Rhode Island’s Underground Storage Tank Program

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Rhode IslandsUnderground Storage TankProgram
RI Department of Environmental Management
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Disclaimer
The 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 Departments 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 Departments interpretation of
applicable regulations, or any policy which may
have developed applying those regulations.
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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

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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

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Program 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

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Program History (contd.)

• 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

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Program History (contd.)

• 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

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Program Elements

• UST Registration
• Existing System Requirements
• leak detection
• OM/record-keeping
• abandonment prohibition
• Upgrading Requirements
• New/Replacement Tank Standards/Approvals
• tank closure
• cathodic protection
• Interior lining
• UST Professional Certification
• Financial Responsibility

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Exempted Tanks (partial 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

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UST 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

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UST Registration (contd.)

• 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

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Existing System Requirements

• 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

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Leak Detection for Tanks (for existing systems)

• Continuous monitoring
• double-walledgt interstitial monitoring
• single-walledgt 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

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Leak Detection for Piping (for existing 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

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Operation Maintenance (existing 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

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Abandonment 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)

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Early Upgrade Requirements

• 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

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1998 Upgrade Deadline- Corrosion Protection
forTanks and Piping

• Options
• close USTs/replace with new
• cathodic protection
• interior lining- lining only requires a variance
  none yet granted
• Dont wait til 98!

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New 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

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New Tank Standards (contd.)

• 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

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General 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

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Installation 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

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Installation Paperwork (contd.)

• cross-sectional view of the tank
• depth of excavation
• bedding thickness
• backfill depth
• supports and anchorage used
• dimensions and thickness of traffic pad

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Installation Paperwork (contd.)

• 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

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Post-Installation Paperwork

• 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 manufacturers installation
  checklist

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Tank 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

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Tank Closure (contd.)

• Residues must be managed appropriately
• must be transported off-site by permitted
  hazardous waste transporter
• Tank must be cut/cleaned per Fire Marshals
  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

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Cathodic 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

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Cathodic Protection OM

• 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

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Cathodic Protection OM (contd.)

• 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

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After Installing Cathodic Protection

• 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

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After Installing Cathodic Protection (contd.)

• 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

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Interior 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

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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

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UST Professional Certification

• 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

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UST Financial Responsibility

• Commercial gasoline USTs, and some others, must
  demonstrate financial responsibility for managing
  releases
• Several allowable mechanisms, including a
  financial test and private insurance

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UST Financial Responsibility (contd.)

• 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

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Questions and Answers

• 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.

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Questions and Answers (contd.)

• 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).

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Final Thoughts

• Expecting an extension to the 1998 deadline?-
  Forget about it!
• Pursue IFCI certification

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Any questions? Call us at-

• 222-OTCA (6822)
• Tom Epstein- ext. 7501
• fax [phone]
• UST Program
• 222-2797
• Greg Yekhtikian- ext. 7521
• fax [phone]

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or visit theOffice of Technical Customer
Assistanceat our new home-

• 235 Promenade Street Providence, RI 02908
• first door on left from the Beach Street entrance

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