A Report to
U.S. Environmental
Protection Agency
DRAFT REPORT
January 1986
Applicability of
Environmental Auditing
To Underground Storage Tanks
DESIGNERS V- ^ CONSULTANTS
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DISCLAIMER
This draft report has been prepared by Roy F. Weston, Inc.
under Purchase Order No. 5W-0111-NASX for the Regulatory Reform
Staff, Office of Policy, Planning and Evaluation, U.S. Environ-
mental Protection Agency. The report is currently being
reviewed by U.S. EPA. The report reflects the findings and
conclusions of the author and not necessarily those of EPA or
any other government entity; mention of any company names,
products, or processes does not constitute an EPA endorsement.
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Section
1
2
3
6093A
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TABLE OF CONTENTS
Title
INTRODUCTION
1.1
1.2
Background
Summary
A REVIEW OF RECENT REGULATORY INITIATIVES
2.1
2.2
2.3
2.4
Introduction
Federal Regulatory Initiatives
2.2.1 Introduction
2.2.2 Existing Regulations: Key
Requirements of Subtitle I
Federal ~egulatory Trends
Relationship to Other EPA Tank
Regulations
Authorization of State Programs
Regulatory Initiatives
Introduction
Existing State Tank Regulations
State Regulatory Trends
Resu1atory Initiatives
Introduction
Existing Local Regulations
Regulatory Trends
2.2.3
2.2.4
2.2.5
State
2.3.1
2.3.2
2.3.3
Local
2.4.1
2.4.2
2.4.3
TANK ASSESSMENT AND AUDITING TECHNIQUES
3.1
3.2
3.3
3.4
3.5
Introduction
Status of UST Auditing
Data Management Systems
3.3.1 Description
3.3.2 Audit Procedures
Tank System Evaluation
3.4.1 Manual Inventory Control
3.4.2 Automatic Inventory Control
3.4.3 Internal Tank Testing Methods
3.4.4 Site Inspection
3.4.5 Groundwater Monitoring
3.4.6 External Monitoring of Tanks
3.4.7 Secondary Containment Monitoring
3.4.8 Pipeline Leak Detectors
Prevention Systems
3.5.1 Existing Tanks
3.5.2 New Tanks
iii
Page
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Section
6093A
3.6
3.7
~
TABLE OF CONTENTS
(continued)
Title
Release Reporting and Corrective
3.6.1 Release Reporting
3.6.2 Corrective Action
Tank Closure
3.7.1 Temporary
3.7.2 Permanent
3.7.3 Abandoned
Action
Closure
Closure
Tanks
ATTACHMENT A - SAMPLE AUDIT CHECK LISTS FOR
UNDERGROUND STORAGE TANKS
iv
Page
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3-22
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3-25
3-25
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SECTION 1
INTRODUCTION
1.1
BACKGROUND
On 8 November 1985, EPA issued an Environmental Auditing Policy
Statement (Federal Register 50, No. 217, 8 November 1985,
46504-8) that encouraged regulated firms to set up audit
programs. The Policy Statement stopped short of explicitly
offering less enforcement oversight, fast-track permitting, and
fewer inspections for these firms. In encouraging the
development of audit programs, the Agency is continuing the
implementation of a 1982 informal, three-pronged policy of
endorsement, analysis, and assistance.
EPA has endorsed environmental auditing: by producing,
compiling, and disseminating audit-related literature; by
speaking about auditing at workshops and conferences; and by
continuing to communicate with an expanding network of
interested professionals, trade associations, and state
agencies. The Agency has analyzed the various factors
affecting compliance management and auditing, the
characteristics of effective audit programs, and the benefits
of auditing to the regulated community and the environment.
Finally, EPA has assisted interested states and Federal
agencies seeking to propose more-specific auditing approaches.
This report is part of EPA's program of providing technical
assistance and public information to support environmental
auditing. In this instance, the issue addressed is the use of
auditing to promote compliance with underground storage tank
regulations.
On 8 November 1984, President Regan signed into law the
Hazardous and Solid Waste Amendments (HSWA). Subtitle I of the
HSWA established requirements for development of a new program
to regulate underground storage of petroleum products and
hazardous substances. Even with active state and local
involvement, the regulation of an estimated 1.2 million tanks
governed by this program is a challenge which cannot be
adequately met by regulatory agency enforcement and inspection
activities. Environmental auditing can improve compliance by
complementing regulatory agency oversight activities.
1-1
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1.2
SUMMARY
The remainder of this report is divided into two sections.
Section 2 is a review of recent regulatory initiatives and
trends. The review indicates that there is a great deal of
regulatory activity related to underground storage tanks at the
Federal, state, and local levels. Unlike some Federal
programs, the Federal UST program encourages states to develop
their own programs without waiting for the passage of Federal
regulations. As a result, existing programs vary widely in
terms of scope, types of tanks and substances regulated, and,
technical standards for tank design and lead detection
systems. Subtitle I of HSWA provides for flexibility in the
authorization of state programs, which means that a wide
variety of tank assessment techniques are likely to remain in
use for some time to corne.
Section 3 is a review of underground storage tank assessment
and auditing techniques. As shown in Table 1-1, assessment
techniques include a wide variety of mechanisms designed to
monitor for, prevent, and/or mitigate leaks. Major classes of
assessment techniques are as follows:
.
.
.
.
.
Data Management Systems
Tank evaluation systems
Prevention Systems
Release reporting/corective
Tank closure.
action
Federal, state and local regulations and
practices can require the use of one or many of
described in Section 3.
good
the
management
techniques
Environmental audits would be used to review both the
underground tank and the systems put in place to monitor,
prevent, or mitigate leaks. Audit techniques can include the
use of inquiry, records review, testing, and observation.
In Section 3, for each assessment technique, there is a
discussion of how an auditor could determine whether the
technique was installed properly, is used properly, and whether
the resultant data on tank integrity is evaluated and acted
upon properly. These proposed audit approaches can be
incorporated directly into an existing audit program but the
approaches must be tailored to meet (1) the type of tank, (2)
the type of in-place assessment techniques, (3) the form of the
checklists used for the current audit program, and (4)
corporate or institutional policy.
1-2
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Table l-i
Summary of Auditing Procedures
Applicable to Tank Assessment and Management Systems
Auchting Procedures
InqL:lry R~('"C'rc~ Revie.. Te~tinCl Observation
~
u: ..., u:
t:I u: r: E
E I- c.,
l> I- ..:: If. ...,
t: ~ ..., If. '" >-
I- c., t: I- g >- ... t: &: ...,
::J 0' 0 r: 0 UJ "'" 0 0
..., .... <: t: ..... c.. ..... ..... l-
I'; Co ..., .::::. - (.; -' - ""' t: ...,
.... >- l> c:: :-' - l> l>
.... c., c .&: c., ""' ~ a.
...., ::. ..., u: ~ -' :J". "" u: u;
" ...., l> r.r. ~ t: Co r: ...... c., ~ ......
Tank Assessment .... "" 11: ... I:J C .... :r. C i- ~ '"
.... t: ":J ..:: E '"
and Management c.' :J ~ E .>< - .>< ''''' ,>< .~ '"' .>c: .>< Ci (.;
Systems t: t: ..., I- "" t'" t: "" l> r: r: II: t: ..., l>
} r.:> CJ C ~ t..: t: [: I- t: ~ r: ~ II: .~ U
::!: c:: Z i- :.J <: E- :J; <:
Data Manaoement
System X X X X X X X X
Tank System Evaluation
Manual Inventory
Control X X X X
Automatic Inventory
Control X X X X X X X X X X
Tank Testing X X X X X X X X
Site Inspection X X X X X
Groundwater Monitoring X X X X
External Mcnltoring X X X X
Secondary
Containment X X X X X X X X X X
Pipeline Leak
Detectors X X X X X X X X X X
Prevention Systerrs
Existing Tank Retroflt
- Cathodic Protection X X X X X X
- Lining/Relining X X X X
- Mandatory. Retirement X X X
- Over f ill Protectlon X X X X X X
New Tanks
- Design X X X X
- Installation X X X X X
- Overf ill Protection X X X X X X X
Release Reporting/
Corrective Action
Release Reporting X X X
Corrective Actlon >: X x X X
Tank Closure
Temporary X X X X X X
Permanent X X X
Abandoned Tanks X X X
l-3
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SECTION 2
A REVIEW OF RECENT REGULATORY INITIATIVES
2.1
INTRODUCTION
Section 2 indicates that federal, state, and local regulations
governing underground storage tanks vary widely in terms of the
types of tanks and substances regulated, as well as in
requirements for new and existing tanks. The current federal
regulatory trend is toward development of a single set of
technical standards governing all tanks and all regulated
substances, with emphasis on broad, performance-oriented
regulations. In contrast to some federal regulatory
initiatives, the federal UST program is designed to encourage
states to develop their own programs as soon as possible,
without waiting for passage of federal regulations. Flexibility
in the authorization of state programs is provided to encourage
state action. As a result, a wide var iety of tank assessment
techniques is likely to remain in use for some time to come.
Existing federal, state, and local regulations and recent
regulatory trends are summarized below-
2.2
FEDERAL REGULATORY INITIATIVES
2.2.1
Introduction
On 8 November 1984 President Reagan signed into law the
Hazardous and Solid Waste Amendments of 1984 (Public Law
98-616). Title VI of this statute establishes a new subtitle to
the Solid Waste Disposal Act (usually referred to by the name
given to the 1976 Amendments, the Resource Conservation and
Recovery Act) which mandates that the Environmental Protection
Agency develop a program to regulate the underground storage of
petroleum and chemical products. A section of this law has a
direct effect on petroleum storage tanks. The requirements of
this law are found in Subtitle I, Section 9000 through 9010.
Key sections are described below.
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2.2.2
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Existing Regulations:
Key Requirements of Subtitle I
Definitions and Exemptions, Section 9001
Section 9001 defines lIunderground storage tank II as a tank or
combination of tanks (including underground pipes which are
connected to such tanks) which is used to contain regulated
substances and is 10 percent or more beneath the surface of the
ground. The volume of the underground pipes must be included in
the calculation of the 10 percent threshold. The definition of
underground tanks does not include any:
.
Farm or residental tank of 1,100 gallons or less
capacity used for storing motor fuel for noncommercial
purposes.
.
Tank used for storing heating oil for consumptive use
on the premises where stored.
.
Septic tank.
.
Pipeline facility (including gathering lines)
regulated under a number of existing federal laws.
.
Surface impoundment, pit, pond, or lagoon.
.
Storm water or wastewater collection systems.
.
Flow-through process tank.
.
Liquid trap
related to
operations.
or
oil
associated
or gas
gathering
production
lines
and
directly
gathering
.
Storage tank si tuated in an underground area (such as
a basement, cellar, or mineworking drift, shaft, or
tunnel) if the storage tank is situated on or above
the surface of the floor.
The term IIregulated substance" means any petroleum, or any
petroleum product, or any hazardous substance as defined in
Section 101 (14) of Superfund, but not a listed or identified
hazardous waste under Subtitle C of RCRA.
6093A
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Notification, Section 9002
Not later than 8 May 1986 each owner of an underground storage
tank must notify the designated state or local agency of the
existence of his tank. The notification, which is to be
provided on a form prescribed by the EPA Administrator, must
spec i fy the age, size, type, location, and use of each tank.
The same information must be provided (within 30 days of
installation) for any tank brought into operation after 8 April
1986.
