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Virginia UST Operator Training A B & C

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Presentation on theme: "Virginia UST Operator Training A B & C"— Presentation transcript:

1 Virginia UST Operator Training A B & C
By Daniel Gerding

2 1st Draft Only

3 Purpose This program is designed to meet the Virginia Department of Environmental Quality requirements for Virginia Underground Storage Tank Operator Training.

4 Contents Section Title Slide Class 1 Safety 6-17 A,B,C 2
Operator Training 18-27 3 Tanks and Piping 28-35 A,B 4 Ancillary Equipment 36-42 B 5 Spill & Overflow Prevention 43-47 6 Release Detection 48-56 7 Interstitial Monitoring 57-63 8 Monitoring 64-72

5 Contents Section Title Slide Class 9 Piping Release Detection 73-78
A,B 10 Corrosion Protection 79-86 11 Product Compatibility 87-92 12 Product Registration 93-97 A 13 Product Closure 98-104 14 Release Reporting 15 Financial Responsibility 16 Acronyms

6 Section 1 Safety

7 Section 1 Safety Emergency Response Plan Emergency Shut-off Switch
Major Releases Minor Releases Fire Alarms

8 Section 1 Emergency Response Plan Safety
Must be at all Facilities Contact Information Emergency Phone Numbers Site Plan Identifying Safety Equipment Procedures for Emergencies Release Procedures Fire Procedures Evacuation Plan Material Safety Data Sheets

9 Section 1 Emergency Shut-off Switch Safety
Location & Identification Shuts Down Tank System Stops all Dispensing Activities Turns off Electricity First Response, in Most Emergencies

10 Section 1 Major Release Safety
Usually Greater than one Gallon Can not be Managed by Employees High fire Potential Exits Property Boundaries Enters Storm Drain Enters Bodies of Water Follow Emergency Response Plan

11 Section 1 Minor Release Safety
Less then one Gallon Managed by on Site by Employees No Emergency Response Personal Safety Clean up Absorbent Material Proper Disposal

12 Section 1 Fire Safety Fire Triangle Fuel Classification
Fire Extinguisher PASS, Pull Aim Squeeze, Sweep Fire Fighting Rules

13 Section 1 Fire Safety Fuel Classification
Description A Wood, paper, cloth, trash, plastics, solid & combustible materials that are not metals. B Flammable liquids , such as, gasoline, oil, grease, acetone, & any non metallic in a liquid state. C Electrical; any energized electrical equipment as long as it’s plugged in is considered a class C fire. D Metals, such as potassium, sodium, aluminum & magnesium.

14 Section Safety PASS Aim at the base

15 Section 1 Fire Rules Safety
Sound the Alarm Leave the Building Call Fire Department Evacuate

16 Section 1 Fire Rules Safety
Never Fight a Fire If: You do Not Know What is Burning The Fire is Spreading Rapidly Your Instincts Tell you Not to Final Rule is: Always keep an exit at your back & never put yourself in harms way !

17 Section 1 Alarms Safety Most Tank Systems Have Alarms Alarm Meaning
Appropriate Response Notification and Reporting Requirements

18 Section 2 Operator Training

19 Section 2 Operator Training
August 8, 2012 Requirements Classes of Operators Availability Responsibilities Class C Class B Class A Recordkeeping

20 Section 2 Aug 8 Requirements Operator Training
At Least one A,B & C Designated Operator May be Designated as More than one Class Required to Dispense or Store Product

21 Section 2 Classes Operator Training
Class A- Statutory and Regulatory Requirements Class B- Field Implementation and Daily Operation and Maintenance Class C- First Responder

22 Section 2 Classes Operator Training

23 Section 2 Availability Operator Training
Required to be Readily Available A or B Immediately Reachable by Phone Manned Facilities- C when in Operation Unmanned Facilities Must Be, Immediately Reachable by Phone and on Site within 2 hours Emergency Contact Information Posting

24 Section 2 Class C Responsibilities Operator Training
Respond to Alarms and Emergencies Notify A & B Operators when Required Monitor the Dispensing of Product Follow written Instructions for Proper Response

