Model
Underground Storage Tank
Environmental Results Program
Workbook
(Based On The Federal Regulations)
An EPA model document to assist states in
preparing their own state ERP workbook
EPA 510-R-04-003
-------
Periodic Walk-Through Inspections
To quickly detect and prevent releases, you should conduct basic walk-through inspections of
your facility frequently to make sure that your essential equipment is working properly and that
you have emergency response supplies on hand. Make sure any problems you find are fixed.
Your initials in each box below the date of
the inspection indicate that the device/
system was inspected and was in working
order on that date.
Release Detection System: Inspect for
proper operation.
Spill Buckets: Make sure spill buckets are
clean and empty and have no cracks or
holes.
Overfill Alarm: Inspect for proper operation.
Can a delivery person hear or see the alarm
when it goes off?
Impressed Current System (if installed):
Inspect to make sure it is on and operating
within normal voltage and amperage values.
Fill And Monitoring Ports: Inspect all
fill/monitoring ports and other access points
to make sure that the covers and caps are
tightly sealed and locked.
Spill And Overfill Response Supplies:
Inventory and inspect the emergency spill
response supplies. If the supplies are low,
restock them. Inspect supplies for
deterioration and improper functioning.
Dispenser Hoses, Nozzles, And
Breakaways: Inspect for loose fittings,
deterioration, obvious signs of leakage, and
improper functioning.
Dispenser And Dispenser Sumps: Open
each dispenser and inspect all visible piping,
fittings, and couplings for any signs of
leakage. If any water or product is present in
the sump, remove it and dispose of it
properly. Remove any debris from the sump.
Piping And Piping Sumps: Inspect all
visible piping, fittings, and couplings for any
signs of leakage. If any water or product is
present in the sump, remove it and dispose of
it properly. Remove any debris from the
sump.
Notes
Date Of Inspection
(enter date in gray box below)
-------
Preamble
This document constitutes a model manual that the United States Environmental Protection
Agency (EPA) has prepared to assist states in adopting an Environmental Results Program
(ERP) where they choose to do so. EPA has based this model manual on its federal
underground storage tank regulations that appear in 40 C.F.R. Part 280. States that choose to
participate in ERP (either as a voluntary or mandatory program for their regulated community)
and wish to use this model manual may need to revise it, as appropriate, to reflect their state
underground storage tank regulations.
In this model manual, EPA describes federal regulations that already exist. This model manual
does not create or impose any new requirements. The references to language such as "must"
or "shall" throughout chapter 4 of the document do not create or indicate any new requirements
or obligations for the regulated community, but merely reflect the existing requirements that are
currently contained in 40 C.F.R. Part 280.
This model manual includes some suggested sample tools for an ERP program that are not
existing requirements under federal law (for example, the model certification of compliance form
in appendix A and the model return to compliance plan form in appendix B). States may choose
to require such tools under state law.
Since this is a model manual only, states may depart or vary from it. EPA intends for this
manual to serve as a model tool to assist states in developing their own ERP manual. In this
spirit, EPA fully expects that many states may make numerous revisions to this manual in
developing their state ERP manual. Each state will have to implement its own state law to
impose any requirements associated with its own ERP. Depending on each state's law, states
may need to modify language in this manual. The regulated community then may be required to
follow the final ERP manual that its state has modified and adopted. The regulated community
is not required to follow this EPA model manual.
EPA has written this model manual in a format that serves as a sample for states to use in
developing their own manual. The language, structure, and organization of the manual provide
one example of how a state manual might read. Depending on actual requirements under state
law, states may need to revise the language and structure of this sample document. For the
convenience of the states in referring to this model manual, EPA has written this document in a
format that uses sample language directed to members of the regulated community. EPA has
also written this document in such a manner that assumes a state's adoption of an ERP.
Therefore, this model manual will only be relevant to those states that have chosen to adopt,
implement or require an ERP in their state and are now interested in preparing their own state
ERP manual by using the EPA manual as a model.
**Disclaimer**
The Environmental Protection Agency and {state} do not endorse any companies or
names that are mentioned or shown in this workbook. Any companies, names,
facilities, services, or commercial products in this workbook are shown only as a written
or visual example.
-------
Contents
1. Does This Workbook Apply To Your Facility? 1
2. Introduction 3
2.1. What Is The Purpose Of This Workbook? 3
2.2. What Is The Environmental Results Program? 3
2.3. Why Participating In The LIST ERP Is Important 4
2.4. Your ERP Requirements 4
3. How To Use This Workbook 5
3.1. Organization Of The Workbook 5
3.2. Steps For Completing Each Section In Chapter4 5
3.3. Example: Joe And The A&B Gas Station 7
3.4. Symbols ForChapter4 18
4. Regulatory Requirements, Best Management Practices, And Compliance Checklists
For USTs At Your Facility 19
General Identifying The USTs At Your Facility 20
4.1. Spill Protection 21
4.2. Correct Filling Practices 24
4.3. Overfill Protection 27
4.3.1 Overfill Alarms 30
4.3.2 Automatic Shutoff Devices 32
4.3.3 Ball Float Valves 34
4.3.4 No Overfill Protection 36
4.4. Corrosion Protection For Tanks 39
4.4.1 Fiberglass Reinforced Plastic Tanks, Jacketed Steel Tanks, And Clad Steel
Tanks 42
4.4.2 Coated And Cathodically Protected Steel Tanks 44
4.4.3 Cathodically Protected Steel Tanks 46
4.4.4 Internally-Lined Steel Tanks 48
4.4.5 Internally-Lined And Cathodically Protected Steel Tanks 50
4.4.6 Metal Tanks With No Additional Corrosion Protection 52
4.5. Corrosion Protection For Piping 55
4.5.1 Fiberglass Reinforced Plastic Piping And Flexible Plastic Piping 58
4.5.2 Coated And Cathodically Protected Steel Piping 60
4.5.3 Cathodically Protected Metal Piping 62
4.5.4 Metal Piping - No Additional Corrosion Protection 64
4.6. Cathodic Protection 67
4.6.1 Galvanic Anode And Impressed Current Cathodic Protection 70
4.6.2 Impressed Current Cathodic Protection - Additional Requirements
And Best Management Practices 72
-------
4.7. Release Detection For Tanks 75
4.7.1 Automatic Tank Gauging 80
4.7.2 Secondary Containment With Interstitial Monitoring 82
4.7.3 Groundwater Monitoring 84
4.7.4 Vapor Monitoring 86
4.7.5 Inventory Control And Tank Tightness Testing 88
4.7.6 Manual Tank Gauging 90
4.7.7 Manual Tank Gauging And Tank Tightness Testing 92
4.7.8 Statistical Inventory Reconciliation 94
4.7.9 Tanks With No Release Detection 96
4.8. Release Detection For Piping 99
4.8.1 Pressurized Piping 102
4.8.1.1 Automatic Line Leak Detectors 104
4.8.2 Suction Piping 106
4.8.3 Line Tightness Testing 108
4.9. What To Do For Suspected Or Confirmed Releases 111
4.10. Financial Responsibility 113
4.11. Temporarily Closed USTs 120
4.12. Keeping Your State Agency Informed Of USTs Brought Into Use And Changes
To USTs 122
4.13. Repairs 123
Appendices
A. Model Certification Of Compliance Form A-1
B. Model Return To Compliance Plan Form B-1
C. Model Non-Applicability Form C-1
D. Sample Emergency Numbers List D-1
E. Definitions E-1
F. For More Information F-1
G. Examples Of Placards For Overfill Devices G-1
H. Sample Cathodic Protection Testing Form H-1
I. Sample Impressed Current 60 Day Inspection Form 1-1
J. Sample 30 Day Release Detection Monitoring Record J-1
K. Sample Daily Inventory Worksheet K-1
L. Sample Manual Tank Gauging Record L-1
M. EPA Notification Form M-1
Periodic Walk-Through Inspections Inside Front Cover
Reminder Of Required Ongoing Activities For USTs Inside Back Cover
Questions About Completing The Workbook? Outside Back Cover
-------
This Page Intentionally Left Blank
-------
Chapter 1: Does This Workbook Apply To Your Facility?
This workbook is designed to help owners and operators of underground storage tanks comply
with {state} environmental underground storage tank regulations. These tanks, along with any
connected underground piping, are called USTs in this workbook. The workbook uses the term
tank when the underground tank is the only thing being discussed. This workbook describes
requirements and best management practices (BMPs) for your USTs and helps you determine
whether they are in compliance with the law.
• If you have underground storage tanks at your facility that meet the criteria described
below, this workbook applies to you.
• If, after reading this section, you determine that the workbook does not apply to you,
fill out the non-applicability form, if required, and send it to {state}. This will inform
{state} that you do not have any USTs that fall under this program. A model non-
applicability form is in appendix C.
To determine if this workbook applies to you, read and answer the following questions:
Question 1. Do you have any USTs at your facility?
Yes
No
An underground storage tank or LIST is an:
underground tank and underground piping.
underground tank and aboveground piping (if at least 10% of the total volume of the tank and piping are
underground).
aboveground tank and underground piping (if at least 10% of the total volume of the tank and piping are
underground). This scenario is not common.
An underground storage tank is not an aboveground tank and aboveground piping.
• • If you answered yes, continue to question 2.
• • If you answered no, this workbook does not apply to you. If required, fill out a non-applicability form
and send it to {state}.
Question 2. How many USTs at your facility meet at least one of the following criteria?
These are types of USTs that are covered by this workbook.
contain petroleum or used oil (that will be recycled) at public gasoline stations or repair shops.
contain heating oil that is not used (or consumed) on the premises where it is stored.
are farm or residential motor fuel tanks greater than 1,100 gallons used for noncommercial purposes.
are petroleum tanks owned by a federal, state, or local entity.
are private petroleum tanks used for fueling of business vehicles (for example: bus terminals).
contain a hazardous substance listed under the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA). An example of a hazardous substance is antifreeze.
Contact {state} if you are not sure if you have a hazardous substance tank.
store product for use by emergency power generators.
Number
of USTs
• • If you have at least one UST that meets the criteria above, continue to question 3.
• • If you have no USTs that meet the criteria above, you do not have any USTs covered by the
Environmental Results Program. This workbook does not apply to you. If required, fill out a non-
applicability form and send it to {state}.
Chapter 1
-------
Question 3. Of the number of USTs you identified in question 2, how many meet at least
one of the following criteria?
USTs that meet at least one of the criteria below are not covered by this workbook.
If you received this workbook, it would be unusual for all of your tanks to meet at least one of
the criteria below.
USTs are not included in this workbook if they meet one of the following:
total tank and piping volume is 110 gallons or less.
LIST with a tank that was constructed or built in the field (field-constructed).
tank situated in an underground area, but situated on or above the surface of the floor.
heating oil tank that is used (or consumed) on the premises where it is stored.
hazardous waste tank (in general, a hazardous waste is a hazardous chemical that cannot be reused
in some way).
tank containing radioactive materials.
flow-through process tank (a tank that forms an integral part of a production process where there is a
steady, variable, recurring, or intermittent flow).
airport hydrant fuel distribution system.
tank located at pipeline facility regulated under the Natural Gas Pipeline Safety Act of 1968 or the
Hazardous Liquid Pipeline Safety Act of 1979 [or an intrastate pipeline facility regulated under
comparable state laws].
tank that is a part of machinery that contains product for operational purposes such as a hydraulic lift
tank or electrical equipment tank.
emergency spill or overflow containment tank that is quickly emptied after use.
tank located at a nuclear power generation facility used for an emergency power generator.
Number
of USTs
• If you have no USTs that meet the criteria in question 3, this workbook applies to you. Begin using
this workbook by reading chapter 2.
• If you have at least one UST that meets the criteria in question 3, continue to question 4.
Question 4. What is the difference between the total number of USTs in question 2 and question 3?
Subtract the number of USTs in your answer to question 3 from the number of USTs in your answer to
question 2.
Answer to question 2:
Answer to question 3:
The difference between the two:
1 If the difference between question 2 and question 3 is "1 or greater," this workbook applies to you.
Begin using the workbook by reading chapter 2.
If the difference between question 2 and question 3 is "zero," you do not have any USTs covered
by the Environmental Results Program. This workbook does not apply to you. If required, fill out a non-
applicability form and send it to {state}.
If you are not sure whether the workbook applies to you, call {state} at {XXX-XXX-XXXX}.
If you are required by {state} to participate in the Environmental Results Program and you
intentionally falsify your applicability, you may be subject to fines and penalties.
Chapter 1
-------
Chapter 2: Introduction
2.1 What Is The Purpose Of This Workbook?
This workbook is designed to:
clearly explain {state} environmental, record keeping, and operation and maintenance
requirements for USTs contained in existing {state} regulations;
clearly explain voluntary actions that you can take to improve environmental performance
and reduce financial risk regarding your LIST; and
help owners and operators of regulated USTs determine if they are in compliance with
existing {state} LIST regulations through compliance checklists.
2.2 What Is The Environmental Results Program?
The Environmental Results Program (ERP) focuses on educating owners and operators of
USTs about the existing {state} environmental regulations that apply to them and encourages
stewardship of the environment around UST tanks and piping systems. It allows users of the
workbook to understand and determine their compliance with existing {state} UST requirements.
Understanding the requirements and best management practices in this workbook and
complying with UST regulations will help you be more proactive in protecting the environment
around your USTs. {State} environmental laws already require that you follow the requirements
described in this workbook. {State} will perform inspections with UST owners and operators
participating in the {state} ERP to ensure that compliance statements are accurate and that
environmental standards are being met.
As a participant in {state} ERP, you will:
use this workbook to understand the {state} requirements and best management practices
for your USTs and determine compliance for USTs at your facility,
be able to attend workshops to learn about the {state} ERP program;
complete, sign, and send in the {state} certification of compliance form to {state}. On this
form you will certify the current compliance status of your facility and acknowledge that the
facility must comply with all applicable environmental regulations. A model certification of
compliance form is in appendix A;
submit {state} return to compliance plan forms to {state} if there are compliance problems
identified in the process of filling out the certification of compliance form that cannot be
corrected at that time. The return to compliance plan describes what you will do so your
facility meets requirements and when you will do it. A model return to compliance plan form
is in appendix B; and
be subject to {state} audits/inspections to confirm the accuracy of the certifications and
compliance with {state} UST regulations.
Chapter 2
-------
2.3 Why Participating In The UST ERP Is Important
There are several reasons why your participation in this program is important.
You are helping to protect public health and the environment. Releases from USTs - spills,
overfills, leaking tanks and piping - can contaminate groundwater. Your local community may
depend on that groundwater as a source of drinking water. In addition, leaks from USTs can
result in fires or explosions, which threaten public safety.
You are protecting your economic investment. It is important to quickly detect, report, and
clean up releases, as required by the UST regulations. Preventing releases protects your real
estate investment. Any product that is lost in a release may cost you in terms of cleanup costs,
potential penalties, the lost revenue of product not sold, and resale value of your property. By
responding quicky and containing a release, you may be able to reduce cleanup costs and
environmental damage.
You are required to follow environmental laws by complying with UST regulations. If you are
the owner or operator of one or more USTs, you are legally responsible for preventing
and quickly detecting releases from your USTs. You are also responsible for reporting and
cleaning up any releases that occur. You will be held accountable if your UST leaks.
Therefore, you should make sure releases do not occur.
This document is not a substitute for {state} law and regulations, nor is it a law or regulation
itself. For a comprehensive and complete understanding of the law and regulations, please
refer to [insert state statutory and regulatory citations and state website here].
[Depending on whether state law requires member of the regulated community to submit a
certification of compliance and return to compliance forms, the following suggested
language in section 2.4 is an example of what states can insert in this section, if applicable.]
2.4 Your ERP Requirements
Under state law [insert citation], you are required to submit a certification of compliance form to
{state} every year (appendix A). Under state law [insert citation], you also must submit return to
compliance plan forms (appendix B) to {state} if you are not in compliance when you submit the
certification of compliance form.
If you do not:
meet the environmental requirements;
send in the certification of compliance form (and any return to compliance plan forms); or
give accurate information on your certification of compliance form (and any return to
compliance plan forms),
you could trigger an inspection that may result in fines or other enforcement action by {state}.
If you have any questions as you go through this workbook, please refer to appendix F for other
resources or call {state} at {XXX-XXX-XXXX}.
Chapter 2
-------
Chapter 3: How To Use This Workbook
This chapter will tell you:
the organization of the workbook,
how to complete chapter 4,
how a person would fill out a section of chapter 4, and
what the symbols in chapter 4 mean.
3.1. Organization Of The Workbook
You have already read chapters 1 and 2. Chapter 1 showed you that you have at least one
regulated LIST and that this workbook applies to you. Chapter 2 explained what the
Environmental Results Program is and why it is important to comply with the existing {state}
regulations. This chapter will help you understand the rest of the workbook. There are two
remaining parts of the workbook, chapter 4 and the appendices.
Chapter 4 will help you understand what you have to do to comply with existing {state} LIST
regulations and to improve the environmental performance of your facility. Chapter 4 contains
an introduction and 13 sections. The introduction includes a table to help you identify the USTs
at your facility. Each of the 13 sections covers a different part of the existing {state} LIST
requirements. Read the beginning of each section and fill out a short checklist to determine the
parts of that section that apply to your facility. Then read and complete the checklists that apply
to your facility.
Do not be concerned about the size of chapter 4. You will only need to complete the
parts of each section in chapter 4 that apply to your facility. Each section in chapter 4
provides clear directions on which section parts you need to complete.
The appendices contain information and checklists to help you understand the workbook and
comply with existing {state} regulations. They include: Model Environmental Results Program
forms, other sample forms and checklists that can help you stay in compliance, and a list of
definitions for technical words used in the workbook.
If you have any problems filling out the workbook, consult the outside back cover to
find {state} contact information.
3.2. Steps For Completing Each Section In Chapter 4
Directions: Important directions are provided in gray boxes like this one. There are
specific directions to follow in each section of chapter 4. Make sure you read the
directions before starting a section.
Chapter 3
-------
The steps for completing each section in chapter 4 are:
1. Read the beginning of each section to understand if it applies to your facility. If you are
sure it does not apply, you can skip that section. If it does apply, complete the section.
The section may ask you to fill out a table to identify which compliance options are used for
each of your USTs. This table will help you understand which parts of the section you will
need to fill out (if there is no table, complete that section). Use the LIST identification table
at the beginning of chapter 4 to keep track of the USTs at your facility.
2. Go to the parts of a section that apply to your facility and read the information on {state}
requirements and best management practices. Next, complete the checklist as follows:
Circle the "UST Number" at the top of the checklist for each UST that uses the option or
meets the characteristics of this checklist.
• Answer the questions in the checklist for USTs that you circled at the top. Circle "Y" for
yes or "N" for no in the column below each UST that you circled. If you do not know
the answer to a question, you will need to look up the relevant information in your
records or call the contractor who worked on your site. Appendix E contains a list
of definitions to help you understand the technical terms used in chapter 4. Answer
either "Y" or "N" for each question that applies to your facility.
Leave all questions blank for USTs that you did not circle.
DIRECTIONS: Sometimes a question will tell you to complete a different section first to get
the answer for the question. After you complete the other section, make sure you return to the
original section you are working on.
3. Answer the summary of compliance question at the bottom of the checklist page. This
question summarizes your compliance with the option on that page. Read the instructions
below the summary of compliance question to determine how to answer the question. If
you answer "no" to the summary of compliance question, fill out a return to compliance plan
form for each area of non-compliance and submit it with your certification of compliance
form as required by {state regulatory cite}.
4. Answer the final summary of compliance question for your facility on the last page of each
section. The final summary of compliance question asks whether all of your USTs are in
compliance with the requirements discussed in that section. If you answered "no" to any
previous summary of compliance questions in the section, you must answer "no" to this
question. As required by {state regulatory cite}, fill out a return to compliance plan form for
each area of non-compliance and submit it with your certification of compliance form.
5. After you have filled out the workbook, transfer your answers from the final summary of
compliance questions in chapter 4 to the certification of compliance form as required by
{state regulatory cite}. Please note that the federal regulations hold owners and operators
responsible for compliance. Therefore, the owner or operator of the facility must sign the
certification of compliance form {states may need to modify this}.
Chapter 3
-------
3.3 Example: Joe And The A&B Gas Station
The next few pages tell the story of Joe, the owner of a gas station, and how he filled out a few
parts of chapter 4 in this workbook. Joe is not a real person; this is a fictitious story to help you
understand how to fill out the information in chapter 4. Joe's story does not tell you everything
he did to fill out chapter 4, but will help you get started. If you already understand how to
complete the workbook, you may skip this section.
Joe's example is explained in dark, bold letters over the next few pages. Try to read the whole
story, because it will help you understand how to:
1. fill out the tables in chapter 4,
2. complete the compliance checklists in chapter 4, and
3. answer the summary of compliance questions in chapter 4.
Joe's Story
Joe is the owner of A&B Gas Station on the corner of Elm and Main Streets. He also
owns Y&Z Gas on the corner of Maple and State Streets. Joe is completing this
workbook for A&B Gas. He will use the information he writes in the workbook to
correctly fill out his certification of compliance form for A&B Gas. He will need to fill out
a separate workbook and a certification of compliance form for Y&Z Gas.
Joe received the workbook in the mail from his state LIST program and began working on
it. He knows starting early will help make sure he has time to collect the right
information and accurately complete the workbook.
Joe has three underground storage tanks at A&B Gas. One LIST holds gasoline, one
holds kerosene, and one holds used oil. The gasoline LIST is compartmentalized. This
means the tank is divided into different sections or compartments. (Usually, each
compartment will have a different product in it.) This tank has a compartment for regular
gasoline and a compartment for premium gasoline.
The three tanks are lined up in a row from east to west. Joe usually calls the gasoline
tank the east tank. He calls the kerosene tank the middle tank and the used oil tank is the
west tank. Joe's kerosene tank is a lot older than his other two tanks, so he does not
know as much about that tank as he does about the gasoline tank and the used oil tank.
After reading chapters 1, 2 and 3, Joe feels he has a pretty good idea of how to fill out the
workbook. He turns to chapter 4.
Chapter 3
-------
Joe Identifies The USTs At His Facility
Before Joe can begin filling out any of the checklists in chapter 4, he has to complete the
table at the beginning of chapter 4; this helps him keep track of his tanks. He will use the
numbers he gives to each tank in the table to identify them in the rest of chapter 4. He
follows the directions in the workbook to put the information for each tank into the table.
You can see a copy of Joe's completed table at the bottom of this page.
Even though the premium and regular gas are stored in the same tank, the directions tell
him to enter each compartment as a separate LIST. So Joe calls the premium section of
his gasoline tank LIST 1. Joe knows the registration number of this tank, so he puts that
in the Identification Number column. He knows how many gallons the tank holds, so he
fills out the Size column. Joe also fills in the type of product contained in this
compartment and the size of the compartment. In the column called Other Identifying
Information, Joe writes that this tank is the east tank, since that is how he thinks of it.
Joe calls the regular compartment of the gasoline tank LIST 2 and fills in the registration
number and location. These are the same as for the premium compartment. He also fills
in the size of this compartment and the type of product it holds.
Joe calls his kerosene tank LIST 3. He does not know this tank's registration number, so
he leaves that blank. He writes in the type of product and size and that this is the middle
tank.
Joe calls the used oil tank LIST 4 and fills in the information for this tank. He calls this
tank the west tank.
Joe has a total of four USTs (since the premium and regular gasoline compartments
count separately). So he does not put anything in the fifth row of the table.
LIST Identification Table
UST
Number
1
2
3
4
5
Identification
Number
00123
00123
00012
Type of Product
Premi urn
Requl dr
Kerosene
Used Oil
Size
(Gallons)
4,000
6,000
2.000
1,000
Other Identifying Information
Edst
Edst
Middle
West
Now that Joe has identified all of his USTs, he is ready to look at the other sections in
chapter 4. Joe reads the directions and fills out sections 4.1 and 4.2. He did not have
much trouble with these sections because he read the directions. We join Joe again
when he starts section 4.3. This section is a lot like the other sections in the workbook,
so seeing how Joe fills it out will help you.
Chapter 3
-------
Joe Identifies The Types Of Overfill Protection He Has
First, Joe reads the instructions in section 4.3. He learns that overfill protection is
equipment on USTs to prevent tanks from overflowing when they are being filled. He
also learns that to be in compliance most USTs must have at least one type of overfill
protection.
Joe sees there are three kinds of overfill protection the regulations allow: overfill alarms,
ball float valves, and automatic shutoff devices. An overfill alarm activates when a tank
is close to being full; this alarm can be seen and/or heard. An automatic shutoff device
is located at the fill pipe of a tank; it stops product from flowing into a tank that is close
to full. A ball float valve is located inside a tank; it slows the rate of product flowing into
a tank that is almost full.
Joe already knows that he has an alarm for his gasoline tank. The information at the
beginning of section 4.3 helps him figure out that he has an automatic shutoff device on
his kerosene tank and no overfill protection for his used oil tank.
At the beginning of section 4.3, Joe fills out a table that asks about the kind of overfill
protection on each of his USTs. This table tells him which checklists in 4.3 he needs to
fill out. A copy of Joe's table is at the bottom of this page.
Using the UST numbers from the identification table he filled out at the beginning of
chapter 4 (see the previous page of this story), Joe marks that USTs 1 and 2 have overfill
alarms. (Remember that Joe was told to treat each compartment of his gasoline tank as a
separate UST.) He also marks that UST 3 (his kerosene tank) has an automatic shutoff
device, and UST 4 (his used oil tank) has no overfill protection. From this table, Joe sees
that he has to fill out checklists in sections 4.3.1, 4.3.2, and 4.3.4. He will complete these
checklists next. None of Joe's USTs have ball float valves, so he can skip section 4.3.3.
Choose the types of overfill protection used for each tank by checking
the appropriate boxes
UST Number:
Overfill Alarm
Go to these sections
for information and
compliance checklists
Section 4.3.1
Automatic Shutoff Device
Section 4.3.2
Ball Float Valve
Section 4.3.3
No Overfill Protection
Section 4.3.4
Chapter 3
-------
Joe Completes The Overfill Alarm Section For His Gasoline Tank
Joe knows he needs to fill out section 4.3.1 because USTs 1 and 2 have overfill alarms
and the table at the beginning of 4.3 directed him to go to section 4.3.1. Joe turns to
section 4.3.1 and reads about the requirements and best management practices for
USTs with overfill alarms. Using that information, he answers the questions in this
checklist.
A copy of Joe's checklist and summary of compliance question are on the right hand
page, so you can follow along. The next few paragraphs will tell you why he
answered the questions the way he did.
At the top of the checklist, he circles the numbers 1 and 2, to show that these two tanks
have overfill alarms. He will not answer any questions on this checklist for USTs 3 and
4, since they do not have overfill alarms.
Since both UST 1 and UST 2 regularly receive more than 25 gallons of gasoline at a time,
Joe answers yes to the first question.
Joe recently had a technician check his overfill alarms, so he knows that they are
working according to the requirements he sees in the workbook. He answers yes for
both tanks to questions 2 and 3.
The question at the bottom of the page is a summary question. Because Joe answered
yes to all of the questions on this checklist for his two USTs with overfill alarms, he
answers yes to this question.
Chapter 3
10
-------
Joe's Overfill Protection Checklist For USTs With Overfill Alarms
Circle the UST number for each UST that has
an overfill alarm. Answer the questions
below for each UST you circled.
Questions
UST# =
1 . Does your UST ever receive more than 25 gallons of A
product at a time? [
0
©
3
4
5
Yes (Y) or No (N)
L >
)(
1
— N^
If you answered yes for an UST, you must answer the remaining questions in this checklist for
that UST.
If you answered no for an UST, you are not required to have an overfill device. This UST is in
compliance with the overfill requirements. Skip questions 2 and 3 below.
2. Does your overfill alarm activate at 90% of tank capacity
or at least one minute before being overfilled?
S, .
)
^^^
^^j
)
If no, then to return to compliance: Have a qualified person adjust your overfill alarm so that it
activates at 90% of the tank capacity or at least 1 minute before being overfilled.
3. Can your overfill alarm be seen and/or heard from the
delivery location so it will alert the delivery person that the
tank is almost full?
°
)
^-
)
^^r
If no, then to return to compliance: Have a qualified person fix your overfill alarm so that it can
be seen and/or heard from the delivery location.
Summary Of Compliance With Overfill Alarms
Answer the following question:
Are all of your USTs with an overfill alarm in compliance with overfill
protection?
To answer yes here, you must have either:
a) answered yes to all questions above, or
b) answered no to question 1 above.
Yes
X
No
If you answered no, fill out a return to compliance plan and submit it with your certification of compliance.
A return to compliance plan form is in appendix B.
11
Chapter 3
-------
Joe Completes The Automatic Shutoff Device Section For His Kerosene
Tank
Joe knows he needs to complete section 4.3.2 because the table at the beginning of 4.3
told him to fill out this section for his kerosene tank, which has an automatic shutoff
device. He reads the information about automatic shutoff devices before he answers
the questions. The questions about automatic shutoff devices are like the questions
Joe answered about overfill alarms.
A copy of Joe's checklist and summary of compliance question are on the right hand
page, so you can follow along. The next few paragraphs will tell you why he
answered the questions the way he did.
Joe starts by circling LIST 3 at the top of the checklist, since that is the only tank with an
automatic shutoff device. He does not circle the other tanks and will not answer any
questions for them.
Because his kerosene tank regularly receives more than 25 gallons of kerosene when it
is filled, he answers "yes" to the first question.
