HomeMy WebLinkAboutDERR-2024-009132UTAH
PETROLEUM STORAGE TANK
(PST)
OWNER/OPERATOR
GUIDANCE DOCUMENT
Developed by the Department of
Environmental Quality-Petroleum Storage
Tank Section
195 North 1950 West
Salt Lake City, Utah 84114
801-536-4100
tanks.utah.gov
February 2024
•Regulations 3
•PST Operator ABC 4
•PST System Components 10
•Release Prevention 20
•Leak Detection 30
•Emergency Shutoff 40
•PST Operator Inspection 41
•State Compliance Inspection 46
•Notification 47
•UST Testing Requirements 48
•Financial Responsibility 54
•PST Installations 55
•Red Tag and One Time Drop 56
•Certificate of Compliance 57
•PST Closures 58
•Release Response 61
•Fee Schedule 64
•Aboveground Petroleum Storage Tank (APST) Requirements 65
o Regulations
o Notification
o Certificate of compliance
•Application
•PPI
•Fees
•Testing
o Installations
o Closures
o Reuse Requirements
o Annual, Three Year, & Future Requirements
o SPCC Plans
2
Table of Contents
Regulations
•Energy Policy Act of 2005 initiated UST Operator Training
Requirements
•40CFR 280 Code of Federal Regulations cover the
installation, operation and closure of USTs
•PST ACT, Utah Code Annotated (UCA), Section 19-6-407 and
R311 authorizes the Division of Environmental Response and
Remediation (DERR) to administer the Utah PST program
•Due to legislation passed in the 2021 session, DERR began
regulating specific types of Aboveground Petroleum Storage
Tanks (APSTs) on May 5, 2021. By statute (19-6-407).
3
INTRODUCTION
ABC PST Operator
Class A Operator –an owner, operator, employee, or individual
designated under Subsection R311-201 that has primary
responsibility for the broader aspects of the statutory and
regulatory requirements and standards necessary to operate and
maintain the PST system
Class B Operator –an owner, operator, employee, or individual
who will implement routine daily aspects of operation,
maintenance, and recordkeeping for PST systems
Class C Operator –an employee who is generally the first line
of response to events indicating emergency conditions
•ABC Operators requirements do not apply to aboveground
storage tank (APST) owners at this time.
4
PST OPERATOR
Class A Operator Responsibilities
•Have a general knowledge of PST systems
•Ensure that PST records are properly maintained
•Ensure proper response to and reporting of emergencies caused
by releases or spills from PSTs
•Ensure that class B and class C operators are trained and
registered
•Ensure that annual PST fees are paid
•Maintain PST system records
5
PST OPERATOR
Class B Operator Responsibilities
•Ensure that on-site PST operator inspections are conducted according to
the requirements of Subsection R311-201-12
•Ensure that PST release detection is performed
•Ensure that the status of the PST system is monitored for alarms and
unusual operating conditions
•Perform required Utah monthly inspections
•Ensure that proper release detection and other records are kept and made
available for inspection
•Ensure that spill prevention, overfill prevention, and corrosion
protection requirements are met
•Be present for any compliance inspections, or designate another
qualified individual
•Ensure that suspected releases are properly documented
•Ensure that class C operators are trained and documented and present
during PST operation hours
6
PST OPERATOR
Utah Third Party Class B Operators
•Shall be trained and registered in accordance with Subsection R311-
201-12 and shall be certified in accordance with R311-201-12 as:
•An PST Tester, or
•An PST Installer as either a general installer or service/repair
technician, or
•Meet the training requirements of a certified PST inspector and
document comprehensive or general liability insurance with
limits of $250,000 minimum per occurrence
Class C Operator Responsibilities:
•Be present at the site at all times during normal operating hours
•Monitor product transfer operations to ensure that spills and
overfills do not occur
•Properly respond to alarms, spills, and overfills
•Notify class A and/or B operators and appropriate emergency
responders when necessary
•Act in response to emergencies and other situations caused by
spills or releases from an PST system that pose an immediate
danger or threat to the public or to the environment, and that
require immediate action
7
PST OPERATOR
PST Operator Training and Registration
Requirements
Training
•Class A, B and C operators must be trained
•Class A and B operators must successfully complete an approved training
course within 30 days of assuming work duties
•Class B operators may train a C operator
Registration
•A and B operators must
•Complete an approved training course
•Pass State administered examination
•Submit an application
•Pay applicable fees
•C operators
•No registration or fees are required for the class C operators
8
PST OPERATOR
Renewal and Reciprocity
Renewal of Registration
•Class A and B operators must apply for renewal of registration every three years
•Pay applicable fees
•No class or test is required
•If an applicant’s registration has lapsed for more than two years, the applicant must go
through the registration process as if it were their initial registration
Reciprocity
•If the DERR determines that another state’s operator training program is equivalent to Utah’s
program, it may be accepted in lieu of the Utah program with the following provision:
•Must take the state approved examination
•Must submit a registration application and pays fees
Violations requiring Re-training
•Class A operator may require re-training within 90 days if the facility is found to be
out of compliance due to:
•Lapsing of the Certificate of Compliance
•Failure to provide acceptable financial responsibility
•Failure to ensure that the class B or C operators are trained and registered
•Class B operator may require re-training within 90 days if the facility is found to be
out of compliance due to:
•Failure to maintain spill and overfill prevention
•Failure to maintain corrosion prevention
•Failure to maintain leak prevention
•Failure to perform PST operator monthly inspections
•Failure to ensure that the class C operators are trained, registered and on site
during facility operation hours
9
PST OPERATOR
Re-training Requirements
•Re-training must occur within 90 days of violation
•Class A and B operators must successfully complete an approved training course,
pass an examination, submit an application and pay fees
•If the documentation of training is not received, the facility’s Certificate of
Compliance may be revoked (R311-201)
UST System
10
PST SYSTEM COMPONENTS
ATG
Vent
Drop TubeSpill Bucket
Emergency Shutoff
STP
Sump
Product
Piping
Liquid
Sensor
UDC
Dispenser
Tank Interstice
Construction of Tanks
•Fiberglass Reinforced Plastic (FRP)
•Composite –clad or jacket
•Steel –cathodically protected and/or lined
•Single or double walled
All underground storage tanks installed after October 2008 must be double walled and
perform interstitial monitoring. This includes Emergency Generator Tanks.
