Massachusetts Department of Environmental Protection Underground Storage Tank Program Tom DeNormandie, Chief Underground Storage Tank and Stage I/II Branch 2016 New England Storage Tank Conference Westborough, Massachusetts October 5, 2016 www.mass.gov/eea/agencies/massdep/toxics/ust/
March 2016 UST Program Implementation Overview Online UST Data Management System Third-Party Inspections Compliance Certifications Record Keeping Important 2017 Compliance Dates 2
October 2016 Where Are We Now And What s Ahead? UST Program By The Numbers UST Data Management System Most Frequent DEP Field Violations Most Frequent TPIR Violations Fall 2016 2017 Compliance Deadlines January 2, 2017 UST Testing and Stage II Decommissioning Deadlines August 7, 2017 SWST Removal/Closure Deadline 3
UST Data Management System As of September 30, 2016: Total # of Registered Users : 2,300 Total # of Authorized Signatories: 1,200 Total # of Third-Party Inspectors: 70 Total # of submittals: 14,000+ Total # of TPIRs: 2,100 TPIR RTC Completion Reports: 300 Changes of Ownership: 550 Compliance Certifications: 425 NONs for failure to submit: 625 RPANs for failure to comply with an NON: 100 4
Most Frequent DEP Field Violations Sump sensors not installed in accordance with manufacturer guidance or at the lowest possible location. Failure to keep spill buckets and sumps free and clear of solid and liquid material at all times. Failure to keep electronic or hard copy records. - Monthly Inspection Reports - Leak detection monitoring reports - FR Certification of Financial Responsibility - Tank designations of A/B Operators Posting of emergency response procedures and labeling of high level alarms. 5
Most Frequent Third-Party Inspection Report Non- Compliance Resulting In A Return to Compliance Plan Category % TPIR Questions Answered No Registration 50% Monthly Visual Inspections 12% - Record Keeping. - Did qualified person perform inspection? A/B Operator 10% - Operators certified and trained. - A, B, C Operator designated for each UST System. - Recordkeeping. - Operator present at time of TPI inspection. Leak Detection 11% - Annual system testing. - Record Keeping. Financial Responsibility 8% Overfill Prevention 4% - Primary overfill correctly installed, operating, and labelled. - Annually inspected and tested. Signage 3% Spill Buckets 2% - Free of solid and liquid material, cracks and holes, sensor correctly set. - Records keeping. Corrosion Protection 2% - Regular/annual system testing. - Record keeping. Facilities With RTC Plans For The Following: No spill buckets 3 No overfill 14 No corrosion protection 10 No leak detection 22 No Financial Responsibility 64 6
Fall 2016 Annual Third-Party Inspector Training - December 8 th in Worcester and December 14 th in Boston - Time and Length: To Be Determined - TPI Attendance Required (No webinars) MassDEP Online Third-Party Inspector Exam Available (1 of 5 Required Exams To Become a Certified TPI) - Will Start The Clock For Existing Third-Party Inspectors to Recertify. - Online Exam and Guidance Materials Will Be Available When Annual Third-Party Inspector Training Formally Announced. 7
2017 Compliance Deadlines January 2, 2017 Stage II Decommissioning and Stage I Component Upgrades. UST Testing of Spill Buckets And All Turbine, Intermediate and Dispenser Sumps. August 7, 2017 All Single-Wall Steel Tanks Must Be Removed or Closed In- Place. 8
Single-Wall Steel Tanks (SWSTs) Come January 2, 2017 - Do You Want to Keep SWST In-Use? If Yes, You: Do Not Need to Decommission Stage II System or Install EVR Stage I Components. Must Comply With Applicable Sump and Spill Bucket Testing Requirements, and All Other Applicable UST Program Requirements; and Must Remove or Close In-Place SWST on or before August 7, 2017. - Owner/Operators of SWST that are Out-of-Service on or before August 7, 2017, and have submitted to MassDEP, on or before August 7, 2017, a signed contract for the removal/ closure in-place of the SWST, may complete removal/closure of the SWST on or before July 1, 2018. 9
Single-Wall Steel Tanks (cont.) If No, or You Want To Avoid Stage II Decommissioning and Sump and Spill Bucket Testing Costs: You Can Remove or Close Your SWST In-Place On or Before January 2, 2017, and Not Be Subject To The Following Requirements: - Decommissioning Your Stage II System; and - Performing Sump and Spill Bucket Testing; Or, You Can Take Your SWST Out-of-Service On or Before January 2, 2017, and Be Exempt From The Following Requirements Until The SWST Is Removed/ Closed In-Place: - Decommissioning Stage II System and Installation of Stage I Components; - Performing Sump and Spill Bucket Testing; - Operating and maintaining cathodic protection; and - Submitting Third-Party Inspection Reports or Compliance Certifications 10
Single-Wall Steel Tanks (cont.) Owner/Operators Taking A SWST Out-of-Service Must: Remove All Solid And Liquid Material And Inert The UST System; Cap, Lock and Secure All Fill Lines and Pipes; Keep Vent Lines Open and Operable; Maintain Financial Responsibility; Update UST Registration in DMS Within 30 Days of Taking SWSTs Out-of- Service; and Remove or Close In-Place SWST on or before August 7, 2017. - Owner/Operators of SWST that are Out-of-Service on or before August 7, 2017, and have submitted to MassDEP, on or before August 7, 2017, a signed contract for the removal/ closure in-place of the SWST, may complete removal/closure of the SWST on or before July 1, 2018. 11
All Other USTs and ASTs Come January 2, 2017, Do You Want to Keep Your UST or AST In-Use? If Yes, You Must: Comply with applicable sump and spill bucket testing requirements; and Decommission Stage II System and Install EVR Stage I Components. 12
All Other USTs and ASTs (cont.) If No, or You Want To Defer Stage II Decommissioning and Sump and Spill Bucket Testing Costs, On or Before January 2, 2017, You Can: Take the UST or AST Temporarily Out-of-Service In Accordance With Applicable Requirements; and Update UST and Stage I Registration Within 30 Days, Documenting Tank Status. 13
All Other USTs and ASTs (cont.) All Other USTs and ASTs Temporarily Out-of-Service, On Or Before January 2, 2017, Are Not Subject To: - Decommissioning Stage II Systems and Installing EVR Stage I Components; and - Performing Sump and Spill Bucket Testing. - All other Applicable UST Program Requirements Apply. Prior to Returning to Service, All Other USTs and ASTs Taken Temporarily Out-of-Service On or Before January 2, 2017, Must: - Decommission The Installed Stage II System and Install Required EVR Stage I Components; and - Perform Required Sump and Spill Bucket Tests. - All Other Applicable UST Program Requirements For Returning a UST System To Service Apply. 14
UST Program Contact Information Have questions? Need assistance? Call the UST Hotline at 617-556-1035, Ext. 2 or email: DEP.UST@state.ma.us www.mass.gov/eea/agencies/massdep/toxics/ust/ 15