Transcript County of San Diego DEPARTMENT OF ENVIRONMENTAL HEALTH
County of San Diego
DEPARTMENT OF ENVIRONMENTAL HEALTH UST and Used Oil Regulations Update Ag Water Quality Research and Education Program Meeting June 15, 2004
Underground Fuel Storage Tanks in Agriculture
June 15, 2004 Lisa Leondis
Abbreviations & Definitions
UST = underground storage tank HMD = Hazardous Materials Division “Farm” a place of agricultural production which has annual sales of agricultural products of $1000 or more.
Exemptions
LG Bulletin 109-1 (7-94) HSC 25281(x) Farm Tanks are exempt from state UST regulations “Farm Tank” means a tank that: • • • • is located on a farm holds < 1100 gal. motor vehicle fuel fuel used primarily for agricultural purposes fuel is not held for resale.
Exemptions
Home Heating Oil Tanks are exempt from state UST regulations “Heating Oil Tank” means a tank: • • • located on a farm or at a personal residence that holds < 1100 gal. of home heating oil which is used consumptively at the premises
Exemptions
Exempt Farm Tanks are not subject to UST installation, operating and closure requirements.
SWQCB maintains authority to require clean up or other pollution prevention measures if the tanks threaten water quality.
There is no exemption from liability.
How to Obtain Exemption
Complete the “Claim of Exemption from Underground Storage Tank Regulations and Law” form.
Submit to HMD at the address on the form.
Provides concurrence that HMD agrees that tank is exempt, may be needed for real estate transactions, lenders, etc.
Loss of Exemption
If the tank is changed to a regulated use: an operating permit must be obtained, or the tank system must be closed in accordance with HSC Chapter 6.7.
Loss of Exemption
If a tank has lost its exemption, do not remove the tank system without a removal permit.
Contact the HMD Duty Desk at 619-338-2231 and request information on UST removal.
A Regulated UST
Regulated USTs
To obtain an operating permit from HMD, tanks must comply with 1998 upgrades: Corrosion protection Spill buckets on fill tubes Overfill prevention Striker plates for “stickable” openings Leak detection for pressurized piping
Regulated USTs
Additional requirements: Secondary containment and testing for tanks, piping and dispensers Annual testing and certification of the monitoring system Monitoring and Emergency Release Plans Certification of Financial Responsibility
Special Concern
USTs within 1000 feet of a public drinking well must use enhanced leak detection with Tracer technology.
Any questions about exempt or regulated USTs so far?
Training Plus Regulations New for USTs May 13, 2004 Sylvia Mosse
Changes, how do we get the word out??
UST Training Plus Regulations •
Effective May 8, 2004
•
Implements training requirements found in SB 989
•
Clarifies double-wall pressurized piping monitoring
•
Addresses materials compatibility and permeability
SB 989 Required Training For: •
UST Owners and Operators
•
UST Service Technicians
•
UST Installers, and
•
UST Inspectors “…..meet minimum industry–established training standards..” HSC 25284.1(a)(4)(A)(i) Adds 23 CCR Section 2715
Owner Requirements:
A signed statement must be submitted to the local agency, which :
•
indicates UST Owner understands and is in compliance with all applicable UST requirements
•
identifies the designated UST operator(s) for each facility owned Any change of the designated operator must be reported to the local agency within 30 days of the change.
Effective January 1, 2005
Designated UST Operator Definition
An individual designated by the owner to have responsibility for:
•
Training facility employees, and
•
Conducting monthly visual inspections The Designated Operator is not considered the UST “operator” as defined in HSC Chapter 6.7, although the same person may hold both positions.