For each tank taken out of operation after 1 January 1974, the
owner must provide notice of the existence of the tank (unless
the owner knows the tank was subsequently removed from the
ground) and the date the tank was taken out of operation. The
notice must also specify the age of the tank when it was taken
out of operation, the size, type, and location of the tank and
the type and quantity of any substances left in the tank.
In addition, beginning 30 days after the Administrator
prescr ibes the form of notice (and for 18 months thereafter)
anyone who deposits regulated substances in an underground
storage tank shall notify the owner or 'operator of the
notification requirements. Beginning 30 days after the
Administrator issues new tank performance standards, anyone who
sells a tank (for use as an underground storage tank) must
notify the purchaser of the notification requirements.
Release Detection, Prevention, and Correction Reguations,
Section 9003
Section 9003 requires the Administrator to promulgate release
detection, prevention, and correction regulations as may be
necessary to protect human health and the environment. These
regula tions must include (but need not be 1 imi ted to)
requirements for:
.
Maintaining a leak detection system, an inventory
control system together with tank testing, or a
comparable system or method designed to identify
releases in a manner consistent with the protection of
human health and the environment.
.
Maintaining records
detection system or
testing system.
of any monitoring or
inventory control system or
leak
tank
2-3
6093A
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.
Reporting of any releases and corrective action taken
in response to a release from an underground storage
tank.
.
Taking corrective action in response to a release from
an underground storage tank.
.
The closure of tanks to prevent future
regulated substances into the environment.
releases
of
.
Maintaining evidence of financial responsibility for
taking corrective action and compensating third
parties for bodily injury and property damage caused
by sudden and nonsudden accidential releases arising
from operating an underground storage tank.
.
Standards
tanks.
of performance
for
new underground
storage
In promulgating these regulations, the Administrator is
permi tted to distinguish between types, classes, and ages of
underground storage tanks. In making such distinctions, the
Administrator may take into consideration factors, including,
but not limited to location of the tanks; soil and climate
condi tions; uses of the tanks; history of maintenance; age of
the tanks; current industry recommended practices; national
consensus codes; hydrogeology; water table; size of the tanks;
quanti ty of regulated substances per iodically deposited in or
dispensed from the t~nk; technical capability of the owners and
operators; and the compatibility of the regulated substance and
the materials of which the tank is fabricated.
In developing the regulations for new tanks, the Administrator
must establish standards concerning release detection and
design, construction, and installation of the tanks, as well as
the compatibility of the tanks to the materials that are stored.
The Administrator may
owners and operators
res po n sib i 1 i t Y " ( e . g . ,
and compensating third
damage caused by sudden
also promulgate regulations requiring
to maintain "evidence of financial
insurance) for taking corrective action
parties for bodily injury and property
and nonsudden accidental releases.
By 8 February 1987 the Administrator must promulgate the leak
detection, prevention, and correction regulations .for tanks
containing petroleum products. The same deadline applies to
regulations for new tank performance standards.
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6093A
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By 8 August 1987 the Administrator must promulgate
standards for new tanks designed to store hazardous
One year later the Administrator must promulgate
for existing tanks containing hazardous substances.
performance
substances.
regulations
In each case,
promulgation.
the regulations take effect three months after
Section 9003 also requires that beginning 7 May 1985 no
underground storage tank may be brought into use unless the
tank will prevent releases due to corrosion or structural
failure during the operational life of the tank: and is
cathodically protected, is constructed of a noncorrosive
material (such as fiberglass), is clad with a noncorrosive
material, or is designed to prevent the release of the stored
substance. In addition, the mater ia1 used in the construction
or lining of the tank must be compatible with the substance to
be stored.
The interim prohibition does not apply if the tank is installed
in soil whose resistivity is 12,000 ohms/centimeter or greater.
To date, EPA has issued final regulations governing tank
notification requirements and final regulations governing the
interim prohibition on bare steel tanks.
Approval of State Programs, Section 90a4
A key element of Subtitle I is the provision which allows
states to administer and enforce the underground storage tank
program in lieu of EPA. To qualify as an approved program, a
state's regulations must be "no less stringent" than the
Administrator's and must include the requirements for new tank
performance standards, as well as the release detection,
prevention, and correction standards for existing tanks.
Inspections, Monitoring, and Testing, Section 9005
In order to assist the Administrator in developing and
enforcing underground tank regulations, Section 9005 p"rovides
that owners and operators shall provide, on request,
information relating to their tanks and associated equipment,
as well as all relevant records. In addition, EPA officials (or
representatives of a state with an approved program) are
authorized to:
.
Enter at reasonable times any establishment or other
place where an underground storage tank is located.
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6093A
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.
Inspect and obtain samples from any person
regulated substances contained in such tank.
of
any
.
Conduct monitoring or testing of the tanks, associated
equipment, contents, or surrounding soils, air,
surface water, or groundwater.
Federal Enforcement, Section 9006
Section 9006 authorizes the Administrator to issue orders
requiring compliance with any requirements that he determines
are being violated. Failure to comply may result in a civil
penalty.
Other Requirements, Section 9007 - 9010
The remaining sections of the Act govern:
2.2.3
federal
facilities,
.
Applicability
Section 9007.
program
to
the
of
.
Ability of states and local authorities to adopt more
stringent regulations, Section 9008.
.
UST studies to be performed, Section 9009.
.
Authorization of appropriations, Section 9010.
Federal Regulatory Trends
To date, EPA has issued final regulations governing tank
notification requirements and final regulations governing the
interim prohibition on bare steel tanks.
New federal regulations
will be promulgated over
time, it appears the
following elements:
governing underground storage tanks
the next several years. At the present
federal program will encompass the
6093A
.
Flexible approach to authorization of state UST
programs, in order to encourage states to develop UST
programs as soon as possible.
.
Emphasis on broad, performance-oriented tank technical
standards in order to accommodate continuing
development of leak detection t\chnologies.
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.
Development of technical standards for all tanks and
all regulated substances through one regulatory
process.
.
Development of regulations for new
petroleum tanks on the same schedule
hazardous substance tanks (despi te
provisions for a phased schedule).
Tailor ing the UST program to EPA I S groundwater
protection strategy by adopted baseline standards for
all tanks wi th additional requirements for tanks in
Class I (vulnerable) aquifers and exemptions available
for tanks in Class III (limited use) aquifers.
and existing
as those for
legislative
.
2.2.4
Relationship to Other EPA Tank Regulations
Subtitle I of RCRA, which establishes the UST program,
specifically excludes hazardous waste storage and treatment
tanks. Hazardous waste tanks are governed by Subtitle C of
RCRA. The approaches to regulating the two types of tanks
differ greatly.
EPA I S existing regulations for (above- and below-ground)
hazardous waste tanks were promulgated in 1980 and 1981.
Interim status standards for the storage and treatment of
hazardous wastes in tanks were promulgated in May 1980 and are
contained in 40 CFR 265, Subpart J. These standards focus on
operational measures designed to prevent releases from tanks.
RCRA permitting standards for tanks which can be entered for
inspection were promulgated in January 1981 and are contained
in 40 CFR 264, Subpart J. These standards emphasize structural
integrity of tanks to protect against rupture, leaks, and
collapse.
Several elements are not addressed in the existing hazardous
waste tank regulations. First, a secondary containment standard
is not included. Secondly, existing permitting standards
contained in 40 CFR 264 address only tanks which can be entered
for inspection. Underground tanks which cannot be entered for
inspection are not addressed. Finally, existing standards do
not require corrosion protection for steel tanks exposed to
corrosion-inducing soils.
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As a result, EPA proposed new regulations to address additional
aspects of hazardous waste tank management in June 1985 (50 FR
26444-26504). These regulations have not been finalized.
The proposed hazardous waste tank regulations are compared to
the UST regulations in Table 2-1. Significant differences
include:
.
Permi t requirement-
permit for UST.
no
tanks;
for
hazardous
waste
.
Groundwater monitor ing and secondary
main features of the hazardous waste
and are only two of several
consideration for UST.
containment are
tank regulations
options under
.
The proposed UST regulations appear
toward an emphasis on improved tank
secondary containment.
to be
designs
leading
without
These inconsistencies can be explained by:
.
Differences in statutory language.
.
Differences in the size of the regulated community.
(Approximately 1,547 underground hazardous waste tanks
exist today, as compared to more than 1.2 million UST.)
.
possible differences
system design.
in management practices and tank
In short, the statutory language and proposed regulations
governing the two types of tanks differ significantly. The two
regulatory approaches will have to be explained based on the
differences in the tank systems, tank management practices, and
number of tanks regulated under the two programs. Otherwise,
one of the two regulatory approaches will have to be changed to
resolve inconsistencies.
2.2.5
Authorization of State Programs
Regulation of more than 1.2 million tanks is a complex task
which clearly requires state and local involvement in
implementation and enforcement. The federal approach to UST
regulation is to encourage states to develop their own programs
as soon as possible, without waiting for the final federal
regulations. The federal approach to authorization of state
programs is therefore flexible in order to accommodate
individual state initiatives.
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Table 2-1
Comparison of Proposed Federal Hazardous Waste Tank
Regulations and Existing Federal UST Regulations
Type of Tank
Containment Requirements
Existing Tanks New Tanks
Hazardous waste
storage/treatment
tanks (RCRA permit
required; proposed
40 CFR 264-265)
Hazardous waste
"less than 90-day"
accumulation
tanks (No RCRA
permit; proposed
40 CFR 262.34)
UST (40 CFR 280)
Within one year of
effective date:
-Full secondary
containment
or
-Leak~esting every
6 months and ground-
water monitoringl
Within one year of
effective date:
-Full secondary
containment
or
-Applyfor Part
264 permit
No requirements at
present
Full secondary
containment
Fu.ll secondary
containment
Emphasis on
improved tank
designs (e.g.,
corrosion-resistant
tanks compatible
with product
stored) without
secondary contain-
ment
lApplies to existing underground tanks. Existing inground
tanks (those partially above ground) require full secondary
containment or partial secondary containment and groundwater
monitoring.
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Beginning in May 1987, states may seek federal authorization to
operate and enforce their UST programs in lieu of the federal
program. States must demonstrate that their programs contain
the major elements of the federal program and provide for
adequate enforcement of these elements.
States may apply for authorization for tanks containing
petroleum, tanks containing other regulated substances, or
both. To obtain author ization, the state's program must be no
less stringent than the federal program. However, RCRA provides
a 1- to 2-year grace period to make it easier for the state to
satisfy the "as stringent" requirement. The objective is to
encourage states to proceed to establish UST programs and not
.wait until federal regulations are developed.
Section 9008 of RCRA allows states and local governments to
adopt regulations which are more stringent than those contained
in the federal program. In fact, many state and local agencies
have already adopted more str ingent regulations, as descr ibed
in Subsection 2.2.
Section 9004 of RCRA, which governs state authorization, can be
interpreted in several ways. However, it appear s that a state
program may be author ized dur ing the initial grace per iod if
the state has legislative authority as stringent as the federal
law in four major areas: corrective action, financial
respons ibil i ty, per formance standards for new tanks, and
notification system, and if the state proceeds to fill gaps in
legislation or regulations after the federal program is
established.
EPA may withdraw authorzation and reinstitute the federal
program if it holds a public hearing and finds that a state is
not administrating and enforcing a program appropriately.
