Petroleum Storage Tank Bureau

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Petroleum Storage Tank Bureau
July 2002 presentation Draft Proposed Changes to
Storage Tank Regulations 20.5 NMAC
Part 6 Release Detection Part 7 Release
Reporting Part 8 Out-of-service Systems and
Closure
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Petroleum Storage Tank Bureau
20.5.6 NMAC Release Detection

• Section 600 Deadlines for Release Detection
  for All Storage Tank Systems
• Section 601 Requirements for Storage Tank
  Systems
• Section 602 Requirements for Hazardous Substance
  Storage Tank Systems
• Section 603 Methods of Release Detection for
  Tanks
• Section 604 Methods of Release Detection for
  Piping
• Section 605 Alternative Methods
• Section 606 Record Keeping

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Petroleum Storage Tank Bureau
20.5.7 NMAC Release Reporting, Investigations,
and Confirmation Detection

• Section 700 Reporting of Spill or Release
• Section 701 When Releases and Suspected
  Releases must be Reported
• Section 702 Investigation of off-site impacts
• Section 703 Release Confirmation Steps
• Section 704 Reporting of Cleanup of Spills
  and Overfills

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Petroleum Storage Tank Bureau
20.5.8 NMAC Out-of-Service Systems and Closure

• Section 800 Temporary Closure
• Section 801 Permanent Closure and Changes in
  service
• Section 802 Assessing the Site at Closure or
  Change in service
• Section 803 Applicability to Previously Closed
  Storage Tank Systems
• Section 804 Closure Records

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Petroleum Storage Tank Bureau
20.5.6 NMAC Part 6 - Release Detection
Presented by Joe Godwin Stakeholders, 7/31/02
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Petroleum Storage Tank Bureau
Section 600 - Deadlines

• No changes for underground storage tank systems.
• Existing USTs must have met requirements by 1998
  Deadline
• New USTs must meet requirements upon installation.

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Petroleum Storage Tank Bureau
AST Systems Deadlines

• Installed on or before June 30, 1991 or where
  date of installation is unknown shall be
  inspected and tested by one year from effective
  date of regulations. The testing will be to
  ascertain if the tank and piping are structurally
  sound and if a release is occurring.
• If a release is suspected from the results of the
  tank testing the owner and operator will comply
  with 20.5.7 NMAC

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Petroleum Storage Tank Bureau
AST Systems Deadlines

• Owners and Operators will meet release detection
  requirements by July 1, 2004.
• Regardless of age any aboveground system that is
  completely aboveground and can be visibly
  inspected does not have to be inspected and
  tested as required by D.1.
• Owners and Operators will close any system by
  July 1, 2004 if they cannot apply a method of
  release detection that complies with Part 6.

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Petroleum Storage Tank Bureau
Section 601 - Petroleum Tanks

• All petroleum storage tank systems will be
  monitored monthly for releases by applicable
  method in 603.
• No significant changes for UST systems from
  previous regulations.
• AST systems can perform monthly inventory control
  in conjunction with testing in accordance with
  either API 653 or STI SP001-00.

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Petroleum Storage Tank Bureau
Petroleum Piping

• Requirements apply to all petroleum piping.
• All piping that conveys regulated substances by
  pressure will be tightness tested annually unless
  the entire piping run is aboveground and can be
  visually inspected.
• All pressurized piping will be equipped with an
  automatic line leak detector.

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Petroleum Storage Tank Bureau
Petroleum Piping

• All pressurized and suction double-walled piping
  whether aboveground or underground shall have a
  method of release detection that monitors the
  interstice of the piping.
• No release detection on suction piping if it
  meets all of the standards listed in 601.B.2.

