THE WYOMING Storage Tank Program

THE WYOMING Storage Tank Program BEFORE THE PROGRAM  Tanks were installed without corrosion protection  Filling was done without concern about overfilling  Lines often leaked without being detected because inventory was not carefully checked RESULTING IN:  Inventory losses due to leakage  Explosions caused by vapors  Contaminated water supplies  Vapors in basements, storm sewers and utilities  Cancer and other serious health problems  Financial Ruin for those responsible for Tanks FOR MORE INFORMATION... The Wyoming Water Quality Division, Storage Tank Program, 122 West 25th Street, Cheyenne, WY 82002 (307) 777-7095 and (307) 777-5973 (FAX) and blucht@missc.state.wy.us You will find references to Wyoming State regulations and statutes in this space >> Each of those references has a link to the actual text of those rules and statutes. On the next screen you will find the “Requirements for Underground Storage Tanks”. Each of those requirements has a link to allow you to start viewing at any of them. This presentation is designed to be viewed without sound. Requirements for Underground Storage Tanks REQUIRED BY ARTICLE 14, ENVIRONMENTAL QUALITY ACT AND CHAPTER 17            Annual Registration Annual Fee Leak Detection for all Tanks Leak Detection for all Connected Lines Minimum Site Assessment Financial Responsibility Corrosion Protection Spill Prevention Equipment Overfill Prevention Equipment Permanent Abandonment of Out of Service Tanks Reporting and Investigation of Suspected Releases Annual Registration REQUIRED BY W.S. 35-11-1425 and CHAPTER 17, SECTION 7 (B) Name and Address of Owner/Operator Location, size, & types of Tanks Type of Substance Stored FOR MORE INFO... The Wyoming Water Quality Division, AUST Program, 122 West 25th Street, Cheyenne, WY 82002 (307) 777-7095 (307) 777-5973 (FAX) and blucht@missc.state.wy.us Tank Fees REQUIRED BY W.S. 35-11-1425  Underground tanks: • Owners pay $200.00 per tank per year  Out of Service Tanks: • Owners pay until removed  Aboveground tanks under 5000 gallons: • Owners pay $50.00 per tank per year  Aboveground tanks over 5000 gallons: • Owners pay $200.00 per tank per year Leak Detection  At least one method of leak detection is required for the Underground Storage Tank itself. – And…  At least one method of leak detection is required for any underground lines attached to the tank. deq: Need a Hotlink on each of these Leak Detection Methods - Tanks REQUIRED BY CHAPTER 17 SECTION 14(a)  Manual Tank Gauging  Inventory Control  Tank Tightness Testing  Automatic Tank Gauging  Statistical Inventory Reconciliation  Interstitial Monitoring  Vapor Monitoring Wells  Groundwater Monitoring Wells MANUAL TANK GAUGING REQUIREMENTS FOR THIS METHOD ARE IN CHAPTER 17 SECTION 16(b)  Manual Tank Gauging or Manual Inventory Control alone for tanks under 1000 gallons  Manual Inventory Control & Tank Tightness Testing for tanks of 1000 to 2000 gallons  Tank Tightness Testing • Overfill • Underfill • Tracer MANUAL TANK GAUGING REQUIREMENTS FOR THIS METHOD ARE IN CHAPTER 17 SECTION 16 (b)  Requires Shut-in of Tank for a minimum of 36 hours and up to 58 hours depending on size of the tank  Stick Readings taken twice at the beginning of the shut-in period and twice at the end of the shut-in period  Stick Readings must be accurate to 1/8”  Must be done once a week  Usually done on small waste oil tanks INVENTORY CONTROL REQUIREMENTS FOR THIS METHOD ARE IN CHAPTER 17 SECTION 16 (a)  At least seven stick readings per month and one stick reading for every day of active use  Deliveries preceded by two stick readings and ended with two stick readings  Reconciled both daily and monthly  Inventory must balance within 1% of inventory flow through plus 130 gallons  Stick readings must be accurate to 1/8” INVENTORY CONTROL  If you are using inventory control in conjunction with an automatic tank gauge, use the automatic tank gauge instead of sticking the tank manually.  