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2.3
STATE REGULATORY INITIATIVES
2.3.1
Introduction
Many states had regulations governing the storage of hazardous
materials underground long before the passage of the 1984 RCRA
amendments. For the most part, these regulations were based on
the National Fire Protection Association (NFPA) standards or
Uniform Fire Code (UFC) standards governing the safe storage of
flammable materials underground. However, the scope of the
regulations varied widely. Some states regulated all hazardous
mater ials, while other s covered only the storage of flammable
materials. Some states have adopted only fire safety standards,
while others included leak detection system requirements. A few
required overfill protection and tank repair/replacement.
The American Petroleum Institute (API) conducted a brief survey
in June/July 1985 to gauge the level of activity relating to
the development of comprehensive state underground storage tank
regulations following passage of the 1984 RCRA amendments. The
survey indicated a high level of interest in the development of
comprehensive state regulations. A number of states have
introduced or enacted leg islation on the subject in the last
year.
A summary of state regulatory activity related to UST is
provided in Table 2-2. The first column summarizes state
activity related to development of comprehensive UST
regulations. This information is based on the June/July 1985
survey conducted by API, which has been updated based on
conversations with selected regulatory agencies and regulatory
updates contained in The Tulsa Letter.
Column two was derived from an April 1984 study performed for
the U.S. EPA, OPA, which compared state pre-UST regulations to
the NFPA and USC standards. This information is prov ided to
give the reader an indication of the scope of existing tank
regulations in states which have not initiated a comprehensive
UST program.
Column 3 summarizes the status of state petroleum leak cleanup
programs . This information was also obtained from a 1985 API
survey, which was included in Options Paper for the Underground
Storage Tank Technical Standards, prepared for U.S. EPA, OSWER,
in August 1985. Those states with asterisks have been selected
for further analysis.
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Table 2-2
Status of State UST Regulations
Comprehensive NFPA/USC- Leak Cleanup
State UST programl Based program2 program3
AL None None None
AK None None None
AZ None Equal to UFC Existing-HW and
petroleum
AR None More stringent Existing-HW and
petroleum
*CA Regulations Legislation only Existing-HW and
existing petroleum
CO None More stringent None
*CN Regulations More stringent Existing-HW and
pending petroleum
DE Legislation More stringent Existing-HW and
existing petroleum
*FL Regulations More stringent Existing-HW and
existing petroleum
GA Legislation More stringent None
pending
HI None None None
ID None Equal to UFC Proposed-HW and
petroleum
IL Legislation More stringent Existing-HW
pending Proposed-petroleum
lSource: API Survey-June/July 1985.
2Source: u.S. EPA, OPA, Review of Underground Storage
Regulations, April 1984.
3Source: U.S. EPA, OSWER, Options Paper for the Underground
Storage Tank Technical Standards, August 1985.
*Selected for further analysis.
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Table 2-2
(continued)
Comprehensive NFPA/USC- Leak Cleanup
State UST programl Based program2 program3
IN None More stringent None
IA Regulations Equal to NFPA Existing-HW and
pending petroleum
*KS Regulations More stringent Existing-HW and
existing petroleum
KY None Equal to NFPA Existing-HW
Proposed-Petroleum
LA Legislation Equal to NFPA None
existing
ME Legislation Equal to NFPA Existing-petroleum
existing in state waters
*MD Legislation and More stringent Existing-petroleum
regulations in state waters
existing
MA Regulations More stringent Existing-HW and
pending petroleum
MI Regulations More stringent Existing-HW and
pending petroleum
MN Legislation More stringent Existing-HW and
pending petroleum
MS None None Existing-Hw and
petroleum
MO None None Existing-HW and
petroleum
lSource: API Survey-June/July 1985.
2Source: u.S. EPA, OPA, Review of Underground Storage
Regulations, April 1984.
3Source: U.S. EPA, OSWER, Options Paper for the Underground
Storage Tank Technical Standards, August 1985.
*Selected for further analysis.
2-13
6093A
-------
~
Table 2-2
{continued}
Comprehensive NFPA/USC- Leak Cleanup
State UST Programl Based program2 Program3
MT Legislation Equal to UFC None
pending
NB Legislation None None
pending
NV None Equal to UFC None
*NH Regulations None Existing-petroleum
existing
NJ Legislation Legislation Existing-HW
pending pending and petroleum
NM None None Existing-HW
and petroleum
NY Legislation Legislation Existing-HW
pending only and petroleum
NC LE:'gislation None Existing-HW
pending and petroleum
ND None None None
OH None More stringent Existing-petroleum
Proposed-HW
and petroleum
OK None Equal to NFPA None
OR Legislation None Proposed-HW
pending and petroleum
lSource: API Survey-June/July 1985.
2Source: U.S. EPA, OPA, Review of Underground Storage
Regulations, April 1984.
3Source: U.S. EPA, OSWER, Options Paper for the Underground
Storage Tank Technical Standards, August 1985.
*Selected for further analysis.
2-14
6093A
-------
~
Table 2-2
(con tinued)
Comprehensive NFPA/USC- Leak Cleanup
State UST Programl Based program2 program3
PA Regulations More stringent None
pending
*RI Regulations Legislation only Existing-HW
existing and petroleum
SC Legislation None Existing-HW
pending and petroleum
SD Legislation Equal to UFC Existing-HW
existing and petroleum
TN None Equal to NFPA Existing-HW
and petroleum
TX None More stringent .None
UT None None Existing-HW
and petroleum
VT Legislation Equal to NFPA Existing-HW
existing and petroleum
VA None None Existing-HW
and petroleum
WA Legislation None Proposed-HW
pending and petroleum
WV None Equal to NFPA None
WI None More stringent Existing-HW
and petroleum
WY Legislation None None
pending
lSource: API Survey-June/July 1985.
2Source: u.S. EPA, OPA, Review of Underground Storage
Regulations, April 1984.
3Source: U.S. EPA, OSWER, Options Paper for the Underground
Storage Tank Technical Standards, August 1985.
*Selected for further analysis.
2-15
6093A
-------
2.3.2
~
Existing State Tank Regulations
Seve~ comprehensive state UST programs were selected for
detalled evaluation and comparison. The states selected for
comparison include: California, Connecticut, Florida, Kansas,
Maryland, New Hampshire, and Rhode Island. The general
requirements, existing tank requirements, and new tank
standards for the seven states are briefly summarized in Tables
2-3, 2-4, and 2-5, respectively. The scope and approach for the
seven programs vary greatly. Significant discrepancies are
noted below.
General Requirements - Table 2-3
.
Only two
hazardous
Island) .
states
storage
regulate both oil and
(California and Rhode
of seven
material
.
Three states regulate above-ground and
storage tanks (Florida, Kansas, and
Exemptions for tanks vary among the states.
under-ground
Maryland) .
$tate approaches to interaction between the government and tank
owners vary. Florida established standards which are assured by
enforcement and inspection. Several states require plans be
submitted to the state for review and approval (Kansas, New
Hampshire, and Rhode Island). Three states require tank permits
be obtained (California, Maryland, and New Hampshire) .
Existing T&nk Requirements - Table 2-4
6093A
.
Inventory control is required in most states, except
those with more stringent monitoring requirements
(California, Florida, and Rhode Island).
.
Leak detection requirements
methodology and frequency.
of
in terms
vary g rea tly
.
Several states have retrofit requirements. In most
instances, retrofit is required for leaking tanks
only. In contrast, Flor ida has established a phased
tank program for upgrading all existing tanks to new
tank standards by 1999.
.
Mandatory retirement of tanks past a certa~n age is
required in two states (Connecticut and New Hampshire) .
2-16
-------
] .
2.
2.
N
I
~
-.I
4.
').
6.
7.
~-- ------------
St ill f'
liST l'r.HJr","
----------
('iJ I j Lot n iil
(I1.- 7-J
S"ven Comprph"ns ive Slate (IS'" Programs
- - (;"f',(.ra] Hequi rpmpnts
Tanks Regulatpc1
Expmptions
(lnderqrounn tanks
no s i z e I i m it
(lndergrounc1 tanks
no size limit
Ahove-ground and
unc1er-qround tanks
550 gal]ons capacity
I\hove-qrounc1 anc1
under-ground tanks
Above-ground and
under-grnunn tanks
lJnder-grounc1 storage
tanks
(lnc1er-grounJ storage
tanks
--- -"- -- -------- ---------.---------.- ----.-----.------.-----
(,Os
Heqistrat inn ,"
ex i s tin q t... n k !;
IH'\-/ clnd
----------.
-------
S L" L I-
lIS'I' Prl,qrdlll
--~--- --.-+ -
I.
Ca II r IJ 1 n i"
((H>Y111 rlL j ...III~
ddoptl'eJ I/U'»
2 .
CUIIIH:-C:l iClil
(I<"'jlll dL ion"
"lh.pLI,d II/U'»
2 .
[o')()1 iet.1
(UI-qn 1 nsive State lIS'J' ProQraRis
-- f';Xif;tillfJ 1\tnk Hpquirements
------------- ---------
I.eak Detection
-- ---'------------'-----------------
Mannatory Rf't 1 rr'mf-nt
- ----------------- - ----
Repair, Relining, Retrofit
..-----------
- Inventory control for motor flll'l tanks
- Visual monitorin'J when ff'i3siloll'
- ~Ionitorin
-------
Stale
US'!' Program
Tahle 2-4
(cont inlled)
Leak Detection
Mandatory Rptirement
.-- -------- -.
Repair, Relining, Retrofit
------
6.
New lIampshire
(Regulations
proposed 2/8~)
7.
Hhode Island
(Regulations
effectivp 5/1I~)
- Inventory controls or annual stand
pipe test -
- Initial tank tightness test with
followup every 5 years; grounrlwater,
soil, or suhsurface monitoring may he
acceptahle alternative
- Precision testing of all existing
tanks by 5/87
- Annual precision testing or continuous
monitoring in comhination-With
precision testing
- Line leak detection system for liST
with remote pumps hy ~/87
- Repair hy installing liner once
- Retrofit with striker plate
- Tiqhtness testing of relined tanks
- All tanks less than 20 years mllst I,e
replaced at age 25
- All tanks more tt,an 20 years mllst he
replaced over 4-ypar schpdll]p
- Overfill protection retrofit
hy 5187
- Line leak detection retrofit for
UST with remote pump hy 5/87
- Not specified
609JA
-------
~
New Tank Standards - Table 2-5
.
All states except Kansas require improved tank designs
which emphas~ze environmental protection. Kansas
requires an impervious base and observation pipe in
the tank excavation.
.
Secondary containment is required in three
(California, New Hampshire, and Rhode Island).
states
.
Most states require installation in accordance with
NFPA and manufacturers' standards, and tank testing
prior to operation.
.
New tank monitoring requirements vary widely from no
requirements in Connecticut, to stringent requirements
in California and Rhode Island.
.
Over f ill protection is required in
(California, Florida, and Rhode Island).
states
three
In summary, states are implementing a variety of different
technical standards, particularly related to leak detection
requirements. The states are more similar in their approaches
to regulating new tanks than they are in their approaches to
regulating existing tanks. The schedules for compliance wi th
regulations also varies among the states.
2.3.3
State Regulatory Trends
New state regulations governing
greatly in terms of their status
following general trends are noted:
6093A
underground
and scope.
storage
However,
vary
the
.
There continues to be a high level of state interest
and activity related to development and implementation
of comprehensive UST programs.
.
Most state activity is related to underground storage
of petroleum products, rather than hazardous
substances.
.
Most state programs stipulate detailed procedures and
technology-based requirements. These procedures and
requirements vary greatly from state to state.
