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ENVIRONMENTAL SURVEY UPDATE ARTICLES
ABOVEGROUND STORAGE TANKS (ASTs)
NEW REQUIREMENTS IN
EFFECT
by Larry Bily, CHMM
On October 11, 2000, several new requirements went into effect for both Small
and Large Aboveground Storage Tanks. These requirements affect ASTs that store
more than 250 gallons of regulated substances - e.g. mixtures or solutions that
when released into the environment, present a substantial danger to the public
health, welfare or the environment.
SMALL ABOVEGROUND STORAGE TANKS
Existing Requirements
Prior to the new requirements, operators of a Small AST (21,000 gallons or
less) had to comply with the following existing requirements:
• Monthly leak detection
• Appropriate security
• Tank system labeled or marked
• Monthly maintenance and operations check (documented and retained
for 12 months)
New Requirements
The following additional requirements for Small ASTs went into effect on
October 11th:
-
Emergency containment - the tank must have an emergency containment system
that will be capable of retaining the total volume of the release for a
minimum of 72 hours, and until the release can be detected and
recovered.
-
The emergency containment system is most often met with a diking system or
with a fabricated tank containment system.
- The suitability of the emergency containment system
will depend on how often the containment is checked for a release and on the
facility’s response capabilities.
- A certified DEP inspector shall perform an inspection
of the containment system when an in-service inspection is required on the
AST.
An in-service inspection is required on tanks greater than 5,000 gallons, or
on tanks greater than 1,100 gallons that store a highly hazardous substance,
according to the following schedule:
New tanks installed after 10/11/97 - within ten years
- Existing tanks installed between 10/11/87 and 10/11/97 - within ten years
after installation or 10/13/02, whichever is later.
- Existing tanks installed before 10/11/87 - by 10/11/02.
In the future, Small ASTs will be required to have secondary containment for
leak detection by October 11, 2007.
LARGE ABOVEGROUND STORAGE TANKS
Existing Requirements
Before October 11th, operators of a Large AST (more than 21,000 gallons) had
to comply with the following requirements:
• Spill Prevention Response Plan
• Monthly leak detection
• Appropriate security
• Tank system labeled or marked
• Written maintenance and operations
• Maintenance of required records
• In-service inspection at least every five years or less based on
corrosion rates
New Requirements
The following additional requirements for Large ASTs went into effect on
October 11th:
The tank shall have a gauge or monitoring device which must:
- Clearly and accurately show the level in the tank;
- Be visible to the person responsible for product deliver; and
- Be installed, calibrated and maintained according to manufacturer's
specifications.
Perform an out-of-service inspection for tanks over ten years old with
unknown corrosion rates.
Future additional requirements for Large ASTs are not associated with
specific dates, but are to be implemented in conjunction with major repair work:
- Install a high-level alarm with either an automatic or a manual product
shutdown at the next out-of-service inspection or major tank
modification.
- Provide emergency containment meeting regulatory technical requirements by
the next out-of-service inspection.
- Install secondary containment under the tank when the floor is
replaced.
- Complete an additional
out-of-service inspection within 1/2 of the tank’s corrosion rate life, with
a maximum inspection interval of twenty years.
EXEMPTIONS
None of the previously discussed requirements apply to several categories
of storage tanks. The most common exemption is for tanks that store heating
oil used on the premises. There are several types of heating oil, but the key
factor is that the delivery ticket MUST say "heating oil".
Another exemption is for tanks with a capacity of 1,100 gallons or less
which store motor fuels for non-commercial purposes (not for resale).
RECENT DEP ACTION
Interim Policy
The DEP’s Bureau of Watershed Conservation released an interim policy for
implementing their permit strategy for ASTs. The focus of this policy is the
General Operating Permit process for large ASTs and small ASTs with capacities
greater than 1,100 gallons containing highly hazardous substances.
The Division of Storage Tanks will provide written notices to owners of
large ASTs who DEP records indicate have facilities that have incomplete
information or lack inspection information in the DEP data system. The General
Operating Permit program will be implemented over the next 18 months and will
provide information the DEP needs to determine compliance with the upgrade,
inspection and operational requirements.
Planned Implementation Priority
DEP plans to use the following categories to prioritize policy
implementation:
- Facilities with ASTs larger than 1,000,000 gallons.
- Facilities with 12 or more ASTs.
- Facilities with large hazardous substance ASTs.
- Large AST terminal facilities.
- Non-responders to AST notice letters.
- Highly hazardous substance ASTs. All other AST facilities.
The process will continue until all 570 facilities requiring permits have
been permitted.
if you have any questions, please call Larry Bily at 610-265-1510.
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