11
PST SYSTEM COMPONENTS -TANKS
Double-Walled (DW) USTs
•Interstice can be equipped with an interstitial sensor for release detection
•DW Tanks usually have an interstitial riser which is accessible from the tank top
•A DW tank interstice can be either dry, or contain a brine solution
Tank Interstitial Riser
Sensor
Brine Reservoir
Under Dispenser Containment (UDC)
•Under dispenser containment sumps prevent fuel from reaching the
soil
•Shear Valves –prevent hazards caused by collision or fires at the
dispenser when properly anchored
•Liquid Sensors –Detect liquid in the containment sumps
•Dispensers installed after October 2008 must have under-dispenser
containment. The UDC must be liquid-tight on its sides, bottom, and
at any penetrations. UDCs must allow for visual inspection and
access to the components in the containment system or be
periodically monitored for leaks from the dispenser system
Update
•All single-walled UDCs that are used as part of an interstitial
monitoring system must be tested every three years.
12
PST SYSTEM COMPONENTS -UDCs
UDC
Shear Valve
Tank Top Containment Sumps
•Prevent product released from the piping, Submersible Turbine Pump
(STP) or other components from reaching the soil or groundwater
•Must be liquid-tight on its sides, bottom and at all penetrations
•All tank top containment sumps and any other single-walled sumps
used for interstitial monitoring of piping must be tested every three
years.
13
PST SYSTEM COMPONENTS -SUMPS
Requirements for Containment Sumps After 2008
•Be present where piping connects to a dispenser
•Be present at the submersible pump or where piping connects to the
tank
•Be present where single-walled piping connects to double-walled
piping
•Be monitored for monthly releases
Automatic Tank Gauge (ATG)
•An ATG system consists of a probe permanently installed in a
tank and wired to a monitor to provide information on product
level and temperature
•An ATG monitoring system can provide operators with alarm
and sensor status, inventory, and some can perform leak
detection testing
•Common ATG systems are Veeder-Root and Incon
•ATGs must be functionality tested every year
14
PST SYSTEM COMPONENTS -ATG
Automatic Tank Gauge Systems:
(ATG may provide one or more of the following)
•Monitor the tank inventory electronically via an in-tank probe
•Provide in-tank release detection using the in-tank probe
•Provide interstitial monitoring on the tank using a sensor
•Monitor the interstitial piping using a containment sump sensor
•Monitor piping release detection via an electronic line leak detector
•Monitor Under Dispenser Containment (UDC) and containment sump
sensors
15
PST SYSTEM COMPONENTS -ATG
ATG In -tank Probe Sump Sensor
Vapor Recovery
•Stage I Vapor Recovery collects vapors at the tank top and is required at most gasoline dispensing facilities
•R307-328 requires any gasoline tank that dispenses 10,000-gallons or more in any one calendar month is required to have stage I vapor recovery.
•Facilities that fail to have vapor recovery on tanks that fall under the requirement may be subject to enforcement actions and/or fines by the Division of Air Quality.
•Stage II Vapor Recovery collects vapors at the dispenser/vehicle, and is not required in Utah
16
PST SYSTEM COMPONENTS –Vapor
Recovery
Two Point Vapor Recovery
•Two Point Vapor Recovery consists of two attachment points
(one for liquid delivery and one for vapor return to the truck)
17
PST SYSTEM COMPONENTS –Vapor
Recovery
Single Point Vapor Recovery
•Coaxial, or Single-Point Vapor Recovery System –the filling
and vapor consist of a single attachment point
18
PST SYSTEM COMPONENTS –Vapor
Recovery
•Pressure relief valves/pressure vent caps are required as part of
the Vapor Recovery System
19
PST SYSTEM COMPONENTS –Vapor
Recovery
Update
•Any gasoline tank with a capacity of 250 gallons or more must have
a pressure relief valve/pressure vent cap
•These pressurized vent caps must be tested by a certified tester
every three years. R307-328.
