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HomeMy WebLinkAboutDERR-2025-001246 Winter 2025 INSIDE: APST Certificate of Compliance Final Notice 1 Testing Requirements for Gasoline Storage Systems 2 Surface Spills-What to Do 3-4 Sump Testing Update 5 SIR Analysis 6-8 PFAFs 101 9 What’s Wrong with the Picture and Dates to Remember 10 Position Changes and Certification Corner 11 Published by the Utah Department of Environmental Quality Kim Shelley Executive Director Division of Environmental Response and Remediation Brent H. Everett Division Director Petroleum Storage Tank Branch Morgan Atkinson PST Branch Manager Mark Crim Utah Tank News Editor FINAL NOTICE: Aboveground Petroleum Storage Tank Compliance As of June 30, 2023, all regulated Aboveground Petroleum Storage Tank (APST) owners must have obtained a Certificate of Compliance (CoC). Facilities without a CoC or an approved compliance schedule are subject to enforcement actions, including delivery prohibition. Current Compliance Status: • 234 facilities submitted notifications. • Only 187 facilities have received a CoC. • Unknown facilities that have not notified? If you have not submitted an APST Notification or you are part of the 20% without a CoC, you will receive a 7-Day Red Tag Letter, giving you seven days to complete your CoC application, pay fees, or enter into a compliance schedule. Failure to act will result in a delivery prohibition tag being placed on your facility. Steps to Obtain Compliance: 1. Submit an APST Notification Form 2. Complete the CoC application, including testing, documentation, and financial assurance 3. Pay all applicable fees upon invoice Visit https://deq.utah.gov/environmental-response-and- remediation/aboveground-petroleum-storage-tanks-apst or contact your assigned area scientist for assistance. Let’s work together to maintain compliance and avoid penalties. Thank you for your cooperation! UTAH TANK NEWS 1 2 Reminder: Testing Requirements for Gasoline Transfer and Storage Tanks By Morgan Atkinson The Division of Environmental Response and Remediation (DERR) and the Division of Air Quality (DAQ) are working together to improve air quality in Utah by reducing fugitive emissions from gasoline storage tanks. As part of this effort, we want to remind all owners and operators of gasoline storage systems of important testing and compliance requirements under UAC Rule R307-328. Key Updates and Requirements: 1.Pressure Vacuum Relief Valve Testing: All gasoline storage tanks are required to have a pressure vacuum relief valve (PVV) installed on vent lines. These valves must be tested or replaced every three years in accordance with the California Air Resource Board (CARB) Test Procedure 201.1E. 2.Documentation of Compliance: DERR requests that you submit documentation of compliance with these requirements as soon as possible. This includes: o A CARB 201.1E test completed within the last three years, or o A receipt confirming the installation of a new PVV within the last three years. 3.Inspection Collaboration: DERR will collect data from the three-year tests as part of our existing Petroleum Storage Tank program. If necessary, we will report findings to DAQ for enforcement action. 4.Owner/Operator Responsibility: It is your responsibility as the owner or operator to ensure compliance. This includes proper installation, regular testing, and ongoing maintenance of PVVs. This collaboration between DERR and DAQ helps streamline inspections while ensuring that federal and state air quality standards are met. We encourage you to review your facility's compliance status and take any necessary steps to meet the updated requirements. If you have any questions or need assistance, please do not hesitate to contact us at: (801) 536-4100. We appreciate your cooperation in our shared effort to improve air quality in Utah. Thank you for your attention to this important matter. 3 Surface Spill Events at PST Sites and What to Do if a Spill Happens By Mark Crim and David Wilson Surface spill events at petroleum storage tank sites (PST) are common and often cleaned up within 24 hours, but most events are still reportable to the Division of Environmental Response and Remediation (DERR) in accordance with Utah Administrative Code R311-202. Reporting •Releases of any amount to waterways or surface water must be reported within 24 hours. •Spills over 25 gallons must be reported within 24 hours. •Spills less than 25 gallons that are not cleaned up must be reported within 24 hours. •Spills less than 25 gallons that are cleaned up within 24 hours do not have to be reported. Response •Owners/Operators must be prepared to respond to a spill event before it happens by having the required equipment and ensuring it is maintained. •Stop the release when it happens. •Contain the release, spill or overfill. •Call for help. What are the causes of the surface spills? The causes are varied and range from problems associated with fuel drops to customer spill events at the point of dispensing. Fuel drop overfill events can occur when PST overfill equipment, such as High -Level Alarms, Automatic Shut Off Devices or Ball Float Valves fail. Fuel drop spill events can also happen when delivery personnel release product while disconnecting the delivery hose. Although Spill Buckets are placed around the product fill pipe to capture spilled fuel, and range in size from 5 to 25 gallons, a spill event can easily overwhelm the Spill Bucket moving fuel from the bucket to surrounding surfaces. Spill events at the point of dispensing can occur when the Automatic Shut Off device on the pump handle fails. In this case a spill can be minimized by an attentive customer or be worse when the filling operation