ACCA Legislative Conference Underground Storage Tank Compliance December 4, 2014 Lee Davis, UST Compliance adem.alabama.gov

UST Compliance Program Outline UST Program Overview Regulatory Requirements 2005 Energy Act adem.alabama.gov

Definition of UST Tanks and Piping Contains Regulated Substances 10% or More Underground adem.alabama.gov

USTs adem.alabama.gov

Regulated Universe Regulated Facilities ~ 5,600 Regulated Tanks ~ 15,300 Number of Tank Owners ~ 3,100 adem.alabama.gov

Inspectors 9 UST Inspectors in 4 Field Offices Approximately 400 inspections per inspector, per year adem.alabama.gov

Performance Standards USTs and Piping Fiberglass-Plastic Construction, or Steel and Protected from Corrosion Piping Nonmetallic, or adem.alabama.gov

UST adem.alabama.gov

Piping adem.alabama.gov

Performance Standards Spill Prevention To contain the volume of the delivery hose after disconnecting adem.alabama.gov

Spill Catchment Basin adem.alabama.gov

Performance Standards Overfill Prevention Activated by product level to prevent tank overfills adem.alabama.gov

Overfill Prevention Flapper Valve 4 1 2 3 2 3

Overfill Prevention Ball Float Valve 3 2 1

Regulatory Requirements Testing and Reporting Corrosion Protection Leak Detection Spill Catchment Basin Closure Suspected Releases adem.alabama.gov

Testing CP Test Cathodic protection test required once every three years adem.alabama.gov

Cathodic Protection System adem.alabama.gov

Impressed Current Anode adem.alabama.gov

Rectifier adem.alabama.gov

Galvanic Cathodic Protection System adem.alabama.gov

Release Detection Tanks – must have monthly method of monitoring for releases Pressurized Piping - must have annual line test or monthly monitoring Suction Piping – No monitoring required if “safe suction” adem.alabama.gov

Automatic Tank Gauge adem.alabama.gov

Testing Leak Detection Leak Detectors - equipment that will shut off or restrict flow of product if a leak is detected – Annual test Sump Sensors – Annual test adem.alabama.gov

Testing & Reporting SIR Annual Summary Report Line Tightness Tests Annual Line Leak Detector Tests Annual Cathodic Protection Tests 3 Year Spill Catchment Basins 3 Year adem.alabama.gov

Reporting Closure and Releases Permanent Closure of a UST System Suspected releases must be reported within 24 hours. Investigation and Corrective Action adem.alabama.gov

Suspected Release adem.alabama.gov

Secondary Containment Delivery Prohibition Operator Training 2005 Energy Act Secondary Containment Delivery Prohibition Operator Training adem.alabama.gov

Secondary Containment Effective August 6, 2007 Tank and Piping Manufactured with Inner and Outer Wall and Interstitial Space Interstitial Monitoring Only Acceptable Form of Leak Detection adem.alabama.gov

Submersible Pumps Effective August 6, 2007 USTs installed with submersible pumps on August 6, 2007 and thereafter, must have submersible pump containment sumps. adem.alabama.gov

Sub Pump Sump adem.alabama.gov

Under Dispenser Containment Effective August 6, 2007 New Dispenser System Includes Equipment Necessary to Connect to UST System adem.alabama.gov

Under Dispenser Containment adem.alabama.gov

Delivery Prohibition 2005 Energy Act Prohibition of delivery or acceptance of product for non-compliant UST facilities Penalty for owner and deliverer Regulations Effective April 25, 2008 adem.alabama.gov

Delivery Prohibition adem.alabama.gov

Delivery Prohibition Reasons Delivery prohibition may be imposed for failure of an owner to: Install, operate and/or maintain cathodic protection, leak detection, under dispenser containment, or spill or overfill controls Ensure compatibility of UST with product Perform required testing Pay regulatory fees Take corrective action for releases adem.alabama.gov

Delivery Prohibition ADEM Steps How will ADEM notify owners they are subject to delivery prohibition? Notice of Delinquency Notice of Violation Notice of Delivery Prohibition Opportunity to meet with Department adem.alabama.gov

Delivery Prohibition DP List How will ADEM notify fuel delivery companies that a facility is prohibited from delivery? Delivery Prohibition List on ADEM web site Delivery Prohibition List updated every Wednesday at 12:00 a.m. adem.alabama.gov

Delivery Prohibition Owner Response How can owners be removed from the Delivery Prohibition List? Return to Compliance Submittal of documentation ADEM will remove facility from list ADEM will send letter adem.alabama.gov

Operator Training adem.alabama.gov

Operator Training 2005 Energy Act Operators must be trained by August 8, 2012. Three classes of operator adem.alabama.gov

UST Trust Fund Registration Motor Fuel Substantial Compliance Orders Spill Prevention Overfill Prevention Corrosion Protection Release Detection adem.alabama.gov

AST Trust Fund Registration Motor Fuel SPCC Plan NPDES Permit adem.alabama.gov

UST Compliance Program I Can Answer Any Questions You May Have Now. adem.alabama.gov

Chief, UST Compliance Unit (334) 271-7759 mld@adem.state.al.us Contact Information – Lee Davis Lee Davis Chief, UST Compliance Unit (334) 271-7759 mld@adem.state.al.us UST Switchboard (334) 270-5655 ustcompliance@adem.state.al.us adem.alabama.gov