Underground Storage Tanks at Duke

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Underground Storage Tanks at Duke

• Duke Medical Center
• 8 permitted USTs located on medical campus
• Range in size from 2,000 gallons to 30,000
  gallons
• Proper management of these USTs will hopefully
  prevent a future LUST or a large surface spill of
  petroleum products

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USTs at Duke

• Operating permits are required for all USTs in NC
  (15A NCAC 2N)
• Associated yearly fee
• Compliance questionnaire must be completed and
  signed before the permit will be issued.

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UNDERGROUND STORAGE TANKS

• 40 CFR 280 - Technical Standards and Corrective
  Action Requirements for Owners and Operators of
  Underground Storage Tanks (USTs).

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Underground Storage Tanks

• General Standards
• No person may install an UST system for the
  purposes regulated substances unless the UST
  system
• will prevent releases due to corrosion or
  structural failure
• is cathodically protected against corrosion,
  constructed of noncorrodible material, steel clad
  with a noncorrodible material, or designed to
  prevent the release of any stored substance and

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Underground Storage Tanks

• Is constructed or lined with material that is
  compatible with the stored substance.
• A UST system may be installed if a corrosion
  expert determines that the site will not be
  corrosive enough to cause a release due to
  corrosion during operating life.

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Underground Storage Tanks

• Performance Standards for New UST Systems
• Tanks and Piping
• must be properly designed and constructed, any
  part underground must be protected from corrosion
• constructed of fiberglass reinforced plastic, or
• constructed of steel and cathodically protected
  in the following ways
• tank is coated with suitable dielectric material
• field installed cathodic protection designed by
  expert
• Impressed current systems are designed to allow
  determination of current operating status and
  systems maintained.

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Double Walled Fiberglass Tank
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Underground Storage Tanks

• constructed of steel fiberglass reinforced
  plastic composite or
• constructed of metal without additional corrosion
  protection measures provided that
• corrosion expert determines corrosion at site is
  not a hazard
• owners/operators maintain records that
  demonstrate compliance with corrosion experts
  findings
• implementing agency determines tank construction
  and corrosion protection sufficient to prevent
  the release or threatened release of any stored
  regulated substance in a manner that is no less
  protective of human health and the environment

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Underground Storage Tanks

• Spill and Overfill Protection
• to prevent spilling and overfilling associated
  with product transfer to the UST system
  owners/operators must use the following
  equipment
• spill prevention equipment that will prevent a
  release of product when the transfer hose is
  detached from the fill pipe
• overfill prevention equipment that will
• automatically shut off flow into the tank when
  the tank is no more than 95 full, or

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Underground Storage Tanks

• Alert the transfer operator when the tank is no
  more than 90 full be restricting the flow into
  the tank or triggering the high-level alarm, or
• restrict flow 30 minutes prior to overfilling,
  alert the operator with a high level alarm one
  minute before overfilling, or automatically shut
  off the flow into the tank
• Owners/operators are not required to use spill
  and overfill prevention equipment if alternated
  equipment is used that is determined by the
  implementing agency to be no less protective of
  human health and the environment or the UST
  system is filled by transfers of no more than 25
  gallons at a time.

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Underground Storage Tanks

• Installation
• All tanks and piping must be properly installed
  in accordance with a code of practice developed
  by a national recognized association or
  independent testing laboratory and in accordance
  with the manufacturers instructions.
• Certification
• owners/operators must provide certification of
  compliance on the UST notification form

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Installation of an UST
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Underground Storage Tanks

• Upgrading existing USTs
• Tank upgrading requirements
• tank may be upgraded to meet one of the following
  requirements
• Interior lining - must be installed in accordance
  with 280.33 and within 10 years after lining and
  5 years thereafter, lining must be inspected and
  found to be structurally sound
• Cathodic protection - must meet the requirements
  of 280.20(a)(2) and the integrity of the tank is
  ensured using
• internally inspected and assessed to ensure the
  tank is structurally sound and free of corrosion
  holes prior to installation

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Underground Storage Tanks

• tank had been installed for less than 10 years
  and is monitored monthly for releases, or
• tank has been installed for less than 10 years
  and is assessed for corrosion holes by conducting
  two tightness tests that meet the requirements of
  280.43(2). The first tightness test must be
  conducted prior to installation of system. The
  second must be conducted between 3 and 6 months
  following first operation on the system, or
• tank is assessed for corrosion holes by a method
  that is determined by the implementing agency to
  prevent release

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Underground Storage Tanks

• Internal lining combined with cathodic protection
• lining installed in accordance with 280.33
• cathodic protection system meets requirements of
  280.20
• Piping upgrades
• metal piping that routinely contains regulated
  substances and is in contact with the ground must
  be cathodically protected .
• Spill and overfill protection
• must comply with the new UST system spill and
  overfill prevention equipment requirements
  specified in 280.20(2).

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Underground Storage Tanks

• Notification Requirements
• Must notify state and local agency when bringing
  tank system online and certification of
  compliance with regulation
• NC UST Section Forms UST-6A/B, UST-15, etc.
• General Operating Requirements
• Owners/operators must ensure that releases due to
  spilling or overfilling do not occur.
• Cathodic protection systems must be inspected for
  proper operation by a qualified tester.

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Underground Storage Tanks

• Compatibility
• Owners/operators must use an UST system made of
  or lined with materials that are compatible with
  the substance stored in the UST system.
• Repairs Allowed
• Owners/operators must ensure that repairs will
  prevent releases due to structural failure or
  corrosion as long as the UST system is used to
  store regulated substances.

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Underground Storage Tanks

• Repairs to fiberglass-reinforced tanks may be
  made by the manufacturers authorized
  representative
• Leaking metal pipes must be replaced. Fiberglass
  pipes and fittings may be repaired.
• Repaired tanks and lines must be fit tested.
• Repaired tanks are internally inspected
• Repaired portion of tank must be monitored
  monthly, or
• as specified by implementing agency
• Within 6 months following the repair of any
  cathodically protected UST system must be tested
  in accordance with the regulations to ensure
  proper operation,

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Underground Storage Tanks

• Owner/operators must maintain records of each
  repair for the remaining operating life of UST
  system.
• Release Detection
• must provide a method, or combination of methods
  of release detection that
• can detect a release from any portion of the tank
  and the connected underground piping that
  routinely contains product,

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Underground Storage Tanks

• Is installed, calibrated, operated, and
  maintained in accordance with the manufacturers
  instructions and
• meet the performance requirements in 280.43 or
  2880.44.
• Any existing UST system that can not apply a
  method of release detection must close the
  system.
• Methods
• Inventory control, manual tank gauging, tank
  tightness testing, vapor monitoring, groundwater
  monitoring, interstitial monitoring, line leak
  detectors

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• Reference
• http//www.wastenotnc.org/ust/ust_main.html
• http//www.wastenotnc.org/ust/forms.html