Rhode Island’s Underground Storage Tank Program

1. Rhode Island’sUnderground Storage TankProgram RI Department of Environmental Management

2. 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 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.

3. 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

4. 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

5. 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

6. Program History (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

7. Program History (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

8. Program 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

9. 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

10. 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

11. UST Registration (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

12. 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

13. Leak Detection for Tanks (for existing 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

14. 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

15. 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

16. 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)

17. 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

18. 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 • Don’t wait ‘til 98!

19. 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

20. New Tank Standards (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

21. 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

22. 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

23. Installation Paperwork (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

24. Installation Paperwork (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

25. 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 manufacturer’s installation checklist

26. 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

27. Tank Closure (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

28. Cathodic Protection • Required for both tanks and piping • Impressedcurrent 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

29. Cathodic Protection O&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

30. Cathodic Protection O&M (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

31. 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

32. After Installing Cathodic Protection (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

33. 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

34. 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

35. 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

36. 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

37. UST Financial Responsibility (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

38. 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.

39. Questions and Answers (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).

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

41. 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

42. 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