If you have a point of sale cash register, use the sales numbers from that system, converted to gallons.  You must close both your sales numbers and your delivery numbers at the same time each day. TANK TIGHTNESS TESTING  Provided by an outside company  Types: • • • • Underfill Overfill Ullage Tracer Tight Surveys Underfill Tank Tightness Tests The tank is first filled to near its capacity... In the Under fill method, a probe of some type is inserted into the tank to accurately measure product level during a shut-in period. Overfill Tank Tightness Tests The tank is first filled to the top... In the Over fill method, a tube is connected to the tank to accurately measure product level during a shut-in period. Ullage Tank Tightness Tests The ullage is the space in the tank above the product level... In the Ullage method, the tank is pressurized with nitrogen with all the vents and product lines blocked. A microphone inside the tank is used to listen for noise caused by leaks. Tracer Tight Tank Surveys In the Tracer Tight method the product in the tank is first “inoculated” with a very volatile organic tracer, which is not normally present in fuel. About a week later, the tester returns to try and find the tracer in the soils around tank tanks and/or lines. Automatic Tank Gauges REQUIREMENTS FOR THIS METHOD ARE IN CHAPTER 17 SECTION 16 (d)  Measure only the volume of product in the tank. Cannot determine if lines are intact and cannot detect holes above the product surface  Two Types: • Earlier Types shut-in the tank once a day • Continuous Statistical Leak Detection  Must detect a 0.2 gallons per hour leak  Three Types of Detectors: Automatic Tank Gauges REQUIREMENTS FOR THIS METHOD ARE IN CHAPTER 17 SECTION 16 (d) Sensor Detects Torque in Tape to Float Magnetic Float on Rigid Tape Product Level Magnets Automatic Tank Gauges REQUIREMENTS FOR THIS METHOD ARE IN CHAPTER 17 SECTION 16 (d) Sensor Measures Buoyancy Force Glass Float Shaped to Account for the Round Tank Product Level Automatic Tank Gauges REQUIREMENTS FOR THIS METHOD ARE IN CHAPTER 17 SECTION 16 (d) Sensor Receives Ultrasonic Wave and Determines Product Level Product Level Ultrasonic Transmitter Automatic Tank Gauges REQUIREMENTS FOR THIS METHOD ARE IN CHAPTER 17 SECTION 16 (d)  You must have one passing result for each month...  You must keep those records for three years.  The passing result should be the highest passing result for the month.  If you cannot obtain one passing result in a month, you must declare as suspected release.  You must also do Inventory Control or another equivalent method along with an ATG. Statistical Inventory Reconciliation REQUIREMENTS FOR THIS METHOD ARE IN CHAPTER 17 SECTION 16 (h) This method requires that all of the measurements made for Manual Inventory Control be taken on a daily basis…... And… the results are sent out to a Consulting firm for statistical analysis by a qualified professional who uses a third party verified method. Statistical Inventory Reconciliation REQUIREMENTS FOR THIS METHOD ARE IN CHAPTER 17 SECTION 16 (h) If the SIR Company cannot produce a conclusive pass or fail, they report an inconclusive result... If you receive an inconclusive result, you must audit your records and resubmit your records to the SIR Company to attempt to achieve a conclusive result. If you receive an inconclusive result, and that cannot be reconciled, you don’t have a valid leak detection method for that month Interstitial Monitoring REQUIREMENTS FOR THIS METHOD ARE IN CHAPTER 17 SECTION 16 (g) Monitoring of the space between the two shells of a double wall tank for both products and water Interstitial Monitoring REQUIREMENTS FOR THIS METHOD ARE IN CHAPTER 17 SECTION 16 (g) If your interstitial monitoring device indicates that product has escaped from your tank, you must declare a suspected release. If your interstitial space is disabled because it is full of rainwater or a cable is broken, you do not have a valid leak detection method for that month. Vapor Monitoring Wells REQUIREMENTS FOR THIS METHOD ARE IN CHAPTER 17 SECTION 16 (e) Monitoring Wells Wells must be monitored for vapors at least monthly Tank Basin Tank Water Table Vapor Monitoring Wells  Cannot be used on any site which is already contaminated in such a way as to prevent detection of any new release.  