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Petroleum Storage Tank Bureau
20.5.6 NMAC Part 6 - Release Detection
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Petroleum Storage Tank Bureau
Section 603 METHODS OF RELEASE DETECTION FOR
TANKS
Presented by John Cochran Stakeholders, 7/31/02
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Petroleum Storage Tank Bureau
There are three types of leak detection methods

• Internal
• External
• Interstitial

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Petroleum Storage Tank Bureau
Leak Detection Methods

• Internal monitoring the volume of liquid in the
  tank to try to detect a loss
• Inventory control and tank tightness testing
• Manual tank gauging
• Automatic tank gauging
• Statistical inventory reconciliation (SIR)

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Petroleum Storage Tank Bureau
Leak Detection Methods

• 2. External monitoring the environment outside
  the tank to detect evidence of a leak
• Groundwater monitoring (UST only)
• Vapor monitoring (UST only)
• Visual inspection (ASTs only)

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Petroleum Storage Tank Bureau
Leak Detection Methods

• 3. Interstitial monitoring the space between
  the primary and secondary walls of a secondarily
  contained tank
• Double-wall tanks
• Secondary containment with interstitial monitor
  

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Petroleum Storage Tank Bureau
Release Detection Requirements for Underground
Storage Tanks have not changed!
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Petroleum Storage Tank Bureau
RELEASE DETECTION FOR ABOVEGROUND STORAGE TANKS
(ASTs)
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Petroleum Storage Tank Bureau
Release Detection Methods for ASTs

• Inventory Control and Tank Tightness Testing
• Automatic Tank Gauge
• Interstitial Monitoring
• Visual Inspection

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Petroleum Storage Tank Bureau
Release Detection Methods for ASTs

• Inventory Control and Tank Tightness Testing
• Tank tightness tests at 0.2 gallons-per-hour
  (gph) must be performed 10 years after
  installation and every 10 years thereafter

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Petroleum Storage Tank Bureau
Release Detection Methods for ASTs

• 2. Automatic Tank Gauge
• Must be able to detect a 0.2 gph leak from any
  portion of the tank that routinely contains a
  regulated substance

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Petroleum Storage Tank Bureau
Release Detection Methods for ASTs

• 3. Interstitial Monitoring
• Double wall tanks
• Testing method complies with the requirements of
  the current edition of an industry code or
  standard approved in advance by the department

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Petroleum Storage Tank Bureau
Release Detection Methods for ASTs

• 3. Interstitial Monitoring
• ASTs inside secondary containment
• tanks manufactured or upgraded to contain a
  double-walled bottom which can be remotely
  monitored or
• tanks installed inside the secondary containment
  with an impervious barrier beneath the tanks and
  the interstice can be remotely monitored

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Petroleum Storage Tank Bureau
Release Detection Methods for ASTs

• 3. Interstitial Monitoring
• ASTs inside secondary containment
• Groundwater, soil moisture, or rainfall will not
  render the testing or sampling method inoperative
  
• Owners and operators conduct an annual test of
  the operation of the interstitial sensor in
  accordance with the manufacturers requirements

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Petroleum Storage Tank Bureau
Release Detection Methods for ASTs

• 4. Visual Inspection
• May be used if all portions of the tank,
  including the tank bottom, are visible and
  readily accessible.
• The tank(s) must be inspected monthly and the
  owner and operator must keep a log that includes
  the date, time, initials of the inspector,
  comments on the condition of each tank, and the
  results of each inspection

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Petroleum Storage Tank Bureau
Section 604 - METHODS OF RELEASE DETECTION FOR
PIPING
Presented by Joseph Romero Stakeholders, 7/31/02
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Petroleum Storage Tank Bureau
Release Detection Methods for Piping

• Automatic Line leak Detectors
• Line Tightness Testing
• Interstitial Monitoring
• Visual Inspection

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Petroleum Storage Tank Bureau
Release Detection Methods for Piping

• 1. Automatic Line Leak Detectors
• All pressurized piping will be equipped with an
  automatic line leak detector
• 2. Line Tightness Test
• Pressurized piping shall be tightness tested
  annually unless the entire piping run is
  aboveground and can be visually inspected

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Petroleum Storage Tank Bureau
Release Detection Methods for Piping

• 3. Interstitial monitoring
• Owners and operators may use interstitial
  monitoring if they ensure that interstitial
  monitoring for double-wall piping, under pressure
  and under suction, complies with the current
  edition of an industry code or standard approved
  in advance in writing by the department, or with
  piping manufacturers requirements

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Petroleum Storage Tank Bureau
Release Detection Methods for Piping