25 Section 2 Class B Responsibilities Operator Training
Implementing Regulatory Requirements at Facility Maintain Spill, Overflow and Corrosion Protection Ensure Operation of Release Detection Equipment Be Familiar with all Aspects of UST Operation

26 Section 2 Class A Responsibilities Operator Training
Installation, Maintenance and Repairs of UST System Regulatory Requirements Recordkeeping Prepare Emergency Procedures Financial Responsibility Be Familiar with all Aspects of UST Operation

27 Section 2 Recordkeeping Operator Training
Operator Training Certificates Inspection Records Designated Operators Contact Information Emergency Response Plan

28 Section 3 Tanks and Piping

29 Section 3 Tanks and Piping
Definition of UST Types of UST’s Construction Materials Definition of Piping Piping Systems Types of Pipe Regulated Substances

30 Section 3 Definition of UST Tanks and Piping
Any one or combination of tanks and connected pipes used to contain an accumulation of regulated substances, and the total volume is 10% or more below ground.

31 Section 3 Types of UST’s & Construction Material Tanks and Piping
Single Walled Double Wall Interstitial Space (Annular) Steel Fiberglass Jacketed Compartmentalized Vaulted

32 Section 3 Piping Definition Tanks and Piping
Hollow Conduit Constructed of Non-Earthen Materials Designed to Transfer Product Including; Product Lines Vapor Lines, Vent Lines and Riser Piping.

33 Section 3 Piping Systems Tanks and Piping
Suction Piping Pressurized Piping Atmospheric Vent Lines Riser Piping Vapor Lines

34 Section 3 Types of Pipe Tanks and Piping
Single Wall Double Wall Steel Coated Steel Fiberglass Reinforced Plastic Flexible Plastic

35 Section 3 Regulated Substances Tanks and Piping
Gasoline Ethanol Blends Kerosene Diesel Heating Oil Antifreeze Hazardous Substances

36 Section 4 Ancillary Equipment

37 Section 4 Ancillary Equipment
Definition Dispensers & Under Dispenser Containment Vapor Recovery Drop Tube & Fill Port Submersible Turbine Pump ( STP ) Sump & Sensors

38 Section 4 Definition Ancillary Equipment
Any devices, including, but not limited to, piping, fittings, flanges, valves, and pumps used to distribute, meter, or control the flow of regulated substances to and from an UST.

39 Section 4 Dispensers Ancillary Equipment
Fill Nozzle Shear Valve Product Piping Vapor Piping Under Dispenser Containment (UDC )

40 Section 4 Vapor Recovery Ancillary Equipment
Captures Vapors that are Displaced During Product Delivery Coaxial Dual Port

41 Section 4 Drop Tube and Fill Port Ancillary Equipment
Access for Product to Enter Tank Catchment Basin (Spill Bucket) Drop Tube Sometimes Sump

42 Section 4 Submersible Turbine Pump Sump & Sensors Ancillary Equipment
Pressurized Located Above Tank Potential Leak Containment Sumps Sloped Pipe with Annular space Continuously Monitored Sump Sensor

43 Spill and Overflow Prevention
Section 5 Spill and Overflow Prevention

44 Section 5 Spill and Overfill Prevention
Regulations Spill Buckets Operation and Maintenance Overfill Protection Alarms Float Valves Automatic Shutoff

45 Section 5 Regulations Spill and Overfill Prevention
Proper Labeling Size of Tank Type of Substance Available Volume Monitor Transfer of Product Maintenance of Spill Prevention Equipment

46 Section 5 Spill Buckets Spill and Overfill Prevention
Definition & Purpose Size Drains Manual Pumps Lids Maintenance

47 Section 5 Overfill Protection Spill and Overfill Prevention
Definition & Purpose Overfill Alarm Ball Float Valve Situations NOT to use Ball Float Valve Automatic Shutoff

48 Section 6 Release Detection

49 Section 6 Release Detection
Release Detection Requirements Types of Release Detection Tanks Piping Hazardous Substances Recordkeeping Inspection

50 Section 6 Requirements Release Detection
Every Owner of UST Must Provide Release Detection Entire UST System Calibration, Installation & Maintenance Repairs Reporting Releases

