dem/office of technical & customer assistance rhode island’s underground storage tank program...
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DEM/Office of Technical & Customer Assistance
Rhode Island’sRhode Island’sUnderground Storage TankUnderground Storage Tank
ProgramProgram
RI Department of Environmental RI Department of Environmental ManagementManagement
DisclaimerDisclaimerThe 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 binding upon the Department; either the Department’s interpretation of applicable regulations, or any policy which may have developed applying those regulations.
DEM/Office of Technical & Customer Assistance
What is a UST?What is a UST? 10% or more of its volume (including piping) is
underground Holds petroleum product or hazardous material Also includes holding tanks serving floor drains
DEM/Office of Technical & Customer Assistance
Why regulate USTs?Why regulate USTs? Small leaks of gasoline or hazardous material from USTs can contaminate large groundwater supplies
Leaks can also create health and fire hazards in nearby buildings
DEM/Office of Technical & Customer Assistance
Program HistoryProgram History First RI UST regulations issued in 1984; amended
in 1985, 1989, 1992, & 1993 Federal UST rules first issued in 1988; financial
responsibility requirements in 1989 Purpose of program is to minimize and detect
releases through proper operation and maintenance of existing facilities; and to prevent future releases through technical standards for new installations, replacements, and upgrades
DEM/Office of Technical & Customer Assistance
Program History Program History (cont’d.)(cont’d.) 1985 rules required new installations to be corrosion
protected, and continuously monitored; included alternatives– required spill and overfill protection– allowed single-walled tanks and piping– set upgrade requirement for existing UST systems
DEM/Office of Technical & Customer Assistance
Program History Program History (cont’d.)(cont’d.) 1992 rules required all new installations to
use double-walled, corrosion protected tanks; and piping with continuous interstitial monitoring– required registration of commercial heating oil
tanks
DEM program received EPA approval in 1992
DEM/Office of Technical & Customer Assistance
Program ElementsProgram Elements UST Registration Existing System Requirements
– leak detection– O&M/record-keeping– abandonment prohibition
Upgrading Requirements New/Replacement Tank Standards/Approvals
– tank closure– cathodic protection– Interior lining
UST Professional Certification Financial Responsibility
DEM/Office of Technical & Customer Assistance
Exempted TanksExempted Tanks (partial (partial list)list)
hydraulic lift tanks basement tanks (specific criteria) septic tanks flow-through process tanks (as defined) propane or LNG tanks intermittent or fill and draw tanks emergency spill protection & overflow tanks
DEM/Office of Technical & Customer Assistance
UST RegistrationUST Registration Commercial USTs of any size storing
motor fuel or hazardous materials must be registered with DEM– includes waste oil USTs
– includes holding tanks serving floor drains USTs storing fuel oil for heating
commercial facilities must be registered
DEM/Office of Technical & Customer Assistance
UST Registration UST Registration (cont’d.)(cont’d.) Annual fee- $50 per tank; DEM issues annual
certificate Application provides information on tank
system age, construction, contents and ownership
DEM must be notified 30 days prior to proposed transfer of ownership
Residential tanks 1100 gallons storing fuel oil for on-site heating are exempt
DEM/Office of Technical & Customer Assistance
Existing System Existing System RequirementsRequirements
Definition- existing systems defined as being in operation prior to October 31, 1984–USTs installed in compliance with the
1985 rules must be continuously monitored, and do not require upgrade
DEM/Office of Technical & Customer Assistance
Leak Detection for Tanks Leak Detection for Tanks (for existing (for existing systems)systems)
Continuous monitoring– double-walled> interstitial monitoring– single-walled> approved ATG
Tightness testing– schedule based on age of tank– results must be submitted to DEM– testers and methods must be certified by DEM
Must also conduct Daily Inventory and Monthly Reconciliation
DEM/Office of Technical & Customer Assistance
Leak Detection for Piping Leak Detection for Piping (for existing (for existing systems)systems)
Double-walled systems must install continuous interstitial monitoring
Single-walled systems– pressurized systems require annual
tests and line leak detector
– suction systems require testing schedule based on age
DEM/Office of Technical & Customer Assistance
Operation & Maintenance Operation & Maintenance (existing (existing systems)systems)
Monitoring systems must be calibrated and tested annually, per manufacturer
Monitoring systems must be operating at all times– any deactivation must be reported immediately– repair within 15 days, or temporarily close
Records must be kept on-site, unless approval for an alternate site is obtained from DEM
Must conform with National Codes of Practice
DEM/Office of Technical & Customer Assistance
Abandonment ProhibitionAbandonment Prohibition 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...
