This presentation addresses the regulations around underground storage tanks (USTs) and best practices for inspection, testing and removal. Find out whether your UST is regulated and what you need to do to stay compliant.

1. What the Regulatory Requirements
Mean for Your UST.
Underground
Storage
Tanks:

2. Meet Your Moderator:
James Ciccone

3.  All lines will be muted – please communicate
via the questions tab in your webinar panel.
 There will be live, interactive polling.
 There will be a Q&A session at the end of the
presentation – submit your question(s)
anytime throughout the webinar.
 Stick around for an exclusive offer at the end
of the webinar.
Webinar Overview

4. Meet Your Presenter:
Kevin Coulon

5. Our Key Message
Understand the requirements that
come with having a UST on your
property

6. Who Is This For?
EHS Managers
Facilities Managers
Property Managers

7. What Will You Learn?
How the Regulations have Changed
UST Inspection Requirements
How to Remove a UST

8. Poll Question
What is your greatest
challenge regarding
USTs?

9. Agenda
UST Overview & Regulations
Monitoring & Testing
Closure & Removal
Summary/Q&A

10. What is a UST?
As defined by Subtitle I in 40 CFR 280:
Tank system, including its piping, that has at least 10%
of its volume underground.

11. Federal UST Programs
Subtitle I Standards
• 40 CFR 280 – Technical
• 40 CFR 280 State program
approval
Subtitle C
• Amends 40 CFR 260, 261, 262,
265, 270 and 271
https://www.epa.gov/ust

13. Compliance
Schedule
• Phase-in of release detection for all
existing tanks over a five-year period
according to age (1989-1993)
• Add release detection to pressurized
product piping systems by
December 22, 1990
• Upgrade or replace as per new
standards within ten years
(December 22, 1998)

14. State Compliance
Schedule
• MA compliance date for removal of
all single walled UST – August 7,
2017
• RI compliance date for removal of all
single walled UST – December 22,
2017
• CA compliance date for removal of
all single walled UST – December
31, 2025

15. Inspection Requirements
• USTs that have not been inspected since 1998 had to be
inspected initially within 2 years of Federal Energy Bill (Aug.
2007)
• Periodic inspections must occur every 3 years thereafter (initially
by August 8, 2010)
This is a minimum requirement
Must be inspected by: EPA inspector, state agency inspector, inspector or
contractor duly designated by the state, or a private inspector operating
under a 3rd party inspection program paid for by the owner or operator
• Operator must perform leak detection tests monthly

16. Tank Requirements
• Corrosion resistant single-wall
• Spill and overfill prevention
 Prevention of transfer hose
disconnection spills – catchment
basin
 Overfill prevention – either auto
shut-off at 95% or operator alert at
90% full
• Release detection
• Proper installation standards

17. Exclusions Under Subtitle I
• Farm or residential tanks of 1,100 gallons
or less capacity storing motor fuel for
noncommercial purposes
• Tanks storing heating oil for consumptive
use on the premises where stored
• Septic tanks
• Pipeline facilities (including gathering
lines) regulated under the Natural Gas
Pipeline Safety Act of 1968, the
Hazardous Liquid Pipeline Act of 1979, or
state laws comparable to these Acts
• Surface impoundments, pits, ponds, and
lagoons

18. Exclusions Under Subtitle I
• Stormwater or wastewater
collection systems
• Flow-through process tanks
• Liquid traps or associated
gathering lines directly related to oil
or gas production and gathering
operations
• Storage tanks situated on or above
the floor of underground areas,
such as basements and cellars

19. Major Provisions Under Subtitle I
• 9002 – Owner must notify state of UST existence
• 9003 – EPA must promulgate regulations applicable to all
owners; issue design, construction, installation, and
compatibility standards for new tanks, as well as
requirements applicable to all tank owners and operators
concerning leak detection, recordkeeping, reporting,
closure, corrective action, and financial responsibility
• 9003(h) – gives states authority to clean-up petroleum
releases or require the owners/operators to do so
• 9004 – authorizes states to implement stricter regulations