Designated UST Operator Requirements •
Pass the California UST System Operator exam administered by International Code Council (ICC) Effective January 1, 2005
•
Perform monthly visual inspections for each facility and maintain a log Effective January 1, 2005
•
Provide on-the-job training for facility employees Effective July 1, 2005
Designated UST Operator Facility Employee Training: Topics required to be covered: •Operation of the UST system consistent with facility’s best management practices •Monitoring equipment operation and alarm response •Spill/overfills response procedures •Emergency contact information
Effective July 1, 2005
Designated UST Operator ICC UST System Operator Exam •
Access Candidate Bulletin at www.iccsafe.org
•
Promissor testing center in San Diego (Computer based testing center)
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$70.00 cost
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Open book test
•
All required references for the California UST Operator are available for free on the web
Designated UST Operator ICC UST System Operator Exam
Topics
•
20%: Tanks, piping containment, monitoring systems and operation authority
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30%: Operating Requirements
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25%: Release detection
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17%: Record keeping
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8%: release reporting and confirmation
Designated UST Operator ICC UST System Operator Exam
Direct link to all references on our website: http://www.sdcounty.ca.gov/deh/hmd/docs/ust training-requirements-04-30-04.doc
• • • •
California Code of Regulations Title 23 California Health & Safety Code Chapter 6.7
Straight Talk on Tanks EPA 510-B-97-007 Operating and Maintaining UST Systems EPA 510-B-00-008
•
Dollars & Sense EPA 510-K-95-004
Designated UST Operator Monthly Visual Inspection • • •
Review UST Alarm History Inspect Spill Containers and UDC Inspect containment sumps that have had an alarm, no service visit, and check for proper placement of sensors (lowest point).
•
Check to assure that all required testing and maintenance have been completed
•
Verify that all appropriate facility employees have been trained
Designated UST Operator Monthly Visual Inspection Report •
Provide a copy of the report each month to owner or operator
•
Alert the owner/operator of any condition requiring follow-up The owner or operator shall maintain a copy of the report and all attachments for the previous 12 months
Designated UST Operator Facility Employee Training
Definition of Facility Employee
: •
an individual who is employed onsite, and
•
may be called upon to respond to spills, overfills and other UST system problems The “Facility Employee” is not considered the UST “operator” as defined in HSC Chapter 6.7, although the same person may hold both positions.
Designated UST Operator Facility Employee Training
Training Topics required:
•
Operation of the UST system consistent with facility’s Best Management Practices
•
Monitoring equipment operation and alarm response
•
Spill/overfills response procedures
•
Emergency contact information Effective July 1, 2005
Designated UST Operator Facility Employee Training •
Required within 30 days of hire for new employee
•
Must be conducted every 12 months
•
At least one trained facility employee must be present during normal operating hours
•
A list of trained facility employees shall be maintained onsite and include: Training dates Hiring dates for all employees hired after 7/1/05
Frequency of UST Training/Certification •
Designated UST Operators, Service Technicians, Installers, and Inspectors must be re-trained/re-certified every 24 months.
•
Facility Employees must be re-trained annually
23 CCR 2631.1
Compatibility and Permeability
UST Owner/operator must provide local agency with the compatibility and permeability testing results for UST components, upon request.
•
Results to include list of compatible products tested and the measured product permeation rates, if such testing is required by the industry code or engineering standard used to evaluate the component.
Required for new UST system components installed after July 1, 2004
23 CCR 2636 (f) Monitoring of Double-walled Pressurized Piping
Requires automatic line leak detectors for all double-walled pressurized piping
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Mechanical or Electronic LLD can be used
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Added in response to sensor study findings
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Consistent with recent API recommendation Effective November 9, 2004
Monitoring of Double-walled Pressurized Piping
Modifies the annual 0.1 gph piping test equivalent alternative:
•
Requires a continuous monitoring system that:
Stops the flow of the product at the dispenser when a leak is detected within the UDC, and
Provides “fail-safe” pump shut-down when a leak is detected at any other point in the piping system (turbine and transition sumps) Effective May 8, 2004
Monitoring of Double-walled Pressurized Piping
Definition of Fail-safe Monitoring system will shut down the turbine pump in the event of:
•
A power outage
•
When the monitoring system fails or is disconnected
You can find the new regulations (and a whole lot more!) on the SWRCB website: http://www.swrcb.ca.gov/cwp home/ust/
Used Oil Regulations
June 15, 2004 Lisa Leondis
What is Used Oil?