No UST may be abandoned- there are no exceptions
Extensions may be granted on a case-by-case basis (temporary closure)
DEM/Office of Technical & Customer Assistance
Early Upgrade Early Upgrade RequirementsRequirements
Spill containment required on all registered USTs since January 1, 1993– three gallon capacity– above-ground fills exempt
Overfill protection required on all tanks since January 1, 1996– fuel oil consumed on-site for heat exempt– three options- automatic, flow restriction, or
alarm; or equivalent
DEM/Office of Technical & Customer Assistance
1998 Upgrade Deadline- 1998 Upgrade Deadline- Corrosion Protection forCorrosion Protection for
Tanks and PipingTanks and Piping Options:
– close USTs/replace with new– cathodic protection– interior lining- lining only
requires a variance; none yet granted
Don’t wait ‘til 98!Don’t wait ‘til 98!
DEM/Office of Technical & Customer Assistance
New Tank StandardsNew Tank Standards Application must be submitted to DEM Must be approved before installation New UST facilities may not be
constructed in wellhead protection areas (replacement tanks are allowed)
Substantial modifications of UST systems must also be pre-approved
USTs serving floor drains have special requirements
DEM/Office of Technical & Customer Assistance
New Tank Standards New Tank Standards (cont’d.)(cont’d.) Tanks must be double-walled, with continuous interstitial
monitoring Piping must be double-walled, with continuously
monitored containment sump, and tested before backfilling
UL or ULC listed, National Codes of Practice Entire system precision tested upon installation Leak detection system must be approved by DEM, and
maintained properly Spill containment and overfill protection required Tank and piping must be compatible with contents
DEM/Office of Technical & Customer Assistance
General Approval ProcessGeneral Approval Process Submit scope of work to DEM 30 days in advance Notify DEM 48 hours prior to installation Written approval from DEM required prior to
commencement of work (including product piping replacement)
All work must be performed in accordance with industry standards
Precision test tank upon completion Written verification of completion within 15 days
DEM/Office of Technical & Customer Assistance
Installation PaperworkInstallation Paperwork 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
DEM/Office of Technical & Customer Assistance
Installation Paperwork Installation Paperwork (cont’d.)(cont’d.)
cross-sectional view of the tank– depth of excavation
– bedding thickness
– backfill depth
– supports and anchorage used
– dimensions and thickness of traffic pad
DEM/Office of Technical & Customer Assistance
Installation Paperwork Installation Paperwork (cont’d.)(cont’d.)
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
DEM/Office of Technical & Customer Assistance
Post-Installation Post-Installation PaperworkPaperwork
for tank and/or piping replacement, submit:–tank tightness test results (tank and
separate line test)
–certification form (available from DEM)
–copy of tank/piping manufacturer’s installation checklist
DEM/Office of Technical & Customer Assistance
Tank ClosureTank Closure Closure of commercial tanks must be pre-
approved by DEM $75 application fee DEM conducts inspection of excavation
– must schedule closure inspection All releases must be reported
immediately to DEM, local water supply (if sensitive area), and local fire authority
DEM/Office of Technical & Customer Assistance
Tank Closure Tank Closure (cont’d.)(cont’d.) 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 report required– except when fuel oil used solely on-site– must be performed by PE or CPG
Closures-in-place only approved under special conditions
DEM/Office of Technical & Customer Assistance
Cathodic ProtectionCathodic Protection Required for both tanks and piping Impressed current or sacrificial anode systems allowed Internal inspection must be performed or certified by
NACE corrosion expert- no alternatives at this time Upgrade must be designed by same
– DEM requires work scope and design to be submitted with NACE certification
– list of equipment/materials/warranties– site plan
Precision tested upon completion Submit as-builts, test results and affidavits within 15 days
DEM/Office of Technical & Customer Assistance
Cathodic Protection Cathodic Protection O&MO&M Systems must be operated, maintained,
and inspected in accordance with National Codes of Practice
Precision testing schedule is not affected by installation of corrosion protection unless continuous monitoring is installed– upgraded USTs can use tightness testing and
inventory control for ten years after date of upgrade
DEM/Office of Technical & Customer Assistance
Cathodic Protection O&M Cathodic Protection O&M (cont’d.)(cont’d.) Must be tested by qualified cathodic protection
tester within six months of installation, and at least every three years following
Also must be tested whenever construction or maintenance in the area of the structure occurs
Impressed current systems must also be inspected every 60 days to ensure equipment is running properly, and tank-to-soil potential reading relative to copper is -850 millivolts, or more negative
DEM/Office of Technical & Customer Assistance
After Installing Cathodic After Installing Cathodic ProtectionProtection submit tank tightness test results
assessment of the structural soundness of the tank
post-construction as-built drawings which include:– location of all tanks and dispensers– materials of construction– piping layout– wiring schematic– products stored
DEM/Office of Technical & Customer Assistance
After Installing Cathodic Protection After Installing Cathodic Protection (cont’d.)(cont’d.)
