NJDEP Bureau of Underground Storage Tanks Compliance Enforcement
NJDEP Bureau of Underground Storage Tanks Compliance & Enforcement
Bureau of UST John Olko, Acting Bureau Chief – (609) 851 -7989 Krista Frey, Secretary – (609) 633 -1205 Jenna Di. Nuzzo (609) 672 -1309 Mail Code 09 -03, PO Box 420 Trenton, NJ 08625 -0420 Northern Region Bergen, Essex, Hudson, Morris, Passaic, Sussex, Warren, Hunterdon Somerset and Union Kevin Marlowe, Supervisor (609) 439 -9589 Auradis Brooks (609) 462 -5649 Mallory May (609) 954 -5158 Seth Moore (609) 815 -0534 David Norville (609) 477 -4265 Jessica Gellatly (609) 789 -7445 Southern Region Atlantic, Burlington, Camden, Cape May, Cumberland, Gloucester, Mercer, Monmouth, Middlesex, Ocean, Salem Michael Hollis, Acting Supervisor (609) 477 -0945 Gregory Davis (609) 439 -9414 Jennifer Lenik (609) 672 -1809 Kristina Lenoir (609) 221 -3306 Lorraine Norville (609) 477 -4263 Janelle Pierson (609) 672 -1327
New Regulations u NJDEP website u http: //www. nj. gov/dep/rules/nja c 7_14 b u EPA OUST website u http: //www. epa. gov/oust/
EPA Guidance Documents u Musts for UST’s u Straight talk on Tanks: Release Detection For Underground Storage Tanks And Piping u Operation and Maintenance of UST’s u Field Constructed Tanks u Airport Hydrant Systems u Underground Storage Tank System Compatibility: An Overview of the Federal Regulations
Operator Training (Every site must have an A/B operator trained by Oct. 13, 2018) http: //www. cpe. rutgers. edu/brochures/intros/ust-AB. html http: //www. nj. gov/dep/enforcement/ust. html
Operator Training u Must designate an AB Operator by October 13, 2018
UST Inspection u Registration u Insurance u Release Detection Monitoring u Cathodic Protection u Spill Prevention u Overfill Prevention u Air Permitting/Compliance
u Facility must have a Current and Accurate Registration Effective Dates v Current Owner & Operator v Correct number & size of USTs v Correct substances stored v
u Facility must have a Current and Accurate Insurance Policy Can be held by the owner or operator v Effective dates v Correct number, size and installation dates for all USTs v
New Registration Requirements u Now Annual u Will be phased in as your current registration comes up for renewal u Fee’s were not increased
New Registration Requirements u u u 1. Emergency generator USTs are no longer exempt from Subchapter 6 -Release Detection 2. Prior to beginning any closure activities on an underground storage tank system the tank must be registered. 3. Regulated substances that contains greater than 10 percent ethanol, greater than 20 percent biodiesel requires notification 30 days prior to introducing the substance into the system pursuant to N. J. A. C. 7: 14 B-5. 3; 4. Submit FCQ within 30 days after the addition, removal, or replacement of the facility’s designated Class A or Class B operator; 5. Submit FCQ within seven days after taking an underground storage tank system out of service or closure of an underground storage tank system;
New Registration Requirements u u u . 6. Submit FCQ a t least 30 days prior to putting an out-of-service underground storage tank system back into service. 7. An owner and each operator shall, at least 60 days prior to the expiration date of the facility’s UST registration certificate, renew the underground storage tank registration in accordance with N. J. A. C. 7: 14 B-2. 2. 8. New Jersey Underground Storage Tank Facility Certification Questionnaire www. nj. gov/dep/srp/forms/ust
New Registration Form ust_facility_cert_questionnaire. pdf
New Registration Requirements u The facility owner shall notify the Department, in writing, at least 30 days prior to the sale or transfer of all or any portion of the facility, and shall provide the following: – 1. Contact information of the current facility owner; – 2. Contact information of the prospective facility owner; – 3. The underground storage tank facility ID number; – 4. The address of the facility; – 5. The extent of the ownership to be sold or transferred; – 6. A date of sale or transfer, if available. They should send information via email (not using FCQ) to our email address at: srpustregistration@dep. nj. gov
