Slide1: DIVISION OF OIL AND PUBLIC SAFETY http://ops.cdle.state.co.us


PETROLEUM STORAGE TANK RULES: PETROLEUM STORAGE TANK RULES October 11, 2006 “Environmental Regulations for Airports”


Operational compliance-USTs: Operational compliance-USTs Operation and maintenance of corrosion protection All systems tested within six months of installation All systems tested every three years Impressed current systems inspected every 60 days All tests and inspections must meet NACE standards


Operational Compliance-USTs (cont.): Operational Compliance-USTs (cont.) – All systems tested within six months of installation All systems tested every three years Impressed current systems inspected every 60 days All tests and inspections must meet NACE standards


Operational Compliance-USTs (cont.): Operational Compliance-USTs (cont.) Release detection Inventory control, monthly reconciliation, tank and line testing where applicable Daily inventories (tank stickings), sales, deliveries, book balance Calculations and daily comparisons Monthly calculations and comparisons with 1% + 130 gallons of sales Appropriate tank chart


Operational Compliance-USTs (cont.): Operational Compliance-USTs (cont.) Tank tightness testing (.1 gallon/hour leak, 95% probability 5 year application Annual line and leak detector operations test, except for suction lines


Operational Compliance-USTs (cont.): Operational Compliance-USTs (cont.) Automatic Tank Gauge (ATG) An ATG system consists of a probe installed inside each UST. The probes are wired to an electronic console that is mounted on the wall inside the facility. The automated process monitors and analyzes product level and temperature in the tank to determine if there has been a suspected release. The console interprets and stores information transmitted by the probes. Most consoles have the capability to print out a tape with the results of the tests.


Operational Compliance-USTs (cont.): Operational Compliance-USTs (cont.) Inventory control/monthly reconciliation Detects a .2 gallon/hour leak rate (95% probability of detection and 5% probability of false alarm Minimum requirement of one valid test every thirty days Various models with various capabilities including line testing ATG maintenance and investigation requirements per manufacturers recommendations “Pass”, “Fail”, “Inconclusive” Manual tank gauging


Operational Compliance-USTs (cont.): Operational Compliance-USTs (cont.) Vapor monitoring Groundwater monitoring Interstitial monitoring Statistical Inventory Reconciliation (SIR) The tank owner/operator provides to the SIR vendor daily inventory, delivery and dispensing data. The vendor’s computer software statistically analyzes the data provided to determine whether a tank system is leaking. The vendor provides to the tank owner a monthly report of that analysis.


Operational Compliance-USTs (cont.): Operational Compliance-USTs (cont.) Daily inventories (tank stickings), sales, deliveries, book balance Appropriate tank chart Detects .2 gallon/hour leak rate (95% probability of detection and 5% probability of false alarm) No two SIR methods exactly alike “Pass”, “Fail”, “Inconclusive” Provide all information to your SIR vendor as soon as possible after the end of each reporting period to ensure you will receive your SIR report no later than the 20th calendar day following the end of your reporting period.


Inspection requirements for internally lined USTs: Inspection requirements for internally lined USTs  Guidance document on website (March 2005)  Outlines requirements for continued operation of USTs that met the corrosion protection requirement either by interior tank lining, or interior tank lining combined with catholic protection.  As part of a settlement, OPS will allow O/O that missed the 10 year internal lining inspection, until December 31, 2005 to add catholic protection if installed in accordance with OPS’s Alternative Assessment Procedure (tightness test, ASTM G158, soil analysis and corrosion modeling)  After December 31, 2005, owners that have missed the 10 year internal lining inspection will have no option but to close the lined tank.  Includes requirements for O/O who want to change their corrosion protection method from internal lining to cathodic protection  Includes forms to document Interior Lining Inspection, Tank Integrity Certification, CP Monitoring (3-year and 60-day).


