Amendments and Additions to North Carolina's Underground Storage Tank Rules

1
Amendments and Additions to North Carolina's
Underground Storage Tank Rules

• Title 15A North Carolina Administrative Code
  Subchapter 2N (15A NCAC 2N)
• Criteria and Standards Applicable to Underground
  Storage Tanks

2
Introductions

• Ruth Strauss, Permits Inspection Branch
  Supervisor, ruth.strauss_at_ncmail.net
• Michael Phelps, UST Inspector Supervisor,
  michael.phelps_at_ncmail.net
• Matt Wegner, Environmental Engineer,
  matt.wegner_at_ncmail.net
• Andria Merritt, Hydrogeologist,
  andria.merritt_at_ncmail.net

3
Logistics

• Please turn off cell phones/pagers
• Agenda
• Restrooms
• Handouts
• Slides
• UST-6 Form
• Synopsis of new requirements
• FAQ
• Inspector Map

4
As of November 1st, 2007...

• The changes affect
• New installations
• Replacements on existing systems
• Notification requirements

5
?
FAQ
Q Why are these changes being implemented?
A In response to North Carolina General Statute
143-215.94T and the Federal Energy Policy Act of
2005 secondary containment option.
6
New Performance Standards

• Tanks
• Piping
• Associated components (e.g., dispensers,
  submersible pumps)
• Containment sumps
• Spill buckets
• Siting for replacement systems
• Operation and maintenance
• Emergency generator tanks
• Replacements

Apply to...
7
New Performance Standards

• Vent lines
• Vapor recovery lines
• Gravity-fed vertical fill ports

Do not apply to...
8
Tanks

• Non-corrodible
• Fiberglass reinforced plastic (FRP),
• Steel clad w/FRP or polyurethane, or
• Jacketed steel tanks

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Tanks (contd)

• Double-walled w/continuous interstitial
  monitoring
• (Must maintain 12 months of monthly printed
  records of release detection results and alarm
  history)
• Vacuum
• Pressure
• Hydrostatic

10
Piping

• Non-corrodible
• Double-walled
• Locatable once installed
  (e.g.,
  trace tape commonly used by utilities)

11
Piping (contd)

• Continuously monitored
• (Must maintain 12 months of monthly printed
  records of release detection results and alarm
  history)
• Vacuum,
• Pressure,
• Hydrostatic, or
• Electronic liquid-detecting sensor in sump that
  piping interstice drains to with primary and
  secondary wall integrity test every three years

12
Piping (contd)

• Also
• Pressurized piping must still have Automatic Line
  Leak Detectors (ALLDs)
• Suction piping, including European, and siphon
  bars must meet new standards
• Flexible connectors and fittings not
  double-walled must be in monitored containment
  sumps

13
FAQ
?
Q Do the new regulations affect siphon bars on
manifolded tanks?
A Yes, siphon bars are considered piping and
must be constructed of double-walled,
non-corrodible materials and monitored
continuously, just like all other piping.
14
Associated Components
Secondary containment w/interstitial monitoring
(Must maintain 12 months of monthly printed
records of release detection results and alarm
history)

• Underground ancillary equipment
• Dispensers
• Line leak detectors
• Submersible pumps
• Remote fill pipes, etc.

15
FAQ
?
Q What are the options for secondary containment
and monitoring of the associated components
listed?
A Typically, containment sumps with sump sensors
are used for every non-tank component and under
dispenser containment for dispensers.
16
Containment Sumps

• Designed, constructed, installed, and maintained
  to prevent water infiltration
• Visually inspected annually
• Non-corrodible

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Containment Sumps (contd)

• Monitored continuously
• (Must maintain 12 months of monthly printed
  records of release detection results and alarm
  history)
• Vacuum,
• Pressure,
• Hydrostatic, or
• Electronic liquid-detecting sensor no more than
  two inches from sump bottom with integrity test
  every three years

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FAQ
?
Q Do containment sumps need to be double-walled
with interstitial monitoring?
A No - As stated earlier, sumps are excluded
from the secondary containment requirement. Sumps
are considered to be the secondary barrier for
single-walled components.
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Spill Buckets

• Non-corrodible OR isolated from backfill
• Prefabricated
• Double-walled
• Designed, constructed,
• installed, maintained to
• prevent water infiltration