Submit post-construction data re:– tank-to-soil potentials
– pipe-to-soil potentials
– dielectric isolation
– foreign structure-to-soil potentials
– test coupons
– permanent reference electrodes
DEM/Office of Technical & Customer Assistance
Interior LiningInterior Lining DEM only accepts direct internal inspection,
per API 631, NLPA 1631- no alternatives New ASTM standards are not acceptable Must submit proposal which outlines scope of
work, including:– list of equipment/materials/warranties– site plan– qualification of person who is applying the lining– method of evaluating the tank interior
DEM/Office of Technical & Customer Assistance
After Interior Lining-After Interior Lining- submit tank tightness test results assessment of the structural soundness
of the tank summary of the testing of the lining
material– holiday testing
– barcol hardness
DEM/Office of Technical & Customer Assistance
UST Professional UST Professional CertificationCertification 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
DEM/Office of Technical & Customer Assistance
UST Financial UST Financial ResponsibilityResponsibility
Commercial gasoline USTs, and some others, must demonstrate financial responsibility for managing releases
Several allowable mechanisms, including a financial test and private insurance
DEM/Office of Technical & Customer Assistance
UST Financial Responsibility UST Financial Responsibility (cont’d.)(cont’d.) Another mechanism, a state UST FR Fund, was
established by the General Assembly in July 1994 Program is not yet operating- will reimburse eligible
costs related to investigation and remediation of UST releases
USTs must be in compliance with UST rules $20,000 deductible; $1,000,000 coverage Rules to be promulgated by UST Fund Review Board
– draft is now available from the Board Hazardous materials USTs not eligible
DEM/Office of Technical & Customer Assistance
What type of electronic monitoring is required for piping replacement only?
–The tank top piping sump is required to be continuously monitored, for both pressurized and suction systems.
–Heating oil consumed on-site for heating purposes is exempt.
Questions and AnswersQuestions and Answers
DEM/Office of Technical & Customer Assistance
Questions and Answers Questions and Answers (cont’d.)(cont’d.) When is the continuous electronic monitoring
system required to be activated?–Prior to commencing regular UST
operation. Can existing steel piping be upgraded?
–Not really. Existing unprotected steel piping should be replaced with new compliant piping (USTs holding fuel oil for on-site heating purposes only are exempt).
DEM/Office of Technical & Customer Assistance
Final ThoughtsFinal ThoughtsExpecting an extension to
the 1998 deadline?- Forget about it!
Pursue IFCI certification
DEM/Office of Technical & Customer Assistance
Any questions? Call us at-Any questions? Call us at-222-OTCA (6822)
Tom Epstein- ext. 7501
fax 222-3810
UST Program
222-2797
Greg Yekhtikian- ext. 7521
fax 222-3813
DEM/Office of Technical & Customer Assistance
or visit theor visit theOffice of Technical & Customer Office of Technical & Customer
AssistanceAssistanceat our new home-at our new home-
235 Promenade Street Providence, RI 02908
first door on left from the Beach Street entrance