is unattended, a common event. Recap of equipment that exist on PST systems that prevent or minimize overfill or spill events PST overfill equipment such as, High-Level Alarms, Automatic Shut Off Devices or Ball Float Valves are required and to be maintained. UST Overfill equipment inspections are required ev ery three years by a certified UST Tester or Installer. ~Continued on Page 4 4 ~PST Spill Equipment Continued from Page 3 Spill Buckets, such as single-walled equipment, must be installed and maintained with integrity testing required every three years. Spill Buckets, such as double-walled equipment with a monitoring gauge, must be installed and maintained. Integrity testing is not required, as long as there is a record of monthly inspections. Concerning the dispenser pump handle, automatic shut off devices are required at each pump handle and need to be maintained. There is no testing required, but owner/operators are required to ensure such equipment meets the industry standard for performance. In all cases of PST equipment that prevents overfills or spills, contact your petroleum equipment specialist for repairs to equipment that is failing. What to do when a spill or overflow event occurs •For continuous product spilling, find and use the Emergency Stop Button at the facility. •Notify the most competent person at the facility. •Apply product adsorptive material or booms to contain the surface spill. •Notify the local fire department and or health department, if applicable. •Notify an environmental spill response company for abatement and cleanup. •Notify the DERR. Once the spill has stopped and been contained, call your petroleum equipment maintenance provider to correct any equipment failures or deficiencies. For emergencies that threaten life or property, call 911 or your local emergency number. You can report a petroleum spill event 24-hours a day by calling the Environmental Incidents Phone Number at: (801) 536-4123. For additional information visit the DERR website at: https://tanks.utah.gov. 5 Sump Testing Update By Sean Warner Since October 2008, new underground storage tanks (USTs) have been required to have double-walled construction, including piping, to allow for interstitial monitoring. Part of this monitoring process involves testing the sumps at the tanks and under the dispensers for tightness. Initially, under-dispenser containment sumps (UDCs) were exempt from this testing requirement if they had crossover tubes to direct a release directly to the submersible turbine sump (STP), where an alarm would be triggered. While this approach was implemented to streamline the testing process, it became evident that crossover tubes were often not properly connected, damaged, or missing. Over time, it was discovered that sumps not tested every three years were more likely to develop issues, such as worn-out penetration boots. To address these concerns, a reevaluation of the policy was conducted in consultation with the UST Task Force. As a result, a decision was made to update the policy. DERR Certified UST Testers are now familiar with sump testing procedures and have developed effective methods for handling potentially contaminated test water. Effective July 2023, all sumps used for interstitial monitoring must be tested for tightness every three years. This ensures that all sumps can contain a spill. If applicable to you, please refer to the test due letters the DERR sent out and plan to have all your sumps tested if you conduct interstitial monitoring. 6 Statistical Inventory Control By Kevin Beery and Mark Crim Statistical Inventory Reconciliation Daily inventory and monthly statistical inventory reconciliation (SIR) are inventory control procedures for determining how much fuel is going through your fuel system, to determine if there is a leak. Taking daily inventory of product in tanks along with SIR, is a leak detection option used for single -walled tanks, single- walled piping, and double-walled tanks and piping without electronic monitoring, installed before September 1991, and can be used with annual SIR. SIR is a mathematical process that analyzes daily inventory data to more accurately assess whether or not a leak exists in a tank or piping. Commercial SIR vendors are typically used, and they use computer programs to evaluate inventory data to determine if you might have a leak. A n SIR company will provide you with a report showing whether the provided records PASS, FAIL or are INCONCLUSIVE. In Utah, by rule, if you fail three consecutive months of statistical inventory analysis, you will be considered to have a leak and a release will be opened by the Division of Environmental Response and Remediation (DERR). You must notify the DERR within 24 hours upon receipt of your report that shows three months of failures. In order to provide the best data for SIR evaluations tank owners or operators need to follow several principals of data collection, whether the tanks are gauged manually or if an Automatic Tank Gauging (ATG) system is used. The end result of tank monitoring is that the collected data is sent to an SIR vendor every thirty-days for monthly statistical inventory analysis. Let’s look at the principals of good tank monitoring. Collecting Daily Inventory Data Includes: •The amount of fuel in the tank •The amount of water in the tank •The amount of fuel sold or dispensed •The amount of fuel delivered Make separate inventory measurements for each product that you store. All of these measurements must be made at the same time, so that no dispensing or deliveries take place between the time when the volume dispensed and the volume in the tank are measured. Take measurements each day that fuel is added or removed