20
Spill Buckets (contd)

• Monitored continuously
• (Must maintain 12 months of monthly printed
  records of release detection results and alarm
  history)
• Vacuum,
• Pressure,
• Hydrostatic, or
• Electronic liquid-detecting sensor with integrity
  test every three years

21
FAQ
?
Q Will a single-walled spill bucket placed
inside a continuously monitored containment sump
satisfy the new requirements?
A Yes - It would be secondarily contained and
continuously monitored by a sump sensor.
22
Siting For UST Systems
Installations of new and replacement systems
prohibited

• In contact with contaminated soil or free product
• Within 100 feet of well serving public water
  system
• Within 50 feet of any other well (human
  consumption)

23
Emergency Generator UST Systems

• Must comply with the new performance standards
  including secondary containment and interstitial
  monitoring

24
Replacements

• Underground storage tanks
• UST can not be connected to piping that does not
  meet new standards

• Dispensers
• Add under dispenser containment with
• continuous monitoring if the connecting
  equipment is also being replaced

25
FAQ
?
Q What if a dispenser is knocked over by a
reckless driver or a severe storm, such as a
hurricane?
A If an existing dispenser is replaced and the
equipment used to connect the dispenser to the
UST system is replaced, then under dispenser
containment must be added.
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Replacements (contd)

• Piping (including extensions)
• Entire piping run must meet
• new standards
• Flex connectors, submersible pumps, other
  ancillary equipment
• Add containment sumps with continuous monitoring

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Summary of Periodic Testing Requirements

• Sumps (monitored by liquid-detecting sensors)
• Integrity test every three years, maintain most
  recent test
• Visually inspect annually, empty water/regulated
  substance within 48 hours of discovery
• Maintain results of most recent
• visual inspection

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Summary of Periodic Testing Requirements

• Piping (that drains to monitored sumps)
• Integrity test of primary and secondary walls
  every three years
• Maintain results of most recent test
• Spill Buckets (monitored by liquid-detecting
  sensors)
• Integrity test of primary and secondary walls
  every three years
• Maintain results of most recent test

29
Summary of Periodic Testing Requirements

• Interstitial monitoring sensors
• Checked annually for operability, proper
  operating condition and proper calibration
• Maintain results of most recent check
• Overfill
• Checked annually for operability and proper
  operating condition
• Maintain results of most recent check
• ALLDs
• Annual functionality test
• Maintain results of most recent test

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New Notification Requirements

• Effective September 21, 2007
• Applies to new installations of
• Tanks
• Piping (including extensions to existing piping)
• Tanks and piping
• Does not apply to new installations of only
• Spill buckets
• Under dispenser containment
• Containment sumps

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New Notification Requirements
OLD PROCESS
UST-8
UST-6
Installation
Pre-Installation
Post-Installation
UST-6 Notice of Intent to Install Underground
Storage Tanks UST-8 Notification for
Activities Involving Underground Storage Tank
Systems (USTs)
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New Notification Requirements
X
OLD PROCESS
UST-8
UST-6
Installation
Pre-Installation
Post-Installation
UST-6 Notice of Intent to Install Underground
Storage Tanks UST-8 Notification for
Activities Involving Underground Storage Tank
Systems (USTs)
33
New Notification Requirements
NEW PROCESS
UST-6B
UST-6A
Installation
Pre-Installation
Post-Installation
UST-6A Application to Install or Replace
Underground Storage Tank Systems
(Pre-Installation) UST-6B Application to
Install or Replace Underground Storage Tank
Systems (Post-Installation)
34
New Notification Requirements
NEW PROCESS
UST-6B
UST-6A
Installation
Pre-Installation
Post-Installation
UST-6A REVIEW
35
New Notification Requirements
NEW PROCESS
UST-6B
UST-6A
Installation
Pre-Installation
Post-Installation
TWO INSTALLATION INSPECTIONS
36
New Notification Requirements
NEW PROCESS
UST-6B
UST-6A
Installation
Pre-Installation
Post-Installation
UST-6B REVIEW PERMIT ISSUED
37
New Notification Requirements
NEW PROCESS (contd)
UST-8
UST-8 Form Notification for Activities Involving
Underground Storage Tank Systems (USTs)

• Used for all other notifications such as
• Putting UST systems into temporary closure
• Changing product stored
• Changing leak detection method

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New Notification Requirements

