Underground Storage Tanks
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The webinar discusses regulatory requirements for underground storage tanks (USTs), focusing on inspection, monitoring, and closure processes, particularly changes in regulations over time. It aims to educate environmental health, facilities, and property managers on compliance with federal and state standards, including deadlines for removal of single-walled tanks. Participants will learn about UST construction, leak detection options, and the necessary steps for proper tank removal or closure.
Underground Storage Tanks
- 1. What the Regulatory Requirements Mean for Your UST. Underground Storage Tanks:
- 2. Meet Your Moderator: James Ciccone
- 3. All lines will be muted – please communicate via the questions tab in your webinar panel. There will be live, interactive polling. There will be a Q&A session at the end of the presentation – submit your question(s) anytime throughout the webinar. Stick around for an exclusive offer at the end of the webinar. Webinar Overview
- 4. Meet Your Presenter: Kevin Coulon
- 5. Our Key Message Understand the requirements that come with having a UST on your property
- 6. Who Is This For? EHS Managers Facilities Managers Property Managers
- 7. What Will You Learn? How the Regulations have Changed UST Inspection Requirements How to Remove a UST
- 8. Poll Question What is your greatest challenge regarding USTs?
- 9. Agenda UST Overview & Regulations Monitoring & Testing Closure & Removal Summary/Q&A
- 10. What is a UST? As defined by Subtitle I in 40 CFR 280: Tank system, including its piping, that has at least 10% of its volume underground.
- 11. Federal UST Programs Subtitle I Standards • 40 CFR 280 – Technical • 40 CFR 280 State program approval Subtitle C • Amends 40 CFR 260, 261, 262, 265, 270 and 271 https://www.epa.gov/ust
- 13. Compliance Schedule • Phase-in of release detection for all existing tanks over a five-year period according to age (1989-1993) • Add release detection to pressurized product piping systems by December 22, 1990 • Upgrade or replace as per new standards within ten years (December 22, 1998)
- 14. State Compliance Schedule • MA compliance date for removal of all single walled UST – August 7, 2017 • RI compliance date for removal of all single walled UST – December 22, 2017 • CA compliance date for removal of all single walled UST – December 31, 2025
- 15. Inspection Requirements • USTs that have not been inspected since 1998 had to be inspected initially within 2 years of Federal Energy Bill (Aug. 2007) • Periodic inspections must occur every 3 years thereafter (initially by August 8, 2010) This is a minimum requirement Must be inspected by: EPA inspector, state agency inspector, inspector or contractor duly designated by the state, or a private inspector operating under a 3rd party inspection program paid for by the owner or operator • Operator must perform leak detection tests monthly
- 16. Tank Requirements • Corrosion resistant single-wall • Spill and overfill prevention Prevention of transfer hose disconnection spills – catchment basin Overfill prevention – either auto shut-off at 95% or operator alert at 90% full • Release detection • Proper installation standards
- 17. Exclusions Under Subtitle I • Farm or residential tanks of 1,100 gallons or less capacity storing motor fuel for noncommercial purposes • Tanks storing heating oil for consumptive use on the premises where stored • Septic tanks • Pipeline facilities (including gathering lines) regulated under the Natural Gas Pipeline Safety Act of 1968, the Hazardous Liquid Pipeline Act of 1979, or state laws comparable to these Acts • Surface impoundments, pits, ponds, and lagoons
- 18. Exclusions Under Subtitle I • Stormwater or wastewater collection systems • Flow-through process tanks • Liquid traps or associated gathering lines directly related to oil or gas production and gathering operations • Storage tanks situated on or above the floor of underground areas, such as basements and cellars
