HomeMy WebLinkAboutAppendix 3 NYSDEC Training Manual UST Ope
October 2015
Rev 1
Training Guide
For Class A and B UST Operators
Petroleum and Chemical
Bulk Storage Programs
Bureau of Technical Support
Division of Environmental Remediation
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Table of
Contents
Table of Contents
Introduction ............................................................................................... 1-1 1.0
1.1 Why Does New York Require UST Operator Testing? ........................... 1-1
1.2 Applicability ............................................................................................ 1-2
1.3 Training and Testing: Timing Requirements ......................................... 1-3
1.4 Operator Testing Requirements ............................................................ 1-3
1.5 Red Tags – Regulatory Consequences of Releases or Serious Deficiencies
............................................................................................................... 1-4
1.6 Summary ................................................................................................ 1-4
Operator Training Requirements and Deadlines ....................................... 2-1 2.0
2.1 Class A Operator .................................................................................... 2-1
2.2 Class B Operator .................................................................................... 2-2
2.3 Becoming an Authorized Operator ........................................................ 2-2
2.4 When Do I Need To Be Authorized? ...................................................... 2-4
2.5 Class C Operator ..................................................................................... 2-5
2.6 Documentation ...................................................................................... 2-6
2.7 Operator Database ................................................................................. 2-6
2.8 Retirement of Authorization .................................................................. 2-6
2.9 Summary ................................................................................................ 2-7
Tank System Basics .................................................................................... 3-1 3.0
3.1 Tank System Categories According To Installation Dates ...................... 3-4
3.2 Tank Construction .................................................................................. 3-4
3.3 Tank Configurations ............................................................................... 3-6
3.4 Documentation of Tank System Installation ....................................... 3-18
Petroleum Tank Registration ..................................................................... 4-1 4.0
4.1 Definition of Petroleum ......................................................................... 4-1
4.2 Regulated Facilities ................................................................................ 4-2
4.3 Facility Owner ........................................................................................ 4-3
4.4 Notification of Tank Installation at a New Facility ................................. 4-3
4.5 Registration of New Facilities................................................................. 4-3
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Table of
Contents
4.6 Registration Certificate .......................................................................... 4-4
4.7 Renewal .................................................................................................. 4-4
4.8 Transfer .................................................................................................. 4-4
4.9 Registration of Additional or Replacement Tanks ................................. 4-4
4.10 Information Correction .......................................................................... 4-5
4.11 Tank Closure ........................................................................................... 4-5
4.12 Summary: ............................................................................................... 4-5
Financial Responsibility .............................................................................. 5-1 5.0
5.1 Meeting the Financial Responsibility Requirement ............................... 5-1
5.2 Reporting and Recordkeeping ............................................................... 5-3
5.3 Summary ................................................................................................ 5-4
Out-of-Service Tanks and Permanent Closure .......................................... 6-1 6.0
6.1 Out-of-Service Tank Systems ................................................................. 6-1
6.2 Permanent Tank Closure ........................................................................ 6-2
6.3 Change in Service ................................................................................... 6-3
6.4 Tank Systems Improperly Taken Out-of-Service before 12/27/1986 .... 6-4
6.5 Closure Records ..................................................................................... 6-4
6.6 Registration Update ............................................................................... 6-4
6.7 Summary ................................................................................................ 6-4
Overfill Prevention ..................................................................................... 7-1 7.0
7.1 Mechanical Overfill Device .................................................................... 7-3
7.2 Electronic Overfill Alarms ....................................................................... 7-5
Inventory Monitoring ................................................................................. 8-1 8.0
8.1 Daily Inventory Monitoring – What To Do Each Day ............................. 8-2
8.2 What To Do At Least Every 10 Days ....................................................... 8-8
8.3 Leak Reporting ..................................................................................... 8-13
8.4 Recordkeeping ..................................................................................... 8-13
8.5 Summary .............................................................................................. 8-13
Tank Leak Detection ................................................................................... 9-1 9.0
9.1 Leak detection for Category 2 and 3 Tanks ............................................ 9-2
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Table of
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9.2 Leak Detection for Category 1 Tanks ..................................................... 9-4
9.3 Maintenance and Operation of Leak Detection Equipment ................ 9-11
9.4 Recordkeeping ..................................................................................... 9-11
9.5 Tank Tightness Testing ......................................................................... 9-12
9.7 Leak Reporting ..................................................................................... 9-13
9.8 Leak Investigation and Confirmation ................................................... 9-13
9.9 Summary .............................................................................................. 9-13
Piping Leak Detection .............................................................................. 10-1 10.0
10.1 Pressurized vs. Suction Piping Systems ................................................ 10-2
10.2 Leak Detection: Category 3 Tank Systems and New Piping ................. 10-3
10.3 Leak Detection: Piping Connected to Category 1 or 2 Tank Systems 10-10
10.4 Operation and Maintenance of Piping Leak Detection Equipment ... 10-11
10.5 Leak Reporting and Investigation ...................................................... 10-11
10.6 Recordkeeping ................................................................................... 10-12
10.7 Summary ............................................................................................ 10-13
Cathodic Protection (Corrosion Protection) ............................................ 11-1 11.0
11.1 Cathodic Protection Requirements ...................................................... 11-2
11.2 Galvanic Systems .................................................................................. 11-2
11.3 Impressed Current Systems ................................................................. 11-3
11.4 Inspection and Testing ......................................................................... 11-3
11.5 Repairs to Cathodic Protection Systems .............................................. 11-5
11.6 Recordkeeping ..................................................................................... 11-6
11.7 Summary .............................................................................................. 11-6
Dispensers ................................................................................................ 12-1 12.0
12.1 Dispensing Equipment ......................................................................... 12-3
12.2 Under-dispenser Containment ............................................................ 12-4
12.3 Valves ................................................................................................... 12-5
12.4 Accidents .............................................................................................. 12-9
12.5 Calibration ............................................................................................ 12-9
12.6 Summary .............................................................................................. 12-9
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Table of
Contents
Spill Prevention and fill ports .................................................................. 13-1 13.0
13.1 Maintenance ........................................................................................ 13-2
13.3 Common Issues .................................................................................... 13-3
13.4 Tank Tags .............................................................................................. 13-3
13.5 Fill Port Color Coding ........................................................................... 13-4
Spill Reporting and Response .................................................................. 14-1 14.0
14.1 Signs of a Spill or Release ..................................................................... 14-2
14.2 Investigating Possible Spills .................................................................. 14-2
14.3 Reporting Spills and Releases .............................................................. 14-4
14.4 Minor Spill Response Actions ............................................................... 14-6
14.5 Release Response, Investigation, and Corrective Action ..................... 14-7
14.6 Corrective Action Plan ........................................................................ 14-11
14.7 Public Participation ............................................................................ 14-11
14.8 Recordkeeping ................................................................................... 14-11
14.9 Summary ............................................................................................ 14-12
UST System Recordkeeping ..................................................................... 15-1 15.0
15.1 Record Storage ..................................................................................... 15-2
15.2 Record Accessibility ............................................................................. 15-3
15.3 Required Records ................................................................................. 15-3
15.4 Summary .............................................................................................. 15-5
Operation and Maintenance .................................................................... 16-1 16.0
16.1 Day to Day Operations - What Do I Need To Do? ................................ 16-1
16.2 Inspections ........................................................................................... 16-3
16.3 Maintenance and Repairs .................................................................... 16-4
16.4 Reminder of Required Ongoing Activities for USTs ............................. 16-4
16.5 Summary .............................................................................................. 16-7
Tank System Compatibility ...................................................................... 17-1 17.0
17.1 Definition of Compatibility ................................................................... 17-1
17.2 Why Does Compatibility Matter? ........................................................ 17-2
17.3 Types of Equipment Compatibility ....................................................... 17-3
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17.4 Steps to Confirm Compatibility ............................................................ 17-3
17.5 When Does Compatibility Matter? ...................................................... 17-4
17.6 Summary .............................................................................................. 17-4
Training of Class C Operators ................................................................... 18-1 18.0
18.1 Training ................................................................................................ 18-2
18.2 Recordkeeping: .................................................................................... 18-5
18.3 Summary: ............................................................................................. 18-6
Chemical Bulk Storage Requirements ...................................................... 19-1 19.0
19.1 Definition of Hazardous Substance ...................................................... 19-1
19.2 CBS Registration ................................................................................... 19-1
19.3 Sale of Hazardous Substances .............................................................. 19-2
19.4 Inspections and Monitoring ................................................................. 19-2
19.5 Spills and Releases ............................................................................... 19-2
19.6 Spill Response Plan and Annual Compliance Evaluations .................... 19-3
19.7 Other Requirements ............................................................................ 19-4
19.8 Summary .............................................................................................. 19-4
References And Web Links ...................................................................... 20-1 20.0
Tables
Table 9.1 Tank Categories ....................................................................................... 9-2
Table 9.2: Manual Tank Gauging............................................................................. 9-9
Table 10.1 Tank Categories ................................................................................... 10-3
Table 10.2 Piping Leak Detection Requirements ................................................ 10-13
Table 3 Fill Port Color Coding in Accordance with API 1637 ................................. 13-4
Table 15.1: Required Records ............................................................................... 15-4
Table 16.1: Daily Checklist .................................................................................... 16-5
Table 16.2 Required Ongoing Activities ................................................................ 16-6
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Table of
Contents
APPENDICES
Appendix A Sample Emergency Contact Placard
Appendix B Sample Ten day Inventory Reconciliation form
Appendix C Sample Manual Tank Gauging Worksheet
Appendix D Sample Monthly Automatic Tank Gauge Operability worksheet
Appendix E Sample 60-Day Impressed Current Rectifier Inspection Form
Appendix F Sample Maintenance Record Log
Appendix G Sample Training Log
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vii New York UST Operator Training Program | New York State Department of Environmental Conservation | October 2015
Note to
Readers
Note to Readers of This Guidance
This Guide contains information to assist individuals who desire to become
authorized Class A and/or Class B Operators at petroleum or chemical bulk storage
facilities in New York State (NYS) to prepare for the NYS Department of
Environmental Conservation’s (DEC) Class A and/or B Operator exam. This Guide
was prepared to assist owners and operators of Petroleum Bulk Storage (PBS) and
Chemical Bulk Storage (CBS) facilities that are simultaneously subject to New York
State [6 NYCRR Part 613 and/or 6 NYCRR 596-599] and to federal [40 CFR Part 280]
regulatory requirements. This guidance does not address requirements for
aboveground storage tanks and is not intended to address every tank system
scenario encountered at a facility. This document should not be relied upon or
cited as a DEC Program Policy.
Adherence to this guidance does not relieve any PBS or CBS facility owner or
operator from:
a) complying with requirements or provisions imposed by any applicable
federal, state or local statutes or regulations that may be determined to be
more stringent;
b) obtaining any and all registrations/licenses/permits required by federal,
state or local statute or regulation;
c) complying with an existing order, agreement, stipulation or permit.
No provisions of this guidance should be construed to alter the requirements of the
NYS Navigation Law, Environmental Conservation Law, or any regulation
promulgated pursuant thereto. It is the responsibility of the tank system owner
and operator to ensure that the facility is in compliance with all applicable (i.e.,
local, state and federal) regulatory requirements. Similarly, inspectors and auditors
are responsible for being aware of any changes to statutory or regulatory
requirements that affect compliance evaluation determinations.
Acknowledgements
Preparation of this Guide was supported under the Environmental Benefits Project
program with funding from BP and the City of New York. The Guide was designed
and written by Stantec Consulting Services Inc. with assistance from DEC. Inclusion
of references to or photos of products, services, or service providers in this Guide
does not constitute an endorsement by DEC, Stantec Consulting Services, Inc., BP,
or the City of New York.
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viii New York UST Operator Training Program | New York State Department of Environmental Conservation | October 2015
Acronyms
Acronyms
Acronym Term
AC Alternating Current
ALLD Automatic Line Leak Detector
AST Aboveground Storage Tank
ATG Automatic Tank Gauge
CBS Chemical Bulk Storage (see 6 NYCRR 596-599)
DC Direct Current
ELLD Electronic Line Leak Detector
EPA Environmental Protection Agency (United States)
FRP Fiberglass Reinforced Plastic
MLLD Mechanical Line Leak Detector
NFPA National Fire Protection Association
NWGLDE National Work Group on Leak Detection Evaluations
NYCRR New York Codes, Rules and Regulations
NYS New York State
DEC New York State Department of Environmental Conservation
PBS Petroleum Bulk Storage (see 6 NYCRR 613)
SIR Statistical Inventory Reconciliation
STP Submersible Turbine Pump
UDC Under-Dispenser Containment
UL Underwriters Laboratories
ULC Underwriters Laboratories of Canada
US United States
USEPA United States Environmental Protection Agency
UST Underground Storage Tank
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Glossary
Glossary
Note: Definitions for CBS facilities and tank systems may differ. Refer to
6 NYCRR Part 596.1(c).
Term Definition0F0F0F0F
Automatic
tank gauge
(ATG)
Probe inside a tank that measures product and water level and
can conduct in-tank testing. An ATG is usually part of an
electronic monitoring system.
Category 1
Tank System
Any tank system whose tank was installed before December 27,
1986. (PBS only)
Category 2
Tank System
Any tank system whose tank was installed from December 27,
1986 through October 11, 2015. (PBS only)
Category 3
Tank System
Any tank system whose tank was installed after October 11,
2015. (PBS only)
Cathodic
protection
Prevention of electrolytic corrosion of a metallic structure (tank
or piping) by causing it to act as the cathode rather than as the
anode of an electrochemical cell.
Class A
Operator
The individual who has primary responsibility to operate and
maintain the UST system(s) at a facility in accordance with
applicable requirements of the PBS and/or CBS regulations. The
Class A Operator typically manages resources and personnel to
achieve and maintain compliance with the requirements of
those regulations.
Class B
Operator
The individual who has day-to-day responsibility for
implementing applicable requirements of the PBS and/or CBS
regulations. The Class B Operator typically implements field
aspects of operation, maintenance, and associated
recordkeeping for the UST system.
Class A/B
Operator
An individual who has both A and B Operator responsibilities
Class C
Operator
The individual who has primary responsibility for initially
addressing emergencies presented by a spill or release from a
UST system. A PBS Class C Operator typically controls or
monitors the dispensing or sale of petroleum.
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Glossary
Term Definition0F0F0F0F
Design
capacity
The amount of petroleum or hazardous substance that a tank is
designed to hold. If a certain portion of a tank is unable to store
petroleum because of its integral design (for example, electrical
equipment or other interior components take up space), the
design capacity of the tank is thereby reduced. Actions taken to
physically alter the design capacity of a tank (such as drilling a
hole in the side of the tank so that it cannot hold petroleum
above that point) will not change the design capacity of the
tank.
Facility See Section 4.2 (PBS) and 6 NYCRR 596.1(c).
Facility
owner
Any person who has legal or equitable title to the real property
of a facility.
Interstitial
space
The space between the primary and secondary walls of a tank
or pipe.
Leak, spill, or
spillage
Any escape of petroleum from the ordinary container employed
in the normal course of storage, transfer, processing, or use.
Any escape of petroleum that enters containment (for example,
a catch basin) is a spill. (For CBS, see Section 19.5)
Operator Any person who leases, operates, controls, or supervises a
facility.
Petroleum Petroleum means:
crude oil and any fraction thereof;
synthetic forms of lubricating oils, dielectric oils,
insulating oils, hydraulic oils, and cutting oils;
any complex blend of hydrocarbons that is not derived
from crude oil; or
any petroleum mixture as defined in Part 613 section
1.3(at).
Petroleum does not include:
any hazardous substance covered under CBS
regulations, except certain blends (see Part 613 section
1.3(at)(2));
animal or vegetable oils; or
substances that are gases at standard temperature and
pressure.
Red tag Tag attached to a tank as notification that product deliveries to
the tank are prohibited by order of DEC
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Glossary
Term Definition0F0F0F0F
Tank The portion of a tank system that contains the majority of the
petroleum or hazardous substance in the tank system. Each
section of a compartmented tank will be treated as an
individual tank.
Tank system A stationary device designed to store petroleum that is
constructed of non-earthen materials that provide structural
support. This term includes all associated piping and ancillary
equipment. This term does not include a dispenser system;
septic tank system; surface impoundment, pit, pond or lagoon;
stormwater or wastewater collection system; flow-through
process tank system; or liquid trap or associated gathering lines
directly related to oil or gas production and gathering
operations. (CBS definition at 6 NYCRR 596.1(53)).
Underground
tank system
or UST
system
A tank system that has ten percent or more of its volume
beneath the surface of the ground or covered by materials. This
term does not include a tank system situated in an “accessible
underground area” such as a basement, cellar, shaft, or vault –
that allows for the physical inspection of the exterior of the
tank. (CBS definition at 6 NYCRR 596.1(58)).
Working
capacity
The portion of the design capacity of a tank that may be filled
before engaging the overfill prevention device, reduced by an
allowance for freeboard and petroleum expansion.
This Guide will help you
prepare to take the
New York State Class A
and/or Class B Operator
exam. Successfully
passing the exam will
authorize you to
operate underground
petroleum and chemical
storage tanks at
facilities registered in
New York State.
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1-1 New York UST Operator Training Program | New York State Department of Environmental Conservation | October 2015
CHAPTER
1
A/B
Introduction 1.0
This Guide will help you prepare to take the New York State Class A and/or Class B
Operator exam. Successfully passing the exam will authorize you to operate
underground storage tanks (USTs) at facilities registered in New York State (NYS).
Note: Because most NYS registered facilities store petroleum, this Guide is focused
on petroleum bulk storage (PBS) tank systems. While much of this information also
applies to chemical bulk storage (CBS) facilities, there are important differences,
particularly for registration, inspections, annual evaluations, spill response plans,
and tank system compatibility. In addition, each of the dozens of regulated
chemicals has unique safety and compatibility requirements. Therefore, in
addition to learning the basic information in this Guide, it is important that CBS
operators be trained on the procedures and requirements for the specific
chemicals stored at each facility at which they are authorized.
At a minimum, all Class A and B Operators must understand the general
requirements for CBS tank systems described in Chapter 19.
1.1 Why Does New York Require UST Operator Testing?
Leaks from USTs can seep into the soil and contaminate groundwater, the source
of drinking water for nearly a quarter of all New Yorkers. Spills, leaks, and overfills
can also flow into lakes, rivers, and streams where the oil or chemicals can harm
people and the environment, including wildlife, fish, and plant life.
For several decades, up into the mid-1980s, most USTs were single-walled, bare
steel tanks, often installed with unprotected metal piping. As these systems aged,
releases due to corrosion and overfills of these tank systems became widespread
and caused impacts so serious that both New York State and the federal
government passed laws to set operating requirements and tank construction
standards to protect human health and the environment. Thousands of tanks
were upgraded or replaced, usually with double-walled tanks made of fiberglass or
protected steel and equipped with methods for detecting unseen leaks and
preventing overfills.
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1-2 New York UST Operator Training Program | New York State Department of Environmental Conservation | October 2015
Tank IQ
UIDE
TANK GUIDE
Chapter 1: Introduction
Leaks from
underground
storage tanks
(USTs) can
seep into the
soil and
contaminate
groundwater,
the source of
drinking water
for nearly a
quarter of all
New Yorkers.
While the
number of
spills has
decreased,
thousands of
spills are still
reported each
year in New
York alone,
often due to
improper tank
system
management.
However, good equipment only prevents leaks and spills IF it is operated and maintained
properly. While the number of spills has decreased, thousands of spills are still reported each
year in New York alone, often due to improper tank system management. In 2008, a new state
law required that tank operators be trained to properly operate, maintain, and document their
systems. The law also gave New York State the authority to prohibit deliveries to tanks that are
in serious noncompliance with regulatory requirements.
The New York State Department of Environmental Conservation (DEC) has developed
regulations to implement the requirements for PBS and CBS UST operator training. No later
than October 11, 2016, facilities with underground petroleum or chemical storage tanks that are
subject to New York State and federal regulation must designate at least one Class A, one Class
B, and one Class C Operator for those tanks. If you wish to become a Class A and/or B Operator,
you must pass an exam administered by DEC. Alternatively, you may qualify for authorization by
obtaining credentials issued by any state program recognized by the U.S. Environmental
Protection Agency (EPA) as meeting operator training grant guidelines.
Along with the new regulations, DEC has developed this Guide to help you prepare for the New
York State exam, but you may use whatever training materials you choose.
DEC will not review third-party training materials, nor will it require third-party trainers to be
certified or otherwise approved. Passing the exam demonstrates that you have the basic
knowledge required for proper operation of USTs. However, you must also become familiar
with the details of the tank systems and operations at your own facility so that you can operate,
maintain, and document that the systems are in compliance with regulatory requirements.
1.2 Applicability
The requirement to have authorized operators applies to USTs at PBS facilities regulated under 6
NYCRR 613-2 and USTs at CBS facilities regulated under 6 NYCRR 596-599. These include
facilities that have petroleum USTs with individual capacities of more than 110 gallons. There
are exceptions for certain USTs that:
(1) contain heating oil used for onsite consumption;
(2) have a design capacity of 1,100 gallons or less and are used to store motor fuel for non-
commercial purposes (not for resale) at a farm or residence;
(3) are part of an emergency generator system at nuclear power generation facilities; OR
(4) are field constructed (i.e. are built onsite).
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1-3 New York UST Operator Training Program | New York State Department of Environmental Conservation | October 2015
Tank IQ
UIDE
TANK GUIDE
Chapter 1: Introduction
Class A
Operators
have primary
responsibility
for operation
and
maintenance
of UST
systems.
Class B
Operators
have daily
responsibility
for onsite
operation and
maintenance
of UST
systems.
Class C
Operators are
onsite
individuals
who are
generally the
first line of
response to
actual or
potential
emergencies.
Chapter 4 provides more details on the definition of a regulated PBS facility. Chapter 19
provides information on CBS facilities.
1.3 Training and Testing: Timing Requirements
Class A Operators have primary responsibility for operation and maintenance of UST systems.
These operators typically manage resources and personnel to maintain compliance. Training for
Class A Operators should help the operator make informed decisions regarding compliance with
regulatory requirements.
Class B Operators have daily responsibility for onsite operation and maintenance of UST
systems. Training for Class B operators should provide an in-depth understanding of operation
and maintenance aspects of UST systems.
Class C Operators are onsite individuals who are generally the first line of response to actual or
potential emergencies. The Class C Operator must be trained to take appropriate action in
response to UST-related emergencies or alarms caused by spills or leaks from an UST system.
A person may be designated to more than one operator class as long as they are properly
trained and authorized in each operator class for which they are designated.
New facilities must designate operators when they commence operation. Class A and B
Operators at those facilities then have 30 days to become authorized. Class C Operators must
be trained before they are designated.
Facilities where operator training is required and that are already operating on October 11, 2015
will have until October 11, 2016 to designate authorized operators and for those operators to
train Class C Operators.
1.4 Operator Testing Requirements
Class A and B Operators must pass the DEC exam. DEC will also accept valid operator training
verification issued by another state (i.e., reciprocity) that is recognized by EPA as meeting
operator training grant guidelines. Class A and B authorization does not expire unless revoked
by DEC due to significant noncompliance with regulatory requirements.
Class C Operators must be trained by a Class A or B Operator; their knowledge must be assessed
and the training must be documented, but a written exam is not required. Class C Operator
training does not expire, but it is good practice for the Class C Operator to periodically receive
refresher training.
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1-4 New York UST Operator Training Program | New York State Department of Environmental Conservation | October 2015
Tank IQ
UIDE
TANK GUIDE
Chapter 1: Introduction
Certain
problems at
your site may
cause DEC to
prohibit
deliveries of
product to
your tanks.
The
information in
this Guide can
help you keep
your tank
system
running in
compliance
with these
regulatory
requirements.
1.5 Red Tags – Regulatory Consequences of Releases or Serious
Deficiencies
Certain serious problems at your site may cause DEC to prohibit deliveries of product to your
tanks. The prohibition is known as red-tagging because DEC will attach a tag to the tank fill pipe
to notify fuel suppliers that they may not deliver fuel to that tank.
The most serious problems, known as Tier 1 conditions, will result in the tank being tagged
when the problem is discovered. Tier 1 conditions include a tank system that is known to be
releasing petroleum, or a tank system that is missing required:
secondary containment;
spill and overfill prevention;
corrosion protection; or
leak detection.
Tier 2 conditions may result in DEC tagging the tank after written notification to the facility.
These conditions include:
leak detection results that indicate the tank system may be leaking, or would not
contain a leak if one occurred; or
failure to comply with standards for secondary containment, spill/overfill prevention,
corrosion protection, or leak detection within 30 days following written notice from
DEC.
Delivering fuel to a red-tagged tank or tampering with the tag is illegal and may result in
enforcement actions including substantial fines. For additional information about the red tag
process, see Subpart 613-5 of the PBS regulations. Complete PBS regulations are at 6 NYCRR
613 of New York’s regulatory code. The complete CBS regulations are at 6 NYCRR 596-599. See
Section 20.0 for links to the regulations online.
Disclaimer: The information in this Guide can help you keep your tank system running in
compliance with regulatory requirements, but it is NOT a substitute for the regulations.
1.6 Summary
Your responsibility as a tank operator is to prevent releases of petroleum products or
harmful chemicals to the environment and to keep your facility in regulatory
compliance.
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1-5 New York UST Operator Training Program | New York State Department of Environmental Conservation | October 2015
Tank IQ
UIDE
TANK GUIDE
Chapter 1: Introduction
Your
responsibility
as a tank
operator is to
help prevent
releases of
petroleum
products or
harmful
chemicals to
the
environment
and to help
keep your
facility in
regulatory
compliance.
By October 11, 2016, every regulated facility where operator training is required must
designate one Class A and Class B Operator, and one or more Class C operators.
Class A Operators have primary responsibility for operation and maintenance of the UST
system.
Class B Operators have daily responsibility for onsite operation and maintenance of UST
systems.
Class C Operators are onsite individuals who are generally the first line of response to
actual or potential emergencies.
Class A and B Operators must pass the DEC exam or an exam administered by another
state recognized by EPA as meeting operator training grant guidelines.
Class C Operators are trained by a Class A or B Operator. Class C Operators must have
their knowledge assessed, and their training must be documented, but a written exam is
not required.
Certain serious problems at your site may cause DEC to prohibit deliveries of product to
your tanks.
The information in this Guide can help you keep your tank system operating in
compliance with regulatory requirements, but it is not designed to replace the
regulations.
Class A and B Operators must understand the general requirements for CBS tank
systems described in Chapter 19.
It is important that CBS operators be trained on the specific procedures and
requirements for each facility at which they are authorized.
Purpose of Operator
Training
(613.1-1)
The purpose of tank
operator training is
to protect human
health and the
environment.
Facilities with USTs
that are subject to
federal and state
regulation must
designate at least
one Class A, Class B,
and Class C Operator
for those tanks.
Class A and B
Operators must pass
an exam
administered by DEC
or obtain credentials
issued by any state
program recognized
by EPA as meeting
operator training
grant guidelines.
DEC may require
Class A or B
operators to be
retested if their
system is found to
be in significant
noncompliance.
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CHAPTER
2
A/B Operator Training Requirements and 2.0
Deadlines
Your responsibility as a tank operator is to prevent releases of petroleum or
harmful chemicals to the environment and to help keep your facility in regulatory
compliance. Tank operator duties are shared between three classes of operators,
designated as Class A, Class B, and Class C. Facilities with USTs that are subject to
federal and state regulation (see Chapter 1) must have at least one operator from
each class, although a person may be designated to more than one operator class
as long as they are properly trained and authorized in each class for which they are
designated.
2.1 Class A Operator
Class A Operators have primary responsibility for operation and maintenance of
the UST system. These operators typically manage resources and personnel to
maintain compliance.
Class A Operators must understand how tank systems work and know the related
regulatory requirements with respect to:
• spill and overfill prevention;
• leak detection;
• corrosion protection;
• emergency response;
• compatibility;
• financial responsibility;
• registration;
• out-of-service/temporary closure and permanent closure;
• recordkeeping;
• environmental and regulatory consequences of releases; and
• knowledge and training requirements for Class B and Class C Operators.
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2.2 Class B Operator
Class B Operators have daily responsibility for onsite operation and
maintenance of UST systems. They must understand how tank systems
work and know the related regulatory requirements with respect to:
• Operation and maintenance;
• Spill and overfill prevention;
• Leak detection and related reporting;
• Corrosion protection and related testing;
• Emergency response;
• Compatibility;
• Recordkeeping;
• Environmental and regulatory consequences of releases; and
• Training requirements for Class C Operators.
2.3 Becoming an Authorized Operator
Individuals who wish to become authorized Class A and/or B Operators
must:
pass an online exam administered by DEC (also may
be taken in person, by request); OR
obtain credentials issued by any state program
recognized by the EPA as meeting operator training
grant guidelines.
For online exams, applicants must register online and provide
the requested information, such as their name, mailing
address, email address, and phone number. The online
version of the exam will be continuously accessible.
DEC will also provide opportunities to take the exam on a
computer or in a “paper-and-pencil” format at a DEC office (i.e., certain Regional Offices and
Central Office in Albany). All such exams will be proctored. Refer to DEC Program Policy DER-40
for more details.
Figure 2.2: Exams will be accessible online
Figure 2.1: Operator opening a
tank top sump. Class A and B
operators are responsible for tank
maintenance and monitoring
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All exam
candidates
must affirm
that they were
not assisted
with taking
the exam, that
they were not
provided exam
questions in
advance, and
that they will
not provide
exam
questions to
others.
All exam candidates (both online and in-person) will need to confirm their identities and affirm
that they were not assisted with taking the exam, that they were not provided exam questions
in advance, and that they will not provide exam questions to others.
The exam will be open book and must be completed within the allotted time. Candidates will be
able to answer exam questions based on information available in this Guide and the regulations,
but exam questions will not directly mirror the Guide or regulatory language. Some questions
will require critical thinking by the applicant.
Candidates seeking authorization:
exclusively as Class A Operators will need to answer approximately 65 questions;
exclusively as Class B Operators will need to answer approximately 50 questions; or
as combination Class A/B Operators will need to answer approximately 80 questions.
DEC will not charge for access to guidance materials or for taking the exam.
The exam will be designed to reflect the varying complexity of the topics and importance in
preventing releases. Emphasis will be given to questions in the following subject areas:
tank system basics,
overfill prevention,
tank leak detection,
piping leak detection,
corrosion protection and related testing,
spill containment,
UST system record keeping, and
operation and maintenance.
The following subject areas will be less heavily
emphasized:
tank registration,
financial responsibility,
out-of-service/temporary closure and
permanent tank closure,
inventory monitoring,
dispensers,
spill reporting and response actions,
product and equipment compatibility, and
training of Class C Operators.