Joe's kerosene tank overflowed when it was filled last month. So Joe does not think his
automatic shutoff device is working and circles no for question two. He realizes he will
need to hire a qualified person to fix his automatic shutoff device so he can be in
compliance with the requirements for automatic shutoff devices.
At the bottom of the page, Joe reads the directions in the summary of compliance
question. He can only answer yes if he is in compliance with all overfill protection
requirements. Because he answered no to question 2, he answers no to the summary of
compliance question. He turns to appendix B and fills out a return to compliance plan.
The return to compliance plan tells the state how and when Joe will fix the problem. Joe
will submit the return to compliance plan with his certification of compliance form.
Joe does not have any tanks with a ball float valve and the table at the beginning of
section 4.3 tells him he can skip section 4.3.3. Next he turns to section 4.3.4 to answer
questions for his tank with no overfill protection.
Chapter 3
12
-------
Joe's Overfill Protection Checklist For USTs With Automatic Shutoff
Devices
Circle the LIST number for each LIST that has an
automatic shutoff device. Answer the
questions below for each LIST you circled.
UST# =
1
Questions
Circle Yes (Y) or No (N)
1. Does your LIST ever receive more than 25 gallons of
product at a time?
If you answered yes for an LIST, you must answer the remaining questions in this checklist for that
UST.
If you answered no for an UST, you are not required to have an overfill device. This UST is in
compliance with the overfill requirements. Skip question 2 below.
2. Does your automatic shutoff device properly activate at
95% of tank capacity or before the fittings at the top of the
tank are exposed to product?
If no, then to return to compliance: Have a qualified person adjust your automatic shutoff device to
properly activate at 95% of the tank capacity or before the fittings at the top of the tank are exposed to
product.
Summary Of Compliance With Automatic Shutoff Devices
Answer the following question:
Yes
No
Are all of your USTs with automatic shutoff devices in compliance with overfill
protection?
To answer yes here, you must have either:
a) answered yes to all questions above, or
b) answered no to question 1 above.
If you answered no, fill out a return to compliance plan and submit it with your certification of compliance.
A return to compliance plan form is in appendix B.
13
Chapter 3
-------
Joe Completes The No Overfill Protection Section For His Used Oil Tank
Joe knows he needs to complete section 4.3.4 because the table at the beginning of 4.3
told him to fill out this section for his used oil tank, which has no overfill protection. He
reads the information about tanks with no overfill protection before he answers the
questions. The questions in section 4.3.4 are like the questions Joe answered for
overfill alarms and automatic shutoff devices.
A copy of Joe's checklist and summary of compliance question are on the right hand
page, so you can follow along. The next few paragraphs will tell you why he
answered the questions the way he did.
Joe circles LIST 4 at the top of the checklist, since that is the only tank with no overfill
protection. He does not circle the other tanks and will not answer any questions for
them.
Joe stores only used oil in this tank and he never puts in more than 25 gallons at one
time. So Joe answers yes to the question in the checklist.
At the bottom of the page, Joe reads the directions in the summary of compliance
question that tell him how to answer it. Since he answered yes to the question above,
he answers yes to the summary of compliance question.
Joe is finished answering detailed questions about overfill protection for his tanks. He
is ready to answer the summary of compliance with overfill protection question at the
end of section 4.3. Joe turns the page and looks at the directions and the question.
Chapter 3
14
-------
Joe's Checklist For USTs Without Overfill Protection
Circle the LIST number for each LIST that does
not have overfill protection. This means the
LIST does not have an overfill alarm, automatic
shutoff device, or ball float valve. Answer the
questions below for each LIST you circled.
UST# =
Question
1 . Does each LIST circled above only receive product in
amounts of 25 gallons or less?
If no, then to return to compliance: Have a qualified person prope
1
2
3
©
^~S
5
Circle Yes (Y) or No (N)
^^
^_^
rly install an overfill protection
device.
Summary Of Compliance For USTs With No Overfill Protection
Answer the following question:
Are all of your USTs with no overfill protection in compliance?
To answer yes here, you must have answered yes to the question above.
Yes
X
No
If you answered no, fill out a return to compliance plan and submit it with your certification of compliance.
A return to compliance plan form is in appendix B.
15
Chapter 3
-------
Joe Answers The Summary Of Compliance With The Overfill Protection
Question
Joe turns to the page that contains the summary of compliance with overfill protection
question. First Joe reads the directions in the gray direction box at the top of the page.
Then he checks to make sure he has completed all the checklists required before he
answers the summary question. Joe filled out the overfill alarm checklist for USTs 1 and
2, the automatic shutoff device checklist for LIST 3, and the no overfill protection
checklist for LIST 4. Because he filled out a checklist for each tank, he is ready to
answer the summary question.
A copy of Joe's summary of compliance question is on the right hand page, so you
can follow along. The next few paragraphs will tell you why he answered the
questions the way he did.
Joe reads the summary of compliance with overfill protection question. He knows that
he answered yes to the summary questions for the overfill alarms on USTs 1 and 2 and
for the no overfill protection for LIST 4. But he answered no to the summary of
compliance for the automatic shutoff device for LIST 2. So he answers no to the
summary of compliance with overfill protection, because he is not in compliance with all
overfill protection requirements for his tanks. He knows he has to fill out a return to
compliance plan form for the automatic shutoff device on LIST 2; however, his other
tanks are currently in compliance with overfill protection requirements.
Joe will copy his answer to this summary of compliance with overfill protection question
to his certification of compliance form in appendix A. He will answer no to question 3
on the certification of compliance form.
Joe is ready to move on to section 4.4 and the other sections of chapter 4, which he will
complete the same way as section 4.3.
Joe will continue through the rest of chapter 4 until he has completed all of the sections
that apply to the USTs at his facility. Then he will complete the certificate of compliance
form in appendix A. Joe will mail this form along with the return to compliance form (if
necessary) to {state}.
Joe has finished the workbook. He will fix any problems and follow through with any
return to compliance plans he has filled out.
Now you are ready to fill out chapter 4 in this workbook. If you need help with this
workbook, contact {state} at:
{address}
{phone}
{email}
Chapter 3
16
-------
Joe's Summary Of Compliance With Overfill Protection
Make sure you read and complete the checklists in the appropriate overfill protection
sections for all of your USTs before answering the question below.
Summary Of Compliance With Overfill Protection
Answer the following question:
Yes
No
Are all of your USTs in compliance with overfill protection?
To answer yes here, you must have answered yes to all summary questions for each overfill
protection device you use for compliance at your facility.
If you answered no, complete and submit a return to compliance plan addressing each area of non-compliance.
A return to compliance plan form is in appendix B.
(Copy your yes or no answer to question 3 of the certification of compliance form in appendix A)
17
Chapter 3
-------
3.4 Symbols For Chapter 4
You will see symbols next to some parts of this workbook. The symbols are used to highlight
key information. Below are the symbols and the meaning of each.
What The Symbols In Chapter 4 Mean
Requirement
• What you must do by law; requirements you, as an owner
or operator, must meet to be in compliance with federal {and
state} regulations
Best Management Practice
• What you should do to help prevent leaks; actions or
activities you, as an owner or operator, are encouraged to
take in order to reduce the potential of leaks
Important Information
• Information to help you better understand an LIST regulatory
option
Chapter 3
18
-------
Chapter 4: Regulatory Requirements, Best
Management Practices, And Compliance
Checklists For USTs At Your Facility
{In this chapter, EPA discusses federal LIST regulations in 40 C.F.R. Part 280. This
discussion serves as a model for how chapter 4 might read in a state ERP workbook.
Depending on their laws, states may need to revise or modify chapter 4 as appropriate to
reflect their own requirements}
This chapter contains the following:
General Identifying The USTs At Your Facility
Section 4.1 Spill Protection
Section 4.2 Correct Filling Practices
Section 4.3 Overfill Protection
Section 4.4 Corrosion Protection For Tanks
Section 4.5 Corrosion Protection For Piping
Section 4.6 Cathodic Protection
Section 4.7 Release Detection For Tanks
Section 4.8 Release Detection For Piping
Section 4.9 What To Do For Suspected And Confirmed Releases
Section 4.10 Financial Responsibility
Section 4.11 Temporarily Closed USTs
Section 4.12 Keep Your State Agency Informed Of USTs Brought Into Use And Changes To
USTs
Section 4.13 Repairs
Although chapter 4 is lengthy, you will only need to complete the parts of each section
that apply to your facility. The instructions will help you determine what parts of each
section to complete.
19
Chapter 4
-------
Identifying The USTs At Your Facility
Complete the table below to identify the USTs at your facility. To help you complete this
workbook, each LIST at your facility is assigned a number (1, 2, 3, etc.) in the first column of
the table. Use this LIST number consistently throughout this workbook. For questions
about completing this table, consult the workbook example in section 3.4.
• The total number of USTs you identify should add up to the same number you calculated
for question 4 in chapter 1 (including temporarily closed tanks).
• The Identification Number in the second column could be a common identification you use
(for example: state tank registration number)
• The Other Identifying Information in the fifth column should contain information to help
further identify each tank, such as:
- the location of the UST at your facility (for example: north, east, southwest, etc.)
- special features of the UST (for example: the specific compartment of a
compartmentalized tank, the specific tank in a manifolded tank system)
Special Instructions - The following are special considerations for cases where your facility
has one or more of the following conditions listed below.
• More Than Five USTs At Your Facility Covered By This Workbook - You will need to
make a copy of the table below. Change the UST numbers on your copy to show additional
tanks (6, 7, 8, etc). You will also need to make copies of the checklists in chapter 4 and
renumber the UST numbers at the top of those lists as well.
• Compartmentalized Tanks - A compartmentalized tank is a tank that has several
separated sections to contain different products. Each section is called a compartment. If
you have a compartmentalized tank, treat each compartment as a separate UST as you
complete this workbook. Make sure to clarify which tank you are referring to in the Other
Identifying Information column in the table below.
Manifolded Tanks - Manifolded tanks are two or more tanks connected together by piping.
These tanks contain the same product. The piping connecting the tanks allows the product
to move from one tank to another as product is added or removed from one of the tanks. If
you have manifolded tanks, treat each manifolded tank as a separate UST as you complete
this workbook. Make sure to clarify which tank you are referring to in the Other Identifying
Information column of the table below.
• Temporarily Closed USTs - Temporarily closed USTs do not have to meet the spill and
overfill requirements in sections 4.1 and 4.3. Section 4.11 contains requirements and best
management practices for temporarily closed USTs.
UST Identification Table
UST
Number
1
2
3
4
5
Identification
Number
Type Of Product
Size
(Gallons)
Other Identifying Information
20
Chapter 4
-------
Section 4.1: Spill Protection
Spill protection devices are used at fill pipes to catch drips and small spills
that may occur when the delivery hose is disconnected from the fill pipe.
Many spill protection devices are called spill buckets or catchment basins.
Sample Spill Bucket/Cross-
Section
Spill protection is typically not designed to contain
product for long periods of time.
Some spill protection devices are equipped with a drain
valve or manual pump which allows you to drain
accumulated product into your tank. Be aware that
when you drain the contents of a spill bucket into your
tank, water and debris may also enter the tank. If spill
protection is not equipped with a drain valve or pump,
any product or water in your spill bucket will need to be
removed manually and disposed of properly.
Directions For Completing The Spill Protection Section
Step 1: Determine if you have spill protection. (If you do not know if you have spill
protection, read the information below this box to determine whether or not it has
been installed).
Step 2: Read the requirements and best management practices on the next page.
Step 3: Fill out the checklist for spill protection and complete the question at the bottom of
the last page of this section that summarizes your compliance with spill protection.
Take the following steps to figure out what is at your facility:
Lift each fill port lid and look to see if you have spill
protection around your fill pipe.
Look through your old records to check if you had spill
protection installed.
• Ask the contractor who installed your LIST.
Sample Spill Protection
Sample Fill Area
21
Chapter 4
Section 4.1
-------
Requirements And Best Management Practices For Spill Protection
• Any LIST that receives more than 25 gallons in a single delivery must have spill
J protection at each fill port where product delivery could occur.
Spill protection must prevent the release of product to the environment when the
transfer hose is detached from the fill pipe. The spill protection cannot meet this
requirement if it is not able to contain liquid or if it is full of liquid or solid debris when
the tank is being filled.
Periodically check to see if your spill protection will hold liquid.
Periodically inspect your spill protection for signs of wear, cracks, or holes.
Make sure your spill protection is empty of liquid and debris before and after
each delivery.
Even though tanks that never receive deliveries of more than 25 gallons of product
at a time are not required to have spill protection, you should consider using spill
protection as part of good LIST system management. Many used oil tanks fall into
this category.
Chapter 4
22 Section 4.1
-------
Checklist For Spill Protection
Circle the LIST number for each LIST that you
have identified in the LIST identification table in
the beginning of chapter 4. Answer the
questions below for each LIST you circled.
UST# =
Questions
Circle Yes (Y) or No (N)
1. Does your LIST ever receive more than 25 gallons of
product at a time?
If you answered yes for an LIST, you must answer the remaining questions in this checklist for that
UST.
If you answered no for an UST, you are not required to have spill protection and do not need to
answer any additional questions for that UST. That UST is in compliance with the spill protection
requirements.
2. Do you have spill protection for each tank that receives
more than 25 gallons of product at a time?
If no, then to return to compliance: Have spill protection (such as a spill bucket) properly installed.
3. Will your spill protection prevent the release of product to
the environment when the transfer hose is detached from the
fill pipe?
If no, then to return to compliance: Have your spill protection emptied, repaired, or replaced so it
will prevent a release to the environment when the transfer hose is detached from the fill pipe.
Summary Of Compliance With Spill Protection
Answer the following question:
Yes
No
Are all of your USTs in compliance with spill protection?
To answer yes here, you must have either:
a) answered yes to all questions above, or
b) answered no to question 1 above.
If you answered no, fill out a return to compliance plan and submit it with your certification of compliance.
A return to compliance plan form is in appendix B.
(Copy your yes or no answer to question 1 of the certification of compliance form in appendix A)
23
Chapter 4
Section 4.1
-------
Section 4.2: Correct Filling Practices
Requirements And Best Management Practices For Correct Filling Practices
As an owner or operator, you are responsible for any releases of product that occur
due to spilling or overfilling during product delivery.
• You must make sure the amount of product to be delivered will fit into the
available empty space in the tank.
• You must make sure the transfer operation is monitored constantly to prevent
overfilling and spilling.
A good management practice that will help you meet the correct filling practice
requirements is to make sure the activities below are performed each time you have
product delivered to your tank. The table below describes activities to perform
before, during, and after product delivery.
Activities To Perform Before, During, And After Product Delivery
What To Do
Before Your
Tanks Are
Filled
• • Determine and record accurate readings for product and water in the tank before
product delivery.
• • Order only the quantity of product to fill 90 percent of the tank. Remember, the
formula for determining the amount of product to order is:
[tank capacity (gallons) X 90% ] — gallons of product in tank now = amount to order
Example: You have a 10,000 gallon tank and currently have 2,000 gallons in the tank.
(10,000 gal X 0.9 ) — 2,000 gal = 7,000 gal (amount to order)
• • Make sure the delivery person knows which type of overfill device is on the tank
and what actions to perform if it activates. One way to do this is to post a copy of
the appropriate sign provided in appendix G where the delivery person will see it.
• • Review and understand the spill response procedures.
• • Make sure the spill bucket is empty, clean, and will contain spills.
What To Do
While Your
Tanks Are
Being Filled
Have an accurate tank capacity chart available for the delivery person.
Have a person responsible for monitoring the delivery available each time tanks
are being filled. The delivery person makes all hook-ups. The person monitoring
the delivery should be prepared to stop the flow of product from the truck to the
tank at any time and respond to any unusual condition, leak, or spill.
Make sure spill response supplies are available in case a spill or overfill occurs.
Make sure there are safety barriers around the delivery area.
Make sure there is adequate lighting around the delivery area.
What To Do
After Your
Tanks Are
Filled
Have a person available to monitor the disconnection of hook-ups following
delivery. The delivery person disconnects the hook-ups.
Determine and record accurate readings for product and water in the tank after
delivery.
Verify the amount of product received.
Make sure fill ports are properly secured.
Make sure the spill bucket is free of product and clean up any small spills.
24
Chapter 4
Section 4.2
-------
Checklist For Requirements For Correct Filling Practices
Answer the following questions:
1. Do you make sure the amount of product to be delivered will fit into the tank
for each delivery at your facility? You can meet this requirement by having
procedures in place so you, an employee, or the delivery person makes sure the tank
will hold the product to be delivered before the delivery occurs.
If no, then to return to compliance: Make sure the amount of product to be delivered v\
tank it is being placed into. Make sure you do this for each delivery.
2. Do you make sure each delivery is monitored constantly to prevent overfilling
and spilling? You can meet this requirement by having procedures in place so you,
an employee, or the delivery person is available to constantly monitor the delivery.
If no, then to return to compliance: Make sure the delivery is monitored constantly to p
overfilling and spilling. Make sure you do this for each delivery.
Yes
No
/ill fit into the
re vent
Summary Of Compliance With Correct Filling Practices
Answer the following question:
Are you in compliance with all correct filling practices?
To answer yes here, you must have answered yes to all questions above.
Yes
No
If you answered no, fill out a return to compliance plan and submit it with your certification of compliance.
A return to compliance plan form is in appendix B.
(Copy your yes or no answer to question 2 of the certification of compliance form in appendix A)
25
Chapter 4
Section 4.2
-------
This Page Intentionally Left Blank
26
-------
Section 4.3: Overfill Protection
Overfill protection equipment installed on USTs helps prevent your tanks from
being overfilled during product delivery. Overfill protection is designed to stop
product flow, reduce product flow, or alert the delivery person during delivery
before the tank becomes full and begins releasing product into the environment.
There are three common types of overfill protection:
overfill alarms
automatic shutoff devices
ball float valves
Directions For Completing The Overfill Protection Section
Step 1: Fill out the table on the next page to identify the type of overfill protection you have
for each UST.
• Different tanks at your facility may have different types of overfill
protection. Make sure to select the appropriate type of overfill
protection for each tank at your facility.
Some of your tanks may have more than one type of overfill protection.
Only choose one type of overfill protection for each tank for this
workbook. You only need to meet the requirements for one type of
overfill protection for each tank.
Step 2: For each type of overfill protection you checked in the table, go to the
corresponding section listed in the far-right column. Read the requirements and
best management practices and fill out the appropriate checklist(s) in that section.
You may need to go to more than one section and fill out more than one checklist -
each overfill protection type has a separate checklist.
Step 3: Once you have completed the checklists for all of your overfill protection type(s),
turn to the last page of this section and complete the question that summarizes your
compliance with overfill protection.
Chapter 4
27 Section 4.3
-------
Identifying The Types Of Overfill Protection You Have
Identify the type of overfill protection you have for each LIST in the table below and proceed
as instructed in the far-right column.
If you do not know the type of overfill protection you have, read the information below
the table to help you.
1 Choose the type of overfill protection used for each tank by checking the
appropriate boxes
Overfill Alarm
Automatic Shutoff Device
Ball Float Valve
No Overfill Protection
Go to these sections
for information and
compliance checklists
Section 4.3.1
Section 4.3.2
Section 4.3.3
Section 4.3.4
Take the following steps to figure out what is at your facility.
• Read the descriptions below to determine if you have overfill protection.
• Look through your old records to see if you had overfill protection installed. Check for the
names of the overfill protection type.
• Ask the contractor who installed your LIST.
Descriptions Of Different Types Of Overfill Protection
Overfill Alarms - An overfill alarm has a sensor in the tank.
The sensor is typically connected to a monitoring device such
as an automatic tank gauge (ATG). An overfill alarm provides
a warning that can be seen or heard (or both) by the person
delivering the product when the tank is close to being full.
Sample Overfill Alarm
Sample Schematic For An
Overfill Alarm
28
Chapter 4
Section 4.3
-------
Automatic Shutoff Devices - An automatic shutoff device is located at the fill pipe of your
tank. Look down your fill pipe to see part of this device. You will see what appears to be a line
cutting through your fill pipe (or a half moon shape in your fill pipe).
Fill Pipe
Float
Looking Down A Fill Pipe At
An Automatic Shutoff Device
Diagram Of An
Automatic Shutoff
Device
Ball Float Valves -
A ball float valve is located inside the tank where
the vent line exits the tank. You might find it
difficult to determine whether or not you have this
device because of where it is located. You might
be able to find an extractor port for the ball float
valve (see picture below). Otherwise, you will
need to look through your paperwork to
determine whether your tank has this device; or
you should ask the contractor who installed your
tanks.
Looking Through The End Of
Automatic Shutoff Device
Sample Ball Float
Valves
Sample
Ball Float
Valve
Sample Extractor Port
Closeup Of Extractor
Port
29
Chapter 4
Section 4.3
-------
4.3.1 Overfill Alarms
Overfill alarms send a warning that can be seen or heard by the person
responsible for monitoring the delivery of product to your tank. The warning
activates when the LIST is approaching tank capacity and warns the delivery
person to stop delivery. When the alarm activates, the delivery person should
immediately stop the flow of product to the tank.
Requirements And Best Management Practices For Overfill Alarms
£H| You must have overfill protection (for example, an overfill alarm) for every LIST that
I is filled with more than 25 gallons of product at one time.
The overfill alarm must activate when the product in the tank reaches 90 percent of
f the tank capacity or is within one minute of being overfilled.
The overfill alarm must be located so it can be seen and/or heard from where the
LIST is filled. This ensures that the person responsible for monitoring the delivery
will know when the tank is almost full.
A qualified LIST contractor should periodically check your overfill alarm to make sure
it is functioning properly.
You should inform your delivery person you have an overfill alarm.
• You could place a durable sign near each fill pipe. The sign should be in clear
view of the delivery person. It should say there is an overfill alarm for this tank,
what occurs when the alarm activates, and indicate the necessary actions to
take. See the sample sign in appendix G as a reference.
Chapter 4
30 Section 4.3
-------
Overfill Protection Checklist For USTs With Overfill Alarms
Circle the LIST number for each LIST that has
an overfill alarm. Answer the questions
below for each LIST you circled.
UST# =
Questions
Yes (Y) or No (N)
1. Is your LIST ever filled with more than 25 gallons of
product at one time?
If you answered yes for an LIST, you must answer the remaining questions in this checklist for that
UST.
If you answered no for an UST, you are not required to have an overfill device. This UST is in
compliance with the overfill requirements. Skip questions 2 and 3 below.
2. Does your overfill alarm activate at 90 percent of tank
capacity or at least one minute before being overfilled?
If no, then to return to compliance: Have a qualified person adjust your overfill alarm so it
activates at 90 one of tank capacity or at least one minute before being overfilled.
3. Can your overfill alarm be seen and/or heard from the
delivery location so it will alert the delivery person that the
tank is almost full?
If no, then to return to compliance: Have a qualified person fix your overfill alarm so it can be seen
and/or heard from the delivery location.
Summary Of Compliance With Overfill Alarms
Answer the following question:
Yes
No
Are all of your USTs with an overfill alarm in compliance with overfill protection?
To answer yes here, you must have either:
a) answered yes to all questions above, or
b) answered no to question 1 above.
If you answered no, fill out a return to compliance plan and submit it with your certification of compliance.
A return to compliance plan form is in appendix B.
31
Chapter 4
Section 4.3
-------
4.3.2 Automatic Shutoff Devices
The automatic shutoff device slows down and stops the flow of product during
delivery when the product has reached a certain level in the tank.
Requirements And Best Management Practices For Automatic Shutoff Devices
You must have overfill protection (for example, an automatic shutoff device) for every
• LIST that is filled with more than 25 gallons of product at one time.
Automatic shutoff devices must activate when the product in the tank reaches 95
percent of the tank capacity or before the fittings at the top of the tank are exposed
to product.
There must not be anything in the fill pipe that would keep the shutoff mechanism
from working properly.
The automatic shutoff device must be placed so the float arm is not blocked and
can move through its full range of motion.
A qualified LIST contractor should periodically check your automatic shutoff device to
make sure it is functioning properly.
You should inform your delivery person you have an automatic shutoff device.
• You could place a durable sign near each fill pipe. The sign should be in clear
view of the delivery person. It should say there is an automatic shutoff device
for this tank, what occurs when the device activates, and indicate the necessary
actions to take. See the sample sign in appendix G as a reference.
You should not use an automatic shutoff device for overfill protection if your tank
receives pressurized deliveries because it might create dangerous situations (such
as pressure building up in the tank) and result in gasoline spraying onto the delivery
person or into the environment.
Chapter 4
32 Section 4.3
-------
Overfill Protection Checklist For USTs With Automatic Shutoff Devices
Circle the LIST number for each LIST that has an
automatic shutoff device. Answer the questions
below for each LIST you circled.
UST# =
Questions
Circle Yes (Y) or No (N)
1. Is your LIST ever filled with more than 25 gallons of product
at one time?
If you answered yes for an LIST, you must answer the remaining questions in this checklist for that
UST.
If you answered no for an UST, you are not required to have an overfill device. This UST is in
compliance with the overfill requirements. Skip question 2 below.
2. Does your automatic shutoff device properly activate at 95
percent of tank capacity or before the fittings at the top of the
tank are exposed to product?
If no, then to return to compliance: Have a qualified person adjust your automatic shutoff device to
properly activate at 95 percent of the tank capacity or before the fittings at the top of the tank are
exposed to product.
Summary Of Compliance With Automatic Shutoff Devices
Answer the following question:
Yes
No
Are all of your USTs with automatic shutoff devices in compliance with overfill
protection?
To answer yes here, you must have either:
a) answered yes to all questions above, or
b) answered no to question 1 above.
If you answered no, fill out a return to compliance plan and submit it with your certification of compliance.
A return to compliance plan form is in appendix B.
33
Chapter 4
Section 4.3
-------
4.3.3 Ball Float Valves
The ball float valve (also called a flow vent valve) is installed at the vent line in
the tank. The valve restricts vapor flow from the LIST as the tank gets close to
full. As the tank fills, the ball in the valve rises, restricting the flow of vapors out
of the LIST during delivery. The flow rate of the delivery will decrease noticeably
and should alert the person responsible for monitoring the delivery to stop the
delivery.
Requirements And Best Management Practices For Ball Float Valves
You must have overfill protection (for example, a ball float valve) for every LIST that
is filled with more than 25 gallons of product at one time.
Ball float valves must begin restricting vapor flow out of the tank when product in the
tank reaches 90 percent of tank capacity or at least 30 minutes before the tank will
be overfilled. For ball float valves to work properly:
• the air hole in the ball float valve must be open,
• the ball cage must be intact,
• the ball must move freely in the cage,
• the ball must seal tightly on the pipe, and
• the top of the tank must be air tight during delivery so vapors cannot escape from
the tank. Everything in the tank (such as other tank access ports, fittings, and
drain mechanisms on spill buckets) must be tight and able to hold the pressure
created when the ball float valve engages.
A qualified LIST contractor should periodically check your ball float valve to make
sure it is functioning properly.
You should inform your delivery person you have a ball float valve.
• You could place a durable sign near each fill pipe. The sign should be in clear
view of the delivery person. It should say there is a ball float valve for this tank,
what occurs when the device activates, and indicate the necessary actions to
take. See the sample sign in appendix G as a reference.
You should not use a ball float valve for overfill protection if any of the following
conditions apply because you could create overfills or dangerous situations (such as
pressure building up in the tank) and result in gasoline spraying onto the delivery
person or into the environment.
Do not use ball float valves if:
• Your LIST receives pressurized deliveries
• Your LIST has suction piping
• Your LIST has coaxial stage I vapor recovery
34
Chapter 4
Section 4.3
-------
Overfill Protection Checklist For USTs With Ball Float Valves
Circle the LIST number for each LIST that has a
ball float valve. Answer the questions below for
each LIST you circled.
UST# =
Questions
Circle Yes (Y) or No (N)
1. Is your LIST ever filled with more than 25 gallons of product
at one time?
If you answered yes for an LIST, you must answer the remaining questions in this checklist for that
UST.
If you answered no for an UST, you are not required to have an overfill device. This UST is in
compliance with the overfill requirements. Skip question 2 below.
2. Does your ball float valve slow the flow of product when the
tank is 90 percent full or at least 30 minutes before the tank
will be overfilled?
If no, then to return to compliance: Have a qualified person adjust your ball float valve to the right
height so it restricts flow at 90 percent of tank capacity or at least 30 minutes before the tank will be
overfilled.
Summary Of Compliance With Ball Float Valves
Answer the following question:
Yes
No
Are all of your USTs with ball float valves in compliance with overfill protection?
To answer yes here, you must have either:
a) answered yes to all questions above, or
b) answered no to question 1 above.
If you answered no, fill out a return to compliance plan and submit it with your certification of compliance.
A return to compliance plan form is in appendix B.
35
Chapter 4
Section 4.3
-------
4.3.4 No Overfill Protection
Requirements And Best Management Practices For USTs With No Overfill Protection
An LIST that is never filled with deliveries of more than 25 gallons of product at one time
does not need overfill protection. You must have overfill protection for every
LIST that is filled with more than 25 gallons of product at one time.
Consider using overfill protection for USTs that never receive deliveries of more than
25 gallons of product at one time. Overfill protection is part of good LIST system
management.
Chapter 4
36 Section 4.3
-------
Overfill Protection Checklist For USTs Without Overfill Protection
Circle the LIST number for each LIST that does
not have overfill protection. This means the LIST
does not have an overfill alarm, automatic
shutoff device, or ball float valve. Answer the
questions below for each LIST you circled.
UST# =
Question
1. Does each LIST circled above only receive product in
amounts of 25 gallons or less?