- 19. Major Provisions Under Subtitle I • 9002 – Owner must notify state of UST existence • 9003 – EPA must promulgate regulations applicable to all owners; issue design, construction, installation, and compatibility standards for new tanks, as well as requirements applicable to all tank owners and operators concerning leak detection, recordkeeping, reporting, closure, corrective action, and financial responsibility • 9003(h) – gives states authority to clean-up petroleum releases or require the owners/operators to do so • 9004 – authorizes states to implement stricter regulations
- 20. Agenda UST Overview & Regulations Monitoring & Testing Closure & Removal Summary/Q&A
- 21. How often do you inspect your UST? Poll Question
- 22. Cause of Release • Most releases come from the pipe, not the tank itself • Filling is the greatest cause Spilling Overfilling • Corrosion, poor workmanship, natural events and accidents are the main reasons for pipe failure
- 23. Tank Tightness Testing 25% of UST systems are found to be “non-tight” when testing under today’s standards Loose tank fittings and faulty piping account for 84% of these failures
- 24. Pre-Existing Tanks • Most existing tanks are bare steel (dating back before 1998) • New technology STI-P3 (industry standard) Electrical isolation Protective coating Cathodic protection (galvanized) FRP(fiberglass reinforced plastic)
- 25. Monitoring & Leak Requirements Leak detection Corrosion protection Spill/overfill prevention
- 26. Leak Detection: 3 Choices 1. Monthly monitoring 2. Monthly inventory control and 5- year tank tightness testing on tanks with overfill and corrosion protection (only until 1998 or 10- years old) 3. Monthly inventory control and annual tank tightness testing (only until 1998)
- 27. Leak Detection Alternatives • Inventory reconciliation • Automatic Tank Gauging (ATG) • Subsurface monitoring (vapor and ground water) • Interstitial monitoring off double-wall tank systems and secondary containment
- 28. Automatic Tank Gauging Detection accuracy of .2GPH Monthly inventory control must be used
- 29. Continuous Statistical Leak Detection • Monitors fuel height and temperature during idle times • Uninterrupted business for 24-hour stations or around the clock fueling operations • Automatic leak test every 24 hours • Meets federal and state requirements for monthly monitoring
- 30. Monitoring Wells Installed in backfill area as close to tank as possible Vapor or ground water monitoring
- 31. Cathodic Protection • Galvanized Uses a sacrificial anode • Impressed Uses a junction box to circulate current • Must be tested every 3 years
- 32. Agenda UST Overview & Regulations Monitoring & Testing Closure & Removal Summary/Q&A
- 33. Closure by Removal: Preparation • Submit closure request and plan to regulatory agent • Health and safety plan • DIG SAFE • Electrical • Barricades and set up • Permits (fire, trench, etc.) • Shoring, trench boxes
- 34. Closure by Removal: Cleaning • Dry ice procedure • Nitrogen purge • Water rinsing • Venturi purge • Triple rinse • Chemical cleaning • Tank entry (CSE) • Include piping
- 35. Closure by Removal: Access • Excavate around tank for access • Dismantle accessible piping and ancillary equipment • Use proper equipment • Tag and label • Plug opening, except 1/8” vent • Inspect tank and piping
- 36. Soil Excavation • Excavate soil around tank Typically 1-2’ around and below • Sample soil and consider a fast turn around for evaluation Dispose of soil according to contamination or clean procedures
- 37. Closure in Place • Only recommended if removal is not an option Can affect the structure of a building • Backfill tank with inert material Concrete Approved poly-foam material Pea gravel (under 1,000 gal.) Sand Slurry
- 38. Agenda UST Overview & Regulations Monitoring & Testing Closure & Removal Summary/Q&A
- 39. Our Key Message Understand the requirements that come with having a UST on your property
- 40. Summary Find out if your tank is state/federally regulated Know your state’s UST testing requirements Understand that there is a process for removing USTs Know who needs to be involved and what each individual’s role is
- 41. QUESTIONS?
- 42. Thank You For Attending! Kevin Coulon: [email protected] Call Us! 1-888-834-9697 www.triumvirate.com • You will receive an email tomorrow with a copy of this presentation • Please complete our short survey • Request a Free Onsite Consultation: http://info.triumvirate.com/ust-webinar-offer