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DNREC Tank Management Branch Underground Storage Tank Regulatory Development Workshops September 200

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To update technical aspects of the Regulations that are outdated ... TMB drafts Regulations to comply with EPACT and new technology ... – PowerPoint PPT presentation

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Title: DNREC Tank Management Branch Underground Storage Tank Regulatory Development Workshops September 200


1
DNREC Tank Management BranchUnderground
Storage Tank Regulatory Development
WorkshopsSeptember 2006
2
Why?
  • To update technical aspects of the Regulations
    that are outdated
  • To comply with the Federal Energy Policy Act of
    2005

3
Federal Energy Policy Act of 2005
  • Owner/Operator Training
  • Delivery Prohibition
  • 3 year inspection cycle
  • Public Access to records
  • http//www.epa.gov/oust/fedlaws/epact_05.htm

4
Delaware s Regulatory Development Process
5
Part AGeneral Requirements for Underground
Storage Tank Systems
6
Part A Section 1 General Provisions
  • The Department can order an investigation or a
    system tightness test if the UST is not in
    compliance with the Regulations.
  • Statement of Joint and Several Liability for
    Owners and Operators added.

7
Part ASection 2 Definitions
  • Terms Deleted
  • Abandoned
  • Corrosion Expert
  • Existing Tank
  • Fund
  • New Tank

8
Part ASection 2 Definitions
  • Terms Added
  • Airport Hydrant Fuel System
  • Change in Substance Stored
  • Closed in Place
  • Containment Sump
  • Hazardous Substance
  • Heating Fuel UST
  • LNAPL
  • Motor Oil
  • Product Tight
  • Watertight

9
Part ASection 2 Definitions
  • Terms Amended
  • Motor Fuel to include biodiesel and ethanol
  • Operator
  • Owner
  • Piping
  • Precision Test
  • Regulated Substance
  • Repair
  • Retrofit
  • Underground Storage Tank System
  • Upgrade

10
Part ASection 3 Referenced Standards
  • Referenced Standards updated
  • The most recent edition of the referenced
    standard shall be used.
  • Where two referenced standards conflict the most
    stringent shall apply.

11
Part ASection 4 Registration and Notification
Requirements
  • Delivery Prohibition no deliveries may be
    made to a tank that is not in significant
    compliance with the Regulations. (from the
    Federal Energy Policy Act of 2005)
  • All ownership transfer documents, including proof
    of financial responsibility, must be submitted to
    the Dept. within 72 hours of change of ownership
    if the tank contains a Regulated Substance.

12
Part ASection 4 Registration and Notification
Requirements(cont.)
  • USTs used for multiple purposes must meet the
    most stringent regulations.
  • Proof of Financial Responsibility must be
    submitted to the Dept before product can be put
    in the tank.

13
Part ASection 4 Registration and Notification
RequirementsRetrofits
  • DNREC must approve or deny submitted retrofit
    plans within 10 days of receipt.
  • Work may begin as soon as DNREC issues approval
    of the retrofit plans.
  • DNREC must be notified within 48 hours of
    starting work.
  • A new form must be submitted if work does not
    begin within 60 days of DNRECs approval.
  • Retrofit approvals must be kept on site work may
    be stopped if approvals are not on hand.

14
Parts B, C and DRequirements for Installation,
Operation and Maintenance of USTs
15
Parts B, C and D
  • Part B Petroleum USTs
  • Section 1 USTs installed after the new
    Regulations are effective
  • Section 2 USTs installed before the new
    Regulations are effective
  • Part C Heating Fuel (HF) USTs (greater than
    1,100 gallons)
  • Section 1 HF USTs installed after the new

    Regulations are effective
  • Section 2 HF USTs installed after 5/14/93 and
    before the new
    Regulations are
    effective
  • Part D Hazardous Substance USTs
  • All Hazardous Substance USTs regardless of date
    of installation

16
Parts B, C and D
  • NEW INSTALLATION REQUIREMENTS

17
Parts B, C and D New Installation Requirements
  • Components of the UST system must be UL or
    equivalent 3rd party certified
  • All equipment must be maintained such that
    manufacturers warranties are not voided for the
    warrantys lifetime