Spill, Overfill, and Corrosion Protection
•Spill Prevention -is containment around the fill pipe that
catches small spills that occur during delivery
•Overfill Prevention –devices either shut off product flow,
restrict product flow or alert the delivery operator with an
alarm when the tank is close to being full
•Corrosion Prevention –a system designed to protect a steel
tank and piping from corrosion
20
RELEASE PREVENTION
Secondary Containment
Provides a convenient means of recovering released product,
makes it easier to detect and contain a discharge from the tanks or
piping, and provides a space that can be monitored for the
presence of releases.
•Spill buckets
•Tank top sumps
•Under dispenser containment
Spill Buckets
•Liquid tight containment that surrounds the fill pipe
•Spill Buckets typically range in size from 5 to 25 gallons
•There is no minimum capacity requirement for spill buckets
•PSTs that receive 25 gallons or less per delivery do not require a spill
bucket
•Must be clean and dry, free of debris, no holes or cracks or
deformation
•You must test or monitor your spill prevention equipment
•Single-walled Spill Buckets must be tested at least every three
years for liquid tightness. The test must be conducted according
to a code of practice or manufacturer’s instructions
•Double-walled Spill Buckets may not require testing if they
conduct periodic interstitial monitoring.
•You must inspect your spill prevention equipment at least every 30
days as part of your walk through inspection (or before each delivery
if you receive deliveries less frequently than every 30 days)
21
RELEASE PREVENTION –Spill Prevention
Double Walled Spill Buckets
•DW spill buckets should have a monitoring gauge.
•The spill bucket will not have to be tested every three years if
•The gauge is checked and recorded once a month during the Monthly
inspection
•The gauge is indicating zero
•The bucket is not cracked or deformed
22
RELEASE PREVENTION –Spill Prevention
Overfill Protection
•Is designed to stop product flow, reduce product flow or alert the
delivery person that the tank is almost full
•Overfill prevention equipment must automatically shut off when the
tank is no more than 95% full
•Overfill devices are not required with transfers of fuel 25 gallons or
less
•Your overfill prevention equipment must be tested at least once every
three years to ensure it will function properly to prevent overfills
•The inspection must be conducted according to a code of practice or
manufacturer’s instructions
Three types of overfill protection
•High level alarm
•Automatic shut off
•Ball float valve
23
RELEASE PREVENTION -Overfill
Overfill Alarm
•Alert the delivery driver to an overfill with an alarm when the
tank reaches 90% of fuel capacity
•Must be located where the driver can see and hear it easily
•Must be identified with a sign
24
RELEASE PREVENTION -Overfill
Automatic Shutoff
•Often called Flapper Valve or Butterfly Valve
•Shut off device installed in the tank’s fill pipe or drop tube
•Stops the flow of fuel into the PST when the fuel level reaches
95% capacity
25
RELEASE PREVENTION -Overfill
Corrosion Protection
•Cathodic protection on metallic components will help prevent the PST system
from corroding and leaking product into the environment.
•All portions of the PST system that routinely contain product must be:
•Constructed of a non-metallic material or
•Isolated from the ground or
•Be cathodically protected
26
RELEASE PREVENTION –Corrosion
Protection
Fiberglass Tanks Steel Tank
•There are two forms of corrosion protection:
•Galvanic
•Impressed current (Rectifier)
•There are two forms of corrosion protection:
•Galvanic
•Impressed current (Rectifier)
Galvanic
•Galvanic uses a coating along with an anode composed of magnesium or zinc attached to
the tank
27
RELEASE PREVENTION –Corrosion
Protection
Steel Tank with anode
Impressed Current
•Impressed Current uses a rectifier and anodes to protect metal tanks and piping
•The rectifier must remain on 24 hours a day
Rectifier
Flex Connectors
•Flex Connectors –are a flexible braided piping, usually found under
the dispenser or at the tank top sump
•Three ways to protect Flex Connectors
•Not in contact with the soil
•Booted
•Cathodically protected
28
RELEASE PREVENTION –Corrosion
Protection
Flex Connector at a dispenser
Corrosion Protection Testing Requirements
•Must be tested within 6 months of installation and every three years
by a Utah Certified CP tester
•Must maintain the last two surveys done by a certified cathodic
protection tester
•All repair records must be kept for the life of the UST system
•Impressed Current Systems (Rectifier) must be monitored every 60
days
•Document that the rectifier is on by initialing or signing the log
•The last 3 system checks must be maintained for compliance
inspections
29
RELEASE PREVENTION –Corrosion
Protection
General Requirements
•Tanks must be monitored for releases at least every 30 days using a proper release detection method
•Your release detection method must be able to detect a release from any portion of the tank and connected underground piping that routinely contains product
•Release detection must be installed, calibrated, operated, and maintained according to the manufacturer’s instructions
•All PST systems (including Emergency Generator Tanks) installed after Oct 2008 must have secondary containment and perform interstitial monitoring
Permanent Forms of Leak Detection are:
•Automatic Tank Gauging (ATG)
•Interstitial Monitoring (IM)
•Statistical Inventory Reconciliation (SIR)
•Groundwater and Vapor Monitoring (Contact the PST section if you have questions)
Non-Permanent Forms of Leak Detection are:
•Inventory Control with Tank Tightness Testing
•Manual Tank Gauging with Tank Tightness Testing
30
LEAK DETECTION –TANKS
Automatic Tank Gauging (ATG)
•Consists of a probe permanently installed in a tank and wired to a
monitor to provide information on product level and temperature
•ATG systems automatically calculate the changes in product volume