Installation and Registration - ASTs: Installation and Registration - ASTs Permit application required for new and upgraded systems Site plan – location of facility buildings and equipment, etc. Written application – corrosion system overfilling, spill prevention, leak detection, pumping systems, size and types of tanks and lines, regulated substance, secondary containment, SPCC Registration and annual fees


Performance Standards - ASTs: Performance Standards - ASTs Material compatibility Nationally recognized construction standard, UL 142, API 650 or equivalent standard External corrosion protection: cathodic protection, approved corrosion resistant materials Security – fencing around tanks or property perimeter


Spill and Overfill Control - ASTs: Spill and Overfill Control - ASTs Ullage comparison Spill and overfill prevention equipment Secondary containment tanks and ASTs at retail must have automatic stop at 95% or audible alarm at 90% Diking – non-permeable earth, steel, concrete, or solid masonry designed to be liquid type and to withstand a full hydrostatic head for enough time until any release therein can be cleaned up Dike floors must be impervious enough to contain the product for enough time until any release therein can be cleaned up Remote impounding


Secondary Containment Tank - ASTs: Secondary Containment Tank - ASTs Special drainage and diking not required if following requirements are met: Capacity shall not exceed 12,000 gallons Piping connections above maximum liquid level Outer tank must contain release from inner tank Collision protection Spill protection – check valve/shut off valve/quick connect coupling at delivery connection Delivery hose tight fill device Retail ASTs – 95% cutoff or 90% alarm


Retail Service Stations - ASTs: Retail Service Stations - ASTs Maximum capacity 12,000 gallon individual tanks and 48,000 gallons aggregate Tanks located 50 feet from nearest important building 50 feet from any fuel dispenser except secondary containment tank or tanks in a vault 50 feet from public way 100 feet from property line Distances reduced by 50% if tanks are fire resistant or in a vault


Airports: Retail/Bulk Plants/Cardlocks - ASTs: Airports: Retail/Bulk Plants/Cardlocks - ASTs If fuels are delivered through a loading rack to refuelers the facility is considered a bulk plant If fuels are delivered through a loading rack to refuelers and through dispensers to motor vehicles or aricraft the facility is considered a bulk plant with cardlock If fules are delivered through dispensers only the facility is considered a retail facility


Variance for location and installation of ASTs at Bulk Plants with retail/fleet motor fuel dispensing facilities: Variance for location and installation of ASTs at Bulk Plants with retail/fleet motor fuel dispensing facilities The retail/fleet motor fuel dispensing facility located at the bulk plant is separated from areas in which bulk plant operations are conducted by a fence and an approved structure (building or retaining wall), preventing direct access from one area to the other. Access to the bulk plant is restricted, and separate from the entrance to the retail/fleet motor fuel dispensing facility.


Variance for location and installation of ASTs at Bulk Plants with retail/fleet motor fuel dispensing facilities (cont.): Variance for location and installation of ASTs at Bulk Plants with retail/fleet motor fuel dispensing facilities (cont.) Tanks storing Class I liquids at an individual site shall be limited to a maximum individual capacity of 12,000 gallons, and an aggregate capacity of 48,000 gallons Tanks storing Class II or III liquids at an individual site shall be limited to a maximum individual capacity of 20,000 gallons, and an aggregate capacity of 80,000 gallons.


Variance for location and installation of ASTs at Bulk Plants with retail/fleet motor fuel dispensing facilities (cont.): Variance for location and installation of ASTs at Bulk Plants with retail/fleet motor fuel dispensing facilities (cont.) The aggregate capacity of all ASTs at Bulk Plants with retail/fleet motor fuel dispensing facilities shall not exceed 80,000 gallons. The above size restrictions do not apply if sales are delivered via refueler only


Operational Compliance-ASTs: Operational Compliance-ASTs Operation and maintenance of corrosion protection Metal thickness, suitable protective coatings, linings Periodic inspections of impressed current systems according to manufacturers specifications Release detection Monthly visual inspections, tank seams, connections, fittings ASTs without corrosion protection in contact with soil or electrolyte starting 10-1-99 and every two years thereafter