18
Parts B, C and D New Installation Requirements
  • UST systems must be Secondarily Contained
  • Double-Wall Tank
  • Double-Wall Piping
  • Liquid Tight Containment Sumps
  • tank top and dispensers
  • Vent piping double walled where necessary to
    protect water resources

19
Parts B, C and D New Installation Requirements
  • UST System Construction
  • Cathodically Protected Steel
  • Sacrificial anode only no impressed current on
    new installations
  • Fiberglass Reinforced Plastic
  • Steel with Non-Metallic or Coated Outer Shell

20
Parts B, C and D New Installation Requirements
  • Release Detection Methods
  • Continuous Interstitial Monitoring
  • Automatic Tank Gauge with monthly tank testing
  • Other methods approved by DNREC
  • NOTE
  • Tank Tightness Testing may be used for Heating
    Fuel and Emergency Generator USTs only
  • Petroleum and Hazardous Substance USTs must also
    perform inventory control

21
Parts B, C and D New Installation Requirements
  • Spill Containment
  • Spill buckets installed at fill ports must have a
    minimum 15-gallon capacity. Alternative designs
    may be allowed with prior approval by the TMB.
  • 5-gallon minimum capacity spill buckets must be
    installed at Stage I vapor recovery adapters and
    around sensor risers.

22
Parts B, C and D New Installation Requirements
  • Overfill Prevention
  • Ball floats are not allowed as overfill
    protection if the system contains suction piping,
    remote fill lines, remote vapor lines, receives
    pressurized deliveries, or any UST system that
    stores Used Oil.
  • UST Systems that receive pressurized deliveries
    require a high level alarm set to 90 full or an
    automatic flow shut-off valve designed for
    pressurized deliveries for overfill protection.

23
Parts B, C and D New Installation Requirements
  • Piping Construction
  • Piping interstitial spaces must be left open and
    slope to the tanks at a minimum of 1/8" per foot
    so that product may travel back to the tank-top
    containment sump and be detected by an electronic
    sensor.

24
Parts B, C and D
  • OPERATION and MAINTENANCE REQUIREMENTS

25
Parts B, C and D Operation and Maintenance
Requirements
  • Release Detection
  • Interstitial Monitoring devices must be checked
    once a month and the results recorded.
  • Automatic Tank Gauge systems must pass a leak
    detection test at least once a month and the
    results must be recorded.
  • Tank Tightness Tests (Heating Fuel and Emergency
    Generator USTs only) must be performed once a
    year and the test results recorded.

26
Parts B, C and D Operation and Maintenance
Requirements
  • Release Detection Records
  • Release Detection Records must be maintained for
    the life of the UST system.
  • If required Release Detection or Inventory
    records are not available the Department may
    require tank and line tightness tests or soil
    sampling at the Owner and Operators expense.

27
Parts B, C and D Operation and Maintenance
Requirements
  • Release Detection Equipment Maintenance
  • Interstitial Monitoring and Automatic Tank Gauge
    equipment must be inspected and tested by a
    qualified service technician at least once a
    year.
  • Records of inspections must be kept for the life
    of the UST system.

28
Parts B, C and D Operation and Maintenance
Requirements
  • Containment Sumps
  • All Containment Sumps must be designed to be
    liquid tight and must pass a liquid tightness
    test once a year.
  • Spill Containment Buckets
  • Spill buckets must be empty at all times and must
    pass a liquid tightness test once a year.

29
Parts B, C and D Operation and Maintenance
Requirements
  • Line Leak Detectors
  • All Mechanical and Electronic Automatic Line Leak
    Detectors must pass a function test once a year.
    (3gph at 10 psi)
  • Electronic Line Leak Detectors performing monthly
    line tightness testing must be approved by the
    Department as an alternative method of release
    detection.

30
Parts B and D Operation and Maintenance
Requirements
  • Inventory Control
  • Inventory control records must now be reconciled
    to 0.5, not 1 130 gallons.
  • Any inventory that shows a constant negative
    trend must be treated as an indicated release,
    even if the leak check calculation passes.
    (will be added to draft regs)
  • Any tank storing an ethanol blend must be checked
    for water once a day. Tanks storing other
    products must be checked once a week.

