Oil Prophets

Winter 2016

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21 Oil Prophets owners must check sump areas for damage, release or leaks. Compliance Date: October 13, 2018 and monthly thereafter. • Spill Prevention Equipment Tests - The final rule requires spill prevention equipment testing once every three years. The final rule does not require periodic testing of double walled spill containment equipment if the integrity of both walls is periodically monitored. Compliance Date: October 13, 2018 and once every three years thereafter. • Overfill Prevention Equipment Inspections – The final rule requires to testing and inspect operation of overfill protection equipment once every three years. Tank owners must inspect automatic shut-off devices, flow restrictors and alarms. The test requires a demonstration that the equipment will operate or activate properly. Compliance Date: October 13, 2018 and once every three years thereafter. • Secondary Containment Testing – The final requires the testing once every three years of all sumps that are used for secondary containment and interstitial monitoring of double walled pipes and/or other equipment including under dispenser containment. The test must show that the sump is water or vacuum pressure tight. Double walled sumps used for interstitial monitoring of piping are not required to be tested if both walls of the containment sump are periodically monitored. Compliance Date: October 13, 2018 and once every year thereafter. • Release Detection Equipment Tests – The final rule requires annual operational and maintenance tests on electronic and mechanical components of release detection equipment to ensure proper operation. Owners must: check ATG systems and other controllers, test alarm, verify system configuration, test battery back-up, inspect probes and sensors, automatic line leak detectors, vacuum pumps and pressure gages, as well as hand held electronic sampling equipment. Compliance Date: October 13, 2018 and once every year thereafter. • E-15 Compatibility Requirements – The final rule incorporates as regulatory requirements previously adopted EPA guidelines that require tank owners to demonstrate UST system compatibility with ethanol gasoline blends greater than E-10 or diesel fuel blends greater than B-20 by; certification and listing of equipment by a nationally recognized testing laboratory; equipment manufacturer approval; or an alternative method developed by a state UST authority. Tank owners who plan to place fuel blends greater than E-10 or B-20 in a UST system must first provide 30-day prior notice to state UST program authorities. This is purely a "housekeeping" measure by the EPA and does not change existing E-15 compatibility requirements which PMAA believes are inadequate to protect tank owners from liability in the event of a release. • Statistical Inventory Reconciliation – the final rule adds statistical inventory reconciliation (SIR) as an approved method of leak detection. The final rule also provides performance standards that SIR methods must meet. Compliance Date: October 13, 2015. • Vent Line Flow Restrictors – the final rule requires ball float valves to be tested periodically for operability. The final rule prohibits the installation of new ball float valves as the primary method of overfill protection. The rule does not require ball float valves to be removed. Instead, existing ball float valves may continue in service until they are replaced with a different method of overfill protection. However, new ball float valves may be installed if not used as the primary method of overfill protection but used as a back-up to a primary method instead. Compliance Date: October 13, 2015. • Internal Tank Linings – The final rule requires tank owners to permanently close USTs that use internal tank liners as the sole method of corrosion protection when an inspection determines the lining is no longer performing to original design specifications and cannot be repaired. Lining must be inspected within ten years after lining and every five years thereafter. Compliance Date: October 13, 2015. • Change of Ownership Notification – The final rule requires tank owners to provide notice to state regulatory authorities anytime ownership of a tank system is changed. The final rule provides a new notification form entitled: Notification of Ownership Change for Underground Storage Tanks. Compliance Date: October 13, 2015. Implementation of the new UST rule is now left up to the states who REGULATORY CORNER Requirements Finalized

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