1
2
3
4
5
Circle Yes (Y) or No (N
If no, then to return to compliance: Have a qualified person properly install an
device.
overfill
protection
Summary Of Compliance For USTs With No Overfill Protection
Answer the following question:
Are all of your USTs with no overfill protection in compliance?
To answer yes here, you must have answered yes to the question above.
Yes
No
If you answered no, fill out a return to compliance plan and submit it with your certification of compliance.
A return to compliance plan form is in appendix B.
37
Chapter 4
Section 4.3
-------
Summary Of Compliance With Overfill Protection
Make sure you read and complete the checklists in the appropriate overfill protection
sections for all of your USTs before answering the question below.
Summary Of Compliance With Overfill Protection
Answer the following question:
Yes
No
Are all of your USTs in compliance with overfill protection?
To answer yes here, you must have answered yes to all summary questions for each overfill
protection device you use for compliance at your facility.
If you answered no, complete and submit a return to compliance plan addressing each area of non-compliance.
A return to compliance plan form is in appendix B.
(Copy your yes or no answer to question 3 of the certification of compliance form in appendix A)
38
Chapter 4
Section 4.3
-------
Section 4.4: Corrosion Protection For Tanks
All of your regulated tanks that are underground and routinely contain product
must be protected from corrosion.
You can protect your underground tanks from corrosion in several ways. Your tanks
may be:
made of fiberglass reinforced plastic (FRP),
steel that is coated and cathodically protected,
steel that is jacketed or clad with a non-corrodible material (such as fiberglass),
steel that is cathodically protected and/or internally-lined (this option is only allowed
for older tanks installed on or before December 22, 1988), or
metal without additional corrosion protection (if specific criteria are met).
Internal lining and cathodic protection require periodic operation and
maintenance activities.
All underground tanks installed after December 22, 1988 need to meet all
appropriate construction standards and must be installed according to a standard
code of practice and manufacturer's instructions.
All tanks must be made of or lined with materials that are compatible with the
substance stored in the LIST.
Keep all paperwork related to your corrosion protected tanks (examples include
paperwork related to: installation, cathodic protection, integrity assessment, repair,
and internal lining).
Directions For Completing The Corrosion Protection For Tanks Section
Step 1: Fill out the table on the next page to identify the type of tank you have for each
UST.
If you have compartmentalized tanks, treat each compartment as a separate UST.
If you have manifolded tanks, treat each tank as a separate UST.
Step 2: For each type of tank you checked in the table, go to the corresponding section
listed in the far-right column. Read the requirements and best management
practices and fill out the appropriate checklist(s) in that section. You may need to
go to more than one section and fill out more than one checklist - each tank type
has a separate checklist.
Step 3: Once you have completed the checklists for all of your tank types, turn to the last
page of this section and complete the question that summarizes your compliance
with tank corrosion protection.
Chapter 4
39 Section 4.4
-------
Identifying The Types Of Tanks You Have
Identify the type of tank you have for each LIST in the table below and proceed as instructed
in the far-right column.
If you do not know the types of tanks you have, read the information below the table to
help you.
Choose the type of tank you have for each LIST by checking the
appropriate boxes
Go to these sections for
information and
compliance checklists
Fiberglass Reinforced Plastic (FRP) Tank
Section 4.4.1
Jacketed Steel Tank
Section 4.4.1
Clad Steel Tank
Section 4.4.1
Coated And Cathodically Protected Steel Tank
Section 4.4.2
Cathodically Protected Steel Tank
Section 4.4.3
Internally-Lined Steel Tank
Section 4.4.4
Internally-Lined And Cathodically Protected Steel Tank
Section 4.4.5
Metal Tank With No Additional Corrosion Protection
Section 4.4.6
If your tank type is not listed above, contact {state} to determine what you must do.
Take the following steps to figure out what is at your facility.
Read the descriptions below to determine which tank types you have.
Look through your old records to see if you have tank installation information. Check for the
names of the tank types.
• Ask the contractor who installed your tank.
Tank Type Descriptions
Fiberglass Reinforced Plastic (FRP) Tank - This tank is made of fiberglass reinforced plastic.
Examples of current and past FRP tank makers include Owens Corning, Xerxes, Cardinal, Fluid
Containment, and Containment Solutions.
Jacketed Steel Tank - This is a steel tank that is encapsulated (or jacketed) in a non-
corrodible, nonmetallic material such as fiberglass or polyethylene. This tank is secondarily
contained. There is a space between the steel wall and the jacket material. This space may be
monitored for a breach of either the inner wall or outer jacket. Examples of jacketed tank
brands include: Permatank®, Glasteel II®, Titan®, Total Containment®, and Elutron®
Clad Steel Tank - This tank is a steel tank that has a thick layer of non-corrodible material such
as fiberglass or urethane that is mechanically bonded (clad) to the outside of the steel tank.
This cladding helps protect the outside of the steel wall from corroding. Examples of clad tank
brands include: ACT-100®, ACT-100-U®, Glasteel®, and Plasteel®
40
Chapter 4
Section 4.4
-------
Coated And Cathodically Protected Steel Tank - This is a steel tank that has both an external
coating and cathodic protection. An example of a coated and cathodically protected tank brand
is the sti-P3® tank. This type of tank is usually installed with galvanic (sacrificial) anodes for
cathodic protection. However, these tanks may have an impressed current cathodic protection
system if the galvanic (sacrificial) anodes no longer protect the tank from corrosion. If you are
not sure whether you have a cathodic protection system, see the Determining If You
Have Cathodic Protection section below.
Cathodically Protected Steel Tank - This is a steel tank that has a cathodic protection system
but does not have an external coating. Typically, this type of tank was originally installed as a
bare steel tank before December 22, 1988 and had cathodic protection installed at some later
date. Tanks installed after December 22, 1988 are required to be both coated and cathodically
protected. Usually this type of tank will have an impressed current cathodic protection system.
If you are not sure whether you have a cathodic protection system, see the Determining If
You Have Cathodic Protection section below.
Internally-Lined Steel Tank - This is a steel tank with an internal lining. Typically, this type of
tank was originally installed as a bare steel tank before December 22, 1988 and had an internal
lining installed at some later date.
Internally-Lined And Cathodically Protected Steel Tank - This is a steel tank that has both
an internal lining and cathodic protection. Typically, this type of tank was originally installed as
a bare steel tank before December 22, 1988 and had cathodic protection and internal lining
installed at some later date. Usually this type of tank will have an impressed current cathodic
protection system. If you are not sure whether you have a cathodic protection system, see
the Determining If You Have Cathodic Protection section below.
Metal Tank With No Additional Corrosion Protection - This is a tank made of metal such as
steel or copper. It does not have cathodic protection, internal lining, or any non-corrodible
material that encapsulates or bonds to the outside of the tank.
Determining If You Have Cathodic Protection - There are two types of cathodic protection
systems commonly used to protect your steel tank from corrosion - impressed current and
galvanic (sacrificial) anodes.
Impressed Current System - If you have an
impressed current system, you will have a rectifier
(a device for converting alternating current into
direct current) located somewhere at your facility.
I
Sample Rectifier
Galvanic (Sacrificial) Anode System - It is more
difficult to tell if you have this type of cathodic protection system
because the anodes are buried and attached to the tank. You cannot
see the anodes and there is no rectifier. Look at any installation
paperwork you have or ask the contractor who installed the tank or
cathodic protection system to determine if you have a galvanic
(sacrificial) anode system. For example, a sti-P3® tank commonly uses
a galvanic (sacrificial) anode system.
Sample Rectifier
41
Chapter 4
Section 4.4
-------
4.4.1: Fiberglass Reinforced Plastic Tanks, Jacketed Steel Tanks, And Clad Steel
Tanks
Fiberglass reinforced plastic (FRP) tanks, jacketed steel tanks, and clad steel
tanks meet the corrosion protection requirements without additional equipment
or operation and maintenance.
Best Management Practices For Fiberglass Reinforced Plastic Tanks
Have your fiberglass reinforced plastic tanks
periodically checked for deflection (deflection is a
measure of the roundness of your tank). Since
these tanks are made from materials considered to
be sensitive to flexing, over deflection may result in
cracking and a leak. Allowable deflections vary
with tank diameters and may be measured by
following the manufacturer's installation checklist.
Sample FRP Tank
Best Management Practices For Jacketed Steel Tanks
Have your jacketed steel tanks periodically tested by a qualified contractor to make sure
the space between the steel tank and secondary jacket is tight. This space is known as
the interstitial space or secondary
containment area. If your primary
tank wall would leak and the
secondary containment jacket was
not tight, a release could get into the
environment and result in cleanup
that could be costly and time-
consuming.
Multi-layer FRP
outer wall
Standoff mpsii
and mylar
~~~~ Inner steel tank
Sample Piece Of A Jacketed Tank
Best Management Practices For Clad Steel Tanks
Some clad steel tanks may also have cathodic
protection. If you have clad steel tanks that have
cathodic protection, then consider having your cathodic
protection system tested periodically to make sure it is
operating properly.
Sample Clad Tank
42
Chapter 4
Section 4.4
-------
Corrosion Protection Checklist For Fiberglass Reinforced Plastic Tanks, Jacketed Steel
Tanks, And Clad Steel Tanks
Circle the LIST number for each clad steel tank,
jacketed steel tank, or fiberglass reinforced
plastic tank.
UST# =
1
2
3
4
5
There are no corrosion protection questions for fiberglass reinforced plastic tanks, jacketed
steel tanks, and clad steel tanks
Fiberglass reinforced plastic tanks, jacketed steel tanks, and clad steel tanks are in compliance with
corrosion protection requirements.
Summary Of Compliance With Corrosion Protection For Fiberglass Reinforced Plastic, Jacketed
Steel, And Clad Steel Tanks
Answer the following question:
Do your fiberglass reinforced plastic tanks, jacketed steel tanks, and clad steel
tanks meet the corrosion protection requirements?
Yes
• •
No
43
Chapter 4
Section 4.4
-------
4.4.2: Coated And Cathodically Protected Steel Tanks
This type of tank has both a coating and cathodic protection on the outside wall
of the tank. The coating is typically applied to the tank at the factory. The
cathodic protection may be either impressed current or galvanic (sacrificial)
anodes. See section 4.4.3 if you have a steel tank that is cathodically
protected but is not coated.
Requirements For Coated And Cathodically Protected Steel Tanks
The coating must be made of a suitable dielectric material (a material that isolates
the tank from the surrounding soil and does not conduct electricity). Coal tar epoxy,
urethane, and isophthalic polyester resins are examples of generic types of coatings
used on coated and cathodically protected steel tanks.
You must comply with specific testing and record keeping requirements for cathodic
protection. Descriptions of cathodic protection, requirements and best management
practices, and checklists for cathodic protection are in section 4.6. Before
completing the checklist on the next page, you will need to read the cathodic
protection section and fill out the checklists in that section.
An example of a commonly used coated and cathodically protected steel tank is the sti-P3®
tank. This tank has a dielectric coating on the outside and has galvanic (sacrificial) anodes
attached to the outside of the tank. You may have had impressed current added to your sti-PS18
tank at some time in the past - this tank is still considered to be coated and cathodically
protected.
Sample Coated And Cathodically
Protected Tank
Chapter 4
44 Section 4.4
-------
Corrosion Protection Checklist
For Coated And Cathodically Protected Steel Tanks
Circle the LIST number for each steel tank that is
coated and cathodically protected. Answer the
questions below for each LIST you circled.
UST# =
1
Questions
Circle Yes (Y) or No (N)
1. Is your tank coated with a suitable dielectric material?
If you don't know whether your tank is coated with a suitable
dielectric material, try to determine if your tank is a sti-P3®tank or
determine if you meet the requirements for cathodically protected
steel tanks in section 4.4.3.
If no, then to return to compliance: Contact {state} to determine how you may return to compliance.
2. Do you meet the requirements for your cathodic protection
system? Complete section 4.6, Cathodic Protection to answer this
question. Copy the answer from the summary of compliance
question in section 4.6 to this table.
If no, then to return to compliance: You must take action to comply with the requirements in section
4.6, Cathodic Protection.
Summary Of Compliance With Corrosion Protection For Coated And Cathodically Protected
Steel Tanks
Answer the following question:
Yes
No
Do your coated and cathodically protected steel tanks meet corrosion protection
requirements?
To answer yes here, you must have answered yes to all questions above.
If you answered no, fill out a return to compliance plan and submit it with your certification of compliance.
A return to compliance plan form is in appendix B.
45
Chapter 4
Section 4.4
-------
4.4.3: Cathodically Protected Steel Tanks
r^ffmm—^ This type of tank has cathodic protection on the outside of the tank. There is
( J no coating (or no known coating) on this tank. The cathodic protection may
be either impressed current or galvanic (sacrificial) anodes. See section
4.4.2 if you have a steel tank that is coated and cathodically protected.
Requirements And Best Management Practices For Cathodically Protected Steel Tanks
Only steel tanks that were installed on or before December 22, 1988 may use cathodic
protection without a dielectric coating to comply with the corrosion protection
requirements. If you have a coated and cathodically protected steel tank, go to
section 4.4.2.
An integrity assessment of the tank must have been conducted before adding
cathodic protection. Examples of methods of integrity assessment of a steel tank
include:
• An internal inspection of the tank - a trained professional enters your tank to
determine if it is structurally sound and free of corrosion holes.
• A video camera inspection of the tank combined with checking soil
characteristics around the tank- the tank is emptied and a trained professional
places a video camera into the fill ports of a tank to determine if the tank has any
holes. The professional also takes some soil measurements to determine the
corrosive characteristics of the soil around your tank. All of the information is
used to determine whether the tank is structurally sound and free of corrosion
holes.
• A detailed site evaluation is performed at your facility - a trained professional
evaluates the site characteristics and places the information into a model that
statistically determines the time it would take a steel tank to corrode through at
that specific location. This information is compared to the age of the tank to
statistically determine whether the tank is structurally sound and free of corrosion
holes.
A code of practice must be followed when adding cathodic protection to a tank.
You must comply with specific testing and record keeping requirements for
cathodic protection. Descriptions of cathodic protection, requirements and best
management practices, and checklists for cathodic protection are in section 4.6.
Before completing the checklist on the next page, you will need to read the
cathodic protection section and fill out the checklists in that section.
Keep records of your integrity assessment and cathodic protection installation.
These records may be useful in determining whether your tank is in compliance with
the corrosion protection requirements.
Chapter 4
46 Section 4.4
-------
Corrosion Protection Checklist ForCathodically Protected Steel Tanks
Circle the LIST number for each steel tank that is
cathodically protected. Answer the questions
below for each LIST you circled.
UST# =
Questions
Circle the Yes (Y) or No (N)
1. Did the installation of this LIST begin on or before December
22,1988?
If no, then to return to compliance: Cathodic protection without a coating is not an option for meeting
the corrosion protection requirements for this tank. Contact {state} to determine how you may return to
compliance.
2. Did this tank pass an integrity assessment before cathodic
protection was installed?
If no, then to return to compliance: Contact {state} to determine how you may return to compliance.
3. Do you meet the requirements for your cathodic protection
system? Complete section 4.6, Cathodic Protection to answer this
question. Copy the answer from the summary of compliance
question in section 4.6 to this table.
If no, then to return to compliance: You must take action to comply with the requirements in section
4.6, Cathodic Protection.
Summary Of Compliance With Corrosion Protection For Cathodically Protected Steel Tanks
Answer the following question:
Yes
No
Do your cathodically protected steel tanks meet corrosion protection
requirements?
To answer yes here, you must have answered yes to all questions above.
If you answered no, fill out a return to compliance plan and submit it with your certification of compliance.
A return to compliance plan form is in appendix B.
47
Chapter 4
Section 4.4
-------
4.4.4: Internally-Lined Steel Tanks
nformation
This tank is made of steel and has a lining attached to the inside wall of the
tank. See section 4.4.5 if you have a steel tank that is internally-lined and
cathodically protected.
Requirements And Best Management Practices For Internally-Lined Steel Tanks
Only steel tanks that were installed on or before December 22, 1988 may use
internal lining alone to comply with the corrosion protection requirements.
If any repairs are performed when your tank is internally-lined, you must keep all
records of those repairs for the life of the tank.
A code of practice must be followed when adding an interior lining to a tank.
Within 10 years of lining, lined tanks must be internally inspected by a qualified
contractor and found to be structurally sound with the lining still performing in
accordance with original design specifications. After the initial 10 year inspection,
these inspections must be conducted at least every 5 years.
Keep records of your lining installation and lining inspections. These records
may be useful in determining whether your tank is in compliance with the corrosion
protection requirements.
Even though a tank that has internal lining is not required to have external corrosion
protection, you should consider adding cathodic protection as part of good LIST
system management. Note that if you add cathodic protection on your internally-lined
tank, you must meet the inspection and testing requirements in section 4.6.
Sample Of A Tank's Interior Being Lined
48
Chapter 4
Section 4.4
-------
Corrosion Protection Checklist For Internally-Lined Steel Tanks
Circle the LIST number for each steel tank that is
internally-lined. Answer the questions below for
each LIST you circled.
UST# =
Insert the date of your lining installation for each tank you
circled above (mm/dd/yy).
Questions
Circle Yes (Y) or No (N)
1. Did the installation for this LIST begin on or before
December 22,1988?
If no, then to return to compliance: Internal lining is not an option for meeting the corrosion protection
requirements for this tank. Contact {state} to determine how you may return to compliance.
2. Do you have all records of repairs for your lined tank?
If your lined tank has never been repaired, then answer yes to this
question - you will not have any repair records.
If no, then to return to compliance: Contact the inspector or repair company that worked on your tank
lining. Obtain a record of any repairs completed on your lined tank.
3. Was your lined tank inspected within 10 years of lining
installation and then every 5 years? If your tank was lined less
than 10 years ago and you have not had an inspection conducted,
this question does not apply. Skip this question.
If your lined tank has been inspected, insert the date of your
most recent inspection.
If no, then to return to compliance: Have a lining inspection conducted on your lined tank.
4. Did your lined tank pass its most recent inspection? If your
tank was lined less than 10 years ago and you have not had an
inspection conducted, this question does not apply. Skip this
question.
If no, then to return to compliance: Contact {state} to determine how you may return to compliance.
Summary Of Compliance With Corrosion Protection For Internally-Lined Steel Tanks
Answer the following question:
Do your internally-lined steel tanks meet corrosion protection requirements?
To answer yes here, you must have answered yes to all applicable questions above.
Yes
No
If you answered no, fill out a return to compliance plan and submit it with your certification of compliance.
A return to compliance plan form is in appendix B.
49
Chapter 4
Section 4.4
-------
4.4.5: Internally-Lined And Cathodically Protected Steel Tanks
nformation
This tank is made of steel, has a lining attached to the inside wall of the tank
and cathodic protection on the outside wall of the tank. The cathodic protection
may be either impressed current or galvanic (sacrificial) anodes.
Requirements And Best Management Practices For Internally-Lined And Cathodically
Protected Steel Tanks
Only steel tanks that were installed on or before December 22, 1988 may use the
combination of an internal lining and cathodic protection without a dielectric coating
to comply with the corrosion protection requirements. If you have a coated and
Cathodically protected steel tank, go to section 4.4.2.
When you combine the use of internal lining and cathodic protection, you must
meet specific testing and record keeping requirements for cathodic protection, which
are in section 4.6. Before completing the checklist on the next page, you will
need to read the cathodic protection section and fill out the checklists in that
section.
You must also meet the lining requirements in section 4.4.4. Before completing the
checklist on the next page, you will need to read the internally-lined steel tank
section and fill out the checklist in that section.
You do not need inspections of the lined tank if both of the following apply to your
lined and Cathodically protected tank:
• the integrity of the steel tank was ensured when cathodic protection was
installed, and
• the method of integrity assessment determined the steel tank shell was
structurally sound and free of corrosion holes.
Examples of integrity assessments are provided in section 4.4.3.
Have your internal lining checked periodically even if the inspections are not
required.
Keep records of your integrity assessment, lining, and cathodic protection
installations. These records may be useful in determining whether your tank is in
compliance with the corrosion protection requirements.
Chapter 4
50 Section 4.4
-------
Corrosion Protection Checklist
For Internally-Lined And Cathodically Protected Steel Tanks
Circle the LIST number for each steel tank that is
internally-lined and cathodically protected. Answer
the questions below for each LIST you circled.
UST# =
1
Questions
Circle Yes (Y) or No (N)
1. Do you meet the requirements for your cathodic protection
system? Complete section 4.6, Cathodic Protection to answer this
question. Copy the answer from the summary of compliance
question in section 4.6 to this table.
If no, then to return to compliance: You must take action to comply with the requirements in section
4.6, Cathodic Protection.
2. Did this tank pass an integrity assessment when cathodic
protection was installed?
Information about the integrity assessment is in section 4.4.3.
If yes, then answer question 4 for that tank (skip question 3).
If no, then answer question 3 for that tank (skip question 4).
3. Do you meet the lining requirements in section 4.4.4?
To answer yes here, you must be in compliance with all of the
lining requirements in section 4.4.4. Complete the internally-lined
tank checklist in section 4.4.4 before answering this question.
If no, then to return to compliance: You must take action to meet the requirements described in
section 4.4.4.
4. Do you meet the lining requirements for the first two
questions in section 4.4.4? To answer "Yes" here, you must be
able to answer yes to the first two questions in section 4.4.4.
If no, then to return to compliance: You must take action to meet the requirements described in
questions 1 and 2 of the checklist in section 4.4.4.
Summary Of Compliance With Corrosion Protection For Internally-Lined
And Cathodically Protected Steel Tanks
Answer the following question:
Yes
No
Do your internally-lined and cathodically protected steel tanks meet corrosion protection
requirements?
To answer yes here, you must have either:
a) answered yes to questions 1 and 3 above, or
b) answered yes to questions 1, 2, and 4 above.
If you answered no, fill out a return to compliance plan and submit it with your certification of compliance.
A return to compliance plan form is in appendix B.
51
Chapter 4
Section 4.4
-------
4.4.6: Metal Tanks With No Additional Corrosion Protection
Buried metal tanks with no additional corrosion protection are not commonly
used to meet the tank corrosion protection requirements. However, if your
tanks meet the criteria below, this option may be used.
Requirements For Metal Tanks With No Additional Corrosion Protection
If you have a regulated underground metal tank without additional corrosion
f protection, you must either:
have the record of a corrosion expert's determination that your LIST site is not
corrosive enough to cause the tank to have a release due to corrosion during
the operating life of the tank, or
have evidence to indicate {state} made a determination the tank construction and
corrosion protection were designed to prevent the release or threatened release
of any stored product.
It is unusual to have a metal tank without additional corrosion protection.
Chapter 4
52 Section 4.4
-------
Corrosion Protection Checklist
For Metal Tanks With No Additional Corrosion Protection
Circle the LIST number for each tank that is a
metal tank with no additional corrosion
protection. Answer the question below for each
LIST you circled.
UST# =
Question
1. Do you have a record or evidence a determination was
made either by a corrosion expert or the state LIST agency
that your metal tank will not have a release due to corrosion
during its operating life?
If you answered no, then to return to compliance: Contact {state}
to compliance.
1
2
3
4
5
Circle Yes (Y) or No (N)
to determine how you may return
Summary Of Compliance With Corrosion Protection For Metal Tanks
With No Additional Corrosion Protection
Answer the following question:
Yes
No
Do your metal tanks meet corrosion protection requirements?
To answer yes here, you must have answered yes to the question above.
If you answered no, fill out a return to compliance plan and submit it with your certification of compliance.
A return to compliance plan form is in appendix B.
53
Chapter 4
Section 4.4
-------
Summary Of Compliance With Tank Corrosion Protection
Make sure you read and complete the checklists in the appropriate tank corrosion protection
sections for all of your underground tanks before answering the question below.
Summary Of Compliance With Tank Corrosion Protection
Answer the following question:
Yes
No
Do all of your underground tanks meet corrosion protection requirements?
To answer yes here, you must have answered yes to all previous summary questions for each
type of tank at your facility.
If you answered no, complete and submit a return to compliance plan addressing each area of non-compliance.
A return to compliance plan form is in appendix B.
(Copy your yes or no answer to question 4 of the certification of compliance form in appendix A)
54
Chapter 4
Section 4.4
-------
Section 4.5: Corrosion Protection For Piping
All of your regulated piping that is in contact with the ground and routinely
contains product must be protected from corrosion - this piping is often
underground or buried. Note: fill pipes and vent lines do not usually need
corrosion protection because these components do not routinely contain product.
You can protect your piping from corrosion in several ways. It may be:
made of a non-corrodible material (such as fiberglass or flexible plastic),
steel that is coated and cathodically protected,
metal that is cathodically protected (this option is only allowed for older piping
that was installed on or before December 22, 1988), or
• metal without additional corrosion protection (if specific criteria are met).
Cathodic protection requires periodic operation and maintenance.
All of your piping that is in contact with the ground and routinely contains product that
was installed after December 22, 1988 needs to meet all appropriate construction
standards and be installed according to a standard code of practice and the
manufacturer's instructions.
All of your underground piping must be made of or lined with materials that are
compatible with the substance that is stored in the UST.
Keep all paperwork related to your corrosion protected piping (examples include
paperwork related to: installation, cathodic protection, and repair).
Directions For Completing The Corrosion Protection For Piping Section
Step 1: Fill out the table on the next page to identify the types of piping you have for each
UST.
Your UST may have different types of piping. For example, part of the
piping that goes from the tank to the dispenser may be made of
nonmetal and part of it may be made of metal. In addition, you may have
piping that goes from one tank to another (such as piping between
manifolded tanks). Make sure that you select all types of piping
associated with each UST.
Step 2: For each type of piping you checked in the table, go to the corresponding section
listed in the far-right column. Read the requirements and best management
practices and fill out the appropriate checklist(s) in that section. You may need to
go to more than one section and fill out more than one checklist - each piping type
has a separate checklist.
Step 3: Once you have completed the checklists for all of your piping types, turn to the last
page of this section and complete the question that summarizes your compliance
with piping corrosion protection.
Chapter 4
55 Section 4.5
-------
Identifying The Types Of Piping You Have
Identify the types of piping you have for each LIST in the table below and proceed as
instructed in the far-right column.
If you do not know the types piping you have, read the information below the table to help
you.
Choose the types of piping you have for each LIST by checking the
appropriate boxes.
UST Number:
Fiberglass Reinforced Plastic Piping
Flexible Plastic Piping
Coated And Cathodically Protected Steel Piping
Cathodically Protected Metal Piping
Metal Piping With No Additional Corrosion Protection
No Piping In Contact With The Ground
Go to these sections for
information and
compliance checklists
Section 4.5.1
Section 4.5.1
Section 4.5.2
Section 4.5.3
Section 4.5.4
No Requirements
If your piping type is not listed above, contact {state} to determine what you must do.
Take the following steps to figure out what is at your facility.
Read the descriptions below to determine which types of piping you have.
Look in your dispenser sumps and turbine sumps (these are areas under your dispenser
and above your tank where piping and other equipment are located) to see if you can
identify the piping. Some piping may have metal flexible connectors in these areas. Look
for the piping beyond the metal flexible connectors.
Look through your old records to see if they match any of the names in the descriptions.
• Ask the contractor who installed your piping.
Piping Type Descriptions
Fiberglass Reinforced Plastic (FRP) Piping - This piping is
nonmetal and is made of fiberglass reinforced plastic. It is a
rigid piping (not flexible). Examples of FRP piping makers
include Ameron and Smith Fiberglass Products Inc. This piping
type may also have metal connectors associated with it.
Sample FRP Piping
Coated And Cathodically Protected Steel Piping - This is steel piping that has both an
external coating and cathodic protection. If you are not sure whether you have a cathodic
protection system, see the Determining If You Have Cathodic Protection section on the
next page.
56
Chapter 4
Section 4.5
-------
Cathodically Protected Metal Piping - This is metal piping without an external coating that has
a cathodic protection system. Typically, this type of piping was originally installed as a bare
metal before December 22, 1988 and had cathodic protection installed at some later date.
Piping installed after December 22, 1988 must be both coated and cathodically protected. If
you are not sure whether you have a cathodic protection system, see the Determining If
You Have Cathodic Protection section below.
Metal Piping With No Additional Corrosion Protection - This is metal piping that does not
have any additional corrosion protection.
Flexible Plastic Piping - This type of piping is made of plastic that is flexible. Examples of
nonmetal flexible piping brand names include: Poly-Tech, Dualoy 3000, EnviroFlex, GeoFlex,
Perma-Flexx, Omniflex, and Co-Flex™. This piping type may also have metal connectors
associated with it.
Sample
Flexible
Piping
Sample Flexible Piping
In A Sump
Sample Flexible Piping
Sample Flexible Piping
Closeup Of Flexible Piping In A
Sump
Determining If You Have Cathodic Protection
There are two types of cathodic protection systems commonly used to protect your metal piping
from corrosion - impressed current and galvanic (sacrificial) anodes.
Impressed Current System - If you have an impressed current system, you will have a rectifier
(a device which converts alternating current into direct current) located somewhere at your
facility. Sample pictures of rectifiers are provided in section 4.4.
Galvanic (Sacrificial) Anode System - It is more difficult to tell if you have this type of cathodic
protection system because the anodes are buried and attached to the piping. You cannot see
them and there is no rectifier. Look at any installation paperwork you have or contact the
contractor who installed the piping or cathodic protection system to try to determine if you have
a galvanic (sacrificial) anode system.
57
Chapter 4
Section 4.5
-------
4.5.1: Fiberglass Reinforced Plastic Piping And Flexible Plastic Piping
( Fiberglass reinforced plastic (FRP) piping and flexible plastic piping are
^-^•••^— made of non-corrodible materials and both meet the corrosion protection
requirements without additional equipment or operation and maintenance.
