Pennsylvania DEP:

Maintaining UST Compliance and Regulation Updates

NISTM

8th Annual Pennsylvania

Storage Tank Conference

May 18, 2017

Presented by:

Randy Martin

Solid Waste Program Specialist, Supervisor of the Underground

Storage Tank Technical Unit

• Technical Topics and Recommendations to Maintain Compliance

• Quick Information on the New Regulations

• Department Contact Information

Topics

Facility Operation Inspections (FOI)

• 3 year inspection interval for normal, routine inspections• 6 months to 1 year after a new underground storage tank

installation or a change of ownership of a storage tank• 6 months to 1 year after a storage tank has gone from

“Temporarily Out of Use” to “Currently-in-Use” status• The PA DEP can ask for an inspection at any time to verify

compliance.

• Your “Facility Operations Inspection” due date is located on your “Storage Tank Registration/Permit Certificate.”

Technical Topics

Facility Operation Inspections (FOI)

• A “Facility Operations Inspection” reminder letter from the PA DEP is mailed as a courtesy; however, the facility can have an inspection at anytime. You don’t need to receive a letter from the PA DEP to have an inspection completed.

• A list of PA DEP certified underground storage tank inspectors (IUMs) can be located on our website. This list is updated daily.

• Shop around for inspectors (IUMs) – the Department does not regulate inspector prices.

Technical Topics

There are three important dates and an important status on the registration certificate:

The certificate expiration date.

The Permit Status.

The next Facility Operations Inspection due date.

The next Lining Inspection due date (Lined tanks only).

Technical Topics

Facility Operation Inspections (FOI)

General Recommendation:When you contact an underground storage tank inspector (IUM), specifically ask them to conduct a “Facility Operations Inspection.” Please don’t ask them to certify your tanks, test them, evaluate them, look at them, etc. These generic terms mean many things to many different people. Many times, PA DEP receives copies of tank tightness tests, pressure/decay tests, ATG maintenance documentation, dispenser calibration documentation, etc. instead of the “Facility Operations Inspection” report. We really don’t enjoy telling tank owners that they spent good money on testing that we

didn’t require or even ask for.

Technical Topics

Facility Operation Inspections (FOI)

More Recommendations: • Have all your underground storage tanks inspected at the same

time so that all of your tanks are on the same inspection cycle. We have facilities with 10 tanks and 5 different inspection due dates!

• Have your cathodic protection testing done at the same time as your inspection. Both are due every 3 years!

• If located in northern Pennsylvania, try not to have your inspection scheduled during the cold winter months. Frozen manway lids and spill buckets are great to inspect! What good is performing an inspection where the inspector could not open equipment to see everything? If they can’t see inside a sump or under dispenser, the facility is assumed to be non-compliant.

Technical Topics

Facility Operation Inspections (FOI)More Recommendations:

• If you are able to do so, keep storage tank system documentation from the original installation. Keep warrantee cards, invoices, brochures, pamphlets, as-built drawings, etc. Take photographs of the tank system installation.

• Keep a compliance binder readily available with good, thorough records.

• Remember, if it isn’t documented, it didn’t happen. Actual quotes from tank owners, “I have a great memory and I keep all my tank release detection records in my head.” “I would do tank release detection if my tank was leaking, but my tank isn’t leaking.”

• Be present during the inspection, learn, and ask questions! The inspector’s job is to inspect the tank systems, educate the owner/operator, and help them achieve compliance!

Technical Topics

Installation photos are gold mines!

Installation photos are gold mines! What’s that?

Tank Release Detection– Many different release detection methods are available for tanks - Interstitial Monitoring,

Automatic Tank Gauging (ATG), Statistical Inventory Reconciliation (SIR), Manual Tank Gauging, Groundwater Monitoring, Vapor Monitoring, etc.

– The selected method depends on the installed tank system. Variables include tank installation date, tank size, product stored, single vs. double-walled tank, the use of the product, etc. There are advantages and disadvantages to each and every tank release detection method. Pick a method, learn it, and stay consistent with it.

– To be compliant during an inspection, a facility owner must have:

• Documentation verifying tank release detection was conducted properly, was passing, and was done at least once every 30 days.

• The last 12 months of tank release detection records prior to the date of the inspection readily available for review.

– HINT! If you keep your release detection records at an alternate location, let the inspector know that and get the records to him as soon as possible. The inspector has 60 days to submit the report to PA DEP. You could potentially avoid a visit or letter from PA DEP if you are able to come into compliance prior to the report submittal!