• 4. Visual inspection
• For above ground tanks, visual inspection may
  used for piping if all portions of the piping are
  visible and readily accessible, and are inspected
  monthly

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Petroleum Storage Tank Bureau
Section 605 - ALTERNATIVE METHODS
If owners and operators want to install another
method of release detection equipment for tank or
piping required in Section 601 through 604 of
20.5.6 NMAC in accordance with the current
edition of an industry code or standard, owners
and operators shall apply in writing to the
department, shall provide supporting
documentation, and shall not begin the
installation unless and until the department
approves the request in writing.
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Petroleum Storage Tank Bureau
Section 606 - Record Keeping
Presented by Patrick Moore Stakeholders, 7/31/02
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Petroleum Storage Tank Bureau
Record Keeping Requirements

• This Section Pertains To All Storage Tank System
  Owners and Operators ( AST and UST )
• If the owner and operator of a storage tank are
  separate persons, only one person is required to
  maintain the records required by this section
  however, both parties are liable in the event of
  noncompliance

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Petroleum Storage Tank Bureau
Record Keeping Requirements

• All written performance claims pertaining to any
  release detection system 5 years from date of
  installation
• Results of sampling, testing, or monitoring 1
  year
• Tank tightness testing Until the next test is
  conducted
• Written documentation of all calibration,
  maintenance, and repair of release detection
  equipment 1 year after the servicing work is
  completed
• Any schedules of required calibration and
  maintenance provided by manufacturer 5 years
  from date of installation

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Petroleum Storage Tank Bureau
20.5.7 NMAC Part 7 - Release Reporting,
Investigation, and Confirmation Detection
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Petroleum Storage Tank Bureau
Reporting of a Release

• Owners and Operators shall give notice of any
  known release, suspected release, or any spill,
  or any other emergency situation to PSTB within
  24 hours.

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Petroleum Storage Tank Bureau
Reporting of a Release

• Owner and Operator shall provide the following
  information
• Owner and operators name, address, and telephone
  number
• Facility agent in charge of the site name,
  address, and telephone number
• Site information (name, address, and location)
• Source and cause of spill, release or suspected
  release

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Petroleum Storage Tank Bureau
Reporting of a Release

• Owner and Operator shall provide the following
  information
• Description of spill, release or suspected
  release
• Estimated volume of spill, release or suspected
  release
• Any action taken to mitigate immediate damage
  from spill, release or suspected release

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Petroleum Storage Tank Bureau
Reporting of a Release
Owners and Operators shall mail or deliver a
written report and any investigation or follow-up
action taken or to be taken to the department
within 14 days.
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Petroleum Storage Tank Bureau
WHEN RELEASES AND SUSPECTED RELEASES MUST BE
REPORTED

• The discovery of regulated substances in the
  surrounding area, ie the presence of phase
  separated liquid and or vapors in soil,
  basements, utility lines, groundwater and
  drinking water, and nearby surface water
• Erratic behavior of product dispensing equipment
  
• Sudden loss of regulated substances
• Unexplained presence of water in the tank
• Presence of regulated substance in the
  interstitial space

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Petroleum Storage Tank Bureau
WHEN RELEASES AND SUSPECTED RELEASES MUST BE
REPORTED

• Anything other than a pass result from any
  release detection method
• Monitoring results from a release detection
  method that indicate a release may have occurred
  
• Sudden loss of regulated substances
• An indication from a field instrument.

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Petroleum Storage Tank Bureau
INVESTIGATION OF OFF-SITE IMPACTS
When required by the department, the owners and
operators shall follow Release Confirmation Steps
listed in Section 703 to determine if the storage
tank system is the source of off-site impacts.
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Petroleum Storage Tank Bureau
RELEASE CONFIRMATION STEPS
Unless corrective action is initiated in
accordance with Part 12 and 13, owners and
operators shall immediately investigate and
confirm all suspected releases of regulated
substances within 14 days
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Petroleum Storage Tank Bureau
RELEASE CONFIRMATION STEPS
Owners and operators shall use either system
test, monitoring result check or site check or
another procedure approved by the
department System Test- Owners and Operator
shall conduct appropriate tests approved by the
department eg line tightness test, tank
tightness test. Site Check- investigation where
contamination is most likely to be present.
Sample types, sample locations and measurement
methods, shall be approved by the department
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Petroleum Storage Tank Bureau
REPORTING AND CLEANUP OF SPILLS AND OVERFILLS