• Three phases
• Pre Installation
• Installation
• Post Installation

39
Pre Installation

• 30 days in advance you must submit
• UST-6A form
  "Application to Install or Replace
• UST Systems (Pre-Installation)
• UST system design plans
• prepared by a NC Professional
• Engineer
• Schedule of materials
• Scale drawings

40
Pre Installation (contd)

• Schedule of Materials (e.g., make and model)
• Tanks
• Piping
• Dispensers
• Leak detection equipment
• Spill prevention equipment
• Overfill prevention equipment
• Vapor recovery equipment

41
Pre Installation (contd)

• Scale Drawing(s)
• No larger than 11 x 17
• Must show the proposed locations of
• UST system features (USTs, piping, dispensers,
  vapor recovery, leak detection systems, etc.)
• Adjacent roadways
• Onsite structures
• Onsite water supply wells

42
Pre Installation (contd)
Incomplete applications will be returned and/or
delay the application process
Please read the instructions of the UST-6
carefully when submitting your UST-6A
43
?
FAQ
Q How long will it take for the State to review
the UST-6A and give approval to proceed with the
install?
A Forever.
44
?
FAQ
Q How long will it take for the State to review
the UST-6A and give approval to proceed with the
install?
A State rules require notification at least 30
days before installation however, the actual
review could take two weeks or less.
45
?
FAQ
Q What common mistakes/problems have been seen
on the UST-6 forms submitted so far?
A 1) Incomplete submittal of UST-6A form,
schedule of materials or scale
drawing 2) Conflicting information 3) Incorrect
model numbers for equipment 4) Poor copies /
legibility
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Installation

• If UST system design is satisfactory
• State issues an approval to construct letter
• including the name and contact information
• of your UST inspector
• Installation may begin
• Two inspections are
• required during installation

47
Installation Inspections

• First Inspection
• Exterior tank surface inspection
• Tank integrity testing prior to placing tank
  into excavation
• Second Inspection
• Testing of all piping and fittings prior to
  back-filling
• Contact UST inspector at least 48 hours in
  advance, not including weekends or holidays.
  Installation cannot proceed until inspection has
  been conducted.

48
Installation Inspections (contd)

• Tank, piping, and equipment information
• Installer information for everyone installing
• Certification type
• Certificate issuer
• Certification number
• Certification date
• Approval for fuel delivery to perform final
  system testing

49
Installation (contd)

• Installers must
• Adhere to manufacturer installation instructions
• Ensure that all personnel installing equipment
  are certified, if offered by manufacturer
• Properly set up sensor locations in monitoring
  console and provide descriptive labels

50
Installation (contd)

• Installers must
• Refer to most recent versions of industry codes
  API 1615, PEI RP100, ANSI B31.3 and B31.4

Be Aware Ball float valves should not be used
for overfill if UST system receives pressurized
deliveries, has suction piping, or has coaxial
stage 1 vapor recovery
51
Summary of Installation Testing Requirements

• Tanks
• Tightness of interstice prior to placement in pit
• Post-Installation tightness test
• Piping
• Before backfilling, air/soap test
• Monitor throughout site construction
• Post-Installation line tightness testing of the
  primary and interstitial spaces

52
Summary of Installation Testing Requirements

• Ancillary Equipment
• Sump and spill bucket integrity tests, after
  assembly but before backfill
• Operability of overfill prevention equipment
• Operability of sensors
• ALLD tests

53
Post Installation

• Submit
• UST-6B form, Application to Install or Replace
  UST Systems
• UST-20 form, Alternative Fuel Compatibility
  Checklist (If applicable)
• UST-15A form, Ownership of UST System(s)
• Appropriate annual operating fees
• Proof of Financial Responsibility
• Certification of Financial
  Responsibility form

54
Post Installation (contd)

• The UST-6B application requires
• Completed manufacturer installation checklists
  for the tanks, piping, and any other applicable
  equipment
• Pre- and post-installation tests of tanks and
  piping
• As-built scale drawings
• (Note Incomplete forms will delay permitting
  process)

55
?
FAQ
Q Where can I obtain all the UST forms?
A http//www.wastenotnc.org
56
Questions?
Thank you for attending! Division of Waste
Management - UST Section 1637 MSC, Raleigh, NC
27699 phone [phone] fax (919)
733-9413 http//www.wastenotnc.org