New Registration Requirements u u u The Department will not approve any application unless all fee requirements of this subchapter (7: 14 B-3 -Fees) are met. The owner and operator shall pay fees and oversight costs related to investigation, closure and remediation of an underground storage tank system pursuant to the Administrative Requirements for the Remediation of Contaminated Sites, N. J. A. C. 7: 26 C-4. The owner and operator of an underground storage tank system that is out-of-service shall: 1. Submit an amended New Jersey Underground Storage Tank Facility Certification Questionnaire, pursuant to N. J. A. C. 7: 14 B-2. 1(b)7, within seven calendar days after the underground storage tank system is placed out-ofservice. The owner and operator of an underground storage tank system that has secondary containment may request that the underground storage tank system remain out-of-service for a period of more than 12 months
New Registration Requirements u u When placing an Out of Service UST back into service, submit an amended New Jersey Underground Storage Tank Facility Certification Questionnaire pursuant to N. J. A. C. 7: 14 B-2, at least 30 calendar days prior to introducing product into the underground storage tank system, including documentation that corrosion protection was operated and maintained in accordance with (c)2 ii above and N. J. A. C. 7: 14 B 5. 2 during the out-of-service period; The New Jersey Underground Storage Tank Facility Certification Questionnaire shall include a statement from a certified installer, pursuant to N. J. A. C. 7: 14 B-13, certifying that the system is properly designed and capable of being put back into service in accordance with a code of practice developed by a nationally recognized association or independent testing laboratory or in accordance with the manufacturer's instructions.
New Registration Requirements u The owner and operator shall notify the Department at least 14 days prior to commencing physical on-site work related to the installation, substantial modification, or closure of an underground storage tank system, or performing any activity specified in N. J. A. C. 7: 14 B-4, 5, or 6 requiring Department approval. Notification shall be provided to the Department by e-mail to 14 day. USTnotice@dep. nj. gov
New Registration Requirements u Both the Owner and Operator are now required to sign the New Jersey Underground Storage Tank Facility Certification Questionnaire
Release Detection Monitoring (tanks)
General ATG Requirements Must PASS leak test at least every 30 days. u Can detect a 0. 2 gph leak. u Must be a valid, passing test. (50% or greater volume, unless CSLD/SCALD is being used) u Is third party approved for the application. u Must have maintenance performed per Manufacturer specifications – annual certification. u 95 % probability of finding a leak and 5 % of a false alarm. u Must measure for water monthly. u If the station is open 24/7 or if tanks are manifolded, a CSLD or SCALD chip may be needed to pass a periodic test. u – For manifolded tanks, other option would be to manually shut off the siphon.
Interstitial Monitoring u u u Double walled tanks only Mandatory for double wall USTs installed since 1990! Can be continuous or every thirty days Annular Sensors or sticking annular Location commonly depends on construction of the tank Sensors connect to an ATG panel
u Facility must have Sensors Normal u No Alarms u Print liquid status reports – Incon: print Regulatory Report – Veeder Root: function to “liquid status”; print
Problems in the Field
Release Detection Monitoring (Lines)
Pressurized Piping u Lines Tightness Test (annual test) u Interstitial u Line Leak Detector (annual test)
Interstitial Monitoring Double wall piping only u Mandatory for lines installed since 1990! u Product tight secondary containment u Any test boots MUST be loose or open u Sensors fixed to the bottom of the sump u
Secondary Containment Testing Requirements • Secondary Containment (after April 11, 2016) – Applies to new and replaced tanks and piping – Includes interstitial monitoring (and sumps if they are used for interstitial monitoring) – Includes under-dispenser containment for new dispenser systems • What you must do for containment sumps: No later than October 13, 2018, you must perform your first three year containment sump test for liquid tightness on sumps used for interstitial monitoring of piping or use double-walled containment sumps with periodic interstitial monitoring of the space between the two walls of the sump. 29
Containment Testing Containment shall be tested at least once every three years – Anywhere that interstitial monitoring of piping is performed – turbine, piping and dispenser sumps
WHEN? • The Owner and Operator of an UST system installed prior to October 13, 2015 shall comply no later than October 13, 2018. • The Owner and Operator of an UST system installed on or after October 13, 2015 shall comply upon installation.
Huh?
It Ain’t Kool-Aid!
