Underground Storage Tank Management Regulations for Commercial Heating

Underground Storage Tank Management Regulations for Commercial Heating Oil Tanks RI Department of Environmental Management RI DEM/Office of Technical and Customer Assistance slide 1

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 being binding upon the Department- neither the Department’s interpretation

What is a UST? l l l 10% or more of its volume (including piping) is underground Holds petroleum product or hazardous material Also includes holding tanks serving floor drains RI DEM/Office of Technical and Customer Assistance slide 3

Why regulate USTs? l Small leaks of petroleum products or hazardous materials from USTs can contaminate large groundwater supplies l Leaks can also create health and fire hazards in nearby buildings RI DEM/Office of Technical and Customer Assistance slide 4

Program Elements for Heating Oil USTs l l UST Registration Existing System Requirements – – l Spill Protection Leak Detection Abandonment Prohibition Tank Closure New/Replacement Tank Standards – New Installation Standards RI DEM/Office of Technical and Customer Assistance slide 5

UST Registration l USTs storing fuel oil for heating commercial facilities must be registered with DEM - including schools l Commercial USTs storing motor fuel or hazardous materials must also be registered – includes waste oil USTs – includes holding tanks serving floor drains RI DEM/Office of Technical and Customer Assistance slide 6

UST Registration (cont’d. ) l Annual fee- $50 per tank (municipalities exempt); DEM issues annual certificate l Application provides information on tank system age, construction, contents and ownership RI DEM/Office of Technical and Customer Assistance slide 7

Existing System Requirements. Spill Protection l Spill containment required on all registered USTs since January 1, 1993 – three gallon capacity – above-ground fills exempt RI DEM/Office of Technical and Customer Assistance slide 8

Existing System Requirements. Leak Detection l l Leak detection is not specifically required for USTs holding heating oil for on-site consumptive use DEM recommends periodic tightness testing, and other inventory controls, as good management practices – DEM licenses testers and approves test methods l All releases must be reported immediately to DEM, the local water supplier (if sensitive area), and the local fire authority RI DEM/Office of Technical and Customer Assistance slide 9

Existing System Requirements. Abandonment Prohibition l 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. . . l No UST may be abandoned- there are no exceptions l Extensions may be granted on a case-by-case basis (temporary closure) RI DEM/Office of Technical and Customer Assistance slide 10

l l l Existing System Requirements. Tank Closure of commercial tanks must be pre-approved by DEM – $75 application fee DEM conducts inspection of excavation – must schedule closure inspection Residues must be managed appropriately – must be transported off-site by permitted hazardous waste transporter Tank must be cut/cleaned per Fire Marshal’s regulations Closure Assessment only required for motor fuel USTs Closures-in-place only approved under special conditions RI DEM/Office of Technical and Customer Assistance slide 11

New Installation Standards Application must be submitted to DEM l Must be approved before installation l New UST facilities may not be constructed in wellhead protection areas (replacement tanks are allowed) l Substantial modifications of UST systems must also be pre-approved l USTs serving floor drains have special requirements l RI DEM/Office of Technical and Customer Assistance slide 12

New Installation Standards (cont’d. ) Tanks must be double-walled, steel tanks must have corrosion protection l Piping must be double-walled, with containment sump l UL or ULC listed, National Codes of Practice l Entire system precision tested upon installation l Spill containment and overfill protection required l RI DEM/Office of Technical and Customer Assistance slide 13

General Approval Process Submit scope of work to DEM thirty (30) days in advance l Written approval from DEM required prior to commencement of work (including product piping replacement) l Notify DEM 48 hours prior to installation l Written verification of completion within fifteen (15) days l RI DEM/Office of Technical and Customer Assistance slide 14

Installation Paperwork l l completed registration application detailed site plan (plans for new facilities require PE stamp) including location of: – – – – – 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 RI DEM/Office of Technical and Customer Assistance slide 15

Installation Paperwork (cont’d. ) l Cross-sectional view of the tank – – – l depth of excavation bedding thickness backfill depth supports and anchorage used dimensions and thickness of traffic pad 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 RI DEM/Office of Technical and Customer Assistance slide 16

UST Professional Certification l l l 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 RI DEM/Office of Technical and Customer Assistance slide 17

Self-Audit Checklist 4 Are all your USTs registered? 3 check DEM registration database T make sure registration fees are paid in full 4 Make sure required documentation is submitted 3 spill containment installation notices 4 Plan for replacement 3 remove/replace (old) tanks 3 evaluate new storage technology- UST vs AST 4 Gasoline or generator fuel USTs? Leak detection, 1998 upgrade requirements, and others apply

Questions and Answers l What about above-ground storage tanks? – ASTs are regulated by DEM – Installations are approved by local authorities l What about the 1998 upgrade requirements? – These only apply to motor fuel USTs, and fuel oil distribution USTs. l What about financial responsibility? – This is only required for motor fuel USTs, and fuel oil distribution USTs. RI DEM/Office of Technical and Customer Assistance slide 19

Any questions? Call us at 277 -OTCA (6822) Tom Epstein- ext. 7501 fax 222 -3810 UST Program 222 -2797 Eric Beck- ext. 7504 fax 222 -3813 RI DEM/Office of Technical and Customer Assistance slide 20

or visit the Office of Technical & Customer Assistance at our new home- l l 235 Promenade Street Providence, RI 02908 first door on left from the Beach Street entrance RI DEM/Office of Technical and Customer Assistance slide 21