This presentation addresses the regulations around underground storage tanks (USTs) and best practices for inspection, testing and removal. Find out whether your UST is regulated and what you need to do to stay compliant.
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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
12.
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
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)
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
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
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
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
42. Thank You For Attending!
Kevin Coulon:
kcoulon@triumvirate.com
Call Us!
1-888-834-9697
www.triumvirate.com
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