Operational Compliance-ASTs (cont.): Operational Compliance-ASTs (cont.) External visual inspection including bottom of tank Approved leakage test (e.g., tracer test) Internal inspection Approved alternative test for corrosion or leakage AST piping not in contact with the soil-monthly visual inspection AST piping in contact with soil-precision tested annually Secondary containment tanks Outer wall visually inspected monthly Interstitial liquid detector, operation verified monthly


Operational Compliance-ASTs in Vaults: Operational Compliance-ASTs in Vaults Liquid tight & sufficient space for inspection Suitably anchored Resistant to damage from motor vehicles Each tank in it’s own vault, common wall okay Connections to permit venting Class 1 liquids – continuous ventilation


Operational Compliance-ASTs in Vaults (cont.): Operational Compliance-ASTs in Vaults (cont.) Detection system for liquids and alarm Means to recover liquid from vault Emergency vents vapor tight, discharge inside vault Personal entry, warning sign, security Means to emit fire suppression agent


Release Reporting-USTs & ASTs: Release Reporting-USTs & ASTs All suspected or confirmed releases must be reported within 24 hours to the Division of Oil and Public Safety. Business hours 8-5, M-F. 303-318-8547 After hours, 1-877-518-5608 Suspected or known releases can include the following: Visible contamination, free product or vapor in soils, basements, utility lines and other receptors, etc.


Release Reporting-USTs & ASTs (cont.): Release Reporting-USTs & ASTs (cont.) Unusual operating conditions such as: failed tank test, inconclusive SIRs, unexplained presence of water in tank, sudden loss of product, etc. Failed monthly monitoring leak detection results unless device is found to be defective and repaired within 24 hours Release investigation Suspected releases to be investigated within 7 days


Release Reporting-USTs & ASTs (cont.): Release Reporting-USTs & ASTs (cont.) System test, tanks, lines, sumps, connections, fittings, etc. If leak exists, repair, replace or upgrade system and begin assessment and corrective action If tests indicate a leak does not exist, further investigation not required


Release Reporting-USTs & ASTs (cont.): Release Reporting-USTs & ASTs (cont.) Site check If site investigation activities are being conducted due to failure of a tank tightness test, the owner/operator must collect a minimum of four samples, which bracket the tank on all sides and are collected from below the elevation of the base of the tank


Release Reporting-USTs & ASTs: Release Reporting-USTs & ASTs If site investigation activities are being conducted due to failure of a line tightness test, the owner/operator must collect samples from beneath the associated dispenser island and from beneath any areas of piping which are suspected to have released petroleum product into the environment (e.g., joints, areas of damage or corrosion, etc.)


Tank Closure-USTs: Tank Closure-USTs Temporary closure – time between when tank is taken out of service and permanent closure Corrosion protection and release detection must be maintained if applicable If temporarily closed for three months or more, leave vent lines open, cap and secure other lines, pumps, man ways and ancillary equipment


Tank Closure-USTs (cont.): Tank Closure-USTs (cont.) After 12 months of temporary closure, tanks must be permanently closed, if applicable Permanent closure – tanks removed from the ground or filled with an inert-solid material (closed in place) 10 days notice to the Division of Oil and Public Safety For tanks removed from ground, owners must empty and clean, remove all liquids and accumulated sludges Environmental site assessment


Tank Closure-ASTs: Tank Closure-ASTs Out of service No notification or leak detection requirements for 90 days if product is removed from the tank Out of service may continue for a total of 9 calendar months Visual inspection of entire AST system required if AST returns to service after 90 days Temporary closure Tanks to be emptied of liquid, rendered vapor free and safeguarded against trespassing


Tank Closure-ASTs (cont.): Tank Closure-ASTs (cont.) May continue temporary closure for up to 24 months If returned to service, tests of piping and physical inspection to ensure that the tank and all secondary containment structures are clean, liquid tight and structurally sound After 24 months, tanks must be permanently closed Permanent closure Empty and clean tank


Tank Closure-ASTs (cont.): Tank Closure-ASTs (cont.) Clean and plug piping Remove all dispensers Render loading facilities inoperative Safeguard AST from trespassing or remove tanks 10 day notification to the Division of Oil and Public Safety Site assessment