 | Administrative Requirements |
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| Technical Requirements |
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| Financial Requirements |
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| Ten-Minute Compliance Self-Test |
Have you upgraded your tanks? Are you in compliance? The key words in these two questions are "upgraded" and "compliance." As tank owners, your real concern should be the matter of compliance.
Usually, tank owners ask the right questions when they call Ecology for assistance. A typical question is "How do I stay out of trouble with you guys -- just tell me what I need to do?" This generally means can you tell me how to comply with the underground storage tank regulations. But every now and then a tank owner will say, "I've upgraded my system, and everything's okay." This statement could be true, but not necessarily.
The terms "upgrade" and "compliance" are sometimes used as if they are mutually exclusive; however, they're not. To say that you've upgraded your tanks does not mean you're in compliance.
Upgrading is only one element of compliance. Being in compliance with the Underground Storage Tank regulations (WAC 173-360) is much broader in scope. To be in compliance, you must meet administrative and financial, as well as technical requirements.
This article is intended to focus on the meaning of compliance.
Record keeping is another administrative task. You need to keep accurate records of all certifications of equipment, repairs, maintenance to your equipment, all required testing of equipment, and any remediation or cleanup reports.
Keeping accurate records can't be stressed enough! Good records are essential, not only for regulatory reasons but also for personal reasons (such as securing refinancing, obtaining pollution liability insurance, or selling your business). Having good records also reduces the stress and worry over inspections.
Leak Detection
The leak detection requirement, which was phased in over the first two years of
the UST program, has been a requirement since 1993. For emergency generator
tanks, it's been a requirement since 1995.
Leak detection is not technically part of the upgrade requirements, but it is considered an "upgrade" since it represents a process and a method not necessarily an equipment modification or component.
To meet the leak detection requirement for your tanks, you can use daily inventory control with monthly reconciliation combined with annual tank tightness testing until December 22, 1998. After that date, you can use daily inventory control with monthly reconciliation combined with tank tightness testing every five years up to ten years if you've added spill, overfill and corrosion protection or upgraded an existing system. Your other leak detection options are: automatic tank gauges (ATGs), statistical inventory reconciliation, interstitial monitoring, ground water monitoring and vapor monitoring. You need to choose one of these options after your ten-year period for daily inventory control with monthly reconciliation and tank tightness testing has expired. (Please note that there are exceptions to emergency generator tanks less than 2,000 gallons. Your regional Ecology office can assist you with questions.)
The choices of leak detection for piping depends on whether your system is a suction system or a pressurized system. A suction system may be intrinsically safe and not require leak detection if it meets the following conditions: 1) the lines must slope back to the tank, 2) the piping has only one check valve and it located at the bottom of the dispenser. If these conditions are not met, the piping needs to have tightness testing done every three years or have monthly monitoring.
Pressurized piping must have an automatic line leak detector (LLD) and either an annual precision tightness test or monthly monitoring. The monthly monitoring methods used for piping are the same as those for tanks. An LLD may be mechanical or electrical and is typically installed as part of the turbine assembly. The LLD must be able to restrict flow, stop flow, or activate an audible or visual alarm. The LLD must also be able to detect a three gallon/hour leak in a line operated at 10 pounds per square-inch within an hour.
Corrosion Protection
Any tank installed after May 7, 1985 should already have corrosion protection.
For steel tanks installed before that date, there are three ways to meet the
corrosion protection requirement. You can line the tanks with epoxy-like
coating, you can install a cathodic protection system (impressed current or
sacrificial anodes) or you can do both.
Lining a tank only protects the inside of the tank, and cathodic protection only protects the outside surface of the tank.
If you decide to only line the tank, you'll have to have it internally inspected every five years. If you install a cathodic protection system, it will need to be inspected every 60 days to ensure it's operating properly.
Corrosion protection for piping is usually achieved by replacing the existing steel piping with non-corrodible material - like fiberglass or flexible piping. A cathodic protection system could be designed for both tanks and piping - or just piping. A cathodic protection system needs to be designed by a certified corrosion protection specialist.
All steel piping - whether galvanized, black pipe, asphalt-covered steel or stainless steel - that regularly contains product and is in contact with soil needs corrosion protection.
Spill Protection
You can add spill prevention to your system by installing a catchment basin
(spill bucket) at the fill port. Please know that spill buckets must be empty of
water and able to accept a spill. No spill bucket is required for manual
transfers of less than 25 gallons.
Overfill Protection
Overfill protection is achieved by adding either one of the following: an
automatic shutoff, an overfill alarm, or ball float valves.
An automatic shutoff is installed in the fill tube. An overfill alarm works with an automatic tank gauge or a separate, stand-alone unit. A ball float is installed in the vent line.