However, these types of piping may have metal joints and connectors that are in
contact with the ground and routinely contain product. These metal components
must be protected from corrosion.
Requirements For Fiberglass Reinforced Plastic (FRP) Piping And Flexible Plastic Piping
Any metal piping components associated with these types of piping that are in
contact with the ground and routinely contain product, such as turbine pump heads,
metal flexible connectors, and metal swing joints must be protected from corrosion
by one of the following:
Isolating the metal component from direct contact with the ground (for example:
by putting a protective covering or boot on a flexible connector or by moving the
soil so it is not in contact with the metal component).
Cathodically protecting metal components in contact with the ground. If you
cathodically protect the metal component, you must meet the cathodic protection
requirements in section 4.6. Before completing the checklist on the next
page, you will need to read the cathodic protection section and fill out the
checklists in that section.
Chapter 4
58 Section 4.5
-------
Corrosion Protection Checklist For Fiberglass Reinforced
Plastic Piping And Flexible Plastic Piping
Circle the LIST number for each LIST that has
FRP or flexible plastic piping. Answer the
questions below for each LIST you circled.
UST# =
1
Questions
Circle Yes (Y) or No (N)
1. Are all of your buried metal piping components associated
with your fiberglass reinforced plastic piping or flexible plastic
piping isolated so that no metal is in contact with the soil (for
example, your metal piping components may have a protective
covering or are not in contact with the ground)? If you have no
metal piping components, answer yes to this question.
For each LIST for which you answered yes to this question, skip questions 2 and 3. That LIST is in
compliance with piping corrosion protection.
For each LIST for which you answered no to this question, proceed to question 2 and answer it.
2. Are all of your buried metal components associated with
your fiberglass reinforced plastic piping or flexible plastic
piping cathodically protected?
If you answered no to both questions 1 and 2 for a given LIST, then to return to compliance: Have
your metal piping components isolated from the soil, cathodically protected, or have the soil removed so
they are no longer in contact with the ground.
3. Do you meet the requirements for your cathodic protection
system? Complete section 4.6, Cathodic Protection to answer this
question. Copy the answer from the summary of compliance
question in section 4.6 to this table.
If no, then to return to compliance: You must take action to comply with the requirements in section
4.6, Cathodic Protection.
Summary Of Compliance With Corrosion Protection For Fiberglass Reinforced
Plastic And Flexible Plastic Piping
Answer the following question:
Yes
No
Does your fiberglass reinforced plastic piping or flexible plastic piping (and any
associated metal piping components) meet corrosion protection requirements?
To answer yes here, you must have either:
a) answered yes to question 1 above, or
b) answered yes to questions 2 and 3 above.
If you answered no, fill out a return to compliance plan and submit it with your certification of compliance.
A return to compliance plan form is in appendix B.
59
Chapter 4
Section 4.5
-------
4.5.2: Coated And Cathodically Protected Steel Piping
( ^ This type of piping has a coating on the outside of the piping and cathodic
^-^••••••J protection on the outside of the piping. Cathodic protection may be either
impressed current or galvanic (sacrificial) anodes. See section 4.5.3 if you
have metal piping that is cathodically protected but is not coated.
Requirements For Coated And Cathodically Protected Steel Piping
The coating is on the outside of the piping and must be made of a suitable dielectric
material (a material that isolates the piping from the surrounding soil and does not
conduct electricity).
Make sure that metal piping components such as pump heads, flexible connectors
and swing joints are either isolated from the soil or are cathodically protected.
You must comply with specific testing and record keeping requirements for cathodic
protection. Descriptions of cathodic protection, requirements and best management
practices, and checklists for cathodic protection are in section 4.6. Before
completing the checklist on the next page, you will need to read the cathodic
protection section and fill out the checklists in that section.
Chapter 4
60 Section 4.5
-------
Corrosion Protection Checklist For Coated And
Cathodically Protected Steel Piping
Circle the LIST number for each LIST that has
coated and cathodically protected steel piping.
Answer the questions below for each LIST you
circled.
UST# =
1
Questions
Circle Yes (Y) or No (N)
1. Is your piping coated with a suitable dielectric material?
If you don't know whether your piping is coated with a suitable
dielectric material, see if you can meet the requirements for
cathodically protected metal piping in section 4.5.3.
If no, then to return to compliance: Contact {state} to determine how you may return to compliance.
2. Are all of your buried steel piping and metal components
cathodically protected?
If no, then to return to compliance: Contact {state} to determine how you may return to compliance.
3. Do you meet the requirements for your cathodic protection
system? Complete section 4.6, Cathodic Protection to answer this
question. Copy the answer from the summary of compliance
question in section 4.6 to this table.
If no, then to return to compliance: You must take action to comply with the requirements in section
4.6, Cathodic Protection.
Summary Of Compliance With Corrosion Protection For Coated
And Cathodically Protected Steel Piping
Answer the following question:
Yes
No
Does your coated and cathodically protected steel piping meet corrosion
protection requirements?
To answer yes here, you must have answered yes to all questions above.
If you answered no, fill out a return to compliance plan and submit it with your certification of compliance.
A return to compliance plan form is in appendix B.
61
Chapter 4
Section 4.5
-------
4.5.3: Cathodically Protected Metal Piping
This type of piping is metal with cathodic protection on the outside of the
piping. There is no coating (or no known coating) on this piping. Cathodic
protection may be either impressed current or galvanic (sacrificial) anodes.
See section 4.2 if you have steel piping that is coated and cathodically
protected.
Requirements For Cathodically Protected Metal Piping
Only metal piping that was installed on or before December 22, 1988 may use cathodic
protection without a dielectric coating to comply with the corrosion protection
requirements.
Make sure that metal piping components such as pump heads, flexible connectors
and swing joints are either isolated from the soil or are cathodically protected.
You must comply with specific testing and record keeping requirements for cathodic
protection. Descriptions of cathodic protection, requirements and best management
practices, and checklists for cathodic protection are in section 4.6. Before
completing the checklist on the next page, you will need to read the cathodic
protection section and fill out the checklists in that section.
Chapter 4
62 Section 4.5
-------
Corrosion Protection Checklist For Cathodically Protected Metal Piping
Circle the LIST number for each LIST that has
cathodically protected metal piping. Answer the
questions below for each LIST you circled.
UST# =
Questions
Circle Yes (Y) or No (N)
1. Did the installation for this LIST begin on or before
December 22,1988?
If no, then to return to compliance: Cathodic protection without a coating is not an option for
corrosion protection on this piping. Contact {state} to determine how you may return to compliance.
2. Are all of your buried metal piping and metal components
cathodically protected?
If no, then to return to compliance: Contact {state} to determine how you may return to compliance.
3. Do you meet the requirements for your cathodic protection
system? Complete section 4.6, Cathodic Protection to answer this
question. Copy the answer from the summary of compliance
question in section 4.6 to this table.
If no, then to return to compliance: You must take action to comply with the requirements in section
4.6, Cathodic Protection.
Summary Of Compliance With Corrosion Protection For Cathodically Protected Metal Piping
Answer the following question:
Yes
No
Does your cathodically protected metal piping meet corrosion protection
requirements?
To answer yes here, you must have answered yes to all questions above.
If you answered no, fill out a return to compliance plan and submit it with your certification of compliance.
A return to compliance plan form is in appendix B.
63
Chapter 4
Section 4.5
-------
4.5.4: Metal Piping - No Additional Corrosion Protection
( "I Metal piping that routinely contains product and is in contact with the ground
and has no additional corrosion protection is not commonly used to meet the
piping corrosion protection requirements. However, if your piping meets the
requirements below, this option may be used.
Requirements For Metal Piping With No Additional Corrosion Protection
If you have metal piping without additional corrosion protection and the piping is in
contact with the ground and routinely contains product, you must either:
have the record of a corrosion expert's determination that your LIST site is not
corrosive enough to cause the piping to have a release due to corrosion during
the operating life of the piping, or
have evidence to indicate {state} made a determination that the piping
construction and corrosion protection was designed to prevent the release or
threatened release of any stored product.
It is unusual to have metal piping without additional corrosion protection.
Chapter 4
64 Section 4.5
-------
Corrosion Protection Checklist
For Metal Piping Without Additional Corrosion Protection
Circle the LIST number for each LIST that has
metal piping with no additional corrosion
protection. Answer the questions below for
each LIST you circled.
UST# =
Question
1 . Do you have a record or evidence that a determination was
made either by a corrosion expert or the state LIST agency that
your buried metal piping will not have a release due to
corrosion during its operating life?
If no, then to return to compliance: Contact {state} to determine ho
1
2
3
4
5
Circle Yes (Y) or No (N)
w you may return to compliance.
Summary Of Compliance With Piping Corrosion Protection For Metal Piping Without Additional
Corrosion Protection
Answer the following question:
Yes
No
Does your metal piping without additional corrosion protection meet corrosion
protection requirements?
To answer yes here, you must have answered yes to the question above.
If you answered no, fill out a return to compliance plan and submit it with your certification of compliance.
A return to compliance plan form is in appendix B.
65
Chapter 4
Section 4.5
-------
Summary Of Compliance With Piping Corrosion Protection
Make sure you read and complete the checklists in the appropriate corrosion protection for
piping sections for all of your piping in contact with the ground and routinely contains
product before answering the question below.
Summary Of Compliance With Piping Corrosion Protection
Answer the following question:
Yes
No
Does all of your piping that is in contact with the ground and routinely contains
product meet corrosion protection requirements?
To answer yes here, you must have answered yes to all previous summary questions for each
type of piping at your facility.
If you answered no, complete and submit a return to compliance plan addressing each area of non-compliance.
A return to compliance plan form is in appendix B.
(Copy your yes or no answer to question 5 of the certification of compliance form in appendix A)
66
Chapter 4
Section 4.5
-------
Section 4.6: Cathodic Protection
Cathodic protection is one option for meeting the corrosion protection
requirements for metal tank and piping components that are in contact with the
ground and routinely contain product. Components of your LIST that may have
cathodic protection include: metal tanks, piping, and piping components such as
turbine pump heads, flexible connectors, and swing joints.
There are two types of cathodic protection: impressed current and galvanic (or
sacrificial) anodes. They are described later in this section.
Directions For Completing The Cathodic Protection Section
Only complete this section if you are directed to do so by sections 4.4 or 4.5. If you
are not required to use cathodic protection to meet corrosion protection requirements
skip this section.
Step 1: Fill out the table on the next page to identify the type of cathodic protection you
use for each tank and piping run.
Step 2: Go to section 4.6.1 and read the requirements and best management practices
and fill out the appropriate checklist in that section. If you have an impressed
current cathodic protection system, you will be directed to complete section 4.6.2.
Answer the questions in the checklists for both the tank and piping for each
LIST that has cathodic protection.
For example, a facility has a tank with impressed current cathodic protection
and piping that is fiberglass with a buried metal flexible connector with a
galvanic (sacrificial) anode. This LIST uses both an impressed current
system and a galvanic (sacrificial) anode system for cathodic protection.
For this example the reader would complete section 4.6.1 for both the tank
and piping. If the answer to a question in the checklist is no for either
cathodic protection system (the system for the tank or the system for the
piping) then the answer to that question will be no. Since the tank has an
impressed current system, the reader will also complete section 4.6.2 for the
tank.
Step 3: Once you have completed the checklists for each LIST, go to the Summary Of
Compliance With Cathodic Protection on the last page of this section and answer
that question. This is the answer you will use for checklists in sections 4.4 and
4.5.
Chapter 4
67 Section 4.6
-------
Identifying The Type(s) Of Cathodic Protection You Use For Your Tanks And Piping
Identify the type of cathodic protection you use for each tank and piping run in the table below
and proceed as instructed in the far right column. Include buried metal piping components
such as turbine pump heads, flexible connectors, and swing joints with the piping.
If you do not know the type(s) of cathodic protection you use, read the information on
the next page to help you.
Choose the type of cathodic protection you use for each tank and piping
run by checking the appropriate boxes.
Go to these sections for
information and
compliance checklists
Tank - Galvanic Anodes
Section 4.6.1
Tank- Impressed Current
Sections 4. 6.1 and 4.6.2
Piping - Galvanic Anodes
Section 4.6.1
Pipina - Impressed Current
Sections 4. 6.1 and 4.6.2
Take the following steps to figure out what types of cathodic protection you use at your
facility.
Read the descriptions on the next page to determine the types of cathodic protection you
use.
Look through your old records to see if they match any of the names in the descriptions.
• Ask the contractor who installed your cathodic protection system.
68
Chapter 4
Section 4.6
-------
Cathodic Protection Descriptions
Impressed Current Systems
An impressed current system uses a rectifier (a device for converting alternating current into
direct current) to provide direct current through anodes to the metal tank, piping, or other
underground components to achieve corrosion protection. The diagram below illustrates
impressed current cathodic protection.
How to tell if you have an impressed current system: You should have a rectifier located
somewhere at your facility. Impressed current cathodic protection systems are typically
installed in the field.
Grade
Current Path
Sample Impressed Current System Diagram
Sample Rectifier
Galvanic (Sacrificial) Anode Systems
A galvanic (sacrificial) anode system uses anodes that are buried and attached to metal LIST
components for corrosion protection. The anode is more electrically active and will sacrifice
itself (corrode) to protect the metal component from corrosion. A sample picture of an anode
attached to a tank is shown on the right.
How to tell if you have a galvanic (sacrificial)
anode system: It is more difficult to tell if you
have a galvanic anode system because you
typically cannot see the anodes and there is no
rectifier. The anodes are attached to the
underground component they are protecting and
are buried. These anodes are usually installed
on tanks at the factory (such as on the sti-P3®
tank) and can be installed on piping and other
underground metal components in the field. In
order to determine whether you have a galvanic
system, look at any installation paperwork you
might have or contact the contractor who
installed the cathodic protection system.
Sample Galvanic (Sacrificial) Anode
69
Chapter 4
Section 4.6
-------
4.6.1: Galvanic Anode And Impressed Current Cathodic Protection
Requirements And Best Management Practices For All Cathodic Protection Systems
Your cathodic protection system must operate continuously to protect the metal
tank and piping components in direct contact with the ground.
If your cathodic protection system is disconnected or turned off, your
underground LIST components are not protected from corrosion.
Never turn off your rectifier and never disconnect a galvanic anode,
unless contractors need to turn off or disconnect your cathodic protection for
short periods during testing or for repairs.
All cathodic protection systems installed in the field must be designed by a
corrosion expert. Field installed means the cathodic protection system was not
installed when the tank or piping was in the factory. An example of a tank that has
a factory installed cathodic protection system is the sti-P3® tank.
A corrosion expert must meet specific qualifications. That person must be either:
Certified by the NACE International, The Corrosion Society as a Corrosion Specialist or
Cathodic Protection Specialist, or
a registered Professional Engineer who has certification or licensing that includes
education and experience in corrosion control of buried or submerged metal piping
systems and metal tanks.
You must follow a code of practice when adding a cathodic protection system to your
tank or piping.
You must have your cathodic protection system tested periodically to make sure it is
working properly. The test must be conducted by a qualified cathodic protection
tester within six months of installation and then at least every three years. In
addition, if you have any repairs conducted to your cathodically-protected LIST, you
must have a cathodic protection test conducted within six months of that repair.
• You must keep records of the last two cathodic protection tests. A sample
cathodic protection test record is in appendix H.
If your cathodic protection system does not pass the test, have your cathodic
protection system evaluated and fixed by a corrosion expert. Keep all records of
the corrosion expert's evaluation and repairs to your cathodic protection system.
A cathodic protection tester is a person who can demonstrate an understanding of the
principles of all common types of cathodic protection systems as applied to buried or
submerged metal piping and tank systems.
Keep all paperwork related to your cathodic protection system.
Have cathodic protection tests conducted more frequently. The more often you have
these tests conducted, the more likely you are to detect cathodic protection problems
before releases occur.
Chapter 4
70 Section 4.6
-------
Checklist For All Cathodic Protection Systems
Circle the LIST number for each LIST that has any
cathodic protection system on either the tank or
piping. Answer the questions below for each LIST
you circled.
UST# =
Questions
1 . Does your cathodic protection system operate
continuously?
1
2
3
4
5
Circle Yes (Y) or No (N)
Answer yes to this question if you never disconnect your galvanic anodes and you never turn off your rectifier, or if
the only time this occurs is for short periods when a contractor tests or repairs your cathodic protection system.
If no, then to return to compliance: Contact {state} to determine how to return to compliance.
2. Was your cathodic protection system either designed by a
corrosion expert or installed at the factory?
If no, then to return to compliance: Contact {state} to determine how you may return to compliance.
3. Do you have the required records of your cathodic
protection tests? These tests are required within six months of
installation, at least every three years thereafter, and within six
months following any repairs to your LIST.
Answer yes to this question if one of the following apply:
• You have the records of your two most recent cathodic protection tests that meet the time criteria for testing.
• Your cathodic protection system was installed less than three and a half years ago, you have one record, and
no repairs have been performed on the LIST. This record will be for the test conducted within six months of
installation and less than three years have passed since that test.
• Your cathodic protection system was installed less than six months ago and you have no records. Don't forget
to have a test performed within six months of installation or repair.
If you had a cathodic protection test conducted, enter the date
of your most recent test (mm/dd/yy).
If no, then to return to compliance: Contact the person who performed your cathodic protection tests and obtain
records of your cathodic protection testing or begin having cathodic protection tests conducted and keep the
records.
4. Does your most cathodic protection test record indicate that
your cathodic protection system passed? Review your most
recent test record to determine if your cathodic protection passed.
Answer yes to this question if you have not yet had a cathodic
protection test conducted.
If no, then to return to compliance: Have a corrosion expert evaluate your cathodic protection system and fix
any problems as soon as possible. Also have a cathodic protection test conducted within six months of the repair
and make sure the cathodic protection system passes the test.
If you have an impressed current cathodic protection system, read the information and
complete the checklist on the next two pages.
If you have galvanic anodes only, skip to the end of this section and complete the
Summary Of Compliance With Cathodic Protection question.
71
Chapter 4
Section 4.6
-------
4.6.2: Impressed Current Cathodic Protection - Additional Requirements And Best
Management Practices
Additional Requirements And Best Management Practices For Impressed Current
Cathodic Protection Systems
If you have an impressed current cathodic protection system, you must inspect the
rectifier at least every 60 days to make sure it is on and operating properly.
• You must keep records of the last three inspections. A sample impressed
current inspection record keeping form is provided in appendix I.
If your rectifier is not operating properly, contact a corrosion expert to evaluate
and fix your cathodic protection system.
Things To Do During Rectifier Inspections
1. Make sure the rectifier is
turned on.
Rectifiers always need to be on to protect your tank and
piping from corrosion. Never turn off your rectifier.
• your rectifier may have a light to indicate that it is
turned on
• your rectifier may have an on/off switch
Your rectifier should be directly wired to a dedicated circuit and not plugged into a wall outlet
or wired to a light switch.
2. Record the values from any
meters on the rectifier. If you
have ammeter and voltmeter
readings, compare them to
operating ranges established by
the corrosion expert.
Some rectifiers may have one or more of the following
meters:
direct current ammeter
direct current voltmeter
hour meter
The person who installed your impressed current system should have provided you with
paperwork to indicate what the normal operating voltage and amperage values are for your
cathodic protection system. If you do not have values for the normal operating voltage and
amperage, contact the person who installed the system and obtain that information.
3. If your rectifier does not appear to be operating properly (such as the rectifier or rectifier
light is not on or meter readings are not within established values), contact a qualified person
to fix the problem. Remember, only a corrosion expert can make changes to the design of
your cathodic protection system.
Warning You should not attempt to fix any problems with your rectifier. The rectifier poses
an electrical shock hazard.
Remember to keep all records of repairs and have a cathodic protection test conducted within
six months of any repair. Make sure the cathodic protection system passes the test.
Perform inspections of your rectifier more frequently than every 60 days. The more
often you inspect the rectifier, the quicker you can detect problems with your cathodic
protection system.
72
Chapter 4
Section 4.6
-------
Additional Checklist For Impressed Current Cathodic Protection Systems
Circle the LIST number for each LIST that has an
impressed current cathodic protection on either the
tank or piping. Answer the questions below for
each LIST you circled.
UST# =
Questions
Circle Yes (Y) or No (N)
1. Do you have the required records of your rectifier
inspections? You must inspect your rectifier at least every 60
days by recording the voltage and amperage readings on your
rectifier and comparing those readings with the normal operating
values.
Answer yes to this question if one of the following apply:
1. You have records of the three most recent rectifier inspections, the most recent inspection was less
than 60 days ago, and there was no more than 60 days between inspections.
2. The rectifier is between four and six months old and you have at least two rectifier inspection
records. Your last inspection must have been conducted less than 60 days ago.
3. The rectifier is between two and four months old and you have at least one rectifier inspection record.
Your last inspection must have been conducted less than 60 days ago.
4. The rectifier is less than two months old and you have no rectifier inspection records yet.
If you have inspection records, enter the date of your most
recent inspection (mm/dd/yy).
If no, then to return to compliance: Begin keeping records of your rectifier inspection.
2. Did your most recent rectifier inspection indicate the
rectifier was running properly? Answer yes here if your rectifier
is less than 2 months old and you have not yet inspected it.
If no, then to return to compliance: Have a corrosion expert evaluate your cathodic protection system
and fix any problems as soon as possible. Also have a cathodic protection test conducted within six
months of the repair. Make sure the cathodic protection system passes the test.
73
Chapter 4
Section 4.6
-------
Summary Of Compliance With Cathodic Protection
Make sure you read and complete the checklists in the appropriate cathodic protection
sections for all of your cathodically protected tanks and piping before answering the
question below.
Summary Of Compliance With Cathodic Protection
Answer the following question:
UST# =
Do your cathodically protected tanks and piping meet the
requirements for cathodic protection?
To answer yes here, you must have:
1. For galvanic (sacrificial) anode cathodic protection - answered yes to all questions in section 4.6.1.
2. For impressed current cathodic protection - answered yes to all questions in sections 4.6.1 and 4.6.2.
Copy these answers to the appropriate checklists in sections 4.4 and 4.5 of the workbook.
If you answered no, complete and submit a return to compliance plan addressing each area of non-compliance.
A return to compliance plan form is in appendix B.
74
Chapter 4
Section 4.6
-------
mrormaiion
Section 4.7: Release Detection For Tanks
You have several options for meeting release detection (also called leak
detection) requirements for your tanks. They include:
• Automatic Tank Gauging
Interstitial Monitoring (for tanks with secondary containment)
Groundwater Monitoring
• Vapor Monitoring
Inventory Control and Tank Tightness Testing (a temporary method)
Manual Tank Gauging (for small tanks)
Manual Tank Gauging and Tank Tightness Testing (a temporary method for small tanks)
Statistical Inventory Reconciliation (SIR)
Emergency generator tanks are not required to have release detection.
Requirements And Best Management Practices For All Tank Release Detection Methods
You must keep records of release detection testing for at least one year.
Your method of release detection must meet specific performance requirements.
• You must keep documentation from the manufacturer, vendor, or installer for at
least five years which shows your release detection equipment can meet
performance requirements.
One way to obtain copies of this documentation is to access the National
Work Group for Leak Detection Evaluations list. This list may be found at:
http://www.nwglde.org
Your release detection must be installed, calibrated, operated, and maintained
according to the manufacturer's instructions.
Keep all schedules of required calibration and maintenance provided by the
equipment manufacturer for at least five years.
Keep all records of calibration, maintenance, and repair for at least one year
after the activity occurred.
If you ever suspect or confirm a release, you must take appropriate action and, if
necessary, report the release. See section 4.9 for information on what to do. Never
ignore release detection alarms or failed leak detection tests. Treat them as
potential leaks!
If you have hazardous substance tanks (as defined under CERCLA), you must have
secondary containment and use interstitial monitoring for release detection unless
you have obtained a waiver from {state}.
Chapter 4
75 Section 4.7
-------
Make sure your vendor or installer provides you with the information and training
necessary to make sure your release detection equipment works effectively to detect
leaks.
Keep all of your records and paperwork for the life of the tank.
Periodically have a qualified LIST contractor, such as the vendor who installed your
release detection system, service your leak detection equipment according to the
manufacturer's service instructions.
Components can wear out and must be checked periodically. Many vendors
recommend or require this maintenance activity at least once annually.
Make sure employees who run, monitor, or maintain the release detection system
know how to run, monitor, or maintain the equipment and to whom to report
problems. Develop and maintain regular training programs for all employees.
Directions For Completing The Release Detection For Tanks Section
Step 1: Fill out the table on the next page to identify the method of tank release detection
you use for each tank.
Different tanks at your facility may use different types of release
detection. Make sure to select the appropriate type of release detection
for each tank at your facility.
Some of your tanks may have more than one type of release detection.
Only choose one type of release detection for each tank for this
workbook. You only need to meet the requirements for one method of
release detection for each tank.
Step 2: For each type of release detection you checked in the table, go to the
corresponding section listed in the far-right column. Read the requirements and
best management practices and fill out the appropriate checklist(s) in that section.
You may need to go to more than one section and fill out more than one checklist •
each release detection type has a separate checklist.
Step 3: Once you have completed the checklists for all your methods of tank release
detection, turn to the last page of this section and complete the question that
summarizes your compliance with tank release detection.
Chapter 4
76 Section 4.7
-------
Identifying The Method Of Release Detection You Use For Your Tanks
Identify the method of tank release detection you use for each LIST in the table below and
proceed as instructed in the far-right column.
If you do not know the methods of release detection you use, read the information below
the table to help you.
If you have an LIST that contains a hazardous substance (one common example is
antifreeze) or you have an LIST that stores product solely for use by emergency power
generators, check the appropriate rows in the table below for that LIST.
Choose the method of tank release detection you use for each LIST
checking the appropriate boxes.
| Automatic Tank Gauging (ATG)
Secondary Containment With Interstitial Monitoring
Groundwater Monitoring
Vapor Monitoring
Inventory Control And Tank Tightness Testing
Manual Tank Gauging
Manual Tank Gauging And Tank Tightness Testing
Statistical Inventory Reconciliation (SIR)
No Release Detection
Check here if your tank contains a hazardous substance
Check here if your tank stores product solely for use by
emergency power generators
by
r
Go to these sections for
information and
compliance checklists
Section 4.7.1
Section 4.7.2
Section 4.7.3
Section 4.7.4
Section 4.7.5
Section 4.7.6
Section 4.7.7
Section 4.7.8
Section 4.7.9
Section 4.7.2
Section 4.7.9
If your tank release detection type is not listed above, contact {state} to determine what you
must do.
Take the following steps to figure out what methods you use at your facility.
Read the descriptions below to determine which tank release detection method you use.
Look through your old records to see if they match any of the names in the descriptions.
• Ask the contractor who installed your release detection system.
Release Detection Descriptions
Automatic Tank Gauging (ATG) Systems -
An ATG system is a sensor permanently
installed in a tank and wired to a monitor to
provide information such as product level and
temperature. You should have a monitor
(sometimes called an ATG) mounted
somewhere at your facility. ATG system Sample ATG Monitor Sample ATG Monitor
monitors automatically calculate the changes
in product volume that can indicate a leaking tank and can be set to activate an alarm when
there is a suspected problem with your tank.
77
Chapter 4
Section 4.7
-------
Secondary Containment With Interstitial Monitoring - Secondary containment is an
additional barrier between the portion of an LIST that contains product and the outside
environment. Hazardous substance tanks must have secondary containment with
interstitial monitoring or a waiver from {state}. Examples of secondary containment include
the outer tank wall of a double-walled system, an excavation liner, and a bladder inside a tank.
The area between the inner and outer barriers is called the interstitial space and can be
monitored manually or automatically. You may have interstitial monitoring ports on the
pavement at your facility.
You might perform interstitial monitoring by doing one of the following:
manually checking the interstitial space for product or water.
manually checking the interstitial space for the appropriate liquid level (for interstitial spaces
designed to be filled with liquid).
manually checking a vacuum or pressure level maintained in the interstitial space.
electronic sensors in the interstitial space that are connected to and monitored by electronic
monitoring equipment.
Groundwater Monitoring -
Groundwater monitoring uses
monitoring wells placed around your
tank field to look for the presence of
liquid product floating on the
groundwater at the LIST site. You
should be able to see monitoring
well covers at your facility. There
are two ways you can perform
groundwater monitoring:
Sample Monitoring Well Cover
Manual - use a bailing device (see picture above) to check each well
for product at least once every 30 days.
Bailing A
Groundwater
Monitoring Well
Electronic - use an electronic monitor at your facility connected to electronic sensors in the
monitoring well that check for the presence of product at least once every
30 days.
Vapor Monitoring - Vapor monitoring uses monitoring wells to look for the
presence of vapors in the soil at the LIST site. Vapor monitoring will not work
well with product that does not easily vaporize (such as diesel fuel). You
should be able to see monitoring well covers at your facility. There are two
ways you can perform vapor monitoring:
Manual - use a hand-held device such as a photo-ionization detector
(PID) or flame-ionization detector (FID) to check for vapors at each
monitoring well at least once every 30 days.
Electronic - use an electronic monitor at your facility connected to
electronic sensors in each monitoring well that check for the presence of
vapors at least once every 30 days.
Sample PID
78
Chapter 4
Section 4.7
-------
Inventory Control And Tank Tightness Testing - This method involves measuring the
contents of the tank, recording the amount of product pumped each day, and reconciling that
data with measurements and records of product delivery. Typically, a measuring stick is used
to take the measurements. This combined method also includes tightness testing every five
years. This method may only be used for up to ten years after installing a new tank or
upgrading an existing tank with corrosion protection.
