Know The Federal Underground Storage Tank Regulations
The federal underground storage tank regulations include several requirements that are not contained in all individual state-level regulations, but still apply to petroleum bulk storage facilities. We’ve seen this create confusion for many clients, which can potentially lead to your underground storage tanks not being fully compliant.
Spill Bucket and Containment Sump Testing
In October of 2015 revisions were made to the Environmental Protection Agency’s (EPA) Underground Storage Tank regulation, 40 CFR Part 280. This covers spill prevention equipment (i.e., spill buckets and spill catchment basins) and containment sumps used for piping interstitial monitoring (i.e., tank-top, transition, and under-dispenser containment). As a result this equipment is required to be periodically tested according to the following schedule:
Type of Spill Bucket or Sump Frequency of Test Required
Single-walled spill bucket Test for liquid-tightness at least once every 3 years
Double-walled spill bucket Test for integrity at least once every 3 years
OR
Be equipped with an indicator that can continuously monitor the integrity of both walls and check the indicator at least once per month
Single-walled sump Test for integrity at least once every 3 years
Double-walled sump Test for integrity at least once every 3 years
OR
Be equipped with an indicator that can continuously monitor the integrity of both walls and check the indicator at least once per year
Since the revisions, the DEC has consistently enforced that spill buckets and containment sumps remain in good working order; equipment that fails testing or is found to lack integrity via a visual inspection will be required to be repaired or replaced. Therefore scheduling frequent tests is crucial to avoid not only environmental issues but DEC penalties.
The DEC has provided guidance for facilities on the available testing procedures and what to do in the event of testing failure, all of which MES develops customized plans to handle:
Guidance on Spill Bucket/Containment Sump Testing and Spill Reporting
Overfill Prevention Equipment Inspections
The EPA requires that all overfill prevention devices be inspected once every three years to confirm, at minimum, they are installed and functioning properly, and that they are set to activate at the appropriate level. Much like the requirement to periodically test spill buckets and containment sumps (used for piping interstitial monitoring), overfill prevention equipment must be tested in accordance with requirements developed by the equipment manufacturer or a code of practice developed by a nationally recognized association or independent testing laboratory.
Release Detection Equipment Inspections
The EPA requires all electronic and mechanical components of release detection equipment be tested annually for operability. This includes the floats on automatic tank gauging systems and sensors for electronically monitored interstitial spaces. These inspections must be performed in accordance with requirements developed by the equipment manufacturer or a code of practice developed by a nationally recognized association or independent testing laboratory.
Monthly and Annual Walkthrough Inspections
The EPA requires that periodic walkthrough inspections of the facility be done to verify that several important pieces of equipment remain in good working order.
Monthly walkthrough inspections must consist of the following:
- Spill buckets
- Visually check for damage;
- Remove liquid and debris;
- Visually check for and remove obstructions in fill port.
- Release detection equipment
- Check that release detection equipment is not operating in alarm or other unusual operating condition;
- Review release detection records and ensure they are current.
Annual walkthrough inspection must consist of the following:
- Containment sumps
- Visually check for damage, leaks, and releases to the environment;
- Remove Liquid and debris.
- Release detection equipment
- Inspection hand-held release detection equipment (e.g., tank gauge sticks and groundwater bailers) for operability/serviceability.
