Transcript Rhode Island’s Underground Storage Tank Program RI Department of Environmental Management

Rhode Island’s
Underground Storage Tank
Program
RI Department of Environmental Management
Disclaimer
The purpose of this session is to provide you with a
general overview of certain regulatory requirements.
As such, the remarks offered by DEM representatives
are merely intended as opinions, offered to assist you
in understanding how the regulations may be applied
in general. These opinions should not be taken as
attempts to apply the regulations to specific factual
scenarios. They are offered without familiarity with all
of the facts presented by a given situation and,
therefore, you should not act in sole reliance upon the
opinions provided. Specific questions about the
application of environmental regulations to individual
cases should be directed to the Department’s Office of
Technical & Customer Assistance, or to the Office of
Waste Management, UST Section. Nothing said today
should be taken as binding upon the Department;
either the Department’s interpretation of applicable
regulations, or any policy which may have developed
applying those regulations.
What is a UST?
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10% or more of its volume (including piping) is
underground
Holds petroleum product or hazardous material
Also includes holding tanks serving floor drains
Why regulate USTs?
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Small leaks of gasoline or hazardous material
from USTs can contaminate large
groundwater supplies
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Leaks can also create health and fire hazards
in nearby buildings
Program History
First RI UST regulations issued in 1984;
amended in 1985, 1989, 1992, & 1993
 Federal UST rules first issued in 1988;
financial responsibility requirements in 1989
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Purpose of program is to minimize and detect
releases through proper operation and
maintenance of existing facilities; and to prevent
future releases through technical standards for
new installations, replacements, and upgrades
Program History (cont’d.)
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1985 rules required new installations to be corrosion
protected, and continuously monitored; included
alternatives
– required spill and overfill protection
– allowed single-walled tanks and piping
– set upgrade requirement for existing UST systems
Program History (cont’d.)
 1992
rules required all new installations to
use double-walled, corrosion protected
tanks; and piping with continuous
interstitial monitoring
– required registration of commercial heating oil
tanks
 DEM
1992
program received EPA approval in
Program Elements
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UST Registration
Existing System Requirements
– leak detection
– O&M/record-keeping
– abandonment prohibition
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Upgrading Requirements
New/Replacement Tank Standards/Approvals
– tank closure
– cathodic protection
– Interior lining
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UST Professional Certification
Financial Responsibility
Exempted Tanks (partial list)
hydraulic lift tanks
 basement tanks (specific criteria)
 septic tanks
 flow-through process tanks (as defined)
 propane or LNG tanks
 intermittent or fill and draw tanks
 emergency spill protection & overflow tanks
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UST Registration
 Commercial
USTs of any size storing
motor fuel or hazardous materials must
be registered with DEM
– includes waste oil USTs
– includes holding tanks serving floor drains
 USTs
storing fuel oil for heating
commercial facilities must be
registered
UST Registration (cont’d.)
Annual fee- $50 per tank; DEM issues annual
certificate
 Application provides information on tank
system age, construction, contents and
ownership
 DEM must be notified 30 days prior to
proposed transfer of ownership
 Residential tanks 1100 gallons storing fuel
oil for on-site heating are exempt
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Existing System Requirements
 Definition-
existing systems defined
as being in operation prior to
October 31, 1984
–USTs installed in compliance with the
1985 rules must be continuously
monitored, and do not require upgrade
Leak Detection for Tanks (for existing systems)
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Continuous monitoring
– double-walled> interstitial monitoring
– single-walled> approved ATG
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Tightness testing
– schedule based on age of tank
– results must be submitted to DEM
– testers and methods must be certified by DEM
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Must also conduct Daily Inventory and
Monthly Reconciliation
Leak Detection for Piping (for existing systems)
 Double-walled
systems must install
continuous interstitial monitoring
 Single-walled systems
– pressurized systems require annual
tests and line leak detector
– suction systems require testing
schedule based on age
Operation & Maintenance (existing systems)
Monitoring systems must be calibrated and
tested annually, per manufacturer
 Monitoring systems must be operating at all
times
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– any deactivation must be reported immediately
– repair within 15 days, or temporarily close
Records must be kept on-site, unless approval
for an alternate site is obtained from DEM
 Must conform with National Codes of Practice
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Abandonment Prohibition
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Abandonment means the relinquishment or termination of
possession, ownership or control of USTs, by vacating or by
disposition, without meeting the closure requirements...; or
the action of taking a UST or UST system out of operation for
a period of greater than 180 consecutive days without the
prior permission of the Director...