Proof of insurance is required to renew your master business license. A copy of your insurance declaration page (which you can get from your insurance broker) needs to be submitted with your renewal application.
This article has been written to clarify the terms "upgrade" and "compliance." It is also intended to provide options available for achieving and maintaining compliance.
It is impossible to address all of the special circumstances that may exist at your site. If you have questions concerning your tank system, the regional UST staff is available to assist you.
If you have an existing tank system that needs to be upgraded to gain compliance and you plan to continue to sell fuel after December 22, 1998, you need to contact a certified contractor to plan, schedule, contract and complete the work. Many contractors are reporting that they are nearly fully scheduled through the end of the year. The Environmental Protection Agency (EPA) and Ecology are not considering an extension after the December 22, 1998 deadline. If you can't get the work completed in time, you may need to find a contractor to temporarily close your system until you can get the work completed.
Below is "compliance" self test. If you can answer "yes" to each of these questions by identifying one or more of the bulleted items as the method you are using to meet the requirements, then you can feel confident that you are in substantial compliance with the UST regulations.
If you're not able to identify the methods you are using to meet the administrative, technical, and financial requirements involved in the ownership or operation of an underground storage tank system, you may be putting yourself at risk. Your risk is primarily financial since failure to comply with these requirements puts your business operation in jeopardy. You are also at risk financially if your tank system were to leak.
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| I use daily inventory control and monthly reconciliation combined with a tank tightness test every 5- years. |
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| I have an automatic tank gauge. |
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| My ATG is certified to meet the annual tank tightness requirement. |
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| My ATG is not certified to meet the annual tank tightness requirement. |
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| I have double-walled tanks with interstitial monitoring. |
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| I use vapor- monitoring wells. |
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| I use statistical inventory reconciliation (SIR) contracted through a third party. |
If you have questions regarding any of the above, it is important that you call the Ecology office nearest your or an International Fire Code Institute (IFCI) certified contractor soon. Contractors are getting booked, and some are already fully scheduled for the upcoming year.
When possible, Ecology provides documents in electronic format in order to reduce paper usage and printing costs.
Last month, several underground storage forms became available on the Internet. Look for these forms at the Toxic Cleanup Program website:
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| 30-Day Notice to Install/Close |
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| Closure and Site Assessment Notice/Temporary Closure/Change in Service |
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| Department of Ecology Guidance for Reporting Spills and Overfills of Petroleum |
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| Focus: Closure Requirements for Temporarily Closed Underground Storage Tank Systems |
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| Focus: Technical Assistance Program |
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| Model Toxics Control Act Cleanup Regulation (Chapter 173-340 WAC) |
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| Site Check/Site Assessment Checklist |
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| Summary of Requirements for UST |
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| UST Permanent Closure Packet |
**Additional UST documents are to be added soon.
Ecology is frequently asked whether the Environmental Protection Agency (EPA) will extend the December 22, 1998 deadline. EPA has made it absolutely clear that they will not extend the deadline - and states do not have the authority to extend it.
Ecology's concern is that if you wait too long, you may encounter delays in getting tanks and other equipment delivered and installed. Those who wait may also have to pay higher prices for equipment! And the more likely owners and operators wait, the more likely the older tanks will leak - requiring costly cleanup.
EPA has written several publications on the 1998 requirements that can aid you through the process. You may receive the following by calling EPA's RCRA/Superfund Hotline (800) 424-9346. You may also send your request to the National Center for Environmental Publications and Information (NCEPI), P.O. Box 42419, Cincinnati OH 45252 or fax your order to NCEPI (513) 891-6685.
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| Musts for USTs - A Summary of the Federal Regulations for Underground Storage Tank Systems. This booklet clearly summarizes federal UST requirements for installation; release detection; spill, overfill and corrosion protection; corrective actions; closure; and reporting and record keeping. Updated and revised 1995 (40 pages). |
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| Straight Talk on Tanks - A Summary of Leak Detection Methods for Petroleum Underground Storage Tanks. This booklet explains federal regulatory requirements for leak detection and briefly describes allowable leak detection methods. Updated and revised 1995 (30 pages). |
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| Doing Inventory Control Right - For Underground Storage Tanks. This booklet describes how owners and operators of USTs can use inventory control and periodic tightness testing to meet federal leak detection requirements. Contains reporting forms (16 pages). |
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| Manual Tank Gauging - For Small Underground Storage Tanks. This booklet provides simple, step-by-step directions for conducting manual tank gauging for tanks 2,000 gallons or smaller. Contains reporting forms (12 pages). |
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| Introduction to Statistical Inventory Reconciliation - For Underground Storage Tanks. This booklet describes the use of Statistical Inventory Reconciliation (SIR) to meet federal leak detection requirements (12 pages). |
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| Don't Wait Until 1998 - Spill, Overfill, and Corrosion Protection for Underground Storage Tanks. This booklet provides information to help owners and operators meet the 1998 upgrade deadline. |
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| Don't Wait Until 1998 - Brief Facts. This three-fold leaflet summarizes the requirements for meeting the 1998 deadline. |
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| Closing Underground Storage Tanks - Brief Facts. This three-fold leaflet summarizes the federal requirements for proper closure of underground storage tanks. |
Visit Ecology's Website for information on underground storage tanks and other environmental subjects. Additional publications andf information are also available at EPA's Website.