Suction Piping European Suction • Check valve only at dispenser – product drains back • to tank when not in use No additional RDM required American Suction • Check valve at the dispenser and top of the tank – • product remains in line when not in use Additional RDM required: • Interstitial if piping installed since 1990 • 3 year tightness OR interstitial if piping installed before 1990
Suction system piping
Corrosion Protection
CP testing requirements u Sacrificial & Impressed u >-. 850 VDC Passing test results u Required Test 1 X 3 years u 6 month test required after CP upgrade / repairs u Impressed system – 60 day rectifier log
Spill Prevention
Spill Prevention u Clean and Dry – No Liquid u 3 year integrity test – due by Oct. 13, 2018 u Inspect for HOLES – Take damaged equipment out of service immediately!
Not Spill Prevention
Overfill
Overfill prevention Options & Function GRAVITY OR PRESSURIZED DELIVERIES • High Level Alarm – Alarm system: must activate when tank is 90% full. Exterior Alarm must be audible/visual to the delivery driver. • Pressure Rated Flow Restrictor (61 F-stop) – Device must be set to shut off when tank is 95% full. GRAVITY DELIVERIES ONLY • Automatic Shutoff (Flapper Valve) – Device must be set to shut off when tank is 95% full. • Ball Float Valve/Flow Restrictor – Must be set to slow down flow when tank is 90% full. Overfill Prevention Module 7 43
Overfill High Level Alarm • Once every year, check the electronic overfill alarm to ensure that the: – Alarm can be heard and/or seen from where the tank is fueled – Electronic device and probe are operating properly Overfill Prevention Module 7 44
Automatic Shutoff Aka (Flapper) Valve • Once every 3 years inspect to ensure: – Device must be set to shut off when tank is 95% full – Specially rated shut off valve is required with pressurized deliveries Overfill Prevention Module 7 45
Automatic Shut Off - Fill Pipe Device Automatic Shutoff Device With The Float Down And The Fill Valve Open Automatic Shutoff Device With The Float Up and The Fill Valve Closed Overfill Prevention Module 7 46
Flapper Valve Bypass = Bad • Never store stick in the drop tube. • Can cause an overfill. • Can damage overfill device.
Ball Float • Once every 3 years, check the ball float to ensure: – Ball cage is still intact – Ball still moves freely in the cage – Ball still seals tightly on the pipe – Ball float is set at 90% of the tank capacity *Not to be used with pressurized deliveries or suction systems * Can NOT repair or replace!!! 48
Ball Float- in Vent Pipe Ball Float Valve with the ball at the bottom of the cage and the vent line open. Ball Float Valve rises as the product rises. Overfill Prevention Module 7 49
Ball Floats *Flow restrictors in vent lines shall not be used to comply with (a)3 ii above when overfill prevention equipment is installed or replaced after October 13, 2015. * NO REPAIRS – MUST BE REPLACED
Release Response Plan u. The owner or operator shall prepare, and update as necessary to reflect changes to the facility and to regulations governing response plans, a release response plan which includes the following information: 1. Site Name & Address 2. Owner/Operator Name & Phone Numbers 3. Emergency telephone numbers: local police, fire, EMS, health dept. and NJDEP Hotline 1 -877 -WARN DEP (877 -927 -6337) 4. Contractor Name & Phone Number 5. LSRP Name & Phone Number 6. List of procedures to be followed in the event of a leak or discharge of a hazardous substance *The owner or operator shall ensure that the release response plan is available for on site inspection. *Any release response plan that is required by and is in compliance with the New Jersey Spill Compensation and Control Act, N. J. S. A. 58: 10 -23. 11 et seq. , and the Discharges of Petroleum and Other Hazardous Substances Rules, N. J. A. C. 7: 1 E, shall suffice for this
UST Compliance Points u u u u Contact UST Enforcement at 609 -943 -3019 for more information Registration - Current and Accurate Insurance - Current and Accurate Policy Release Detection Monitoring For Tanks – Functional and Passing Method of Release Detection – 0. 2 passing and or Interstitial Sensors Normal/No Alarms For Pressurized Lines – Functional and Passing Method of Release Detection – Mechanical Line Leak Detectors– Annual Passing Test – Pressure Monitoring Lines -. 2 GPH Test = Pass – Annual Line Tightness Test – Interstitial Monitoring u Test Boots Loose, Sensors mounted in correct position u Sump must be free of liquid Suction Piping – What type do you have? – American requires either monthly monitoring OR a 3 -year test. Corrosion Protection – Required Test 1 X 3 years – >-. 850 Passing test results – 60 day rectifier inspection (If applicable ) Proof of Tank Construction– UL 1746 Compliant Spill Prevention (Spill Buckets) – Clean and Dry – No Liquid, Inspect for HOLES Overfill Prevention – Present and Functional Monthly Containment Device Inspection Log Air Permit Issues – Current and Accurate Air Permit – Check all Stage 1 and 2 hardware – Ensure all required testing is completed and passing Release Response Plan DEP HOTLINE – 1 -877 -927 -6337
