Title: Rhode Island’s Underground Storage Tank Program
1Rhode IslandsUnderground Storage TankProgram
RI Department of Environmental Management
2Disclaimer
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.
3What 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
4Why 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
5Program 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
6Program 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
7Program 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
8Program 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
9Exempted 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
10UST 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
11UST 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
12Existing 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
13Leak 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
14Leak 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
15Operation 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
16Abandonment 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)
17Early 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
181998 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!
19New 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
20New 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
21General 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
22Installation 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
23Installation 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
24Installation 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
25Post-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
26Tank 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
27Tank 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
28Cathodic 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
29Cathodic 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
30Cathodic 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
31After 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
32After 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
33Interior 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
34After 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
35UST 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
36UST 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
37UST 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
38Questions 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.
39Questions 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).
40Final Thoughts
- Expecting an extension to the 1998 deadline?-
Forget about it! - Pursue IFCI certification
41Any 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
42or 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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