Figure 2.3: Sample Operator Training Certificate
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Tank owners
must keep
facility
registration
information
current with
respect to
designated
Class A and
Class B
Operators.
Exams taken online will be automatically scored, with results provided to candidates
immediately upon completion of the exam. Candidates who pass will be given the opportunity
to print a document identifying them as an authorized UST operator (Class A, Class B, or
combination Class A/B) in New York State. The document will be dated and uniquely numbered.
Candidate information will be stored in DEC’s operator training database.
Paper exam results will be manually entered into the database by DEC Central Office staff.
Results of paper exams should be mailed to candidates within 30 days after the exam date.
Examinees who do not pass an online exam may retake it, but must wait 24 hours between
failing an exam and retaking that exam or taking any other operator class exam. Examinees may
take no more than three exams (whether passed or failed) in a rolling six-month period.
Reciprocity
DEC will accept valid operator training credentials issued by another state without requiring
operators to pass the DEC exam. Credentials issued by any state program recognized by EPA as
meeting operator training grant guidelines will be accepted.
2.4 When Do I Need To Be Authorized?
Initial Authorization
For facilities with UST systems that require an authorized operator and that were installed prior
to October 11, 2015:
owners must designate Class A and Class B Operators by October 11, 2016; AND
operators must become authorized by DEC by October 11, 2016.
For facilities with UST systems that require an authorized operator and that were installed on or
after October 11, 2015:
owners must designate Class A and Class B Operators at the time of facility registration;
AND
operators must become authorized by DEC within 30 days after being designated.
Tank owners must keep facility registration information current with respect to designated Class
A and Class B Operators.
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Authorized
operators are
not required
to be retested
unless DEC
finds
significant
non-
compliance at
one or more
facilities
where the
operator has
been
designated.
Retesting as Result of Noncompliance (613-2.5(e))
Authorized operators are not required to be retested unless DEC finds significant noncompliance
at one or more UST systems where the operator has been designated. (Chapter 1 has additional
information on significant noncompliance.) If DEC finds a facility to be in significant
noncompliance, the operator must be retested by taking the NYS exam regardless of how the
operator was previously authorized.
Operators who need to be re-authorized may use any training method they desire. They must
retake and pass the exam for the operator class for which they wish to be authorized.
Operators must complete the exam within 30 days after being notified by DEC that re-
authorization is required. If the operator is unable to complete the exam online and the next in-
person exam offering is more than 30 days after the time of being notified by DEC, the operator
must contact DEC for an extension.
If no extension is given or the operator does not achieve a passing score on the exam, the tank
owner must designate a new operator within 30 days after being notified of the need for re-
authorization.
If DEC observes that a Class A or Class B Operator is authorized at one or more facilities with
continual noncompliance issues, DEC may revoke that operator’s authorization for a specified
period of time.
2.5 Class C Operator
Class C Operators are onsite individuals who are generally
the first line of response to emergencies resulting from a
spill or release from a UST. Class C Operators are not
required to pass an exam. However, you must teach your
Class C Operators the emergency procedures they need to
follow at your facility and verify that they understand and
can implement those procedures. Chapter 18.0 has
additional information on training and documenting Class
C Operators.
Authorized Class A or Class B Operators are responsible for:
• ensuring that Class C Operators are trained in
emergency response procedures specific to their facility before being designated;
Figure 2.4: Class C Operators are often the clerks at
convenience stores
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Every facility
that is
required to
have
authorized
operators
must maintain
a list of their
designated
Class A, Class B
and Class C
operators.
• maintaining evidence of the required training of all Class C Operators at their facility, as
well as their subsequent assessment of knowledge;
AND
• producing evidence of the training of all Class C Operators at a facility upon request.
Although re-training Class C Operators is not required, it is a good idea to check their knowledge
of emergency procedures from time to time by asking questions such as: “What should you do if
the monitoring system alarms?”, “Where is the emergency shut-off, and when should you
activate it?”, or “Where do we keep the tank records?”.
2.6 Documentation
Every facility that is required to have authorized operators must maintain a list of their
designated Class A, Class B and Class C operators.
The list must:
identify each Class A, Class B and Class C operator at the facility for as long as the
operator is designated AND for an additional 3 years; and
include the name of the operator, class of the operator, date that the operator was
designated, date the operator initially completed testing or training and the date of any
retesting. In addition, all Class C operator records must include the name and
authorization number of the Class A or B Operator that trained them.
Records verifying completion of testing, training or retesting must be recorded on paper or
electronically for all operator classes. Operator authorization number should also be added to
any list of designated Class A or B Operators. Operator authorization number should also be
added to the list of designated Class A or B Operators.
2.7 Operator Database
DEC will make the list of currently authorized operators available online on its website. This
information will be limited to operator name, identification number, and authorization date.
If re-authorization is required for designated operators, then DEC will remove the name of the
operator from the list until the operator has completed the re-authorization process.
2.8 Retirement of Authorization
Operator authorization does not expire unless the operator is found to be associated with a
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facility in significant noncompliance. When an operator decides to stop serving as an authorized
operator in New York State (i.e., out-of-state relocation, change in career, or retirement), the
operator may voluntarily request that their authorization as a Class A and/or Class B Operator
be retired.
2.9 Summary
Your responsibility as a tank operator is to prevent releases of petroleum or harmful
chemicals to the environment and to help keep your facility in regulatory compliance.
Tank operator duties are divided between three classes of operators, designated as
Class A, B, and C.
Each facility that is required to have authorized operators must have at least one
operator from each class, although a person may be designated to more than one
operator class as long as they are properly trained and authorized in each class for
which they are designated.
Class A Operators have primary responsibility for operation and maintenance of the UST
system. These operators typically manage resources and personnel to maintain
compliance.
Class B Operators have responsibility for onsite operation and maintenance of UST
systems.
Individuals who wish to become authorized Class A and/or B Operators must:
o pass an exam administered by DEC; or
o obtain credentials issued by any state program recognized by EPA as meeting
operator training grant guidelines.
Class C Operators are onsite individuals who are generally the first line of response to
emergencies resulting from a spill or release from a UST. You must teach your Class C
Operators the emergency procedures they need to follow at your facility and verify that
they understand and can implement those procedures.
The exam will be open book and the guidance materials will be available free of charge.
Candidates will be able to answer exam questions based on information available in this
Guide and the regulations, but exam questions will not directly mirror the Guide or
regulatory language. Some questions will require critical thinking by the applicant.
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Authorized operators are not required to be retested unless DEC finds significant
noncompliance at one or more UST systems for which the operator has been
designated.
If DEC observes that a Class A or Class B Operator is authorized at one or more facilities
with continual noncompliance issues, DEC may revoke that operator’s authorization for
a specified period of time.
DEC will make the list of currently authorized operators available online on its website.
This information will be limited to operator name, identification number, and
authorization date.
Tank System
Knowledge
Know your UST
system to prevent
spills.
Maintain the various
components of your
UST system to
ensure proper
operation.
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CHAPTER
3
A/B Tank System Basics 3.0
The purpose of this section is to help you:
identify the key components of your UST system;
understand how each component works; and
understand the regulatory requirements for tank operation and
maintenance throughout the rest of this training course.
This is an introductory discussion only, and does not include every possible
component or design. For additional information on tank systems, see the
references provided in Chapter 20.0.
USTs are petroleum storage tanks that are 10% or more underground. Tanks
located in underground vaults, but with all sides visible for inspection, are not
considered USTs. While each UST facility is unique, all systems consist of common
components that allow for the storage, delivery, monitoring and dispensing of
petroleum.
USTs store petroleum products underground. The tank holds product at
atmospheric pressure, meaning at the same pressure as the air around us. All
tanks have a fill pipe to bring product into the tank and a suction or pressurized
piping system to take product out. All tanks also have a vent line to allow the tank
to “breathe” by relieving tank pressure. Figure 3.1 illustrates these concepts.
Figure 3.1 Basics of Tank Construction
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Figure 3.2:Typical tank top layout
Vent Stacks
Tank sumps (for tank
top equipment)
Fill ports
Automatic tank gauge sensors
USTs are equipped with threaded fittings, also known as bungs, that provide access to the tank
for various purposes. Bungs are used to fit UST accessories such as fill ports, automatic tank
gauging systems, submersible or turbine sumps, product piping, vapor recovery ports, and
vents. These devices are typically accessed through containment sumps, manholes or other
access covers. Not all tank top bungs are accessible from the ground surface. Vent lines and
suction lines may terminate at the tank without access to the surface.
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USTs are generally buried 3-4 feet beneath the surface. Tanks are typically located beneath a
concrete pad; but they may also be buried under gravel, grass or other materials. Figure 3.2 is a
photo of a typical UST layout.
Most UST systems contain the following items:
Tank(s) Tank fill port (with spill bucket)
Tank containment sump Interstitial inspection port
Product piping Dispenser(s)
Vent Dispenser containment sumps
Vapor recovery port Alarms, sensors and electronic monitoring console
This equipment will be explained in more detail later in this chapter and in subsequent chapters.
Figure 3.3 illustrates a typical underground layout and elevation of a tank system.
Figure 3.3: Tank top layout and elevation
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FRP tanks do
not require
cathodic
protection
3.1 Tank System Categories According To Installation Dates
The DEC PBS regulations divide UST systems into three distinct categories:
Category 1 Tank System: Any tank system whose tank was installed before December 27, 1986.
Category 2 Tank System: Any tank system whose tank was installed between December 27,
1986 and October 11, 2015.
Category 3 Tank System: Any tank system whose tank was installed after October 11, 2015.
Different regulatory requirements may apply to tanks in different categories.
3.2 Tank Construction
USTs are either single- or double-walled. Single-walled tanks consist of a single, primary tank.
Double-walled tanks, by comparison, consist of two tanks – a primary tank surrounded by a
secondary tank – separated by an interstitial space (also known as the interstice). The purpose
of the secondary tank is to prevent a release into the environment in the event of a leak within
the primary tank.
In a double-walled tank, the interstitial space is the space between the primary tank wall and
the secondary tank wall. It can be fitted with a leak detection system to detect leaks in the
primary or secondary tank, and is normally accessed through an inspection port in the tank pad.
See Figure 3.3 to learn where you can expect to find an interstitial monitoring port. Chapter 9.0
has more information about interstitial monitoring.
In addition to single- and double-walled design, USTs may
be constructed from a variety of materials, as summarized
below.
Fiberglass Reinforced Plastic (FRP)
A fiberglass-reinforced plastic (FRP) UST may be single- or
double-walled. FRP is commonly used because it is
corrosion resistant and durable in underground
environments. FRP tanks meet corrosion protection
requirements without any extra equipment or operating
requirements. Figure 3.4: Double-walled FRP tank ready for
installation
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Jacketed Steel
Jacketed steel tanks are steel tanks that are enclosed by a non-corrodible, nonmetallic material
such as fiberglass, plastic or urethane. The tanks are constructed with a space between the
steel wall and the jacketed material where the tank can be monitored for leaks. A cut-away
view of a jacketed steel tank is shown in Figure 3.5.
Steel Tank with Dielectric Coating and Cathodic Protection
Steel tanks may also be protected from corrosion by a factory-installed corrosion resistant
coating and cathodic protection (impressed current or sacrificial anodes – see Chapter 11).
Tanks that meet the Steel Tank Institute sti-P3 specification
are common examples of this type of design. These tanks
have dielectric bushings at tank openings to provide
electrical isolation of the tank from piping or other
components. “Dielectric” means a material that does not
conduct direct electrical current. A corrosion resistant
coating is installed on the outer tank wall. Anodes are then
attached to the outer tank to prevent corrosion.
Figure 3.5: Jacketed steel UST
Figure 3.6: STP-P3 tank
Dielectric bushings
Anode
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Figure 3.7: Worker spraying a
lining on a cathodically
protected tank
Steel Tanks with Internal Lining and Cathodic Protection
Internally lined steel tanks are steel tanks that have a spray-on lining inside the
tank to prevent internal corrosion. Sacrificial anodes or an impressed current
system are installed outside the tank to prevent corrosion on the exterior of the
tank. See Chapter 11 for more corrosion protection information.
Clad Steel Tanks
A clad steel tank consists of a steel tank with a thick layer of non-corrodible
material, such as fiberglass or urethane bonded to the outside. There is no
interstitial space between the steel tank and the non-corrodible coating.
3.3 Tank Configurations
Tanks or piping systems may be configured in different ways. Knowing if there
are connections and how those connections are configured is important. Those
configurations determine how the tank is registered and
what type of leak detection system must be used. If
product can move between your tanks, if the dispensing
piping from two or more tanks is connected, or if your
system blends different grades of fuel together, you must
have a leak detection system and inventory reconciliation
method that can properly account for the effects of these
connections
Manifolded/Siphoned Tanks
In this configuration, two or more tanks are connected
together by a siphon, which is a pipe connected to two
tanks of the same product. The siphon uses gravity to
allow product to move from one tank to the other as
product levels change. Siphoned tanks will tend to
maintain the same product level, as gravity will force product in the tank with a higher level into
the tank with a lower level.
There are some important things to remember about manifolded/siphoned, tanks:
Product usually moves between the tanks slowly. As such, the siphon pipe cannot move
product as fast as the rate of delivery from a truck, generally meaning that the delivery
vehicle will still have to connect to both tanks when delivering to both tanks.
Figure 3.8: Siphoned tank
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When tanks are manifolded, the total amount of product that can be released from a
failure in one of the tanks is the total volume of BOTH tanks. This means that the two
tanks manifolded together tend to behave like a single tank.
If in-tank leak detection methods are used, the monitoring system has to be
programmed so that the leak detection system treats the two tanks as a single, large
tank.
Siphons have to initially be primed to work. This means that a priming tube must be
connected to the submersible pump to create suction and draw fuel into the pipe. If the
siphon line has any air leaks, or it is not properly primed, the siphon/manifold will not
work properly.
Manifolded Piping
In a system with manifolded piping, the pipes leaving two or more tanks containing the same
product are connected after the product leaves the submersible pumps. In this type of system,
two or more tanks, each with a submersible pump, supply a single combined pipe that leads to
the dispensers. Depending on the system, one pump may operate at a time or both may
operate together.
There are some important things to remember about manifolded piping systems:
Unlike the manifolded/siphoned tank configuration, when the piping system is
manifolded, the total amount of product that can be released from a failure in one of
the tanks is not affected by the manifold, and therefore the contents of the tank do not
passively communicate. As such, the two tanks behave like two independent tanks, in
that the tank volumes are not combined when in the tanks.
Submersible pumps in pressurized piping systems require automatic line leak detectors.
Because those leak detectors service a common pipe in manifolded piping systems, the
leak detectors must be carefully selected and configured to ensure that they operate at
the proper threshold.
Because fuel from two or more tanks serves the same dispensers in this configuration,
inventory reconciliation calculations will have to account for fuel as if it is coming from a
single tank.
Blending Systems:
Vehicle fuel dispensers may dispense multiple grades of product, such as low-grade, mid-grade,
and high-grade gasoline. Often, to avoid having a third tank, the mid-grade fuel is a blend of the
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low- and high-grade products. The low- and high-grade products are piped from different tanks
and blended inside the dispenser. Blending systems do not involve the connection of tanks or
piping systems (except at the dispenser), so the tank and piping leak detection systems are not
affected. A blending configuration, however, will affect how inventory reconciliation
calculations are performed.
Compartmented Tanks
Compartmented tanks are constructed with dividers (typically single-walled) to create two or
more separate sections within the primary tank. Each section is called a compartment.
Compartmented tanks are most commonly used to separate grades of gasoline. Each
compartment must be listed as a separate tank on the facility registration. Typically each
compartment in a given tank has the same number followed by individual letters (“1A”, “1B”,
etc.).
Figure 3.9: Compartmented tank
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You must
provide the
proper
Properly
maintain all
tank top
equipment
Tank Top Equipment
The equipment discussed in this section is commonly found on the top of USTs. Figure 3.10
shows the top of several typical gasoline USTs before they are covered with soil.
Tank Top Sumps
Tank top sumps are usually accessed through covers in the tank pad and contain a variety of
equipment. Typical sumps range from 2 to 4 feet in diameter and can be round, oval, square or
rectangular.
Figure 3.11 shows a typical tank top sump layout, with the following equipment:
1. submersible or turbine pump,
2. product piping,
3. tank top sump sensors,
4. product line leak detector, and
5. automatic tank level gauge.
Interstitial Monitor
Tank Top Sump
Fill Port (Spill Bucket)
Vapor Recovery
Figure 3.10: Common service station UST layout
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Most tank top sumps are contained sumps with integrated sides and bottom that are liquid-
tight. Contained tank top sumps will keep any petroleum leaks from entering the environment
and protect the components from corrosion by isolating them from the surrounding soil.
Double-walled piping systems are designed so that leaks in the piping will flow back to the tank
top sump or the dispenser sump. Figure 3.12 shows a tank top sump containing product.
Product in your sump means that you may have a leak in your primary piping. Water in the
sump may mean that you have a leak in your secondary piping, or it could be a sign of a leak in
the sump or sump cover seals.
Looking in your tank top sump can help you determine whether you have a pressurized or
Figure 3.12:Product from double-walled piping
collecting in a tank top sump
1
2
3
4
Figure 3.13: Suction piping system Figure 3.14: Pressurized piping system
Figure 3.11: Typical tank top sump (refer to bullet list
in text for numbered items)
1
2 3
4
5
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suction piping system.
A suction piping system has a pump located inside the dispenser. The pump in the dispenser
draws product from the tank by suction. When you look into your tank top sumps, you will find
product piping but no pump (Figure 3.13).
A pressurized piping system has a submersible turbine pump inside a tank, with the pump head
visible in a tank top sump. The submerged pump will pump product to your dispenser. When
you look into your tank top sumps you will find product piping and a submersible turbine pump
head (Figure 3.14).
Dispensers
Dispensers deliver product to your customers. They are part of either a pressurized or suction
system. Figure 3.15 shows a dispenser (left side) that is part of a suction system. You can see
the suction pump located inside the dispenser.
The right-hand photo in Figure 3.15 shows a dispenser that is part of a pressurized system. This
dispenser does not house a suction pump because the dispenser is served by a submersible
pump located inside the tank.
Figure 3.15: Suction system dispenser (left) and pressurized system dispenser (right).
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Dispensers may also contain under-dispenser
containment sumps (UDCs). UDCs are located
under your dispenser and are designed to contain
any leaks from the dispenser piping. UDCs are
usually made of fiberglass, steel or HDPE (plastic).
You will be able to see your UDC when you look
down inside your dispenser cabinet. Dispenser
sumps may also contain electrical conduit to the
dispenser meter, product piping and fittings, and a
sump leak sensor.
Motor vehicle fuel dispensers served by
pressurized piping systems must also have a shear
valve. This is also known as the emergency,
impact, or crash valve. A shear valve is designed to
stop product flow if a car strikes the dispenser or if
a fire occurs at the dispenser. The shear valve location is shown in Figure 3.16. The valve must
be properly anchored and installed at the correct height.
Spill Buckets
Spill buckets are used at fill ports to prevent
small drips or spills from entering the
environment. A spill bucket is a liquid-tight
container that surrounds the fill port. Spill
buckets are commonly located underground
within the tank pad. They catch small leaks,
drips or spills from the delivery hose that may
occur during a delivery. Spill buckets must be
able to contain spills from a leaky fill connection
or drips when the delivery hose is disconnected.
Spill buckets must be kept clean and dry. See
Chapter 13: Spill Prevention for more
information.
Figure 3.17: Spill bucket
Figure 3.16: Typical dispenser layout
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Product Piping
It is important to know what type of piping your facility contains so that you can maintain and
monitor it properly. This section describes common underground piping systems that may be
present at your facility.
Single walled piping does not have a secondary outer wall or interstitial space. A leak from the
pipe will be immediately released into the environment.
Double-walled piping is a pipe-within-a-pipe, or a pipe encased in an outer covering, with an
interstitial space between the two pipe walls. The inner pipe is called the primary pipe (also
known as the carrier pipe) and the outer pipe is called the secondary or containment pipe.
Double-walled piping should be monitored for leaks with your leak detection system. Leaks
from the primary or secondary piping will run back into your under-dispenser containment or
tank top containment sump and can be detected by a leak sensor installed in the sump or by
weekly visual checks.
Flexible piping is typically made of non-corrodible nylon or Teflon. The piping may be fitted
with metal connectors. As long as any metal components are not in contact with soil, flexible
piping meets corrosion protection requirements without additional equipment, operation or
maintenance. Flexible piping can be either single- or double-walled.
Steel piping must be equipped with a cathodic protection system to prevent corrosion of the
piping by surrounding soils. Steel piping is usually single-walled, but double-walled steel piping
is occasionally used.
Figure 3.19: Flexible piping during installation Figure 3.18: Double-walled flexible pipe
Interstitial
Space Secondary Pipe
Primary Pipe
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Figure 3.21: Vent stack arrangement
FRP piping is constructed of non-corrodible fiberglass
reinforced plastic (FRP) and may be either single or
double-walled. FRP requires little maintenance and
can be used with both pressurized and suction
systems. The piping may be fitted with metal
connectors and, as long as any metal components are
not in direct contact with soil, meets corrosion
protection requirements without additional
equipment, operation or maintenance.
Vent Lines
All underground tanks are vented. Venting protects the tank
from damage by allowing air to flow in or out as the tank is
filled or emptied of product or as atmospheric pressure
changes. Venting also allows deliveries to proceed normally.
Vent lines run underground from your tank to a vent stack
which can be attached to a building or stand on its own.
Every vent stack will have a vent top cover. Pressure vacuum
vent (P/V vent) caps are required for gasoline tanks. The P/V
vent cap prevents vapors from escaping the tank until the tank
reaches a pre-set pressure. When the tank reaches that
pressure, the vent will open to allow your tank to breathe.
Once the tank pressure equalizes, the P/V vent will close in
order to minimize vapor loss. A P/V vent cap will also protect
your tank against the intrusion of water, debris or insects.
Tanks containing semi-volatile products (diesel, motor oil,
kerosene, etc.) can be vented with an open atmospheric vent
cap. An open atmospheric vent cap has an internal wire screen
and is designed to protect your tank and vent lines against the
intrusion of water, debris or insects. The vent is always open to
the atmosphere and will allow any pressure or vacuum in the
tank to equalize.
Figure 3.20: FRP piping during installation
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Chapter 3: Tank System Basics
Vapor Recovery
Vapor recovery systems are designed to prevent air
pollution by stopping the escape of gasoline vapors
from the UST system. Stage I systems operate
during product delivery to the UST and are required
only for gasoline storage tanks.
During delivery, the tanker truck operates two
hoses. One hose delivers product to the tank, while
the other hose takes vapors out of the tank and
back to the truck. The vapor hose will typically have
a Stage I vapor recovery adaptor on the end. The
adaptor attaches to the vapor recovery riser pipe,
which is typically accessible in a spill bucket. The
adaptor creates a tight seal to prevent vapors from
escaping and keeps water, dust and debris from
entering the tank.
Figure 3.23 shows a typical set up for a Stage I vapor recovery delivery. The truck has a product
hose attached to the tank to delivery, and a vapor recovery hose attached to remove the vapors.
Figure 3.22: P/V vent cap (left); Atmospheric vent cap (right) (Source: OPW)
Figure 3.23: Typical stage I delivery set up
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Figure 3.26: Overfill alarm
Monitoring Wells
Monitoring wells are used to detect a release within the tank backfill, or the
buried material surrounding an UST. Monitoring wells for leak detection are not
common but you may have one at your facility. It is important to locate and
properly mark your monitoring well to ensure product is not accidently
delivered to it.
Monitoring wells should be painted white, with a black triangle.
It is important that the wells are secure and have locking caps. A monitoring
well without a cap or cover can allow contamination or product to flow
directly into the soil or groundwater. Monitoring wells cannot be used as a
leak detection method where there is a history of spills or site contamination.
Electronic Monitoring Systems
Electronic monitoring systems can be used to monitor UST systems for
leaks. Monitoring systems typically consist of a console - the brain of an
automatic tank gauging (ATG) system - attached to various sensors,
probes and alarms. A typical monitoring system wiring layout is shown in
Figure 3.27.
Automatic tank gauging (ATG) probes:
measure product level in a tank;
measure water level in a tank; and
conduct in-tank testing.
Sensors:
monitor dispenser sumps, tank sumps and interstitial spaces for the
presence of liquid; and
measure the level of the brine solution in a tank with a wet interstitial
space.
Alarms indicate:
overfilling of a tank;
presence of a liquid in a sump or interstitial space;
presence of water in a tank;
low product level/whether a delivery is needed; and
Figure 3.24: Monitoring well
Figure 3.25: Typical monitoring
system console
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when the printer is out of paper
There are many types and models of monitoring systems. You should be familiar with your
system. It is important that you understand what each alarm indicates and the reason for the
alarm.
Emergency Stop (E-stop)
Facilities with pressurized product delivery (e.g. service stations with submerged turbine pumps)
typically have an emergency stop (E-stop) system that allows an operator to shut off product
flow by turning off power to the pumps. The E-stop is typically activated by an emergency
switch or button. If you facility is subject to Fire Code of New York State requirements for
motor fuel-dispensing facilities and repair garages, then you must meet the E-stop/emergency
Figure 3.27: Typical monitoring system schematic
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Chapter 3: Tank System Basics
disconnect switch installation criteria specified in the code regardless of whether you have a
pressurized or suction system.
3.4 Documentation of Tank System Installation
For Category 2 and 3 UST systems, each facility must maintain an accurate diagram showing the
location of:
each UST and its associated piping, including registration identification number;
dispensers or loading equipment;
check valves;
transition sumps (if any); and
monitoring or recovery wells (if any).
For Category 3 UST systems, the diagram must also show:
1. The following tank system attributes:
(i) physical dimensions of each tank; and
(ii) installation date for each portion of piping that was installed after October 11,
2015.
2. At least one visible reference point (for example, facility structure), a frame of reference
(for example, north arrow), and scale of the drawing.
For each component installed in a Category 3 tank system after October 11, 2015, facilities must
also maintain:
1. a signed statement by the installer certifying that the tank system component was
installed in compliance with the PBS regulations; and
2. the completed manufacturer’s installation checklist showing that the tank system
component was installed in accordance with the manufacturer’s instructions or that the
tank system component installation has been inspected and certified.
Tank Registration
6 NYCRR 613-1.9
All new or
replaced regulated
UST systems must
be registered with
DEC before they
receive their first
delivery.
Petroleum tank
registrations must
be renewed every
5 years.
The current
registration
certificate must be
on display at all
times at the
facility.
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CHAPTER
4
A Petroleum Tank Registration 4.0
Regulated petroleum USTs must be registered with DEC, except in delegated
counties (Nassau, Suffolk, Rockland, Westchester, and Cortland) where they must
be registered with county agencies. Facility/property owners or their authorized
representatives must obtain a registration certificate from DEC before any product
may be delivered to a new or replaced tank.
Registrations must be renewed every five years. If ownership of the property
where regulated tanks are located is transferred, an application for a new
registration must be submitted to DEC within 30 days after the transfer of
property. Registrations must be updated when new or replacement tanks are
installed, when tanks are out-of-service or permanently closed, or when other
registration information changes. Depending on a facility’s total storage capacity,
registration fees vary between $100-500. Delegated counties may have different
fee structures.
See Chapter 19 for general CBS tank registration requirements.
4.1 Definition of Petroleum
As defined in the PBS regulations, petroleum includes:
crude oil and any fraction thereof, including gasoline, diesel, fuel oil, etc.;
synthetic forms of lubricating oils, dielectric oils, insulating oils, hydraulic
oils, and cutting oils;
any complex blend of hydrocarbons that is not derived from crude oil; and
petroleum mixtures, including certain blends of petroleum and hazardous
substances.
This definition does not include:
hazardous substances except in certain blends with petroleum;
animal or vegetable oils; or
substances that are gases at standard temperature and pressure (e.g.
propane).
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Chapter 4: Petroleum Tank Registration
Check the DEC
website for
updated
forms.
4.2 Regulated Facilities
A facility must be registered if it has a total petroleum storage capacity greater than 1,100
gallons, or has AT LEAST one UST with capacity greater than 110 gallons (with some conditions
and exceptions). Tanks storing used oil, regardless of size, must also be registered. The PBS
Registration Fee Worksheet below can be used to determine whether the tanks at your facility
need to be registered with DEC. A copy is available from the DEC website
http://www.dec.ny.gov/chemical/4767.html
Figure 4.1: PBS Fee Worksheet (Check DEC website for updated forms)
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Chapter 4: Petroleum Tank Registration
The facility
owner is
responsible for
registering the
tanks, even if
the tanks are
owned by
someone else.
However, the
facility owner
can designate
an authorized
representative
(e.g. the tank
owner) to
submit the
registration.
You must
notify DEC of
tank
installations at
a new facility
at least 30
days prior to
installing any
tanks.
4.3 Facility Owner
The facility owner is the person who owns the property on which the regulated tanks are
located. The facility owner is responsible for registering the tanks, even if someone else owns
the tanks. However, the facility owner can designate an authorized representative (e.g. the tank
owner) to submit the registration. If you wish to be an authorized representative, you should
have the facility owner sign a written authorization. Be prepared to provide a copy to DEC if
requested.
4.4 Notification of Tank Installation at a New Facility
You must notify DEC of tank installations at a new facility at least 30 days prior to installing any
tanks. A Pre-Work Notification Form is available online at
http://www.dec.ny.gov/docs/remediation_hudson_pdf/tankmodnotice.pdf.
After the tanks are installed, and before having any product delivered to the tanks, you must
obtain a registration certificate for the facility. See Section 4.9 for registration of additional or
replacement tanks.
4.5 Registration of New Facilities
A new facility must be registered before product is delivered to the tanks. The applicant must
use forms provided by DEC. The PBS Registration Application and instructions are available at
all DEC offices and online at
http://www.dec.ny.gov/chemical/4767.html
Instructions are available at
http://www.dec.ny.gov/docs/remediation_hudson_pdf/pbsinstr.pdf
Forms are often revised, so you should download the most recent form instead of using old
copies.
A new registration must be accompanied by a copy of the deed page showing the owner name
and date of ownership for the property where the facility is located. If the facility is located on
multiple properties, then the deed page(s) for each property must be submitted. The deed
page(s) provide confirmation of the property’s legal ownership.
The facility owner or an authorized representative for the facility owner must sign the
registration application. In addition, every application must be accompanied by payment of the
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Chapter 4: Petroleum Tank Registration
Registration
MUST be
renewed every
five years from
the date of the
last valid
registration
certification.
Corrections of
information at
a facility must
be submitted
to DEC.
registration fee as determined in the regulations. The application must list the actual names
(not titles) of the Class A and B Operators and their operator authorization number.