51 Section 6 Types Release Detection
Secondary Containment with Interstitial Monitoring Groundwater Monitoring Vapor Monitoring Manual Tank Gauging Automatic Tank Gauging Manual Inventory Reconciliation Statistical Inventory Reconciliation

52 Section 6 Tanks Release Detection
Method Must Meet All Regulations Must Be Monitored Every 30 Days Secondary Containment Systems Every 30 days

53 Section 6 Piping Release Detection
All Piping Shall Be Regularly Monitored Line Tightness Testing Pressure Piping Automatic Leak Detector Alarm or Auto Shut off Annual Tightness Testing

54 Section 6 Hazardous Substances Release Detection
Must Meet the Same Requirements as Petroleum Secondary Containment Inspected Every 30 Days Alternative Release Protection With Prior Approval of Regulatory Agency

55 Section 6 Recordkeeping Release Detection
Maintained According to Method Manufacturer Documents 5 Years Maintenance & Repairs 5 Years Monitoring Results 5 Years Installer Documents 5 Years

56 Section 6 Inspection Release Detection
Inspection Checklist Date Release Detection System Spill Buckets Overfill Alarm Impressed Current System Fill and Monitoring Ports Spill and Overfill Response Supplies Dispenser Hoses, Nozzles, and Breakaways Dispenser and Dispenser Sump Piping and Piping Sumps

57 Interstitial Monitoring
Section 7 Interstitial Monitoring

58 Section 7 Interstitial Monitoring
Secondary Containment Double-Walled Tanks Interstitial Monitors Requirements & Regulations Recordkeeping

59 Section 7 Secondary Containment Interstitial Monitoring
Barrier Between Tank and Environment Holds Leak in Interstitial (Annular) Space Leaks are Directed Towards Monitor Double-Walled Internal Bladder Excavation Liners

60 Section 7 Double-Walled Tanks Interstitial Monitoring
Commonly Used Secondary Containment Has Annular or Interstitial Space Monitoring Manually - Daily Electronically - Continually

61 Section 7 Interstitial Monitors Interstitial Monitoring
Monitors Space Between Tank & Barrier Manual Testing Three Types of sensors Fluid Hydrostatic Pressure

62 Section 7 Requirements & Regulations Interstitial Monitoring
Barrier Under or Around Tank Double Wall Must Detect Leak Through Inner Wall Monitors Must be Checked Every 30 days Excavation Liner Requirements

63 Section 7 Recordkeeping Interstitial Monitoring
Inspection Every 30 Days Record and Maintain Results for 5 years Record Manual Readings in Log Book & Maintain for 5 Years Vacuum Monitoring 5” of Mercury For At Least 3 Months

64 Section 8 Monitoring

65 Section 8 Types Monitoring
Secondary Containment with Interstitial Monitoring Groundwater Monitoring Vapor Monitoring Manual Tank Gauging Automatic Tank Gauging Manual Inventory Reconciliation Statistical Inventory Reconciliation

66 Section 8 Secondary Containment with Interstitial Monitoring Monitoring
Barrier Between Tank and Environment Holds Leak in Interstitial (Annular) Space Leaks are Directed Towards Monitor Monitors Space Between Tank & Barrier

67 Section 8 Groundwater Monitoring
Installation of Permanent Monitoring Wells Professional Site Assessment for Location Water no more than 20ft. Secure, Labeled & Sealed Detect 1/8” or Less Inspect Every 30 Days Maintain Record 5 years

68 Section 8 Vapor Monitoring
Measures Product Vapor in Soil Product Volatility & Tracer Compounds Professional Site Assessment for Design Inspect Every 30 Days Maintain Records 5 Years Secured, Labeled & Sealed

69 Section 8 Manual Tank Gauging Monitoring
Tanks up to 2000 Gallons Tank Taken out of Service Recording Stick Readings Weekly Calculations Monthly Calculations Weekly & Monthly Standards

70 Section 8 Automatic Tank Gauging Monitoring
Automated Product Inventory Control Tank Not Required to be Taken Out of Service for Continuous Monitoring Detect 0.2gal/hr. One Passing Test Per Month

71 Section 8 Manual Inventory Reconciliation Monitoring
Temporary – 10 years Combined With Tank Tightness Test Measure to 1/8”,Monthly Gauge Stick & Gauging Paste Tank Chart Piping not covered

72 Section 8 Statistical Inventory Reconciliation Monitoring
Similar to Manual, But Uses Computer Analysis of Data Information Provided to a 3rd Party Vendor Daily & Monthly Inventory Keep All Documentation For 5 Years.

