Underground Storage Tank Management Regulations for Commercial Heating Oil Tanks

1. Underground Storage Tank Management Regulations for Commercial Heating Oil Tanks 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 being binding upon the Department- neither the Department’s interpretation of applicable regulations, nor any policy which may have been developed through 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 petroleum products or hazardous materials from USTs can contaminate large groundwater supplies • Leaks can also create health and fire hazards in nearby buildings

5. Program Elements for Heating Oil USTs • UST Registration • Existing System Requirements • Spill Protection • Leak Detection • Abandonment Prohibition • Tank Closure • New/Replacement Tank Standards • New Installation Standards

6. UST Registration • USTs storing fuel oil for heating commercial facilities must be registered with DEM - including schools • Commercial USTs storing motor fuel or hazardous materials must also be registered • includes waste oil USTs • includes holding tanks serving floor drains

7. UST Registration (cont’d.) • Annual fee- $50 per tank (municipalities exempt); DEM issues annual certificate • Application provides information on tank system age, construction, contents and ownership

8. Existing System Requirements-Spill Protection • Spill containment required on all registered USTs since January 1, 1993 • three gallon capacity • above-ground fills exempt

9. Existing System Requirements- Leak Detection • Leak detection is not specifically required for USTs holding heating oil for on-site consumptive use • DEM recommends periodic tightness testing, and other inventory controls, as good management practices • DEM licenses testers and approves test methods • All releases must be reported immediately to DEM, the local water supplier (if sensitive area), and the local fire authority

10. Existing System Requirements- Abandonment Prohibition • Abandonmentmeans 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)

11. Existing System Requirements-Tank Closure • Closure of commercial tanks must be pre-approved by DEM • $75 application fee • DEM conducts inspection of excavation • must schedule closure inspection • 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 only required for motor fuel USTs • Closures-in-place only approved under special conditions

12. New Installation 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

13. New Installation Standards (cont’d.) • Tanks must be double-walled, steel tanks must have corrosion protection • Piping must be double-walled, with containment sump • UL or ULC listed, National Codes of Practice • Entire system precision tested upon installation • Spill containment and overfill protection required

14. General Approval Process • Submit scope of work to DEM thirty (30) days in advance • Written approval from DEM required prior to commencement of work (including product piping replacement) • Notify DEM 48 hours prior to installation • Written verification of completion within fifteen (15) days

15. 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

16. 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 • 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

17. 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

18. Self-Audit Checklist • Are all your USTs registered? • check DEM registration database • make sure registration fees are paid in full • Make sure required documentation is submitted • spill containment installation notices • Plan for replacement • remove/replace (old) tanks • evaluate new storage technology- UST vs AST • Gasoline or generator fuel USTs? Leak detection, 1998 upgrade requirements, and others apply

19. Questions and Answers • What about above-ground storage tanks? • ASTs are regulated by DEM • Installations are approved by local authorities • What about the 1998 upgrade requirements? • These only apply to motor fuel USTs, and fuel oil distribution USTs. • What about financial responsibility? • This is only required for motor fuel USTs, and fuel oil distribution USTs.

20. Any questions? Call us at- 277-OTCA (6822) Tom Epstein- ext. 7501 fax 222-3810 UST Program 222-2797 Eric Beck- ext. 7504 fax 222-3813

21. 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