4.6 Registration Certificate
Once your completed application and registration fee is submitted, DEC will issue a registration
certificate. The current registration certificate must be displayed at all times in a conspicuous
location at your facility. Make sure your Class C Operators know where the certificate is posted.
DEC will also maintain a copy of the information you have submitted about your facility in a
form called the Facility Information Record (FIR). If you need a copy of that information, you can
request a copy of your FIR from DEC.
4.7 Renewal
Registration MUST be renewed every five years from the date of the last valid registration
certificate. Registrations must be renewed until all regulated tanks at the facility are
permanently closed. You may receive a courtesy reminder from DEC, along with pre-printed
forms, when registration is due; however, you are responsible for submitting a renewal
application whether or not you receive such a reminder. If there have been any changes at your
facility, you may cross out the old information on the form and write in the new information.
4.8 Transfer
If ownership of the property where a facility is located is transferred, the new property owner or
authorized representative must submit a new registration application to register the facility
within 30 days after the transfer. The application must be accompanied by a copy of the current
deed page(s) for the facility property (or properties) showing the new owner. The registration
fee will be the same as for a new facility.
4.9 Registration of Additional or Replacement Tanks
Additional or replacement tanks must be registered when they are installed at a regulated
facility. This includes brand-new tanks as well as tanks that are moved from one location of the
property to be used at another location on the property.
Advance notification of the installation of a tank must be given to DEC at least 30 days prior to
installing the tank, using the Pre-Work Notification Form.
Once a new or replaced tank is installed, you must submit an updated registration application.
You will use the same form as for a new facility, but check “Tank Installation” in the
”Transaction” box and enter the information for only the new tank on the second page of the
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Chapter 4: Petroleum Tank Registration
When a facility
intends to
permanently
close a new
tank, the
owner must
notify DEC at
least 30 days
prior to
beginning the
permanent
closure
process.
form. If adding a new tank results in an increased fee, the increased fee will not apply until the
next renewal date. DEC will issue a new registration certificate that must be posted at your
facility in place of the old certificate.
4.10 Information Correction
Corrections of facility information must be submitted to DEC. This includes changes in contact
information, Class A or Class B Operator, tank system equipment, or type of petroleum stored.
You may submit:
a copy of your most recent application with old information crossed out and new
information written in, being sure to make these corrections neat and legible; OR
a new copy of the application with the corrected information entered.
If there has been a change in tank equipment, you do not need to enter information for tanks
that were not modified. However, you should enter complete information for tanks whose
equipment has changed. For other information (e.g. changes in contact information), you
should circle or highlight the information that has changed.
4.11 Tank Closure
The facility registration must be updated when a tank is out-of-service, following the procedure
in section 4.10. The owner must notify DEC at least 30 days prior to beginning a permanent
tank closure process. No later than 90 days after a tank has been permanently closed, the
owner must submit a registration application indicating that the tank has been permanently
closed. The owner is responsible for conducting a site assessment if one is required and
submitting a closure report to DEC (see Chapter 6 for more information on closure requirements
and practices).
4.12 Summary:
All regulated tanks MUST be registered BEFORE any product is delivered to the tank and
within 30 days after a transfer of ownership.
Use the PBS Fee Worksheet to determine if your tanks need to be registered.
The current registration certificate must be on display at the facility at all times.
Tank registrations MUST be renewed every 5 years.
See Chapter 19 for registration requirements for CBS tanks.
Financial Responsibility
40 CFR 280, Part H
The tank owner,
operator, and
facility owner are
each potentially
responsible for
cleanup costs,
including third-
party bodily injury
claims, caused by
an accidental
release from a UST
system.
Tank owners or
operators must
maintain
documentation of
financial
responsibility.
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CHAPTER
5
A Financial Responsibility 5.0
As a tank owner or
operator you are required
to clean up any spill or
release from your UST
system.
Corrective actions are
required for all spills, from
small surface releases to
major impacts to soil and
groundwater. Such
actions could include
cleaning up leaked
petroleum, correcting
environmental damage,
supplying drinking water,
and compensating injured parties for property damage. In some cases clean-up
costs can reach hundreds of thousands of dollars.
State statute (Navigation Law, Article 12) and federal regulations (40 CFR 280) hold
the tank owner, the tank operator, AND the facility owner liable for these costs.
You may also be financially responsible for any third-party bodily injury claims
caused by an accidental release from your UST system.
5.1 Meeting the Financial Responsibility Requirement
Private tank owners/operators have several different mechanisms available to
demonstrate financial responsibility. Local governments - such as cities, counties
and towns - may also use any of these mechanisms in addition to those available
only to local governments. Once you have chosen a mechanism for meeting
financial responsibility requirements, you must have a document that
demonstrates your compliance with the requirement. The format and type of
documents vary. The federal regulations contain information that is required for
particular mechanisms. Be sure that your documents are complete, up-to-date,
and meet the requirements.
Figure 5.5.1: Gasoline spill
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Chapter 5: Financial Responsibility
You should
have financial
assurance to
cover liabilities
including, but
not limited to:
clean-up, third
party property
damage and
legal costs.
You must have
financial
assurance to
cover third-
party bodily
injury.
Oil Spill Fund
DEC may use money from the New York State Environmental Protection and Spill Compensation
Fund - (also known as the Oil Spill Fund) to undertake corrective actions if an owner or operator
is unable or unwilling to undertake a spill clean-up. HOWEVER, the Oil Spill Fund does not
cover third-party bodily injury. In addition, the State is obligated by law to recover these
funds, plus penalties and interest, from the owner or operator.
You should have financial assurance to cover liabilities including, but not limited to: clean-up;
third property damage; third-party bodily injury and legal costs. You must have financial
assurance to cover third-party bodily injury in the amounts described below.
Required Amounts of Financial Responsibility
It is important for you to understand the level of financial responsibility that applies to your site.
Your method of coverage for every UST at your site must include at least the minimum required
amount per occurrence as well as the minimum aggregate amount. The number of tanks may
be based on multiple facilities under the same ownership.
Minimum financial responsibility, per occurrence:
For petroleum marketing facilities, or for any facility that
handles an average of more than 10,000 gallons per
month based on the previous calendar year’s throughput
$1,000,000 per occurrence
For all other facilities $ 500,000 per occurrence
Minimum aggregate financial responsibility:
For owners with 1 - 100 UST systems $1,000,000
For owners with 101 or more UST systems $2,000,000
These amounts of assurance do not include legal costs and do not limit tank owner/operator
liabilities.
Acceptable Methods to Demonstrate Financial Responsibility
There are various ways to demonstrate financial responsibility. These methods are detailed in 40
CFR 280 Subpart H and can be combined to meet the requirements. The regulations list specific
language that must be included in financial assurance documents. Your responsibility as a Class
A Operator is to ensure the proper documentation is available and up-to-date.
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Chapter 5: Financial Responsibility
The tank
owner or
operator must
maintain
records of
financial
responsibility.
The following mechanisms can be used to provide financial responsibility for private and local
government tank owners/operators (for specific requirements, refer to 40 CFR 280.95 - 103):
Liability insurance coverage from a qualified provider
Financial test of self-insurance
Guarantee
Surety bond
Letter of credit
Trust fund
The following mechanisms can be used in addition to the previously listed mechanisms to
provide financial responsibility for local government tank owners/operators:
Local government bond rating test
Local government financial test
Local government guarantee
Local government fund
The tank owner/operator may substitute any compliant financial responsibility mechanism at
any time provided that an effective mechanism or combination of mechanisms is maintained at
all times.
Note: Guarantees and surety bonds are currently not allowed pending a statement from the
State Attorney General that they are legally valid and enforceable obligations in New York State.
Insurance
Insurance coverage is a common mechanism to meet the requirement of financial responsibility.
It is important to note the expiration date of the insurance policy and to promptly renew the
policy to avoid any lapse in coverage. Be certain that your insurance company provides you with
a renewed insurance certificate prior to the expiration of the previous certificate. A valid
certificate is required to demonstrate that you meet the requirements of financial responsibility.
5.2 Reporting and Recordkeeping
The tank owner/operator must maintain documentation of financial responsibility. The type of
document needed is based on the mechanisms used to meet the requirement. The accepted
documents and evidence are described in the 40 CFR 280, Subpart H. You should contact the
person responsible for meeting the financial responsibility requirements for your facility to
ensure that the proper documents are available either at the facility or at the owner/operator’s
place of work. These documents must be made available to DEC upon request.
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Chapter 5: Financial Responsibility
It is the owner
or operator’s
responsibility
to be familiar
with the
details of the
financial
responsibility
requirements.
Documentation of your facility’s financial responsibility mechanisms must be maintained until
the UST system has been permanently closed.
It is the owner/operator’s responsibility to be familiar with the details of the financial
responsibility requirements. In the event of an accidental release at your site, it is important for
an owner/operator to have the resources necessary to promptly perform the proper corrective
actions.
5.3 Summary
As a Class A Operator, you should:
Understand that you, the tank owner, and/or the facility owner are potentially
financially responsible for accidental releases from your USTs.
Understand that the Spill Fund is not an insurance program and that DEC is obligated to
recover costs for cleanups it conducts.
Understand that there must be financial responsibility (e.g., private insurance) in place
to pay for damages due to accidental releases from your USTs.
Know what kind of financial responsibility mechanism is required and in place for your
site.
Know how to access those funds promptly if necessary.
Have a clear understanding with the tank owner regarding who is financially responsible
in case of a spill.
Understand the limits and the effective dates of coverage.
Out-of-Service UST
Systems and Closure
Requirements
6 NYCRR 613-2.6
UST systems that are
out-of-service for
more than 12
months must be
permanently closed
DEC must be notified
30 days prior to
permanent closure
Closure records
must be maintained
for 3 years
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CHAPTER
6
A
Tank IQ
Out-of-Service Tanks and Permanent Closure 6.0
Tank systems that do not receive or dispense product for 30 days or more are
considered out-of-service. Those that are out-of-service for over 12 months must
be permanently closed. Suspending service or closing a tank system requires more
than simply shutting off the electricity, locking up the facility, and walking away. If
you take a tank system out-of-service, you are still responsible for all required
corrosion protection, leak detection, inspections, reporting, and registration. Tank
systems that you do not plan to use again should be permanently closed. Prior to
permanent closure, you must investigate your site for leaks that may have gone
undetected over the life of the tank system. You must then close the system in
compliance with regulations. You must take specific steps if you intend to convert
a petroleum tank system to store a non-petroleum product.
You are required to notify DEC thirty days before permanently closing a tank
system or switching the tank system to storage of a non-petroleum product.
6.1 Out-of-Service Tank Systems
If you temporarily take a tank system out-of-service, you must do ALL of the
following after dispensing and deliveries to/from the tank cease:
Submit an updated tank registration application to DEC, preferred within
30 days, showing the change in tank status.
Figure 6.1: Out-of-Service Gas Station
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Chapter 6: OUT-OF-SERVICE TANKS: TEMPORARY
AND PERMANENT CLOSURE
Out-of-service
tanks must
remain
registered and
continue to be
maintained to
prevent leaks.
Continue to perform leak detection (including ten-day inventory reconciliation, if
required) OR remove product from the tank so there is no more than 1 inch of residual
liquid (product or water) remaining in the tank.
Maintain all corrosion protection. Power must remain on for impressed current
systems.
Continue required inspections and recordkeeping.
If you plan to take your tank system out-of-service for more than three months you must
continue the practices listed above, and ALSO do the following:
Lock all fills and dispensers.
Cap and secure all lines, manways and ancillary equipment.
Leave the vent lines open.
USTs that are temporarily closed for more than 12 months must be properly permanently
closed.
6.2 Permanent Tank Closure
UST systems that are out-of-service for over 12 months
must be permanently closed. In addition, any tank system
that you do not plan to return to service should be
permanently closed. You must notify DEC at least 30 days
before beginning permanent closure, unless the closure is a
result of corrective action required by DEC.
To permanently close a tank system:
Empty and clean the tank by removing all liquids
and accumulated sludge
Remove the tank from the ground or fill it with an
inert solid material (such as sand or concrete
slurry). If an inert solid material is used all voids within the tank must be filled.
All piping, vent lines and ancillary equipment must be disconnected and removed.
Ensure that all scheduled deliveries to the tank are terminated.
No tank may be re-installed or returned to service after closure unless the tank meets
Category 3 standards.
Figure 6.2: Tank Removal
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Chapter 6: OUT-OF-SERVICE TANKS: TEMPORARY
AND PERMANENT CLOSURE
Site Assessment
Before permanent closure or a change in service is completed, you must assess the site for the
presence of a release. The site assessment must include measurements for the presence of a
release of product. Typically these measurements are made by analyzing samples of soil,
groundwater, and/or vapor from the site. You must assess the area where contamination, if
any, is most likely to be present. In selecting sample types, sample locations, and
measurement methods, you must consider the method of closure, petroleum stored, type of
backfill, depth to groundwater, and other factors appropriate for identifying the presence of a
release.
If a facility uses groundwater monitoring or vapor monitoring as a method of leak detection,
AND there is no indication that a release has occurred prior to closure, the site assessment is
not required. If subsurface vapors and/or contaminated soil/groundwater are found,
corrective action must be taken. Records from the site assessment must be submitted to the
DEC within 90 days after the tank system is permanently closed.
6.3 Change in Service
A change in service means switching your tank system to storage of a substance other than
petroleum. Before a change in service, you must:
Empty and clean the tank by removing all liquid and accumulated sludge. All cleaning
must be done in accordance with one of the codes of practice listed in the regulations;
AND
Complete a site assessment that meets the same requirements as for permanently
closed tank systems.
You should also verify that the UST system is compatible with the new product and meets
applicable codes and regulatory requirements.
If you switch the tank system to storage of a different type of petroleum product, you do not
have to complete a site assessment, but you must submit a registration update to DEC within
30 days after the change in service. You also need to verify that your tank system is compatible
with the new product and meets applicable codes and regulatory requirements.
Before
permanent
closure or a
change in
service, you
must assess
the site for the
presence of a
release.
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Chapter 6: OUT-OF-SERVICE TANKS: TEMPORARY
AND PERMANENT CLOSURE
Copies of all
closure
records must
be
transmitted to
DEC within 90
days following
permanent
closure.
6.4 Tank Systems Improperly Taken Out-of-Service before
12/27/1986
Tank systems that were taken out-of-service before 12/27/1986 and were not properly
permanently closed must be properly permanently closed. In addition, all tank systems must
be registered so that DEC has a record of their existence and proper closure.
6.5 Closure Records
All closure records must be transmitted to DEC within 90 days following permanent closure. All
closure records must be maintained for 3 years.
6.6 Registration Update
A registration update must be submitted to DEC after any change in status: out-of-service,
permanent closure, change in petroleum product stored, or change in service. Registration
updates may be submitted using the same forms as a new registration (see Chapter 20.0 for
web links to current forms).
6.7 Summary
Tank systems that do not receive or dispense product for 30 days or more are
considered out-of-service.
Tank systems that are out-of-service for over 12 months must be permanently closed.
If you temporarily close a tank, you are still responsible for all required corrosion
protection, leak detection, inspections, reporting, and
registration
Prior to permanent closure, you must investigate
your site for petroleum leaks that may have gone
undetected over the life of the tank system. This
investigation is known as a site assessment.
You must provide the results of the site investigation
to DEC no later than 90 days after the date the tank
system was permanently closed.
Figure 6.3: Out-of-service tank systems must
be maintained until permanent closure.
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Chapter 6: OUT-OF-SERVICE TANKS: TEMPORARY
AND PERMANENT CLOSURE
Tank systems taken out-of-service before 12/27/1986 that were not properly
permanently closed must be properly closed.
Specific steps, including a site assessment, must be taken if you intend to convert a
petroleum tank system to store a non-petroleum product.
Overfill Prevention
Requirements
6 NYCRR 613-
2.1(b)(3)
Must prevent
spilling and
overfill when
petroleum is
being transferred
to the UST System
Must prevent
spills when
transfer hose is
detached from fill
pipe
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CHAPTER
7
A/B Overfill Prevention 7.0
Operators and drivers share the responsibility of ensuring that overfills or spills do
not happen during fuel deliveries. The best way to prevent overfills is to deliver
the proper amount of product.
Before the delivery begins, the driver should determine how many gallons of
product can safely be delivered to the tank. The delivery driver must only deliver
enough product to fill the tank to its working capacity, which is typically 90 or 95%
of the tank volume. The portion of the tank that is unfilled at the start of delivery
is often referred to as the ullage. Many automatic tank gauging systems will
indicate the amount that can be safely delivered as the 95% ullage of the tank.
Why not 100%? Because if your tank is 100% full before the tank truck
compartment is empty, the driver will be left with a hose full of fuel and nowhere
to drain it. Overfills occur when there is not enough room in your tank for the
remaining product. Additionally, fuels can expand due to temperature changes,
resulting in a release from a 100% full tank. Spills to the environment could result
in potential contamination of soil or water, or could even start a fire.
Tanks must be equipped with automatic alarms or other approved devices to warn
the driver or to stop the delivery before an overfill occurs.
Figure 7.1 shows a driver preparing to make a fuel delivery. The
farthest pink hose carries vapors from the UST to the truck. The
other carries regular gasoline from the truck to the UST. The
green hose is double-walled. It delivers premium product
through an inner hose and returns vapors to the truck via an
interstitial space. “Elbow” fittings on the end of the green hose
and closest pink hose create a liquid tight seal to the tank fill
pipes.
Fire codes require delivery drivers to be standing near their
vehicles and attentive during delivery, not sitting in their truck
or in your building. Chapter 20 lists web links to organizations
such as the National Fire Protection Association and the
American Petroleum Institute that provide standards for fuel
transfers.
Figure 7.1: Fuel Delivery
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Inspect spill
buckets
routinely
Shut-off
valves must be
maintained.
Figure 7.2: Installing a flapper
valve
Operator’s Responsibilities to Prevent Delivery Overfills
You should confirm that your fuel supplier has a written delivery procedure for their drivers.
Alternatively, you may provide written procedures and require drivers to follow them.
In addition you MUST:
Monitor all fuel deliveries from beginning (either operator or carrier) to end. Physically
monitor your delivery drivers or focus a security camera on your fuel-delivery area.
Inspect your spill buckets routinely for presence of product or water, as well as cracks,
worn seals, etc. See Chapter 13 for more information.
Respond to ALL overfill indications. Never ignore overfill alarms or fuel flow shut-off.
Report and clean up all spills. Have spill clean-up materials handy during all fuel
deliveries. Post emergency phone numbers in a prominent location for reportable spills.
Report spills to the proper authorities. See Appendix A for a sample emergency phone
number template.
What Do Overfill Prevention Devices Do?
You are the primary overfill prevention device! You are responsible for seeing
that your tanks are equipped with proper overfill prevention devices and that
delivery personnel follow proper procedures. An overfill alarm will alert the
delivery driver that the tank has reached the working capacity but, if ignored,
will not prevent an overfill. Other overfill prevention devices either stop or limit
the flow of product into the tank BEFORE the tank is filled to the very top, so
that product left in the hose will still fit into the tank.
You are required to have an overfill prevention device that will perform one of
these three functions:
automatically shut off flow into the tank when the tank is no more than
95% full;
alert the operator or driver when the tank is no more than 90% full by
restricting flow into the tank or triggering a high-level alarm; or
restrict flow 30 minutes prior to overfilling, or alert the operator or
carrier with a high-level alarm one minute before overfilling.
Flapper
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The two most common overfill prevention devices used to perform the functions above are:
electronic alarms;
mechanical overfill devices (ball float valves, shut-off valves).
What is Exempt?
A facility is not required to use spill or overfill prevention devices on UST systems that are only
filled by transfers of 25 gallons or less at a time.
7.1 Mechanical Overfill Device
Automatic Shut-off Valves
Automatic shut-off valves (also known as flapper valves) are installed in the tank’s drop tube.
The drop tube is a thin aluminum tube located inside the tank’s fill pipe that extends to the
bottom of the tank. A float-activated “flapper” slams shut and restricts flow to the tank when
the liquid level in the tank reaches 95% of the fill tank volume. The delivery hose then “jumps”,
alerting the driver that the flapper has been closed. The driver should immediately stop the
flow of fuel from the truck and drain any excess fuel from the hose into the tank. Drivers need
to be watching the delivery hose in order to notice this “jump”.
Shut-off valves work well as long as they are installed correctly and maintained properly. The
most common issues with shut-off valves are:
Shut-off valves have moving parts that can break.
Test your shut-off valve annually.
Shut-off valves must not be disabled or bypassed.
Never leave a gauging stick or other item in your fill pipe. Such
items can keep your shut-off valve from closing properly. Call
your service technician to check your shut-off valve if you find
an item stuck in your drop tube. Do not allow deliveries to a
tank with the shut-off valve jammed open.
The sudden closing of the drop tube will put stress on the delivery
system.
The hose connections to the tank and the truck must be secure or they may
disconnect, causing a surface spill.
The connection between the tank and the delivery hose MUST be liquid tight.
Deliveries must be made by gravity only.
Figure 7.3: View of a flapper valve
from a spill bucket
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Ball float
valves are NOT
user friendly
Figure 7.4: Ball Float Valve
Ball Float Valves (613-2.1(b)(3)(i)(b)(2))
A ball float valve is contained in a short piece of pipe that extends into the top of
the tank where the vent pipe or Stage I vapor recovery exits the tank. You might
find it extremely difficult to determine whether or not your UST has this device
because it is not readily visible. Typically, a ball float valve consists of a wire cage
containing a hollow ball. The cage is fastened to the lower end of the vent pipe.
The ball sits below the end of the pipe inside the wire cage. As the product level in
the tank rises, the ball floats up on the rising liquid. The ball will eventually block
the vent opening if the level of the product gets too high. With the vent opening
blocked, very little fuel can enter the tank. For a ball float to prevent an overfill,
the tank must be air-tight and the delivery hose must be tightly clamped onto the
fill pipe. The working capacity of a tank equipped with a ball float valve should be
set at no more than 90% of the design capacity.
Ball float valves are NOT user friendly. They increase the pressure in the tank,
sometimes causing fuel to splash back onto the driver if he/she tries to disconnect
the hose. Drivers often try to relieve the pressure by opening the drain in the spill
bucket or the cap of the automatic tank gauge. These fittings are NOT DESIGNED
to be opened during delivery. Doing so can release flammable vapors, which can
cause an explosion.
The Petroleum Equipment Institute (PEI) recommends ball float valves NOT be
used at all. See the PEI link in Chapter 20.0 for more information.
The following issues may lead to extremely hazardous conditions when using a ball
float valve:
Deliveries should be made by gravity only.
Ball float valves are not designed to be used with pressurized deliveries.
Fill connections must be tight.
If the fill connection is not tight, fuel will back up in the fill pipe and result in a spill on the
ground when the ball float valve closes.
Ball float valves should not be used for generators or heating oil tanks.
These tanks often have loose connections or fill via pumped (pressurized) delivery.
Ball float valves may cause product to escape through remote fills and gauge openings.
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Never ignore
overfill alarms
Ball float valves perform poorly in suction piping systems.
When a ball float closes, the fuel in the tank pressurizes and looks for an escape route.
Dispensers are the most common escape routes and an overfill can occur through a
dispenser near your customers.
Coaxial Stage I vapor recovery systems render the ball float useless because the recovery
port allows the tank to keep venting.
Note: It is illegal and unsafe for a tank to be equipped with both an automatic shut-off valve
AND a ball float valve. Having both of these devices is NOT allowed. A ball float valve will
interfere with the operation of the automatic shut-off valve if it activates before the shut-off
valve closes.
7.2 Electronic Overfill Alarms
Electronic overfill alarms are the most versatile of the overfill prevention technologies. They
can be used with tanks that have tight or loose-fill connections and receive either gravity or
pumped (pressurized) deliveries.
Most overfill alarms are tied to an automatic tank gauging (ATG) system
by means of probes/sensors. One such probe is located inside the tank
and has a float that rises as the tank is filled. Typically, an alarm is
triggered when the tank is 90% full. The alarm can be seen or heard or
both. An overfill alarm should be located outdoors near the fill area and
be clearly labeled so the driver knows when the tank has reached its
working capacity. When the alarm sounds, the valve at the truck must
immediately be closed and the contents of the delivery hose drained into
the tank.
When an overfill alarm activates often, DO NOT ignore it. A frequent
overfill alarm may mean there is something wrong with the delivery
procedure or your tank. The working capacity of the tank may be less than
you think it is. Call your service provider to verify the overfill alarm settings are correct and
match the working capacity of your tank.
Many overfill alarms are equipped with a test button. The alarm must be tested monthly to
ensure the audible and visual alert mechanism is operating properly.
Figure 7.5: Electronic overfill alarm
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The most common issues with electronic overfill alarms are:
Automatic tank gauging systems must be programmed for the correct tank and tank chart to
ensure the correct working capacity is used.
The system power must be on.
If the power to the overfill alarm or the ATG is turned off the delivery driver will not be
aware of an overfill. If the alarm is equipped with a test button, the delivery driver
should test the alarm prior to delivering product to the tank.
Many sites have several tanks and one alarm.
Once the alarm is activated, it will remain on while delivering to any additional tanks.
The driver may then have no way of knowing when the next tank has reached its
working capacity
Inventory monitoring 6
NYCRR 613-2.3(c)(1)
If your tanks store
motor fuel or
kerosene, and if
any amount of that
product will be sold
as part of a
commercial
transaction, you
must track your
tank’s inventory to
determine whether
your tank is leaking
Inventory
reconciliation must
be done every 10
days.
The reliability of
inventory
information is only
as good as the care
you take in your
measurements and
calculations.
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CHAPTER
8
A/B
Tank IQ
Inventory Monitoring 8.0
Inventory monitoring helps you track how much product is going into your tank
and how much is coming out. Tracking gallons “in” and gallons “out” versus how
much is in the tank will help you detect missing product and possible leaks.
If your tanks store motor fuel or kerosene, and if any amount of that product will
be sold as part of a commercial transaction, then you must perform 10-day
inventory reconciliation. You must ALSO meet the leak detection requirements
outlined in Chapters 9.0 and 10.0. If you have tanks that store other types of
product, or product that is only used onsite, you may use 10-day inventory
reconciliation as an extra leak detection measure.
Ten-day inventory reconciliation includes five important steps:
1. Take daily measurements of the product in the tank. This measurement is
usually called the “stick reading” even if you use an electronic gauge instead
of a stick. Also measure the total gallons of product dispensed from the tank
(totalizer readings) and gallons of product delivered to the tank.
2. Calculate the daily difference (“variance”) between the product level
calculated from your totalizer and delivery receipts, and the product level
you actually measure.
3. Calculate the sum of daily variances at least every 10 days.
4. Compare the sum of daily difference to allowable variances at least every 10
days.
5. React to variances and investigate possible leaks.
Inventory monitoring tracks all the changes to the amount of product in your
system, from delivery to dispensing. It allows you to identify leaks from many
different components of your UST system.
The reliability of inventory information is only as good as the care you take in
your measurements and calculations.
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Chapter 8: Inventory Control
8.1 Daily Inventory Monitoring – What To Do Each Day
Each operating day you must record the volume/amount of:
petroleum delivered;
petroleum dispensed;
petroleum remaining in tank; and
water (if any) in tank.
Take separate inventory measurements for each UST at your facility. Collect the tank level
readings and the daily sales data at the same time. These steps will ensure that no sales or
deliveries are missed. You only have to record these measurements on days you receive or
dispense product. At facilities where the site does not dispense or receive product for a day or
more during a given 10-day period, you should stick the tank at the end of the last operating day
before the shut-down period and at the beginning of the first day afterwards. Each intervening
day should be crossed out on the reconciliation spreadsheet (not filled out with zeroes, which
might be interpreted as measurements).
Measuring the Product Level with an Electronic Monitoring System
An automatic tank gauging (ATG) electronic monitoring system is designed to tell you what’s
going on in your tank system. Along with monitoring your tanks for leaks, the system may tell
you the product level, volume, and temperature; water
level and volume; and high and low level product
warnings. A typical monitoring console is shown in Figure
8.1.
Your ATG monitoring system must be able to measure
both product and water level in your tank. It must be
accurate within 1/8” to be used for inventory monitoring.
Make sure your ATG system has been calibrated for the
tank at your site and has been programmed using your
specific tank’s tank chart. A good way to check to see if
your ATG has been programmed correctly is to take the
product height on your inventory report and find the
volume of product (in gallons) using your tank chart. The
volume you find from your tank chart should match the
volume on your inventory report.
Figure 8.1: ATG system console (example of one
make/model)
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Some systems can be programmed to automatically perform 10-day inventory reconciliation,
but this requires the system to interface with the dispenser. You can check with your service
technician to see if your system can do automatic reconciliation.
Measuring the Product Level Using a Gauging Stick
You can manually measure the product level in your UST using a
gauging stick. Gauging sticks are long wooden sticks with height
measurements marked on them. For accurate measurements and to
meet the requirements in the regulations your gauging stick must
be:
straight
unbroken
without wear or damage on the bottom
marked in 1/8” increments
marked with legible numbers.
To take a product level reading, lower the stick gently to the
bottom of the tank. Be sure to keep the stick vertical and try not to
touch the sides of the riser. Do NOT bounce the stick on the tank
bottom. Remove the stick from the tank and locate the line where the stick is wet. Record the
number in inches to the nearest 1/8”. Figure 8.2 shows proper technique for using a tank
gauging stick.
Sites where tanks are not stuck to the nearest 1/8” can expect to have
significant inventory variances, and the results will not meet regulatory
requirements.
Gauging sticks must be clearly legible and in good condition. Do NOT use a
gauging stick that is broken or rounded on the end. Your tank gauging stick
may have a Teflon “button” at the bottom. If the button is missing your stick
is not the correct length.
Using a stick that is not in good condition will cause serious problems with
your inventory records. Figure 8.3 and Figure 8.4 show tank gauging sticks
that should NOT be used for inventory monitoring.
Figure 8.3: Tank gauging
stick with broken end (EPA)
Figure 8.2: Measuring tank level with gauging
stick
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Make sure your
gauging stick is
not rounded or
broken at the
end.
Figure 8.4: SAMPLE tank chart. Each tank will have its own chart. You must use the correct chart for your
tank.
Use a tank chart to convert the depth measurement into gallons. Make sure you have the
correct tank chart for your tank. Tank charts are available through your tank manufacturer. If
your tanks are not all the same size, be sure that you are using the correct tank chart for each
tank. Your tank chart must include measurements in 1/8” increments. Record the number of
gallons in your inventory reconciliation report.
Figure 8.5: Rounded tank gauging stick (EPA)
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Chapter 8: Inventory Control
Make sure the
water finding
paste you are
using is
compatible with
your product
Daily tank inventory levels must be recorded on your 10-day inventory reconciliation worksheet.