that can indicate a leak
•The tank must contain a minimum amount of product to perform a
valid test according to the manufacturer’s specifications
•Have an owner’s manual on site
•Keep the results of your ATG system monthly tests for 3 years
•ATGs must be functionality tested once a year
Example of an ATG monitor
31
LEAK DETECTION –TANKS
Automatic Tank Gauging (ATG)
Two types of ATG monitoring
•Continuous In-tank Leak Detection
•Continuous monitoring
•Allows for around the clock fueling
•Static/Shutdown Testing
•Requires the system to be shut down for a required amount of time for
testing
PASS –FAIL –INCONCLUSIVE
•Pass -Everything is OK
•Fail -If you get a failed monthly test (.2gph test) it must be justified
within 24 hours
•Run another test
•Contact your service provider for assistance
•If a failed test cannot be justified the DERR may require additional
follow-up and a tank tightness test
•Inconclusive/other than Pass or Fail
•Contact your service provider for assistance
32
LEAK DETECTION –TANKS
Interstitial Monitoring
•All new tank installations must have secondary containment on tanks
and piping and perform interstitial monitoring
•Secondary containment provides a barrier between the tank/piping
and the environment
•Monitors are used to check the area between the tank/piping and the
barrier for leaks and alert the operator if a leak is suspected
•Keep liquid status reports for each month
•Ensure that all sensors are located at the lowest point in all sumps
Sensor Reports
•“Normal” is good
•For Interstitial Monitoring you should be getting a “Liquid Status
Report”
•Anything other than “normal” means there is a problem
•In many cases the monitor will signal an alarm
•Contact your maintenance provider
•If the alarm can not be justified contact the DERR within 24
hours
33
LEAK DETECTION –TANKS
Testing Requirements for electronic and
mechanical leak detection components
•Mechanical LLD must be tested at installation and annually
•Electronic LLD must be tested at installation and annually
As of Oct 13, 2018 you must perform annual release detection equipment testing on mechanical and electronic components, including: automatic tank gauges and other controllers, monitors, probes and sensors.
•ATG and other controllers
•Test alarm
•Verify system configuration
•Test battery backup
•Probes and Sensors
•Inspect for residual build up
•Ensure floats move freely
•Ensure it is not damaged
•Ensure cables are free of kinks and breaks
•Test alarm and communication with controller
•Automatic Line Leak Detectors (electronic and mechanical) must be tested by simulating a leak
Tests must be performed according to the manufacturer’s instructions, or a code of practice developed by a nationally recognized association or independent testing laboratory.
34
LEAK DETECTION –TANKS
You must perform annual functionality tests on all line leak detectors (LLD)
Statistical Inventory Reconciliation (SIR)
•SIR uses sophisticated computer software to conduct a statistical
analysis of inventory, delivery and dispensing data
•You must supply the SIR provider with data each month
•Most SIR methods analyze both tanks and lines
•Two ways to collect data
•Manually stick the tank
•Using an ATG or other tank monitoring system
Pass –Fail -Inconclusive
•Pass –Is good
•Fail –If you get a failed monthly test you must contact the DERR
within 24 hours and do the following:
•Start an investigation
•Contact your service provider for assistance
•You have 7 days to justify the “fail”
•If the fail cannot be justified the DERR may require a tank
tightness test or additional investigation
•Inconclusive –Two consecutive inconclusive tests will be treated as a
Failed Test.
35
LEAK DETECTION –TANKS
Inventory Control and Tank Tightness
Testing
Inventory control involves taking measurements of tank contents and
recording the amount of product pumped each operating day, measuring
and recording tank deliveries, and reconciling all this data at least once
a month.
•This method includes tank tightness testing annually
•Can be used for tanks installed after 1998 and before 2008
Manual Tank Gauging
•Involves taking the tank out of service each week (up to 36 hours at a
time) during which the contents are measured twice at the beginning
and end of the test period
•The measurements are compared to a weekly and monthly standard to
determine if the tank is tight
36
LEAK DETECTION –TANKS
Two Methods of Fuel Dispensing
•Pressurized piping –uses a submersible turbine pump (STP)
•Suction
•Safe Suction Piping
•US Suction
37
LEAK DETECTION –Piping
STP -pressurized
pump under dispenser -
suction
Line Leak Detectors are designed to detect a catastrophic release from
pressurized piping
•Mechanical (restricts product flow)
•Electronic (shuts off product flow)
•Both Electronic and Mechanical Leak Detectors must be tested
for functionality/simulated leak test at installation and every year
by a certified PST tester
38
LEAK DETECTION –Line Leak Detectors
Electronic LLD Mechanical LLD
Piping Testing Requirements
•Pressurized (Pressurized piping must have a Leak Detector and one
of the following forms of leak detection)
•Annual line tightness test at .1 gph leak rate at 1.5 times the
operating pressure of the product line
Or
•Monthly monitoring (.2 gph, using Interstitial Monitoring or SIR)
•The ELLD has performed a .2 gph test, at least once a month for
12 months
•IM –liquid status report printed or manual log completed at least
once a month for 12 months
•SIR reports available for the past 12 months
•Suction –Two types
•US suction –has a check valve at the tank, requires a line test
every 3 years
•Safer Suction –release detection is not required for safe suction if
the system operates at less than atmospheric pressure, the piping
slopes back toward the tank and there is only one check valve in
the system located under the dispenser
Note:All line tightness tests and leak detector tests must be
performed by a Utah certified PST tester.