• Owners and operators shall contain and
  immediately clean up a spill or overfill and
  report to the department within 24 hours in the
  following cases
• Spill or overfill that results in a release that
  exceeds 25 gallons
• Spill or overfill that causes a sheen on nearby
  surface water
• Spill or overfill of a hazardous substance that
  results in a release that exceeds its reportable
  quantity

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Petroleum Storage Tank Bureau
REPORTING AND CLEANUP OF SPILLS AND OVERFILLS

• Owners and operators shall contain and
  immediately clean up any spill or release that is
  less than 25 gallons and a spill of hazardous
  substances that is less than its reportable
  quantity.
• Owners and operators shall notify the department
  if cleanup cannot be accomplished within 24
  hours.
• A release of hazardous substance in excess of its
  reportable quantity shall also be reported the
  National Response Center
•  

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Petroleum Storage Tank Bureau
20.5.8 NMAC Part 8 Out of Service Systems and
Closure
Presented by Keith Chavez and Tom Gray
Stakeholders, 7/31/02
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Petroleum Storage Tank Bureau
Storage Tank Temporary Closure Requirements

• Owners and Operators shall continue to operate
• Corrosion protection - 20NMAC5.5
• Any release detection method unless the tank is
  empty - 20NMAC5.6

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Petroleum Storage Tank Bureau
Storage Tank Systems Temporarily Closed for 3
months or more

• Requirements
• Maintain vents
• Cap and secure lines equipment
• Protect the tank from flotation
• Disconnect all piping from ASTs as soon as the
  tank is emptied

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Petroleum Storage Tank Bureau
Storage Tank Systems Temporarily Closed for 12
months or more

• Requirements
• Permanently close tanks if they dont meet new or
  upgrade standards (but spill and overfill
  requirements arent necessary)
• Comply with site assessment requirements
• Complete closure paperwork

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Petroleum Storage Tank Bureau
Placing Field Erected ASTs Back Into Service

• If a field-erected AST has been out of service
  for 3-12 months, prior to placing it back in
  service, the owner and operator shall
• Integrity test the tank
• Tightness test the piping
• Verify leak detector functionality

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Petroleum Storage Tank Bureau
Permanent Closure and Change in Service

• Requirements
• 30 Day Notification to PSTB
• Empty and properly dispose of tank sludge
• Remove or fill USTs
• Remove or dismantle ASTs if appropriate
• Utilize existing codes or standards
• Owners and operators held liable for
  non-compliance

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Petroleum Storage Tank Bureau
Assessing the Site at Closure or Change of Service

• Requirements Owners and Operators Shall
• Collect soil or water samples for analysis unless
  using vapor monitoring or groundwater monitoring
  as the method of leak detection
• Begin corrective action

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Petroleum Storage Tank Bureau
Previously Closed Systems
The Environment Department has the authority to
direct responsible parties to conduct site
assessments at locations where USTs were
permanently closed prior to 12/22/88, and at AST
sites where fuel systems were permanently closed
prior to 7/1/01
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Petroleum Storage Tank Bureau
Closure Records

• Requirements
• Owners or operators shall maintain their closure
  records for at least 3 years
• Site assessment records may be kept by the
  storage tank owners or operators, property owners
  or operators, or by mailing them to NMED
• The owner or operator may keep records, but both
  are liable for noncompliance

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Petroleum Storage Tank Bureau
History of 20NMAC5, Part 8
Previous regulations for UST systems for
temporary and permanent closure
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Petroleum Storage Tank Bureau
DRAFT REGULATION SCHEDULE (Tentative)

• September 4 - Release Parts 9, 10, 11
• September 10 - 1000 1200 Meet with Marina
  Owners, State Bar Office, 5121 Masthead
  NE, Albuquerque
• September 18, 900 1200, Stakeholders Meeting,
  Albuquerque Eastside Animal Center, 8920
  Lomas NE, Albuquerque
• End of October Stakeholders Meeting to discuss
  Parts 4 through 8