Unfortunately, vapor monitoring wells tend to be a one shot deal. Once they detect a leak, it may not be possible to clean them up sufficiently that they can be used to detect a second leak later. Groundwater Monitoring Wells REQUIREMENTS FOR THIS METHOD ARE IN CHAPTER 17 SECTION 16 (f) Monitoring Wells Wells must be monitored at least monthly for free product Tank Basin Tank Water Table Leak Detection Methods Lines REQUIRED BY CHAPTER 17 SECTION 14 (b)  Pressurized Lines • Pressure Check of the Lines - Annually • Automatic Line Leak Detector (ALLD) • Annual Check of the ALLD  Suction Lines  Exposed Lines FOR MORE INFORMATION... The Wyoming Water Quality Division, AUST Program, 122 West 25th Street, Cheyenne, WY 82002 (307) 777-7095 (307) 777-5973 (FAX) and blucht@missc.state.wy.us PRESSURIZED LINES REQUIRED BY CHAPTER 17 SECTION 14 (b) and SECTION 17 All systems which use pressurized lines must have an automatic line leak detector (ALLD) ALLD Tank SOLENOID VALVE ALLD’s only detect leaks between the solenoid valve in the dispenser and the ALLD itself All ALLD’s must detect any leak of 3 gallons per hour at 10 psi within one hour SUCTION LINES SEE CHAPTER 17 SECTION 14 (b)(ii) All systems which use suction pumps AND have no pressure on the lines. These systems cannot have to have an (ALLD) CHECK VALVE Tank Systems which have only one check valve are exempt from release detection requirements (Exempt Suction) Systems which have a second check valve are not exempt (US Suction) Minimum Site Assessment REQUIREMENTS FOR MSA’S ARE IN CHAPTER 17 SECTION 27  Number of Drill holes or Test Pits depends on size and number of tanks Tank Basin Drill hole or test pit  May be met during removal or replacement of a tank  Tanks installed before Sept 22, 1988 AND in use after September 22, 1988 were required to have an MSA by December 22, 1998 Financial Assurance REQUIRED BY W.S. 35-11-1428  $1,000,000 liability per release • (Federal Requirement) • $30,000 deductible  Compliance with the AUST Program makes a site eligible for the: • Wyoming Corrective Action Account • Wyoming Financial Responsibility Account CORRECTIVE ACTION ACCOUNT SET UP BY W.S. 35-11-1425 Pays 100% of the cleanup cost of a release from a regulated tank system The DEQ contracts directly for cleanup No deductible Major funding from a set aside equal to 1 cent per gallon of fuel taxes Wyoming is the only State with this type of coverage. Financial Responsibility Account SET UP BY W.S. 35-11-1427  Pays only after a judgement is rendered against the owner or operator of the site  Pays the first $1,000,000 of any judgement  $30,000 deductible  Meets the Federal Financial Assurance Requirement 1998 UPGRADES REQUIRED BY CHAPTER 17, SECTION 5 AND SECTION 6  Overfill Protection  Spill Prevention  Corrosion Prevention Overfill Prevention Equipment Three Types of Overfill Prevention: SEE CHAPTER 17 SECTION 5 (C)(I)(B) Butterfly Valve in Fill Tube Check Valve in Vent Lines Automatic Alarm System Spill Prevention Equipment SEE CHAPTER 17 SEC 5(C)(I)(A) SPILL BUCKET A spill bucket is designed to catch spills during the filling of the tank FILL TUBE Tank Corrosion Prevention SEE CHAPTER 17 SEC 5(A) Non Corrodable Tanks and Lines Steel Tanks and Lines • • • • Sacrificial anode cathodic protection Impressed Current cathodic protection Fiberglass Clading Lining Corrosion Prevention Non Corrodable Tanks SEE CHAPTER 17 SEC 5 (A)(I) NON-CORRODABLE STEEL THEY ARE MADE OFTANKS ARE MADE BEEN WHICH HASENTIRELY OF FIBERGLASS CLAD WITH A COMPLETELYREINFORCED PLASTIC SECOND TANK MADE OF OR... FIBERGLASS REINFORCED PLASTIC (COMPOSIT STEEL/FIBERGLASS TANK) Corrosion Prevention Composite Steel/Fiberglass Tanks STEEL TANK SHELL FIBERGLASS