31
Parts B, C and D Operation and Maintenance
Requirements
  • Routine Inspections
  • The Owner and Operator must conduct a visual
    inspection of all dispensers, dispenser sumps,
    access ports and Containment Sumps once a month.
  • A record of each inspection must be kept on file
    for at least 3 years and must include any repairs
    made as a result of the inspection.

32
Parts B, C and D Operation and Maintenance
Requirements
  • Cathodic Protection (CP)
  • All CP systems must be tested by a NACE-certified
    professional within 6 months of installation,
    once a year thereafter, and within 6 weeks of any
    underground work at or near the site. Records of
    the tests must be permanently maintained.
  • If the system fails the test, the cause must be
    determined and repairs made by a NACE-certified
    professional.

33
Parts B, C and D Operation and Maintenance
Requirements
  • Cathodic Protection (CP)
  • Impressed current CP cannot be used to make
    repairs or upgrades to failing CP systems.
  • The Department may require an integrity
    assessment if a CP system is inactive, fails
    testing, or is not being tested as required.

34
Parts B, C and D Operation and Maintenance
Requirements
  • Cathodic Protection (CP)
  • Impressed current CP (ICCP) systems cannot be
    turned off except during work on the system or
    power failures.
  • All ICCP rectifiers must be read once a month and
    the results permanently recorded.
  • Any repairs, retrofits, or upgrades to ICCP
    systems are prohibited.

35
Part B
  • USED OIL
  • EMERGENCY GENERATOR
  • USTs

36
Used Oil USTs
  • Used Oil tanks may use a high level alarm or a
    standard operating procedure for overfill
    prevention. Ball floats and flapper valves are
    not acceptable.
  • Used oil tanks with capacities of 1,000 gallons
    or less may use manual tank gauging (MTG) for
    release detection.
  • Used oil tanks with capacities of 2,000 gallons
    or less may use manual tank gauging in place of
    modified inventory control.

37
Emergency Generator USTs
  • Emergency Generator tanks must utilize at least
    one method of release detection within one year
    of the effective date of the new Regulations.
  • NOTE Existing piping is exempt from release
    detection
  • Annual tightness testing will be allowed as a
    release detection option for the lifetime of the
    UST system.
  • Emergency generator UST systems will continue to
    be exempted from inventory control.

38
Phase-Outs for Existing USTs
  • Tank Tightness Testing will not be allowed as a
    primary form of release detection after December
    31, 2008.
  • Observation Tubes, Monitoring Wells, Vapor Tubes,
    or U-tubes will not be allowed as a primary form
    of release detection 5 years after the effective
    date of the new Regulations.

39
Repairs, Retrofits, Upgrades
  • All Repairs, Retrofits and Upgrades must be made
    in accordance with the new tank standards.

40
Upgrades Required
  • Containment Sumps
  • Existing containment sumps must be tightness
    tested by July 31, 2008, and replaced within a
    year if they fail the test.
  • Sumps that are not designed to be liquid tight
    must be replaced with liquid tight containment
    sumps within 1 year of the effective date of the
    new Regulations.

41
Upgrades Required
  • Double Elbow Swing Joints must be replaced with
    Flexible Connectors by July 31, 2008.
  • A spill containment device must be installed on
    all Stage I vapor recovery adaptors by Dec. 31,
    2007.

42
Change in Service Requirements
  • An UST system that is out of service for a year
    or more must be emptied of all product.
  • A site assessment must be completed after an UST
    system is out of service for a year or more.

43
Removal and Closure in Place Requirements
  • It is the Owners and Operators responsibility
    to submit a closure report or have it submitted
    on their behalf to the Department within 60 days.

44
Change in Product Requirements
  • A site assessment must be completed within 30
    days of the cleaning of an UST system for a
    change in product stored.