39
LEAK DETECTION –Piping
•R311 -203-8
•Facilities that are open to dispense fuel at times when no
employee is on site must have:
•A sign posed in a conspicuous place, giving the name and
telephone number of the owner, operator, or local
emergency responders
•Have an emergency shutoff device in a readily accessible
location, if the facility dispenses fuel
40
EMERGENCY SHUTOFF
Monthly Inspections
•By rule, each PST facility must have an on site operator inspection
every 30 days
•The inspection must be performed by or under the direction of the
designated class B operator
•The class B operator must sign all monthly inspection forms
•Must use the approved PST Operator Inspection –Utah form found
on the DERR website (undergroundtanks.utah.gov) or another form
approved by the DERR
41
PST OPERATOR INSPECTIONS
42
PST OPERATOR INSPECTIONS
Filling Out The Inspection Form
General Instructions
•Fill in the Year, Facility Name, Facility ID#, Address, print the name of the primary Class B operator.
•Questions 1-7 use Y(Yes), N(No), or NA(Not Applicable)
•Do not use an X or √in these boxes
•The individual conducting the inspection must initial each month in the box below line 7
Monthly Inspection (1-7)
Release Detection
#1 (on the form)
•Check release detection equipment on a regular basis
•Unusual operating conditions may include:
•An Alarm
•A Spill or Overfill
•Dispensers not working
•Sudden Loss of product
#2 (on the form) Release Detection records may include one or more of the following
•ATG results for each month for the last 12 months
•Liquid Status Report for each month for the last 12 months
•Containment Sensor Reports –monthly for the last 12 months
•SIR reports for each month for the last 12 months
•Line Tightness Tests -annual
•Line Leak Detector Tests -annual 43
PST OPERATOR INSPECTIONS
Filling Out The Inspection Form
Spill Prevention Equipment
#3-7 (on the form) Spill Buckets
•Inspect the equipment identified on that line
•Fill out boxes 3-7 for the appropriate month
•If problems are encountered make a note in the comment section at the bottom of the form and describe how the problem was resolved
Annual Inspection (8-10)
Containment Sumps
#8-10 (on the form) Tank Top, Dispensers and Transition Sumps
•Indicate the date of the annual inspection in the box above line 8
•Inspect the equipment identified on the line
•Enter the appropriate response (Y, N, NA) in the box at the right
•If problems are encountered make a note in the comment section at the bottom of the form and describe how the problem was resolved
*Best business practices would include more frequent inspections of
the equipment listed on lines 8-10
44
PST OPERATOR INSPECTIONS
Filling Out The Inspection Form
Page Two of the Form –if applicable
•Fill out the first table if you use a monthly visual check rather than a sump sensor for interstitial monitoring
•The second table is for Impressed Current Systems only
45
PST OPERATOR INSPECTION
UST Operator Inspection - Utah – Page 2 of 2
If you perform Interstitial Monitoring on your tanks and/or piping and use a visual check rather than sump or
interstitial sensors for your monthly leak detection, complete the table to document the monthly visual checks.
Months of the Current Year J F M A M J J A S O N D
1 Visual check of the interstitial space of the double-walled tank indicated no
release or unusual operating conditions.
2 Visual check of piping (STP, dispenser and transition) containment sumps
indicates normal function and no indication of water or leaked product.
Impressed Current 60 Day Rectifier Check
Months of the Current Year J F M A M J J A S O N D
Show the date the Impressed Current
system was inspected to ensure the
equipment is running properly
Amperage reading from impressed
current rectifier
Voltage reading from impressed current
rectifier
INSTRUCTIONS
1. The monthly UST system inspections must be conducted by or under the direction of the Primary Class B UST Operator.
2. The Primary Class B UST Operator must alert the UST Owner or Operator of any condition discovered during the monthly visual
inspection that may require follow-up actions.
3. The UST Owner or Operator must maintain a copy of the monthly inspection reports for the most recent 12 months. The records
shall be maintained on-site or off-site at a readily available location.