Manual Tank Gauging - Manual tank gauging alone may be used only for tanks of 1,000
gallons or less capacity. It involves taking your tank out of service for the testing period each
week, during which the contents of the tank are measured at the beginning and end of the test
period. Typically, a measuring stick is used to take the measurements. The measurements are
then compared to weekly and monthly standards to determine if the tank is tight.
Manual Tank Gauging And Tank Tightness Testing - This method is for tanks of 2,000
gallons or less capacity. Manual tank gauging involves taking your tank out of service for the
testing period each week, during which the contents of the tank are measured at the beginning
and end of the test period. Typically, a measuring stick is used to take measurements. The
measurements are then compared to weekly and monthly standards to determine if the tank is
tight. This combined method also includes tightness testing every five years. This method
may only be used for up to ten years after installing a new tank or upgrading an existing
tank with corrosion protection.
Statistical Inventory Reconciliation (SIR) - SIR is a method of release detection where
computer software is used to conduct a statistical analysis of inventory, delivery, and dispensing
data you collect every 30 days. A measuring stick or an ATG is commonly used to gather the
inventory data. Depending on the vendor, you may either have to send your data to the vendor
and receive a report or enter the data into a computer program that provides you with the
results. The result of the analysis may be pass, inconclusive, or fail.
Sample Part Of A Measuring Stick
79
Chapter 4
Section 4.7
-------
4.7.1: Automatic Tank Gauging
r j
Automatic tank gauging (ATG) systems
automatically calculate the changes in
product volume that can indicate a
leaking tank.
Requirements And Best Management Practices For
Automatic Tank Gauging
Sample ATG
Use your ATG system to test for leaks at least once every 30 days for each tank and
keep a record of the result for at least one year. Your ATG system must be able to
detect a 0.2 gallon per hour leak rate with at least a 95 percent probability of
detection and no more than five percent probability of false alarm.
Remember to test each tank.
Make sure you are properly testing the portion of the tank that routinely contains
product.
Make sure the amount of product in your tank is sufficient to run the ATG leak
test. The tank must contain a minimum amount of product to perform a valid leak
detection test (this information should be on the performance certification for
your leak detection equipment).
Test your tanks more frequently in order to catch leaks sooner. Testing more
frequently will also help you ensure a valid test result each month.
Frequently test your ATG system according to the manufacturer's instructions to
make sure it is working properly.
Read your owner's manual and run the appropriate tests to see if your ATG
system is set up and working properly.
Most ATG systems have a test or self-diagnosis mode that may run these
checks.
Periodically have a qualified LIST contractor, such as the vendor who installed your
ATG, service all the ATG system components according to the manufacturer's
service instructions.
• Tank sensors and other components can wear out and must be checked
periodically. Many vendors recommend or require this maintenance activity at
least once annually.
80
Chapter 4
Section 4.7
-------
Checklist For Automatic Tank Gauging
Circle the LIST number for each tank that uses an
ATG. Answer the questions below for each LIST
you circled.
UST# =
Questions
Circle Yes (Y) or No (N)
1. Do you have all release detection records for the last 12
months? You must check for releases at least every 30 days.
Appendix J contains a sample record keeping form.
Enter the date of your last ATG test (mm/dd/yy).
If no, then to return to compliance: You may be able to obtain past results of leak tests from your
ATG. Consult your ATG owners manual to determine how to do this. Otherwise, begin using a release
detection method to check for releases at least every 30 days and keep a record of the results.
2. Do you have records of any calibration, maintenance, or
repair performed on your ATG system in the last 12 months?
Answer yes here if no calibration, maintenance, or repairs were
performed in the last 12 months.
If no, then to return to compliance: Contact the person who did the work and obtain these records.
3. If your ATG system is less than five years old, do you have
calibration and maintenance schedules for your ATG?
Skip this question if your system is five years old or older.
If no, then to return to compliance: Contact the ATG vendor or manufacturer and obtain these
schedules.
Summary Of Compliance With Release Detection For Automatic Tank Gauging
Answer the following question:
Are you in compliance with release detection requirements for your ATG?
To answer yes here you must have answered yes to all applicable questions above.
Yes
No
If you answered no, fill out a return to compliance plan and submit it with your certification of compliance.
A return to compliance plan form is in appendix B.
81
Chapter 4
Section 4.7
-------
4.7.2: Secondary Containment With Interstitial Monitoring
Secondary containment is an additional barrier between the portion of an LIST
that contains the product and the outside environment. Examples of tank
secondary containment include the outer tank wall of a double-walled system,
an excavation liner, and a bladder inside a tank. The area between the inner
and outer barriers is called the interstitial space and can be monitored to catch
problems before product reaches the environment. Hazardous substance
tanks must have secondary containment with interstitial monitoring or a
waiver from {state}.
Requirements And Best Management Practices For Secondary Containment With
Interstitial Monitoring
Use your Interstitial monitoring system to test for leaks at least once every 30 days
for each tank and keep a record of the result for at least one year.
Interstitial monitoring systems must be designed, constructed and installed to detect
a leak from any part of the tank that routinely contains product.
For double-walled tanks, the test method must be able to detect a release
through the inner wall.
For a secondary containment barrier in the excavation zone (for example an
external liner), the following must be met:
- the barrier must be thick and impermeable (at least 10~6 cm/sec for the
product stored),
- the barrier must be compatible with the product stored,
- the barrier must be installed so that it does not interfere with the proper
operation of any cathodic protection system,
- groundwater, soil moisture, or rainfall will not make the testing or sampling
method inoperative so that a release could go undetected for more than 30
days,
- a site assessment is conducted to make sure that the secondary barrier is
always above the groundwater and not in a 25 year flood plain (unless the
barrier and monitoring designs are for use under these conditions), and
- monitoring wells are clearly marked and secured.
For tanks with internally fitted liners, the automated device must be able to
detect a release between the inner wall of the tank and the liner. The liner also
must be compatible with the product stored.
If you have an electronic system, you should frequently test your interstitial
monitoring system according to the manufacturer's instructions to make sure it is
working properly.
If you have an electronic interstitial monitoring system, periodically have a qualified LIST
contractor, such as the vendor who installed it, service all the system components
according to the manufacturer's service instructions.
Chapter 4
82 Section 4.7
-------
Checklist For Secondary Containment With Interstitial Monitoring
Circle the LIST number for each tank that uses
secondary containment with interstitial
monitoring. Answer the questions below for each
LIST you circled.
UST# =
Questions
Circle Yes (Y) or No (N)
1. Do you have all release detection records for the last 12
months? You must check for releases at least every 30 days.
Appendix J contains a sample record keeping form.
Enter the date of your last interstitial monitoring test (mm/dd/yy).
If no, then to return to compliance: If you use electronic monitoring with your interstitial monitoring,
you may be able to obtain past results. Consult the owners manual for your electronic monitoring
equipment to determine how to do this. Otherwise, begin using a release detection method to check for
releases at least every 30 days and keep a record of the results.
2. Do you have records of any calibration, maintenance, or
repair performed on your interstitial monitoring system in the
last 12 months? Answer yes here if no calibration, maintenance,
or repairs were performed in the last 12 months.
If no, then to return to compliance: Contact the person who did the work and obtain the records.
3. If your interstitial monitoring system is less than five years
old, do you have calibration and maintenance schedules?
Skip this question if your system is five years old or older.
If no, then to return to compliance: Contact the vendor or manufacturer and obtain the schedules.
4. Do you meet the design, construction, and installation
requirements for your interstitial monitoring system?
See the previous page for specific design, construction, and
installation requirements.
If no, then to return to compliance: Contact {state} to determine how to return to compliance.
Summary Of Compliance With Release Detection For Interstitial Monitoring
Answer the following question:
Yes
No
Are you in compliance with the tank release detection requirements for
interstitial monitoring?
To answer yes here you must have answered yes to all applicable questions above.
If you answered no, fill out a return to compliance plan and submit it with your certification of compliance.
A return to compliance plan form is in appendix B.
83
Chapter 4
Section 4.7
-------
4.7.3: Groundwater Monitoring
Groundwater monitoring uses monitoring wells placed around your tank field to
ls J look for the presence of liquid product floating on the groundwater.
Requirements And Best Management Practices For Groundwater Monitoring
._ Test each monitoring well for leaks at least once every 30 days and keep a record
• of the result for at least one year.
You must keep all of your groundwater monitoring ports clearly marked and secured.
• According to American Petroleum Institute Recommended Practice 1637,
monitoring well covers should be marked with a solid white circle containing a
solid black triangle.
A site assessment must have been conducted at your facility to determine the
following:
• the appropriate number and placement of monitoring wells so that any release
from the UST will be detected,
groundwater at your facility is never more than 20 feet below the surface,
• the hydraulic conductivity of the soil between your UST and the monitoring wells
is not less than 0.1 cm/s (i.e., the soil should consist of gravels, coarse to
medium sands, coarse silts, or other permeable materials),
• the product stored in your tank does not mix or blend with water,
• the slotted part of the well casing allows product to collect in the well, but does
not allow surrounding soil to enter under both low groundwater and high
groundwater conditions,
monitoring wells are sealed from the ground surface to the top of the filter pack,
monitoring wells are in the excavation zone or are as close to it as feasible, and
• the method used for detection can determine the presence of at least one-eighth
of an inch of free product on top of the water in the monitoring well.
If you have an electronic system, you should frequently test your groundwater
monitoring system according to the manufacturer's instructions to make sure it is
working properly.
If you have an electronic groundwater monitoring system, periodically have a
qualified UST contractor, such as the vendor who installed it, service all the system
components according to the manufacturer's service instructions.
Check your monitoring wells more frequently in order to catch leaks sooner.
Chapter 4
84 Section 4.7
-------
Checklist For Groundwater Monitoring
Circle the LIST number for each tank that uses
groundwater monitoring. Answer the questions
below for each LIST you circled.
UST# =
Questions
Circle Yes (Y) or No (N)
1. Do you have all release detection records for the last 12 months?
You must check for releases at least every 30 days.
Appendix J contains a sample record keeping form.
Enter the date of your last groundwater monitoring test (mm/dd/yy).
If no, then to return to compliance: If you use electronic monitoring with your groundwater monitoring wells, you
may be able to obtain past results. Consult the owners manual for your electronic monitoring equipment to
determine how to do this. Otherwise, begin using a release detection method to check for releases at least every
30 days and keep a record of the results.
2. Do you have records of any calibration, maintenance, or repair
performed on your groundwater monitoring system in the last 12
months? Answer yes here if no calibration, maintenance, or repairs were
performed in the last 12 months.
If no, then to return to compliance: Contact the person who did the work and obtain the records.
3. If your groundwater monitoring system is less than five years old,
do you have calibration and maintenance schedules?
Skip this question if your system is five years old or older.
If no, then to return to compliance: Contact the vendor or manufacturer and obtain the schedules.
4. Are your groundwater monitoring ports clearly marked and
secured?
If no, then to return to compliance: Clearly mark and secure these ports.
5. Was a site assessment conducted to determine the number and
positioning of groundwater monitoring wells and that your site was
suitable for groundwater monitoring? See the previous page for
specific site assessment requirements.
If no, then to return to compliance: Contact {state} to determine how to return to compliance.
Summary Of Compliance With Release Detection For Groundwater Monitoring For Your Tanks
Answer the following question:
Yes
No
Are you in compliance with the tank release detection requirements for
groundwater monitoring?
To answer yes here you must have answered yes to all applicable questions above.
If you answered no, fill out a return to compliance plan and submit it with your certification of compliance.
A return to compliance plan form is in appendix B.
85
Chapter 4
Section 4.7
-------
4.7.4: Vapor Monitoring
Vapor monitoring uses monitoring wells to look for the presence of vapors in
the soil at the LIST site. Vapor monitoring will not work well with a product
such as diesel fuel that does not easily vaporize.
Requirements And Best Management Practices For Vapor Monitoring
Use your vapor monitoring system to test for leaks at least once every 30 days and
keep a record of the result for at least one year.
Remember to check each monitoring well.
You must keep all of your vapor monitoring ports clearly marked and secured.
• According to American Petroleum Institute Recommended Practice 1637,
monitoring well covers should be marked with a solid white circle containing a
solid black triangle.
A site assessment must have been conducted at your facility to determine the
following:
• the appropriate number and placement of monitoring wells so that any release
from the UST will be detected,
• the materials used as backfill must be porous enough to readily allow vapor
movement from a release (e.g., gravel, sand, crushed rock),
• the product stored in the tank or tracer compound can vaporize enough to be
detected by the monitor,
• the measurement of vapors by the monitoring device is not made inoperative by
groundwater, rainfall, soil moisture, or other interferences that would allow a
release to go undetected for more than 30 days,
background contamination in the excavation zone must not cause any
interference, and
• vapor monitors are designed and operated to detect any significant increase in
the concentration (above the background levels) of product stored in the tank, a
component or components of that product, or a tracer compound placed in the
tank system.
If you have an electronic system, you should frequently test your vapor monitoring
system according to the manufacturer's instructions to make sure it is working
properly.
If you have an electronic vapor monitoring system, periodically have a qualified UST
contractor, such as the vendor who installed it, service all the system components
according to the manufacturer's service instructions.
Check your monitoring wells more frequently in order to catch leaks sooner.
Chapter 4
86 Section 4.7
-------
Checklist For Vapor Monitoring
Circle the LIST number for each tank that uses
vapor monitoring. Answer the questions below
for each LIST you circled.
UST# =
Questions
Circle Yes (Y) or No (N)
1. Do you have all release detection records for the last 12 months?
You must check for releases at least every 30 days.
Appendix J contains a sample record keeping form.
Enter the date of your last vapor monitoring test (mm/dd/yy).
If no, then to return to compliance: If you use electronic monitoring with your vapor monitoring wells, you may
be able to obtain past results. Consult the owners manual for your electronic monitoring equipment to determine
how to do this. Otherwise, begin using a release detection method to check for releases at least every 30 days
and keep a record of the results.
2. Do you have records of any calibration, maintenance, or repair
performed on your vapor monitoring system in the last 12 months?
Answer yes here if no calibration, maintenance, or repairs were performed
in the last 12 months.
If no, then to return to compliance: Contact the person who did the work and obtain these records.
3. If your vapor monitoring system is less than five years old, do you
have calibration and maintenance schedules?
Skip this question if your system is five years old or older.
If no, then to return to compliance: Contact the vendor or manufacturer and obtain these schedules.
4. Are your vapor monitoring ports clearly marked and secured?
If no, then to return to compliance: Clearly mark and secure these ports.
5. Was a site assessment conducted to determine the number and
positioning of vapor monitoring wells and that your site was suitable
for vapor monitoring? See the previous page for specific site
assessment requirements.
If no, then to return to compliance: Contact {state} to determine how to return to compliance.
Summary Of Compliance With Release Detection For Vapor Monitoring For Your Tank
Answer the following question:
Yes
No
Are you in compliance with the tank release detection requirements for vapor
monitoring?
To answer yes here, you must have answered yes to all applicable questions above.
If you answered no, fill out a return to compliance plan and submit it with your certification of compliance.
A return to compliance plan form is in appendix B.
87
Chapter 4
Section 4.7
-------
4.7.5: Inventory Control And Tank Tightness Testing
Requirements And Best Management Practices For Inventory Control And Tank
Tightness Testing
You may use this combination method for up to ten years after installing a new LIST
or for up to ten years after your existing tank met the corrosion protection
requirements.
For inventory control you must do the following:
• Take inventory and dispenser readings and record the numbers at least once
each day that product is added to or removed from your tank.
Reconcile deliveries with delivery receipts by taking inventory readings before
and after each delivery.
Reconcile all of your data at least once every 30 days and record your results.
Keep inventory records for at least one year.
Your equipment (for example: a stick or electronic monitoring device) must be
capable of measuring to the nearest one-eighth inch and be able to measure the
level of product over the full range of the tank's height.
Check your measuring stick periodically to make sure you can read the
markings and numbers, that the bottom of the stick is not worn, and that the
stick is not broken, bowed, or warped.
You must make sure your product dispensers are calibrated according to local
standards or to an accuracy of six cubic inches for every five gallons of product
withdrawn.
Look on your dispenser for a weights and measures sticker or contact your
local department of weights and measures.
You must measure the water in your tank to the nearest one-eighth inch at least
once a month.
• You can use a paste that changes color when it comes into contact with water.
You must have a tightness test conducted at least once every five years.
• The test may be conducted by a trained tester or by using a permanently
installed electronic system.
Make sure the method of tank tightness testing is certified for the types of tanks
you have and for the product you store in those tanks.
• The tightness test must be capable of detecting a 0.1 gallon per hour leak rate
from any portion of the tank that routinely contains product.
Keep the results of your most recent tightness test.
For more consistent stick measurements, have the same person stick the tank at
the same time each day.
Chapter 4
88 Section 4.7
-------
Checklist For Inventory Control And Tank Tightness Testing
Circle the LIST number for each tank that uses
inventory control and tank tightness testing.
Answer the questions below for each LIST you
circled.
UST# =
Questions
Circle Yes (Y) or No (N)
1. Is your tank either less than ten years old or upgraded with
corrosion protection less than ten years ago?
If no, then to return to compliance: Inventory control and tank tightness testing is not an option for release
detection for these tanks. Begin using another method of release detection.
2. Do you perform inventory control properly? Appendix K contains
a sample worksheet and record keeping form.
You Must: — Take inventory and dispenser readings at least once each day that product is added to or removed from
your tank.
- Reconcile deliveries with delivery receipts by taking inventory readings before and after each delivery.
- Reconcile all of your data at least once every 30 days.
If no, then to return to compliance: Begin performing proper inventory control.
3. Do you have all records of inventory control (including monthly
water measurements) for at least the last 12 months?
Enter the date of your last inventory control result (mm/dd/yy).
If no, then to return to compliance: Begin keeping records of inventory control and water measurements.
4. Is the measuring equipment used capable of measuring the
entire height of the tank to the nearest one-eighth inch?
If no, then to return to compliance: Get equipment (e.g., a measuring stick) that meets these requirements.
5. Are your dispensers calibrated according to local standards or
to an accuracy of six cubic inches for every five gallons of product
withdrawn?
If no, then to return to compliance: Have your dispenser calibrated to either the local or specified standard.
6. Do you have a record of a passing tank tightness test
conducted within the past five years?
If no, then to return to compliance: Have a tightness test conducted and keep the record. If your tanks did
not pass the tightness test, report a suspected release, have a qualified LIST contractor fix the problem, and
perform another tightness test.
Summary Of Compliance With Release Detection For Inventory Control And Tank Tightness Testing
Answer the following question:
Yes
No
Are you in compliance with the tank release detection requirements for inventory control
and tank tightness testing?
To answer yes here you must have answered yes to all applicable questions above.
If you answered no, fill out a return to compliance plan and submit it with your certification of compliance.
A return to compliance plan form is in appendix B.
89
Chapter 4
Section 4.7
-------
4.7.6: Manual Tank Gauging
Requirements For Manual Tank Gauging
Only tanks of 1,000 gallons or less meeting the size and test requirements in the
table below may use manual tank gauging.
Tank Size
up to 550 gallons
(any tank diameter)
551-1 ,000 gallons
(when tank diameter is 64")
551-1 ,000 gallons
(when tank diameter is 48")
Minimum Period
Of Test
36 hours
44 hours
58 hours
Weekly
Standard
(One Test)
10 gallons
9 gallons
12 gallons
Monthly
Standard
(Four Test
Average)
5 gallons
4 gallons
6 gallons
You must perform weekly testing as follows:
• Take your tank out of service for the period of the test to ensure no product is
added or removed.
Record two inventory readings at the beginning and end of the test period.
Reconcile the numbers weekly and keep records. For the tank to pass, the
difference between the beginning and ending measurements cannot exceed the
weekly standard value listed in the third column of the table above. Instructions
and a record keeping form are provided in appendix L.
You must reconcile your records every 4 weeks to obtain monthly numbers. For the
tank to pass, the difference between the average of the four weekly beginning and
ending measurements cannot exceed the monthly standard value listed in the fourth
column of the table above. Instructions and a record keeping form are provided in
appendix L.
Your equipment (e.g., your measuring stick) must be capable of measuring to the
nearest one-eighth inch and be able to measure the level of product over the full
range of the tank's height.
Check your measuring stick periodically to make sure you can read the markings
and numbers, that the bottom of the stick is not worn, and that the stick is not
broken, bowed, or warped.
90
Chapter 4
Section 4.7
-------
Checklist For Manual Tank Gauging
Circle the LIST number for each tank that uses
manual tank gauging. Answer the questions
below for each LIST you circled.
UST# =
Questions
Circle Yes (Y) or No (N)
1. Is each tank using manual tank gauging 1,000 gallons or
less in size and does it meet the tank diameter
requirements listed in the table on the left-hand page?
If no, then to return to compliance: Manual tank gauging alone is not an option for release
detection for this tank. Begin using another method of release detection.
2. Are you performing manual tank gauging properly?
Instructions and a record keeping form are provided in
appendix L.
You Must: - Perform weekly testing by recording two readings at the beginning of the test,
waiting at least the minimum required time, recording two readings at the end of the
test, and reconciling the data.
- Reconcile four weeks of data every four weeks and record the results for the
monthly standard.
If no, then to return to compliance: Begin performing manual tank gauging properly.
3. Do you have all records of manual tank gauging for at
least the last 12 months?
Enter the date of your last manual tank gauging result
(mm/dd/yy).
If no, then to return to compliance: Begin keeping records of manual tank gauging.
4. Is the measuring equipment used capable of measuring
the entire height of the tank to the nearest one-eighth
inch?
If no, then to return to compliance: Get equipment (e.g., a measuring stick) that meets these
requirements.
Summary Of Compliance With Manual Tank Gauging
Answer the following question:
Yes
No
Are you in compliance with the tank release detection requirements for
manual tank gauging?
To answer yes here you must have answered yes to all applicable questions above.
If you answered no, fill out a return to compliance plan and submit it with your certification of compliance.
A return to compliance plan form is in appendix B.
91
Chapter 4
Section 4.7
-------
4.7.7: Manual Tank Gauging And Tank Tightness Testing
Requirements For Manual Tank Gauging And Tank Tightness Testing
Manual tank gauging combined with tank tightness testing is a temporary release
detection method that may be used for up to 10 years after installing a new LIST or
for up to 10 years after your existing tank met the corrosion protection requirements.
Only tanks of 2,000 gallons or less meeting the size and test requirements in the
table below may use manual tank gauging combined with tank tightness testing.
See section 4.7.6 if your tank is 1,000 gallons or less and you can use manual
tank gauging only.
Tank Size
551 - 1,000 gallons
1,001 -2,000 gallons
Minimum Period
Of Test
36 hours
36 hours
Weekly Standard
(One Test)
13 gallons
26 gallons
Monthly Standard
(Four Test Average)
7 gallons
13 gallons
You must perform weekly testing as follows:
• Take your tank out of service for the period of the test to ensure no product is
added or removed.
Record two inventory readings at the beginning and end of the test period.
Reconcile the numbers weekly and keep records of the results. For the tank to
pass, the difference between the beginning and ending measurements cannot
exceed the weekly standard value listed in the third column of the table above.
Instructions and a record keeping form are provided in appendix L.
You must reconcile your records every four weeks to obtain monthly numbers. For
the tank to pass, the difference between the average of the four weekly beginning
and ending measurements cannot exceed the monthly standard value listed in the
fourth column of the table above. Instructions and a record keeping form are
provided in appendix L.
Your equipment (e.g., your measuring stick) must be capable of measuring to the
nearest one-eighth inch and be able to measure the level of product over the full
range of the tank's height.
Check your measuring stick periodically to make sure you can read the markings
and numbers, that the bottom of the stick is not worn, and that the stick is not
broken, bowed, or warped.
You must have a tightness test conducted at least once every five years.
• The test may be conducted by a trained tester or by using a permanently
installed electronic system.
Make sure the method of tank tightness testing is certified for the types of tanks
you have and for the product you store in those tanks.
• The tightness test must be capable of detecting a 0.1 gallon per hour leak rate
from any portion of the tank that routinely contains product.
Keep the results of your most recent tightness test.
Checklist For Manual Tank Gauging And Tank Tightness Testing
92
Chapter 4
Section 4.7
-------
Circle the LIST number for each tank that uses
manual tank gauging and tank tightness
testing. Answer the questions below for each
LIST you circled.
UST# =
Questions
Circle Yes (Y) or No (N)
1. Is your tank either less than 10 years old or upgraded with
corrosion protection less than 10 years ago?
If no, then to return to compliance: Manual tank gauging and tank tightness testing is not an option for
release detection for this tank. Begin using another method of release detection.
2. Is each tank using manual tank gauging 2,000 gallons or less
in size?
If no, then to return to compliance: Manual tank gauging is not an option for release detection for this tank.
Begin using another method of release detection.
3. Are you performing manual tank gauging properly?
Instructions and a record keeping form are provided in appendix L.
You must: - Perform weekly testing by recording two readings at the beginning of the test, waiting at least the
minimum required time, recording two readings at the end of the test, and reconciling the data.
- Reconcile four weeks of data every four weeks and record the results for the monthly standard.
If no, then to return to compliance: Begin performing manual tank gauging properly.
4. Do you have records of manual tank gauging for at least the
last 12 months?
Enter the date of your last manual tank gauging result
(mm/dd/yy).
If no, then to return to compliance: Begin keeping records of manual tank gauging.
5. Is the measuring equipment used capable of measuring the
entire height of the tank to the nearest one-eighth inch?
If no, then to return to compliance: Get equipment (e.g., a measuring stick) that meets this requirement.
6. Do you have a record of a passing tank tightness test
conducted within the past five years?
If no, then to return to compliance: Have a tightness test conducted and keep the record. If your tank did
not pass the tightness test, report a suspected release, have a qualified LIST contractor fix the problem, and
perform another tightness test.
Summary Of Compliance With Manual Tank Gauging And Tank Tightness Testing
Answer the following question:
Yes
No
Are you in compliance with the tank release detection requirements for manual
tank gauging and tank tightness testing?
To answer yes here, you must have answered yes to all applicable questions above.
If you answered no, fill out a return to compliance plan and submit it with your certification of compliance.
A return to compliance plan form is in appendix B.
93
Chapter 4
Section 4.7
-------
4.7.8: Statistical Inventory Reconciliation
Statistical Inventory Reconciliation (SIR) is a method of release detection
where computer software conducts a statistical analysis of inventory, delivery,
and dispensing data every 30 days. SIR must be able to detect a 0.2 gallon
per hour leak rate with at least a 95 percent probability of detection and no
more than 5 percent probability of false alarm or be approved by {state}.
Depending on the vendor, you may either have to send your data to the
vendor and receive a report or enter the data into a computer program that
provides you with the results. The result of the analysis may be pass,
inconclusive, or fail.
Requirements And Best Management Practices For SIR
You must supply inventory data to your SIR vendor (or enter your inventory data
into a computer software program and generate your leak detection results) at least
once every 30 days. If you submit your data, a vendor will provide you with your
leak detection results after the statistical analysis is completed. Keep your SIR
results for at least one year.
Make sure the vendor provides your results quickly so you know whether or not
your tank is leaking every 30 days.
Check with your SIR vendor or computer software to determine what specific
inventory data is necessary.
If you receive an inconclusive result, you must correct the problem (the problem
might be poor measurement techniques or something more serious such as a
release) and document the results of the investigation.
• An inconclusive result means you have not performed leak detection for that
month.
Many vendors require you to measure product to the nearest one-eighth inch (for
example by using a stick or electronic monitoring device) and that the equipment be
capable of measuring the level of product over the full range of the tank's height.
If you have a measuring stick, check it periodically to make sure you can read
the markings and numbers, that the bottom of the stick is not worn, and that the
stick is not broken, bowed, or warped.
For more consistent measurements, take measurements at the same time each
day.
If you use an automatic tank gauge to gather inventory data, periodically have a
qualified LIST contractor, such as the vendor who installed it, service all the system
components according to the manufacturer's service instructions.
Make sure your product dispensers are calibrated according to local standards.
Look on your dispenser for a weights and measures sticker or contact your local
department of weights and measures.
Periodically measure the water in your tank to the nearest one-eighth inch. You can
use a paste on your measurement stick that changes color when it comes into
contact with water.
Chapter 4
94 Section 4.7
-------
Checklist For Statistical Inventory Reconciliation
Circle the LIST number for each tank that uses SIR.
Answer the questions below for each LIST you
circled.
UST# =
Questions
Circle Yes (Y) or No (N)
1. Do you supply your SIR vendor with inventory data (or
enter inventory data into a SIR computer program to generate
a release detection result) at least once every 30 days?
If no, then to return to compliance: Begin gathering inventory data daily and supply it to your SIR
vendor (or enter inventory data into a SIR program yourself to generate a release detection result)
every 30 days.
2. Do you investigate and resolve all inconclusive results?
If no, then to return to compliance: Investigate any recent inconclusive results and begin
investigating all inconclusive results you receive.
3. Do you have records of at least the last 12 months of SIR?
Make sure the SIR vendor provides you with your leak detection
results when the statistical analysis is completed or you print the
results from your SIR program.
Enter the date of your last SIR test result (mm/dd/yy).
If no, then to return to compliance: Begin keeping records of SIR.
Summary Of Compliance With Statistical Inventory Reconciliation
Answer the following question:
Are you in compliance with the tank release detection requirements for SIR?
To answer yes here you must have answered yes to all applicable questions above.
Yes
No
If you answered no, fill out a return to compliance plan and submit it with your certification of compliance.
A return to compliance plan form is in appendix B.
