storage tank program regulation revisions and...

Storage Tank ProgramRegulation Revisions and

ePermitting

Eric LingleSmall Business Compliance Advisory Committee

Harrisburg, PAOctober 25, 2017

Overview

• Federal regulations in 40 CFR 280 were revised in July 2015.• Pennsylvania has State Program Approval (SPA), which gives DEP

primary jurisdiction over the storage tank program.• DEP has 3 years to implement new regulations to address the

federal revisions and reapply for SPA.

PA Chapter 245 Regulation Changes

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245.1** Certification

• Adding a new certification category for UST Minor Modifications -UMI.

• Reducing the number of activities needed for UMX certification, and making the activity requirements consistent among similar certification categories.


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245.2** Permitting

• 5 year expiration date added to issued Storage Tank Site Specific Installation Permit (SSIP), unless an extension is requested and approved.

• Combining “Permit by Rule” and “General Operating Permit” into simply “Operating Permit”.


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245.3** Corrective Action• Adds reporting requirements on Responsible Party

– A responsible party shall notify the Department by telephone or electronic mail as soon as practicable, but no later than 24 hours:

• after the initiation of interim remedial actions.• of providing an alternate source of water to the owner of the affected or diminished water supply.• after the initiation of site characterization activities.

• Adds posting requirements to the Department– Following submission of a complete remedial action plan (and completion report) selecting the

background or Statewide health standard or site-specific standard, the Department will publish an acknowledgment of receipt of the remedial action plan in the Pennsylvania Bulletin

– Publish a notice of its final action in the Pennsylvania Bulletin.

• Adds authority to the Department– The Department may require the responsible party to suspend remedial action and notify the

Department, by telephone or e-mail, within 24 hours of suspension.


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245.4** Underground Storage Tanks

New Operation and Maintenance Requirements

• Periodic walkthrough inspections– Maintenance (owner/operator)

• Visual inspection of spill buckets (clear of debris, etc.) and release detection every 30 days

• Visual inspection of sumps and handheld release detection devices annually


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• Three-year overfill prevention equipment inspections– UMX or UMI certification

• Three-year containment sump (used for interstitial monitoring) and spill bucket testing

– UMX, UMI, UTT, IUM certification

• Failures would be required to be reported by certified individual to DEP on DEP Testing Form

– Report failures within 48 hours

• Annual release detection equipment testing– UMX, UMI, UTT, IUM certification– Includes Line Leak Detectors (mechanical and electronic)


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Phase-in Periods

• Monthly walk-through inspection – 1 year from effective date

• Three-year overfill prevention equipment inspection, spill bucket testing, and containment sump testing – 1 year from effective date, then phased-in– Regulations become effective on Day X; after 1 year, testing must be

completed prior to the next Facility Operations Inspection due date or 3 years from Day X, whichever is sooner

• Annual release detection equipment testing– 1 year from effective date


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Phase-in Periods

• Emergency Generator (EG) Release Detection– For any EG tanks installed after the effective date, release detection

requirement would be immediate– For EG tanks installed after 11/10/2007, must perform release

detection within 1 year from effective date– For EG tanks installed on or before 11/10/2007, must perform release

detection within 2 years from effective date


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245.5** Large Aboveground Storage Tanks• Add timeframe for owner to submit updated Spill Prevention

Response Plan (SPRP)– 120 days– Federal SPCC requires implementation “as soon as possible” and amendments

within 6 months– PPC requires amendments immediately

245.6** Small Aboveground Storage Tanks• Increasing the in-service inspection frequency due to history of non-

compliance


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• First Phase – online payment of annual tank registration fees

– Going live November 2017

• Second Phase – online submittal of Storage Tank Registration/Permitting Applications

– Currently in design

• Future Plans– Certification applications– Mobile inspection application– Ability to submit all forms electronically

ePermitting Project

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ePermitting Advantages

Advantages for DEP:• Currently processing over 9,000 checks/year by hand – this system will automate the process.• Accuracy of payments – payments will need to match the invoiced amount.• Significant reduction in number of manually generated temporary registration letters due to

certificate expiration.

Advantages for tank owners:• Instant processing of credit/debit card payment or ACH payment. No need to request a paper check.• Immediate availability of temporary registration certificate for the facility.• Ability to update contact information without paper submittal.

Future:• Currently working on next phase, which is the online submittal of registration information.• Eventually integrate with certified installers/inspectors for certification applications, electronic

workflow between tank owners and certified individuals, and online inspection and modification reporting.

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Questions?

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