2-20
-------
State
liS'!' I't oy r alii
--.-----
Comparison lit
Tallie 2-5
S..ven ('omprehensive State liST Programs
-- New Tank Requirements
Design Requirements
Monitoring Requirements
Installation Requirements
~---- --- ------
--- . -- -~---
1.
California
(Regulations
adopt<:d l/1J5)
2.
Connect icut
(Regulations
arJopted 11/1J'i)
2.
Florida
(Regulations
adopt ed 5/1J4)
4.
Kansas
(Reyulations
implem<:nl<:d 5/1J4)
5.
MaryliJnd
(R<:'Jnl at ions
prupos"rJ '.1/84)
- Improved tank designs (rJiffer for
motor fuel and hazardous suhstances)
Primary and secondary containment
(hazardous suhstance tanks only)
- Over~ill protection (all tanks)
- Improved tank rJesigns
- Piping and underground components
protected against corrosion and
designed to facilitate testing
- Contact plates
- Improved tank designs (4 rJesigns
al lowed)
Corrosion resistant piping
- Overfill protection
- Striker plate
Tank must be installed on impervious
base sloped to collection hasin
equipped with observation pipe
- Plans must he submitted for review
and approval by state
Cathodic protection system testing -
annually
- Improved tank designs (cathodic pro-
tection or noncorrosive material
- Pressure drop leak detectors (sub-
mersihle pumps)
- .Overfil 1 protl"ction (at state's
discretion)
- Meet NFPA anrJ manufacturers' specs
- Tank tes~ing prior to being put
into service
- Meet NFPA and manufacturers' specs;
contractor certification
- Tank tightness testing within 2 years
of installation and I year hefore
end of tank guarantee
- Meet NFPA, API, ur., and
requirements
Test FRP for deflection
- Allow testing of piping
manufacturers'
- Visuill monitoring when fei'lsibl..
- Daily monitoring of all tanks,
alternatives specified
- Inventory control - motor 'uel
lnnlrs
Testing of tank and piping required
prior to use
- Meet NFPA, NACA, and manufacturers'
specs
- Tank testing prior to installation
(precision testing or air tl"st
- No blanket monitoring requirplnpnts
- State may stipulate groundwater
monitoring wells
- Daily invencory control
- Leak detector system monitoring
(tank and piping) monthly
Inventory control
Leak detection on underground
pressurized piping
Daily inventory control
- Inventory controls
- Two permanent monitoriny wells
---------
609JA
-------
State
US'" Proqr dOl
Design Requirements
Tahle 2-5
(continllP
-------
~
.
Inventory control is mandated in most states. However,
the method, frequency, and reporting requirements to
be used vary greatly.
State programs are more similar in their approaches to
regulation of new tanks than their approaches to
regulation of existing tanks.
The wide variety of regulations facing owners and operators of
underground storage tanks indicates that extensive public
education and technology transfer programs will be needed to
achieve compliance.
.
2-23
6093A
-------
~
2.4
LOCAL REGULATORY INITIATIVES
2.4.1
Introduction
Under .Section 9008 of RCRA, a state or local government may
establ~sh UST regulations, requirements, and standards which
are more stringent than the federal program.2 Nearly 100
cities and counties have promulgated ordinances governing
underground storage tanks. The scope and detail involved in the
local programs varies widely. Several of the most comprehensive
programs are listed in Table 2-6.
In some cases, state regulations preempt local ordinances.
Other states have delegated the authority to local governments.
Several examples are highlighted below.
2.4.2
Existing Local Regulations
The State of California adopted UST regulations in January
1985. Ci ties and counties which adopted their own ordinances
and regulations pr ior to I January 1984 are exempt from the
state regulations. All other cities and counties are required
to implement the state regulations. As indicated in Table 2-7,
owners and operators of underground storage tanks may be
subject to anyone of 54 regulatory programs in the state (53
local ordinances or the state regulations) , which are
administered by 99 different local agencies.
There has been no UST legislative initiative
in Texas. However, the City of Austin, Texas
most str ingent UST programs in the country
Austin's ordinance governs above-ground and
for storage of hazardous materials.
at the state level
adopted one of the
in December 1984.
under-ground tanks
Austin's program requires permits to be obtained from the local
fire marshall. All new tanks must consist of one of the
following: double-wall tanks with internal monitoring; tank
liner system; or a modified vault with electronic monitoring.
In addition, secondary containment for piping and overfill
protection is required for new tanks. Existing tanks must meet
one of two leak detection options: daily inventory control,
leak detection on subpumps, and precision testing on def ined
schedule based on age; or installation of leak detection in
monitoring wells adjacent-ro the facility-
2Tulsa Letter, May 1984.
2-24
6093A
-------
~
Table 2-6
Partial List of Local Underground Storage Tank Regulations
Santa Clara County, California
San Francisco Water Quality Board, California
Broward County, Florida (Proposed)
Dade County, Florida
Savannah, Georgia (Proposed)
New Orleans, Louisiana (Proposed)
Baltimore, Maryland (Proposed
Montgomery County, Maryland (Proposed)
Cape Cod Planning and Economic Development
Commission, Massachusetts
Omaha, Nebraska
Nassau County, New York
Suffolk County, New York
Philadelphia, Pennsylvania
Austin, Texas
Fairfax County, Virginia (Proposed)
2-25
6093A
-------
~
Table 2-7
State of California -- Local UST Regulations
Number
Number with Implementing
Local State
Ordinancesl Regulations Total
Cities 332 12 45
Counties 20 34 54
Total 53 46 993
NOTES
lCities and counties with local ordinances in place prior to
1/1/84 are exempt from state regulations.
2Does not include one city which delegated program to county.
30wners and operators of UST in California are regulated by 54
different programs involving 99 regulatory agencles.
Source:
State of California, State Water
Board, Memo dated 13 August 1985.
Resources
Control
2-26
6093A
-------
~
If the tank si te is located in the Edwards Aquifer or its
recharge zone, double-wall tanks and liner systems are the only
acceptable methods of secondary containment.
Dade County, Flor ida passed a package of ordinances governing
management and disposal of hazardous materials in November
1982. These regulations govern establishment of a trust fund
for hazardous waste cleanup, permitting of liquid waste
transporters, and regulations governing under-ground storage of
hazardous materials and hazardous waste. The UST ordinance
regulates the permitting, design, installation, modification,
repair, replacement, and operation of UST for hazardous
materials. All existing tank operators must maintain daily
inventory control systems. In addition, all existing tanks
within the cone of influence of the Northwest Well Field,
within 210 days travel time of any potable public water supply
well, or located in an area where public water supply is not
available, must meet additional protective measures. These
protective measures include installation of continuous leak
detection systems and secondary containment in accordance with
a schedule tied to tank age. Tanks located outside city limits
in these vulnerable water supply areas are alsQ regulated.
New tank standards in Dade County, Flor ida are among the most
stringent in the country. All new tanks must be equipped with
line leak detectors, four groundwater monitoring wells (if in
close proximity to water supply), continuous automatic leak
detection, and secondary containment. Written approval of plans
must be obtained pr ior to installation, and installation must
be supervised by a "registered professional engineer or
under-ground storage facility supervisor.
Suffolk County (Long Island), New York adopted a comprehensive
UST program which became effective in October 1982. Suffolk
County's program regulates gasoline and oil storage tanks, as
well as hazardous substances and hazardous waste tanks. All
existing tanks and piping must be modified to meet new tank
standards in accordance with a specified, phased schedule. New
tank standards require installation of leak detection systems,
line leak detection systems, and daily inventory reconciliation.
2-27
6093A
-------
~
New .ta~ks ,must meet improved tank design standards which are
speclf1:d ln the ordinance. New tank piping must have corrosion
pro~ectlon~ be able to withstand pressure testing, and be
equlpped wlth a monitoring system. Hazardous materials storage
tanks must meet more stringent design standards than oil and
gasoline storage tanks, which include secondary containment, as
well as install tion of manways, str iker plates, and over fill
protection. Petroleum product tanks in sensitive recharge and
water supply areas must also comply with- the more stringent,
nonpetroleum tank standards. An unusual feature of Suffolk
County's ordinance is that all new tank installations must be
inspected and certified by a county representative prior to
backfilling.
2.4.3
Regulatory Trends
In summary, local governments are actively involved in the
development and implementation of comprehensive UST programs.
These programs are highly var iable in terms of the required
technical standards for tank design and leak detection systems.
However, most local programs are more stringent and more
comprehensive (governing both oil and hazardous substances)
than their state counterparts.
For the most part, local governments with sensitive groundwater
resources have been most active in the development of
comprehensive UST programs. In many cases, more stringent
requirements are specified for tanks located in recharge areas
and in the vicinity of public water supplies.
Local UST acti vi ty has in many cases preceded the development
of comprehensive state programs. States recognize the
importance of local involvement. However, the large and growing
number of state and local governments involved in the
regulation of UST presents tank owners and operators with a
myriad of complex and conflicting compliance requirements.
2-28
6093A
-------
~
SECTION 3
TANK ASSESSMENT AND AUDITING TECHNIQUES
3.1
INTRODUCTION
EPA's policy is to encourage the use of environmental auditing
techniques by the regulated community to help achieve and
maintain compliance with environmental laws and regulations, as
well as to help identify and correct unregulated environmental
hazards.l
Environmental auditing can help to ensure compliance with
underground storage tank regulations. Even with active state
and local involvement, regulation of more than 1.2 million
tanks is a challenge that cannot be met adequately by
regulatory agency enforcement and inspection activities.
Environmental auditing can improve compliance by complementing
regulatory agency oversight activities.
Environmental auditing techniques typically evaluate the
effectiveness of direct compliance management activities. These
activities include obtaining permits and meeting their
requirements, installing monitoring systems, keeping records,
and reporting violations. Environmental auditing is used to
verify compliance with these environmental requirements, but
also to evaluate the effectiveness of management systems, or
assess risks associated with regulated and unregulated
activities.
As shown in Figure 3-1, for underground storage tanks, both the
tanks themselves and the monitoring and assessment systems can
be audited.
l"Environmental Auditing Policy Statement," U.S. EPA, 50 FR
46504, 8 November 1985.
3-1
6093A
-------
Auditing Techniques
. Records Review
. Interview Facility Operators
. Facility and Equipment Inspections
. Others
Tank Assessment and Management Systems
. Data Management Systems
. Tank System Evaluation
. Prevention Systems
. Release Reporting/Corrective Action
. Tank Closure
. Other
Underground Storage Tank
Systems
Figure 3-1.
Tank assessment and auditing techniques.
3-2
-------
~
3.2
STATUS OF UST AUDITING
Interviews with representatives from various industries and
government agencies subject to underground storage tank
regul~tions . indi?ate that development of UST auditing
techn~9ues. ~s S~~ll in the preliminary stages. The current
emphas~s 1S on ~nstallation of facilities and equipment and
establ1shm~nt of recordkeeping and management systems required
by regulat~ons. As would be expected, the petroleum industry is
a leader in this area.
For ex~mple, one major oil company has initiated a program of
replac~ng all tanks on each site that it owns or operates by
1990. Each newly installed tank system is to be equipped with
two observation wells in the tank backfill. Several major oil
companies are conducting integrity testing of all their tanks.
Tanks at these locations are being replaced with new tanks that
conform with the oil company specifications. Several oil
companies have actually conducted studies of various tank
systems, and developed engineering specifications for new
thicker-walled and specially-outfitted tanks based on the
results of these studies.
