Underground Storage Tanks

What the Regulatory Requirements

Mean for Your UST.

Underground

Storage

Tanks:

Meet Your Moderator:

James Ciccone

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Webinar Overview

Meet Your Presenter:

Kevin Coulon

Our Key Message

Understand the requirements that

come with having a UST on your

property

Who Is This For?EHS Managers

Facilities Managers

Property Managers

What Will You Learn?

How the Regulations have Changed

UST Inspection Requirements

How to Remove a UST

Poll Question

What is your greatest

challenge regarding

USTs?

Agenda

UST Overview & Regulations

Monitoring & Testing

Closure & Removal

Summary/Q&A

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.

Federal UST ProgramsSubtitle 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

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)

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

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

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

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

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

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

Agenda

UST Overview & Regulations

Monitoring & Testing

Closure & Removal

Summary/Q&A

How often do you

inspect your UST?

Poll Question

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

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

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)

Monitoring & Leak

Requirements

Leak detection

Corrosion protection

Spill/overfill prevention

Leak Detection: 3 Choices1. 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)

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

Automatic Tank Gauging

Detection accuracy of

.2GPH

Monthly inventory control

must be used

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

Monitoring

WellsInstalled in backfill area

as close to tank as

possible

Vapor or ground water

monitoring

Cathodic Protection• Galvanized

Uses a sacrificial

anode

• Impressed

Uses a junction box

to circulate current

• Must be tested every

3 years

Agenda

UST Overview & Regulations

Monitoring & Testing

Closure & Removal

Summary/Q&A

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

Closure by

Removal: Cleaning

• Dry ice procedure

• Nitrogen purge

• Water rinsing

• Venturi purge

• Triple rinse

• Chemical cleaning

• Tank entry (CSE)

• Include piping

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

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

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

Agenda

UST Overview & Regulations

Monitoring & Testing

Closure & Removal

Summary/Q&A

Our Key Message

Understand the requirements that

come with having a UST on your

property

SummaryFind 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

QUESTIONS?

Thank You For Attending!

Kevin Coulon:

kcoulon@triumvirate.com

Call Us!

1-888-834-9697

www.triumvirate.com

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