Figure 8.6 highlights the column where you should enter your tank level at the beginning of the
day (“Start stick inventory”). A sample 10-day inventory reconciliation worksheet and
instructions is available in Appendix B.
Measuring Water in the Tank
The best way to manually measure water in your tank is by using water-finding paste (also
known as water paste) on your gauging stick. Most gasoline today contains ethanol, so be sure
to use a paste that is compatible with ethanol-blend gasoline. If you have a
different product at your site make sure you use a water finding paste that is
compatible with your product. Follow the paste manufacturer’s instructions,
paying particular attention to how long the paste needs to stay in the tank and
to what color the paste will change (Figure 8.7).
Record the height of water, to the nearest 1/8”, on your inventory
reconciliation report.
Electronic monitoring systems may have a water sensor to detect water in
tanks. Confirm that the water sensor is installed and working properly before
you rely on your ATG to detect water in your tanks. Be sure to confirm that the
water sensor is compatible with the product you are storing.
Figure 8.6: Excerpt from DEC 10-day inventory reconciliation worksheet
Figure 8.7: Tank gauging stick with
water-finding paste. This brand
turns red to indicated water level
in the tank . Other brands of paste
may use different colors.
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Figure 8.8: Excerpt from DEC 10-day inventory reconciliation worksheet
The number of
gallons
dispensed must
be metered
and recorded
within an
accuracy of 6
cubic inches for
every 5 gallons
of product
withdrawn
Daily water levels should be recorded on your 10-day inventory reconciliation worksheet. Figure
8.8 highlights the column in which to record this information.
Measuring Dispensed Product
The gallons of product pumped can be read on the totalizer meters located on your dispensers.
Totalizers look and work a lot like an automobile odometer. They record the total gallons of
product that flow through your dispenser. Subtract the previous totalizer reading from the
current totalizer reading to get the number of gallons pumped since the last reading.
Volume of dispensed product should be recorded on your 10-day inventory reconciliation
worksheet. This is NOT equal to the totalizer reading; this is the difference between the current
totalizer reading and the previous totalizer reading. Figure 8.9 highlights the column in which to
record this information.
Figure 8.9: Excerpt from DEC 10-day inventory reconciliation worksheet
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Chapter 8: Inventory Control
Use the gross
volume as the
number of
gallons
delivered for
inventory
monitoring
calculations.
The net
volume is
corrected for
temperature
and should
NOT be used
for inventory
monitoring.
You may also be able to find the number of gallons of each grade of product pumped from the
sales volume in your point of sale system, console or product management system.
Whether you find the number of gallons pumped from your totalizer or from your point of sale
system your meters need to be properly calibrated. The number of gallons dispensed must be
metered and recorded within an accuracy of 6 cubic inches for every 5 gallons of product
withdrawn.
Recording the Amount of Product Delivered
You can find the amount of product delivered by looking at your bill or delivery receipt. The
delivery receipt should indicate both a net and a gross delivery volume. Use the gross volume
as the number of gallons delivered for inventory monitoring calculations. The net volume is
corrected for temperature and should not be used for inventory monitoring. For accurate
delivery volumes, product must be delivered in a drop tube that extends within 1 foot of the
tank
bottom.
Volume of product delivered should be recorded on your 10-day inventory reconciliation
worksheet, Figure 8.10 highlights the column in which to record this information
Completing the Math
To complete the required calculations, see the instructions for the Sample Inventory Report in
Figure 8.11 (blank form is provided in Appendix B). You can make your job much easier and
reduce math errors by creating a spreadsheet on your computer to complete the calculations
for you. Some electronic monitoring systems may be even be programmed to perform these
calculations automatically.
Figure 8.10: Excerpt from DEC 10-day inventory reconciliation worksheet
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Chapter 8: Inventory Control
Be sure that
you are using
the correct
blend ratio if
your
dispensers
blend fuels.
Check your
total variance
after
completing
your 10-day
inventory
reconciliation.
Your variance
may indicate a
leak.
Your daily variance will rarely, if ever, be zero because the measurements you are taking are not
exact. HOWEVER, your daily variance shouldn’t be too large. If you have a large daily variance
and it is not a math error, PAY ATTENTION - your facility may have a leak.
If your total variance is larger than your allowable variance and can’t be explained within 48
hours by a math error, or some other reason that isn’t related to leakage, then you must notify
DEC.
What To Do If You Have A Blended Mid-Grade Product
Some dispensers blend low- and high-grade product to make a mid-grade product. You must
record sales of these products correctly on your daily inventory. You can use the blend ratio to
determine how much of each product is dispensed for each gallon of mid-grade product. For
example, a site that combines 87 octane and 93 octane to dispense 89 octane would have a
blend ratio of 60% (87 octane) product and 40% of 93 octane. In other words, for every 100
gallons of mid-grade sold, there are 60 gallons of 87 octane and 40 gallons of 93 octane. Be sure
you are using the correct blend ratio for your site based on the octane ratings of each product.
Using the wrong blend ratio can give incorrect inventory results.
What To Do If You Have Siphoned/Manifolded Tanks
Some facilities have tanks with a siphon between the tanks, or have tanks that with manifolded
fill pipes (see Chapter 3 for more information). The stick readings for each tank should be taken
at the same time, but recorded separately. Often, the stick readings will be within an inch or
two of each other. If your tanks have different sizes, be sure to use the correct stick reading for
each tank or it could affect your inventory results. When two tanks are siphoned or manifolded
together, the inventory, sales and deliveries will be combined.
8.2 What To Do At Least Every 10 Days
Check the Total vs. the Allowable Variance
At the end of each 10-day inventory reconciliation period you must compare your total gallons
delivered, total gallons pumped, and total tank volume to see which of these values is the
largest. The allowable variance is 0.75% of the largest of those three values. Your total
variance must be less than the allowable variance; otherwise, you will have to explain the
exceedence. See the Sample Inventory Report for detailed instructions on how to determine
your total variance.
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Chapter 8: Inventory Control
Water in your
tank may be an
indication of a
leak.
Be sure to use
the correct
blend ratio
when
determining
inventory for
your blended
fuels
Sample Inventory Report
The red numbers in the list below reference the red numbers in Figure 8.11
1. Start Stick Inventory: This is the actual amount of product (End Stick Inventory) from the
previous day, measured by your electronic monitoring system or by a gauging stick. On Day
1, this number is the End Stick Inventory from Day 10 of the previous ten days.
2. Gallons Delivered: Record the total volume delivered for each day that product is delivered
to the tank.
3. Gallons Pumped: Record net totalizer readings or look them up on your point-of-sale
system. No product should be pumped between making End Stick Inventory readings and
Gallons Pumped readings.
4. Book Inventory: Add “Gallons Delivered” to “Start Stick Inventory”, then subtract “Gallons
Pumped”. (Start Stick Inventory + Gallons Delivered – Gallons Pumped).
5. End Stick Inventory: Record the actual amount of product present at closing time as
measured by your ATG or gauging stick.
6. Daily Over/Short: Subtract your Book Inventory from your measured End Stick Delivery.
(End Stick Inventory – Book Inventory).
7. Water: Record the depth of any water at the bottom of the tank. It must be recorded each
day even if it is zero.
8. Total Gallons Delivered: Add up all the deliveries in the “Gallons Delivered” column.
9. Total Gallons Pumped: Add up all the product pumped in the “Gallons Pumped” column.
10. Total Tank Volume: The total volume of your tank. This should be listed on your tank chart.
The actual volume will likely be a little more or less than the volume on the chart.
11. Total Gallons Over/Short (Total Variance): Sum the daily over/short values. Be sure you
add “over” amounts and subtract “short” amounts. If the amount is negative, do not enter
the minus sign. You will use only the absolute value (ignoring the sign) of this number in
step 14.
12. Compare your Total Gallons Delivered, Total Gallons Pumped and Total Tank Volume.
Choose the largest number.
13. Multiply the largest number from Step 12 by 0.0075. This is your Allowable Variance.
14. Compare the Allowable Variance to the Total Gallons Over/Short. If the Total Gallons
Over/Short is larger than the Allowable Variance then you must investigate the possible
leak. If the Total Variance is greater than the Allowable Variance AND cannot be explained,
or if there is recurring water in your tank, you must notify DEC.
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DO NOT
IGNORE
VARIANCES!
11
14
13
7
9 10
12
2
8
3 4 5
6
1
Figure 8.11: Sample 10-day inventory reconciliation worksheet
11
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Check for
math errors
that may have
occurred if you
have a high
inventory
variance
Check for Recurring Accumulation of Water
If your water levels are increasing you may have a leak. Small amounts of water can enter your
tank during deliveries or tank maintenance but if you have a steady increase in the amount of
water in your tank you need to investigate for a possible leak.
Troubleshooting Variance Measurements
If you are calculating high variance amounts, you may be inaccurately measuring or completing
the calculations. Try the following troubleshooting suggestions:
Check the tank chart: Are you using the correct tank chart for your tank? Are you mis-
reading the tank chart?
Tank gauging stick: Your tank gauging stick must accurately measure product height to
the nearest 1/8”. In addition, the numbers on your stick should be legible and the stick
should not be broken or rounded at the end. The Teflon “button” at the bottom of the
stick should be intact.
Stick reading recorded to nearest 1/8”: Are you recording your tank readings to the
nearest 1/8”?
Siphoned/manifolded tanks: Make sure your siphoned or manifolded tank inventories
are recorded correctly. If a siphoned system has two different tank sizes, be sure that
the correct stick reading is used for each tank.
Tank gauge calibration: If you are using an electronic monitoring system, you need to
check to make sure your tank gauges are calibrated correctly.
Dispenser meters (totalizers): Check that your dispenser totalizers are calibrated and
are working correctly.
Math errors: Check for math errors. If you are using a spreadsheet, check the formulas
in your cells to make sure they haven’t been accidentally changed.
Proper totalizers are used for each product: If your pumps dispense multiple products
make sure you are reading the gallons dispensed off the proper totalizer.
Confirm blend ratios: Confirm the amount of high-grade and low-grade product you are
blending to create your blended mid-grade gasoline.
Confirm electronic monitoring system matches tank chart: Electronic monitoring
systems should be calibrated according to your tank chart. Be sure the correct tank
chart was used and that your electronic monitoring system was calibrated correctly.
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Temperature variations: Product can expand and contract in different temperatures. If
you have a 10-day period where the air temperatures have varied greatly, it may be
affecting your variance measurements.
Tank tilt: If possible, determine whether the tank is tilted. A tank measurement on a
tilted tank could create a variance.
Multiple tanks: Confirm that the correct stick readings and tank charts are used for each
tank.
Compare product variances to determine if a loss in one product is resulting in a gain
of product in a different product. This could indicate that: the wrong sales data was
used, a cross drop may have occurred, or the product blending ratio is not correct.
Cross Drops: The delivery driver may deliver product to the wrong tank. It is important
to take stick reading before and after each delivery. This will confirm that the correct
amount of product was delivered to the correct tank. If the driver overfills a tank, it is
possible for the product to travel through a vent manifold to a different tank. The
delivery driver should stop delivery when the overfill prevention method is triggered.
If your variance is too high but the discrepancy can be explained, you must add your explanation
to the inventory reconciliation worksheet. There is a space at the bottom of the worksheet for
you to record your explanation.
Discrepancies that may be explained include:
Inaccurate recordkeeping
Temperature variations
Other factors not related to leakage
Taking the tank out-of-service
The inventory at your site should be consistent.
If your site has major variances, investigate the cause.
Do not expect a bounce back correction to occur.
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Any suspected
leaks must be
reported.
Suspected
leaks must be
reported
within 48
hours
All inventory
records must
be kept for 3
years.
8.3 Leak Reporting
You must report any leaks or suspected leaks to DEC. If you have any unexplained discrepancies
in your inventory report, this is considered a possible/suspected leak and must be reported. You
must notify DEC within 48 hours if the discrepancies cannot be explained.
Report evidence of a possible leak to the DEC spill hotline:
1-800-457-7362
(or 1-518-457-7362 outside New York state)
Leak Investigation and Confirmation Steps
All leaks must be investigated by one of the following methods:
System (tightness) test or
Site check
Investigations must start within 48 hours of reporting a suspected leak. The investigation must
be completed within 7 days of starting the investigation.
See Chapter 9 for more information on leak detection and confirmation steps.
8.4 Recordkeeping
Your 10-day inventory reconciliation worksheets must be kept for 3 years.
The following must also be maintained for 3 years:
results of any sampling, testing or monitoring;
written documentation for all calibration, maintenance and repair of leak detection
equipment; and
manufacturer’s schedules for calibration and maintenance of leak detection equipment
following installation.
8.5 Summary
Inventory monitoring tracks all the changes to the amount of fuel in your system, from
delivery to dispensing. It allows you to identify leaks from many different components
of your fuel system.
The reliability of inventory information is only as good as the care you take in your
measurements and calculations.
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Inventory reconciliation must be done every 10 days.
Your total variance must be less than the allowable variance. If it is greater than the
allowable variance, you have to be able to explain this discrepancy. If you can’t explain
it, call the DEC Spill Hotline.
Your electronic monitoring system must be able to measure both fuel and water level in
your tank. It must be accurate within 1/8” to be used for inventory monitoring. Make
sure your ATG has been calibrated for the tank at your site and has been programmed
using your specific tank’s tank chart.
For manual measurements, your gauging stick must be clearly legible and in good
condition. Sites that do not stick the tanks to the nearest 1/8” can expect to have
significant inventory variances, and the results will not meet regulatory requirements.
The best way to manually measure water in your tank is by using water-finding paste on
your gauging stick. Be sure to use a paste that is compatible with your product.
Whether you find the number of gallons pumped from your totalizer or from your point
of sale system your meters need to be properly calibrated. The number of gallons
dispensed must be metered and recorded to an accuracy of 6 cubic inches for every 5
gallons of product withdrawn.
The delivery receipt should indicate both a “net” and a “gross” delivery volume. Use
the gross volume as the number of gallons delivered for inventory monitoring
calculations. The net volume is corrected for temperature and should NOT be used for
inventory monitoring.
When two tanks are siphoned or manifolded together, the inventory, sales and
deliveries will be combined.
Be sure your calculations use the correct blend ratio for blended products. Using the
wrong blend ratio can give incorrect inventory results.
If your variance is too high but the discrepancy can be explained, you must add your
explanation to your inventory report.
The inventory at your site should be consistent. If your site has major daily or ten-day
total variances, investigate the cause. Do not expect a bounce back correction to occur.
You must report any leaks or suspected leaks to DEC.
Your 10-day inventory reconciliation sheets and leak detection test/maintenance
documentation must be kept for 3 years.
Leak Detection
6 NYCRR 613-2.3
NEVER ignore
alarms.
Suspected leaks
must be reported
to DEC.
You must check
your tanks for
leaks and record
leak test results at
least once a week.
You must keep
your last 30 days
of leak detection
records onsite.
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9
A/B Tank Leak Detection 9.0
Each of your underground storage tanks must be monitored for leaks by at least
one method. The regulations allow for several different types of leak detection,
depending on the date your tank was installed (see Table 9.1). The leak detection
system for each tank must be listed on your facility registration application, and
can be found on your Facility Information Report (see Chapter 4). The piping must
have its own leak detection listed on system, as discussed in Chapter 10.0. It is
important to remember that the requirements for piping leak detection are
separate from the requirements for tank leak detection.
Tank leak detection systems must be able to detect a leak from any portion of the
tank that routinely contains petroleum. Any monitoring system used for leak
detection must be installed and calibrated in accordance with the manufacturer’s
instructions.
Any tank without a properly functioning leak detection system must be taken out-
of-service.
The registered method of leak detection can be found on your facility registration
(see Chapter 4). Although you are only required to have one method of leak
detection, you may register more than one method. For example, a facility could
be registered with interstitial monitoring as well as automatic tank gauging. If your
registration indicates more than one registered method of leak detection, EACH
method of leak detection MUST be monitored, maintained and documented.
The operator of any tank that contains any amount of motor fuel or kerosene that
will be sold as part of a commercial transaction must also
conduct inventory monitoring for that tank, as discussed in
Chapter 8.0.
Indications of a leak should not be ignored. If your leak
detection system indicates a potential leak, you must
immediately investigate the cause of the alarm and determine
if the system is leaking.
Suspected leaks must be reported to the DEC. The operator
must report a suspected leak within the required time frame
(see Section 9.6). Figure 9.1: Monitoring console in alarm
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Monitor the
interstitial
space and
address all
alarms in
order to
promptly
detect fuel
leaks into
environment,
should they
occur.
To determine what kind of leak detection method is permitted for your tanks, first see Table 9.1
below to identify the category of each tank. This chapter describes acceptable methods of leak
detection for each tank category.
Table 9.1 Tank Categories
Tank Category Installation Date
Category 1 Before December 27, 1986
Category 2 From 12/27/86 through October 11, 2015
Category 3 After October 11, 2015
9.1 Leak detection for Category 2 and 3 Tanks
Category 3 tanks MUST be double-walled. Category 2 tanks MUST be double-walled OR have
another permitted method of secondary containment. Category 2 and 3 double-walled tanks
MUST be monitored by interstitial monitoring. Alternative types of secondary containment for
Category 2 tanks MUST be monitored by an appropriate method.
Interstitial Monitoring
Double-walled tanks have an
interstitial space between the
primary (inner) tank wall and the
secondary (outer) tank wall. The
interstitial space can be equipped
with a sensor/indicator to detect
leaks in the primary or secondary
tank and may be either a dry or wet
type. Both types are normally
accessed through a manhole in the
tank pad. It is important to
understand which type of
interstitial space is in your tank.
A dry interstitial space is not
intended to contain any liquid and should be free of liquid at all times. The presence of liquid in
this space is an indication that the primary or secondary tank may be leaking. Usually, dry
interstitial spaces are monitored with a sensor that detects the presence of liquid (product or
Figure 9.2: Wet interstitial space
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water) in the interstitial space. Some dry interstitial spaces are monitored using a vacuum or
pressure system. Any change in the pressure or vacuum level of the interstitial space may
indicate a leak in the primary or secondary tank.
A wet interstitial space contains a liquid brine solution (salt water). The brine solution is
typically colored blue for easier detection. The interstitial space is connected to a reservoir
where the brine level is monitored for any gains or losses. If the brine liquid level rises or falls
by more than the amount specified by the manufacturer (typically a few inches) then either the
primary or secondary tank may be leaking.
The interstitial monitoring may be done either electronically or manually. Electronic monitoring
is done through an electronic monitoring console, while manual monitoring can be done using a
dipstick or a pop-up indicator. Manual results of interstitial monitoring results must be recorded
at least weekly. Where electronic monitoring methods are used, these systems must be
inspected to ensure operability at least monthly. If the monitoring system goes into alarm, your
tank may be leaking.
Secondary Barrier Monitoring
Secondary barrier monitoring is not
a permitted monitoring method for
new tanks, but you may have this
system if you have older Category 2
tanks. Usually these tanks are
single-walled tanks installed in a pit
that is lined on all sides and bottom
with a heavy plastic liner (i.e., the
secondary barrier) and then filled
with soil and/or gravel. The
secondary barrier is sealed to the
concrete tank pad to create an
impermeable (liquid-tight) “tub”
around the tank. A monitoring well
is used to monitor the space between the tank and the barrier.
Use of a secondary barrier is subject to a couple of requirements. The secondary barrier can
only be used for tanks located above the 25-year floodplain. In addition, the barrier must be
compatible with the product stored. For example, the product cannot cause the liner to rot or
dissolve. The barrier must also not interfere with the cathodic protection system.
Figure 9.3: Tank system with a secondary barrier (shown in green)
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Interstitial
monitoring is
the preferred
method of
leak detection
for Category 1
double-walled
tanks.
After the tank is installed, you will not be able to tell if your system has a secondary barrier by
looking at the tank pad. Check your tank installation report or tank registration to see if you
have a secondary barrier at your site.
Your must monitor your wells at least weekly, and document your monitoring results. If you
find product in your wells, it means that a tank may be leaking.
9.2 Leak Detection for Category 1 Tanks
There are several different acceptable methods of leak detection for Category 1 tanks.
Interstitial monitoring
Automatic tank gauging
Manual tank gauging
Groundwater monitoring
Vapor monitoring
Statistical inventory reconciliation
Other approved methods
Interstitial Monitoring
Interstitial monitoring detects leaks between the inner and outer walls of double-walled tanks,
and is the preferred method of leak detection for double-walled Category 1 tanks. See Section
9.1 for a more detailed discussion.
Figure 9.4: Tanks being installed with a
secondary barrier
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Automatic Tank Gauging (ATG)
Automatic tank gauging (ATG) systems can
be programmed to conduct periodic tests of
your tank system. During each test, the ATG
probe will measure the product level and the
temperature over a period of time. Your
ATG probe must be capable of detecting a
0.2 gallon per hour (gph) leak rate with a
95% probability of detecting a leak. It must
also have no more than a 5% probability of a
false alarm. As an operator, you must
determine if the equipment used to conduct
a test meets the leak rate requirement.
You can determine if your ATG meets the
requirements by checking whether it is listed
by the National Work Group on Leak
Detection Evaluations (NWGLDE). NWGLDE
listed systems meet the requirements. A link to the NWGLDE website is
provided in Chapter 20.0. You can also have your tank contractor check
whether your system meets the leak threshold requirements.
Special considerations may apply to manifolded systems. For instance, if
your tanks are connected by a siphon system, then your ATG system must
be programmed to treat the siphoned tanks as a single, large tank.
There are two types of ATG leak detection tests: static or continuous.
Static Tests are conducted over a period of time (about 2 hours) during
which the station does not dispense fuel or receive a delivery. The ATG is
usually programmed to test the tank overnight while the facility is closed.
Be sure the time of day is set correctly on the ATG so that the test does
not occur during the day or when the system is in operation.
Continuous In-Tank Leak Detection System (CITLDS) Tests are conducted while the facility is
operating. This type of test conducts product level and temperature measurements throughout
the day whenever the system is idle. If you have a CITLDS system, typically the system is
programmed to report a pass/fail test result at the end/beginning of each day. This type of test
is also known as a Continuous Statistical Leak Detection (CSLD) test.
Figure 9.6: Example of an electronic
monitoring console
Figure 9.5: Typical ATG schematic
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For either type of test, the tank must contain a minimum volume of product. The minimum
volume depends on your tank and on the type of ATG you have. You must be sure that the tank
is sufficiently full that the test will be able to check all parts of the tank that routinely contain
product. You or your service technician must verify that these requirements are met.
In addition, you must have a passing test each week (for either method). You can use the form
in Appendix D to record the results of the test.
Become familiar with the ATG at your facility. Know what type of test the ATG performs and
when the tests are scheduled. You should also learn how to conduct an additional test at any
time.
Your ATG console should be accessible AT ALL TIMES. You need to be able to see or hear
alarms. You also need to be able to record test reports, usually by printing them out or writing
them down. Keep the area around your console clear.
Figure 9.7: ATG console that is not
accessible
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Figure 9.8: ATG console with an overfill
alarm. The print out will indicate which
alarms are current and need to be addressed
Your ATG system is designed to go “into
alarm” if your system has a leak. A red
light will typically light up on your console
if the system is “in alarm.” Alarms can be
triggered by tank sensors, sump sensors,
product level probe or interstitial
monitoring sensors. If an alarm is
triggered be sure to investigate!
Never ignore any alarms. Figure 9.8
shows an ATG console in alarm. The
alarm light is on and an alarm message is
scrolling on the screen. A print out from
the console details the alarm that is
activated.
Manual Tank Gauging
Manual tank gauging (MTG) is based on measuring product levels with a gauging stick. The test
can take from 36 to 58 hours, depending on the size of the tank. The tank cannot dispense or
receive product during the test. Note: While this method seems
similar to the process for inventory monitoring, it is NOT THE SAME;
the only similarity between the two is that both use gauge sticks.
Manual tank gauging is a leak detection method; inventory
monitoring is not.
This method can ONLY be used for:
Tanks less than 550 gallons; or
Tanks 550-1,000 gallons with a diameter of 64 inches or 48
inches.
You will need:
A tank gauging stick. The stick must be legible, in good
condition, and accurate to 1/8”; and
A tank chart that shows the volume of your tank vs. height
of product. The chart must be accurate to 1/8”.
To manually gauge a tank you must measure the product level in the
tank and then leave the tank undisturbed for a certain length of time
(see Table 9.2). At the end of the test period you must measure the Figure 9.9: Measuring the amount of product
in the tank
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in
Record all data
from a manual
tank gauging
test
Record all data
from a manual
tank gauging
test
product level again and calculate the difference in tank volume. Manual tank gauging must be
conducted weekly. The sample form in Appendix C shows an acceptable method to document
the test.
To conduct a test:
1. Measure and record the product height in the tank to the nearest 1/8”.
2. Immediately re-measure and record the height of product in the tank to the nearest
1/8”.
3. Using the tank chart, calculate the volume of product in the tank for both initial
measurements.
4. Calculate the average of the two volume measurements. This is your Average Initial
Volume.
5. Record the date and time of the initial tank readings.
6. Wait for the minimum test period based on the tank volume (see Table 9.2). During the
test period no product may be added or removed from the tank.
7. At the end of the test period measure and again record the product height to the
nearest 1/8”.
8. Immediately re-measure and record the height of product in the tank to the nearest
1/8th of an inch
9. Using the tank chart, calculate the volume of product in the tank for both
measurements.
10. Calculate the average of the two volume measurements. This is your Average Final
Volume.
11. Record the date and time of the final tank readings.
12. Subtract the smaller of the average volumes (Initial or Final) from the larger average
volume. This is the weekly standard volume variance allowed. Compare the loss or gain
in volume to the Allowable Weekly Standard Volume Variance in Table 9.2.
13. Each month, average the 4 weekly standard volume variances and compare the average
to the “Allowable Monthly Standard Volume Variance” in Table 9.2.
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Groundwater
monitoring is
NOT
recommended
as a primary
leak detection
method.
Table 9.2: Manual Tank Gauging
Design Capacity of Tank Minimum
Duration of test
Allowable Weekly
Standard Volume
Variance
(one test)
Allowable Monthly
Standard Volume
Variance
(Four-test average)
550 gallons or less 36 hours 10 gallons 5 gallons
551-1,000 gallons (when
tank diameter is 64”) 44 hours 9 gallons 4 gallons
551-1000 gallons (when
tank diameter is 48”) 58 hours 12 gallons 6 gallons
If the difference between the average initial volume and the average final volume
exceeds the allowable weekly or monthly variance, the tank may be leaking.
Groundwater Monitoring
Groundwater monitoring is done by testing water in wells located close to your tank for possible
petroleum contamination. Groundwater monitoring relies on discovering product in the
groundwater AFTER the tank has leaked into the environment.
This method of leak detection is not commonly used and is not recommended.
Wells may only be installed in areas where groundwater is always within 20 feet of the ground
surface. The groundwater monitoring wells are monitored at least weekly, either electronically
or manually, and the monitoring system must be able to detect the presence of 1/8” of product
Figure 9.10: Groundwater monitoring system
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Vapor
monitoring is
NOT
recommended
as a primary
leak detection
method.
on top of the ground water. The monitoring wells must be
clearly marked, as shown in Figure 9.11. Wells must also be
secured to avoid unauthorized access and tampering.
If you find product in your wells, the tank may be leaking
product into the groundwater at your facility.
Vapor Monitoring
Vapor monitoring tests the vapor in the soil through monitoring wells around your tank for any
significant increase in concentration of product or tracers. Vapor monitoring relies on
discovering product in the soil AFTER the tank has leaked into the environment.
This method of leak detection is not commonly used and is not recommended.
This method only works if the product is volatile enough to generate a detectable vapor
level, or if a volatile tracer chemical is added to the product. Monitoring wells or vapor
probes are placed in the soil around the tank to monitor the soil vapor for product. The
vapor monitoring system must be operable even in the presence of rain, groundwater or
moisture in the soil for more than seven days. Background vapors must not interfere
with the detection of leaks from the tank. The soil around the tank must consist of
gravels, coarse to medium sands, course silt or other permeable materials; otherwise,
vapors may not travel freely through the soil. The monitoring wells must be clearly
marked and secured to avoid unauthorized access and tampering.
Statistical Inventory Reconciliation
Statistical inventory reconciliation (SIR) analyzes inventory data to detect leaks. The analysis
must be conducted by a third-party and must be capable of detecting a leak of 0.2 gallons per
hour with a 95% probability of detection and a 5% chance of a false alarm. The third-party
report must include a quantitative result and a calculated leak rate.
The third-party will provide the operator with a report indicating the leak rate. The operator
must review the information provided by the third-party to determine if the leak rate exceeds
the acceptable leak rate of 0.2 gallons per hour.
Figure 9.11: Groundwater
monitoring well
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Maintain all
leak detection
equipment to
prevent spills.
A leak must be reported within 48 hours of determining the results of the statistical inventory
analysis unless the results can be explained by factors that are not related to leakage, e.g.
mistakes in recordkeeping.
Other Acceptable Methods of Leak Detection
DEC may approve an alternate leak detection method, if the method is capable of detecting a
leak rate of 0.2 gallons per hour or a leak of 150 gallons within a month. The method must have
a 95% probability of leak detection with a 5% probability of false alarm. The operator must be
able to demonstrate that the method of leak detection meets these requirements and is as
effective as the methods allowed in the regulation.
9.3 Maintenance and Operation of Leak Detection Equipment
The A, B and C operators at the facility must be familiar with their leak detection system and
take appropriate actions when the system is in alarm. The system should be accessible to
operators at all times and not locked in an office or storeroom. The operators should know
immediately when the alarm goes on. In addition:
All leak detection equipment must be installed, calibrated and maintained in accordance
with the manufacturer’s recommendations.
Leak detection equipment must remain on and powered at all times. Do not disconnect
the power to the system to silence an alarm.
At least once a month the operator should inspect the system to record the system
status, document test results and verify that the system is operating correctly. The form
in Appendix D is one acceptable way to record inspections.
Any necessary repairs to the system should be conducted immediately.
Have a reliable tank service contractor on call to help you as needed.
You should be familiar with the operation of your leak detection system. Many
manufactures provide quick reference guides. Have the guide or a user’s manual on
hand and available. You can also ask your service contractor for training on the system.
You must be familiar with each alarm in order to respond properly. Be sure you know
the difference between a leak alarm and a low product alarm.
9.4 Recordkeeping
Facilities must meet the following recordkeeping requirements:
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You must keep the last 30 days of leak monitoring results at the facility at all times
All leak detection records must be available for at least three years
Records of any maintenance, repairs alarms, calibration or investigations must be
available for 3 years.