73 Piping Release Detection
Section 9 Piping Release Detection

74 Section 9 Piping Release Detection
Types of Release Detection Suction Piping Pressure Piping Line Tightness Test

75 Section 9 Types Piping Release Detection
Groundwater Monitoring Vapor Monitoring Secondary containment with Interstitial Monitoring Statistical Inventory Reconciliation Tightness Testing Automatic Leak Detectors

76 Section 9 Suction Piping Piping Release Detection
Must Use 1 of Three Methods Monthly Monitoring Line Tightness Test Every 3 Years Design Standards for Release Detection Not to be Required

77 Section 9 Pressure Piping Piping Release Detection
One Method From Each of 2 Groups Group 1 – Automatic Line Leak detector Group 2 – Monthly Monitoring of Interstitial Space, Groundwater, Vapor, SIR, or Annual Tightness Testing

78 Section 9 Line Tightness Test Piping Release Detection
Pressure Testing Tracer Testing Suction Every 3 Years Pressure Every 1 Year 0.1 Gallon/Hour at 1.5 Times Operating Pressure

79 Section 10 Corrosion Protection

80 Section 10 Corrosion Protection
Requirements Types of Protection Cathodic Protection Piping STIP3 Tank Recordkeeping

81 Section 10 Requirements Corrosion Protection
All Metal Components of UST System Must Have Corrosion Protection Standards for Components in Contact with Ground

82 Section 10 Types Corrosion Protection
Completely Non-Corrosive Material Steel Clad Tanks Corrosion Resistant Coating with Cathodic Protection Interior Tank Lining Cathodic Protection Combinations

83 Section 10 Cathodic Corrosion Protection
Prevents Corrosion By Making the Ferrous Substrate the Cathode of an Electrochemical Cell Designed by Corrosion Expert Galvanic Anodes Impressed Current

84 Section 10 Piping Corrosion Protection
Completely Non-Corrosive Material Corrosion Resistant Coating with Cathodic Protection Cathodic Protection Impressed Current Coating with Dielectric Material

85 Section 10 STIP-3 Tanks Corrosion Protection
Three Types of Protection Heavy-duty Anti-corrosive Coating Cathodic Protection Dielectric or Nylon Bushings

86 Section 10 Recordkeeping Corrosion Protection
Test within 6 Months of Installation Test Minimum of Once Every 3 Years The Reports from the Last 2 Tests Must be Retained

87 Product Compatibility
Section 11 Product Compatibility

88 Section 11 Product Compatibility
Biofuels Biodiesel Ethanol Product Conversions

89 Section 11 Biofuels Product Compatibility
Additive or Supplement to Petroleum Fuel Alternative to Fossil Fuel Long Term Impact on Equipment Uncertain Compatibility to Entire UST System Required

90 Section 11 Biodiesel Product Compatibility
Produced From Vegetable Oil Refinery Process B100- Biodiesel Compatibility Problems Blending from 1% to 20 % B-20 Biodiesel

91 Section 11 Ethanol Product Compatibility
Alcohol Made from Corn E-10 , E-85 & Cars Labeling Mixes With Water Different Paste Compatibility Problems with Older UST Systems

92 Section 11 Product Conversions Product Compatibility
Verify Compatibility Clean Tanks Label Fill & Access Points Notify VDEQ Maintain Financial Responsibility Upgrade Inspections During Initial Operation

93 Section 12 Registration

94 Section Registration Requirements Changes Recordkeeping

95 Section 12 Requirements Registration
Every Owner of a UST Must Register With Regulatory Agency Notification days Prior to Operation Discovering Unknown UST’s Delivery of Product