SHELL Composite Tanks may or may not have an interstitial space between the steel and the fiberglass shells The fiberglass shell is more than a coating, it is a complete tank in and of itself. Corrosion Prevention Cathodic Protection of Steel Tanks SACRIFICIAL ANODE OR IMPRESSED CURRENT SYSTEMS CATHODIC PROTECTION SACRIFICIAL ANODES MUST SYSTEMS MUST BE EXPERTS AND TESTERS MUST BE CHECKED BY A CATHODIC DESIGNED BY A MEET THE QUALIFICATIONS PROTECTION TESTER ONCE CATHODIC PROTECTION FOUND SIX MONTHS OF WITHININ CHAPTER 17, EXPERT WATER QUALITY RULES AND INSTALLATION AND AGAIN REGULATIONS ONCE EVERY THREE YEARS THEREAFTER Corrosion Prevention Cathodic Protection of Steel Tanks SACRIFICIAL ANODE SYSTEM SEE CHAPTER 17 SECTION 9 POTENTENTIAL DIFFERENCES MUST BE: STI-P3 TANKS HAVE DIELECTRIC FITTING -.85 VOLTS LINES -.85 VOLTS TANK OR 200 MILLIVOLTS ABOVE BACKGROUND SACRIFICIAL ANODES Corrosion Prevention Cathodic Protection of Steel Tanks IMPRESSED CURRENT SYSTEM SEE CHAPTER 17 SECTION 9 POTENTIAL BETWEEN THE TANK, LINES AND ANODES MUST BE: RECTIFIER LINES TANK -.85 VOLTS OR 200 MILLIVOLTS ABOVE BACKGROUND POTENTIAL NON-SACRIFICIAL ANODES CRITERIA REQUIRED FOR CP CHECKS SEE CHAPTER 17, SECTION 9(b), Wyoming Water Quality Rules and Regulations  Must be in accordance with the National Association of Corrosion Engineers Standard RP-02-85, “Control of External Corrosion on Metallic Buried, Partially Buried or Submerged Liquid Storage Systems”. CP EXPERT vs. CP TESTER SEE CHAPTER 17, SECTION 4(K) AND 4(O) Wyoming Water Quality Rules  CORROSION EXPERT  CATHODIC PROTECTION • Certified by the National Association of Corrosion Engineers • or • A Registered Professional Engineer with education and experience in corrosion control TESTER • a person who can demonstrate understanding of the principles and measurements • education and experience in soil resistivity, stray current, structure to soil potential, and isolation measurements IDEAL REPORT OF A CP CHECK rectifier TANK 1: 6000 GALLON SUPER TANK 2: 10000 GALLON UNLEADED TANK 3: 6000 GALLON PLUS TANK 4: 6000 GALLON UNLEADED 1 5 2 8 11 12 14 15 3 6 9 7 10 13 16 5 4 Island Island Facility ID 0-002357 IDEAL REPORT OF CP CHECK POINT ID 1 2 3 4 ETC. Facility ID 0-002357 DESCRIPTION ANODE 4 ANODE 5 TANK 3 LINE 4 ON OFF -.540 -1.063 -.536 -1.034 -.554 -1.067 -.560 -1.098 IDEAL REPORT OF A CP CHECK  Current Required  Minimum Anodes  Rectifier Voltage  Groundbed Resistance  Name of NACE Certified Corrosion Specialist  Rectifier Data Facility ID 0-002357 Corrosion Prevention Interior Lining of Steel Tanks INTERIOR LINING STEEL TANK SHELL OUT OF SERVICE TANKS  All tanks must be removed or permanently abandoned within one year after they are taken out of service. • This is to prevent tanks from becoming a problem years after they are abandoned. • Old tanks, abandoned with fuel in them have caused many of the problems that we have found to date.  Permanently abandoning a tank requires emptying the tank and filling it with an inert material TWO METHODS OF PERMANENTLY ABANDONING A TANK Remove the tank from the ground • Tanks must be decommissioned if removed • Decommissioning facilities must be permitted • DEQ inspects all removals to determine if the site is contaminated with products Clean out the tank and fill with an inert material REPORTING OF SUSPECTED RELEASES  Operator must report a suspected release orally with 24 hours, whenever: • there are unusual operating conditions such as erratic behavior o dispensing equipment, water in the tank, or sudden loss of product from the tank. • there is a discovery of products in the surrounding area, such as vapors in basements, storm drains or utility lines. • any monitoring result indicates a loss of product RELEASE INVESTIGATION AND CONFIRMATION SEE CHAPTER 17, SECTIONS 21, 16(C) AND 17(B) TESTS WHEN THERE IS A SUSPECTED RELEASE, OWNERS MUST TEST BOTH…. AND THE LINES THE TANKS OWNERS MUST: REPAIR REPLACE UPGRADE, OR PERMANENTLY CLOSE ANY TANK FOR WHICH A RELEASE IS CONFIRMED