 No
UST may be abandoned- there
are no exceptions
 Extensions
may be granted on a caseby-case basis (temporary closure)
Early Upgrade Requirements
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Spill containment required on all
registered USTs since January 1, 1993
– three gallon capacity
– above-ground fills exempt
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Overfill protection required on all tanks
since January 1, 1996
– fuel oil consumed on-site for heat exempt
– three options- automatic, flow restriction, or
alarm; or equivalent
1998 Upgrade DeadlineCorrosion Protection for
Tanks and Piping
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Options:
– close USTs/replace with new
– cathodic protection
– interior lining- lining only
requires a variance; none yet
granted
 Don’t
wait ‘til 98!
New Tank Standards
Application must be submitted to DEM
 Must be approved before installation
 New UST facilities may not be
constructed in wellhead protection
areas (replacement tanks are allowed)
 Substantial modifications of UST systems
must also be pre-approved
 USTs serving floor drains have special
requirements
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New Tank Standards (cont’d.)
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Tanks must be double-walled, with continuous
interstitial monitoring
Piping must be double-walled, with continuously
monitored containment sump, and tested before
backfilling
UL or ULC listed, National Codes of Practice
Entire system precision tested upon installation
Leak detection system must be approved by DEM,
and maintained properly
Spill containment and overfill protection required
Tank and piping must be compatible with contents
General Approval Process
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Submit scope of work to DEM 30 days in advance
Notify DEM 48 hours prior to installation
Written approval from DEM required prior to
commencement of work (including product
piping replacement)
All work must be performed in accordance with
industry standards
Precision test tank upon completion
Written verification of completion within 15 days
Installation Paperwork
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completed registration application
detailed site plan (plans for new facilities require PE
stamp) including location of:
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all tanks and piping
dispensing units
groundwater monitoring wells
water table elevation
public water supply wells or reservoirs within 400’
facilities served by private wells within 200’
proposed and existing buildings and associated structures
boundaries of the facility
north arrow
Installation Paperwork (cont’d.)
 cross-sectional
view of the tank
– depth of excavation
– bedding thickness
– backfill depth
– supports and anchorage used
– dimensions and thickness of traffic pad
Installation Paperwork (cont’d.)
 Equipment
list and written description
– tank(s)
– piping
– leak monitoring systems
– spill/overfill protection methods
– corrosion protection methods
– operation and maintenance requirements
for any of the above
Post-Installation Paperwork
 for
tank and/or piping replacement,
submit:
–tank tightness test results (tank and
separate line test)
–certification form (available from DEM)
–copy of tank/piping manufacturer’s
installation checklist
Tank Closure
 Closure
of commercial tanks must be
pre-approved by DEM
 $75 application fee
 DEM conducts inspection of excavation
– must schedule closure inspection
 All
releases must be reported
immediately to DEM, local water supply
(if sensitive area), and local fire authority
Tank Closure (cont’d.)