WALKTHROUGH INSPECTIONS • Beginning no later than October 13, 2018 • Conducting a walkthrough inspection, at a minimum and as appropriate to the facility, as follows: • 30 day inspection • annual inspection
30 DAY WALKTHROUGH INSPECTIONS • Open and visually inspect: – Spill prevention equipment • (document interstitial monitoring if applicable) – Fill pipe – Anywhere WITHOUT containment; dispensers, STPs, piping sumps • Check and record monthly release detection monitoring **Any water/debris should be removed immediately and disposed of properly. **
Annual Inspection • Open and visually check for leaks, damage, leaks from interstitial areas, remove water/debris (and dispose of properly) from: – STP containment sumps – Piping containment sumps – Dispenser cabinets • Trigger high level alarm • Check devices such as tank gauge sticks or ground water bailers for operability and serviceability • Verify all annual testing
Compatibility • Notification - Owners and operators must notify the implementing agency at least 30 days before switching to a regulated substance containing greater than 10 percent ethanol, 20 percent biodiesel, or any other regulated substance identified by the implementing agency • Demonstration of compatibility – Owners and operators must demonstrate compatibility of the UST system through a nationally recognized testing lab listing or manufacturer approval of UST equipment or components, of use an alternative option identified by the implementing agency that is no less protective than demonstrating compatibility of the UST system • Recordkeeping - Owners and operators must maintain records for as long as the biofuel blend is stored to demonstrate compliance 56
Testing your Release Detection Monitoring System
*RDM Testing • On or before October 13, 2018, owners and operators shall ensure that all underground storage tank systems, including electronic and mechanical components, are operated, maintained, and tested in accordance with the following: • Requirements developed by the manufacturer, if any; • A code of practice developed by a nationally recognized association or independent testing laboratory, such as Petroleum Equipment Institute Recommended Practice RP 1200, “Recommended Practices for the Testing and Verification of Spill, Overfill, Leak Detection, and Secondary Containment Equipment at UST facilities” (available at www. pei. org); or
RDM Testing • Testing of electronic and mechanical components in accordance with (g) above shall be performed at least annually and shall include, as applicable, the following: • 1. For automatic tank gauge and other controllers: testing alarm, verifying system configuration, and testing battery backup; • 2. For probes and sensors: inspecting for residual buildup and ensuring floats move freely, ensuring shaft is not damaged, ensuring cables are free of kinks and breaks, and ensuring that the alarm is operable and communicates with the controller;
Contractor Certification u Installation u Closure u CP –tester/specialist u Tank Testing – (includes line and monitoring systems) Now using ICC test centers (no CP test) Eliminated the Sub-Surface Classification
Fourteen day notification
14 Day Notification u Email to 14 day. USTnotice@dep. nj. gov u Installation, Closure, Sub. Modification work, Stage 2 decommissioning and air testing. - 14 days before routine work - Within 14 days of emergency work - Include: site name, owner info, contractor info, date of work and summary of work to be completed.
14 day. USTnotice@dep. nj. gov • Notification shall be provided to the Department by the UST facility owner and operator by e-mail to 14 day. USTnotice@dep. nj. gov and shall include the following information in each notification: • i. The address, name, and UST facility ID number where the work activities will occur; • ii. The approved activity to be undertaken and the anticipated date(s) of the activity;
14 day. USTnotice@dep. nj. gov • iii. The name, phone, and email contact information of the owner and operator submitting the notification; and • iv. The name, phone, and email contact information of the contractor performing the activities, if different from the owner and operator submitting the notification.
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