The Do’s & Don’ts of Tank Removal
(These Safety suggestions are published as a service to the petroleum marketing equipment industry by the Safety Committee of the Petroleum Equipment Institute.)DO:
ü Have a
plan or outlined procedure.
ü See that all
employees on site are trained, using API Recommended Practice 1604 Removal and
Disposal of Used Underground Petroleum Storage Tanks and Tank Closure Without
Tears as guidance.
ü Obtain all permits.
ü Locate all
underground utility lines prior to excavating.
ü Know how to properly
purge or inert tanks.
ü Keep a vent line in
the tank until the tank has been inerted.
ü Plug all openings
after the tank has been inerted or purged, leaving a 1/8 inch vent.
ü Calibrate all testing
equipment prior to checking a tank for vapor or oxygen levels.
ü Know materials left
in tanks and pipe systems.
ü Barricade work site
as well as excavation.
ü Post and enforce No
Smoking rules on site.
ü Eliminate all sources
of ignition, including static electricity, electrical, etc.
ü Know the fire
triangle and how to control it.
ü Take photos before,
during, and after removal.
ü Drain all piping to
the tank prior to devaporizing the tank.
ü Remove all contents
from the tank.
ü Test the oxygen level
of each tank prior to removal, if inerting.
ü Test the explosion
level of each tank prior to removal, if purging.
ü Continuously monitor
the tank and excavation for flammable vapors.
ü Make certain lifting
equipment is capable of handling the tanks to be removed.
ü Avoid hitting the
tank and/or piping with machinery during removal.
ü Chock the tank
immediately after removal.
ü Immediately notify
controlling authority of any contamination encountered.
ü Properly placard tank
for hauling.
ü Haul tanks offsite as
soon as possible after removal.
ü Verify with manifests
that all materials were properly hauled away and disposed of.
DON’T:
ý Work without proper
personal protective equipment.
ý Expose yourself to
harmful vapors.
ý Inert tank if manned
entry is planned; tank should be purged.
ý Enter confined spaces
without using proper confined space techniques, procedures, and permits.
ý Weld or cut without
knowing that tanks are vapor free or inerted.
ý Enter excavations
that are not safe.
ý Allow untrained
personnel on the site.
ý Allow bystanders on
the site.
ý Allow movement of air
or gas into the tank without proper grounding and bonding procedures.
ý Allow tanks to be
transported without being labeled and rendered unsuitable for future liquid
storage.
ý Disconnect any lines
before draining.
ý Assume a tank has
been inerted or purged. Check the atmosphere with meters.
ý Lift a tank before
all contents are removed.
ý Pressurize a tank
after removal to locate leaks.
ý Transport a tank that
has not been purged or inerted.
ý Remove a tank prior
to checking the oxygen and vapor level.
ý Transport a tank
without marking each tank with placards.
ý Assume a tank marked
Vapor Free is vapor free.
ý Leave a "hot" tank
unattended or improperly barricaded.
The Do’s & Don’ts of Tank Tightness Testing
(These Safety suggestions are published as a service to the petroleum marketing equipment industry by the Safety Committee of the Petroleum Equipment Institute.)DO:
ü Make certain all fittings are tight.DON’T:
ý
Overpressurize tanks.
ý Attempt to remove
fittings from tank, lines or testing equipment while under pressure.
ý Leave tank hardware
out of tank after test is done.
ý Leave test area
unattended during test.
ý Allow pedestrians to
walk through test area.
ý Wash spills into
sewers.
ý Leave barrels or
containers of gasoline or other flammable liquids open and unattended.
ý Start work before
telling management of your arrival.
ý Overfill tanks and
risers with transport truck hoses – use only small diameter hose to prevent
spills upon disconnect.
ý Leave tools used to
remove tank fittings laying around – they can be tripped on.
ý Use test equipment
that is damaged.
ý Disable vapor
recovery equipment prior to filling the tank system for the test.
TCP
Ecology