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Residues must be managed appropriately
– must be transported off-site by permitted hazardous
waste transporter
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Tank must be cut/cleaned per Fire Marshal’s
regulations
Closure Assessment report required
– except when fuel oil used solely on-site
– must be performed by PE or CPG
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Closures-in-place only approved under special
conditions
Cathodic Protection
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Required for both tanks and piping
Impressed current or sacrificial anode systems allowed
Internal inspection must be performed or certified by
NACE corrosion expert- no alternatives at this time
Upgrade must be designed by same
– DEM requires work scope and design to be submitted with
NACE certification
– list of equipment/materials/warranties
– site plan
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Precision tested upon completion
Submit as-builts, test results and affidavits within 15 days
Cathodic Protection O&M
Systems must be operated, maintained,
and inspected in accordance with National
Codes of Practice
 Precision testing schedule is not affected by
installation of corrosion protection unless
continuous monitoring is installed
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– upgraded USTs can use tightness testing and
inventory control for ten years after date of
upgrade
Cathodic Protection O&M (cont’d.)
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Must be tested by qualified cathodic protection
tester within six months of installation, and at
least every three years following
Also must be tested whenever construction or
maintenance in the area of the structure occurs
Impressed current systems must also be
inspected every 60 days to ensure equipment is
running properly, and tank-to-soil potential
reading relative to copper is -850 millivolts, or
more negative
After Installing Cathodic Protection
submit tank tightness test results
 assessment of the structural soundness of
the tank
 post-construction as-built drawings which
include:
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– location of all tanks and dispensers
– materials of construction
– piping layout
– wiring schematic
– products stored
After Installing Cathodic Protection (cont’d.)
 Submit
post-construction data re:
– tank-to-soil potentials
– pipe-to-soil potentials
– dielectric isolation
– foreign structure-to-soil potentials
– test coupons
– permanent reference electrodes
Interior Lining
DEM only accepts direct internal inspection,
per API 631, NLPA 1631- no alternatives
 New ASTM standards are not acceptable
 Must submit proposal which outlines scope of
work, including:
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– list of equipment/materials/warranties
– site plan
– qualification of person who is applying the lining
– method of evaluating the tank interior
After Interior Lining submit
tank tightness test results
 assessment of the structural soundness
of the tank
 summary of the testing of the lining
material
– holiday testing
– barcol hardness
UST Professional Certification
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Individuals who conduct precision tests must now be
licensed by DEM
Installers must be licensed by RI Dept. of
Labor/Division of Professional Regulation, and
certified by applicable equipment manufacturers
DEM encourages voluntary efforts by UST installers,
removers, and corrosion protection experts to obtain
certification from a non-profit testing agency- the
International Fire Code Institute
– we hope to make this certification mandatory
UST Financial Responsibility
Commercial gasoline USTs, and some
others, must demonstrate financial
responsibility for managing releases
 Several allowable mechanisms, including a
financial test and private insurance
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UST Financial Responsibility (cont’d.)
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Another mechanism, a state UST FR Fund, was
established by the General Assembly in July 1994
Program is not yet operating- will reimburse eligible
costs related to investigation and remediation of UST
releases
USTs must be in compliance with UST rules
$20,000 deductible; $1,000,000 coverage
Rules to be promulgated by UST Fund Review Board
– draft is now available from the Board
Hazardous materials USTs not eligible
Questions and Answers
 What
type of electronic monitoring is
required for piping replacement only?
–The tank top piping sump is required
to be continuously monitored, for both
pressurized and suction systems.
–Heating oil consumed on-site for
heating purposes is exempt.
Questions and Answers (cont’d.)
When is the continuous electronic monitoring
system required to be activated?
– Prior to commencing regular UST
operation.
 Can existing steel piping be upgraded?
– Not really. Existing unprotected steel piping
should be replaced with new compliant
piping (USTs holding fuel oil for on-site
heating purposes only are exempt).
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Final Thoughts
Expecting
an extension to
the 1998 deadline?- Forget
about it!
Pursue IFCI certification
Any questions? Call us at222-OTCA (6822)
Tom Epstein- ext. 7501
fax 222-3810
UST Program
222-2797
Greg Yekhtikian- ext. 7521
fax 222-3813
or visit the
Office of Technical & Customer Assistance
at our new home-
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235 Promenade Street
Providence, RI 02908
first door on left from the
Beach Street entrance