95
Chapter 4
Section 4.7
-------
4.7.9: Tanks With No Release Detection
Requirements And Best Management Practices For Tanks With No Release Detection
__ You are not required to have release detection on emergency generator tanks. All
• other tanks for which you must complete this workbook must have release detection.
Consider performing release detection on your emergency generator tank as part of
good tank management. Remember, you are responsible for responding to,
investigating, and reporting any suspected or confirmed releases that occur from
your USTs.
96
Chapter 4
Section 4.7
-------
Checklist For Tanks With No Release Detection
Circle the LIST number for each tank that does
not have release detection. Answer the
question below for each LIST you circled.
UST# =
Question
1. Is your tank an emergency generator tank?
If no, then to return to compliance: If this tank is not an emerge
have release detection. Begin using an acceptable method of rel
1
2
3
4
5
Circle Yes (Y) or No (N)
ncy generator tank, it needs to
aase detection for this tank.
Summary Of Compliance For Tanks With No Release Detection
Answer the following question:
Yes
No
Are you in compliance with the requirements for no release detection for your
tanks?
To answer yes here you must have answered yes to the question above.
If you answered no, fill out a return to compliance plan and submit it with your certification of compliance.
A return to compliance plan form is in appendix B.
97
Chapter 4
Section 4.7
-------
Summary Of Compliance With Release Detection For Tanks
Make sure you read and complete the checklists in the appropriate release detection
sections for all of your tanks before answering the question below.
Summary Of Compliance With Release Detection For Tanks
Answer the following question:
Yes
No
Are all of your tanks in compliance with release detection requirements?
To answer yes here, you must have answered yes to all previous summary questions for
each type of tank release detection you use for compliance at your facility.
If you have a tank that contains a hazardous substance listed on the CERCLA list of hazardous substances (an
example would be a tank that contains antifreeze), then to meet the tank release detection requirements, you
must either:
•• use secondary containment and interstitial monitoring, or
•• have a waiver from {state} for that LIST
If you answered no, complete and submit a return to compliance plan addressing each area of non-compliance.
A return to compliance plan form is in appendix B.
(Copy your yes or no answer to question 6 of the certification of compliance form in appendix A)
98
Chapter 4
Section 4.7
-------
Section 4.8: Release Detection For Piping
f 1 When looking at release detection requirements for piping, we must look at how
^— product is delivered through the piping. There are several types of product
delivery systems for piping that could be used with underground storage tanks.
A product delivery system is piping that delivers product from one tank to another
tank or from a tank to a dispenser. Product delivery systems may be either
pressurized or operate by suction. In addition, piping could either be above
ground or underground. The release detection requirements apply to piping
delivery systems that are underground only. The release detection requirements
are different depending on whether the piping delivery system is pressurized or
suction.
If you have piping associated with an emergency generator tank, then that piping
is not required to have release detection.
Directions For Completing The Release Detection For Piping Section
Step 1: Fill out the table on the next page to identify the type of product delivery piping you
have for each LIST.
Different piping at your facility may use different types of product delivery
systems. Make sure to select the appropriate type of product delivery
system for all of the piping at your facility.
Do not include fill pipes or vent lines as part of your product delivery
piping.
The release detection requirements only apply to the parts of your piping
that are underground. If all piping associated with an LIST is above
ground, then that piping has no requirements for release detection.
Step 2: For each type of piping you checked in the table, go to the corresponding section
listed in the far-right column. Read the requirements and best management
practices and fill out the appropriate checklist(s) in that section. You may need to
go to more than one section and fill out more than one checklist.
Step 3: Once you have completed the checklists for all your types of product delivery
piping, turn to the last page of this section and complete the question that
summarizes your compliance with piping release detection.
Chapter 4
99 Section 4.8
-------
Identifying The Types Of Product Delivery Piping You Have
Identify the type of product delivery piping you have for each LIST and proceed as instructed
in the far-right column.
Do not include fill pipes or vent lines as part of your product delivery piping.
If you do not know the types of product delivery piping you have, read the information
below the table to help you.
Choose the type of product delivery piping used for each tank by
checking the appropriate boxes
Go to these sections for
information and
compliance checklists
Pressurized (with some piping underground)
Section 4.8.1
Suction (with some piping underground)
Section 4.8.2
No Underground Piping
No Requirements
No Piping
No Requirements
Piping associated with an LIST that stores product solely
for use by emergency power generators
No Requirements
Take the following steps to figure out what is at your facility.
Read the descriptions on the next page to determine which types of piping you have.
Look through your old records to see if they match any of the names in the descriptions.
• Ask the contractor who installed your piping system.
100
Chapter 4
Section 4.8
-------
Product Delivery System Descriptions
Pressurized product delivery pushes product from the
tank to the dispenser through piping. Pressurized piping
delivery commonly uses a submersible turbine pump
(STP) located inside the tank. You should be able to tell
if you have a pressurized piping system by looking for a
STP head in a sump above the tank. These sumps are
usually covered with a lid and may also have a sump
cover under the lid. In rare cases, pressurized piping
delivery may be by gravity feed. Gravity feed has no
pump and relies on the downward slope of the piping to
transport product.
Sample STP Head In A
Sump On Top Of A Tank
Sample Lid And Sump Cover
Sample STP Head In A Sump On
Top Of A Tank
Suction product delivery pulls product from the tank
to the dispenser through the piping by using a suction
pump located at the dispenser. You should be able
to tell if you have suction piping by looking for a
suction pump (you may see pulleys and belts) inside
the dispenser. There will not be a STP pump head in
a sump above the tank.
Example Of A Suction Pump
Inside A Dispenser
101
Chapter 4
Section 4.8
-------
4.8.1: Pressurized Piping
Requirements For Pressurized Piping
Pressurized piping must have an automatic line leak detector (LLD) installed. You
must meet specific requirements for your LLDs. See section 4.8.1.1 for
information and checklists for LLDs.
Along with a LLD, each pressurized piping must have one of the following:
monthly vapor monitoring
monthly groundwater monitoring
If you are using groundwater or vapor monitoring for your tank, you may be
using these methods for your piping too.
monthly SIR - check your monthly SIR reports to see if this method is also being
used for your piping.
monthly interstitial monitoring - to use this method, your piping must be
secondarily contained and you must be monitoring the interstitial space at least
once every 30 days for releases. If you have a hazardous substance LIST, you
must either use interstitial monitoring or have a waiver from {state}.
annual line tightness test - you must have a line tightness test conducted at
least every 12 months for pressurized piping. See section 4.8.3 for information
and checklists for line tightness testing.
If you use monthly groundwater monitoring (section 4.7.3), vapor monitoring (section
4.7.4), or SIR (section 4.7.8), the requirements are the same for both tanks and
piping. Monitoring wells need to be placed appropriately to detect a release from all
parts of the piping.
If you use interstitial monitoring (section 4.7.2), the requirements are the same for
both tanks and piping. In addition, if you use sump sensors, you must ensure the
following for interstitial monitoring for piping:
Sensors are typically located in the turbine or dispenser sump areas for
interstitial monitoring. These sumps must be tight and free of leaks for piping
interstitial monitoring to operate correctly.
- Piping should slope to the sump containing the monitoring sensor.
- Make sure the rubber boot is pulled back from the outer wall of the piping so
product will drain into the sump if a problem occurs.
- Make sure the sump does not have any water in it.
- Make sure the sensors are located near the bottom of the sump so they
activate quickly when a release occurs.
Chapter 4
102 Section 4.8
-------
Checklist For Pressurized Piping Release Detection
Circle the LIST number for each LIST that has
pressurized piping. Answer the questions
below for each LIST you circled.
UST# =
Questions
1. Do you have an automatic LLD on your pressurized piping?
If you answer no here, skip question 2.
1
2
3
4
5
Circle Yes (Y) or No (N)
If no, to return to compliance: Have a contractor install a LLD on your pressurized piping.
2. Does your LLD meet the regulatory requirements?
Read and fill out the checklist in section 4.8.1.1 before answering
this question.
If no, to return to compliance: Have a contractor fix or replace your LLD so it meets the requirements
in section 4.8.1.1.
3. In addition to your LLD, what is the second method of
release detection you use for your pressurized piping?
Use these abbreviations for this question: IM = interstitial monitoring VAP = vapor monitoring
SIR = statistical inventory reconciliation GW = groundwater monitoring LIT = line tightness testing
4. Do you meet the release detection requirements for your
second method of release detection for your piping?
If you use:
Interstitial monitoring -to answer yes here, you must meet the piping interstitial monitoring
requirements on the previous page and the requirements contained in section 4.7.2.
Groundwater monitoring, vapor monitoring, or statistical inventory reconciliation - to answer
yes here, you must meet the leak detection requirements for the appropriate release detection
method in sections 4.7.3, 4.7.4, or 4.7.8.
Line tightness testing - to answer yes here, you must meet the tightness testing requirements for
pressurized piping. Fill out the checklist in section 4.8.3 to make this determination.
If no, to return to compliance: Take action to meet all of the release detection requirements for the
release detection method you are using or begin performing a method of release detection that meets
the regulatory requirements.
Summary Of Release Detection Compliance For Pressurized Piping
Answer the following question:
Yes
No
Is all of your pressurized piping in compliance with release detection
requirements?
To answer yes here, you must have answered yes to all questions above and identified the
second method of release detection you are using in question 3 above.
If you answered no, fill out a return to compliance plan and submit it with your certification of compliance.
A return to compliance plan form is in appendix B.
103
Chapter 4
Section 4.8
-------
4.8.1.1: Automatic Line Leak Detectors
Sample LLD
Automatic line leak detectors (LLD) are devices
designed to detect a catastrophic release from
pressurized piping. Typically, they are located
on the submersible turbine pump (STP) head in
the sump above your tank.
There are two types of automatic LLDs:
Mechanical LLDs are mechanically
operated pressure valves that test for piping
leaks each time the pump is turned on.
Electronic LLDs have an electronic
detection element that connects to an
Sample STP Head With
LLD
electronic control panel and monitors for piping releases.
Some interstitial monitoring devices may also serve as LLDs or an electronic LLD may also be
able to conduct a line tightness test. Check with {state} to see if these options apply to you.
Requirements And Best Management Practices For Automatic Line Leak Detectors
Pressurized piping must have a LLD installed that can detect a release of three
gallons per hour at a line pressure of ten pounds per square inch within one hour.
When a leak is detected, automatic LLDs must either:
shut off product flow;
restrict product flow; or
• trigger an alarm that you can see or hear.
You must have a test conducted that demonstrates proper functioning on each LLD
at least every 12 months. The test must be performed according to the
manufacturer's instructions.
• You must keep a record of the LLD tests for at least one year.
You must have all records of any calibration, maintenance, or repair of your LLDs
that were performed in the last 12 months.
If you have LLDs that are less that five years old, you must have all records of
performance claims, as well as calibration and maintenance schedules.
Make sure your LLDs are designed to operate with the type of product your LIST
stores. For example, some LLDs are designed to work with gasoline, while others
are intended to work with diesel.
104
Chapter 4
Section 4.8
-------
Checklist For Automatic Line Leak Detectors
Circle the LIST number for each LIST that has a
LLD. Answer the questions below for each LIST
you circled.
UST# =
Questions
Circle Yes (Y) or No (N)
1. Do you have a record indicating that your LLD passed a
functionality test within the last 12 months?
If your LLD is less than 12 months old, you should have a test of
functionality from when it was installed.
Enter the date of your most recent test (mm/dd/yy).
If no, to return to compliance: Either find the record, obtain the record from the person who
conducted the test, or have a test conducted. If a test is conducted:
make sure each LLD passes the test
Keep records of the results for at least one year
If a LLD fails a functionality test, have a trained person repair or replace the LLD.
2. Do you have records of any calibration, maintenance, or
repair performed on your LLD in the last 12 months?
Answer yes here if no calibration, maintenance, or repairs were
performed in the last 12 months.
If no, to return to compliance: Contact the person who did the work and obtain these records.
3. If your LLD is less than five years old, do you have
calibration and maintenance schedules? Skip this question if
your system is equal to or greater than five years old.
If no, to return to compliance: Contact the LLD vendor or manufacturer and obtain these schedules.
Summary Of Compliance For Your LLDs
Is your automatic LLD in compliance with release detection
requirements?
To answer yes here, you must have answered yes to all applicable questions above.
Copy this answer to question 2 of section 4.8.1.
105
Chapter 4
Section 4.8
-------
4.8.2: Suction Piping
Requirements For Suction Piping
If you have suction piping, you must meet one of the following:
monthly vapor monitoring
monthly groundwater monitoring
If you are using groundwater or vapor monitoring for your tank, you may be
using these methods for your piping too.
monthly SIR - check your monthly SIR reports to see if this method is also being
used for your piping.
monthly interstitial monitoring - to use this method, your piping must be
secondarily contained and you must be monitoring the interstitial space at least
once every 30 days for releases. If you have a hazardous substance LIST, you
must either use interstitial monitoring or have a waiver from {state}.
line tightness test every three years - you must have a line tightness test
conducted at least every three years for suction piping. See section 4.8.3 for
information and checklists for line tightness testing.
• no release detection and you meet the criteria described in the box below.
No release detection is required for suction piping that meets the following conditions:
• the piping is sloped so product will drain back to the tank when suction is lost, and
• there is only one check valve located as close as practical to the suction pump
beneath the dispenser.
Piping that meets these two criteria is sometimes called safe suction or European suction.
Piping that does not meet these conditions is sometimes called U.S. suction or American
suction.
If you use monthly groundwater monitoring (section 4.7.3), vapor monitoring (section
4.7.4), or SIR (section 4.7.8), the requirements are the same for both tanks and
piping. Monitoring wells need to be placed appropriately to detect a release from all
parts of the piping.
If you use interstitial monitoring (section 4.7.2), the requirements are the same for both
tanks and piping. In addition, if you use sump sensors, you must ensure the
following for interstitial monitoring for piping:
Interstitial monitoring sensors are typically located in a sump above the tank or
the dispenser sump areas. These sumps must be tight and free of leaks for
piping interstitial monitoring to operate correctly.
- Piping should slope to the sump containing the monitoring sensor.
- Make sure the rubber boot is pulled back from the outer wall of the piping so
product will drain into the sump if a problem occurs.
- Make sure the sump does not have any water in it.
- Make sure the sensors are located near the bottom of the sump so they
activate quickly when a release occurs.
Chapter 4
106 Section 4.8
-------
Checklist For Suction Piping Release Detection
Circle the LIST number for each LIST that has
suction piping. Answer the questions below for
each LIST you circled.
UST# =
Questions
Circle Yes (Y) or No (N)
1. Does your suction piping slope back to the tank and do you
have only one check valve located as close as practical to the
suction pump underneath the dispenser?
This piping is sometimes called safe suction or European suction.
If you answered yes for an LIST, you are in compliance with release detection for piping for this LIST.
Skip the remaining questions in this checklist for that specific LIST.
If you answered no for an LIST, you must answer the remaining questions in this checklist for that LIST.
2. What method of release detection do you use for your
suction piping?
Use these abbreviations for this question: IM = interstitial monitoring VAP = vapor monitoring
SIR = statistical inventory reconciliation GW = groundwater monitoring LIT = line tightness testing
3. Do you meet the release detection requirements for your
release detection?
If you use:
Interstitial monitoring -to answer yes here, you must meet the piping interstitial monitoring
requirements on the previous page and the requirements contained in section 4.7.2.
Groundwater monitoring, vapor monitoring, or statistical inventory reconciliation - to answer
yes here, you must meet the leak detection requirements for the appropriate release detection
method in sections 4.7.3, 4.7.4, or 4.7.8.
Line tightness testing - to answer yes here, you must meet the tightness testing requirements for
suction piping. Fill out the checklist in section 4.8.3 to make this determination.
If no, to return to compliance: Begin performing a method of release detection that meets the
requirements for that release detection method.
Summary Of Release Detection Compliance For Suction Piping
Answer the following question:
Yes
No
Is all of your suction piping in compliance with release detection requirements?
To answer yes here, you must have either:
answered yes to question 1 above; or
identified your method of release detection in question 2 and answered yes to question
3 above.
If you answered no, fill out a return to compliance plan and submit it with your certification of compliance.
A return to compliance plan form is in appendix B.
107
Chapter 4
Section 4.8
-------
4.8.3: Line Tightness Testing
f 1 A periodic line tightness test may be used to meet release detection requirements
^ for your piping. Line tightness testing may be performed by either a qualified
tester or by using a permanently installed electronic system. Line tightness testing must be able
to detect a 0.1 gallon per hour leak rate at 1.5 times the operating pressure of the piping.
Complete this section only if you use line tightness testing to meet the release detection
requirements for your piping.
Requirements And Best Management Practices For Line Tightness Testing
m
I You must keep records of tightness testing results until the next tightness test is
conducted.
For pressurized piping, testing is required every 12 months.
For suction piping, testing is required every three years.
If you use a permanently installed electronic system, you must keep records of any
calibration, maintenance, or repair of your equipment that were conducted in the last
12 months.
If you have an electronic system which is less than five years old, you must have all
records of performance claims, as well as calibration and maintenance schedules.
If you use a permanently installed electronic system, periodically have a trained
contractor such as the vendor who installed the system service that system
according to the manufacturer's instructions.
Chapter 4
108 Section 4.8
-------
Checklist For Line Tightness Testing
Circle the LIST number for each LIST that uses
line tightness testing. Answer the questions
below for each LIST you circled.
UST# =
Questions
Circle Yes (Y) or No (N)
1. Do you have a record of a passing test for your most recent line
tightness test? If your piping was recently installed, you should have a
line tightness test result from when it was installed.
If no, to return to compliance: Either find the record, obtain the record from the person who conducted the test,
or have a tightness test conducted and keep the record. If your tightness test did not pass, have a qualified LIST
contractor fix the problem and perform another tightness test.
2. Was your last tightness test conducted less than one year ago for
pressurized piping or less than three years ago for suction piping?
Enter the date of your most recent test (mm/dd/yy).
If no, to return to compliance: Have a tightness test conducted and make sure each section of piping passes the
test. Keep records of tightness testing at least until the next tightness test is conducted.
3. Do you have a line tightness tester come to your facility and
perform your line tightness testing?
If you answer yes to this question, stop. You do not have to answer the rest of the questions.
If you answer no to this question, that means you probably have a permanently installed electronic system.
Continue to question 4.
4. Do you have records of any calibration, maintenance, or repair
performed on your electronic system in the last 12 months? Answer
yes here if no calibration, maintenance, or repairs were performed in the
last 12 months.
If no, to return to compliance: Contact the contractor who performed the work and obtain the records.
5. If your electronic system is less than five years old, do you have
calibration and maintenance schedules?
Skip this question if your system is five years old or older.
If no, to return to compliance: Contact the vendor or manufacturer and obtain these schedules.
Summary Of Compliance For Line Tightness Testing
Is your line tightness test in compliance with release detection
requirements?
To answer yes here, you must have either:
answered yes to questions 1, 2 and 3 above; or
answered yes to questions 1, 2, 4 and, if applicable, question 5 above.
Copy these answers to question 4 of section 4.8.1 for pressurized piping or question 3 of section 4.8.2 for suction
piping.
109
Chapter 4
Section 4.8
-------
Summary Of Compliance With Piping Release Detection
Make sure you read and complete the checklists in the appropriate piping release detection
sections for all of your underground piping before answering the question below.
Summary Of Compliance With Piping Release Detection
Answer the following question:
Yes
No
Does all of your underground piping meet release detection requirements?
To answer yes here, you must have answered yes to all previous summary questions for each
type of piping delivery system at your facility.
If you have piping that contains a hazardous substance listed on the CERCLA list of hazardous substances (an
example would be a tank that contains antifreeze), then to meet the piping release detection requirements, you
must either:
use secondarily contained piping with interstitial monitoring (this is necessary for both pressurized and
suction piping); or
have a waiver from {state}
If you answered no, complete and submit a return to compliance plan addressing each area of non-
compliance. A return to compliance plan form is in appendix B.
(Copy your yes or no answer to question 7 of the certification of compliance form in appendix A)
110
Chapter 4
Section 4.8
-------
Section 4.9: What To Do For Suspected Or Confirmed Releases
r \ Personnel at your facility should be fully prepared to respond to releases
^ ' before they occur. In addition, employees need to know what to do when
release detection methods indicate a suspected or confirmed release.
Requirements And Best Management Practices For Suspected Or Confirmed Releases
^
I You must respond to, investigate, and report suspected or confirmed releases when
they occur.
The following steps will assist you in responding to suspected or confirmed releases.
Step 1. Stop The Release
• Take immediate action to prevent the release of more product.
• Turn off the power to the dispenser and tie a plastic bag around the nozzle.
Make sure you know where your emergency shutoff switch is located.
If necessary, empty the tank. Be careful to avoid further contaminating the site. You
may need the assistance of your supplier or distributor.
Step 2. Contain The Release
Contain, absorb, and clean up any surface release. You should keep enough absorbent
material at your facility to contain a spill or overfill of petroleum products until emergency
response personnel can respond to the incident.
The suggested supplies include, but are not limited to, the following:
Containment devices, such as containment booms, dikes, and pillows.
• Absorbent material, such as kitty litter, chopped corn cobs, sand, and sawdust. Be
sure you properly dispose of used absorbent materials.
Mats or other material capable of keeping spill or overfill out of nearby storm drains.
Spark-free flash light.
Spark-free shovel.
Buckets.
Reels of caution tape, traffic cones, and warning signs.
Personal protective gear.
Step 3. Identify Any Hazards
Identify any fire, explosion, or vapor hazards and take action to neutralize these hazards.
Chapter 4
111 Section 4.9
-------
Step 4. Call For Help
Contact your local fire or emergency response authority. Make sure you have these
crucial telephone numbers prominently posted where you and your employees can
easily see them.
Step 5. Report To Authorities
If you observe any of the following, contact {state} to report a suspected or confirmed
release as soon as possible (within 24 hours):
• Any spill or overfill of petroleum that exceeds 25 gallons or causes a sheen on
nearby surface water. Spills and overfills under 25 gallons that are contained and
immediately cleaned up do not have to be reported. If they cannot be quickly cleaned
up, they must be reported to your regulatory authority.
• Any released product at the UST site or in the surrounding area — such as the
presence of liquid petroleum; soil contamination; surface water or groundwater
contamination; or petroleum vapors in sewer, basement, or utility lines.
• Any unusual operating conditions you observe — such as erratic behavior of the
dispenser, a sudden loss of product, or an unexplained presence of water in the
tank. However, you are not required to report if the system equipment is found to be
defective, but not leaking, and is immediately repaired or replaced.
Results from your release detection system indicate a suspected release. However,
you are not required to report this if:
- The monitoring device is found to be defective and is immediately repaired,
recalibrated, or replaced and further monitoring confirms the initial suspected
release did not happen.
- In the case of inventory control, a second month of data does not confirm the
initial result.
Keep a list of emergency contacts and make sure everyone at your UST facility is
familiar with the list of contacts. Appendix D contains a blank list for names and
phone numbers of important contacts. Fill out this information for your facility so
you will know who to call in case of an emergency. Remove this page from the
manual, copy it, fill it out, and post it in a prominent place at your facility.
Summary Of Compliance With Suspected Or Confirmed Releases
Answer the following question:
Yes
No
Do you appropriately respond to and report all suspected or confirmed
releases? This includes responding to a suspected problem due to a failed
release detection result.
If you answered no, fill out a return to compliance plan and submit it with your certification of compliance.
A return to compliance plan form is in appendix B.
(Copy your yes or no answer to question 8 of the certification of compliance form in appendix A)
112
Chapter 4
Section 4.9
-------
Section 4.10: Financial Responsibility
To be in compliance with LIST regulations, you must demonstrate financial
responsibility (FR) - the ability to pay for cleanup or third-party liability
compensation - for all of your regulated underground storage tank systems.
This section provides a general explanation of the FR requirements. For detailed information on
FR, see the Office of Underground Storage Tank's web site at:
http://www.epa.gov/swerust1/ustsystm/finresp.htm.
Requirements For Financial Responsibility
You must have the appropriate:
• FR mechanism(s),
• amount of coverage,
• scope of coverage, and
• certification.
Each of these components of financial responsibility is discussed on the following
pages.
State and federal government entities whose debts and liabilities are the debts and
liabilities of a state or the United States are exempt from the FR requirements. If you
meet these criteria, skip this section.
Directions For Completing The Financial Responsibility Section
Step 1: Read the requirements you must meet for financial responsibility.
Step 2: Complete the Checklist For Financial Responsibility For Your Facility.
Step 3: Complete the Summary Of Compliance With Financial Responsibility Requirements
question on the bottom of the last page of this section.
Chapter 4
113 Section 4.10
-------
Requirements For Financial Responsibility Mechanisms
You must have an appropriate FR mechanism at your facility. The following mechanisms
may be used to comply with the FR requirements. You may use one or a
combination of these mechanisms.
• Financial Test Of Self-Insurance - A firm with a tangible net worth of at least $10 million
may demonstrate FR by passing one of the two financial tests listed in the federal
regulations.
Corporate Guarantee - You may secure a corporate guarantee from another eligible firm.
The provider of the guarantee has to pass one of the financial tests listed in the regulations.
Insurance Coverage - You may buy insurance from an insurer or a risk retention group.
Surety Bond - You may obtain a surety bond, which is a guarantee by a surety company
that it will satisfy FR obligations if the person who obtained the surety bond does not.
Letter Of Credit - You may obtain a letter of credit, which obligates the issuer to provide
funding for corrective action and third-party compensation.
Trust Fund - You may set up a fully-funded trust fund administered by a third party to pay
for corrective action and third-party compensation.
Other State Authorized Methods - You may use additional methods of coverage (e.g.,
certificate of deposit) authorized in {state}. Contact {state} to find out if this can apply to you.
State Financial Assurance Funds - You may be covered by a state fund that provides all
or a portion of FR to the degree it pays for cleanup and third-party compensation costs.
If you are a local government, there are four additional methods that you can use to comply with
the FR requirements:
• Bond Rating Test - A local government may demonstrate (or guarantee) FR by passing a
bond rating test.
Financial Test - A local government may demonstrate (or guarantee) FR by passing a
financial test.
Guarantee - A local government may obtain a guarantee from another local government or
the state.
Dedicated Fund - A local government may demonstrate (or guarantee) FR by establishing a
fund.
You may use one or a combination of mechanisms listed above to meet your FR obligations.
Combinations may be used to cover:
Different sets of tanks - For example, tanks in one state may be covered by a state fund,
while tanks in another state may be covered by insurance.
Different scopes of coverage - For example, an owner may use a state fund to cover
corrective action obligations and a letter of credit to cover third-party liability obligations.
Different dollar amounts of coverage - For example, an owner may have a letter of credit
for the first $20,000 (the deductible amount) of coverage and state fund coverage for the
rest.
Chapter 4
114 Section 4.10
-------
Requirements For Financial Responsibility Amount Of Coverage
Your FR mechanism (or combination of mechanisms) must provide the appropriate
amount of coverage. The text and table below describe the appropriate coverage.
The amount of coverage required varies by the type of tank owner or operator and
the number of tanks owned or operated. There are two general types of coverage
required: per occurrence and annual aggregate.
Per occurrence means the amount of money that must be available to pay the
costs for each occurrence of a leaking LIST. The amount of per occurrence
coverage required depends on the type of facility and, in some cases, on the
amount of throughput at the facility.
• Annual aggregate means the total amount of FR available to cover all
obligations that might occur in one year. The amount of annual aggregate
coverage required depends on the number of tanks that are owned or operated.
The amount of coverage required is provided in the table below.
Required Coverage Of Financial Responsibility
Group Of LIST Owners And Operators
Per Occurrence Amount
Aggregate Amount
Group 1: Petroleum producers, refiners,
or marketers
$1 million
Group 2: Non-marketers (Non-marketing
facilities do not sell or transfer petroleum to
the public or any other facility that would sell
the petroleum. Additionally, non-marketing
facilities do not produce or refine petroleum.
An example of a non-marketer is a bus
terminal.)
$500,000
(if throughput is 10,000
gallons monthly or less)
or
$1 million
(if throughput is more than
10,000 gallons monthly)
$1 million
(for 100 or fewer tanks)
or
$ 2 million
(for more than 100
tanks)
115
Chapter 4
Section 4.10
-------
Requirements For Financial Responsibility Scope Of Coverage
£•1 Your FR mechanism (or combination of mechanisms) must provide the appropriate
I scope of coverage.
The scope of coverage your insurance must provide includes different types of
obligations and releases.
Types of Obligations - FR must cover the costs of corrective action and third-
party compensation. Third-party compensation includes bodily injury and
property damage.
Types of Releases - Owners or operators must demonstrate FR for taking
corrective action and for compensating third parties for bodily injury and property
damage caused by accidental releases. FR is not required for intentional
releases. An accidental release may be sudden or non-sudden. All releases,
whether sudden or non-sudden, must be covered. This is necessary to ensure
adequate coverage for USTs in particular, because it is often difficult to
determine whether an LIST release is sudden or gradual. Therefore, to ensure
adequate protection of human health and the environment, both types of
coverage are necessary.
Requirements For Financial Responsibility Certification
You must maintain an up-to-date certification of FR.
The certification of FR must identify the financial assurance mechanism(s) used to
demonstrate FR. For each mechanism, the owner or operator must list the
following:
• type of mechanism,
name of issuer,
mechanism number (if applicable),
amount of coverage,
effective period of coverage, and
• whether the mechanism covers taking corrective action and/or compensating
third parties for bodily injury and property damage caused by either sudden
accidental releases or non-sudden accidental releases or accidental releases.
