Understanding Underground Storage Tanks

– KPA CONFIDENTIAL –

Understanding Underground Storage Tanks

– KPA CONFIDENTIAL – 2

Understanding Underground Storage Tanks

Underground Storage Tanks

– KPA CONFIDENTIAL – 3

Understanding Underground Storage Tanks

Underground Storage Tanks

After completing this training you should be able to:• Have a better understanding of UST Systems and their components.• Feel more comfortable addressing UST issues with your clients.• Increase your use of the appropriate UST Codes in MKO.

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Increased UST Enforcement!

Underground Storage Tanks

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Why Increased UST Enforcement?

Underground Storage Tanks

RECENT HEADLINES

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Why Increased UST Enforcement?

Underground Storage Tanks

RECENT UST REGULATION CHANGES

August 8, 2009 States must develop UST Operator Training Requirements and Guidelines

August 8, 2010 States must have completed inspections of All USTs (and continue to repeat this at least every 3 years).

August 8, 2012 All UST Operators must pass UST Operator Test.

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Why Increased UST Enforcement?

Underground Storage Tanks

American Recovery and Reinvestment Act of 2009• Allocated $200 Million to the EPA UST Program• $190 Million Sent to State & Local UST Programs

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Underground Storage Tanks

An EPA Regulated UST System Must:• be 110 gallons or more• have 10% or more of the

volume underground• storing petroleum or

hazardous substances• always include the tank and

piping

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Underground Storage Tanks

Tanks that are exempt from EPA UST Regulations:• Tanks on or above the floor of underground areas

(Dealership Quick Lube Pits)

• Tanks storing heating oil used on the premises (some states differ on this)

• Tanks less than 110 gallons

• Other exemptions do exist

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UST – LEAKING USTs

LEAKING UST

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UST – LEAKING USTs

11

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UST – Regulations

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UST – Regulations

RCRA Subtitles 40 CFR 260-270A - General Provisions B - Solid Waste C - Hazardous WasteD - State or Regional Plans E - Commerce Responsibilities F - Federal Responsibilities G - Miscellaneous Provisions H - Research, development, info I - Underground Storage Tanks

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UST – Regulations

RCRA Subtitle I –Underground Storage TanksRegulations Published in 1988

Compliance Date set for December 22, 1998

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UST – Regulations

States with Approved UST Programs (in green)

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UST – Regulations

Why are USTs so complicated?

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UST – Regulations

1. The applicable regulations vary depending upon what kind of equipment the client has.

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UST – Regulations

Types of Underground Storage Tanks• Protected Steel

Steel tank coated at the factory and built with sacrificial (galvanic) anodes.• Steel with Impressed Current Steel tanks that have been retrofitted with an impressed current system.• Fiberglass-Reinforced Plastic Commonly referred to as fiberglass tanks.• Polyethylene-Jacketed Steel Tank Double-wall tank with a steel inner wall and a plastic outer wall. • Fiberglass-Jacketed Steel Tank Double-wall steel tank with a fiberglass reinforced plastic outer wall.• Clad Steel Tank Steel tank that has a thick layer of non-corrodible material that is mechanically bonded (clad) to the outer wall of the steel tank.• Protected Steel Fiberglass Lined Cathodically protected steel tank lined with fiberglass.

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UST – Regulations

2. Your client’s often don’t know what kind of UST equipment they have.

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UST – Regulations

3. You can’t see what kind of UST equipment they have.

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UST – Regulations

1. The regulations vary depending upon what kind of equipment the client has.

2. Your client’s often don’t know what they have.

3. You can’t see what they have.

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UST – MKO Codes

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UST – MKO Codes

UST00 UST Reg/Permit• UST Registration/Permit is

not Current or Posted

• Post the UST Registration and or permit issued by local agency or state on site

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UST – MKO Codes

UST01 Cert Finance Resp• Certification of Financial

Responsibility is unavailable.

• Complete the Certification of Financial Responsibility and file it with the appropriate local or state agency.