Refer to Chapter 15 for additional recordkeeping information
Note: Many ATG system use thermal printer paper to print test results and sensor status. This
paper can fade over time and the necessary records may not be available. Along with keeping a
scanned or electronic copy of the ATG print-out, consider keeping a written log with leak
detection results.
9.5 Tank Tightness Testing
Tank tightness testing CANNOT be registered as a method of leak detection for tanks discussed
in this guide; however, it CAN be used to determine if a tank system may be leaking. The test
must be able to detect a leak at a rate of 0.1 gallons per hour from any portion of the tank that
routinely contains petroleum.
There are several different types of tank tightness tests. A test is only valid if it is performed by
a person who has been trained and certified by the
manufacturer of the test method.
To have your tank tested for leaks, hire a third-party tank
testing company. The technician must be certified to
perform the tank testing method used. The tank testing
company will bring all required equipment to complete the
type of tank test performed.
You must keep a copy of the test results with your tank
records until the tank system is tested again.
Figure 9.12: Technician performing a tank test
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Chapter 9: Tank Leak Detection
NEVER ignore
leak detection
alarms
9.7 Leak Reporting
Leaks or suspected leaks must be reported to DEC within 2 HOURS.
THE DEC SPILL HOTLINE NUMBER IS 1-800-457-7362
(518-457-7362 outside New York State)
The following are examples of conditions that require reporting within 2 hours:
Petroleum found outside of the tank system (spills) such as free product or vapors in
soil, basements, utility lines, sewers or nearby surface water.
Unusual operating conditions: (unless equipment is found to be defective and is
IMMEDIATELY repaired or replaced)
o Erratic behavior of dispensing equipment
o Sudden loss of product from the tank system
o Unexplained presence of water in the tank
o Liquid (water/petroleum) in the dry interstitial space of the tank or any
secondarily contained system
o Liquid (water/petroleum) in a tank top or piping transition sump.
o Loss or gain of fluid in wet interstitial space
o Leak alarms
o Failed ATG test
o Failed tank tightness test
o Suction dispenser loses suction
In addition, you must report within 48 hours:
any result from statistical inventory reconciliation analysis that indicates a suspected
leak.
9.8 Leak Investigation and Confirmation
You must take certain steps to investigate possible leaks and to clean up confirmed leaks. See
Chapter 14 for more information.
9.9 Summary
Each of your underground storage tanks must be equipped with AT LEAST ONE leak
detection system. Category 3 tanks and Category 2 double-walled tanks must have
interstitial monitoring. Other methods may be allowed, depending on your tank
category.
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Chapter 9: Tank Leak Detection
NEVER ignore
leak detection
alarms
Tank leak detection systems must be able to detect a leak from any portion of the tank
that routinely contains petroleum.
Indications of a leak should not be ignored. If your leak detection system indicates a
potential leak, you must immediately investigate the cause of the alarm and determine
if the system is leaking.
Suspected leaks must be reported to the DEC. The operator must report a suspected
leak within the required time frame.
All leak detection equipment must be installed, calibrated and maintained in accordance
with the manufacturer’s recommendations.
Any tank without a properly functioning leak detection system must be taken out-of-
service.
Leak detection equipment must remain on and powered at all times. Do not disconnect
the power to the system to silence an alarm.
You must keep the last 30 days of leak monitoring results at the facility at all times. All
leak detection records must be available for a minimum of 3 years.
Records of any maintenance, repairs alarms, calibration or investigations must be
available for a minimum of 3 years.
Piping Leak Detection
6 NYCRR 613-2.3(b)(2)
Monitor your piping
to prevent leaks
Pressurized and
suction piping
systems have
different leak
detection
requirements.
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CHAPTER
10
A/B Piping Leak Detection 10.0
Piping leaks can allow product to contaminate the soil and groundwater at your
site. Piping leak detection methods allow you to monitor your underground piping
so that you can detect and respond to possible leaks. Methods of piping leak
detection are discussed in this chapter.
Leak detection is required for all piping that routinely contains petroleum and is in
contact with the ground. Tank leak detection requirements and methods are
different than piping leak detection requirements. Tank leak detection is covered
in detail in Chapter 9.
Piping leak detection systems must be installed and calibrated according to the
manufacturer’s instructions. Piping without proper leak detection must be taken
out-of-service.
Never ignore any alarms from your piping monitoring system. Alarms indicate a
possible leak in your system and should be investigated right away.
Figure 10.2: Underground piping
connected to dispenser sumps
before being buried
Figure 10.1: Underground piping system connected to tank top
sumps before being buried
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Chapter 10: Piping Leak Detection
Make sure you
know what
type of piping
system you
have at your
site.
Check inside
your tank top
sump to
determine
which type of
piping system
you have.
10.1 Pressurized vs. Suction Piping Systems
Pressurized and suction piping systems have different leak detection requirements. The
information in Chapter 3 can help you determine which type of system you have.
Pressurized Piping System: Pressurized piping systems are the most common fuel pumping
method at retail motor-fuel operations. A pressurized system has a pump, usually called a
submersible turbine pump (STP), located in the tank. The STP will pump product from the tank
to your dispenser. If you have a pressurized system, you can see the submersible pump head
when you look into your tank top sump. Figure 10.3 shows a sump containing a submersible
pump head and product piping.
Submersible pumps operate under positive pressure. The high operating pressure means that
leaks in underground piping served by these pumps can go unnoticed. This happens because
the system acts like a garden hose with the faucet turned on full. Even if the hose has small
holes in it, most of the water still comes out the nozzle. If you only look at the nozzle, you can’t
tell that water is also leaking out of the small holes. But if you leave the faucet open for a long
time, water spraying from the small holes will eventually soak the ground. In much the same
way, you can’t tell that there are small leaks in pressurized underground piping just by looking at
how fast product is dispensed. Over time, however, those small leaks of product can
contaminate soil and groundwater at your site. Leaks from pressurized piping systems account
for a large number of underground product releases.
Suction Piping System: A suction piping system has a pump located inside the dispenser, instead
of in the tank. When you look into your tank top sump, you will find product piping but no
pump. The pump in the dispenser draws product from the tank by suction. Pumping fuel with a
suction system is similar to drinking water through a straw. A leak in the piping will cause the
Figure 10.4: Suction pump system Figure 10.3: Pressurized pumping system
STP head
No STP
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Chapter 10: Piping Leak Detection
Piping in
Category 3
tank system
piping or NEW
(i.e. replaced)
piping must
have
interstitial
monitoring
unless the
system meets
“safe suction”
criteria.
system to lose suction, just as it is difficult to drink through a straw with a hole in it. If product
leaks from the line or drains back to the tank, the suction pump has lost its prime. When the
suction dispenser loses its prime, the pump will hesitate after it is turned on. A suction pump
that will not pump or frequently loses its prime may have a line leak, a faulty check valve, or
both.
The type of leak detection that is required for your tanks depends on the tank category and on
whether you have pressurized or suction piping. You can use the information above, or check
with your service technician, to determine what type of piping system you have. Table 10.1 will
help you determine the category of your tanks. This chapter describes acceptable methods of
leak detection for each tank category and piping type.
Table 10.1 Tank Categories
Category Installation Date
Category 1 Tank installed before December 27, 1986
Category 2 Tank installed from 12/27/86 through October 11, 2015
Category 3 Tank installed after October 11, 2015
If you replace 50% or more of a single piping run, and the existing piping does not meet new
piping standards, then the entire run must be replaced. All piping installed after October 11,
2015 must meet new piping requirements.
10.2 Leak Detection: Category 3 Tank Systems and New Piping
Piping connected to a Category 3 tank system or new piping that is installed in a Category 1 or 2
tank system must meet the following requirements for leak detection.
Pressurized Piping Systems – Category 3 and New Piping
Pressurized piping connected to Category 3 tank systems, or new pressurized piping connected
to Category 1 or 2 tank systems, must have TWO types of leak detection:
an automatic line leak detector (mechanical or electronic); AND
weekly interstitial monitoring of the tank top sump (electronic or manual).
These leak detection methods are described below.
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Chapter 10: Piping Leak Detection
Automatic Line Leak Detector
Automatic line leak detectors (LLDs) can detect leaks in pressurized piping. Typically, LLDs are
installed on the submersible turbine pump (STP) head in the tank top sump.
There are two types of LLDs: mechanical and electronic.
Mechanical LLDs (MLLDs) are mechanically
operated pressure valves that detect a loss
in piping line pressure each time the pump
is turned off. Mechanical LLDs WILL NOT
completely shut off flow to the pipe if they
detect a leak. A MLLD will not trigger an
audible or visual alarm when a leak occurs.
The only way to tell that the MLLD has
been triggered is by noticing that the fuel is
now being dispensed at a very slow rate. If
your normal flow is around 7-10 gallons
per minute (gpm) a leak will be indicated
by flow restricted to about 3 gpm or less.
A MLLD device is threaded into the top of the submersible pump head and has no
wiring connections. The LLD may have a round or hexagonal top as shown in Figure 10.5 and
Figure 10.6. Newer models will also have copper lines attached.
If you experience a slow flow condition, the line leak detector may be indicating a leak in the
pipe. Investigate the system and do not ignore the signs of a leak.
Common problems with mechanical LLDs are listed below.
Slow flow may be caused by conditions other than leaks, such as plugged filters or
defective pump motors. Call your service technican immediately to investigate the cause
of low flow.
Cold temperatures overnight can cause a mechanical LLD to slow product flow first thing
in the morning. If slow flow persists after your first dispensing period, call your service
technican.
LLDs can wear out. Mechanical LLDs typically need to be replaced every few years.
Figure 10.5: Mechanical LLD
(Alaska DEC)
Figure 10.6: Mechanical LLD
(Alaska DEC)
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Chapter 10: Piping Leak Detection
Figure 10.9: Double-walled pipe
Electronic LLDs have an electronic detection element that connects to an
electronic control panel and monitors for releases by looking for pressure
losses in the piping. Unlike mechanical LLDs, electronic LLDs will completely
shut down the submersible pump if they detect a leak. The shutdown will
usually appear as an alarm on your ATG console or other monitoring device.
Typically, electronic LLDs check for leaks of three gallons per hour, although
some can also perform a 0.1 or 0.2 gallon per hour test.
An electronic LLD is threaded into the submersible pump head. It is
connected to the pump electrical system and is either hard wired or wirelessly
connected. Figure 10.7 shows an electronic LLD on a submersible pump.
Electronic LLDs are much more reliable indicators of leaks than mechanical
LLDs.
If your pressurized piping does not have an LLD, then you must install one.
Figure 10.8 is an example of submersible pump with no LLD. If your
submersible pump is not equipped with an LLD, you should contact your
service provider to discuss retrofit options.
Both mechanical and electronic LLDs must be designed to detect leaks of
three gallons per hour.
You should check your records or check with your service provider to verify
that your LLD meets the three gallons per hour requirement.
You are also required to test your LLD every year to ensure that it is operating
properly. Records from LLD tests must be kept for three years.
Interstitial Monitoring for Double-walled Piping
Interstitial monitoring is the second leak detection method required for
new pressurized piping systems.
Remember from Chapter 3 that double-walled piping is a primary pipe
encased inside a secondary pipe. Between the two walls is an interstitial
space. The secondary pipe is designed to keep any leaks from the
primary pipe contained inside the interstitial space. You must monitor
the interstitial space in your double-walled piping for leaks at least
weekly.
Figure 10.7: Electronic line leak
detector on a submersible pump
(EPA)
Figure 10.8: Submersible pump
with no LLD
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Chapter 10: Piping Leak Detection
Figure 10.11: Diagram of a double-walled piping system
Leaks into the piping interstitial space will drain to liquid-tight
sumps that are typically located where the piping connects to
the tank top (tank top sump). Sumps are typically made of
fiberglass or polyethylene plastic. Figure 10.10 shows a tank
top sump with product from a piping leak.
Figure 10.11 illustrates a typical double-walled piping system
layout. The piping slopes down from the dispenser to the
tank so that leaks from the primary pipe will drain down into
the tank top sump. Leaks from equipment within the tank
top sump will also be contained inside the sump. Leaks from
piping inside the dispenser cabinet will be contained in the
under-dispenser containment (UDC) sump.
Some systems may also include intermediate sumps, also
known as transition sumps. Intermediate sumps are typically installed to break up long
underground piping runs. Leaks from the primary pipe in these piping runs are contained in the
intermediate sump.
Double-walled piping can be monitored electronically or manually.
Figure 10.10: Tank top sump with product
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Chapter 10: Piping Leak Detection
Electronic Interstitial Monitoring is often used to
monitor piping systems for leaks. Many systems,
like the one shown in Figure 10.12, combine fuel
level monitoring by the automatic tank gauge (ATG)
with continuous leak detection monitoring by leak
sensors. Other systems may have a separate
console just for leak detection. This particular
system has sensors both in the tank top sump and
in the UDC (Figure 10.13). The sensors will trigger
an alarm at the console if liquid is detected in the
sump or UDC.
There are two different types of leak detection
sensors: discriminating and non-discriminating. Discriminating sensors can tell the difference
between water and product and provide a separate alarm for each liquid. Non-discriminating
sensors, which are more common, only tell you whether liquid is present. You will need to look
in the sump to determine if it is product or water. If visual
determination is difficult, you may find it helpful to test the
liquid with sorbent pads that absorb only oil.
Sensors must be installed in accordance with manufacturer’s
instructions, which typically state that sensors must be
installed vertically, with the bottom of the sensor within one
inch of the bottom of the sump. Sensors should be tested
each year to ensure they are in good working condition and
are operating correctly.
Become familiar with your monitoring console and
understand the alarm messages.
Tip: Keep a list of all the sensor locations with the sensor
identification number posted close to your ATG console or
release detection console. This will allow you or your service
technician to easily locate which part of your piping system is
causing the alarm.
Figure 10.13: Cut-away view of a UDC with a leak
sensor and plastic tubing connected to Schrader
valves. Note the correct (vertical) orientation of
the sensor.
Leak sensor
Figure 10.12: Electronic monitoring console in alarm
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Chapter 10: Piping Leak Detection
Never ignore
piping leak
detection
alarms on your
ATG console.
Common problems with electronic interstitial monitoring:
Water is present in the tank top sump. If you have frequent alarms due to water in
your tank top sump, talk to your service technician about options to fix the problem.
Sumps are not liquid tight. Leaks from your sumps can allow product to escape into the
environment before the sensors detect them. It is a recommended practice to test your
sumps periodically to make sure they are still liquid tight.
Schrader valves are closed. Schrader valves are similar to the valves used to fill tires.
They are typically installed where double-walled piping transitions to single walled
piping. Two Schrader valves, which may be connected with plastic tubing, close off the
interstitial space. These valves should ONLY be connected during tightness testing of
the double-walled pipe. They must be opened or removed during normal operation in
order for leaks to be detected.
If the Schrader valves are not opened or removed, leaks from the primary piping will be
trapped inside the interstitial space instead of flowing into the sump. This will prevent
your sump sensors from triggering the alarm when you have a leak. To keep your
system operating properly, you MUST open the Schrader valves and disconnect tubing
between the valves during normal operation. This will allow leaks to reach your sump
sensor and trigger your warning alarm.
If either your ATG console or leak detection console is in alarm take the following steps:
Visually inspect all sumps to determine if product is present.
Stop dispensing product until the alarm can be identified and corrected. Shut off power
to the submersible pump to prevent additional releases to the environment. Otherwise,
the submersible pump will pressurize the line each time a dispenser is used, potentially
causing additional product to be released into the environment.
Contact your service technician immediately to determine the cause of the alarm.
Have a tightness test performed on the piping.
Report any alarms or the presence of fuel or water in sumps within 2 hours to the DEC
(see Chapter 14 for more information about reporting leaks).
Manual Interstitial Monitoring must be performed if you do not use an electronic monitoring
system. To conduct manual interstitial monitoring you must open each sump weekly to visually
inspect for water or fuel.
If you discover product in your sump:
Turn off the pump
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Chapter 10: Piping Leak Detection
Contact your service technician
Have a tightness test performed on the line.
Report any alarms or the presence of product in sumps within 2 hours to the DEC (see
Chapter 14 for more information about reporting leaks).
If you discover water in your sump, you should remove and properly dispose of the water, then
diagnose and fix the cause of the water intrusion.
Suction Piping Systems – Category 3 and New Piping
It is relatively easy to tell if a suction piping system
has a hole in it because it will not operate properly.
The pump may make unusual noises when it is first
turned on and it will take longer than usual for
product to come out of the nozzle. These symptoms
are caused by air entering the hole in the pipe, known
as losing the prime. Loss of prime could also be the
result of a faulty check valve.
Suction piping systems have a check valve to keep the
piping and pump full of liquid when the pump is
turned off. The check valve is a one-way valve that
opens whenever product is flowing through the
dispenser nozzle, and closes automatically when the
pump is turned off, in order to keep product from flowing back to the tank.
You must monitor your suction piping, using a permitted leak detection method, UNLESS the
system is designed to meet ALL the following safe suction (also known as European suction)
criteria:
The underground piping operates at less than atmospheric pressure (i.e.: under suction);
The underground piping is sloped so that the contents of the pipe will drain back into
the tank if the suction is released;
there is only one check valve in each suction line;
the check valve is located directly below and as close as possible to the suction pump
(directly under the dispenser). Placement of the check valve is crucial to ensuring that
product flows back to the tank and not into the environment.
Figure 10.14: Suction system dispenser
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Chapter 10: Piping Leak Detection
Vapor
monitoring
and
groundwater
monitoring are
not
recommended
piping leak
detection
methods.
Suction systems that do not meet the safe suction criteria are known as “American” suction
systems and must be monitored for leaks.
New piping systems that do not meet the safe suction criteria must have weekly interstitial
monitoring as the primary leak detection.
10.3 Leak Detection: Piping Connected to Category 1 or 2 Tank
Systems
Existing piping connected to a Category 1 or 2 tank system must meet the following
requirements for leak detection. New piping connected to a Category 1 or 2 tank system must
meet the leak detection requirements for new piping.
Pressurized Piping Systems – Tank System Category 1 or 2
Pressurized piping connected to Category 1 or 2 tank systems must have two methods of leak
detection.
automatic line leak detector (mechanical or electrical)
AND one or more of the following:
weekly interstitial monitoring (manual or electronic); OR
other permitted type of weekly monitoring methods; OR
annual line tightness test.
Automatic line leak detectors work for Category 1 and 2 systems in the same way as for
Category 3 systems (see Section 10.2).
Interstitial monitoring is conducted for Category 1 and 2 systems in the same way as for
Category 3 systems (again, see Section 10.2).
If you use one of the other weekly monitoring methods, monitoring must be conducted for all
portions of piping that normally contain petroleum. The permitted alternatives include the
following:
Vapor monitoring
Groundwater monitoring
Statistical inventory reconciliation (SIR)
Vapor monitoring, groundwater monitoring, and SIR are described in Chapter 9. Groundwater
and vapor monitoring rely on discovering product in the groundwater or soil AFTER product has
leaked into the environment and are difficult to implement for piping leak detection. These two
methods therefore are NOT RECOMMENDED.
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Chapter 10: Piping Leak Detection
Maintain all
your leak
detection
equipment to
ensure proper
operation.
If you use annual line tightness tests as your piping leak detection method, the test must be
capable of detecting a leak at a rate of 0.1 gallons per hour. The tests must be performed by a
certified technician, and you must retain the test documentation for three years.
Suction Piping Systems – Tank System Category 1 or 2
Suction piping connected to Category 1 or 2 tank systems must be monitored using:
weekly interstitial monitoring (manual or electronic); OR
other permitted type of weekly monitoring methods; OR
line tightness test every three years.
Allowable weekly monitoring and line tightness testing methods are the same as for pressurized
piping connected to Category 1 and 2 tank systems. Safe suction systems are exempt from
piping leaking detection requirements.
10.4 Operation and Maintenance of Piping Leak Detection Equipment
All leak detection equipment (mechanical or electronic) must be installed, calibrated and
maintained according to the manufacturer’s instructions.
Automatic line leak detectors must be tested each year by a certified technician to ensure
proper operation. You should also test your other monitoring system components (e.g.,
sensors, alarm, and console readouts) each year.
Any leak detection equipment that is not working properly must be repaired or replaced
immediately.
10.5 Leak Reporting and Investigation
Reporting
Suspected leaks must be reported to DEC within 2 HOURS.
THE DEC SPILL HOTLINE NUMBER IS 1-800-457-7362
(518-457-7362 outside New York State)
The following are some unusual operating conditions related to piping which require reporting
with 2 hours unless equipment is found to be defective and is IMMEDIATELY repaired or
replaced:
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Chapter 10: Piping Leak Detection
Maintain all
leak detection
records for 3
years.
Maintain
results of
sampling,
testing, and
monitoring for
at least 3
years.
Dispensers operating at a restricted flow rate (around 3 gallons per minute or less) due
to an automatic line leak detector restricting flow (tell-tale sign: customers complain
about unusually long fill up times);
Liquid (water/petroleum) in the tank top or intermediate sump;
Sump sensor alarms;
Failed line tightness test; or
Suction dispenser loses suction (prime).
Never ignore signs of a leak from your piping. Suspected leaks must be reported even if they
occur on a weekend or a holiday.
Leak Investigation and Confirmation
You must take certain steps to investigate possible leaks and to clean up confirmed leaks. See
Chapter 14 for more information.
10.6 Recordkeeping
The following records must be retained for at least 3 years:
records of any sampling, testing or monitoring;
all calibration, maintenance and repair records for all leak detection equipment that is
permanently located on site and; and
schedule of required calibration and maintenance provided by the leak detection
manufacturer after installation.
Line tightness testing results must be retained AT LEAST until the next test is conducted.
You should keep all leak detection records in a log book. The book should be easily accessible
and available at all times. In addition, consider creating a log of (or print out) all leak detection
results from your electronic monitoring system. The thermal paper your ATG console prints on
can fade, so you should make more permanent copies (e.g. electronic scans, paper photocopies,
or written logs) that can be kept for the required three years.
Requirements for piping leak detection are summarized in Table 10.2.
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Chapter 10: Piping Leak Detection
Table 10.2 Piping Leak Detection Requirements
Tank System Piping System Leak Detection
Category 3+ Pressurized ALLD AND Weekly interstitial monitoring
Suction++ Weekly interstitial monitoring
Category 1 or 2
Pressurized ALLD AND one of the following:
Annual line tightness test; OR
Weekly interstitial monitoring; OR
Weekly monitoring – one of:
o Vapor monitoring+++
o Groundwater monitoring+++
o SIR+++
Suction++ Line tightness test every three years; OR
interstitial monitoring; OR
Weekly monitoring – one of:
Vapor monitoring+++
Groundwater monitoring+++
SIR+++
+ Also includes new piping systems installed for Category 1 and 2 tank systems.
++ Leak detection not required for suction systems that meet “safe suction” criteria (see text).
+++These leak detection methods are not recommended.
10.7 Summary
Piping leaks can allow product to contaminate the soil and groundwater at your site.
Piping leak detection methods allow you to monitor your underground piping to detect
possible leaks. Leak detection is required for piping that routinely contains petroleum
and is in contact with the ground.
Category 3 tank systems and new piping connected to Category 1 and 2 systems must
meet Category 3 requirements, including the requirement for double-walled piping
(except “safe suction systems”).
Pressurized piping systems must have two types of leak detection:
o an automatic line leak detector (mechanical or electronic); and
o weekly monitoring (must be interstitial for Category 3 systems).
o Category 1 or 2 systems may substitute annual line testing for weekly
monitoring.
Suction piping systems must be monitored weekly (must be interstitial for Category 3
systems), unless they meet criteria for “safe suction” systems.
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Chapter 10: Piping Leak Detection
o Category 1 or 2 systems may substitute line testing at three-year intervals for
weekly monitoring.
Piping leak detection systems must be installed and calibrated according to the
manufacturer’s instructions. Piping without proper leak detection must be taken out-of-
service.
Never ignore any alarms from your piping monitoring system. Alarms indicate a
possible leak in your system and should be investigated right away.
Cathodic Protection
6 NYCRR 613-2.1(b)(1)
and (613-2.2(b)
Maintain your CP
system to prevent
leaks
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CHAPTER
11
A/B Cathodic Protection (Corrosion Protection) 11.0
Cathodic protection (CP) - also known as corrosion protection - applies to steel
tank systems and steel piping. Without cathodic protection, underground metal
tank systems will corrode (rust) and may leak product into the environment.
Corrosion can attack the steel uniformly or create a hole in a small, localized area
(see Figure 11.1). Localized corrosion is the most common form of corrosion.
Given the right environmental conditions, localized corrosion can create a leak in
an unprotected tank or pipe in a very short time. It is YOUR responsibility to
maintain your CP system so that your UST system remains protected from
corrosion.
New York’s PBS regulations state that underground steel components and any
other UST system components that are not corrosion resistant MUST be
protected against corrosion.
Corrosion can be prevented by:
using non-metallic components such as fiberglass,
coating the metal to isolate it from soil and groundwater, and/or
using a cathodic protection (CP) system.
Certain non-metallic materials, like fiberglass, do not corrode. Therefore,
components made from these types of materials do not need CP.
Note: A CP system only protects the outside of
the tank system that is in contact with soil. CP
does not protect against corrosion that starts
from the inside of your tank, which often occurs
due to water in the tank. It is important to keep
water out of your tanks.
Figure 11.1: Corroded tank
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Chapter 11: Cathodic Protection
Figure 11.2: Steel tank with sacrificial anodes (EPA)
Anodes
11.1 Cathodic Protection Requirements
Buried steel UST system components, including tanks or piping, that routinely contain
petroleum must be protected from corrosion. CP systems must be designed, fabricated and
installed according to one of the codes of practice listed in the PBS regulations. Every field-
installed cathodic protection system must be designed by a corrosion expert.
For the cathodic protection system to work correctly, tanks must be electrically isolated from
other metal objects unless the CP system is designed to also protect the other metal objects. A
cathodic protection tester can determine if your system is electrically isolated.
All steel piping that routinely contains petroleum and is in contact with the ground MUST be
cathodically protected. Cathodic protection for steel piping must:
include a pipe coating system made of a suitable dielectric material,
be designed and installed according to the codes of practice listed in the regulations,
be designed by a corrosion expert, and
be properly maintained and operated, including required testing.
Metal piping or fittings that have leaked petroleum due to damage or corrosion cannot be
repaired, but must be replaced. For piping systems that do not meet new piping requirements,
if 50% or more of a piping run needs to be replaced, then you must replace the entire piping
run. The replacement piping must meet the standards in effect at the time of installation
(including requirements for double-walled piping, if applicable).
Non-corrodible pipes and fittings may be repaired
in accordance with manufacturer’s specifications.
11.2 Galvanic Systems
Galvanic cathodic protection systems are the
most common type of cathodic protection. They
are relatively easy to install and maintain because
they do not require a connection to an electrical
power circuit. In galvanic CP systems, sacrificial
anodes attached to the tank provide CP (Figure
11.2). Corrosion then occurs at the anodes
instead of the tank or piping. However, the
system may fail over time as the anodes corrode
away. Therefore, these systems must be tested
annually by a qualified corrosion tester.
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Chapter 11: Cathodic Protection
It is difficult to check whether you have a galvanic corrosion system because all the components
are buried. However, a CP tester can determine whether your steel tanks
and piping are:
cathodically protected;
receiving adequate levels of protection; and
electrically isolated from other metal components such as electrical
conduits.
11.3 Impressed Current Systems
In contrast to galvanic systems, impressed current systems require an
electric power source. These systems are typically connected through a
rectifier to the same electric service as the pumps, dispensers, lights, etc. at
your facility. The rectifier powers buried anodes that create electrical
currents to protect your steel tanks and/or steel piping (see Figure 11.3 and
Figure 11.4 for examples of rectifiers).
The rectifier MUST be powered on at ALL times to properly protect your
tank from corrosion. Do NOT turn off the rectifier and do NOT shut off the
circuit breaker it is connected to.
Most rectifiers are equipped with voltmeters and ammeters to
monitor system voltage and electrical current/amperage (see
figures). These readings will help you to determine if your system is
operating properly.
11.4 Inspection and Testing
All CP systems must be tested YEARLY by a qualified CP tester. The
test must conform to one of the codes of practice listed in the PBS
regulations.
In addition impressed current systems must be inspected every 60
days to verify that the rectifier is on and is operating properly. This
inspection may be performed by facility personnel or a service
contractor. 60-day inspections are not required for galvanic CP
systems.
Galvanic and Impressed Current System Testing
Your CP system (impressed or galvanic) must be tested:
Figure 11.4: Rectifier
Voltmeter
Ammeter
Figure 11.3: Rectifier
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Chapter 11: Cathodic Protection
DO NOT ignore
failing cathodic
protection tests!
six months after installation; and
EVERY year, starting after the initial six month test.
The testing MUST be performed by a qualified CP tester. A qualified CP tester must have the
training and experience to properly perform the testing.
The testing does not require any excavation. For an impressed current system, the rectifier
MUST be turned off during the test. Be sure that your rectifier is not blocked by store
merchandise or equipment, so that the CP tester can easily reach it. Also, keep access clear to
the test port by your tank. Be sure that this port is not paved over when re-paving is done at
your facility. Check that the rectifier is turned back on when the test is complete.
The CP tester will provide you with test results that indicate whether your system is adequately
protected. Keep these records in accordance with Section 11.6. If your system is not
adequately protected, make repairs immediately and retest the cathodic protection system
within six months.
60-Day Inspections for Impressed Current System
Inspection
If you have an impressed current system, you MUST inspect
your rectifier every 60 days. This inspection is in addition to
the yearly CP test described in the previous section. You
may do the 60-day inspection yourself, or have a contractor
do it.
To perform your 60-day inspection you must:
Check to make sure your rectifier is on; 1.
Record the volts shown on the voltmeter; 2.
Record the amps shown on the ammeter; 3.
Record the number of hours of operation; 4.
Compare the volts and amps you recorded to the 5.
volts and amps that were recorded when the
system was installed. There should be a sticker on
your rectifier stating the voltage and amps recorded
at installation;
Repair the CP system if the readings are outside the allowable range (see below); 6.
The operator can
complete the 60-
day inspection
for impressed
current
Your CP
system must
be tested
YEARLY
All CP annual
tests MUST be
performed by
a certified
tester
System voltage and
amperage design
readings when first
installed
Figure 11.5: 60-day rectifier test (Maine DEP)
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Chapter 11: Cathodic Protection
Compare the number of hours to the previous total hours to verify that the system has 7.
been on continuously (see below). Take appropriate action if it has not.
File your inspection report with your tank records and maintain it for at least 3 years. 8.
See Appendix E for a sample 60-day inspection log.
To check voltage and current readings, you need to know the allowable range of the voltage
and current/amperage readings.
