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States With Requirements More Stringent Than The Federal Significant Operational Compliance Requirements - UST Training

October 30, 2013

I recently found this summary states with additional UST prevention rules above and beyond the federal laws. Any surprises here, you UST Class A/B operators?
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States With Requirements More Stringent Than The Federal Significant Operational Compliance Requirements
CONNECTICUT
  • Lining not allowed.
  • Tanks and piping require weekly and monthly monitoring for releases and records must be available (for 2 of the most recent consecutive months and for 8 of the last 12 months).
  • Statistical Inventory Reconciliation (SIR) not allowed as a stand-alone method.
IDAHO
  • Release Prevention: Operation and Maintenance of Cathodic Protection: Three 60-day rectifier inspection checks are required.
  • Two three-year system checks are required for impressed current and galvanic.
  • Percent of UST facilities in compliance with both release detection and release prevention also factors in financial responsibility and EPAct requirements, such as operator training and secondary containment.
ILLINOIS
  • Release Detection: Testing: Owner/operator must produce records within 30 minutes of arrival of inspector.
KANSAS
  • Release Prevention: Spill Prevention: Owners/operators cannot have debris or water in the spill bucket.
  • Release Prevention: Cathodic Protection: Owner/operator must ensure that the cathodic protection rectifier log is available at the time of inspection.
MICHIGAN
  • Release Detection: Required Methods: Owners/operators must have inventory control plus another method of release detection.
MISSOURI
  • Release Prevention: Cathodic Protection: All metal components in contact with any electrolyte must be cathodically protected. (note: keep your sumps extra dry in the Show me state.)
RHODE ISLAND
  • Release Prevention: Operation and Maintenance: All tanks and piping are required to be tightness tested after a repair. No exemptions.
  • Release Prevention: Operation and Maintenance of Cathodic Protection: Impressed current cathodic protection systems ar e required to be tested every 2 years.
  • Sacrificial anode systems are required to be tested every 3 years.
  • Release Detection: Testing: Records required for the past 36 months.
  • Inventory control is required for all tanks (single-walled and double-walled).
  • The automatic tank gauge (ATG) has to be checked monthly and have an annual test conducted.
  • Tightness testing schedule is different than the federal requirement; it depends on the type of tank.
  • Tank tightness must be performed on all single walled tanks.
  • Tightness tests must be performed every 5 years after the installation of the ATG until
  • the tank has been installed for 20 years and every 2 years thereafter.
  • UST systems upgraded with interior lining and/or cathodic protections are not required to have an ATG for 10 years after the upgrade. Tank tightness testing must be conducted annually during these 10 years.
  • After 10 years, an ATG is required and tank tightness testing must be performed every 5 years until the tank has been installed for 20 years and then every 2 years thereafter. The results of all tightness tests shall be maintained for 3 years beyond the life of the facility.
  • Groundwater or vapor monitoring not accepted as a method of leak detection.
  • SIR not accepted.
VERMONT
  • Release Prevention: Operation and Maintenance of Cathodic Protection: Lining not allowed unless with impressed current.
  • Release Detection: Method Presence and Performance Requirements: Weekly monitoring required for tank and piping. Records must be available for the two most recent consecutive months and for 8 of the last 12 months.
  • Release Detection: Testing: Inventory control /Tank Tightness Testing (TTT) not allowed as a release detection method after 6/30/98.
  • Manual Tank Gauge (MTG) allowed alone up to 550 gallons; 551-1,000 gallons, MTG with annual TTT.
WISCONSIN
  • Release Prevention: Operation and Maintenance of Cathodic Protection Require annual cathodic protection test.
  • Release Prevention: Spill Prevention: Require USTs to be equipped with overfill prevention equipment that will operate as follows (NFPA 30-2.6.1.4 – 2000 and 2003 version):
  • Automatically shut off the flow of liquid into the tank when the tank is no more than 95% full;
  • Alert the transfer operator when the tank is no more than 90% full by restricting the flow of liquid into the tank or triggering the high-level alarm; and,
  • Other methods approved by the authority having jurisdiction.
  • Release Detection: Testing Require NFPA 30A09.2.1 (2000 and 2003 versions). Accurate daily inventory records shall be maintained and reconciled for all liquid fuel storage tanks for indication of possible leakage from tanks or piping. The records shall be kept on the premises or shall be made available to the authority having jurisdiction for the inspection within 24 hours of a written or verbal request. The records shall include, as a minimum and by product, daily reconciliation between sales, use, receipts, and inventory on hand. If there is more than one storage system serving an individual pump or dispensing device for any product, the reconciliation shall be maintained separately for each system.
  • Release Detection: Deferment: No exclusion or deferment for “remote” emergency generator tanks.
  • Other: Require annual permit to operate that includes verification of financial responsibility.

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