20. Agenda
UST Overview & Regulations
Monitoring & Testing
Closure & Removal
Summary/Q&A

21. How often do you
inspect your UST?
Poll Question

22. Cause of Release
• Most releases come from the pipe, not the tank itself
• Filling is the greatest cause
 Spilling
 Overfilling
• Corrosion, poor workmanship, natural events and
accidents are the main reasons for pipe failure

23. Tank Tightness Testing
25% of UST systems are
found to be “non-tight” when
testing under today’s
standards
Loose tank fittings and faulty
piping account for 84% of
these failures

24. Pre-Existing Tanks
• Most existing tanks are bare
steel (dating back before
1998)
• New technology
 STI-P3 (industry standard)
 Electrical isolation
 Protective coating
 Cathodic protection (galvanized)
 FRP(fiberglass reinforced
plastic)

25. Monitoring & Leak
Requirements
Leak detection
Corrosion protection
Spill/overfill prevention

26. Leak Detection: 3 Choices
1. Monthly monitoring
2. Monthly inventory control and 5-
year tank tightness testing on
tanks with overfill and corrosion
protection (only until 1998 or 10-
years old)
3. Monthly inventory control and
annual tank tightness testing
(only until 1998)

27. Leak Detection Alternatives
• Inventory reconciliation
• Automatic Tank Gauging (ATG)
• Subsurface monitoring (vapor and ground
water)
• Interstitial monitoring off double-wall tank
systems and secondary containment

28. Automatic Tank Gauging
Detection accuracy of
.2GPH
Monthly inventory control
must be used

29. Continuous Statistical
Leak Detection
• Monitors fuel height and temperature during idle times
• Uninterrupted business for 24-hour stations or around
the clock fueling operations
• Automatic leak test every 24 hours
• Meets federal and state requirements for monthly
monitoring

30. Monitoring
Wells
Installed in backfill area
as close to tank as
possible
Vapor or ground water
monitoring

31. Cathodic Protection
• Galvanized
 Uses a sacrificial
anode
• Impressed
 Uses a junction box
to circulate current
• Must be tested every
3 years

32. Agenda
UST Overview & Regulations
Monitoring & Testing
Closure & Removal
Summary/Q&A

33. Closure by Removal:
Preparation
• Submit closure request and plan to
regulatory agent
• Health and safety plan
• DIG SAFE
• Electrical
• Barricades and set up
• Permits (fire, trench, etc.)
• Shoring, trench boxes

34. Closure by
Removal: Cleaning
• Dry ice procedure
• Nitrogen purge
• Water rinsing
• Venturi purge
• Triple rinse
• Chemical cleaning
• Tank entry (CSE)
• Include piping

35. Closure by Removal:
Access
• Excavate around tank for
access
• Dismantle accessible piping
and ancillary equipment
• Use proper equipment
• Tag and label
• Plug opening, except 1/8” vent
• Inspect tank and piping

36. Soil Excavation
• Excavate soil around tank
 Typically 1-2’ around and
below
• Sample soil and consider a
fast turn around for
evaluation
 Dispose of soil according to
contamination or clean
procedures

37. Closure in Place
• Only recommended if removal is
not an option
 Can affect the structure of a building
• Backfill tank with inert material
 Concrete
 Approved poly-foam material
 Pea gravel (under 1,000 gal.)
 Sand
 Slurry

38. Agenda
UST Overview & Regulations
Monitoring & Testing
Closure & Removal
Summary/Q&A

39. Our Key Message
Understand the requirements that
come with having a UST on your
property

40. Summary
Find out if your tank is state/federally
regulated
Know your state’s UST testing
requirements
Understand that there is a process for
removing USTs
Know who needs to be involved and what
each individual’s role is

41. QUESTIONS?

42. Thank You For Attending!
Kevin Coulon:
kcoulon@triumvirate.com
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1-888-834-9697
www.triumvirate.com
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