Many electr ic utili ties are currently inventorying their
collection of tanks in order to prepare tank notification forms
by 8 May 1988. At least two utilities interviewed have
initiated comprehensive tank testing programs to identify
existing and potential problems. The utility industry also
performs daily inventory reconciliation of the tanks it owns.
A finishes and formulation manufacturer is conducting precision
testing of all their tanks. An observation well is then to be
placed in each backfill area surrounding a tank following
integrity testing. If the well is clean, a second well is
drilled and will be equipped with an as of yet unspecified type
of continuous monitoring equipment. Problem tanks are being
retired and removed, and the extent of contamination is
assessed during removal and cleaned up.
A major electronics component manufacturer has prepared an
inventory of all tanks, and conducted field validation of the
data. Twenty-five abandoned tanks were removed prior to the 8
May 1986 notification deadline. Remaining in-service tanks are
managed using a computerized data base which holds information
on both UST-reportable and non-reportable tanks. The remaining
tanks will be tested, and replacement or retrofitting
priorities set based on the test results. This industry has
also developed audit checklists for underground storage tanks,
which are included as Attachment A.
3-3
6093A
-------
~
The Indu~try Clean Water Task Force (ICWTF) is a coalition of
:lec.tron1cs companies in Santa Clara County, Califor-nia which
1S 1nvolved in cleaning up sites with contaminated soils or
groundwater. The ICWTF is providing public information on
cleanup progress and working with regulatory agencies to
prevent future leaks. The UST-related activities of this group
have included:
.
Closure or removal of 60 percent
in-ground as a precautionary measure.
of
the
tanks
.
In tegr i ty testing of rema ining
with routine monitoring.
tanks,
in
conjunction
.
Installation of
existing tanks.
secondary
containment
systems
on
The Department of Defense established the Defense Environmental
Leadership Project in the Office of the Secretary of Defense in
January 1984. The Leadership Project is charged with developing
innovative solutions to long-term environmental problems,
including the UST issue. DOD has established procedures for
daily inventory reconciliation by operating personnel, with
monthly accounting performed by the Installation Fuels
Management officers. This monthly accounting process is a form
of audi ting. DOD standards also require routine visual
inspections of tanks, and pipeline and piping inspections at
specified intervals. In addition, periodic tank integrity
testing and checking of cathodic protection systems are
required.
The U. S. Air Force has developed an Env ironrnen tal Compl iance
and Management Program (ECAMP) manual. This manual is a guide
for conducting comprehensive environmental audits at Air Force
bases. The ECAMP Manual includes audi t procedures related to
UST. Specifically, the ECAMP manual addresses auditing of
cathodic protection mechanisms, inventory control, and UST
notification. In short, the DOD has taken a proactive approach
to UST compliance and is working closely with EPA to develop
innovative compliance strategies.
In this section, the various types of tank assessment and
management systems currently in use are briefly described.
Auditing techniques which can be used to evaluate each of these
systems are br iefly discussed. Audi ting techniques applicable
to the various tank assessment and management systems are
summarized in Table 3-1.
3-4
6093A
-------
Tatle 3-1
Summary of Auditing Procedures
Applicable to Tank AssessITient and Mani:.gement Systems
Auditing Procedures
Inquay Records Revie. Testlng Observet lor.
e:
C
UJ ....
.., UJ
UJ II: E
E .. QJ
;,; ... :. UJ -'
e: ..... UJ UJ >-
.. ~ "- e: .. e: >- ... e: e:
C 0" C It! 0 C IIJ ... 0 C
.., .. < e: :.; tr c.. .... C .... tr =
t: 0 -' " e: C: "'" e: ..... ..... e:
... >- .... U r .... c: U 0 ;:! u
~ ... -' ::> 0 -' CJ .... .= CJ .... t; ;.
-' 0 rc -' ~ ..... ..... ..... IIJ ..... v:
'- ..... u: CJ c c: CJ It! " CJ QJ 8 ......
Tank Assessment rc It! -' - u ~ QJ C .. II) C I-
and ... .... .... ~ e: 't: .Q E :r.
Management ~ ;:! E .x. c.. .x. .x. .. .x. .x. CJ ~
Systems ~ c: £ ..... .. rc v: e: It! u It! It! ItI e: .....
It! ~ ~ e: .., ... e: :E '" CI to;: .... .:;:
:I: :Z ,... I- :.; < I- 'J'.
Data ManaoelT'ent
S:isteJ1' X X X X X X X X
Tank System Evaluation
Manual Inventory
Control X X X X
Automatic Inventory
Control X X X X X X X X X X
Tank Testing X X X X X X X X
Slte Inspection X X X X X
Groundlolater Monitoring X X X X
External Monitoring X X X X
Secondary X X X X
Contalnment X X X X X X
Pipeline Leak
D~tectors X X X X X X X X Y. X
Prevention SvsteJ1'.s
Existing Tank Retrofit X
- Cathodlc Protection X X X X X
- Lining/Relining X X X X
- Mandatory Retlrement X X X
X X X X X
- Overf ill Protectlon X
Nelol Tanks
Deslgn X X X X
- Installation X X X X X
Overf ill Protection X X X X X X :-:
Release Reportinc/
Corrective hctlcr.
Release Repcrting X X X
Correctlve Action X X X X ~:
Tank Closure
Temporary X X X X X X
PerlT'.anent X X X
J,car.doned Tanks X X X
-------
3.3
DATA MANAGEMENT SYSTEMS
3.3.1
Description
The tank notification program established under RCRA requires
owner~ of in-service tanks to notify designated state or local
agencles of the age, size, type, location, and use of all tanks
by ~ May 1986. In addition, owners of tanks taken out-of-
serVice after 1 January 1974 must also provide notification to
the designated agencies.
'Many industries and agencies subject to the UST regulations own
or operate hundreds of tanks throughout the country. The
not i fica tion process forces tank owners to determine how many
tanks they have and where they are located. In addition, owners
are forced to face the fact that they are probably going to
have to meet different regulatory requirements in different
parts of the country.
As a result, some tank owners have established computerized
data management systems (DMS) to manage their tank programs.
For example, an electronics manufacturing operation stores data
on all tanks, includ ing septic tanks, fuel oil tanks, above-
ground tanks, and UST. Data stored in the DMS includes tank
location, use, size, type, interior/exterior protection, date
in service/out-of-service, and tank testing information. Both
UST-reportable and nonreportable tanks are included in the
system. The' DMS is used currently to drive the tank
not if ica t ion process, identi fy abandoned tank s wh ich will be
removed prior to the May 1986 'deadline (to avoid notification),
and identify tank retrofit/replacement requirements. In the
future, the DMS could be used as a trigger mechanism, to ensure
tanks are tested and replaced on schedule and in accordance
with regulatory requirements. This capability will be
particularly important because the manufacturer has tanks in
four states wi th widely var iable regulatory requirements. The
DMS is a corporate (as opposed to a plant-level) initiative,
due to t;he complexi ty of UST compl iance , and the mul timill ion
dollar cost of compliance.
A DMS may be much more simple and less comprehens i ve than the
one descr ibed previously and may consist of no more than tank
notification information. Other regulated entities may use a
DMS to ensure tank operating permits are obtained and renewed
in a timely manner.
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3.3.2
Audit Procedures
Au~it ,Procedures will vary in accordance with the scope and
Ob]ectlves of a company's DMS. In all cases, review of the data
to verify that it is accurate and kept up-to-date is a key
auditing technique.
A unique feature of a DMS is that it can actually be used to
drive the audit program. The auditor can use data from the DMS
~o locate tanks for inspection; determine (through interviews)
lf the tanks are tested in accordance with established
schedules and procedures indicated in the DMS; and verify that
new tanks are properly entered into the system.
3.4
TANK SYSTEM EVALUATION
3.4.1
Manual Inventory Control
Description
Instituting and correctly following a manual procedure for
inventory control is widely recognized as an important
component in the operation of an under-ground storage tank
system. Manual inventory control generally involves the
measuring of fuel stocks in a tank system at set intervals
using a gaug ing stick, obtaining readings from meter ing pumps
at the dispensers, and calculating any quantity of fuel that
was delivered to the tank system since the last inventory
measurements. All of these numbers (stock on hand, fuel
dispensed, and fuel delivered) are balanced against one another
to determine if any unexplained loss or addition is found. This
results in the calculation of the mass balance of fuel in the
tank over a specific interval. Measurable losses or additions
are usually attributed to one or more factors including:
.
.
.
.
.
Tank or pipe leak.
Short or over delivery of fuel.
Theft.
Calibration problems in metering pumps.
Human error in measurement and arithmetic
operations.
Reconciliation calculatio]1s should be recorded in a permanent
form; these records should be maintained for some set period of
time.
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Audit Procedures
Ad' .
,u 1t1ng of manual inventory control systems would usually
7nclud: sev~ral steps performed dur ing a si te inspection. An
7nterv1ew W1 th the tank owner/operator will serve to discover
1f ,such a system is in place and is followed on a regular
bas1s., ~ll, records on-site pertaining to the inventory
reconc1l1at1on should be examined to verify the completeness
and ~re<;Iuency of the system's operation. Any discrepancy that
may lnd1cate a tank system problem should be noted. Interviews
should be used to ver ify that corrective action or investiga-
tion has been taken or made.
3.4.2
Automatic Inventory Control
Description
This type of system usually involves the installation of a set
of equipment mounted both inside of and external to a tank
system for the purpose of taking either periodic or continuous
measurements of the volume of fuel in an underground storage
tank system. The automatic system eliminates some of the human
error associated with manual inventory control such as
measurement and ar i thmetic errors. It also produces more data
points during day-to-day operation than manual tank gauging
and, therefore, may more clearly point out trends that might be
indicative of a problem. The major disadvantages include
cons iderable costs assoc iated wi th purchase, installation, and
maintenance.
The automatic inventory control systems determine the mass
balance of the UST system in which it is installed. Some of the
devices on the market have built-in microprocessors that
reconcile the inventory and produce a printed report, while
others have computer communication to a remote station where
inventory reconciliation takes place.
Audit Procedures
Audit procedures for on-site controlled versus remote computer
controlled automatic inventory control devices differ in that
the on-site controlled device? include a site inspection. This
is necessary to ascertain the operating status of the device.
Dur ing the site visit, the pr inted records should be examined
to determine if inventory discrepancies have been investigated
and corrective action has been taken, if necessary. Remotely
controlled devices directed from a central control area enables
a number of sites to be audited quite ea~ly. The audit should
determine if any necessary corrective action was taken in
response to problems.
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3.4.3
Internal Tank Testing Methods
Description
The precision or final test is specified by NFPA as the method
for tank testing and is defined in NFPA 329 as a test that is
designed to determine if either parts or the entire tank system
are tight. NFPA requires these tests to detect a leak of >0.05
gal/hr or 1.2 gal/day, while taking a number of critical-test
parameters, such as temperature, condensation, and tank-end
deflection into account. To perform the test, the tank system
must be taken out of service for a period of not less than four
hours. This method is not used as a leak detection method since
it is too costly to perform regularly~ Between testing, a long
interval with even a small leak could release a considerable
quantity of fuel into the environment surrounding the site.
Therefore, tank testing is used to confirm a suspected tank
system problem. It is necessary to have a trained operator
conduct the test because of its complexity.
Evaluations of internal tank testing methods are currently
undergoing extensive field evaluation studies by an EPA
contractor. These studies will address the performance of
various systems under a number of field conditions and will
look at improvements that might be made to some of these
systems. The results of these studies should be available by
mid-1986.