from the storage system, i.e., you don’t conduct inventory measurements on days your business is not open. SIR Points to Remember: •Make sure your SIR vendor’s methodology is certified and approved for use in Utah. •Always check for discrepancies which may indicate a release. ~Continued on Page 7 7 ~SIR Points to Remember, Continued from Page 6 •Supply daily inventory data to your SIR vendor at least every 30 days. The vendor will provide you with your leak detection results after the statistical analysis is completed. •If you receive an “Inconclusive” result, you must work with your SIR vendor to correct the problem and document the results of the investigation: o An inconclusive result means that you have not performed leak detection for that month. o If you cannot resolve the problem, treat the inconclusive result as a suspected release. •If you use an ATG system to gather data for the SIR vendor, have the ATG peri odically serviced according to the manufacturer’s specifications. •If you stick your tank to gather data for the SIR vendor, make sure your stick can measure to 1/8 of an inch and can measure the level of product over the full range of the tank’s height. •Keep results of your SIR tests for at least 3 years. •If you use an ATG system, keep all records of calibration, maintenance and repair. •Keep records of investigations conducted as a result of any monthly monitoring conclusion of “inconclusive” or “fail” for at least 3 years. Measuring the Fuel in the Tank The traditional way of measuring the amount of fuel in a petroleum tank is with a gauge stick. It must be straight and marked in 1/8-inch increments with clearly legible numbers. To take a reading, lower the stick gently to the bottom of the tank and raise it quickly. Locate the line where the stick is wet and record the number of inches to the nearest 1/8 inch. Use a tank chart, available from the tank manufacturer, to convert the depth measurement to gallons. Be sure you have the correct tank calibration with 1/8-inch increments, corresponding to your tank. Record the number of gallons on the inventory reconciliation report. If you have an automatic tank gauge (ATG), you can get the tank gallon readings directly from the ATG display or printout. Check the operator’s manual to find out how to get this information from your ATG. Measuring for Water in the Tank The best way to measure for water is to use water-finding paste that is applied to the bottom of a gauge stick. Almost all gasoline in Utah today contains ethanol, so be sure to use a water paste that is formulated for use with ethanol-blended gasoline. Follow the paste manufacturer’s directions for using the water paste, paying particular attention to the amount of time the stick needs to stay in the tank and what color change indicates the presence of water. Record the number of gallons of water on the inventory reconciliation record. Remember, ATGs have water sensing capabilities but they should not be relied on to detect water in tanks containing gasoline blends with ethanol. ~Continued on Page 8 8 ~SIR Continued from Page 7 Measuring Dispensed Fuel The amount of fuel dispensed can be read from the totalizer meters located on your dispensers. Totalizers look and work just like your automobile odometer. They track the total amount of fuel passing through the meter, or through-put. Subtract the previous totalizer reading from the current reading to get the number of gallons dispensed. You may also get your through-put volume from a point-of-sale system (computerized cash register) report that shows how much of each grade of fuel you sold. Whether you obtain the through-put amount from totalizer meters or reports from your point-of-sale system, it is important that the meters that measure the fuel are properly calibrated. Calibrating meters annually is recommended to maintain the accuracy of inventory records. Recording the Amount of Fuel Delivered The amount of fuel delivered is documented on a bill of lading or other delivery receipt from the fuel delivery driver, typically showing both a “net” and a “gross” volume. Use the gross volume as the number of gallons delivered for inventory record-keeping purposes, as the net volume is corrected for temperature and should not be used. What if you have a blended mid-grade fuel Normally, you would keep separate inventory records for each grade of fuel that you dispense. The exception to this is if you blend a mid-grade gasoline from your high- and low-grade products. If you have a blended mid- grade product, you may add together the sales, tank inventory, and delivery volumes for the high- and low- grade products and treat them as a single product for inventory purposes. What to Do at the End of the Month At the end of the month, supply your SIR vendor with your collected data so that the vendor can statistically evaluate your inventory. Upon receipt of your SIR report, determine if the system components PASS, FAIL or are INCONCLUSIVE. Remember, if you fail three consecutive months of SIR, you are considered to have a leak and a release will be opened by the DERR. You must notify the DERR within 24 hours of your receipt of the report showing three- months of statistical failures. For additional information visit the DERR website at: https://tanks.utah.gov. 9 PFAS 101 and What to Watch Out For By Chris Howell PFAS, or (perfluoroalkyl and polyfluoroalkyl substances), have been widely used since the 1940s and have recently been identified as one of the biggest global environmental pollution issues ever. PFAS have been linked to cancer, immune system disorders, reproductive disorders, childhood development issues, hormone imbalance, high cholesterol, liver damage, thyroid