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UST – MKO Codes

UST02 Spills Rptd 24 Hr • Unreported Releases, Spills or Overfills

• Report all unauthorized releases, spills, or overfills have been reported to the local agency hours within 24 hours.

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UST – MKO Codes

UST03 UST Repair Notification• Agency Not Notified of UST Change

• Notify a local environmental agency of all planned and/or completed repairs, upgrades or changes to the UST system. Ensure records are available for review.

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UST – MKO Codes

UST04 UST Closure• Records of tank closures or

change of service are not maintained onsite (including site investigation).

• Remove all product from the tank• Notify local EPA• Test for contamination• Fill or remove the tank.

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UST – MKO Codes

UST05 Cathodic Prot Dox • Cathodic Protection

Documentation Missing.

• Ensure documentation of operation of cathodic protection equipment is available on site. The last two inspections are required unless impressed current is used; then the last three inspections are required.

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UST – MKO Codes

Fe + O2 + H2O → Fe2O3

Iron + Oxygen + Water → Iron Oxide (aka Rust)

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UST – MKO Codes

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UST – MKO Codes

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UST – MKO Codes

IMPRESSED CURRENT CATHODIC PROTECTION SYSTEM• Electrical current run

through anodes into the ground

SACRIFICIAL/GALVANIC CATHODIC PROTECTION

SYSTEM• SACRIFICIAL ANODES

ATTACHED TO THE TANKS PROVIDE THE CURRENT

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UST – MKO Codes

• UST05 Cathodic Prot Dox

• Documentation of operation of cathodic protection equipment was not observed on site.

• Ensure documentation of operation of cathodic protection equipment is available on site. The last two inspections are required unless impressed current is used; then the last three inspections are required.

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UST – MKO Codes

UST05 Cathodic Prot Dox • Documentation of operation of cathodic protection

equipment was not observed on site.UST11 UST Corrosion Prot

• The Underground Storage Tank onsite was observed to have inadequate corrosion protection as required by the regulations.

UST12 Pipe Corrosion Prot• Inadequate Underground Storage Tank pipe corrosion

protection was observed.

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UST – MKO Codes

UST06 Leak Detect Dox• Records from testing, sampling,

monitoring, calibration or maintenance were not available for the tank leak detection method.

• All records must be retained for at least one year and tank tightness results must be maintained until the next test is conducted.

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UST – MKO Codes

UST13 UST Leak Detect• Inadequate underground storage tank leak detection was observed.

• Ensure all underground storage tanks use at least one of the following leak detection methods: • Inventory control, • Manual tank gauging, • Automatic tank gauging, • Interstitial monitoring, • Vapor monitoring, • Tank tightness testing, • Ground water monitoring

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UST – MKO Codes

UST07 - Pipe Leak Detection Dox UST14 UST Pipe Leak Detect

• Inadequate underground storage tank pipe leak detection was observed.

• Piping Leak detection methods very similar to the Tank methods.Pressurized Piping:

• Automatic line leak detectors are required for pressurized piping and one other leak detection method.

• If using line tightness test for pressurized piping, the test must be completed annually.

Suction Piping: • Line tightness test is used as a leak detection method for suction piping, the test

must be completed every three years.• Does not require leak detection if there is only one check value and it is located as

close to the dispenser as possible).

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UST – MKO Codes

Pressurized Piping: • Pumps on top of tanks use pressure to

move the product up to the dispenser aboveground.

• Pipes are continuously filled with product.

Suction Piping:• Pumps located aboveground inside the

dispenser pull the product up through the piping.

• Once dispensing is completed, the pump shuts off and all of the pressure is released, so all of the product drains back into the tank.

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UST – MKO Codes

UST09 Ovrfll EqpmntUST10 Ovrfll Eqpmnt Calibration• Underground Storage Tank overfill prevention

equipment was inadequate or not present.

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UST – MKO Codes

UST08 Spill Prev Equpmnt Ensure spill prevention equipment for an

underground storage tank is present that will prevent the release of contents to the environment when a transfer hose is detached from the fill pipe (i.e. spill catchment basin).