Audit Procedures
The major consideration in the successful performance of the
NFPA precision test is the skill of the operator conducting it.
Therefore, determining if the test operator has had the correct
training is paramount. This could be done by interview and
observation of the operator during a test.
A clearer picture of alternative internal testing techniques
may emerge after the above mentioned report is issued. A
further evaluation of audit procedures for these devices would
be premature at this time.
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3.4.4
Site Inspection
Description
A simple and easy but important method for the detection of
some UST leaks involves walking the site using trained eyes and
other senses to detect changes on the site that could be due to
a leak. Some observations that may lead to the conclusion that
a leak exists include the detection of a strong odor, the
presence of surface stains, stressed vegetation, or physical
evidence of vandalism. Any of these observations should be
noted in an inspection log. Any action taken in response to
these conditions should also be noted.
Audit Procedures
Audi t procedures for this technique involve interviewing the
personnel charged with conducting site inspections to determine
if useful observations are being made on a regular basis. In
addition, the site should be walked to confirm that no
pertinent indications of a leak have been overlooked.
3.4.5
Groundwater Monitoring
Description
Groundwater moni tor ing involves examining the groundwater that
is found in or around a specific location for any material that
degrades the quality of that water. Evaluations of groundwater
usually include chemical analyses, determining physical
parameters such as depth and flow direction, and aestheti~
qualities such as smell, taste, and color. This type of
investigation includes only those methods that examine the
water at or below the groundwater surface.
This type of UST monitoring is required by only a few states.
In addi tion, EPA seems reluctant to encourage this method of
tank monitor ing due to problems wi th determining the presence
of fuels in groundwater. The construction of wells is both
complex and costly and, if the groundwater table is deep, a
considerable quantity of fuel could be released from a UST
before it could be detected in the groundwater.
The results of a groundwater monitoring program usually include
both qualitative and quantitative data about the presence or
absence of contaminants of interest.
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Audit Procedures
In almost every state, a well drilling permit is required
before a well can be installed. This permit should be examined
and compared with conditions on-site to determine if the
location and number of wells indicated is correct. The wells
should then be examined to see if the locking caps are in
place, the surface grout seal is intact, and the casing appears
straight. Interviews should then be conducted with personnel
who are responsible for the well sampling to determine what
procedures are followed. A check of the records should be
conducted to determine sampling frequency - A data review to
ascertain if any problems have been noticed and appropriate
response to them will complete the audit of the site.
3.4.6
External Monitoring of Tanks
External tank monitoring is a method to rapidly detect a
release of stored fuel into the immediate environment
surrounding a UST system. The basic devices used in this type
of UST monitoring is the observation well. Devices in this
category include groundwater monitor wells, vapor wells,
U-tubes, or lysimeters. Proper installation of these devices in
the tank backfill is cr itical to the success of their opera-
tion. Problems are usually encountered when trying to install
these in existing sites. Drilling clearances in the tank
backfill can pose a serious safety hazard and the alternative,
placing the wells away from the tank, will lessen the
possibility that a leak can be detected.
Each of these types of observation wells can be outfitted with
an array of detection sensors such as grab samplers, electrical
sensors, or chemical sensors. These sensors can be used to
periodically monitor for petrole~m hydrocarbons. In some cases,
sensors that monitor continuously can be installed. This is
usually required in an environmentally sensitive area. It is
worth noting that many of the sensors currently on the market
have had limited field testing and are, therefore, basically
unproven. EPA is currently conducting evaluations of each type
of device or sensor at their research laboratory in Las Vegas.
A report on the relative performance of each device should be
available by the fourth quarter of 1986.
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Audit Procedures
If this type of device is installed around an underground
~torag7 tank, the auditor must conduct a site inspection and
lntervlew. to determine if the system is in-place and being
used. A check of the maintenance and sampling log will ver ify
the frequency of operation and will allow a review of the
monitoring data to determine if corrective action has been
taken as needed.
3.4.7
Secondary Containment Monitoring
Description
There are three basic methods by which a secondary containment
system can be incorporated into a UST system. They are:
.
.
.
Double-wall tank.
Containment liner.
Vaulted tank.
The major advantage of these systems is the high level of
protection against release of fuel that they afford. Besides
providing two barriers that would have to be breeched to
release fuel to the environment, there is usually a space
between these walls or barriers known as the annular space that
can be monitored either continuously or periodically. This will
alert the operator if a problem exists in the tank system.
There are a number of disadvantages
These include:
to secondary containment.
.
Cost It is two to five times more
install secondary containment than
protected single wall tank.
expensive to
a corrosion
.
Installation problems Liners
difficult to install correctly-
and
vaults
are
In cr i tical areas, such as areas where the release of fuel
would have a deleter ious effect on a large number of people,
the use of secondary containment is clearly warranted and
monitoring of the annular space is necessary. The methods used
to moni tor the annular space fall into a number of categor ies
including:
Visual and olfactory inspection of vaults.
.
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.
Vacuum pressure gauges to monitor a vacuum pulled on
the annular space in a double-wall tank.
.
Various
placed
liners.
electrical or
in the annular
chemically
space of
activated sensors
tanks, vaults, or
Audit Procedures
Audit procedures will vary according to the type of method used
to monitor the annular space. A site inspection, an examination
of the inspection log, as well as an interview with the on-site
personnel who are charged with makinq the inspections are
required audit procedures. An examination of any instrumen-
tation used for monitoring is also required. The auditor should
also determine if any investigation or corrective action has
been taken when warranted.
3.4.8
Pipeline Leak Detectors
Description
Recently developed statistical analyses of leaking tanks have
shown that pipeline leaks are responsible for about 50 percent
of all tank system leaks. Leaks in pressure piping can largely
be eliminated by the use of pipeline leak detectors, as long as
they are operating properly. Pipeline leak detectors have an
internal hydraulic circuit which tests the delivery line for a
drop in pressure each time the line is used. If the line
pressure has dropped, the detector will shut off product flow.
This detector action is automatic and requires no decision on
the part of the tank system owner/operator.
Some systems utilize suction pumps to dispense fuel. In these
cases, the use of a check valve on the line is indicated. If a
leak is present, it will be demonstrated by a loss of prime in
the line which will result in either a delay of the arrival of
fuel at the nozzle or no fuel at all.
Audit Procedures
Check valves and pipeline leak detectors are routinely
installed on UST systems~ Unfortunately, their function can be
abridged by tampering with the mechanism. During an audit, the
pipeline leak detectors should be inspected to determine if the
tamper seal is undamaged. An interview with the UST system
owner/operators should be conducted to see if reduced or
low-flow conditions that might be the result of a pipeline leak
have been noticed and appropriate corrective actions have been
initiated.
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.........
3.5
PREVENTION SYSTEMS
3.5.1
Existing Tanks
3.5.1.1
Cathodic Protection System Retrofit of Steel Tanks
Description
A cathodic protection system reduces or eliminates corrosion of
metallic tanks by inducing electrical current in the soil
(impressed current system) or creating a current reversal
(sacrificial anode or galvanic system). Cathodic protection
systems can be retrofit on existing tanks. The systems are
pre-engineered and must be installed in accordance with
manufacturers' standards.
Two types of cathodic protection are commonly used, galvanic
and impressed cur rent. Both types can be retrofit to existing
tanks. Galvanic cathodic protection employs sacr ificial anodes
composed of mater ia1s such as magnesium or zinc in electr ical
contact with the object to be protected. They protect by
creating a current at the physical expense of the sacrificial
anode. Systems using this type of anode must be correctly
designed to operate adequately. Measurements of soil
resistivity and the life expectancy of the system must be known
in order to determine the type and size of the anodes required.
Impressed current cathodic protection employes direct current
provided by an external source. This current is passed through
the sys ;"em by the use of non-sacr if icia1 electrodes typically
made of materials like carbon or platinum. These electrodes are
buried on the site and connected to the positive terminal of a
power supply. The tanks are connected to the negative side of
the same power supply. The current generated protects the tanks
from corrosion.
Of the two types, the impressed current system is the easiest
to retrofit. Both systems do require per iodic examination and
maintenance to maintain protection levels. The impressed
current cathodic protection is the easiest to inspect, but
major disadvantages include a high power consumption and the
possibility of electrical interference with foreign structures
such as nearby tanks. Determining if a galvanic system is
working is harder. Tank-to-soil electrical potentials should be
measured on an annual basis. Site changes, such as the
"installation of a new water pipe may also upset the sjstem.
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Despi te these problems, cathodic protection is a widely used
~ethod of. prot.ection for tanks and piping. In ma-ny cases, its
lnsta~latlon lnto an existing tank system, which has not
deterlorated too badly, can effectively extend life time.
Audit Procedures
Audit procedures
include:
applicable
to
cathodic
protection
systems
.
Verify that the system was inspected and tested prior
to backfilling.
.
Verify that the system is periodically
maintained while in operation. Records
should be reviewed to verify voltage does
recommended limits.
tested and
of testing
not exceed
.
Inspect the system to detect
Ver ify that the power supply
system) and swi tches are secured
unauthorized disconnection.
signs of tampering.
(impressed current
from tamper ing and
3.5.1.2
Tank Lining and Relining Technology
Description
Repairing an underground storage tank usually costs
considerably less than replacing it. One such method of repair
involves 'the lining of the interior of a prepared tank with a
plastic resin mater ial such as epoxies or polyester resins. A
limited amount of historical information as to the effective-
ness of such a method of tank repair is available. A number of
linings installed in the 1970's failed, probably due to
material incompatibilities with the stored fuel. As a result of
this problem, manufacturers have upgraded the formulation of
the lining material and have developed stringent guidelines for
the application of such materials. There have been no reported
failures of the new formulations applied in the approved manner.
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~he performance of the application is still the limiting factor
ln the success of such repairs. In addition, any newly blended
fuels must be compatible with the lining material. Also, the
outer shell of the tank must be sound, since it provides
structural integrity to hold the liner in place.
Audit Procedures
Tank lining audit procedures should include interviews with
lining manufacturers to determine if the material to be used
has been properly tested for compatibility. Additional site
inspections should be made and interviews conducted with
installers to determine if they are using installation
procedures that comply with the manufacturers' recommendations~
3.5.1.3
Mandatory Retirement
Description
Some state and local programs or corporate policies require
existing tanks to be replaced before a certain age, whether
they are leaking or not. However, some agencies contend that a
leak detection program can achieve basically the same result.
Audit Procedures
Audi t procedures must be tailored to state and local
requirements. The basic auditing technique would consist of
reviewing tank notification forms to determine the approximate
tank age, compar ing the tank age to mandated retirement age,
and verifying through interviews that the tanks have indeed
been retired. Tank retirement should be accompl ished in
accordance with tank replacement and closure requirements
contained in state or local regulations.
3.5.1.4
Overfill Protection Retrofit
Description
Certain states require existing
overfill protection systems.
tanks
to
be
retrofit
with
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Overfill protection devices
systems, automatic shut-off
which monitor tank levels.
include
devices,
aud ible or vis ible alarm
and liquid level sensors
Spill containment systems are another common approach to
Gverfill protection. The fill pipe is placed in a manhole below
the surface into which the product drains. Spilled product may
be removed by the use of "imbiber beads" which allow water to
pass, but absorb hydrocarbons and swell. When they reach
capacity, they completely seal the manhole. At this time, they
must be replaced and disposed of as a hazardous waste. Other
containment systems drain into the tank.
