dem/office of technical & customer assistance rhode island’s underground storage tank program...

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.


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


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


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


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


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


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


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


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


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


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


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


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


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


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)


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


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!


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


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


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


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


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


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


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


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


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


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


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


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


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


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


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


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


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


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


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


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


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).


Final ThoughtsFinal ThoughtsExpecting an extension to

the 1998 deadline?- Forget about it!

Pursue IFCI certification


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


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

dem/office of technical & customer assistance rhode island’s underground storage tank program...

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