Ver. 4/14/2016
What you need to have on site
•Class B operator or qualified representative
•Monthly Operator Inspection Form
•Documentation of Repairs
•List of Class C operator training
•Leak Detection Records (one or more may apply)
•ATG reports
•SIR reports
•Liquid Status Reports
•Manual Tank Gauging Records
•Line and Leak Detector Tests
•60 day Rectifier Check
•Cathodic Test Reports
Visual Checks with inspector
•Be prepared to open containment sumps, spill buckets and dispensers ( have necessary keys and tools available)
•Ensure all leak detection and cathodic protection equipment is accessible for inspection
•Safety note: it is always a good idea to have safety cones and a reflective vest
46
STATE PST COMPLIANCE INSPECTION
Notification
EPA Form 7530-1, Notification for Underground Storage Tanks, must
be completed, revised, and submitted to the DERR when:
•New PSTs are installed
•Ownership changes –within 30 days
•Changes made to the tank or piping system
•Release detection, corrosion protection, spill or overfill prevention systems are installed, changed or upgraded
•Change in fuel type, including alternative fuels
47
NOTIFICATION
48
UST TESTING REQUIREMENTS
49
UST TESTING REQIREMENTS
50
UST TESTING REQIREMENTS
51
UST TESTING REQIREMENTS
52
NEW UST TESTING REQIREMENTS
53
ALL PST TESTING REQUIREMENTS
Financial Responsibility
•State and Federal PST regulations require that owners and operators of PSTs demonstrate financial responsibility to show they can pay the costs of clean-up and third-party claims for leaks from PSTs
•Owners/Operators may show Financial Responsibility through one of the following
•Participation in the Petroleum Storage Tank Trust Fund (PST
Fund)
OR
•Demonstrate financial responsibility through one of the
following:
•Self Insurance
•Insurance coverage
•Letter of Credit
•Trust Fund
•Surety Bonds
•Corporate Guarantee
54
FINANCIAL RESPONSIBILITY AND
CERTIFICATE OF COMPLIANCE
New Installations
Owners/Operators are required to notify the DEQ ten days prior to
beginning the work. An installation permit and fee of $200 per tank is
required and must be obtained prior to the completion of the
installation. The local fire jurisdiction and health department must be
contacted for any requirements that they may have associated with the
installation.
UST Installation Permit
•Utah Certified PST Installer who is directing all critical operations associated with tank installation
•Installation company name, address and current PST Installation Company Permit number. (Process Installation Company Permit Protocol, Appendix C-3)
•Date the work will commence
•Tank owner name and address
•Facility name and address
•Complete description of what is to be installed: tank or piping, capacity, material of construction, substance to be stored, etc.
•Integrity testing of the containment sumps and spill buckets
55
PST INSTALLATIONS
Red Tag Program and One Time Drop
Red Tag
Delivery prohibition tags will be placed on new PSTs during the
installation process, to help ensure that no unauthorized deliveries (other
than the one time drop) are made to the PST before it qualifies for a
Certificate of Compliance. When the new PST does qualify for a
certificate, the DEQ will issue the certificate and a letter authorizing the
removal of the delivery prohibition tag.
One Time Drop Letter
Before the PST can be put into use, the integrity of the PST and
associated piping must be evaluated through a tank and line tightness
test. To receive fuel for the test, the owner or installer must contact the
DEQ for authorization of a one-time delivery. After the initial drop, the
PSTs may not receive subsequent deliveries of fuel until they are issued
a Certificate of Compliance and a letter authorizing the removal of the
delivery prohibition tags.
56
PST INSTALLATIONS
The Utah PST Act requires that Owners/Operators of regulated petroleum PSTs
qualify their tanks for and receive a Certificate of Compliance, and keep the PSTs
in substantial compliance with all UST rules and regulations.
It is a violation of the UST Act to operate these PSTs without a certificate. New
PSTs must have a certificate before being put into operation. Fines may be assessed
if product or other regulated substance is delivered to or placed into an PST that
does not have a Certificate of Compliance.
57
CERTIFICATE OF COMPLIANCE
There are two types of PST closures: temporary or permanent. All regulated PSTs that do not meet the federal upgrade requirements must be permanently closed. Regulated PSTs that meet federal upgrade requirements can be temporarily closed for periods when the tanks will not be in operation.
