

Environmental Regulations and Codes For Underground Tank Storage of Flammable & Combustible Liquids

Safe Operating Procedure

How to Stop Spill Buckets from Draining You Dry

UST General Requirements Inspection Checklist

Code Requirements for ASTs at Motor Vehicle-Dispensing Stations

The VST Enviro-Loc Vapor Recovery System

This handbook is provided as a general guide. assistance/content/storage-tank-compliance

CONTENTS. Foreword...iii. 1. Introduction...1

Pennsylvania DEP: Maintaining UST Compliance and Regulation Updates. NISTM 8 th Annual Pennsylvania Storage Tank Conference May 18, 2017

40 CFR 63, Subpart CCCCCC

Sunoco, Inc Market Street LL Philadelphia, PA June 29, 2006

Syracuse University Petroleum Bulk Storage Tank Program Manual

Underground Storage Tank Guidance for Commercial Building Inspectors

ES Fueling Aircraft, Vehicles, and Auxiliary Equipment Document Identification Number

PETROLEUM PRODUCT STORAGE TANK REGULATION SAFETY AND BUILDINGS DIVISION BUREAU OF PETROLEUM INSPECTION AND FIRE PROTECTION

Management of Underground Storage Tanks

Aboveground Tank Equipment. Presenter: Steven Allwein Northeast Regional Sales Manager Morrison Bros. Co.

Code Requirements for ASTs at Motor Vehicle-Dispensing Stations

COLORADO DEPARTMENT OF LABOR AND EMPLOYMENT DIVISION OF OIL AND PUBLIC SAFETY STATISTICAL INVENTORY RECONCILIATION (SIR) GUIDANCE DOCUMENT

Transcription:

EPA UST Regulations Update May 22, 2018

Founded in 1988, Tanknology has grown to become one of the largest testing and inspection service companies in the world. Our fleet of 150 vehicles provides service in all 50 states domestically, and we have a presence in more than 30 countries with international licensees. We hold 22 patents covering our test equipment and various leak detection methodologies.

Headquartered in Austin, TX 8 Strategically Located Regional Offices: Southern California Northern California Georgia Illinois Minnesota Ohio Philadelphia Texas Our regional operating structure empowers us to provide clients with the best customer experience.

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