Technical Topics

Tank Release Detection

Recommendations:

• Run Automatic Tank Gauge (ATG) tests early each month and later in the same month. If the first ATG test is invalid or fails, you can easily run an ATG test a second time. This will also count towards your suspected release investigation as long as it’s within 7 days of the invalid or failed test.

• Keep price in mind. The interstitial space of a double-walled steel tank can be stuck manually with a gauge stick and the results documented on a piece of paper for no cost!

• Learn your ATG system and it’s capabilities. Example: Without special software called Continuous Statistical Leak Detection (CSLD), a Veeder Root TLS-350 ATG must test a tank when it is between 50-95% full to achieve a valid, passing result.

• We often see kerosene, premium gasoline, and marina tanks get inconclusive or failing ATG results because of low product levels. Keep that information in mind when selecting your release detection method for these type of tanks.

Technical Topics

Tank Release Detection

Other Recommendations:

• Respond to alarms quickly and appropriately! An alarm does not automatically equal a violation. However, not doing anything about an alarm does equal a violation.

• Select a method, learn it, and stick with it.

• Keep a compliance binder readily available - photo copy ATG printouts and place them in a binder – the ink on ATG printouts fades and disappears.

• Pay attention! Even Continuous Statistical Leak Detection (CSLD) may “miss” a leak unless the ATG records are closely reviewed. Without a module called Pump Sense, a constant, ongoing leak can occur and the ATG thinks fuel is constantly being dispensed into vehicles. Since there is no downtime, the ATG never triggers a test, doesn’t fail the test, and doesn’t go into a tank failure alarm. Pump Sense links the ATG to the submersible turbine pumps or suction pumps. Pump Sense asks, “How can the tank be losing fuel without the pumps running?”

Technical Topics

Release Detection Records – Pay attention!

Here’s the result of not paying attention to Tank RD records...

a 12,000 gallon release!

Good Record Keeping?

Good Record Keeping?

We take pride in our appearance…

Good ATG maintenance?

Suction Piping Release Detection

– There are two different types of suction piping systems out there: European (check valve at pump) or American (check valve at tank)

– Different release detection methods are available for suction piping - Interstitial Monitoring, Statistical Inventory Reconciliation (SIR), Precision Line Tightness Testing, Groundwater Monitoring, Vapor Monitoring, etc.

– The selected method depends on the installed suction piping system. Variables include piping installation date, piping construction, single-walled or double-walled, piping size, product stored, how product is used, etc. There are advantages and disadvantages to each and every method.

– To be compliant during an inspection, a facility must have:

• Documentation verifying the type of suction system installed - European or Suction.

• Documentation verifying appropriate suction piping release detection was completed. This documentation varies greatly. The piping system could be exempt from release detection, required to complete monthly interstitial monitoring, or required to complete tightness testing every 3 years.

Technical Topics

Pressurized Piping Release Detection

– Many different release detection methods are available for pressurized piping - Interstitial Monitoring, Electronic Line Leak Detector, Mechanical Line Leak Detector, Statistical Inventory Reconciliation (SIR), Precision Line Tightness Testing, Groundwater Monitoring, Vapor Monitoring, etc.

– The selected method depends on the installed piping system. Variables include piping installation date, piping construction, single-walled or double-walled, piping size, product stored, how product is used, etc. There are advantages and disadvantages to each and every method.

– There are two forms of pressurized piping release detection required : “big” or “catastrophic” leak (3.0 gallon per hour with in 1 hour) and “little” leak (0.2 gallon per hour within 1 hour or 0.1 gallon per hour within 1 hour)

– To be compliant during an inspection, a facility must have:

• Documentation verifying that “big” or “catastrophic” leak piping release detection was valid, passing and was done at least annually.

• Documentation verifying that “little” leak piping release detection was valid, passing and was done monthly or annually which depends on the method used.

• The last 12 months of records prior to the date of the inspection are readily available.

Technical Topics

Pressurized Piping Release Detection

Recommendations:

• Keep price in mind. If you have secondary containment on your suction piping runs, monthly visual sump inspections can be performed and documented for free!

• Learn your unique system and it’s capabilities. All methods aren’t the same!

• Respond to alarms quickly and act appropriately!

• Select a piping release detection method, learn it, and stick with it.

• Many companies offer compliance assistance programs where they keep track of your testing due dates and ensure that testing is completed on time.

• Keep a compliance binder readily available for all your release detection records –photo copy all ATG printouts and place in the binder – ATG printer ink fades and disappears.

• Check all your sumps after snow melts and significant rainfalls.

• When installing new sumps, leave plenty of space for backfill between the sump and steel ring and keep the backfill clean!

Technical Topics

Which is the better tank top sump installation?