Temporary Closure
•Seasonal use PSTs which are only in operation during part of the year
•PSTs are not in operation, but the owner has not decided to permanently close them
Less than Three Months
•Operate and maintain cathodic protection (if any)
•Operate and maintain leak detection (if any) or empty the tank to less than one inch of product
Three Months or More
•Operate and maintain cathodic protection (if any)
•Operate and maintain leak detection (if any) or empty the tank to less than one inch of product
•Submit a Temporary Closure Notice
•Leave vent lines open but cap and secure all other lines, pumps, manways and ancillary equipment
•If corrosion protection and leak detection are maintained then the tank can remain temporarily closed indefinitely
58
PST CLOSURES
Permanent Closure
Regulated PSTs that do not meet federal upgrade requirements must be
permanently closed. Permanent closure entails the removal of the PST
from the ground or in place closures may be approved by the local fire
department and the DEQ. To properly close an PST in Utah, an owner
must:
•Contract with a Utah Certified Remover
•File a Closure Plan, and obtain approval
•Notify the local fire department, LHD and the DEQ 72 hours prior to
closing the tank
•Close the tank either by removing it or by filling it with an inert
substance, like sand or cement slurry
•Have a Utah Certified Soil/Groundwater Sampler collect the
necessary environmental samples and have them analyzed at a
certified laboratory
•If contamination is present, the Owners/Operators and/or the certified
person must notify the DEQ within 24 hours
•Submit the Closure Notice with the sample analytical results within
90 days of closure
•In the case of in-place closures, meet the requirements of the Division
of Solid Waste Management and Radiation Control by placing a
notice on the title of the property
59
PST CLOSURES
Closure Plan
A completed Closure Plan must be submitted by the Owner/Operator
and approved before commencing closure of the PST. A contractor may
complete the Closure Plan; however, the Owner/Operator is responsible
for compliance with all rules and regulations. Information on the
Closure Plan includes:
•Once approved the Closure Plan is valid for one year
•Changes to an approved plan must be submitted in writing to the
DERR and approved before closing the PST
•A copy of the approved Closure Plan must be on-site during closure
activities
Closure Notice
Within 90 days of closing the PST, the Owner/Operator must submit the
following:
•Completed Closure Notice signed by the Owner/Operator and the
certified soil/groundwater sampler
•Updated site map and sample information table with the actual depths
and locations of all soil and water samples, including depth of
groundwater
•Analytical results of all samples
•Chain of Custody form, which tracks the samples from the time they
were collected until they were delivered to the laboratory
60
CLOSURES
Release:is any spilling, leaking, emitting discharge, escaping,
leaching or disposing from an PST in groundwater, surface water or
subsurface soils
Spills:occur during customer’s use at the dispenser or during the
filling of an PST at the tank fill pipe and impact the ground surface
Overfills:occur when an PST tank is filled beyond its capacity
resulting in a discharge of product to the environment
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 then 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
61
RELEASE RESPONSE
Suspected Release may include:
•Overfill Alarm
•ATG Alarm
•Failed ATG test
•Failed SIR report
•Fuel Alarm
•Sudden loss of product
•Any other unusual operating condition
•ATG says “No Idle Time”
•More fuel deliveries than normal
•Pumps are slow or don’t pump
•Inventory doesn’t seem to match up or make sense
•Owners and Operators must report a suspected release or unusual
operating condition to the DERR within 24 hours of the spill, overfill
or release
62
RELEASE RESPONSE
Suspected Release Confirmation Steps
•Owners/Operators must investigate and confirm within 7 days that a
suspected release of a substance occurred
•If the Owner/Operator cannot obtain a passing test or justify the
alarm, the owner must notify the DERR
Response
•Owners/Operators must be prepared to respond to a release before it
happens
•Stop the release
•Contain the release or spill or overfill
•Call for help
63
RELEASE RESPONSE
•Environmental Assurance Program (EAP) and Registration Fees are
due by July 1 of each year
•This is not a complete fee schedule. To verify current fee schedule
please see our website for more information
New Installations
•EAP -$150/tank
•Registration Fee : $110/tank if using EAP, $220 if not using EAP
Existing Facilities
•EAP Fees based on through-put. Cut off is 70,000 gallons per
facility per year
•Over -$150/tank
•Under -$450/tank
•Registration Fee
•$110/tank if using EAP
•$220/tank if not using EAP
•$300/tank if out of compliance for more than six months
•Late Fees -$60
•Certifications -$225/two years
•AB operator initial certification -$100
•AB operator renewal -$50/three years 64
Fee Schedule FY 2024
65
tanks.utah.gov
OR
astnotice.utah.gov
Aboveground Petroleum Storage Tank
(APST) Requirements
•Regulations 67
•Notification 68
•Certificate of compliance 69
•Application
•PPI
•Fees
•Testing
•Installations 70
•Closures 71
•Reuse Requirements 72
•Annual & Three Year Requirements 73
•Five Year & Future Requirements 74
•SPCC Plans 75
66
Table of Contents for APSTs
Due to legislation passed in the 2021 session, DERR began regulating
specific types of Aboveground Petroleum Storage Tanks (APSTs) on
May 5, 2021. By statute (19-6-407).
What is a regulated APST?
A petroleum storage tank greater than 500 gallons and meets one or both of the
following:
•If the APST rests on soil or gravel
•If any portion of the piping is underground
APSTs not regulated include:
•Less than 501 gallons
•Commercial airport for fueling
•Used in farming or agriculture
•Petroleum refiner (SIC Code 2911)
•Petroleum bulk stations and terminals (SIC Code 5171)
•Related to oil or gas production and gathering operations
•Used for heating oil on premises
For additional exemptions see R311-200-1
67
APST Regulations
Owners and Operators of regulated APSTs must notify the DERR APST Notification Form. A $250 processing fee will be assessed once the notification form is received.
Please email notification forms to tankcompliance@utah.gov
The notification form can be found at astnotice.utah.gov
68
APST Notification
To qualify for a certificate of compliance the APST owner/operator must
complete and submit the following (R311-206-3):
•Payment of annual registration fee ($110 per tank or $220 per tank if not
participating in the Environmental Assurance Program (EAP))
•Payment of annual PST fund fee if participating in the EAP ($150 per tank, or $450
per tank if you don’t submit annual throughput or if your annual throughput is less
than 70,000 gallons);
•Certificate of Compliance Application;
•Previous Pollution Incident form;
•Financial Responsibility Declaration
•Tank Tightness Test(s) performed in the last six months;
Refer to the Steel Tank Institute (STI)R912 Reference Document for testing
procedures.