Audit Procedures
Obv iously, aud i ting techniques for overfill protection
must be tailored to state and local requirements and
type of method employed at a given location. Some
auditing techniques which may be applicable include:
devices
to the
generic
.
Verify overfill protection system is
accordance with applicable regulations.
installed
in
.
Verify tank operator is familiar with good operating
practices (e.g., tank measurement prior to unloading,
continuous monitoring of unloading, careful
connection/disconnection of hose).
.
Ver ify overfill protection
tested (interview operators
standards) .
devices are regularly
and check calibration
.
Verify spill containment system is properly maintained
(inspect system and interview operator) .
If practical, observe tank filling procedure to ensure
good operating practices are followed.
.
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3.5.2
New Tanks
3.5.2.1
Design Standards
Description
Section 9003(g) of RCRA contains an interim prohibition on the
installation of new steel tanks, which took effect 7 May 1985.
Sometimes referred to as "the bare steel tank ban,"
installation of new tanks is prohibited unless the tank: will
prevent releases due to corrosion or structural failure for its
operational life; is cathodically protected or constructed of
noncorrosive material, steel coated with a noncorrosive
material, or designed to prevent release," and is made of
material compatible with its contents.
Many states and local governments are including design
standards for new tanks in their comprehensive UST regulatory
programs. These standards generally require improved tank
des igns (e. g., f iberglas reinforced plastic (FRP) tanks, steel
tanks with FRP coatings or cathodic protection, or noncorrosive
tanks), and selection of tanks which are compatible with
product stored and the surrounding environment. Similar design
standards for underground piping are also specified. Design
requirements also encompass proper sizing and siting of storage
tanks and dispensers.
In addition, some states require secondary containment,
as installation of leak detection systems, striker
overfill protection, or groundwater monitoring
Stenciling and marking of tanks is also required in
cases. The des ign standards governing these i terns vary
from state to state.
as well
plates,
wells.
a few
widely
An unusual approach to regulating new tank design is employed
by the State of Kansas. Instead of focusing on design standards
for tank systems, the Kansas regulations focus on lining the
tank excavation with an impervious material sloped to a
collection basin equipped with an observation pipe.
State approaches to enforcement of design standards also vary
widely. Some states require submittal of detailed plans for
review and approval pr ior to construction. A few states have
established permit requirements for new tanks. In a few cases,
states have established detailed design standards which will be
subject to inspection and enforcement actions.
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Audit Procedures
A~diting techniques applicable to new tank design standards
wlll have to be tailored to state and local requirements.
General approaches to aUditing could encompass:
.
Review of the overall procurement practices employed
by a company to ensure:
Purchas ing department
design requirements.
is familiar with new tank
Environmental department is involved
and/or review of new tank specs to
are compatible with material
environmental conditions.
in selection
ensure tanks
stored and
Compa~y policy governing tank procurement
addresses safety and environmental concerns.
.
Review of
applicable)
obtained.
tank permit or registration (where
to ensure appropr iate approvals have been
.
Interviews with facility personnel to establish their
familiarity with state and local requirements.
.
Spot checking of as-built drawings to verify
compliance with design requirements. At a minimum, the
location and type of system components could be
verified using these drawings.
Development of guidance manuals and training
to state and local requirements will be a
encouraging compliance with the various
standards.
programs tailored
prerequisite for
new tank design
3.5.2.2
Installation Procedures
Description
Poor installation practices, including abrasion and deflection
caused by crossed lines, improper material handling,
incompatible pipe fittings, improper connections, poor tank
siting or placement, and poor workmanship, have resulted in
leaks and failures in numerous tank and piping systems. As a
resul t, the importance of ensur ing proper installation cannot
be ignored during development of an overall compliance strategy.
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~ost state and ~ocal programs require new tanks to be installed
ln accordance wlth NFPA 30 and API standards and in accordance
with t~nk manufacturer~' specifications. The tank owner is
responslble for selectlng qualified installation contractors
and ensuring proper tank installation.
Even if a tank has been designed in accordance with established
des~g~ standards, proper installation encompasses a variety of
addlt~onal factors. These factors include proper material
handllng to prevent damage to tank shells and coatings;
adequate excavation size, bedding, and site preparation; proper
backfilling to provide structural support and protect
structural integrity; proper anchorage; proper installation of
containment and external monitoring systems; and proper
installation of piping, valves, and fittings. In addition, tank
and piping tightness testing is often required prior to
operation. However, at least one state (Connecticut) requires
tank testing within one to two years of installation, after the
tank is put in operation. Leak detection and cathodic
protection systems should also be tested prior to operation.
Audit Procedures
Effective auditing of installation procedures can only be
accomplished in conjunction with evaluations of the adequacy of
tank design, procurement practices, and contractor selection.
In fact, auditing of installation procedures would best be
accomplished during construction ra-ther than "after-the-fact. II
A certification program for tank installers has been considered
by both state and federal regulatory agencies, but does not
currently exist. Such a certification program would provide
tank owners wi th some assurance that competent, well-trained
personnel are installing their tanks. If a tank installer
certif ication program is established, it could be audited by
reviewing records and conducting interviews to verify that only
installers with up-to-date certifications are used. "An instal-
lers certification program would reduce the incidence of leaks
attributable to poor workmanship and improper installation
techniques.
Several states (e. g., Connecticut) require tank installer s to
cerfify that tanks have been installed in accordance with
approved plans. In this case, audit~ng is accomplished by
verifying certification has been submltted to the state and
that a copy is kept on file. If the state or regulatory agency
inspects" and certifies compliance with insta~lation .r:qui~e-
ments (as in Suffolk County, New York), thlS certlflcatlon
should also be verified and reviewed.
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Another method of aUditing tank installation would be to
request and review copies of final test results for tank and
piping tightness, satisfactory operation of leak detection and
monitoring systems, and cathodic protection systems (if
installed). This testing should be per formed only by proper ly
trained and certified personnel.
Finally, an audit should verify that the installer provided the
tank owner with component documentation, including installation
instructions for replacement parts, recommended test
procedures, preventative maintenance schedules, and operational
requirements. Compliance with these requirements should also be
evaluated during the audit.
3.5.2.3
Overfill Protection
Description
Spills dur ing product del i very may result f rom over filling of
tanks or from the product transfer connection between the tank
and the truck. Transfer connections may not be regulated by
RCRA because the hose is part of the truck rather than the
tank. Overfilling can lead to two problems: environmental
contamination and creation of corrosive conditions in soil
surrounding the tank which may damage tank coatings.
Overfill protection devices include audible or visible alarm
systems, automatic shut-off devices, and liquid level sensors
which moni tor tank levels. Some states and local governments
have established design and operational standards for transfer
fac il i ties (such as truck f ill stands) and unloading/loading
facili ties. The pr imary means of preventing spills from
transfer connections involves the use of "dry-disconnect"
couplings. The coupling is equipped with a spring-loaded valve
which is opened after it is connected to a fill pipe and closed
prior to disconnect. This device is larger and heavier than the
more commonly-used "quick-disconnect" hose, making it more
difficult to use.
Spill containment systems are a common approach to overfill
protection. The fill pipe is placed in a manhole below the
surface into which the product drains. Spilled product may be
removed by the use of n imbiber beads n which allow water to
pass, but absorb hydrocarbons and swell. When they reach
capacity, they completely seal the manhole. At this time, they
must be replaced and disposed of as a hazardous waste. Other
containment systems drain into the tank.
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New ,underground, tank regulations generally require tank
overflll ~rotectlon. However, most regulations do not spell out
how overflll protection is to be achieved.
Audit Procedures
Obviously, ~uditing techniques for overfill protection
must be tallored to state and local requirements and
type of method employed at a given location. Some
auditing techniques which may be applicable include:
3.6
3.6.1
devices
to the
generic
.
Verify overfill protection system is
accordance with applicable regulations.
Verify tank operator is familiar with good operating
practices (e.g., tank measurement prior to unloading,
continuous. monitoring of unloading, careful
connection/disconnection of hose).
installed
in
.
.
Ver ify overfill protection
tested (interview operators
standards) .
devices are regular ly
and check calibration
.
Verify spill containment system is properly maintained
(inspect system and interview operator) .
.
If practical, observe tank filling procedure to ensure
good operating practices are followed.
RELEASE REPORTING AND CORRECTIVE ACTION
Release Reporting
Description
Section 9003 (a) (C) (3) of RCRA requires EPA to establish
requirements for reporting of releases and corrective actions
taken. The term "release" is broadly defined to include "any
spilling, leaking, emitting, discharging, escaping, leaching,
or disposing from an underground storage tank." Releases to air
are not included. EPA has yet to define at what level releases
will have to be reported and who will have to be notified.
Most state UST programs require suspected leaks to be verified
and reported to appropriate authorities within a specified time
frame. In some cases, written status reports are also required.
6093A
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-
Spil~ response and ~ontingency plans are not specifically
requIred under Subtltle I. Contingency plans for larger
underg round storage tanks (over 42,000 gallons) are requ ired
pursuant to the Federal Water Pollution Control Act Amendments
of 1972 and are governed by regulations contained in 40 CFR 112.
Audit Procedures
To ver ify compliance with release reporting
following auditing techniques could be used:
requirements,
the
.
Interview facility owners and operators to determine
whether they have established procedures for verifying
leaks and notifying appropriate authorities as
required by state and local regulations.
.
Verify that the list
numbers of authorities
reviewed and updated.
containing names and phone
to be notified is routinely
.
Determine if records (e.g., leak detection system
records) containing time, date, and details of any
reportable incident are kept. Review records and
determine that proper notifications were made.
3.6.2
Corrective Action
Description
Subtitle I of RCRA does not define the
action." Thus, EPA will have broad latitude
corrective action will mean.
term "corrective
in defining what
Basically, implementation of corrective action involves two
steps. First, tank operators have responsibility to make an
acceptable response, such as removing remaining product from a
tank to prevent additional leakage. In addition, appropr iate
actions should be taken to immediately respond to spills that
may occur on a site or to contain a spill. The second step
involves defining the extent of contamination, potential
migration pathways and conducting a risk assessment. This
information is used to define remedial action requirements. If
the risk is significant, a remedial action plan will have to be
developed and implemented.
3-23
6093A
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~
State regulations vary with regard to their requirements for
corrective action. Some states, such as New Hampshire, allow a
tank to be repaired with a liner only once. In most states,
repairs must be performed according to manufacturer's
specifications and under the guidance of trained personnel.
Tank testing is required prior to reuse. In states with
mandatory retirement provisions or "retrofit to new tank
standards" requirements, repair of leaking tanks may not be
practical. Obviously, auditing techniques and protocols would
have to be tailored to state and local requirements.
Audit Procedures
To verify compliance with corrective action requirements,
following auditing techniques could be used:
the
.
Verify that a spill response kit is available and that
it is properly stocked.
.
Verify operators have been properly trained to respond
to emergencies and spills.
Verify the facility has established specific
procedures for responding to spills and accidents. (An
emergency response plan is not required by Subtitle I
of RCRA. However, an audit should also address good
management practices such as emergency procedures.)
.
.
Rev iew records of inc idents. Ver ify that appropr ia te
corrective actions are taken in a timely manner.
3-24
6093A
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~
3.7
TANK CLOSURE
3.7.1
Temporary Closure
Description
Temporary closure requirements vary among state and local UST
programs. The defini tion of temporary closure ranges from 180
days or less in Rhode Island, to two years or less in Suffolk
County, New York.