You must update this certification whenever the financial assurance mechanism(s)
used to demonstrate financial responsibility change(s).
Chapter 4
116 Section 4.10
-------
Requirements For Financial Responsibility Records And Reporting
You must maintain the appropriate records.
In addition to the certification of FR, you must keep evidence of all financial
assurance mechanisms used.
• You must maintain the evidence of all financial assurance at the underground
storage tank site or the place of work. Records maintained off-site must be made
available upon request of the implementing agency.
In all cases, you must maintain a copy of documentation for your FR mechanism
as worded in the regulations. Depending upon the mechanism used, various
other documentation must be maintained as well.
You must submit appropriate FR documentation to the implementing agency in the
following circumstances:
• Within 30 days after you identify a release from an LIST.
If you fail to obtain alternate coverage when required.
• At any time, as requested by the implementing agency. Many states require
annual reporting of FR documentation.
Chapter 4
117 Section 4.10
-------
Checklist For Financial Responsibility For Your Facility
Answer the following questions:
1. Do you have an appropriate FR mechanism or combination of mechanisms?
List the FR mechanism(s) you use at your facility. You may list more than one.
If no, then to return to compliance: Obtain one or more FR mechanism(s).
2. Does your FR mechanism (or combination of mechanisms) provide the
appropriate amount of coverage?
If no, then to return to compliance: Obtain the appropriate amount of coverage for FR.
3. Does your FR mechanism (or combination of mechanisms) provide the
appropriate scope of coverage?
If no, then to return to compliance: Obtain the appropriate scope of coverage for FR.
4. Do you have a current certificate of FR?
If no, then to return to compliance: Complete a certificate as worded in the federal regi
section 280.1 11(b)11.
5. Do you have all of your properly worded documentation for your FR
mechanism (or combination of mechanisms), as specified in the federal
regulations for FR?
If no, then to return to compliance: Obtain the properly worded documentation.
6. Do you keep all of your FR records at your LIST site or at your off-site place of
business?
If no, then to return to compliance: Obtain the appropriate records and begin keeping t
LIST site or at your off-site place of business.
7. Have you submitted the required FR documentation to {state}?
Some states require annual submission of FR documentation. Also, you must submit
documentation within 30 days after you identify a release from an LIST, if you fail to
obtain alternate FR coverage when required or as requested by the state.
If no documentation is required to be submitted, answer yes here.
If no, then to return to compliance: Submit any required documentation to {state} .
Yes
Y
No
N
Y
N
Y
N
Y
N
jlations,
Y
N
Y
N
hem at your
Y
N
Summary Of Compliance With Financial Responsibility Requirements
Answer the following question:
Yes
No
Are you in compliance with the financial responsibility requirements?
To answer yes here, you must have answered yes to all questions above.
If you answered no, fill out a return to compliance plan and submit it with your certification of compliance.
A return to compliance plan form is in appendix B.
Remember if you are a state or federal government entity, you are not required to meet the FR requirements.
(Copy your yes or no answer to question 9 of the certification of compliance form in appendix A)
118
Chapter 4
Section 4.10
-------
This Page Intentionally Left Blank
119
-------
Section 4.11: Temporarily Closed USTs
USTs in temporary closure must meet the requirements for corrosion protection
and, if not emptied, the requirements for release detection. USTs in temporary
closure for more than three months must have their vent lines open and all other
lines, pumps, manways, and ancillary equipment must be capped and secured.
Directions For Completing The Temporarily Closed USTs Section
Step 1: Answer the question below.
Step 2: Proceed as instructed by the text in the grey box below the question.
Do you have at least one LIST that is in temporary closure? Yes No (Circle one)
Typically, you as an owner or operator would have decided to place an LIST in temporary
closure. If you are not sure whether you have an LIST in temporary closure, contact {state}.
If you answered yes to this question, read the requirements below and complete the
Checklist For USTs In Temporary Closure questions and Summary Of Compliance For
Temporary Closure question on the next page for each LIST in temporary closure.
If you answered no to this question, skip section 4.11.
Requirements For Temporarily Closed USTs
If your LIST is not empty, it must continue to meet the leak detection requirements for
both tank and piping.
• An empty tank means that no more than one inch of residue (including product,
sludge, water, etc.) or 0.3 percent by weight of the total tank capacity, remain in
the LIST. Empty tanks do not require leak detection.
All corrosion protection systems must remain operational on the LIST and must
continue to be monitored. Vent lines should remain open.
If an LIST remains temporarily closed for more than three months, you must leave
vent lines open but close all other lines, pumps, manways, and ancillary equipment
by capping and securing them.
You must respond to any releases from your temporarily closed LIST, just as you
would from an LIST that you are currently using.
Chapter 4
120 Section 4.11
-------
Checklist For Temporarily Closed USTs
Circle the LIST number for each LIST that is in
temporary closure. Answer the questions below
for each LIST you circled.
UST# =
Questions
Circle Yes (Y) or No (N)
1. Does your temporarily closed LIST meet all the appropriate
requirements for release detection in sections 4.7 and 4.8?
You must read and complete sections 4.7 and 4.8 for each LIST in
temporary closure before answering this question.
Skip this question if your tank is empty. Empty means that no more than one inch of residue or 0.3
percent by weight of the total tank capacity remains in the LIST.
If no, then to return to compliance: Either empty the LIST or ensure your LIST meets the appropriate
leak detection requirements.
2. Does your temporarily closed LIST meet the requirements
for corrosion protection described in sections 4.4 and 4.5?
You must read and complete sections 4.4 and 4.5 for each LIST in
temporary closure before answering this question.
If no, then to return to compliance: Ensure your LIST meets the appropriate corrosion protection
requirements.
3. Are the vent lines open on your temporarily closed LIST?
If no, then to return to compliance: Open the vent lines.
4. For an LIST in temporary closure for more than three
months, have you capped all lines (except vent lines), pumps,
manways, and ancillary equipment on that LIST?
Skip this question if your LIST has been in temporary closure for less than three months.
If no, then to return to compliance: Cap all lines (except vent lines), pumps, manways, and ancillary
equipment on the temporarily closed LIST.
Summary Of Compliance For Temporarily Closed USTs
Answer the following question:
Are all of your USTs currently in temporary closure in compliance?
To answer yes here, you must have answered yes to all applicable questions above.
Yes
No
If you answered no, fill out a return to compliance plan and submit it with your certification of compliance.
A return to compliance plan form is in appendix B.
(Copy your yes or no answer to question 10 of the certification of compliance form in appendix A)
121
Chapter 4
Section 4.11
-------
Section 4.12: Keeping Your State Agency Informed Of USTs Brought
Into Use And Changes To USTs
Directions For Completing This Section
Step 1: Answer the question below.
Step 2: Proceed as instructed by the text in the grey box below the question.
Have you brought an UST into use in the last year? Yes No (Circle one)
If you answered yes to this question, read the requirements and best management
practices below. Then complete the question below.
If you answered no to this question, you may skip this section.
Requirements And Best Management Practices For USTs Brought Into Use And Changes
To USTs
Within 30 days of bringing an UST into use, you must submit a notification form
(appendix M contains the federal form or you can download it from the internet at
http://www.epa.gov/OUST/fedlaws/cfr.htmtfustform). If you are not sure who to
notify, contact {state}.
You should notify {state} anytime changes are made to any of your USTs. To notify
the appropriate agency you may use a notification form (appendix M contains the
federal form or you can download it from the internet at
http://www.epa.gov/OUST/fedlaws/cfr.htmtfustform). If you are not sure who to
notify, contact {state}.
Examples of changes for which you should notify {state} include but are not limited
to:
• change in ownership;
change in tank or tank equipment;
change in tank contents; and
change in piping or piping equipment.
Checklist For USTs Brought Into Use
Summary Of Compliance With Notification For New USTs
Answer the following question:
Did you submit a notification form to {state} for all USTs that you recently
brought into use?
If no, then to return to compliance: Submit a notification form as soon as possible.
Yes
No
(Copy your yes or no answer to question 11 of the certification of compliance form in appendix A)
122
Chapter 4
Section 4.12
-------
Section 4.13: Repairs
Directions For Completing This Section
Step 1: Answer the question below.
Step 2: Proceed as instructed by the text in the grey box below the question.
Have you had any repairs performed on any of your UST systems? Yes No
If you answered yes to this question, read the requirements below. Then complete the
question below.
If you answered no to this question, you may skip this section.
Requirements For Repairs
A code of practice must be followed when repairs are performed on your UST
system.
If you have a fiberglass-reinforced plastic tank, repairs may be made by the
manufacturer's authorized representative or according to a code of practice.
Metal piping sections and fittings that have released product must be replaced.
Fiberglass pipe and fittings may be repaired according to manufacturer's
specifications.
Repaired tanks and piping must meet one of the following:
Be tightness tested within 30 days of the repair.
Be internally inspected according to a code of practice.
Be monitored monthly for releases.
__ Cathodically protected UST systems that are repaired must have a cathodic
• protection test performed within six months of the repair to make sure the cathodic
protection system is working properly.
• You must keep records of all repairs for the remaining operating life of the UST
system.
Checklist For UST System Repairs
Summary Of Compliance With UST System Repairs
Answer the following question:
Yes
No
Do all of your repaired UST systems meet the repair requirements?
If no, then to return to compliance: Contact {state} to determine how to return to compliance.
(Copy your yes or no answer to question 12 of the certification of compliance form in appendix A)
123
Chapter 4
Section 4.13
-------
This Page Intentionally Left Blank
124
-------
Appendix A: Model Certification Of Compliance Form
{This model form is designed to assist states in developing a certification of compliance
form where certification is part of an environmental results program for underground
storage tanks.}
Complete this form by answering the questions below (these answers may be transcribed from
chapter 4 of the workbook), reading and completing the certification statement, and signing the
certification statement. More than one responsible owner and/or operator may sign this
certification form. If more than one person signs, then indicate the appropriate responsible
owner and/or operator responding to each question below. Signatories #1 and #2 correspond
to the signatures on the back of this form.
Submit this form to:
{state}
{address}
{address}
Questions
(Answer each question below. Skip a question only if directed to do so.)
Question 1: Spill Protection (Section 4.1)
Are all of your USTs in compliance with spill protection?
Question 2: Correct Filling Practices (Section 4.2)
Are you in compliance with correct filling practices?
Question 3: Overfill Protection (Section 4.3)
Are all of your USTs in compliance with overfill protection?
Question 4: Tank Corrosion Protection (Section 4.4)
Do all of your underground tanks meet corrosion protection requirements?
Question 5: Piping Corrosion Protection (Section 4.5)
Does all of your piping that is in contact with the ground and routinely contains
product meet corrosion protection requirements?
Question 6: Release Detection For Tanks (Section 4.7)
Are all of your tanks in compliance with release detection requirements?
Question 7: Release Detection For Piping (Section 4.8)
Does all of your underground piping meet release detection requirements?
Question 8: Suspected Or Confirmed Releases (Section 4.9)
Do you appropriately respond to and report all suspected or confirmed releases?
Question 9: Financial Responsibility (Section 4.10)
Are you in compliance with the financial responsibility requirements?
Question 10: Temporary Closure (Section 4.11)
Are all of your USTs currently in temporary closure in compliance?
Skip this question if you have no USTs in temporary closure.
Question 11: New UST Installations (Section 4.12)
Did you submit a notification form to {state} for all USTs that you recently
brought into use?
Skip this question if you have not recently brought any USTs into use.
Question 12: UST System Repairs (Section 4.13)
Do all of your repaired UST systems meet the repair requirements?
Skip this question if you do not have any repairs to UST systems.
Circle
Either
Yes Or No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
No
No
No
No
No
Circle The
Appropriate
Responsible
Signatory
#1
#1
#1
#1
#1
#1
#1
#1
#1
#1
#1
#1
#2
#2
#2
#2
#2
#2
#2
#2
#2
#2
#2
#2
A-1
Appendix A
-------
Certification Statement
NOTE: Before signing this statement, check the following boxes to make sure you:
D read and understood the accompanying workbook;
D completely read and filled out this form (all questions should be answered unless you are
directed to skip a question);
D indicated the number of questions for which you were directed to fill out a Return To
Compliance Plan Form here:
I attest under the pains and penalties of perjury that, where I have indicated that I am the
responsible owner and/or operator,
I have personally examined and am familiar with the information contained in this submittal,
including any and all documents accompanying this certification statement;
Based on my inquiry of those individuals responsible for obtaining the information, the
information contained in this submittal is to the best of my knowledge true, accurate, and
complete;
Systems to maintain compliance1 are in place at this facility and will be maintained for the
coming year even if processes or operating procedures are changed over the course of the
year;
If any non-compliance items were identified in the compliance certification process, this
facility will return to compliance in accordance with the plan proposed in the attached Return
To Compliance Plan Form(s);
I realize that other federal, state, or local environmental laws, including more stringent
county and municipal requirements, may apply to my facility. I acknowledge that my facility
must comply with all applicable environmental laws, even if they are not included in this
form, and that submission of this form does not provide immunity from any applicable
environmental laws; and
I am fully authorized to make this attestation on behalf of this facility and am aware that
there are significant penalties [fill in applicable state law] for [knowingly/willfully, depending
on state law] submitting any false statement, representation, or certification.
Responsible Owner And/Or Operator #1:
Printed Name Signature Title Date
Responsible Owner And/Or Operator #2 (if applicable):
Printed Name Signature Title Date
Facility Name Facility Identification Number
Address (Street Address, City, Zip Code) Phone Number
1For purposes of this statement, "systems to maintain compliance" means procedures the facility
owner and/or operator has established to ensure periodic tests are conducted, broken or defective
components are repaired or replaced, and required records are maintained.
Appendix A
A-2
-------
Appendix B: Model Return To Compliance Plan Form
{This model form is designed to be used in states that have developed an environmental results
program for underground storage tanks and who require submission of a return to compliance plan
form as part of that program.}
Complete a return to compliance plan for each question for which you are out of compliance.
The next page contains continuation sheets for the return to compliance plan. Copy and
complete these sheets for additional areas of non-compliance at your facility.
Submit your return to compliance plan(s) to {state} with your certification of compliance.
Completing this form does not relieve the facility of its affirmative responsibility to operate in
compliance with applicable regulations. Failure to operate in full compliance with the
applicable regulations may result in enforcement actions that include fines or penalties.
Facility Information
Facility Name Facility Contact Contact Phone Number
Facility Street Address City State Zip Code
Return To Compliance Information
What is the specific area of non-compliance (include the workbook section number in which the
requirement is explained, the LIST numbers not in compliance, and a description of the
requirement)?
a) Workbook section number:
b) LIST number(s) not in compliance:
c) Brief description of the requirement:
2. What action will you take to return to compliance?
3. What is the date by which you will return to compliance? (month/day/year)
(This date should be as soon as possible, but no more than 90 days after submitting your
certification of compliance)
Appendix B
B-1
-------
Return To Compliance Information (Continuation Sheet)
What is the specific area of non-compliance (include the workbook section number in which the
requirement is explained, the LIST numbers not in compliance, and a description of the
requirement)?
a) Workbook section number:
b) LIST number(s) not in compliance:
c) Brief description of the requirement:
2. What action will you take to return to compliance?
3. What is the date by which you will return to compliance? (month/day/year)
(This date should be as soon as possible, but no more than 90 days after submitting your
certification of compliance)
Return To Compliance Information (Continuation Sheet)
1. What is the specific area of non-compliance (include the workbook section number in which the
requirement is explained, the LIST numbers not in compliance, and a description of the
requirement)?
a) Workbook section number:
b) LIST number(s) not in compliance:
c) Brief description of the requirement:
2. What action will you take to return to compliance?
3. What is the date by which you will return to compliance? (month/day/year)
(This date should be as soon as possible, but no more than 90 days after submitting your
certification of compliance)
Appendix B
B-2
-------
Appendix C: Model Non-Applicability Form
{This model form is designed to be used in states that have developed an environmental results program for
underground storage tanks and who require submission of a non-applicability form as part of that program.}
Instructions
Complete chapter 1 of the workbook to determine whether the underground storage tank Environmental
Results Program applies to your facility.
Complete this form and send it to {state} only if you are not required to participate in the underground
storage tank Environmental Results Program. Completing this form means that either you do not have
any underground storage tanks or all of your underground storage tanks meet the exceptions described
in chapter 1. If any of your underground storage tanks are regulated or if any of your underground
storage tanks store product solely for use by emergency power generators, then you are included in the
underground storage tank Environmental Results Program.
Keep a copy of this statement for your records.
Information:
Name Of Person Completing Form
Address City/Town
Zip Code Phone Number Fax Number
Number of underground storage tanks at your facility:
This facility is not eligible for the underground storage tank Environmental Results Program for the
following reason(s): (Check at least one of the boxes below)
D There are no underground storage tanks at this facility.
Indicate the type of facility on the lines below.
(example: auto repair shop that has no underground storage tanks)
D All underground storage tanks at this facility are not covered by the Environmental Results
Program.
• Write on the lines below the number of underground storage tanks at your facility and the reason why
each underground storage tank is not covered by the Environmental Results Program.
(example: one underground storage tank that is a septic tank)
Exclusion from the underground storage tank Environmental Results Program does not relieve you of
your responsibility to comply with other environmental requirements.
Signature Of Person Completing Form Title Date
Appendix C
C-1
-------
Appendix D: Sample Emergency Numbers List
Important Contact Information
Contact Name
Phone #
State UST Agency:
Local UST Agency:
Fire Department:
Ambulance:
Police Department:
Repair Contractor:
Other Contacts:
Release Response Checklist
Stop The Release: Take immediate action to prevent the release of more product. Turn off the
power to the dispenser and wrap a plastic bag around the nozzle. Make sure you know where
your emergency shutoff switch is located. Empty the tank, if necessary, without further
contaminating the site.
Contain The Spill Or Overfill: Contain, absorb, and clean up any surface releases. Identify any
fire, explosion, or vapor hazards and take action to neutralize these hazards.
Call For Help And Report Suspected Or Confirmed Releases: Contact your local fire or
emergency response authority. Contact your state's underground storage tank regulatory authority
within 24 hours.
Appendix D
D-1
-------
Appendix E: Definitions
This appendix contains both definitions from the federal LIST regulations at 40 C.F.R. Part 280
and definitions developed or gathered specifically for this model workbook and are not listed in
the regulations. The definitions are separated below into these two categories.
Definitions In The Federal LIST Regulations At 40 C.F.R. Part 280
Accidental Release means any sudden or non-sudden release of petroleum from an LIST that
results in a need for corrective action and/or compensation for bodily injury or property damage
neither expected nor intended by the tank owner or operator.
Ancillary Equipment means any devices including, but not limited to, such devices as piping,
fittings, flanges, valves, and pumps used to distribute, meter, or control the flow of regulated
substances to and from an LIST.
Beneath the surface of the ground means beneath the ground surface or otherwise covered
with earthen materials.
Cathodic Protection is a technique to prevent corrosion of a metal surface by making that
surface the cathode of an electrochemical cell. For example, a tank system can be cathodically
protected through the application of either galvanic anodes or impressed current.
Cathodic Protection Tester means a person who can demonstrate an understanding of the
principles and measurements of all common types of cathodic protection systems as applied to
buried or submerged metal piping and tank systems. At a minimum, such persons must have
education and experience in soil resistivity, stray current, structure-to-soil potential, and
component electrical isolation measurements of buried metal piping and tank systems.
CERCLA means the Comprehensive Environmental Response, Compensation, and Liability Act
of 1980, as amended.
Compatible means the ability of two or more substances to maintain their respective physical
and chemical properties upon contact with one another for the design life of the tank system
under conditions likely to be encountered in the LIST.
Connected Piping means all underground piping including valves, elbows, joints, flanges, and
flexible connectors attached to a tank system through which regulated substances flow. For the
purpose of determining how much piping is connected to any individual LIST system, the piping
that joins two LIST systems should be allocated equally between them.
Appendix E
E-1
-------
Corrosion Expert means a person who, by reason of thorough knowledge of the physical
sciences and the principles of engineering and mathematics acquired by a professional
education and related practical experience, is qualified to engage in the practice of corrosion
control on buried or submerged metal piping systems and metal tanks. Such a person must be
accredited or certified as being qualified by the National Association of Corrosion Engineers or
be a registered professional engineer who has certification or licensing that includes education
and experience in corrosion control of buried or submerged metal piping systems and metal
tanks.
Dielectric Material means a material that does not conduct direct electrical current. Dielectric
coatings are used to electrically isolate LIST systems from the surrounding soils. Dielectric
bushings are used to electrically isolate portions of the LIST system (e.g., tank from piping).
Existing Tank System means a tank system used to contain an accumulation of regulated
substances or for which installation has commenced on or before December 22, 1988.
Installation is considered to have commenced if:
(a) the owner or operator has obtained all federal, state, and local approvals or permits
necessary to begin physical construction of the site or installation of the tank system;
and if,
(b) (1) either a continuous on-site physical construction or installation program has begun;
or,
(2) the owner or operator has entered into contractual obligations - which cannot be
cancelled or modified without substantial loss - for physical construction at the site or
installation of the tank system to be completed within a reasonable time.
Farm Tank is a tank located on a tract of land devoted to the production of crops or raising
animals, including fish, and associated residences and improvements. A farm tank must be
located on the farm property. Farm includes fish hatcheries, rangeland and nurseries with
growing operations.
Flow-Through Process Tank is a tank that forms an integral part of a production process
through which there is a steady, variable, recurring, or intermittent flow of materials during the
operation of the process. Flow-through process tanks do not include tanks used for the storage
of materials prior to their introduction into the production process or for the storage of finished
products or by-products from the production process.
Hazardous Substance LIST System means an underground storage tank system that contains
a hazardous substance defined in section 101(14) of the Comprehensive Environmental
Response, Compensation, and Liability Act of 1980 (but not including any substance regulated
as a hazardous waste under subtitle C) or any mixture of such substances and petroleum, and
which is not a petroleum LIST system.
Appendix E
E-2
-------
Heating Oil means petroleum that is No. 1, No. 2, No. 4-light, No. 4-heavy, No. 5-light, No. 5-
heavy, and No. 6 technical grades of fuel oil; other residual fuel oils (including Navy Special
Fuel Oil and Bunker C); and other fuels when used as substitutes for one of these fuel oils.
Heating oil is typically used in the operation of heating equipment, boilers, or furnaces.
Hydraulic Lift Tank means a tank holding hydraulic fluid for a closed-loop mechanical system
that uses compressed air or hydraulic fluid to operate lifts, elevators, and other similar devices.
Maintenance means the normal operational upkeep to prevent an underground storage tank
system from releasing product.
New Tank System means a tank system used to contain an accumulation of regulated
substances and for which installation has commenced after December 22, 1988. (See also
Existing Tank System.)
Noncommercial Purposes with respect to motor fuel means not for resale.
Occurrence means an accident, including continuous or repeated exposure to conditions,
which results in a release from an LIST.
On The Premises Where Stored with respect to heating oil means LIST systems located on
the same property where the stored heating oil is used.
Operator means any person in control of, or having responsibility for, the daily operation of the
LIST system.
Overfill Release is a release that occurs when a tank is filled beyond its capacity, resulting in a
discharge of the regulated substance to the environment.
Owner means:
(a) in the case of an LIST system in use on November 8, 1984, or brought into use after that
date, any person who owns an LIST system used for storage, use, or dispensing of regulated
substances; and
(b) in the case of any LIST system in use before November 8, 1984, but no longer in use on that
date, any person who owned such LIST immediately before the discontinuation of its use.
Petroleum LIST System means an underground storage tank system that contains
petroleum or a mixture of petroleum with cfe minimi's quantities of other regulated substances.
Such systems include those containing motor fuels, jet fuels, distillate fuel oils, residual fuel oils,
lubricants, petroleum solvents, and used oils.
Pipe or Piping means a hollow cylinder or tubular conduit that is constructed of non-earthen
materials.
Appendix E
E-3
-------
Pipeline Facilities (Including Gathering Lines) are new and existing pipe rights-of-way and
any associated equipment, facilities, or buildings.
Regulated Substance means
(a) any substance defined in section 101(14) of the Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) of 1980 (but not including any substance regulated
as a hazardous waste under subtitle C), and
(b) petroleum, including crude oil or any fraction thereof that is liquid at standard conditions of
temperature and pressure (60 degrees Fahrenheit and 14.7 pounds per square inch absolute).
The term regulated substance includes but is not limited to petroleum and petroleum-based
substances comprised of a complex blend of hydrocarbons derived from crude oil though
processes of separation, conversion, upgrading, and finishing, such as motor fuels, jet fuels,
distillate fuel oils, residual fuel oils, lubricants, petroleum solvents, and used oils.
Release means any spilling, leaking, emitting, discharging, escaping, leaching, or disposing
from an LIST into groundwater, surface water or subsurface soils.
Release Detection means determining whether a release of a regulated substance has
occurred from the LIST system into the environment or into the interstitial space between the
LIST system and its secondary barrier or secondary containment around it.
Repair means to restore a tank or LIST system component that has caused a release of product
from the LIST system.
Residential Tank is a tank located on property used primarily for dwelling purposes.
Septic Tank is a water-tight covered receptacle designed to receive or process, through liquid
separation or biological digestion, the sewage discharged from a building sewer. The effluent
from such receptacle is distributed for disposal through the soil and settled solids and scum
from the tank are pumped out periodically and hauled to a treatment facility.
Storm-Water Or Wastewater Collection System means piping, pumps, conduits, and any
other equipment necessary to collect and transport the flow of surface water run-off resulting
from precipitation or domestic, commercial, or industrial wastewater to and from retention areas
or any areas where treatment is designated to occur. The collection of storm water and
wastewater does not include treatment except where incidental to conveyance.
Tank is a stationary device designed to contain an accumulation of regulated substances and
constructed of non-earthen materials (e.g., concrete, steel, plastic) that provide structural
support.
Appendix E
E-4
-------
Underground Storage Tank or UST means any one or combination of tanks (including
underground pipes connected thereto) that is used to contain an accumulation of regulated
substances, and the volume of which (including the volume of underground pipes connected
thereto) is 10 percent or more beneath the surface of the ground. This term does not include
any:
(a) Farm or residential tank of 1,100 gallons or less capacity used for storing motor fuel for
noncommercial purposes;
(b) Tank used for storing heating oil for consumptive use on the premises where stored;
(c) Septic tank;
(d) Pipeline facility (including gathering lines) regulated under:
(1) The Natural Gas Pipeline Safety Act of 1968 (49 U.S.C. App. 1671, etseq.), or
(2) The Hazardous Liquid Pipeline Safety Act of 1979 (49 U.S.C. App. 2001, etseq.), or
(3) Which is an intrastate pipeline facility regulated under state laws comparable to the
provisions of the law referred to in paragraph (d)(1) or (d)(2) of this definition;
(e) Surface impoundment, pit, pond, or lagoon;
(f) Storm-water or wastewater collection system;
(g) Flow-through process tank;
(h) Liquid trap or associated gathering lines directly related to oil or gas production and
gathering operations; or
(i) Storage tank situated in an underground area (such as a basement, cellar, mineworking,
drift, shaft, or tunnel) if the storage tank is situated upon or above the surface of the floor.
The term underground storage tank or UST does not include any pipes connected to any tank
which is described in paragraphs (a) through (i) of this definition.
Upgrade means the addition or retrofit of some systems such as cathodic protection, lining, or
spill and overfill controls to improve the ability of an underground storage tank system to prevent
the release of product.
UST System or Tank System means an underground storage tank, connected underground
piping, underground ancillary equipment, and containment system, if any.
Wastewater Treatment Tank means a tank designed to receive and treat an influent
wastewater through physical, chemical, or biological methods.
Appendix E
E-5
-------
Definitions Developed Or Gathered For This ERP Workbook And Not
Listed In The Federal Regulations
Coating means a layer of dielectric material (a material that does not conduct direct electrical
current) that is applied to the outside wall of steel tanks and piping.
Compliance means that a facility meets the minimum requirements as stated in the regulations.
Corrective Action means activities associated with cleaning up a site where a release to the
environment has occurred.
Corrosion means the degradation of a material due to a reaction with its environment. An
example of corrosion is the rusting of steel.
Empty means that all materials have been removed using commonly employed practices so
that no more than 2.5 centimeters (one inch) of residue (including product, water, sludge, etc.),
or 0.3 percent by weight of the total tank capacity of the LIST system, remain in the system.
Field Constructed Tank is a tank that was not constructed or built in a factory, but rather,
constructed or built in the field (such as at the location where it was installed). For example,
very large tanks may be field constructed.
Fill Pipe is the pipe that extends from the surface to the tank that is used for filling the tank with
substances.
Financial Responsibility is the ability to pay for cleanup or third-party liability compensation.
Non-corrodible material means a material that will not corrode or degrade in the environment
where it is placed. For example, fiberglass material in the soil.
Non-marketing facility means a facility that does not sell or transfer petroleum to the public or
any other facility that would sell the petroleum. Additionally, non-marketing facilities do not
produce or refine petroleum. An example of a non-marketer is a bus terminal.
Pressurized Delivery is a delivery where product is pumped from the delivery truck to the tank.
Secondary Containment is an additional barrier between the part of the tank or piping that
contains product and the outside environment. Examples of secondary containment are double-
walled tanks and piping, tank bladders, tank jackets, and excavation liners.
Appendix E
E-6
-------
Stage I Vapor Recovery is a system that captures the vapors expelled from an underground
storage tank as a result of being filled by a delivery truck. There are two primary types - coaxial
and two point. Coaxial Stage I vapor recovery is two concentric channels, one inside of the
other. The inner channel conveys product from the delivery truck to the tank while the outer
channel conveys vapors from the tank to the delivery truck. Two point Stage I vapor recovery
uses two separate connections, one to deliver product to the tank and the other to deliver
vapors to the delivery truck.