•Line Tightness Test(s) performed in the last six months;
•Spill Bucket Test(s) performed in the last six months required only for APST
facilities participating in the EAP;
•As-built drawing or site plat;
•Site assessments for regulated APST facilities participating in the EAP are optional.
If a site assessment is not conducted, new releases from a documented, known
source are 100% covered starting day one of participation. Historic contamination
discovered after 10-years of continuous coverage will also be 100% covered. Non-
regulated APSTs must perform a site assessment and historic impacts are not
covered.
All forms can be found at astnotice.utah.gov
69
Certificate of Compliance (CoC)
70
APST Installations
•As of July 1, 2022 –APSTs must notify DERR within 30-days of
installation using the install notification form.
•Before operating a new APST an owner/operator shall provide
documentation of financial responsibility.
Recommendations for Owners/Operators of APST
Hire a qualified contractor
Recommendations for Petroleum Contractors
Prior to installing an aboveground tank, we suggest the following sources be
consulted:
•NFPA 30: Flammable and Combustible Liquids Code
•NFPA 30A: Code for Motor Fuel Dispensing Facilities and Repair Garages
•PEI/RP200 –Recommended Practices for Installation of Aboveground Storage
Systems for Motor Vehicle Fueling
•The Manufacturers Installation Instructions
•State and Federal Regulations
•Local Fire Department
•Local Ordinance
71
APTS Closures
•All regulated APSTs are required to submit a closure plan for
any closures, upgrades, line replacements, etc.
•A Closure Plan for the removal of APSTs must be submitted and
approved by the DERR before any work begins.
•Permanent Closure Requirements (same as USTs):
•Contract with a Utah Certified Tank Remover
•Notify local fire department, local health department, and DERR prior to
closing the tank
•Contract with a Utah Certified Soil/Groundwater Sampler
•If contamination is present, notify the DERR within 24 hours
•Submit the Closure Notice with sample analytical results w/in 90 days
of closure
•Closure Plan Requirements (same as USTs):
Tank Info
Tank Remover and Sampler
Sampling Plan & analysis method to be used
Site Plat showing surrounding buildings, streets, utilities, etc.
72
APTS Reuse Requirements
•R311 -204-3(3):
•Any removed APST that is to be reused as an APST must be recertified by the
manufacturer of the tank or undergo a tank inspection, conducted by a qualified
contractor, using a nationally recognized standard such as API 653.
AND
•STI R912 6.5
•6.5 Tank relocation requirements –Aboveground storage tanks are often
relocated. The following instructions are to be followed when this occurs. All
steps are to be documented and the documentation is to be kept for the life of
the tank.
•6.5.2 A tank must undergo the appropriate inspection prior to relocation. The
tank must be subjected to a pressure (or vacuum) test as detailed paragraph 3.2
above except an inert gas, such as nitrogen, should be used for tanks that have
previously held fuel.
Annual Requirements
•Pay annual registration Fees;
•Pay Environmental Assurance Program (EAP)
Fund Fees if applicable;
•Submit annual line tightness tests.
73
Three-Year Requirements
•Submit pressure relief valve testing on
gasoline tanks.
74
Future Requirements
•Overfill, cathodic protection, and line leak
detector tests will be required starting
7/1/2026.
•Must meet Fire Code for Spill Buckets
Five-Year Requirements
•Tank Tests
Precision tightness test done by certified
Utah tester
OR
Visual Inspection done by certified Utah
tester
•REGULATORY SUMMARY The Spill Prevention Control and Countermeasure
(SPCC) regulations strive to prevent oil from entering navigable waters through the
prevention, control, and mitigation of oil spills.
•This fact sheet focuses specifically on requirements for the development of SPCC
Plans, which incorporate specific steps for preventing, controlling, and mitigating oil
spills. SPCC plans are required for facilities that store oil and oil-containing
products exceeding certain capacity thresholds where there is a possibility that an oil
spill would reach a navigable water.
•Any small business that maintains a total aboveground oil storage capacity of greater
than 1,320 gallons, or a total undergrounds oil storage capacity of greater than
42,000 gallons, where there is a reasonable potential for a discharge to reach
navigable waters is subject to SPCC regulatory requirements. Aboveground storage
containers with a capacity of 55-gallons or more are included in the aboveground
capacity threshold calculation. Underground storage tanks regulated under 40 CFR
280 and 281 are not subject to the SPCC regulations and are discussed in a separate
fact sheet.
•WHERE TO FIND OIL POLLUTION PREVENTION REGULATIONS Statutory
Authority: The Clean Water Act of 1977 and its amendments, primarily the Water
Quality Act of 1987, and the Oil Pollution Act of 1990. Regulations: The
requirements for the development and implementation of SPCC Plans are found in
40 CFR: • Part 112 –Requirement to prepare and implement an SPCC Plan. • Part
110 –Requirements for spill reporting.
75
SPCC Plan
SPCC plans are a federal requirement and will be enforced by the EPA
https://www.epa.gov/oil-spills-prevention-and-preparedness-
regulations/overview-spill-prevention-control-and