Most states require tanks to be emptied, and fill lines and
other openings to be capped and secured. In some cases, such as
Suffolk County, tightness testing is required prior to reuse.
In Florida, product may be left in the tank if weekly inventory
control, monthly leak detection, and monitoring system
evaluations are continued. Flor ida also requires monthly
inspections of empty tanks.
Audit Procedures
Audit procedures for temporary closures include:
.
Verify that proper notifications
authority have been made.
of
state
or
local
.
Conduct interviews and records
required monitoring is performed.
review
to
verify
.
Inspect tanks to verify that the tanks are empty and
access is controlled (locks are secured).
.
Conduct interviews to verify that the period
closure has not exceeded the required time frame.
of
3.7.2
Permanent Closure
Description
Most state and local programs permit both on-site closure and
removal of tanks. On-site closure typically consists of
removing remaining product, cutting fill lines, and filling the
tank with an inert material. However, some states have
addi tional requirements. Rhode Island requires empty tanks to
be cleaned and precision tested if they are to remain in the
ground. California requires tank owners to demonstrate that no
release has occurred.
3-25
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~
The pr?cess for removin~ a tank typically involves removing
rem~lnln~ produ~t, purglng vapors, ~nd puncturing the tank.
Callfornla requlr~s documentation of the method of disposal.
Rhode Island requlres tank owners to notify the state 72 hours
in advance of excavation so the site may be inspected for the
presence of pollutants. Rhode Island also requires that a
certificate of closure be obtained.
Audit Procedures
Audit procedures for permanent closure include:
.
Verify that proper notifications have been made. (The
RCRA notification requirement pertains to tanks taken
out of service after 1 January 1973.)
.
Ver ify that the appropr iate state or local approvals
have been obtained prior to closure.
.
When appropriate, verify that a certificate of closure
has been obtained.
.
Inspect site to determine if there is any evidence of
improper or inadequate closure practices.
3.7.3
Abandoned Tanks
Description
An abandoned tank is one taken out of service prior to 8
November 1974 which remains in the ground. Tanks which have
been abandoned wi thout proper closure have the potential for
deteriorating and leaking into the ground. EPA has yet to
determine whether or not to include abandoned tanks in the UST
regulations.
EPA has two options. First, abandoned tanks could be subjected
to the same closure and corrective action requirements as
operational tanks. The other option would be to limit the UST
regulations to operational tanks.
Some states, such as Rhode Island, prohibit
tanks. Other states do not address this issue.
abandonment
of
3-26
6093A
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\.J.A.; oj )U~-,
'-.....
Audit Procedures
At a minimum, the audit should verify that proper notifications
have been filed in accordance with Section 9002(a) of RCRA.
RCRA requires that notification be filed by 8 May 1985 for all
tanks taken out of service since 1 January 1973.
Informa t ion on the tank not i fica t ion forms can be used as the
bas is for the aud it. Interv iews and site inspect ions should be
conducted to determine if tanks have been proper 1y closed and
to identify any signs of leakage.
3-27
6093A
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ATTACHMENT A
SAMPLE AUDIT CHECK LISTS
FOR UNDERGROUND STORAGE TANKS
6093A
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.......
Facility I Compliance Category I Auditor(s) \ Date
ANSWER
Based On:
REGULATORY AUDIT AUDITOR
REaUIREMENTS aUESTIONS c COMMENTS
~ ,g
Yes No N/A .. i
'5 ~
0' ...
.5 "
.a
0
1. A master list of all above- 8 Does the facility have a
ground and underground stor- master list of all above-
age tanks should be main- . ground and underground stor-
tained at each facility age tanks?
(good management practice).
8 Does the master list contain
information on:
- Tank capacity?
- Tank construction material
and type of internal/exter-
nal protection?
- Tank age?
- Dates of integrity testing?
- Dates of service/repairs?
- I~ak detection systems in
place?
8 Is a map available that shows
the location of all tanks and
piping? (The auditor should
use this map for reference
during the audit.)
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N
Facility I Compliance Category , Auditor(s) 1 Date
ANSWER
REGULATORY Based On:
AUDIT AUDITOR
REQUIREMENTS QUESTIONS g COMMENTS
Yes No N/A ~ .. i
'5 i
CT ...
.: SJ
0
.
2. Facilities with underground 8 Was EPA Form 7530-1 "Notifi-
storage tanks for hazardous fication for Underground Stor-
substances or petroleum age Tank in Use" or state form
products are subject to prepared and submitted to the
notification requirements designated state or agency by
(40 CFR 280). May 8, 1986?
(OOTE: Heating oil tanks, 8 Are copies of the notification
septic tanks, and certain forms maintained at the plant?
other tanks are exempt
from notification require- 8 Is the information on the noti
ments. Refer to definition fication forms the same as
of UST.) that on the facility's master
list of tanks?
8 Record any inconsistencies.
3. Facilities with underground 8 Have any underqround tanks
tanks taken out of operation been taken out of service
after Jan. 1, 1974, but stil] since Jan. 1, 1974?
in the ground should provide still
notification to the state by 8 Are any abandoned tanks
May 1986. Notification should in the ground?
include known information on:
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w
Facility I Compliance Category 1 Auditor(s) T Date
-
ANSWER
REGULA TORY Based On:
AUDIT AUDITOR
REQUIREMENTS QUESTIONS g COMMENTS
~ :;:
Yes No N/A .. i
-:i ~
CT ...
.: .s
0
3. (continued) . If so, has EPA Form 7530-2,
- Date of deactivation; "Notification for Underground
- Substances in the tank; Storage Tank No Longer in
- Tank size and type; Operation," or state form heen .'
- Location of tanks ( 4 0 CFR suhmitted to the designated
280) state agency?
4. Facilities that bting under- . Are there any plans to install
ground storage tanks into a new underground tank at the
use after May 8, 1986 ITUst, plant?
within 30 days of bringing
such tanks into use, notify . If so, is there a formal pro-
designated state or local, cedure to ensure that notifi-
agencies (40 CFR 280.3(c». cation (registration) of new
underground tiIDks will be made
to the state within 30 days
of hringing the tank into use?
. EPA Form 7530-1, "f\btification
for Underground Storage Tank
in Use," or state form should
he used for this purpose.
~,- _.~ " .~~, -, _. -
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Facility
I Compliance Category
I Auditor(s)
REGULATORY
REQUIREMENTS
5.
Facilities may not install
any new underground tank un-
less it has been cathodical-
ly protected or designed to
prevent any release (RCRA
Sect. 9004).
:r
~
(NOTE: This provision known
as the "bare steel tank"
prohibition will remain in
effect until EPA issues per-
formance standards for new
underground tanks (scheduled
for Feb. 1987).)
6.
Inventory control procedures
should be in place for all
undergro1tnd storage tanks
/ .
(good management practIce).
(NOTE: '!he 1984 RCRA Amend-
ments require EPA to issue
leak detection, prevention,
and corrective action regu-
lations by Feb. 1987.)
AUDIT
QUESTIONS
Yes No N/A
. Have all new steel underground
tanks installed after May 1985
been:
- Cathodically protected?
- Constructed of non-corrosive
material (e.g., fiberglas)?
- Clad with a non-corrosive
material?
OR
=-Designed to prevent release?
. Are inventory and use records
kept for all UST?
.
Does the facility:
- Measure tank levels with a
gauging stick on a daily
basis?
- Obtain readings from meters
at dispensers?
- Calculate quantity of mater-
ial delivered to the tank?
ANSWER
Based On:
~
":i
go
E
, Date
.
J
j
o
AUDITOR
COMMENTS
i
I-
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U1
Facility I Compliance Category 1 Auditor(s) 1 Date
ANSWER
Based 0":
REGULATORY AUDIT AUDITOR
REQUIREMENTS QUESTIONS g COMMENTS
~ :::I
Yes No N/A "' i
'S j
.,. ~
.=
0
6. (continued) - Balance these numbers
against each other to iden-
tify unexplained losses or
additions?
8 Are calculations recorded in
a permanent log?
8 Review inventory control rec-
ords to verify completeness
and frequency of operation.
8 Are any discrepancies noted?
8 If so, have follow-up inves-
tigations been made?
(NOTE: Pressure testing with
air or other gases to detect
tank leaks is not recommended
because of severe danger of
tank rupture.)
.
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0'1
I Compliance Category ,
F acUity -1 Auditor(s) -' Date
.- ..-
ANSWER
REGULA TORY AUDIT Based On:
AUDITOR
REQUIREMENTS QUESTIONS ~ COMMENTS
Yes No N/A ~ " 'I
'S ~
IT ., .....
.: III
.a
0
6. (continued) 8 Have releases been reported to
state and EPA?
8 Have corrective actions been
taken?
(NOTE: NFPA 329 provides add i-
tional guidance on UST leakage)
7. Underground metallic storage 8 Does the facility have an un-
tanks and pipings with cath- derground metatlic storage tan
odic protection must be rou- with cathodic protection? If
tinely tested (good manage- not, go to Item 8.
ment practice).
8 For impressed current systems:
- Is voltage checked monthly
and recorded in a log?
- Do records indicate the
voltage is greater than
-0.85, but not more than
-3.0 volts?
8 For sacrificial anode system:
- Is the voltage checked bi-
annually?
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-J
Facility I Compliance Category I Auditor(s) 'Date
ANSWER
REGULATORY Based On:
AUDIT AUDITOR
REQUIREMENTS QUESTIONS I COMMENTS
Yes No N/A ~ .. i
"5 j
0" ...
.:
0
7. (continued) - Do records indicate the
voltage is greater than
- 0.85, but not mre than
-3.0 volts?
. Are failures and leak de-
tection reported?
8. Regular inspections of UST . Inspect underground storage
should be conducted (good tank sites.
management practice).
. Is there evidence of potential
leakage, such as:
- Strong odors?
- Presence of surface stains?
- Presence of stressed vegeta-
tion?
- Presence of liquids in secon
dary containment system (if
" applicahle)?
- Evidence of spills (satura-
ted and darkened soil,
stained concrete, soft spots
in asphalt)?
- Damaged fill pipes?
,--" ," -- ,,,.. "-, -" --""'- '----""'-_¥ --......,~
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:r
co
F acUity I Compliance Category 1 Auditor(s) 1 Date
ANSWER
Based 0":
REGULATORY AUDIT AUDITOR
REQUIREMENTS QUESTIONS ~ j COMMENTS
Yes No N/A ca i
.:i ~
C7 ....
= III
.0
0
8. (continued) - Evidence of flammable or
combustible liquids in
streams and bodies of water
(oil sheen)?
- Excavations that may have
damaged US~ or indicate re-
pairs?
8 Are there signs of vandalism
or tampering with:
- Leak detection systems?
- Valves or access ports?
- Alarms?
- Overfill protection devices?
- Monitoring wells?
8 Are inspection Jogs kept?
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:r
'I)
Facility I Compliance Category , Audltor(s) 1 Date
ANSWER
Based On:
REGULATORY AUDIT AUDITOR
REQUIREMENTS QUESTIONS c COMMENTS
~ ,2
Yes No N/A ;; i
'5 t
CT ...
.: ..
.a
0
8. (continued) . Does the facility have a leak
detectjon system in place? If
so:
- Is the system routinely cal-
ibrated in accordance with
manufacturer's instructions?
. - Does the system show signs
of tampering?
- Does the system indicate
potential leakage?
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