Sump means an underground area such as a hole or pit that is used to house equipment.
Sumps may or not be contained.
(a) in the case of a turbine sump, it is an area above the tank over which a cover is placed
that houses the submersible turbine pump head, line leak detector, piping and other
equipment.
(b) In the case of a dispenser sump, it is the area beneath a dispenser that houses piping
and other equipment.
Appendix E
E-7
-------
Appendix F: For More Information
This section identifies LIST program contacts and other resources that can help answer your
questions and provide you with information about good LIST management.
State Regulatory Agency Information
{To be filled in by state agency}
Internet Resources
U.S. Government Links
U.S. Environmental Protection Agency's (EPA) Office of Underground Storage Tanks
Home Page: http://www.epa.gov/oust. To go directly to the compliance assistance
section of the Home page go to: http://www.epa.gov/swerust1/cmplastc/index.htm.
To go directly to EPA's listing of publications, go to:
http://www.epa.gov/swerust1/pubs/index.htm.
U.S. EPA Office of Enforcement and Compliance Assurance compliance assistance
website: http://www.epa.gov/compliance/assistance/index.html
Professional And Trade Association Links
• American Petroleum Institute (API): http://www.api.org/
• American Society For Testing and Materials (ASTM): http://www.astm.org/index.html
Fiberglass Tank and Pipe Institute (FTPI): http://www.fiberglasstankandpipe.com
NACE International - The Corrosion Society: http://www.nace.org/
National Fire Protection Association (NFPA): http://www.nfpa.org
Petroleum Equipment Institute (PEI): http://www.pei.org
Steel Tank Institute (STI): http://www.steeltank.com/
Underwriters Laboratories (UL): http://www.ul.com
Free Informative Publications Available From EPA
The publications listed on the next pages are free and available from the U.S. EPA. You can
access these publications via EPA's website or you can call, write to, or fax EPA.
• You can download, read, or order documents from
http://www.epa.gov/swerust1/pubs/index.htm.
• To order free copies or ask questions, call EPA's toll-free RCRA/Superfund Hotline at 800-
424-9346 or call EPA's publication distributor's toll-free number at 800-490-9198 or fax
513-489-8695. You can also write and ask for free publications by addressing your request
to EPA's publication distributor: National Service Center for Environmental Publications
(NSCEP), Box42419, Cincinnati, OH 45242.
Fax-on-Demand allows you to call 202-651-2098 on your fax to access over 220 UST
documents.
Appendix F
F-1
-------
Document
General Information About USTs
Operating And Maintaining
Underground Storage Tank
Systems: Practical Help And
Checklists (August 2000)
Musts For USTs: A Summary Of
Federal Regulations For
Underground Storage Tank
Systems (July 1995)
Underground Storage Tanks:
Requirements And Options (June
1997)
Description
And Your Requirements
Contains brief summaries of the federal LIST requirements for
operation and maintenance, as well as practical help that goes
beyond the requirements. Checklists prompt the user to look
closely at what kinds of equipment are in use and how to keep
equipment working properly over the lifetime of the LIST. The
manual provides record keeping forms to help the LIST owner
and operator keep equipment operating properly.
Plain language summary of federal LIST requirements for
installation, release detection, spill, overfill, and corrosion
protection, corrective action, closure, reporting and record
keeping.
Trifold leaflet alerts LIST owners and operators who are
nonmarketers (who do not sell stored petroleum) of their
responsibilities and choices for complying with federal LIST
regulations.
Leak Detection Information
Straight Talk On Tanks: Leak
Detection Methods For
Petroleum Underground Storage
Tanks (September 1997)
Automatic Tank Gauging
Systems For Release Detection:
Reference Manual For
Underground Storage Tank
Inspectors (August 2000)
Getting The Most Out Of Your
Automatic Tank Gauging System
(March 1998)
Doing Inventory Control Right:
For Underground Storage Tanks
(November 1993)
Manual Tank Gauging: For Small
Underground Storage Tanks
(November 1993)
Explains federal regulatory requirements for leak detection and
briefly describes allowable leak detection methods.
Contains detailed information on automatic tank gauging (ATG)
systems, including information on various types of ATGs,
information on certified detectable leak rate/threshold, test
period duration, product applicability, calibration requirements,
restrictions on the use of the device, vendor contact
information, printing and interpreting reports, sample reports,
and so on.
Trifold leaflet provides LIST owners and operators with a basic
checklist they can use to make sure their automatic tank
gauging systems work effectively and provide compliance with
federal leak detection requirements.
Booklet describes how owners and operators of USTs can use
inventory control and periodic tightness testing to temporarily
meet federal leak detection requirements. Contains record
keeping forms.
Booklet provides simple, step-by-step directions for conducting
manual tank gauging for tanks 2,000 gallons or smaller.
Contains record keeping forms.
Appendix F
F-2
-------
Document Description
List Of Leak Detection A summary of specifications, based on third-party certifications,
Evaluations For LIST Systems, 9th for over 275 systems that detect leaks from USTs and their
Edition (November 2001) piping. Each summary provides information on such items as
certified detectable leak rate/threshold, test period duration,
'Available through the EPA website product applicability, calibration requirements, restrictions on
the use of the device, and so on.
Introduction To Statistical Booklet describes how Statistical Inventory Reconciliation (SIR)
Inventory Reconciliation: For can meet federal leak detection requirements.
Underground Storage Tanks
(September 1995)
Information On Closing Underground Storage Tanks
Closing Underground Storage Trifold leaflet presents brief facts on properly closing USTs in
Tanks: Brief Facts (July 1996) order to comply with federal closure requirements.
Financial Responsibility Information
Dollars And Sense: Financial Booklet summarizes the financial responsibility required of LIST
Responsibility Requirements For owners and operators.
Underground Storage Tanks
(July 1995)
List Of Known Insurance Booklet provides LIST owners and operators with a list of
Providers For Underground insurance providers who may be able to help them comply with
Storage Tanks (January 2000) financial responsibility requirements by providing suitable
insurance mechanisms.
Financial Responsibility For This detailed, comprehensive manual provides LIST inspectors
Underground Storage Tanks: A with the restrictions, limitations, and requirements of each
Reference Manual (January 2000) financial responsibility mechanism provided in the federal LIST
regulations.
'Available through the EPA website
Appendix F
F-3
-------
Appendix G: Examples Of Placards For Overfill Devices
Delivery Person - Avoid Overfills
An overfill alarm is used for overfill protection at this
facility.
Do not tamper with this alarm in any attempt to defeat
its purpose.
When the tank is 90 percent full or is within one minute
of being overfilled, the overfill alarm sounds and/or a
light comes on or flashes.
If you hear the alarm or see the light on or flashing,
Stop The Delivery Immediately!
Appendix G
G-1
-------
Delivery Person - Avoid Overfills
A ball float valve is used for overfill protection at this
facility.
Do not tamper with this device in any attempt to defeat
its purpose.
When the tank is 90 percent full, or 30 minutes prior to
when the product would overfill the tank, the ball float
will activate and the flow rate of the delivery will
decrease noticeably.
When you notice a decrease in flow rate,
Stop The Delivery Immediately!
Appendix G
G-2
-------
Delivery Person - Avoid Overfills
An automatic shutoff device is used for overfill
protection at this facility.
Do not tamper with this device in any attempt to defeat
its purpose.
When the tank is 95 percent full or before the fittings on
top of the tank are exposed to product, the device will
activate and slow down, and then stop the delivery
before the tank is overfilled.
When the automatic shutoff device activates,
Stop The Delivery Immediately!
Appendix G
G-3
-------
This Page Intentionally Left Blank
-------
Appendix H: Sample Cathodic Protection Testing Form
(For Use By A Qualified Cathodic Protection Tester)
Test Date: / / Facility Name/ID:_
Note: Provide a site sketch as directed on the back of this page.
Cathodic Protection (CP) Tester Information:
Name: Phone Number:_
Address:
Testing must be conducted by a qualified CP tester. Indicate your qualifications as a CP tester:
Identify which of the following testing situations applies:
• »Test required within six months of installation of CP system (installation date was / /
• »Test required at least every three years after installation test noted above
• »Test required within six months of any repair activity - note repair activity and date below:
Indicate which industry standard you used to determine that the cathodic protection test criteria are
adequate:
Cathodic Protection Test Method Used (check one)
100 mV Cathodic Polarization Test
-850 mV Test (Circle 1 or 2 below)
1) Polarized Potential ("instant off') 2) Potential with CP Applied, IR Drop Considered
Note: All readings taken must meet the -850 mV criteria to pass
Other Accepted Method (please describe):
Is the cathodic protection system working properly? Yes No (circle one)
My signature below affirms that I have sufficient education and experience to be a cathodic protection
tester; I am competent to perform the tests indicated above; and that the results on this form are a
complete and truthful record of all testing at this location on the date shown.
CP Tester Signature: Date:_
Keep This Paper On File For At Least Six Years
Appendix H
H-1
-------
Site Sketch: Provide a rough sketch of the tanks and piping, the location of each CP test, and
each voltage value obtained (use space below or attach separate drawing). Voltage readings
through concrete or asphalt do not provide accurate readings and are not acceptable. Perform
sufficient testing to evaluate everything that is cathodically protected.
If the cathodic protection system fails the test, a corrosion expert must evaluate the
cathodic protection system so it can be fixed. A corrosion expert has additional training,
skills, and certification beyond the corrosion tester who filled out the bulk of this form. A
corrosion expert must be: accredited/certified by NACE International, The Corrosion Society
as a corrosion specialist or cathodic protection specialist or be a registered professional
engineer with certification or licensing in corrosion control.
Be sure to keep a record for as long as you own the LIST that clearly documents what
actions were taken to fix your CP system.
Appendix H
H-2
-------
Appendix I: Sample Impressed Current 60 Day Inspection Form
Facility Name:_
Amperage Range Recommended:_
Voltage Range Recommended:
Date
Your Name
Voltage
Reading
Amperage
Reading
Is Your System Running
Properly? (Yes/No)
If the rectifier voltage and/or amperage output(s) are outside the recommended operating
levels, contact a corrosion expert to address the problem.
Never turn off your rectifier.
Keep This Record For At Least Six Months After
The Date Of The Last Reading
1-1
Appendix I
-------
Appendix J: Sample 30 Day Release Detection Monitoring Record
(could be used for monitoring wells, interstitial monitoring, and automatic tank gauging)
Release Detection Method:
Facility Name:
Date
Your
Name
UST (Tank & Piping)
(Enter N for no release detected or Y for a suspected
or confirmed release)
UST#
UST#
UST#
UST#
UST#
If your release detection system reports a suspected or confirmed release, take appropriate
actions. See section 4.9 for what to do for suspected or confirmed releases.
Keep This Piece Of Paper And Any Associated Printouts On File
For At Least One Year From The Date Of The Last Entry
J-1
Appendix J
-------
Appendix K: Sample Daily Inventory Worksheet
Facility Name:
Your Name:
Date:
Tank Identification |
Type Of Product
Tank Size In Gallons
End Stick Inches |
Amount Pumped 1
Totalizer Reading
Totalizer Reading
Totalizer Reading
Totalizer Reading
Totalizer Reading
Totalizer Reading
Totalizer Reading
Totalizer Reading
Today's Sum Of Totalizers
Previous Day's Sum Of Totalizers
Amount Pumped Today
Delivery Record 1
Inches Of Product Before
Delivery
Gallons Of Product Before
Delivery
(from tank chart)
Inches Of Product After
Delivery
Gallons Of Product After
Delivery
(from tank chart)
Gallons Delivered (Stick)
[Gallons After • -Gallons Before]
Gross Gallons
Delivered (Receipt)
•
•
•
•
•
•
•
•
•
•
K-1
Appendix K
-------
Sample Monthly Inventory Record
Month/Year:
Tank Identification And Type Of Product:_
Facility Name:
Date Of Water Check:
Level Of Water (Inches):.
Date
1
2
3
4
5
6
7
8
9
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
Start Stick Book
Inventory Gallons Gallons Inventory
(Gallons) Delivered Pumped (Gallons)
(+) (-) (=)
(+) (-) (=)
(+) (-) (=)
(+) (-) (=)
(+) (-) (=)
(+) (-) (=)
(+) (-) (=)
(+) (-) (=)
(+) (-) (=)
(+) (-) (=)
(+) (-) (=)
(+) (-) (=)
(+) (-) (=)
(+) (-) (=)
(+) (-) (=)
(+) (-) (=)
(+) (-) (=)
(+) (-) (=)
(+) (-) (=)
(+) (-) (=)
(+) (-) (=)
(+) (-) (=)
(+) (-) (=)
(+) (-) (=)
(+) (-) (=)
(+) (-) (=)
(+) (-) (=)
(+) (-) (=)
(+) (-) (=)
(+) (-) (=)
(+) (-) (=)
(+) (-) (=)
(+) (-) (=)
(+) (- (=)
End Stick Inventory
(Inches) ' (Gallons)
Total Gallons Pumped > Total Gallons Over Or Short >
Daily Over (+) Or
Short (• )
[End • -Book]
Initials
Drop the last two digits from the V 7 Total Gallons
Pumped number and enter on the \/ line below
Leak Check: +
Compare these
130
numbers
_ gallons
Is the Total Gallons Over Or Short larger than the Leak Check result? Yes No (circle one)
If your answer is yes for 2 months in a row, notify the regulatory agency as soon as possible.
Keep This Piece Of Paper On File For At Least One Year
Appendix K
K-2
-------
Appendix L: Sample Manual Tank Gauging Record
Circle your tank size, test duration, and weekly/monthly standards in the table below:
Tank Size
up to 550 gallons
551 -1,000 gallons
(when tank diameter is 64")
551-1,000 gallons
(when tank diameter is 48")
551-1 ,000 gallons (also requires
periodic tank tightness testing)
1 ,001 -2,000 gallons (also requires
periodic tank tightness testing)
Minimum
Duration
Of Test
36 hours
44 hours
58 hours
36 hours
36 hours
Weekly
Standard
(1 test)
10 gallons
9 gallons
12 gallons
13 gallons
26 gallons
Monthly Standard
(4-test average)
5 gallons
4 gallons
6 gallons
7 gallons
13 gallons
Month _
Tank Identification:
Person Completing Form:_
Facility Name:
Year
Compare your weekly readings and the monthly average of the 4 weekly
readings with the standards shown in the table on the left.
If the calculated change exceeds the weekly standard, the LIST may be
leaking. Also, the monthly average of the 4 weekly test results must be
compared to the monthly standard in the same way.
If either the weekly or monthly standards have been exceeded, the LIST
may be leaking. As soon as possible, call your implementing agency to
report the suspected leak and get further instructions.
Start Test
(month, day,
and time)
Date:
Time: AM/PM
Date:
Time: AM/PM
Date:
Time: AM/PM
Date:
Time: AM/PM
First
Initial
Stick
Reading
Second
Initial
Stick
Reading
Average
Initial
Reading
Initial
Gallons
(convert
inches to
gallons)
[a]
End Test
(month, day, and
time)
Date:
Time: AM/PM
Date:
Time: AM/PM
Date:
Time: AM/PM
Date:
Time: AM/PM
First
End
Stick
Reading
Keep This Piece Of Paper On File For At Least One Year
Second
End
Stick
Reading
1 To see how
1 standard, d
1 readings
Average
End
Reading
^^^^^^H
close you are tc
vide the sum of
by 4 and enter
End
Gallons
(convert
inches to
gallons)
[b]
^^^^™
) the monthly
the 4 weekly
result here >
Change
In Tank
Volume
In Gallons
+ or (-)
[a-b]
Tank
Passes Test
(circle
Yes or No)
Y N
Y N
Y N
Y N
Y N
Appendix L
L-1
-------
Appendix M: EPA Notification Form
A ^"^%Jl United States Form Approved.
^Sf^rrMA Environmental Protection Agency OMB No. 2050-0068
^^^i * m Washington, DC 20460
Notification for Underground Storage Tanks
State Agency Name and Address:
STATE USE ONLY
ID NUMBER:
DATE RECEIVED:
TYPE OF NOTIFICATION ^^^^^^^^^^^^^^^^^^^^^^^^^^H
DA. NEW FACILITY D B. AMENDED D C. CLOSURE
Number of tanks Number of continuation sheets attached
at facility
DATA ENTRY CLERK INITIALS:
OWNER WAS CONTACTED TO CLARIFY RESPONSES, COMMENTS:
INSTRUCTIONS AND GENERAL INFORMATION ^^^^^^^^^^^^^^^^^^^^^^^^^^^^|
Please type or print in ink. Also, be sure you have signatures in ink for
sections VIII and XI. Complete a notification form for each location
containing underground storage tanks. If more than 5 tanks are owned at
this location, you may photocopy pages 3 through 5 and use them for
additional tanks.
The primary purpose of this notification program is to locate and evaluate
underground storage tank systems (USTs) that store or have stored
petroleum or hazardous substances. The information you provide will be
based on reasonably available records, or in the absence of such records,
your knowledge or recollection.
Federal law requires UST owners to use this notification form for all
USTs storing regulated substances that are brought into use after May
8, 1986, or USTs in the ground as of May 8, 1986 that have stored
regulated substances at anytime since January 1, 1974. The
information requested is required by Section 9002 of the Resource
Conservation and Recovery Act (RCRA), as amended.
Who Must Notify? Section 9002 of RCRA, as amended, requires owners of
USTs that store regulated substances (unless exempted) to notify
designated State or local agencies of the existence of their USTs. "Owner" is
defined as:
• In the case of an UST in use on Novembers, 1984, or brought into use
after that date, any person who owns an UST used for storage, use, or
dispensing of regulated substances; or
• In the case of an UST in use before November 8, 1 984, but no longer in
use on that date, any person who owned the UST immediately before its
discontinuation.
Also, if the State so requires, any facility that has made any changes to
facility information or UST system status, must submit a notification form
(only amended information needs to be included).
What USTs Are Included? An UST system is defined as any one or
combination of tanks that (1 ) is used to contain an accumulation of regulated
substances, and (2) whose volume (including connected underground
piping) is 10% or more beneath the ground. Regulated USTs store
petroleum or hazardous substances (see the following "What Substances
Are Covered").
What Tanks Are Excluded From Notification?
•• Tanks removed from the ground before May 8, 1986;
• Farm or residential tanks of 1 ,1 00 gallons or less capacity storing motor fuel
for noncommercial purposes;
• Tanks storing heating oil for use on the premises where stored;
• Septic tanks;
• Pipeline facilities (including gathering lines) regulated under the Natural Gas
Pipeline Safety Act of 1 968, or the Hazardous Liquid Pipeline Safety Act of
1979, or which is an intrastate pipeline facility regulated under State laws;
• Surface impoundments, pits, ponds, or lagoons;
• Storm water or waste water collection systems;
• Flow-through process tanks;
• Liquid traps or associated gathering lines directly related to oil or gas
production and gathering operations;
• Tanks on or above the floor of underground areas, such as basements or
tunnels;
• Tanks with a capacity of 1 1 0 gallons or less.
What Substances Are Covered? The notification requirements apply to USTs
containing petroleum or certain hazardous substances. Petroleum includes
gasoline, used oil, diesel fuel, crude oil or any fraction thereof which is liquid at
standard conditions of temperature and pressure (60 degrees Fahrenheit and
1 4.7 pounds per square inch absolute). Hazardous substances are those found
in Section 101 (14) of the Comprehensive Environmental Response,
Compensation and Liability Act of 1 980 (CERCLA), with the exception of those
substances regulated as hazardous waste under Subtitle C of RCRA.
Where To Notify? Send completed forms to:
When To Notify? 1 . Owners of USTs in use or that have been taken out of
operation after January 1 , 1 974, but still in the ground, must notify by May 8,
1986. 2. Owners who bring USTs into use after May 8, 1986, must notify within
30 days of bringing the UST into use. 3. If the State requires notification of any
amendments to facility, send information to State agency immediately.
Penalties: Any owner who knowingly fails to notify or submits false information
shall be subject to a civil penalty not to exceed $1 1 ,000 for each tank for which
notification is not given or for which false information is given.
I. OWNERSHIP OF USTte) II. LOCATION OF USTte)
Owner Name (Corporation, Individual, Public Agency, or Other Entity)
Street Address
County
City State Zip Code
Phone Number (Include Area Code)
If required by State, give the geographic location of USTs by degrees, minutes, and
seconds. Example: Latitude 42° 36' 12" N, Longitude 85° 24' 17" W
Latitude Lonqitude
Facility Name or Company Site Identifier, as applicable
n If address is the same as in Section I, check the box and proceed to section III.
If address is different, enter address below:
Street Address
County
City State Zip Code
EPA Form 7530-1 (Rev. 9-98) Electronic and paper versions acceptable.
Previous editions may be used while supplies last.
M-1
Page 1 of 5
Appendix M
-------
&EPA
United States
Environmental Protection Agency
Washington, DC 20460
Form Approved.
OMB No.2050-0068
Notification for Underground Storage Tanks
III. TYPE OF OWNER
Federal Government
State Government I—I Commercial
Local Government I—I Private
^
Gas Station
Petroleum Distributor
Air Taxi (Airline)
Aircraft Owner
Auto Dealership
IV. INDIAN COUNTRY
USTs are located on land within an Indian .
Reservation or on trust lands outside |
reservation boundaries.
USTs are owned by a Native American I
nation or tribe.
V. TYPE OF FACILITY
Railroad
Federal - Non-Military
Federal - Military
Industrial
Contractor
Tribe or Nation where USTs are located:
Trucking/Transport
Utilities
Residential
Farm
Other (Explain)
VI. CONTACT PERSON IN CHARGE OF TANKS
Name:
Job Title:
Address:
VII. FINANCIAL RESPONSIBILITY
Phone Number (Include Area Code):
I—11 have met the financial responsibility requirements (in accordance with 40 CFR Subpart H) by using the following mechanisms:
Check All that Apply
Self Insurance
Commercial Insurance
Risk Retention Group
Local Government Financial Test
Guarantee
Surety Bond
Letter of Credit
Bond Rating Test
State Funds
Trust Fund
Other Method (describe here)
VIM. CERTIFICATION (Read and sign after completing ALL SECTIONS of this notification form)
I certify under penalty of law that I have personally examined and am familiar with the information submitted in Sections I through XI of this notification form and
all attached documents, and that based on my inquiry of those individuals immediately responsible for obtaining the information, I believe that the submitted
information is true, accurate, and complete.
Name and official title of owner or owner's
authorized representative (Print)
Signature
Date Signed
Paperwork Reduction Act Notice
EPA estimates public reporting burden for this form to average 30 minutes per response including time for reviewing instructions, gathering and maintaining the data needed and completing
and reviewing the form. Send comments regarding this burden estimate to Director, OP, Regulatory Information Division (2137), U.S. Environmental Protection Agency, 401 M Street,
Washington D.C. 20460, marked "Attention Desk Officer for EPA." This form amends the previous notification form as printed in 40 CFR Part 280, Appendix I. Previous editions of this
notification form may be used while supplies last.
EPA Form 7530-1 (Rev. 9-98) Electronic and paper versions acceptable.
Previous editions may be used while supplies last.
Page 2 of 5
M-2
Appendix M
-------
f^ ^^P^ Jft United States Form Approved.
ti*fctHr\ Environmental Protection Agency OMB NO 2050-0068
Washington, DC 20460
Notification for Underground Storage Tanks
IX. DESCRIPTION OF UNDERGROUND STORAGE TANKS (Complete for all tanks and piping at this location.)
Tank Identification Number
1. Status of Tank (check only one) Currently In Use
Temporarily Closed
Permanently Closed
2. Date of Installation (month/year)
3. Estimated Total Capacity (gallons)
4. Material of Construction (check all that apply)
Asphalt Coated or Bare Steel
Cathodically Protected Steel
Coated and Cathodically Protected Steel
Composite (Steel Clad with Fiberglass)
Fiberglass Reinforced Plastic
Lined Interior
Excavation Liner
Double Walled
Polyethylene Tank Jacket
Concrete
Unknown
If Other, please specify here
Check box if tank has ever been repaired
5. Piping Material (check all that apply) Bare Steel
Galvanized Steel
Fiberglass Reinforced Plastic
Copper
Cathodically Protected
Double Walled
Secondary Containment
Unknown
Other, please specify
6. Piping Type "Safe" Suction (no valve at tank)
(Check all that apply) "U.S." Suction (valve at tank)
Pressure
Gravity Feed
Check box if piping has ever been repaired
Tank No
H
|
n
|
I
Tank No
H
|
n
|
I
Tank No
H
|
n
|
I
Tank No
H
|
n
|
I
Tank No
H
|
n
|
I
EPA Form 7530-1 (Rev. 9-98) Electronic and paper versions acceptable.
Previous editions may be used while supplies last.
Page 3 of 5
M-3
Appendix M
-------
4% ^F>Jj United States
^SHt tHr\ Environmental Protection Agency
^^ Washington, DC 20460
Form Approved.
OMB No. 2050-0068
Notification for Underground Storage Tanks
Tank Identification Number
7. Substance Currently Stored (or last Gasoline
stored in the case of closed tanks) Diesel
( Check all that apply) Gasohol
Kerosene
Heating Oil
Used Oil
If Other, please specify here
Hazardous Substance
CERCLA name and/or
CAS number
Mixture of Substances
Please specify here
8. Release Detection (check all that apply)
Manual tank gauging
Tank tightness testing
Inventory Control
Automatic tank gauging
Vapor monitoring
Groundwater monitoring
Interstitial monitoring
Automatic line leak detectors
Line tightness testing
No release detection required (such as some types of
suction piping, emergency generator tanks or field
constructed tanks)
Other method allowed by implementing agency
(such as SIR)
Please specify other method here
9. Spill and Overfill Protection
Overfill device installed
Spill device installed
Tank No
Q
[]
[]
n
n
n
n
n
TANK
D
D
n
n
n
n
n
D
n
PIPE
D
D
D
D
D
n
D
n
n
Tank No
Q
[]
[]
n
n
n
n
n
TANK
D
D
n
n
n
n
n
D
n
PIPE
D
D
D
D
D
n
D
n
n
Tank No
Q
[]
[]
n
n
n
n
n
TANK
D
D
n
n
n
n
n
D
n
PIPE
D
D
D
D
D
n
D
n
n
Tank No
I
a
a
TANK
D
D
n
n
n
n
n
D
n
PIPE
°
Tank No
Q
[]
[]
n
n
n
n
n
TANK
D
D
n
n
n
n
n
D
n
PIPE
D
D
D
D
D
n
D
n
n
EPA Form 7530-1 (Rev. 9-98) Electronic and paper versions acceptable.
Previous editions may be used while supplies last.
Page 4 of 5
M-4
Appendix M
-------
^% ^™P^ J^ United States Form Approved.
-------
Reminder Of Required Ongoing Activities For USTs
Keep the appropriate records of these activities
Release Detection Activities (may vary depending on the types of release detection you use)
Release Detection
(See Sections 4.7 and 4.8)
Automatic Tank Gauging,
Groundwater Monitoring,
Vapor Monitoring, And
Interstitial Monitoring
Inventory Control
Statistical Inventory
Reconciliation (SIR)
Manual Tank Gauging
Line Leak Detector
Line Tightness Test
For All Release Detection
Activity
Release Detection Monitoring
Inventory Measurements
Reconcile Daily Inventory Control Measurements
Check Tank For Water
Tank Tightness Test
Inventory Measurements
Release Detection Monitoring
Testing
Reconcile Weekly Manual Tank Gauging Tests
Tank Tightness Test (if required)
Test To Demonstrate Proper Function Of Line Leak
Detector
Line Tightness Test -for pressurized piping
Line Tightness Test -for suction piping
Periodic Calibration And Maintenance Of Release
Detection Equipment
Minimum
Frequency
Every 30 days
Daily
Every 30 days
Every 30 days
Every 5 years
Daily
Every 30 days
Weekly
Every 4 weeks
Every 5 years
Every 12 months
Every 12 months
Every 3 years
Per manufacturer's
instructions
Cathodic Protection Activities (may vary depending on the type of cathodic protection you use)
Cathodic Protection
(See Section 4.6)
Impressed Current
For Both Impressed
Current And Galvanic
(Sacrificial) Anodes
Activity
Rectifier Inspection
- keep records of the last 3 inspections
Cathodic Protection Test
- performed by a qualified cathodic protection tester
- keep records of the last 2 tests
Minimum
Frequency
Every 60 days
Within 6 months of
installation
Every 3 years
Within 6 months of
any repairs
Internal Lining Activities
Internal Lining
(See Section 4.4.4)
Internally Lined Steel
Tank
Activity
Internally Lined Tank Inspection - not required if combined
with cathodic protection and tank passed an integrity
assessment before adding cathodic protection
- recommend keeping a record of the inspection
Minimum
Frequency
Within 10 years of
installation
Every 5 years
thereafter
-------
Questions About Completing The Workbook?
If you want more information or need help completing this workbook you
can:
• Look in appendix E for definitions of technical words.
• Contact your LIST contractor, vendor of your equipment, environmental
compliance consultants, or the manufacturer of your LIST equipment. Look
through your records for information on how to contact them.
• Contact {State Agency}. They may be able to help you identify equipment or
sources of information about your LIST equipment.
{State}
{Address}
{Phone}
{E-mail}
Read information from other resources such as state or EPA publications or
Internet sites. You may also want to use industry Internet sites. See appendix
F for these additional resources.
United States Solid Waste And EPA 510-R-04-003
Environmental Protection Emergency Response June 2004
Agency 5401G www.epa.gov/oust/
------- |