disease, and increased risks to asthma. The term PFAS is a catchall for an expansive group of man-made chemicals with similar chemical makeup. PFAS are used to make everyday items better, and thousands of different compounds are known to exist. They are in products that make non-stick cooking pans, fabrics that repel stains, waxes that repel water, firefighting foams, and many other uses we are still learning about. In short, PFAS were excellent at doing what they were designed to do and have made it into our daily lives. The problem is that PFAS can't naturally break down into less hazardous compounds, and why they are known as “forever chemicals”. Scientists continue to learn new information about how PFAS interact with the environment and their long-term toxicological effects. Some PFAS can build up in the environment or our bodies, leading to negative health effects, and drinking water sources are known to be impacted. As such, scientists are researching methods to safely and effectively treat groundwater contaminated with PFAS. In recent years, global manufacturers and governments have made a concerted effort to remove some, but not all, PFAS from commercial and consumer products. Still, everyone is behind the 8-ball because the problem is already out there. The Environmental Protection Agency is in the process of making new federal regulations to combat this issue, but it will take years to develop a full understanding of this new public health issue. How might this affect you? If you are considering purchasing a property, part of your due diligence is to assess if there are previous environmental impacts from past uses on or near the property. By evaluating the risks first, you can avoid purchasing a property with significant liability tied to historical impacts that may not be obvious. Operations on or near a property with potential PFAS impacts include, but are not limited to, car washes, dry cleaners, landfills, wastewater facilities, bio-solids used in agriculture, ski wax, fire control systems that may have expelled fire-retardant foam, and more. We recommend working with a qualified environmental professional to perform an environmental site assessment before purchasing a property to avoid becoming potentially liable for historic PFAFS impacts to that property. _________________________________________________________ Important Dates to Remember •June 30, 2023-APSTs needed to have Financial Responsibility and obtain a Certificate of Compliance-Now PAST DUE •July 1st- Annual Tank Registration fees and EAP Fund fees are due •July 15th- penalty billing is sent out •September 1st- Any facility that has not paid the annual fees will lose Petroleum Storage Tank (PST) Fund coverage and the Certificate of Compliance will lapse •December 15th- Secondary Containment Tests to qualify for a rebate must be received and Certificates of Compliance are mailed out •March 15th- Throughput forms are mailed out •April 30th- Throughput forms are due •May 15th- Annual Tank Registration fees and EAP Fund fees invoices are mailed out. What’s Wrong with this Picture? By Mark Crim This picture of a breakaway valve found underneath a dispenser, shows loose nuts on U-bolts meant to secure the breakaway valve. In order to function properly, ensure the breakaway valve is properly secured. This is a safety issue. 10 11 DERR Updates Position Changes Tonya Taylor, CERCLA, Support Staff Member, Becomes PST Support Staff Member, June 2024 Crystal Burnett, CERCLA-Site Assessment Section, New Hire, June 2024 Kim Viehweg, PST Compliance Section, Scientist, Retired, December 2024 Nicole Chavez, EAP Section, Scientist, Left the DERR, January 2025 Certification Corner EXAMS for A/B Operators, Groundwater and Soil Samplers, UST Removers, UST Installers, UST Technicians, UST Testers and PST Consultants Regarding the DERR’s A/B Operator Certification program, we are now offering an online option to take the final exam. We are happy to announce that we have 3 approved A/B Operator Courses that include a final exam. Those courses are provided by UST Training, Inc., Pass Training & Compliance, and Tait Environmental. The exam provided is one that can be taken in place of the in-person exam offered by the State. This is not an endorsement of these courses, rather it is an added option we are offering to give applicants more flexibility with testing. Please note that the rest of the certification requirements must still be met, and be submitted via email or mail to Chelsea Qualls in order to be certified through the State. Taking a course with an exam is not enough to be certified. The requirements for State certification are below: Requirements for Initial A/B Operator 1.Application 2.A/B Owner Operator Training Certification within 30 days of beginning work, options listed here https://deq.utah.gov/environmental-response-and-remediation/owner-operator-testing- approved-training-courses-ust 3.Notarized Citizenship Form (page 3 of application) 4.Copy of Driver's License 5.$100 Registration Fee payable online here: https://secured.utah.gov/derr/Forms/Page/derr- market/derr-market/?groupName=PST%20Certifications *Renewal fee is $50. Please wait until your application is ready to email to the DERR before making your payment, since the DERR accounting group cannot process payments without the corresponding applications. Certified PST Consultant Recertification Changes Regarding the Certified PST Consultant course: the DERR is now transitioning back to having in-person courses again. The course is held twice a year and was last held December 9, 2024. The next date is To Be Announced. If you need additional help, please contact Chelsea Qualls at cqualls@utah.gov or 801-536-4100.