The voltage and amperage readings on the rectifier will be different for every facility. However,
the actual numbers are not important. What IS important is that the numbers do not change
over time. This means that the numbers should be within 10% of the readings when the system
was first installed. The installation readings will be printed or written on the sticker on your
rectifier. If your readings are more than 10% higher or lower than the installation readings, then
something is wrong with your CP system. Contact a corrosion expert to check your system.
To check for continuous operation, you need to know how long the impressed current system
has been working.
After recording the current total hours, subtract the previous total from the current total.
Divide the number of hours by 24 and compare to the number of days since the last reading.
Note: 30 days = 720 hours; 60 days = 1440 hours. These numbers should be the same. If they
are not, determine the cause and correct it. Be sure that facility employees know that they
must not turn off the rectifier or the circuit breaker that controls it. If necessary, contact an
electrician or CP technician to repair the system.
DO NOT ignore failing cathodic protection tests or 60-day rectifier inspections!
If your system fails a CP test or rectifier inspection, you must repair the system immediately.
Without proper cathodic protection, steel tanks and piping can rapidly corrode and release
petroleum to soil or groundwater at your facility.
11.5 Repairs to Cathodic Protection Systems
Eventually your CP system will need repairs. Repairs made to cathodic protection systems
should be made by a certified cathodic protection expert and must be installed to the codes of
practice listed in the PBS regulations. Once your CP system is repaired you must conduct a CP
test within 6 months of the repair, and continue testing each year as described in Section 11.4.
Keep in mind that any repairs or upgrades being made to your site or UST system could damage
your CP system. If you have an impressed current system, be especially aware of any site
excavation work. Make sure that excavation work does not damage the underground wires that
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Chapter 11: Cathodic Protection
Maintain all
cathodic
protection
testing records
for 3 years
You are required
to complete a CP
system test
within 6 months
of any repair to
the CP system
Cathodic
protection
records MUST
be kept for 3
years
travel from your rectifier to your tank. The CP system must be tested within 6 months after any
repairs are made to the tanks or piping.
11.6 Recordkeeping
All cathodic protection testing results and inspection logs MUST be maintained for 3 years. Keep
your documents well organized, and store them in a place where you can access them quickly.
See Appendix E for a sample 60-day inspection log and Appendix F for a sample maintenance
record form.
In addition to your testing records, maintain all records of repairs until the system is closed.
11.7 Summary
Cathodic protection is vital to the maintenance of any steel UST systems at your site.
Corrosion protection systems must be maintained to protect steel tanks and piping from
rusting.
Cathodic protection systems must be inspected by a certified cathodic protection tester
within 6 months of installation and every year after that.
Impressed current cathodic protection systems must be inspected every 60 days to
ensure the system is operating properly.
Cathodic protection compliance records must be kept for at least 3 years.
Repairs to a cathodic protection system must be tested in accordance with a referenced
standard within 6 months of the repair.
6 NYCRR 613-1.1 lists cathodic protection standards that apply to underground tanks. For
additional information about cathodic protection systems and training of corrosion
professionals see the NACE International website www.nace.org.
Dispensers
NYCRR 613-2.1(b)(5)
UDCs are required
for all new
dispensers
All pressurized
systems must have
a shear valve
Dispensers must be
calibrated to record
the proper amount
of fuel dispensed.
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CHAPTER
12
A/B Dispensers 12.0
Most facilities with underground storage tanks are connected to dispensers by
underground piping. In addition to piping, dispensers may contain filters, pumps,
multiple joints, and valves. Each of these components is a potential site for leaks to
occur. Understanding the components of your dispenser and performing proper
maintenance can help you prevent leaks into the environment. Inspection and
maintenance of dispensers is your responsibility. You should visually inspect your
dispensing equipment daily to ensure it is working properly and leak free.
Figure 12.1, Figure 12.3, and Figure 12.2 show different types of dispensers that
may be present at your site. Dispensers come in many different shapes, sizes and
colors but they are all required to have some of the same features.
Figure 12.1: Typical fleet
dispenser
Figure 12.2: Typical retail
dispenser
Figure 12.3: Typical retail
dispenser providing three
different products
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Chapter 12: Dispensers
Make sure you
have a key to
your dispenser
cabinet
available at all
times
Typical Parts of a Dispenser
Typical dispensers are made up of the following parts:
dispenser cabinet
product hose
breakaway
swivel fitting
nozzle
shear/crash valve – must be properly anchored to the concrete island
under-dispenser containment sump (UDC)
The locations of these parts are shown in Figure 12.4 In addition, most dispensers also contain a
filter and a totalizer (which measures total product dispensed) inside the dispenser cabinet.
Make sure you have a key to your dispenser cabinet available at all times for maintenance and
periodic inspection.
You should complete periodic inspections of your dispenser and dispensing equipment. The
Petroleum Equipment Institute (PEI) publishes a document titled Recommended Practices for
Inspection and Maintenance of Motor Fuel Equipment (RP500) that includes detailed
instructions and checklists for completing daily, monthly and annual dispenser inspections.
Figure 12.4: Typical dispenser layout
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Chapter 12: Dispensers
Figure 12.6: Pressurized system
dispenser
Figure 12.5: Suction system dispenser
Pump
Motor
12.1 Dispensing Equipment
Pumps: Pressurized vs. Suction Systems
Your dispenser is part of
either a suction system or a
pressurized system. In a
suction system (see Figure
12.5), the system pump is
inside the dispenser and
“sucks” product from the
tank.
In a pressurized system, the
system pump is inside the
tank instead of inside the
dispenser (see Figure 12.6) and the pump “pushes” product to the
dispenser. Suction and pressurized systems must meet different regulatory
requirements, so it is important to know which type of system you have. If
you can see a pump and motor inside your dispenser, you have a suction
system. You can also listen when you activate the dispenser. If you can hear a pump and motor
start, then there is a good chance it is a suction dispenser.
Dispensers with Blended Products
Some dispensers are tied to blending systems that mix low- and high-grade
products from separate tanks to create a midgrade product. These dispensers
could have one nozzle, similar to the dispenser shown in Figure 12.7. Dispensers
that provide blended fuels may also have three different product nozzles.
The blended mid-grade product is mixed inside the dispenser just before it is
dispensed.
Figure 12.7: Typical retail
dispenser with blending to
dispense 3 grades of fuel
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Chapter 12: Dispensers
Piping
Buried steel pipe connected to the dispenser must be protected from corrosion by an approved
protective coating and/or cathodic protection (see Chapter 11). Alternatively, the piping may
be routed through a corrosion resistant sleeve that isolates the piping from soil and
groundwater. Both ends of the sleeve must be protected from contact with soil.
12.2 Under-dispenser Containment
Under-dispenser containment (UDC) – or simply, a
dispenser sump - is designed to contain leaks from the
dispenser piping. The UDC sits beneath your dispenser as
shown in Figure 12.8. UDCs typically contain the following:
valves
piping
buried risers
flex connectors
sump sensor
electrical conduit
UDCs are required for all new dispensers. Dispensers are
considered new when both the dispenser and the
equipment needed to connect the dispenser to the UST
are installed at a facility. The connecting equipment includes check valves, shear valves,
unburied risers, flexible connectors, or other transitional components installed beneath the
dispenser and connected to underground piping.
Figure 12.9 shows a UDC before burial. Underground piping and
conduit enter the UDC where they transition to dispenser piping.
UDCs may be made of fiberglass, steel or HDPE plastic. When you
open the door to your dispenser cabinet and look inside, you should be
able to see your UDC.
UDCs MUST be liquid tight on all sides, on the bottom, and at any
penetrations (i.e. where the underground piping and conduit enter the
UDC). In addition, your UDC must allow for visual inspection and
access to the components (dispenser piping) contained within the
Figure 12.9: UDC with a steel island
before burial, showing
underground piping and
conduit connections.
Figure 12.8: View into UDC from the dispenser
cabinet
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Chapter 12: Dispensers
UDC. If UDCs cannot be visually inspected then they are required to be continuously monitored
for leaks from the dispenser system.
12.3 Valves
Shear Valves
Every dispenser that is part of a pressurized piping system
must be equipped with a shear valve, also known as a crash
valve or impact valve. When properly installed, a shear
valve that meets NFPA 30A standards satisfies the
regulatory requirement. The shear valve is designed to stop
product flow from the pressurized pipe if your dispenser is
dislodged or struck by a vehicle. In order to stop product
flow, the shear valve must be located in the supply line at
the inlet of the dispenser.
The valve must be properly anchored and installed at the
correct height (usually at grade). Figure 12.10 shows a
shear valve that has been properly anchored. You should
have your shear valve inspected yearly.
Shear valves must not be modified or tampered with to keep them open. Figure 12.11 and
Figure 12.12 show shear valves that have been tampered with to keep them open. These valves
would not perform as intended in a collision, and would fail a DEC inspection.
Figure 12.11: Retrofitted shear
valve. This defeats the safety
purpose of the valve and
would fail a DEC inspection.
Figure 12.10: Proper shear valve placement
Figure 12.12: Shear valve held open with a socket
wrench and zip tie. This, like the shear valve in the
previous figure, is a major fire and environmental
hazard, and would fail a DEC inspection.
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Figure 12.13 and Figure 12.14 illustrate the difference between a non-working shear valve and a
working one. In Figure 12.13 the shear valve failed to close properly during a vehicle collision.
Therefore, product continued to flow. The result was a damaging fire and costly clean up.
Figure 12.14 illustrates a vehicle collision where the shear valve closed properly. Product flow
therefore stopped, and no fire occurred.
Check Valves
A piping system is considered a “safe suction” system if it satisfies ALL of the following criteria:
The piping operates at less than atmospheric pressure (i.e., under suction);
it has a check valve at the bottom of the dispenser;
there is no other check valve on the suction piping; AND
the piping slopes down to the tank.
Safe suction systems - also known as European suction systems - are defined by the placement
of the check valve (see Figure 12.15). The purpose of the check valve is twofold. First, the
check valve keeps product flowing in one direction by preventing backflow. Second, if the
piping in a safe suction system springs a leak, most of the product will likely flow back into the
tank instead of through the leak into surrounding soil. If a suction system satisfies the criteria
above, it does NOT require leak detection. You must be able to show that your safe suction
system has only one check valve, and that the valve is properly located. However, it can be
difficult to identify in-line check valves. If you do not have documentation of your check valve
location, a service contractor may be able to investigate your system and provide a written
report that documents the valve for your records.
Figure 12.13: Accident where the shear valve failed to shut
off fuel flow.
Figure 12.14: Accident where the shear valve
properly shut off fuel flow.
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Chapter 12: Dispensers
Your tanks
must have
operating
valves to
control the
flow of
product
through tank
connections
Some suction systems have a check valve located at the tank, either near the top of the tank or
at the bottom of the suction line in the tank. This type of system is called an “American suction”
system. If the piping in this system leaks, the product in the piping will be blocked by the check
valve and will not drain back into the tank. Instead, the product will be released into the
environment. Therefore, this type of system requires leak detection (see Chapter 10).
If product is delivered to your tank using a pump (e.g. the on-board pump of a fuel delivery
truck), and if the fill pipe is arranged such that product could flow back out of your tank through
the fill pipe, then you MUST have a check valve on the fill pipe to prevent backflow.
Solenoid Valves
Gravity head systems are fuel systems where the UST sits at a higher elevation than the fuel
dispenser. You may see this type of system, for example, at many marinas (see Figure 12.16). If
the dispenser or hose has a leak, gravity can cause product to flow from the tank (up high) and
out the leak (down low). The product can keep flowing until the tank is empty, creating a large
spill at your facility. To prevent this type of spill you MUST install a solenoid valve, an anti-
siphon valve, or similar device, to keep the pipe closed off when you are not dispensing fuel.
The solenoid must be installed adjacent to and downstream of the tank’s operating valve
(usually in the tank top sump). A solenoid valve that meets NFPA 30A satisfies these
requirements.
2
1
Figure 12.15 Diagram showing location of check valves for (1) European (safe) and (2)
American suction system (Source: DEC)
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Chapter 12: Dispensers
Operating Valves
Your tanks must have operating valves to control the flow of product through tank connections,
so that product flow can be stopped in situations such as maintenance, repair, or emergencies.
An operating valve that meets NFPA 30 standards meets this
requirement.
Breakaway Valves
The breakaway is located on your dispensing hose. The
purpose of a breakaway is to prevent spills if a customer
drives off with the nozzle still in their fuel tank. The
breakaway will “break” and snap the hose shut to prevent
product from escaping from the dispenser. The break occurs
at the breakaway instead of shearing the hose open. Some
breakaways are designed so that you can reconnect the
hose. Other kinds must be replaced before you can use the
hose again. In either case, you should look over the interior
and exterior of the dispenser to make sure the dispenser or
shear valve wasn’t damaged during the incident.
Figure 12.16: Typical gravity head system layout
Figure 12.17: Breakaway valve
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Chapter 12: Dispensers
12.4 Accidents
If a vehicle impacts your dispenser you should inspect your
dispenser thoroughly before you continue to use it. You should do
an inspection even if there appears to be no damage done.
Open your dispenser and verify the piping was not cracked or
damaged during the collision. Also, make sure your shear valve
was not damaged. Call a service contractor for assistance if you
have any safety concerns about performing an inspection yourself.
12.5 Calibration
All dispensers should be calibrated to properly record the amount
of product you are dispensing. Proper calibration will help insure
that your inventory and other records are correct.
Retail facilities must display a current Bureau of Weights and
Measures seal (or Bureau of Consumer Affairs seal in New York City). Calibration is not required
for non-retail dispensers but it can help you keep your inventory reports accurate and detect
potential loss or theft of product.
12.6 Summary
Understanding the components of your dispenser and performing proper maintenance
can help you prevent leaks into the environment.
Inspection and maintenance of dispensers is your responsibility. You should visually
inspect your dispensing equipment daily to ensure it is working properly and leak-free.
Suction and pressurized systems must meet different regulatory requirements, so it is
important to know which type of system you have.
Make sure you have a key to your dispenser cabinet available at all times for
maintenance and periodic inspection.
Buried steel piping connected to the dispenser must be protected from corrosion.
UDCs are required for all new dispensers. UDCs MUST be liquid tight on all sides, on the
bottom, and at any penetrations. In addition, UDCs must allow for visual inspection and
access to the components contained within the UDC.
Figure 12.18 Be sure to check your shear
valve after an accident such as a vehicle
hitting a pump
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Chapter 12: Dispensers
Every dispenser that is part of a pressurized piping system must be equipped with a
shear valve, also known as a crash valve or impact valve. Be sure the valve is properly
anchored and is installed at the correct height. Shear valves must not be modified or
tampered with.
If you have a safe suction system, you must be able to show that it has only one check
valve and that the valve is properly located.
If product can flow by gravity from your tank to your dispenser, then you must install a
solenoid valve or similar device, to keep the pipe closed off when you are not dispensing
fuel.
Your tanks must have operating valves to control the flow of product through tank
connections, so that product flow can be stopped in situations such as maintenance,
repair, or emergencies.
If product is delivered to your tank using a pump (e.g. the on-board pump of a fuel
delivery truck), and if the fill pipe is arranged such that product could flow back out of
your tank through the fill pipe, then you must have a check valve on the fill pipe to
prevent backflow.
If a vehicle impacts your dispenser or breaks the hose, you should inspect your
dispenser thoroughly before resuming use of the dispenser in order to verify that all
components, including the shear valve, are in proper working condition.
All dispensers should be calibrated to properly record the amount of product you are
dispensing.
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Spill Containment
Requirements
6 NYCRR 613-2.2 (a)
Ensure that
releases do
NOT occur
Report and
investigate all
spills
Label fill ports
Color code fill
ports
Spill Prevention and fill ports 13.0
Spill prevention devices are used at fill ports to prevent small drips or spills from
entering the environment. The most common spill prevention device is a spill
bucket. A spill bucket is a liquid tight container that surrounds the fill port and is
designed to catch small leaks, drips or spills from the delivery hose that may occur
during a delivery. Spill buckets are commonly located underground within the tank
pad.
Note: Spill buckets are also sometimes called “catch basins”. Do not confuse them
with the “catch basins” that drain to storm sewers.
CHAPTER
13
A/B
Figure 13.2: Fill port inside spill
bucket
Figure 13.1: Fill hose connected to
fill port inside a spill
bucket
Figure 13.3 Dirty spill bucket in need of cleaning
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Chapter 13: Spill Prevention and Fill Ports
Spill buckets
must be
properly
maintained.
13.1 Maintenance
It is YOUR responsibility to keep spill buckets CLEAN and DRY at all times.
Any water or fuel left in your spill bucket may damage the spill bucket over
time, causing the bucket to rust or rot and potentially leak product into the
environment.
Spill bucket and their lids/plow rings should also be inspected to ensure
they create a water tight seal. Any chips or cracks in the lid or plow ring
will allow water to enter the spill bucket. Cracks or holes in the spill bucket
will allow water or fuel to leak out. Damaged spill buckets must be
replaced.
Most spill buckets are equipped with a drain valve. The drain valve is
located at the bottom of the bucket and when used, drains any liquid
contained in the spill bucket into the tank. Fuel in a clean bucket can be
returned to the tank by opening the drain valve.
If your spill bucket contains water or a fuel/water mixture, the liquid must be
disposed of properly. Contact your UST service provider for assistance in disposing
this waste.
Many spill buckets either do not have a drain valve or have a valve that has been
plugged to prevent water from draining into the tank. When the spill bucket does
not have a functional drain valve, the operator must have a method to remove the
liquid from the spill bucket. This is often done using a hand
pump.
Double-walled spill containment buckets can also be installed.
These buckets are easily replaced and may be equipped with a
mechanical or electronic gauge to monitor the interstitial space
between the spill bucket and the containment bucket.
Figure: 13.5 Double-walled
spill bucket
Figure: 13.4 Spill bucket and
hand pump.
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Chapter 13: Spill Prevention and Fill Ports
Spill buckets
must be
maintained.
Tank fill ports
must be
properly
tagged and
color coded.
13.3 Common Issues
It is important to be aware of some common issues
related to spill buckets and to address them immediately:
Spill bucket contains liquid:
Clean spill bucket before and after delivery
Any product remaining more than 2 hours is
considered a reportable spill and must be
reported to the DEC immediately.
The spill bucket is no longer water tight:
Inspect the spill buckets for holes or cracks and replace if needed.
Damaged plow ring:
Repair or replace
Broken caps or gaskets:
Caps should lock tightly
Gasket should create a liquid-tight seal
Repair or replace as needed
If water continues to build up in a spill bucket it needs to be replaced or regraded.
Contact your service provider to discuss.
Ice in spill bucket:
Take care to avoid damaging spill bucket when removing the ice.
13.4 Tank Tags
The fill port on Category 2 and 3 tanks must have a label
containing the following:
registration identification number
tank design capacity
tank working capacity
product that is able to be stored
The tank tag must be visible before any deliveries can be made to your tank. The
Figure 13.6: Damaged spill bucket
Figure: 13.7 Fill port tag
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Chapter 13: Spill Prevention and Fill Ports
label or tag must be permanently fastened to the fill port (i.e. bolted, chained, zip
tied). If the tag is not present, contact your service provider to provide a tag with
the required information.
13.5 Fill Port Color Coding
Every tank system fill port must be permanently marked and color coded in
accordance with API RP 1637. The colors to be used are:
Table 3 Fill Port Color Coding in Accordance with API 1637
Product Color/symbol
High-grade unleaded gasoline Red circle w/white cross
Mid-grade unleaded gasoline Blue circle w/white cross
Low-grade unleaded gasoline White circle w/black cross
Vapor recovery Orange circle
Diesel Yellow hexagon
#1 fuel oil Purple hexagon w/yellow bar
#2 fuel oil Green hexagon
Kerosene Brown hexagon
Used oil / waste oil Purple square
#4 fuel oil Green hexagon w/ black or white ‘4’
#6 fuel oil Green hexagon w/ black or white ‘6’
Ultra low sulfur diesel Yellow hexagon w/ black ‘U’
Ultra low sulfur kerosene Brown hexagon w/ black ‘U’
Alcohol-blended fuels Bronze “home plate” symbol w/ black lettering,
e.g., ‘E85’
Biodiesel Bronze hexagon w/ yellow outer band & black or
white lettering, e.g., ‘B20’
Monitoring well Black equilateral triangle on white background
A border must be painted around the symbols in the above table for fuel products
containing extenders such as alcohol. The border will be black around a white
symbol and white around all other colors.
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Chapter 13: Spill Prevention and Fill Ports
Figure 13.8: Properly colored fill port
for unleaded low-grade gasoline
(white with black cross) and vapor
recovery port (orange circle).
Any monitoring wells located at the facility must be properly identified to prevent
accidental delivery of petroleum to the well. Additional protection can be provided
by marking the well with a “Do Not Fill” label.
Spill Reporting and
Response Actions
6 NYCRR 613-2.4
and Subpart 613-6
Suspected leaks
must be reported
within 2 hours
Suspected leaks
MUST be
investigated
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CHAPTER
14
A/B Spill Reporting and Response 14.0
Spills and releases of petroleum from any source at your facility must be addressed
immediately. Even small spills can contaminate drinking water supplies, lakes,
rivers or streams. Small continuous drips, for example, can add up to a lot of
spilled product over time.
There are many potential spill sources from an underground storage tank system.
Spill can occur due to tank overfills, customer errors, dispenser leakage, leaking
hose or nozzles, piping failure, tank failure, and other causes.
Make sure you are familiar with your system and all of its components so that you
are prepared to respond if a spill occurs.
It is your responsibility to identify, report, investigate and respond to spills.
Spill Response Planning
Your facility should have a spill and emergency response plan in place. The plan
should outline what you will do in the event of a spill. Be sure to review the plan
with your staff periodically to make sure that they are familiar with their
responsibilities. If you don’t yet have a spill response plan, NOW is a good
time to create one.
Make sure all Class C operators have been trained on leak/spill
identification, response, and reporting before they begin work. Their
completion of training must be documented and kept in a log for as long as
they work at your facility, and a minimum of three years after they leave.
You should have a spill kit on hand to clean up minor spills. These kits are
readily available and contain absorbent towels and material. Be sure to
properly dispose of any material used to clean up a spill.
Figure 14.1: Keep a spill kit available
at all times for minor spill cleanup
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Chapter 14: Spill and Leak Reporting and
Response Actions
14.1 Signs of a Spill or Release
The terms “spill” and “leak” are both defined to mean any
escape of petroleum from the container (e.g. the tank, piping,
and dispensers) that is ordinarily used for storage, transfer,
processing, or use. This definition includes any escape of
petroleum into containment (e.g. into a spill bucket, a sump, or
the tank interstitial space). A spill that enters the environment is
called a “release”.
You should always be mindful of the operations at your site. Be
alert for any unusual operating conditions, especially those that
indicate that something is wrong with the system and that a spill
or release could result.
Typical signs of a leak include the following:
exceedance of the allowable inventory variance;
tank monitor alarms;
tank or line test failure;
slow product flow;
vapors in your facility or nearby buildings/basements/sewers;
and
presence of product in any location that is not designed to
store product.
If you see any signs of a leak or spill, you must take action
immediately. Always assume that the sign indicates an actual leak.
For instance, if your ATG console is in alarm, don’t assume that your
leak detection is malfunctioning and that you can ignore the alarm.
You must respond to the alarm as a possible spill.
Ignoring signs of a leak or assuming a false alarm may:
allow the leak to become worse;
cause harm to people and/or the environment; and
cost more to clean up.
14.2 Investigating Possible Spills
If there are signs of a spill or leak at your site, do an immediate investigation to determine if you
have a situation that needs to be reported to DEC.
Figure 14.2: Stain from a spill that was not
immediately cleaned up
Figure 14.3: Vehicle that drove off with the
fuel nozzle
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Chapter 14: Spill and Leak Reporting and
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Any product
found where it
shouldn’t be is
considered a
spill
To investigate the possible spill or leak, follow the steps below:
Check the tank top sump, transition sumps and dispenser sumps for product or water.
Check your inventory records and the math on your inventory monitoring. Did you
make a mistake?
Check your leak detection equipment. Is it operating properly? If not, can it be replaced
or repaired immediately?
Look around your site for other signs of a leak or spill.
If you determine you may have a leak, take action:
Identify fire, explosion, and vapor hazards.
Take appropriate safety measures.
Stop the leak and contain any releases if feasible and safe to do so.
Report the leak.
Discontinue use of the system/activate the emergency stop.
If necessary, call a service provider to investigate the leak.
Test the tank and/or piping.
Empty the tank if necessary.
To report the leak:
Notify the Class A and Class B Operators.
Notify DEC.
Notify your local fire department, if needed.
Call designated staff within your company who can help you with spill response (i.e.
corporate safety officer or manager).
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Chapter 14: Spill and Leak Reporting and
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NEVER ignore
leak detection
alarms
14.3 Reporting Spills and Releases
Any product found where it shouldn’t be is considered a spill. This includes, but is not limited
to:
product in the tank top sump, dispenser sump or transition sump;
accidental overfills during deliveries; and
spills by consumers filling their tanks.
You must report spills to DEC within 2 HOURS of discovery.
THE DEC SPILL HOTLINE NUMBER IS 1-800-457-7362
(518-457-7362 outside New York State)
A spill MUST be reported unless ALL of the following are true:
the spill is less than 5 gallons in total volume, and
is contained and under control, and
has not reached and will not reach the State’s waters (including groundwater), or any
land, and
is cleaned up within two hours after discovery.
Some examples:
If a quart of fuel is spilled into the spill bucket during a delivery, but none is spilled
outside the spill bucket and all the fuel is cleaned up immediately, then the spill is not
reportable.
If five gallons or more are spilled into the spill bucket, OR if any of the fuel is spilled to
soil, OR if it takes longer than two hours to clean up all the fuel, then the spill MUST be
reported.
If you are excavating during the removal/replacement of a tank, or for any other reason,
and find petroleum staining in the soils or sheens on the groundwater, this MUST be
reported.
You must report releases of petroleum outside of the tank system such as free product or
vapors in soil, basements, utility lines, sewers or nearby surface water within 2 hours after
discovery.
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Chapter 14: Spill and Leak Reporting and
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You must report the following conditions within 2 hours after discovery unless they were NOT
caused by an actual reportable spill AND any equipment found to be defective is IMMEDIATELY
repaired or replaced:
Monitoring results, including alarms, which
indicate a possible leak.
Unusual operating conditions:
o Erratic behavior of dispensing
equipment
o Sudden loss of product from the
tank system
o Unexplained presence of water in
the tank
o Liquid (water/petroleum) in the dry
interstitial space of the tank or any
secondarily contained system
o Liquid (water/petroleum) in the
piping containment sump
o Product in the spill bucket
o Loss or gain of fluid in wet
interstitial space
o Leak alarms
o Failed ATG test
o Failed tank tightness test
o Suction dispenser loses suction
o Any other conditions that indicate a leak or possible leak
You must report within 48 hours any indications of a leak based on:
statistical inventory reconciliation (SIR) (see Chapter 9); or
ten-day inventory reconciliation (see Chapter 8).
Once you discover a spill you must contain the spill and begin corrective action as detailed in
rest of this chapter.
You must immediately discontinue the operation of any leaking UST system and take the system
out of service, or permanently close the UST system. It is important to clean up a spill as soon as
possible to mitigate the risk to people and the environment.
Figure 14.4: Surface spills should be cleaned up
immediately. Petroleum can travel a long way in a short
time.
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Chapter 14: Spill and Leak Reporting and
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You must
immediately
discontinue
the operation
of any leaking
UST system
and take the
system
temporarily
out-of-service,
or
permanently
close the UST
system.
14.4 Minor Spill Response Actions
If a minor spill occurs at your site you may be able to clean up
the spill yourself. But you should only attempt to clean up the
spill IF you can do so safely.
Call 911 and/or contact a spill contractor if you do not feel
that you can clean up the spill on your own. You should reach
out to a spill contractor NOW to determine their availability
and pricing in preparation for a spill that needs professional
assistance.
Figure 14.5 shows workers cleaning up a spill with “Speedi-dri”
and absorbent pads. “Speedi-dri” and other similar products
are similar to cat litter and will soak up spilled petroleum.
However, these products will not absorb any oil if they
become saturated with rain or if they otherwise become wet.
Petroleum-specific absorbent pads will only soak up
petroleum. They repel water and can be used to soak up spills even if it is raining or the spill
occurs in a wet area.
Use “Speedi-dri” or absorbent pads to soak up as much of the spill as possible. Never leave fuel-
soaked materials lying around, since they are a fire hazard. Fuel-contaminated soils and fuel-
soaked materials must be disposed of properly. Due to the potential
presence of fuel, the disposal of these materials may need to be treated as a
regulated or hazardous waste. The operator should be:
familiar with applicable waste disposal laws and regulations; and
able to determine when spill clean-up wastes require disposal as a
regulated or hazardous waste.
THE OPERATOR IS RESPONSIBLE FOR PROPER DISPOSAL OF CLEAN-UP
MATERIALS.
Never use a garden hose to clean up any spills. The water will wash product
into the soil and/or storm sewer system or nearby water bodies and will
contaminate an even larger area.
Figure 14.6: Your spill kit should
contain absorbent pads or
Speedi-dri which can be used to
clean up minor spills
Figure 14.5: Workers cleaning up a spill with
“Speedi-dri" and absorbent pads
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Chapter 14: Spill and Leak Reporting and
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Leak
investigations
must start within
48 hours of
reporting a
suspected leak.
14.5 Release Response, Investigation, and Corrective Action
For spill or leaks without an obvious cause or that cannot be quickly contained and cleaned up,
your response must include: an initial response; leak investigation and/or site check; initial
abatement; site characterization; free product removal; and corrective action.
Initial Response
First: perform the safety, reporting, and action steps listed in Sections 14.2 and 14.3. Then,
unless you can completely contain and clean up the spill using the steps in section 14.4, you
must complete the measures below, or other measures as directed by DEC.
Leak Investigation: System Tightness Test and Site Check
You must conduct a leak investigation that meets the requirements of 6 NYCRR 613.-2.4(c) if
1. you suspect a leak at your facility, OR
2. your tank system may be the source of impacts that are observed by (or reported to)
DEC on a nearby property.
Signs of environmental contamination on another property
include conditions such as the presence of free product or
vapors in any of the following:
soil,
basements,
sewers,
utility lines,
nearby surface water, or
drinking water.
If a leak or spill is suspected on your site or another
property, you must begin an investigation within 48 hours
and complete it within 7 days.
If evidence of a leak is not based on environmental contamination (e.g. equipment-based alarms
or leak monitoring results), then you must do a tightness test on your tank system.