Any oil refined from crude oil, or any synthetic oil, that has been used, and as a result of use or consequence of extended storage, or spillage, has been contaminated with physical or chemical impurities.
What is Used Oil?
Vehicle crankcase oil Engine lubricating oils Transmission fluids Gearbox & differential oils Hydraulic oils Compressor oils Turbine, Bearing & Gear oils Transformer/Electrical oils Refrigeration oils Metal working oils
What is not Used Oil?
Antifreeze, brake fluid, other auto wastes Fuels: gasoline, diesel, kerosene… Grease, Solvents Oils mixed with hazardous waste Oils with >1000 ppm total halogens or > 5ppm PCBs Wastewater with small amounts of used oil Cooking oils
Regulatory Status & Labeling
Used oil shall be managed as a hazardous waste (HSC 25250.4) .
Must be labeled “used oil” Must be stored in tanks or containers Containers and tanks must include the accumulation start date Containers must also include the generator’s name and address, physical state, hazardous properties, and be closed.
Improper Storage of Used Oil & Filters
No labels Open containers Containers in poor condition
Used Oil Container Labeling (a good start)
Used Oil Container Labeling
Portable Tanks
DTSC is working on portable tank regulations.
For the meantime, these are regulated as containers.
Labeling of Tanks
Accumulation (Storage) Time
Used oil may be accumulated on site for 90 to 365 days depending on the total amount of hazardous waste produced by the generator in any given month. 90 days for LQGs (>270 gal. or 2,200 lbs/mo.) 180 days for SQGs (<270 gal. or 2,200 lbs/mo.) or 270 days for SQGs if waste is transported 200+ miles 365 days under satellite accumulation (<55 gal., direct supervision, at the point of generation)
Record keeping
Hazardous waste manifests, disposal records must be kept on site for 3 years.
If self-hauling, keep a record of how much used oil is transported, when, and to what collection center.
For used oil and used oil filters Documents exempt status, if applicable
EPA ID Numbers
All generators of hazardous waste, even if exempt, need to obtain an EPA ID number.
The only exceptions are households, silver only (photographic) waste, and sponsored collection events.
Take application form if you need to obtain an EPA ID number.
Exemptions
Household (do-it-yourselfers) are exempt from regulation, but must take used oil to a used oil collection center.
HMD exempts farms that generate < 5 gal/ month and < 50 gallon per year from obtaining a hazardous materials permit (UPFP) if the used oil is generated incidental to farming operations and is managed/recycled properly.
When is FARM used oil not exempt?
If more than 5 gal/month or more than 50 gal/year are generated, or If 55 gallons or more are accumulated on site a any one time If the used oil generation in not incidental to farming A hazardous materials permit from the HMD (UPFP) must be obtained annually.
Disposal/Transportation Options
Registered Hazardous Waste Haulers – using consolidated manifest Self-Hauling: up to 55 gallons, but make sure the collection center can accept/handle drums Mobile Maintenance Operations – these have their own requirements County of San Diego “CESQG” program – if less than 27 gal. or 220 lbs. of hazardous waste is generated each month, special rates are available. Call our contractor at 800-714-1195.
CESQG Program
Must generate less than 27 gallons or 220 pounds of hazardous waste per month.
Radioactive, infectious, and explosive wastes are not accepted.
Appointments are required.
Call phone number on flyer to get started.
Used Oil Filters
Must be drained of all free flowing oil Labeled as “Drained Used Oil Filters” with initial date of accumulation Stored in rain-proof, non-leaking, tightly sealed containers Up to one ton may be stored for one year Must be recycled (scrap metal)
Universal Waste
CRTs may not be disposed of to landfills must be recycled - see brochure.
Other universal wastes include batteries, fluorescent lamps, non-empty aerosol cans, and many other items.
Businesses are currently regulated.
Household exemptions expire 2-8-06.