Sensors can be great but…

Eyeballs can sometimes be better!

Equipment maintained in a good state of repair?

Equipment maintained in a good state of repair?

Corrosion Protection

– Cathodic Protection (CP) is used to protect metal tanks and metal product piping

– Two different types: Galvanic (sacrificial anodes) or Impressed Current (rectifier on wall)

• 6 month CP survey interval after a new cathodic protection system installation or repairs to an existing system

• 3 year CP survey interval for all cathodically protected metal tanks and metal product piping

– Impressed Current - volts, amps, and runtimes from rectifier must also be documented every 60 days

– To be compliant during an inspection, a facility must have:

• The last 2 CP survey results that are passing (Today and 3 years prior)

• The last 3 volt, amp, and run times from rectifier for impressed current systems (Today, 60 days ago, 120 days ago)

Technical Topics

Corrosion Protection

Recommendations:

• Have the CP survey done at the same time as the FOI. Most IUMs can perform the CP survey or arrange to have it done. That’s one less date to remember and one less mobilization charge!

• Three years is three years. Three years and two months = non-compliant

• A CP system requires liquid moisture (electrolyte) to achieve a passing CP survey. If the CP survey is done in the cold winter months or during drought conditions, the CP survey might not pass. If needed, try adding water to the backfill with a garden hose.

• If you have an impressed current system, look for significant changes in your volts and amperage. If you see a change of more than 10% of your initial volt or amperage readings, call your corrosion expert company! When impressed current systems fail, bad things happen relatively quickly.

• Any repairs must be designed by a corrosion expert and conducted by a DEP UMX certified individual.

• Keep a compliance binder readily available for review.

Technical Topics

Spill Prevention

– Unless the tank is filled in less than 25 gallon increments, a spill bucket must be permanently installed on the tank fill or fills.

– To be compliant during an inspection, a facility must have:

• Spill buckets installed on the tank fills.

• All spill buckets must be in good, operable condition.

➢ Recommendations:

• During install have your spill buckets raised up from the concrete pad to help with water runoff. This does make them targets for snowplows.

• Keep spill buckets clean and free of debris, water, and fuel - spill buckets are designed to catch drips of fuel and be cleaned out and not to be continuously in contact with fuel - Maintenance is the key!

• Check spill buckets after snow melt or a significant rainfall.

• Remember to watch for spill buckets when plowing snow.

• The average life span of a spill bucket is roughly 5 years!

Technical Topics

Technical Topics

Technical Topics

Overfill Prevention

– Unless the tank is filled in less than 25 gallon increments, an overfill prevention device must be installed on each tank. There are different types of devices: Drop tube shutoff valves, ball floats, overfill alarms, etc.

– IMPORTANT: The overfill prevention device must be compatible with both the fuel delivery and vapor recovery methods – generally, pressurized deliveries need different devices than gravity deliveries.

– Bypassing of the overfill prevention device is prohibited. Example: diesel and coaxial drop tube shutoff valve.

– To be compliant during an inspection, a facility must have:

• An overfill prevention device installed on all tanks.

• Overfill prevention equipment must be in good, operable condition and it has to be compatible with the delivery and vapor recovery methods.

➢ Recommendations:

• Maintenance is the key!

• Periodically test and inspect overfill alarms or devices: Do the lights and sirens actually work? Can you actually hear it were the driver is standing or see it? Is there a gauge stick jammed in your tank fill?

• Does the delivery driver stick your tank prior to filling it and stand by the nozzle during the entire delivery?

• Does your contract clearly state the responsibilities and what you

expect of the delivery driver?

Technical Topics

Could you hear or see these alarms?

Would these shut off valves actually work?

Notes on Upcoming Regulations

From the Storage Tank Homepage, scroll down until you see “Storage Tank Advisory Committee” in the blue box on the right side of the page

Notes on Upcoming RegulationsUnder March 7, 2017, there is a bullet titled “Draft proposed rulemaking to revise Chapter 245 (Administration of the Storage Tank and Spill Prevention Program).” This is the most current rulemaking proposal.

Keep an eye out for the Public Comment Period which should be the last quarter of 2017 or the first quarter of 2018.

We are striving for the revised regulations to be effective in the last quarter of 2018.

DEP Regional Office Contact Information

PA DEPRachel Carson State Office Building400 Market StreetP.O. Box 8763Harrisburg, PA 17105-8763Phone: 1-800-42-TANKS (in PA)

717-772-5599FAX: 717-772-5598Web address: www.dep.state.pa.usKeyword: “Storage Tanks”

DEP Central Office Contact Information