45
Part ERequirements for Release Reporting,
Release Investigation, Corrective Action and Site
Closure
46
Part E General Changes
  • Consolidation
  • Spans release indication through LUST site
    closure
  • Requirements remain consistent with existing
    Regulations with some new additions

47
Part E Section 1 Release Reporting Requirements
  • Defines Indicated Release, abnormal operating
    conditions and details reporting
  • Anything indicating a release must be reported to
    the release hotline and TMB (regardless of who
    observes it) within 24hrs
  • Abnormal operating conditions must be reported to
    TMB within 24hrs

48
Part E Section 2 Indicated Release
Investigation Requirements
  • Rewrite of Part B, Section 4.01 (Initial
    Response) and Part A, Section 8.04 (Leak
    Investigation due to Inventory Discrepancies) of
    current Regulations
  • Within 30 days of completion of any UST system
    Repairs or release investigation, submit
    documentation to TMB

49
Part E Section 3 Release Response Requirements
  • Rewrite of Part B, Section 4.01 with an expansion
    of Free Product Removal subsection
  • Light Non-Aqueous Phase Liquid (LNAPL) is now
    defined in Part A distinguishes between Mobile
    NAPL, Free LNAPL and Residual LNAPL. Free
    Product is history!
  • Requires development of LNAPL Conceptual Site
    Model (LCSM) when LNAPL exists

50
Part E Section 3 LNAPL Conceptual Site Model
  • Goal is to effectively determine the optimum
    corrective action methodology for sites with
    LNAPL
  • Result Close sites and protect HHE
  • Tiered type guidance in developing LCSM to follow

51
LNAPL Additional Information
  • http//clu-in.org/download/rtdf/napl/Decision
  • Framework.pdf
  • http//groundwater.api.org/lnaplguide/

52
Part E Section 4 Hydrogeologic Investigation
Requirements
  • No significant changes

53
Part E Section 5 Corrective Action Requirements
  • Corrective Action Work Plan (CAWP) must include
    design information and an estimated time frame
    for cleanup completion
  • CAWP must be implemented within TMB approved
    time-frame (v.s. 30 days)
  • Corrective action measures must be reviewed every
    12 months for effectiveness towards achieving
    cleanup goals in the proposed time-frame and
    revised accordingly

54
Part E Section 5 Corrective Action
Requirements (continued)
  • Post-remedial monitoring is required (4 quarters
    or Department approved schedule)
  • All data shall be reported per the Departments
    specifications and will be detailed in
    correspondence and/or guidance

55
Part E Section 6 Site Closure Requirements
  • No longer requires signature of DE PG or DE PE on
    site closure report
  • Closure approval is based on current land use and
    additional corrective action may be necessary if
    land use changes in the future

56
Part FFinancial Responsibility Requirements for
Underground Storage Tank Systems
57
Part FSection 1
  • Financial Responsibility requirements expanded to
    include Hazardous Substance USTs.
  • Hazardous Substance USTs must show proof of FR by
    January 1, 2008.

58
  • Part G
  • Requirements for Contractor Certification

59
Part G Contractor CertificationGeneral Changes
  • Make Contractor requirements more specific
  • Requirements remain consistent with existing and
    proposed Regulations with some new additions

60
Part G Section 1
  • Delete Interior Lining of USTs for Companies and
    Supervisors
  • Provide proof of Contractors Pollution Liability
    Insurance in the amount of 250,000

61
Part G Section 1.4
  • Add standards of performance for Companies and
    Supervisors
  • Certified contractor must report contamination
    encountered while performing UST activities

62
  • Part H
  • Requirements Governing Reimbursement for
    Petroleum Contamination Site Cleanup through the
    Early Compliance and Detection Incentive Program
    (ECDI)

63
Part HECDI Program
  • No changes

64
What Next?
  • Incorporate public comments into the draft
    Regulations
  • Hold a second set of public workshops if the
    changes are significant
  • Publish Proposed Regulations in the State
    Register 20 days prior to the Public Hearing
  • After the Regulations are effective DNREC will
    hold training sessions and will publish a new
    Technical Guidance Manual

65
Where to find information
  • DNREC, Tank Management Branch
  • http//www.dnrec.state.de.us/dnrec2000/Divisions/A
    WM/ust/
  • Delaware Information Subscription Service
  • http//diss.state.de.us/DWS/public.diss
  • Delaware Register of Regulations
    http//regulations.delaware.gov/services/register.
    shtml

66
To submit comments by October 30,
2006DNRECTank Management Branch391 Lukens
DriveNew Castle, DE 19720302-395-2500jill.hall
_at_state.de.us
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