For a tightness test to be valid it must:
be capable of detecting a leak from a tank system at 0.1 gallons per hour;
have a probability of detection of at least 95% and probability of false alarm of no more
than 5%; and
Figure 14.7: Technician performing a tank test
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Chapter 14: Spill and Leak Reporting and
Response Actions
Leak
investigations
must start within
48 hours of
reporting a
suspected leak.
A tank or piping
tightness test will
help you
determine if your
system does have
a leak.
Respond
immediately
to spills or
leaks.
Identify and
mitigate any
fire or
explosion
hazards during
your initial
spill response.
Prevent
release of
additional
product.
be performed by a person who has been trained and certified or credentialed by the
manufacturer/vendor of the test method.
If the results of the tightness test do not indicate a leak and there is no evidence of
environmental contamination, then no further investigation is required.
If the tightness test confirms a leak, you must conduct a site check as described below. A site
check must also be performed if the results of the tightness test do not indicate a tank leak but
environmental contamination is the basis of the leak investigation.
A site check requires the facility to measure for the presence of a release where contamination
is most likely to be present. You must consider the location, methods of storage and type of
petroleum stored to be sure the investigation can identify the source of the release.
As an example, some sites may have existing monitoring wells on site. These wells could be
used to measure for contamination as long as the release is likely to be discovered through
those wells. Facilities may need to install monitoring wells or excavate the subsurface to
determine if the tank system is leaking.
If the site check does not reveal a release, further investigation is not required. Be certain to
document any investigation and the results of the investigation.
If the site check does reveal a release, the DEC must be notified within 2 hours after the
discovery.
A corrective action may be required if a release has occurred. Steps to develop and implement a
corrective action plan include: initial abatement, site characterization, free product removal,
investigations for clean-up, and plan development/implementation.
Initial Abatement Measures (613-6.3)
Once a release is confirmed, you must perform the following initial abatement measures, unless
directed otherwise by DEC.
1. Remove as much of the petroleum from the tank system as necessary to prevent further
release.
2. Visually inspect aboveground releases or exposed below-ground releases and prevent
further petroleum migration.
3. Continue to monitor any fire or safety hazards posed by vapors or product that have
migrated from the excavation zone.
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All free
product
removal must
be conducted
according to
the standards
outlined in the
PBS
regulations.
4. Remedy hazards posed by contaminated soils that are excavated or exposed during
response, investigation, or corrective action.
5. Complete a site check, as described above, unless the location of the release has already
been determined.
6. Investigate to determine the amount of free product that has been released and begin
free product removal as soon as possible (see “Free Product Removal” below).
Within twenty days after release confirmation, you must submit a report to the DEC
summarizing the initial abatement steps you have taken as well as any resulting
information/data.
Initial Site Characterization
Unless otherwise directed by DEC, you must perform an initial site characterization by gathering
required information about the site and the nature of the release. You must include
information gained during the initial abatement and site check. Required information includes
all of the following:
the nature and estimated quantity of the release;
data from available sources and/or site investigations concerning:
o the surrounding populations
o water quality
o use and approximate locations of wells potentially affected by the release
o subsurface soil conditions
o locations of subsurface sewers
o climatological conditions
o land use;
results of the site check; and
results of the free product investigations (see below).
The above information must be submitted to DEC within 45 days after the release is confirmed
or another reasonable period of time determined by DEC.
Free Product Removal (613-6.5)
If you discover free product during your site check, it must be cleaned up. You may contact a
local spill clean-up consultant to complete the free product removal for you.
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You should establish an agreement with a local spill clean-up contractor before you ever
experience a spill. Develop an understanding of their pricing and availability if you were to
require their assistance.
All free product removal must be conducted according to the standards outlined in the PBS
regulations.
Unless otherwise directed by DEC, within 45 days after confirming a release you must prepare
and submit a free product removal report that contains at least the following:
Name of the person(s) responsible for the clean-up measures;
Estimated quantity; type and thickness of free product observed or measured;
Type of free product the system used;
Whether any discharge will occur during clean-up (and where);
Type of treatment applied to the clean-up as well as the resulting effluent quality;
The steps being taken to obtain necessary permits for any discharge; and
Disposition of the free product.
Investigations for Soil and Groundwater Clean-Up
You must conduct soil/groundwater investigations of the release, your site, and surrounding
areas that may be affected if:
you find free product on your site; OR
there is evidence that a release at your site may affect surface water or groundwater;
OR
DEC requests an investigation, based on potential impacts to surface water or
groundwater.
The investigations must determine the full extent and location of soils contaminated by the
release and the concentrations of dissolved product in the groundwater. These investigations
must be conducted according to the guidelines presented in the PBS regulations. You will likely
need to hire a contractor to complete the investigations.
The facility must present the information to DEC as soon as practicable or in accordance with a
schedule established by DEC.
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Initiate a
relationship
with a clean-
up contractor
before a spill
occurs at your
site.
A corrective
action plan
may be
required by
DEC to initiate
clean-up of a
spill at your
site.
Spill clean-up
plans may be
disclosed to
the public.
Spill clean-up
plans may be
disclosed to
the public.
14.6 Corrective Action Plan
At any point during your spill response and investigations, DEC may require you to submit
additional information. You may also be required to develop and submit a corrective action plan
for responding to contaminated soils and groundwater.
Your plan must provide adequate protection for public health and the environment and must
address the factors listed in the regulations. You must modify your plan as required to provide
this protection. Once DEC approves your plan, you are responsible for implementing,
monitoring, evaluating, and reporting the results according to the schedule and format
established by DEC.
14.7 Public Participation
If a release from your facility requires a corrective action plan, DEC will require an opportunity
for public involvement by anyone who may be affected by the spill or the corrective action.
Notice of the opportunity may include public notices in local newspapers, block advertisements,
public service announcements, e-mail, publication in a state register, letters to individual
households, or personal contacts by field staff.
DEC will ensure that site release information and decisions about corrective action will be
available to the public upon request.
Before approving a corrective action plan DEC may hold a public meeting to consider comments
on the proposed corrective action plan. Public notice will be required if the corrective action
plan fails to achieve its clean-up goals and DEC is considering termination of the plan.
14.8 Recordkeeping
The following records regarding spills or leaks must be maintained for at least 3 years:
Your ten-day inventory reconciliation sheets;
Results of any sampling, testing or monitoring (for tanks and piping);
Written documentation for all calibration, maintenance and repair of leak detection
equipment;
Manufacturer’s schedules for calibration and maintenance of leak detection equipment
following installation;
Calibration, maintenance and repair records for all leak detection equipment that is
permanently located on site;
Schedule of required calibration and maintenance provided by the leak detection
manufacturer after installation; and
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The last 30
days of leak
monitoring
results MUST
be available to
DEC at the time
of request.
Tank closure records.
Line or tank tightness testing results must be maintained until the next test is conducted, while
the LLD operability test records must be maintained for three years. In addition, you must make
the last 30 days of weekly leak monitoring available to DEC at the time of request.
You should keep all leak detection results in some type of log book. The book should be easily
accessible and available at all times.
Note: Many ATG systems use thermal printer paper to print test results and sensor status. This
paper can fade over time and the necessary records may not be available. Along with
maintaining copies of ATG print-outs, consider creating a written log with leak detection results,
or create longer lasting copies by photocopying or scanning the print-outs.
14.9 Summary
It is your responsibility to identify, report, investigate and respond to spills.
Any product found where it shouldn’t be is considered a spill.
Spills and releases from any source at your facility must be addressed immediately.
Figure 14.8: Keep all spill or leak detection
documentation in a log book
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It is your
responsibility
to identify ,
report,
investigate
and respond
to spills.
You must report spills to the DEC Spill Hotline within 2 HOURS after discovery.
Make sure you are familiar with your system and all of its components so that you will
be prepared to respond if a spill occurs.
Your facility should have a spill and emergency response plan in place. The plan should
outline what you will do in the event of a spill.
Make sure all Class C Operators have been trained on leak/spill identification, response,
and reporting before they begin work.
Be alert for any unusual operating conditions. An unusual operating condition may
indicate that something is wrong with the system and that a spill or release could result.
For spill or leaks without an obvious cause or that cannot be quickly contained and
cleaned up, you may be required to conduct some or all of these actions: leak
investigation and/or site check; initial abatement; site characterization; free product
removal; investigations for clean-up; and corrective action.
If a release from your facility requires a corrective action plan, DEC will require an
opportunity for public involvement by anyone who may be affected by the spill or the
corrective action.
Most records regarding spills or leaks must be maintained for at least 3 years.
UST System Record-
keeping
6 NYCRR 613-1.5
Keep organized
records of your UST
system
All records should
be available to DEC
at the time of the
request.
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CHAPTER
15
A/B UST System Recordkeeping 15.0
Incomplete or missing paperwork is one of the most frequent causes of regulatory
citations. Keeping your UST system records in order is important so you can
demonstrate to an inspector that you are in compliance with the PBS regulations.
Organized records will help your inspection go smoothly and will help you - and the
inspector - determine whether your system is in compliance.
The person keeping your records should know what records need to be kept and
should keep them up-to-date and in a neat, well-organized manner. A 3-ring
binder with divider tabs is a good way to organize UST system information so that
it can be easily located when needed.
Operators must make records available to DEC within three business days after a
request by DEC. However, the results of leak detection monitoring for the past
thirty days MUST be made available to DEC at the time of the request.
The operator, facility owner or tank system owner must allow a designated
employee or agent of DEC to review and copy any requested books, paper,
documents or records related to PBS compliance. Any designated employee or
agent of DEC may enter and inspect a facility to ensure compliance.
Figure 15.1: An organized compliance binder will make inspections go much more smoothly
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Chapter 15: UST System Recordkeeping
15.1 Record Storage
The following are tips to keep your records organized:
Keep records organized in a 3-ring
binder or similar file organizer.
Create a table of contents for your
binder. Figure 15.2 shows a sample
Table of Contents for a compliance
binder. Note: This is an example only -
not every site will need the same table
of contents. Be sure you have the
correct documents for your site in your
binder.
Keep all logs in your compliance binder
organized and legible. ATG consoles
often print on thermal paper that will
fade over time, similar to retail receipts.
You should transfer inventory reports
printed on thermal paper to a
computerized spreadsheet or
handwritten inventory form so that
they remain legible.
Insert documents into your compliance
binder right away so that they will not
get lost or ruined. You may find it
easiest to keep documents in your
compliance binder in page protectors,
so that documents do not need to be
hole punched and can be inserted
directly into the binder.
Make sure that your record keeper
maintains the binder in a neat and
organized manner and keeps records
up-to-date. Make sure they know what
records need to be kept and for how
long.
Figure 15.2: Sample table of contents for a compliance
binder
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Chapter 15: UST System Recordkeeping
Figure 15.4: Create a binder with a colorful cover and
spine to make it easy to find
15.2 Record Accessibility
Records must always be accessible to DEC.
Operators MUST know where the information is located.
Records should be located where operators
can easily access them.
Any records not available at the time of DEC’s
request MUST be provided to DEC within three
business days.
If you have permanently closed any tanks or
changed their service (e.g. switched to an
unregulated product) within the last three
years, then you must keep records that
document compliance with closure
requirements, including a site assessment, if
required. Copies of those records must also be
transmitted to DEC within ninety days after the
tank is physically closed or changes service.
Note: The last 30 days of leak detection documentation MUST made be available to DEC at the
time of request. If an inspector asks for this documentation, you must be able to produce it
immediately.
15.3 Required Records
Table 15.1 lists the records your facility is required to keep
and how long they must be kept. The records should be
kept in a compliance binder or otherwise organized so that
they are neat and easily accessible.
Figure 15.3: Organized compliance binders make
inspections easier
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Chapter 15: UST System Recordkeeping
Table 15.1: Required Records
Record Timeframe the record must be retained
Operator Training (Chapter 2)
Operator Training For as long as the Class A, Class B, and Class C
operators are designated AND for an additional 3 years
Tank Registration (Chapter 4)
Registration Certificate 5 years from date issued
Financial Responsibility (Chapter 5)
Financial Responsibility Life of tank system
Tank Closure (Chapter 6)
Closure Record Forward copies of the permanent closure record(s)
with the site assessment to DEC within 90 days after
closure; keep originals of both records for at least 3
years (recommended to keep as permanent record) Site Assessment
10-day Inventory Monitoring (Chapter 8)
Daily Readings 3 years
Reconciliations 3 years
Tank Leak Detection (Chapter 9)
Tank Tightness Testing Until next test is conducted
Weekly Monitoring 3 years
Leak Detection Repair 3 years after the repair
Piping Leak Detection (Chapter 10)
Line Tightness Testing Until next test is conducted
Weekly Monitoring 3 years
Annual Line Leak Detector
Operability Test 3 years
Leak Detection Repair
3 years after the repair
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Chapter 15: UST System Recordkeeping
Record Timeframe the record must be retained
Cathodic Protection (Chapter 11)
60-Day Rectifier Readings
(impressed current system
only)
3 years
Annual Cathodic Protection
System Test 3 years
Spill Reporting (Chapter 14)
Reporting of Suspected Leaks 3 years
Equipment Compatibility (Chapter 17)
Compatibility No records required
General System Records
Installation Records (i.e. as-
built diagrams, manufacturer
details)
Life of tank system
Lining Inspection 5 years
Repairs Life of tank system
15.4 Summary
Incomplete or missing paperwork is one of the most frequent causes of regulatory
notices of violation (NOVs).
Keeping your UST system records in order is important so you can demonstrate to an
inspector that you are in compliance with the PBS regulations.
The person keeping records should know what records need to be kept and should keep
them up-to-date and in a neat, well-organized manner. A 3-ring binder with divider tabs
is a good way to organize UST system information so that it can be easily located when
needed.
Operators must make records available to DEC within three business days following a
request by DEC. However, the results of leak detection monitoring for the past thirty
days MUST be made available to DEC at the time of request.
Operation and
Maintenance
EPA Grant Guidelines,
Solid Waste Disposal
Act Section 9010(a)
Understand how
your UST system
works to prevent
spills.
Maintain the
various
components of
your UST system to
ensure proper
operation.
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CHAPTER
16
A/B Operation and Maintenance 16.0
It is important to follow the proper operating procedures and maintain your tank system
to prevent spills and leaks. Know the components and operating requirements of your
tank system. Record your required inspection observations and test results.
Establish a regular routine to inspect and maintain your tank system. Consider setting a
calendar reminder or assigning the task of inspecting and recording information to an
employee to help you meet required deadlines.
16.1 Day to Day Operations - What Do I Need To Do?
The activities in this section should be performed every day to ensure that your tank
system is operating properly.
Complete inventory and reconciliation
Ten-day inventory reconciliation is required at certain sites and is a good management
practice for other sites with metered tanks. See Chapter 8 for more information. Daily
inventory tasks include:
Check your entries daily to catch any inconsistencies before you complete your
10-day inventory reconciliation.
Reconcile your inventory at least every 10 days.
Investigate variances that exceed the allowable limit as
soon as you notice them.
Report any unexplained variances to DEC within 48 hours
following the end of the 10-day inventory reconciliation
period.
Measure water in your tank
Water in your tank is a sign that your tank may be leaking.
The best way to detect water is to measure it with a
gauging stick and water-finding paste. Manually sticking
your tank for water is a good practice even if your
automatic tank gauge is set up to read water levels. See
Chapter 8 for more information.
Figure 16.1: Operators have a responsibility to
maintain and operate their system according
to the PBS regulations
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Chapter 16: Operation and Maintenance
Inspect and clean spill buckets
Spill buckets should be inspected and cleaned (if necessary) every day. They should be
free or water and debris. Ensure that buckets are repaired when necessary to avoid
water intrusion and to make sure any spills will be contained. See Chapter 13 for more
information.
Look for any spills around the delivery area and dispensing area
Remember that spill buckets, tank top sumps, and dispenser sumps should be kept free
of product at all times.
Inspect leak detection equipment
Check and respond to any alarms on your ATG. See Chapters 9 and 10 for more
information.
Make sure the leak detection system is powered on and operating.
Test the overfill alarm.
Be sure your class C Operators are trained for:
Emergency stop procedures
Spill response
Leak detection alarms response
Contacting A/B operator when required
Reporting unusual operating conditions
Making sure that necessary contact numbers are
current and readily available
Knowing the location of compliance
binder/record information
Be sure your impressed cathodic protection is on (if
present at your site)
Your rectifier should be on at all times.
Make sure that the breaker to the rectifier is properly labeled and doesn’t get turned off
at night.
Read and record rectifier amperage and voltage every sixty days. See Chapter 11 for
more information.
Figure 16.2: Accurate inventory monitoring is crucial to
preventing leaks from your UST system
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Chapter 16: Operation and Maintenance
To properly
demonstrate
compliance be
sure to record
all inspections,
training and
investigations.
Check your compliance requirements for:
Annual tank tightness, line tightness and leak detector tests
Annual cathodic protection testing
Weekly leak detection inspection
16.2 Inspections
Weekly Leak Detection
Weekly interstitial monitoring is required for all Category 2 and 3 tanks and for newly installed
piping or piping connected to Category 3 tanks. Weekly monitoring may also be used for
Category 1 tank systems. Many systems are equipped with continuous electronic monitoring
systems. Monitoring results from electronic monitoring systems must be documented at least
weekly.
You must keep the last thirty days of leak monitoring results at the facility at all times.
All leak detection records must be available for three years.
Records of any maintenance, repairs alarms, calibration or investigations must be
available for three years.
Keep your weekly leak detection reports in a log and be sure it is accessible at all times.
Systems that conduct continuous monitoring must be set up to print or record weekly
results.
All operators (Classes A, B AND C) should know where to find the leak detection reports.
Annual Tests
Annual tests that may be required at your site include:
Automatic line leak detector (LLD) operability test. Remember that pressurized piping
(piping connected to a pump in your tank) must be equipped with an automatic LLD.
See Chapter 10 for more information.
Cathodic protection system operability test. This requirement applies to impressed
current and galvanic systems. The test must be performed by a qualified cathodic
protection tester. See Chapter 11.
Tank tightness testing. This requirement may apply to Category 1 and 2 tanks in lieu of
weekly tank leak detection. See Chapter 9.
Line tightness testing. This requirement applies to piping connected to Category 1 and 2
tanks if weekly pipe leak detection is not performed. If these tanks have “safe suction”
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Records from
any repairs
made to your
tank system
must be kept
until your
system is
permanently
closed or
undergoes a
change in
service.
systems, then tightness testing is only required every three years. Testing must be
performed by a certified tester. See Chapter 10.
Note that:
Cathodic testing reports must be retained for three years.
Tank and piping tightness test reports must be retained until the next tightness test.
Test reports must be made available within three days of a request by DEC.
It is also a good practice to test your shear valves annually.
16.3 Maintenance and Repairs
All of the equipment within your tank system should be properly installed and maintained.
Maintenance is essential to prevent spills and to prolong the life of your system.
You must ensure that repairs to your tank system will prevent releases of product due to
structural failure or corrosion. Repairs made to your tank system must be conducted in
accordance with one of the codes of practice listed in the PBS regulations. In addition, any
repairs to your cathodic protection system or leak detection equipment should be completed by
certified technicians.
A tightness test may be required after repairs of tanks that do not have weekly leak detection
monitoring. A cathodic protection test is required within six months of repairs to a cathodically
protected tank system.
Keep good records. If you are conducting the necessary inspections and providing the proper
training, be sure these items are recorded and documented. Without records there is no way
to demonstrate compliance.
Records from any repairs made to your tank system must be kept until your system is
permanently closed or undergoes a change in service. Make sure that these records are
accessible at all times.
16.4 Reminder of Required Ongoing Activities for USTs
Use the checklists provided in this section as a resource to complete the required daily and
ongoing activities for your tank system. You should make them part of your regular routine.
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Chapter 16: Operation and Maintenance
Table 16.1: Daily Checklist
Daily Checklist- What to Do Each Day
Complete inventory reconciliation
Inspect and clean spill buckets
Look for any spills around the delivery area
Inspect leak detection equipment
Be sure your class C operators are trained
Verify that your impressed current cathodic protection is on (if
applicable:)
Stick your tank for water
You should also keep up with the ongoing activities needed to maintain your tank system (see
table, next page).
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Chapter 16: Operation and Maintenance
Table 16.2 Required Ongoing Activities
Required Ongoing Activities
Keep the proper records for these activities
Method Activity Minimum Frequency
Release Detection
Inventory
monitoring
Inventory measurements (ATG or manual) Daily
(Ch 8) Water measurements (ATG or manual) Daily
Measure dispensed fuel Daily
Measure the amount of fuel delivered Daily
Reconcile daily measurements Every 10 days
Check variance Every 10 days
Check for recurring accumulation of water Every 10 days
Tank Leak Weekly monitoring Weekly
Detection (Ch 9) Tank tightness testing Yearly
Piping Leak Weekly monitoring Weekly
Detection (Ch 10) Line tightness testing Yearly (every 3 years for
non-exempt suction
systems)
Cathodic Protection
Impressed Current Rectifier inspection Every 60 days
Impressed Current
and Galvanic
Cathodic protection test (performed by a
qualified cathodic protection tester)
Within 6 months of
installation and then
annually
Within 6 months of any
repairs and then annually
You should maintain your tank system in accordance with manufacturers’ recommendations.
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Chapter 16: Operation and Maintenance
16.5 Summary
Maintenance is essential to prevent spills and to prolong the life of your system. You
should establish a regular routine to inspect and maintain your tank system.
All of the equipment within your tank system should be properly installed and
maintained.
Repairs made to your tank system must be conducted in accordance with one of the
codes of practice listed in the PBS regulations.
Any repairs to your cathodic protection system or leak detection equipment should be
completed by certified technicians.
Records from any repairs made to your tank system must be kept until your system is
permanently closed or undergoes a change in service.
Compatibility
6 NYCRR 613-2.2(c)
Tanks, piping and
all components of
your UST system
must be compatible
with the product
stored.
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CHAPTER
17
A/B Tank System Compatibility 17.0
Underground storage tanks and piping systems may not be able to safely store all
types of petroleum products. With many new blended and alternative fuels on the
market, such as ethanol and biodiesel, it is more important than ever to verify that
your UST system and components are compatible with the types of product stored
at your site. Tank system compatibility can also be a problem when switching
between types of product stored.
Product that is not compatible with your system may degrade your tank, piping,
seals, gaskets and other components of the equipment and could result in product
being released into the environment.
17.1 Definition of Compatibility
All the components of the tank system must be compatible with a stored product.
The manufacturer certifies the product compatibility of the tank system
components. When product is used with system components that are not
compatible, it can cause the tank, piping, or system components to rust, soften,
weaken, or otherwise degrade. Some blends of gasoline, such as ethanol blends,
are more corrosive than others, and may require special materials or tank linings to
prevent the tanks from failing over time.
Because there are so many blends
and combinations of products, you
must know which products are
being delivered to your site. What
is the percentage of ethanol or
biodiesel? Has the product
delivered to your site changed or
are the products going to change?
Contact your supplier for specific
product information.
Figure 17.1: Is your UST system compatible with the product
you are storing?
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Chapter 17: Compatibility
Blends of
gasoline,
diesel and
other
petroleum
products
frequently
change.
17.2 Why Does Compatibility Matter?
Use of UST system equipment to store incompatible products or blends is not permitted. Using
incompatible equipment can cause equipment failure and result in releases into the
environment.
Ethanol
Ethanol has a corrosive effect on soft metals such as lead and galvanized zinc. It also has a
tendency to deteriorate or dissolve gaskets, alcohol-based glues, sealants, fittings, O-rings,
bushings, couplings and boots in your UST system. The components of your UST system were
built and designed for a certain level of ethanol in the product. Do not store a higher ethanol
blend than your system is designed to store. Also be aware that equipment that is compatible
with certain ethanol blends may not be compatible with all other ethanol blends. You should
confirm compatibility for your system before adding any blends to your tanks (see Section 17.4,
below).
In addition, system components such as overfill prevention and leak detection may need to be
calibrated for the specific ethanol blend you are storing, even if they are otherwise compatible
with a range of blend ratios.
Ethanol can also cause problems if water enters your UST system. The ethanol in your fuel
system will bond with water. If enough water is present in the fuel, phase separation of the fuel
and ethanol/water mixture can occur. The water/ethanol mixture leaves the fuel in the tank
without the proper ethanol blend. This reduces the octane of the fuel. Off-specification fuel is
illegal to sell and fuel mixed with water can damage vehicle engines.
Small amounts of water can enter your UST system through regular tank operation and
maintenance, for instance as a result of condensation of humid air. If enough condensation
occurs to cause a measureable accumulation of water in your tank, you may have a serious
problem. DO NOT ignore such accumulations, since they are likely to indicate a larger problem
that may result in equipment failure or spills.
Accumulated water can circulate through the piping system as well, because product is drawn
off the tank bottom, where water accumulates. If fuel is contaminated with water, then the
piping system must be flushed out to ensure that all contaminated product is removed.
Contaminated fuel and/or water must be properly managed and disposed.
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Chapter 17: Compatibility
Biodiesel
Like ethanol, biodiesel can degrade tank system components such as hoses, seals, and gaskets.
Biodiesel itself is less stable than regular diesel, and tends to break down when exposed to air,
water, and metals including copper, brass, bronze, lead, tin, and zinc. Exposure to water can
cause microbial growth in the fuel (bio-fouling) and make the fuel unfit for use. In addition,
water that accumulates in the bottom of the tank can cause metal tanks to rust. You should
confirm compatibility for your system before adding any blends to your tanks.
17.3 Types of Equipment Compatibility
All of the equipment in your UST system must be compatible with the type of product stored.
This includes:
tanks;
tank lining;
piping;
line leak detector;
ATG sensors and probes and floats;
STP (submersible pump) and components;
drop tube;
flexible connectors;
spill and overfill prevention equipment;
fill and riser caps;
dispensers;
product shear valves;
hoses and nozzles;
sealants (including pipe dope and thread sealant),
fittings, gaskets, O-rings, bushings, couplings and
boots; and
containment sumps (including tank top sumps and under-dispenser containment)
17.4 Steps to Confirm Compatibility
You are responsible for verifying that your system is compatible with the products you store. To
confirm compatibility of your components you may need to do one or more of the following:
Check that components are independently certified, such as equipment that is listed by
Underwriters Laboratory (UL), for use with your product. You should maintain this
equipment information onsite (e.g. in your Compliance Binder) or in a readily available
location.
Figure 17.2: Corroded STP
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Chapter 17: Compatibility
USTs and
components
MUST be
compatible
with the type
of product
stored
Confirm that you have a manufacturer’s written certification of product compatibility
that specifies the range of product compatibility.
Check the manufacturer’s installation instructions for your system and components.
You should maintain this information in your onsite documentation (e.g. in your
Compliance Binder).
Have your service technician or equipment supplier help determine the model and
manufacturer of your fuel system components and/or to help research your equipment
compatibility.
The installer or distributor can help you gather the proper information, but you should
document compatibility with information specifically from the manufacturer.
See Chapter 20 for links to additional resources.
17.5 When Does Compatibility Matter?
New tank systems should be designed for compatibility with the product to be stored. However,
blends of gasoline, diesel and other petroleum products frequently change. Before changing
products or introducing a new blend of product to your system, verify that the components of
the system are compatible with the product.
Use compatible parts and equipment for repairs or upgrades to your facility. Work with a
qualified service technician or engineer to make sure your new parts or components will be
compatible with the product stored.
17.6 Summary
Underground storage tanks and piping systems may not be compatible with all types of
products.
Using incompatible equipment can cause equipment failure and result in releases into
the environment.
The components of your gasoline UST system were built and designed for a certain level
of ethanol in the product. Do not store a higher ethanol blend than your system is
designed to store.
Use compatible parts and equipment for repairs or upgrades to your facility. Work with
a qualified service technician or engineer to make sure your new parts or components
will be compatible with the product stored.
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You are responsible for verifying that your system is compatible with the products you
store. Confirm tank system compatibility BEFORE storing a new/different product in
your UST. You should document compatibility with information from the manufacturer.
Training C Operators
6 NYCRR 613-2.5(d)(2)
It is the
responsibility of the
Class A and B
Operators to train
all Class C
Operators at their
site.
Class C Operators
must know what to
do in case of an
emergency, alarms
or spills.
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CHAPTER
18
A/B Training of Class C Operators 18.0
You should have a trained Class C Operator onsite any time your UST system is
operating and an A or B Operator is not present. Class C Operators are individuals
who have been trained to take appropriate actions in response to emergencies
and alarms caused by spills or releases from the UST system. Typically, these
operators are individuals who control or monitor the dispensing or sale of
petroleum. They must be trained by a Class A or B Operator BEFORE being
designated as Class C Operator. This training can minimize the risks and impacts of
petroleum leaks and spills.
Alternatively, the designated Class C operators can be:
Class A operators who also meet the Class C Operator requirements; or
Class B Operators (who are considered qualified to be Class C Operators
without further training).
The training should include appropriate responses to:
product spills and releases;
tank monitoring system alarms;
fire; and
other situations that pose an immediate danger to the public or to the
environment.
Since there are many types of registered facilities, there is no “one size fits all”
plan. Your facility is responsible for developing a site
specific emergency spill response plan and for training your
Class C Operators. There is little time to think when a spill
occurs. Your Class C Operator should understand your
facility’s plan and be ready to follow it immediately. The
plan should describe immediate steps to protect human
health and the environment. It should also provide contact
information for appropriate emergency personnel, spill
responders and Class A and B Operators. See Appendix A
for a sample contact information form.
Figure 18.1: Most Class C Operators will be store
clerks or the person monitoring fuel dispensing
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Post all
important
contact
information at
your site for
easy access by
Class CC
Operators.
Do NOT
neglect Class C
Operator
training. As a
Class A or B or
A/B Operator,
you will have
to rely on your
Class C
Operators
when you are
not onsite.
18.1 Training
Your Class C Operators will be the individuals watching over the UST system when you aren’t
around. Ask yourself: Will they know what to do in the event of a spill? An emergency? A leak
alarm? The proper response to alarms, spills and releases can minimize the risk to people and
the environment. Knowing what to do BEFORE an emergency occurs can make all the
difference. Class C Operators must be trained before they can be assigned operator duties.
If the training of a Class C Operator is meaningful and comprehensive, the operator will be
better equipped to respond and communicate in the event of a spill or emergency. Knowledge
of the UST system can help the Class C Operator communicate to responders what is happening
at the site. Typically, Class C Operator training should include the following:
1. Basic overview of UST system components:
A basic overview of the UST system components can help the Class C Operator assist
emergency response workers in the event of an emergency.
Class C Operators should generally know:
UST location, size, and type of product;
How the tanks are monitored for leaks. If you have an automatic monitoring system,
the Class C Operator should know where the control panel is. They should be able to
see and hear an alarm and know what to do if the alarm is activated;
Location of fire suppression pull station
(if present) and when to use it;
Location of emergency stop (if present)
and when to use it;
How breakaway valves work and who
to call to reconnect or replace them (if
present);
Location of spill response supplies and
how to use them, or who to call for
clean-up; and
Location of safety data sheets.
Figure 18.2: Class C operators need to be aware of the basic
system components. Class A or B operators should explain
the onsite equipment during training.
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Chapter 18: Training C Operators
Class C
Operators
should have an
understanding
of your UST
system to
better respond
during
emergencies.
Class C
Operators
should have an
emergency
contact list
posted and
accessible.
You may use the information, photos and drawings from Chapter 3 of this Guide in your training
program.
When training Class C Operators, take the time to familiarize them with the various tank system
components located at your site. It is important for an operator to know what they are seeing
and what the components do so that they can be better prepared to assist inspectors or
emergency responders.
2. Emergency Contact Information:
Class C Operators need to know whom to contact in the event of an emergency, leak, or
spill/release. If they cannot reach the Class A or B Operator, whom should they call next?
When should they call emergency responders (911)?
Figure 18.3: Tank top layout and side view. Explain your tank system to your Class C
Operator. Walk the operator around your site and show them the basic tank system
components.
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Provide your Class C Operators with a contact list. This list should include names,
job titles, phone numbers and whom to contact first, second and so on.
Make sure your Class C Operators know whom to contact and when. In an
emergency, if they cannot reach a Class A or B Operator they need to keep making
calls until they reach a responsible individual. Waiting “until tomorrow” or just
leaving a message with someone is NOT an adequate response.
3. How to respond to spills or emergencies:
Spills or leaks can happen at any time, not just while the Class A or B Operator
is onsite. You need to feel confident your Class C Operator is trained to
respond to emergencies correctly when you are not there to direct them.
Information you should consider including in your C Operator training includes
how to:
recognize spills, leaks, and emergency situations;
recognize leak alarms;
isolate spills and keep people away;
stop the flow of product if possible (many sites have an
emergency stop for this purpose);
activate the fire suppression system if appropriate;
contact the Class A or B Operator;
know when to contact emergency responders (911); and
locate and use the spill clean-up kit, and/or contact the appropriate clean-up
responder.
Class C Operators may be trained on how to use a spill kit for
small spills. This can keep the spill from getting worse. They
should also know how to stop the flow of product. Make sure
they know where the emergency shut-off switch or valve is
located.
Class C Operators should also know what to do in the event of
emergencies such as a:
broken dispenser hose;
spill during product delivery;
vehicle colliding with a dispenser or canopy; or
Figure 18.4: Spill kit. Do you have one
of these at your site? Do your
employees know where to find it?
Figure 18.5: Workers put spill absorbent on a
spill. Should your Class C Operators know how
to use absorbent in a spill situation?
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Chapter 18: Training C Operators
Training
records for
Class C
Operators
must be
available to
demonstrate
compliance.
First responses
are critical to
dealing with
spills and
emergencies.
Make sure
your Class C
Operator is
trained to
respond
properly to
emergencies.
fire.
If an alarm goes off when the Class A and B Operators are away from the site, the Class C
Operator should know what the alarm means and what to do. Alarms can include:
tank monitoring system alarms;
slow product flow; and
loss of prime for a suction system.
If you have a tank monitoring system, your Class C Operators should know where the panel is
and where your sensors are located. The should also have a basic understanding of what the
control panel does and what the lights, audio alarms and status read outs mean.
Finally, the Class C Operator should know where your facility stores its tank operation records.
The Class C Operator may need to produce these documents for DEC inspectors and emergency
responders. These records include:
compliance records (Compliance Binder);
operator training records; and
the last 30 days of leak detection records.
You must keep the last 30 days of leak detection records stored onsite and it is a good idea for
other records, as well. You should make sure all Class C Operators know where this information
is kept and keep the records accessible to them (not in a locked back room).
Before you sign off on your Class C Operator’s training, they must demonstrate that they
understand and can perform their duties. You can check their understanding by asking them
questions such as: “What should you do if the monitoring system alarm light goes on?” or “How
would you turn off the fuel flow in an emergency?” It is a good idea to ask similar questions
from time to time to make sure that your operators remember the emergency procedures.
18.2 Recordkeeping:
You must keep records showing that your Class C Operators have been trained. You must
provide the records to DEC, upon request, within three business days. Appendix G has a sample
training log you can use to record the training of the operators at the site. The log should
include:
Name of the operator;
Class of the operator;
Date the operator was designated as a Class C Operator;
Date the operator completed testing and/or training;
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Name and signature of trainer;
Name, address, and phone number of the trainer’s employer; and
Date of any retraining.
You must also keep operator records as long as the operator is designated at a facility and for
at least three years after they leave.
18.3 Summary:
First responses to spills and leaks are critical to reduce the potential for injuries and to
minimize releases to the environment. properly
Your Class C Operators must know what to do in case of an emergency. Your emergency
contact list should be posted where it is immediately accessible at all times.
Operators should never ignore an alarm or a spill. They should address the situation
immediately; waiting “until tomorrow” or just leaving a message with someone is NOT
an adequate response.
Class C Operators must be trained BEFORE they can be assigned operator duties.
You must maintain records of Class C Operator training.
Chemical Bulk Storage
6 NYCRR 596-599
Class A and B
Operators need to be
generally familiar with
requirements related
to bulk storage of
hazardous substances
in underground tanks.
CBS operators will
typically require
specialized training at
their facility in
addition to receiving
authorization as a
Class A and/or B
Operator.
adsfsadf
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CHAPTER
19
A/B Chemical Bulk Storage Requirements 19.0
In addition to regulatory requirements related to bulk storage of petroleum
products, all Class A and B Operators need to be generally familiar with
requirements related to bulk storage of hazardous substances in underground
tanks. This chapter describes some important chemical bulk storage (CBS)
requirements that differ from requirements for PBS facilities.
Operators who are authorized at CBS facilities should refer to regulations for
details of regulatory requirements applicable to their facility and to the particular
chemicals stored there. CBS operators will typically require specialized training at
their facility in addition to receiving authorization as a Class A and/or B Operator.
19.1 Definition of Hazardous Substance
As defined in the New York State CBS regulations (6 NYCRR 596-599), hazardous
substance means:
a substance included on the list provided under Part 597.3 of the CBS
regulations; or
a hazardous substance mixture.
A hazardous substance mixture means a:
a mixture of any hazardous substances as defined above; or
certain mixtures of petroleum and hazardous substances not otherwise
defined as petroleum.
Mixtures containing less than a total of 1% of any listed hazardous substances are
not subject to CBS regulations, though they may be subject to PBS or other
requirements. Mixtures containing any amount of hazardous waste are subject to
a different set of regulations. Part 597 provides more information on determining
whether a substance is subject to CBS requirements.
19.2 CBS Registration
Facilities with underground CBS tanks must be registered, regardless of the tank
size. Tanks must be registered prior to the delivery of a hazardous substance to
any tank system.
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Chapter 19: Chemical Bulk
Storage Requirements
Registrations
must be
renewed every
two years
The
manufacturer
or distributor
of a hazardous
substance
must provide
the tank
system owner
or operator
with technical
guidance and
recommended
practices for
its storage and
handling.
Reportable
quantities
have been
determined
for each listed
hazardous
substance.
Registrations must be renewed every 2 years (not 5 years, as for PBS facilities) until the facility
has been permanently closed, or ownership of the facility has been transferred. In most cases,
you must notify DEC at least 3 days prior to installing a new tank.
If ownership of the real property on which a facility is located is transferred, the new owner
must submit an application to register the facility within 30 days after the transfer.
Registration fees are assessed per tank and are based on the size of each tank. The fees per
tank range from $50 to $125 and there is a cap of $50,000 on the total registration fee for a
single facility.
19.3 Sale of Hazardous Substances
The manufacturer or distributor of a hazardous substance must provide the tank system owner
or operator with technical guidance and recommended practices for the storage and handling of
the substances purchased. Minimum requirements for this information are listed in the CBS
regulations at Part 596.4.
19.4 Inspections and Monitoring
Inspections and monitoring of underground CBS tank systems are similar to the requirements
for PBS systems, but there are some differences. Operators should refer to the regulations at
Part 598.6.
19.5 Spills and Releases
Reportable quantities have been determined for each listed hazardous substance and are listed
at 6 NYCRR 597.4. The following must be reported to DEC’s Spill Hotline within 2 hours:
1. the release of a reportable quantity that occurs within any 24 hour period;
2. the release of a quantity that is less than a reportable quantity if any of the following
conditions exist:
(a) such release results, or may reasonably be expected to result, in a fire with
potential off-site impacts;
(b) such release results, or may reasonably be expected to result, in an explosion;
(c) such release results, or may reasonably be expected to result, in a contravention
of air quality standards;
(d) such release results, or may reasonably be expected to result, in vapors, dust
and/or gases that may cause illness or injury to persons, not including persons in
a building where a release originates; or
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Chapter 19: Chemical Bulk
Storage Requirements
The owner or
operator of
any facility
must prepare
and maintain a
Spill
Prevention
Report (SPR)
for preventing
and
responding to
spills, releases
and accidents
at the facility.
(e) runoff from fire control or dilution waters may reasonably be expected to result
in or contribute to a contravention of water quality standards.
A release of a hazardous substance mixture is subject to the following reporting requirements:
1. If the quantity of the hazardous constituents of the hazardous substance mixture is
known, notification is required where a reportable quantity or more of any individual
hazardous constituent is released.
2. If the quantity of one or more of the hazardous constituents of the hazardous substance
mixture is unknown, reporting is required where the total amount of the mixture
released equals or exceeds the reportable quantity for the hazardous constituent with
the lowest reportable quantity.
It is not necessary to report a spill of a reportable quantity of a hazardous substance if all of the
following conditions are met:
1. there is control over the spill and it is completely contained;
2. the spill has not and will not reach the land or waters of the State;
3. the spill is cleaned up within two hours after discovery;
4. the total volume of the spill is recovered or accounted for; and
5. the spill will not result in any of the conditions requiring reporting (see list under first
paragraph of this section).
It is not necessary to report the release of a hazardous substance that is continuous and stable
in quantity and rate, provided that the person responsible for reporting the release submits to
DEC a duplicate of the written notification made to the United States Environmental Protection
Agency (EPA) pursuant to 40 CFR 302.8. This submission must be made at the same time as the
notification is submitted to the EPA.
19.6 Spill Response Plan and Annual Compliance Evaluations
The owner or operator of any facility must prepare and maintain a Spill Prevention Report (SPR)
for preventing and responding to spills, releases and accidents at the facility. The report must be
filed on the premises of the facility at all times and must be updated at least annually.
Requirements for the SPR are listed in Part 598.1(k) and additional guidance is provided in DEC’s
publication DER-26 / How to Prepare a Spill Prevention Report for a Chemical Bulk Storage
Facility. Some of those requirements differ from PBS requirements, including provisions for
secondary containment of product transfer areas, prevention of mixing incompatible
substances, and requirements for a pump and valve maintenance program.
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Chapter 19: Chemical Bulk
Storage Requirements
19.7 Other Requirements
Requirements for construction, installation, recordkeeping, maintenance, closure, financial
responsibility, delivery prohibition, and operator training for CBS tank systems are similar to the
PBS requirements, but many details may differ, and operators should refer to the applicable
sections of the CBS regulations.
19.8 Summary
In addition to regulatory requirements related to bulk storage of petroleum products, all
Class A and B Operators need to be generally familiar with requirements related to bulk
storage of hazardous substances in underground tanks.
CBS operators will typically require specialized training at their facility in addition to
receiving authorization as a Class A and/or B Operator.
Facilities with underground CBS tanks must be registered, regardless of the tank size.
Registrations must be renewed every 2 years (not 5 years, as for PBS facilities).
The manufacturer or distributor of a hazardous substance must provide the tank system
owner or operator with technical guidance and recommended practices for the storage
and handling of the substances purchased.
Reportable quantities have been determined for each listed hazardous substance.
However, releases of smaller quantities must be reported under certain circumstances.
Operators at CBS facilities must be familiar with the details of reporting requirements.
The owner or operator of any facility must prepare and maintain a Spill Prevention
Report (SPR) for preventing and responding to spills, releases and accidents at the
facility.
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CHAPTER
20
A/B References And Web Links 20.0
New York State Laws, Regulations, and Regulatory Guidance
Environmental Conservation Law Article 17, Title 10, Control of the Bulk Storage of
Petroleum.
6 NYCRR Part 613, Petroleum Bulk Storage regulations, October 11, 2015.
http://www.dec.ny.gov/regs/2490.html
PBS Registration Worksheet (to determine whether a facility must be registered)
http://www.dec.ny.gov/docs/remediation_hudson_pdf/pbsform.pdf
Petroleum Bulk Storage Application
http://www.dec.ny.gov/docs/remediation_hudson_pdf/pbsrenewal.pdf
PBS Bulk Storage Application Instructions
http://www.dec.ny.gov/docs/remediation_hudson_pdf/pbsinstr.pdf
DER-18 / Petroleum Bulk Storage – New Nonmetallic Underground Piping,
http://www.dec.ny.gov/regulations/2387.html
DER-25 / Petroleum Bulk Storage (PBS) Inspection Handbook (draft)
http://www.dec.ny.gov/regulations/2387.html
DEC Petroleum Bulk Storage Inspection Form. Note: As of late 2015, DEC was
updating this form – check for the most recent edition.
http://www.dec.ny.gov/regulations/2387.html
DEE-22 PBS Inspection Enforcement Policy
http://www.dec.ny.gov/regulations/2379.html
Article 12 of the Navigation Law Section 170 et. seq.
6 NYCRR Part 596-599, Chemical Bulk Storage regulations, October 11, 2015.
http://www.dec.ny.gov/regs/2490.html
Federal (EPA) Laws, Regulations, and Regulatory Guidance
40 CFR Part 280, Federal Underground Storage Tank regulations, United States
Environmental Protection Agency. October 13, 2015.
USEPA publications, available at http://www.epa.gov/oust/pubs/
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20
A/B USEPA, Musts For USTs: A Summary Of Federal Regulations For Underground
Storage Tank Systems, EPA 510-K-95-002 July 1995] Note: As of late 2015, EPA
was updating this publication – check for the most recent edition.
USEPA, UST Systems: Inspecting and Maintaining Sumps and Spill buckets, EPA
510-R-05-001, May 2005
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Chapter 20: References and Web
Links
USEPA, Source Water Protection Practices Bulletin: Managing Above Ground
Storage Tanks to Prevent Contamination of Drinking Water: EPA 916-F-01-022,
July 2001
USEPA, Automatic Tank Gauging Systems For Release Detection Reference
Manual For Underground Storage Tank Inspectors, EPA 510-B-00-009, August
2000
USEPA, Doing Inventory Control Right For Underground Storage Tank Inspectors,
EPA 510-B-93-004, November 1993
USEPA, Straight Talk on Tanks Leak Detection Methods for Petroleum
Underground Storage Tanks and Piping, EPA 510-B-05-001, September 2005
USEPA, Introduction to Statistical Inventory Reconciliation for Underground
Storage Tanks, EPA 510-B-95-009, September 1995
USEPA, Volumetric Tank Testing: An Overview , EPA 625-B-89-009, April 1989
Standards
Underwriters Laboratories, 2600 N.W. Lake Rd., Camas, WA 98607-8542
http://www.ul.com/global/eng/pages/]
Underwriters Laboratories of Canada, 7 Underwriters' Road, Toronto, Ontario,
Canada M1R 3B4 [http://www.ul.com/canada/eng/pages/]
American Petroleum Institute, 1220 L Street NW, Washington, DC 20005-4070
[http://www.api.org/Standards/]
Steel Tank Institute, 944 Donata Ct., Lake Zurich, IL 60047
[https://www.steeltank.com]
National Association of Corrosion Engineers, 1440 South Creek Drive, Houston, TX,
USA 77084-4906
[http://www.nace.org/content.cfm?parentid=1001¤tID=1001&CFID=2314675
&CFTOKEN=64165521]
National Fire Protection Association (NFPA),1 Batterymarch Park, Quincy, MA 02169-
7471 [http://www.nfpa.org]
Other References
American Petroleum Institute’s Worksafe Service Station Contractor Safety
Qualification Program may be found on their website: [https://worksafe.api.org]
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Chapter 20: References and Web
Links
National Working Group on Leak Detection Evaluations (NWGLDE) List of Leak
Detection Evaluations for Storage Tank Systems
[http://www.nwglde.org/downloads.html]
New England Interstate Water Pollution Control Commission publishes LUSTLine, a
national bulletin on underground storage tanks: [http://www.neiwpcc.org/lustline/]
(free online)
Petroleum Equipment Institute, [http://www.pei.org/]
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Appendix A
Sample Emergency Contact Placard
Note: this form is an example for reference only. Each facility is responsible for preparing a form that will meet their individual
requirements. You MUST customize the form with the appropriate procedures and contact information for your site.
EMERGENCY PETROLEUM SPILL PROCEDURES
New York State Dept. of Environmental Conservation: Tank IQ: Appendix A October 2015
Facility Name DEC PBS #
Facility Address (street address, town, state, and zip code)
Primary Emergency Coordinator
Back-up Emergency Coordinator
Cell phone number Cell phone number
Other phone number(s) Other phone number(s)
Fire Department Telephone
Location of Tank System Emergency Stop (E-stop)
Location of Fire Extinguishers and/or Fire Suppression Pull Station (be specific)
Location of Spill Control Materials (be specific)
Corporate Emergency Call Center
NYS SPILL “HOTLINE”
1-800-457-7362
Local Health Department
Spill Response Contractor Name and Phone number
EMERGENCY ASSEMBLY POINT (employees to meet here if evacuated from the building):
__________________________________________________________________________________________________
IN THE EVENT OF A SPILL EMERGENCY
Activate the Emergency Stop Call the Emergency Coordinator(s)
Stop using the underground storage tank system Call Spill Response Contractor if directed by
Emergency Coordinator
Call 911 if needed Investigate the discharge source and control if
safe to do so
Mitigate any fire, safety or health hazards arising
from the release
Notify NYSDEC within two hours of discovering
the spill
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Appendix B
Sample Ten day Inventory
Reconciliation form
10-DAY INVENTORY RECONCILIATION WORKSHEET FOR METERED USTs
Facility Name: PBS Number:
Address: Tank ID No:
Product Stored:
Inventory record for period from _____/_____/_____ to _____/_____/_____
D D START STICK GALLONS GALLONS BOOK END STICK DAILY OVER (+)
A A INVENTORY DELIVERED PUMPED INVENTORY INVENTORY or SHORT (-) WATER
Y T [A] [B] (END - BOOK)
E (GALLONS) (GALLONS) (GALLONS) (GALLONS) (INCHES) (GALLONS) [B] - [A] (INCHES)
1 (+) (-) (=)
2 (+) (-) (=)
3 (+) (-) (=)
4 (+) (-) (=)
5 (+) (-) (=)
6 (+) (-) (=)
7 (+) (-) (=)
8 (+) (-) (=)
9 (+) (-) (=)
10 (+) (-) (=)
L Is the TOTAL GALLONS OVER/SHORT LARGER than the ALLOWABLE VARIANCE? (circle one) YES (see below*) NO
L Is there an INCREASE/FLUCTUATION/RECCURENCE of water in the bottom of the tank? (circle one) YES (see below*) NO
* If you answered YES above, if the TOTAL GALLONS OVER/SHORT is LARGER than the ALLOWABLE VARIANCE, or if there
was an INCREASE/FLUCTUATION/RECCURENCE of water in the bottom of the tank – in accordance with 6 NYCRR Part 613.4(d),
the operator MUST initiate an investigation into possible causes. If WITHIN 48 HOURS the cause CANNOT be explained by inaccurate
recordkeeping, temperature variations, or other factors not related to leakage, the operator MUST notify the owner and the New York
State Department of Environmental Conservation (SPILL HOTLINE: 1-800-457-7362). The tank MUST be taken temporarily out-of-
service in accordance with Part 613.9(a) UNTIL such time that inspections and/or tightness tests are performed, the cause is determined
and necessary repairs or replacements are made.
EXPLANATION OF EXCEEDANCE OF ALLOWABLE VARIANCE
Cause determined to be:
Describe required action taken (i.e., inspection/repairs/tests, etc.) on / / (date):
TOTAL GALLONS
DELIVERED
TOTAL GALLONS
PUMPED
TOTAL TANK
VOLUME
TOTAL
GALLONS
OVER / SHORT
× 0.0075 =
At the end of the 10-day period, determine which of the above totals is the LARGEST
(TOTAL GALLONS DELIVERED, TOTAL GALLONS PUMPED or TOTAL TANK VOLUME)
and enter the number into the box below to calculate the ALLOWABLE VARIANCE.
(DROP SIGN)
ALLOWABLE
VARIANCE
COMPARE
THESE
TWO
NUMBERS
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Appendix C
Sample Manual Tank Gauging
Worksheet
Note: this form is an example for reference only. Each facility is responsible for preparing a form that will meet their individual requirements.
Start Test
(month, day,
and time)
First
Start
Stick
Reading
(inches)
Second
Start
Stick
Reading
(inches)
Average
Start
Stick
Reading
(inches)
Average Start
Gallons
(convert
inches to
gallons)
[a]
End Test
(month,
day,
and time)
First
End
Stick
Reading
(inches)
Second
End
Stick
Reading
(inches)
Average
End
Stick
Reading
(inches)
Average
End
Gallons
(convert
inches to
gallons)
[b]
Change in
Tank Volume
(gallons)
[a – b]
Show minus
sign if less
than zero
Tank Passes
Test*
(circle
YES or NO)
Date:
Time:
AM/PM
Date:
Time:
AM/PM
Y N
Date:
Time:
AM/PM
Date:
Time:
AM/PM
Y N
Date:
Time:
AM/PM
Date:
Time:
AM/PM
Y N
Date:
Time:
AM/PM
Date:
Time:
AM/PM
Y N
Add the 4 weekly changes in tank volume
Divide the sum by 4 and enter result here.
Compare the result to the monthly
standard (ignore any minus sign).
Y N
MANUAL TANK GAUGING RECORD
6 NYCRR 613-2.3
DEC PBS # Year Tank ID
CIRCLE your tank size, test duration, and weekly/monthly standards in the table
below:
Completed by (name)
Facility name and address
Tank Size
Minimum Test Duration (hours)
Weekly Standard 1 test (gallons)
Monthly Standard 4-test average (gallons)
Compare your weekly readings and the monthly average of the 4 weekly
readings with the standards shown in the table on the left.
If either the weekly or monthly standards have been exceeded, the UST
may be leaking. Follow your facility spill response plan, including reporting
to the DEC Spill Hotline, 1-800-457-7362.
Keep this record for at least three years.
Up to 550 gallons 36 10 5
551-1000 gallons
(when tank diameter is 64”) 44 9 4
551-1000 gallons
(when tank diameter is 48”) 58 12 6
New York State Dept. of Environmental Conservation (DEC): Tank IQ: Appendix C October 2015
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Appendix D
Sample Monthly Automatic Tank
Gauge Operability worksheet
Note: this form is an example for reference only. Each facility is responsible for preparing a form that will meet their individual requirements.
New York State Department of Environmental Conservation (DEC): Tank IQ: Appendix D October 2015
In- Tank (Auto Tank Gauge) Monitoring System Log
New York tank systems registered with “in-tank system (auto tank gauge)” as their leak detection method must pass a 0.2 gallon per hour (gph)
leak test at least once each month. Use this form to record your test results. Also note whether the monitoring system is showing a leak alarm. If
your monitoring system is not operating, shows a leak alarm, or fails to pass a leak test you must report a possible spill to the NYS Spill Hotline
unless the equipment is found to be defective, is IMMEDIATELY repaired or replaced, and additional monitoring does not indicate occurrence of a
leak.
SPILL HOTLINE NUMBER: 1-800-457-7362
DEC PBS #: Owner/Operator:
Facility Name:
Facility address (street, city, state, zip code):
Date Operational
Y/N
Leak Alarm
Y/N
Passes 0.2 GPH Test
Y/N
Action
(Required for non-operational system, alarm, or
failed test)
Signature of person
performing test
Yes / No Yes / No Yes / No
Yes / No Yes / No Yes / No
Yes / No Yes / No Yes / No
Yes / No Yes / No Yes / No
Yes / No Yes / No Yes / No
Yes / No Yes / No Yes / No
Yes / No Yes / No Yes / No
Yes / No Yes / No Yes / No
Yes / No Yes / No Yes / No
Yes / No Yes / No Yes / No
Yes / No Yes / No Yes / No
Yes / No Yes / No Yes / No
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Appendix E
Sample 60-Day Impressed Current
Rectifier Inspection Form
Note: this form is an example for reference only. Each facility is responsible for preparing a form that will meet their individual requirements.
New York State Department of Environmental Conservation (DEC) Tank IQ: Appendix E October 2015
IMPRESSED CURRENT CATHODIC PROTECTION SYSTEM: 60-Day Inspection Log. Complete at LEAST every 60 days.
DEC PBS #: Rectifier design volts: Rectifier design amps:
Facility Name 90% design volts: 90% design amps:
Facility address: (street, city, state, zip code): 110% design volts: 110% design amps:
Location of Rectifier at facility:
NOTE: If a rectifier is turned on and the Volts and/or Amps readings are zero, or if any answer in the last three columns is “No”, immediately contact a
cathodic protection tester or expert to repair the cathodic protection system
Year: Date
Inspected
# Days
since last
Inspection
Inspector
Initials
Rectifier
Turned
On?
Rectifier DC
Output
Rectifier Clock
Reading
(Hours)
Volts between
90-110%
design?
Amps
between 90-
110% design?
(Hours since last
reading)/24=
days since last reading? Volts Amps
January
February
March
April
May
June
July
August
September
October
November
December
Date of any repairs Description of Repairs
Keep this record for at least 3 years (per 6 NYCRR 613-2.3).
Note: this form is an example for reference only. Each facility is responsible for preparing a form that will meet their individual requirements.
New York State Department of Environmental Conservation (DEC) Tank IQ: Appendix E October 2015
Instructions for completing the Impressed Current Cathodic Protection System 60-Day Inspection Log
If you have an impressed current cathodic protection system, the system rectifier must be inspected every 60 days. To perform the 60-day test inspection:
Rectifier design volts (or amps): Record the “design” volts and amps. These are the volts and amps recorded when the system was installed. There should be a
sticker on your rectifier stating the voltage and amps recorded at installation.
90% design volts (or amps) and 110% design volts (or amps): Record the 90% and 110% volts and amps. To calculate: multiply design volts by 0.90 to get 90%
volts, then multiply design volts by 1.10 to get 110% volts. Do the same for amps.
Make sure all facility information is filled in on the form.
Date Inspected: Record the date.
# Days since last Inspection: Calculate the number of days since the last inspection (should be no more than 60 days). For the first reading on this sheet, refer to
the prior inspection sheet. Remember that some months have less than 31 days.
Initials: Enter your initials
Rectifier turned on? Check to make sure your rectifier is on and record Y (yes) or N (no). If the rectifier is turned off, your tank is not protected, and your facility
may be in non-compliance with New York State regulations at 6 NYCRR 613. Be sure that facility employees know that they must not turn off the rectifier or
the circuit breaker that controls it.
Rectifier DC Output: Record the volts and amps shown on the voltmeter and ammeter display
Rectifier clock hours: Record the number of hours of operation from the clock.
Volts (or amps) between 90-110% design? Compare the volts (or amps) you recorded to the 90% and 110% volts (or amps). If the value you recorded is greater
than the 90% value and less than the 110% value, then enter “Y” (yes). Otherwise enter “N” (no).
(Hours since last reading)/24=days since last reading? Subtract the last clock reading from today’s clock reading. Divide that number by 24 to get the number
of days the rectifier was on (round the number to the ones place). Compare it to the number of days since the last inspection. If they are the same, enter
“Y” (yes). If not, enter “N” (no).
If a rectifier is turned on and the volt and/or amp reading recorded is zero, or if any answer in the last three columns is “No”, immediately contact a cathodic
protection tester or expert to repair the impressed current cathodic protection system.
File your inspection report with your tank records and maintain it for at least 3 years.
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Appendix F
Sample Maintenance Record Log
Note: this form is an example for reference only. Each facility is responsible for preparing a form that will meet their individual requirements.
New York State Dept. of Environmental Conservation: Tank IQ: Appendix F October 2015
Petroleum Bulk Storage Tank Maintenance Record
Petroleum bulk storage facilities (PBS) registered in New York State must keep records of repairs to their tanks. Keeping accurate and complete
records will help facilities maintain their tanks, prepare for inspections, and stay in compliance with PBS regulations. Records for each tank must
be maintained until the tank is permanently closed or undergoes a change in service, and must be made available to the NYS Department of
Environmental Conservation (NYSDEC) upon the Department’s request. (Reference: 6 NYCRR 613-1.5)
DEC PBS #: Owner/Operator:
Facility Name:
Facility address (street, city, state, zip code):
Tank ID: Product stored: Volume:
Date
mm/dd/yyyy
Repair description: state reason and type of repair. State
where technician reports and invoices are filed.
Repair performed by
Reported
by (Name)
Company:
Name of repairer:
Phone #:
Address:
Company:
Name of repairer:
Phone #:
Address:
Company:
Name of repairer:
Phone #:
Address:
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Appendix G
Sample Training Log
Note: this form is an example for reference only. Each facility is responsible for preparing a form that will meet their individual requirements.
New York State Department of Environmental Conservation (DEC) Tank IQ: Appendix G October 2015
C Operator – PBS/CBS Underground Storage Tank Training Record
Facility Name______________________________________________________ DEC PBS # ______________________________________
Facility Owner _____________________________________________________ Facility phone # _________________________________
Address (street, city, state, zip) _______________________________________________________________________________________
Name of C Operator (print): _______________ ______ _
is designated as a Class C Operator for the underground storage tanks at this facility. This person has received training from the Class A or B
operator listed below, and understands the Class C Operator MUST:
have specific knowledge of this facility’s emergency procedures and alarm response procedures.
immediately and properly respond to alarms and other indications of emergencies caused by leaks or releases from underground
storage tank systems.
List location of written emergency procedures for this facility, including C Operator responsibilities: _____________________________
C Operator was trained by (A or B Operator Contact Information):
Name (print):____________________________________________________________________________________________________
Title/Department: ________________________________________________________________________________________________
NYSDEC Authorization #_________________ Class A or B (Circle One or Both)
Address:________________________________________________________________________________________________________
Phone: ________________________________________________ Secondary Phone: _________________________________________
Email: _______________________________________________________________________
Signature: ____________________________________________________________________
Date of C Operator training completion: _________________ Date operator assumed duties: ______________ Retraining: _______________
Keep this record for as long as the above Operator performs C Operator duties at this facility, and for at least three years thereafter.