96 Section 12 Changes Registration
New UST Systems Transfer of Ownership Modifications

97 Section 12 Recordkeeping Registration
Maintain Current Registration Documentation Available For Inspection Product Delivery Seller to Notify New Owner & Regulatory Agency

98 Section 13 Closure

99 Section 13 Closure Temporary Permanent Change of Service
Closure Assessments Recordkeeping

100 Section 13 Temporary Closure
Taken out of Service for any Reason Continue Corrosion Protection If Tank is Empty, No Release Detection 3 months Remove Product & Cap Lines, but no Vent Cap 12 months Must Permanently Close Unless, all New Standards

101 Section 13 Permanent Closure
Notify 30 Days Prior Remove Remaining Product Clean All Tanks & Piping Proper Disposal of Waste Site Assessment

102 Section 13 Change of Service Closure
Continued use of a UST to Store Non-regulated Substance Notify 30 Days Prior Remove Remaining Product Clean All Tanks & Piping Proper Disposal of Waste

103 Section 13 Closure Assessment Closure
Prior to Permanent Closure Remediation Specialist Test for Release Corrective Action Contaminated Soil

104 Section 13 Recordkeeping Closure
Notify 30 Days Prior To Tank Actions Maintain Records of Closure Activities & Keep Available Maintain Closure Assessment for 5 Years

105 Section 14 Release Reporting

106 Section 14 Release Reporting
Spills and Overfills Notification Release Indications Release Investigation Release Conformation Site Investigation Initial Abatement Site Assessment

107 Section 14 Spills & Overfills Release Reporting
Take Immediate Action Small Spills Less than 25 Gallons Complete Cleanup in Less than 24 hrs. or Report Large Spills Greater than 25 Gallons Must Report within 24 hrs. Hazardous Substances

108 Section 14 Notification Release Reporting
All Suspected Releases Must be Reported within 24 hrs. Contact Information Site Information Description of the Release Including, Product, Volume, Source, Cause, Date and Time Action Taken Potential Hazardous Conditions

109 Section 14 Indications Release Reporting
Free Product or Vapors in Surrounding Area Monitoring Results Indicating a Possible Release Unusual Operating Conditions

110 Section 14 Investigation Release Reporting
Within 7 days Site Checks System Checks

111 Section 14 Conformation Release Reporting
Report Within 24 hrs. Visible Leaks Detecting Non-aqueous Phase Liquid Detecting Product Vapors Close UST System Until Repaired or Replaced

112 Section 14 Site Investigation Release Reporting
Sampling Considerations Product Locations Sampling Method Geology Receptors Cause for Release

113 Section 14 Initial Abatement Release Reporting
Remove product Inspect Prevent Migration of Released Product Monitor Mitigate all Safety Hazards Contaminated Soils

114 Section 14 Site Assessment Release Reporting
After Initial Abatement Soil Testing Groundwater Testing Remove all “Free Product” Determined to Exist Groundwater Remediation Benzene

115 Financial Responsibility
Section 15 Financial Responsibility

116 Section 15 Financial Responsibility
Requirements Amounts Mechanisms Recordkeeping

117 Section 15 Requirements Financial Responsibility
Corrective Action Costs Third Party Lawsuits All USTs Must Have Valid Certificate Maintained until System Closed Exemptions

118 Section 15 Amounts Financial Responsibility
Financial Responsibility Requirements Annual Throughput (gallons) Corrective Action (per occurrence) Third Party Liability Annual Aggregate 600,000 or less $5,000 $15,000 $20,000 Million $10,000 $30,000 $40,000 Million $60,000 $80,000 1.8 – 2.4 Million $120,000 $150,000 Over 2.4 Million $50,000 $2000,000

119 Section 15 Mechanisms Financial Responsibility
Self Insurance Guarantee Letter of Credit Liability Insurance Surety Bond Trust Fund

120 Section 15 Recordkeeping Financial Responsibility Annual Update Table
Financial Mechanism Annual Update Timeframe Letter from Chief Financial Officer 120 days after the close of the entity’s fiscal year Guarantee None, provided continued use of Guarantee Trust Fund Anniversary of effective date of trust fund Letter of Credit Anniversary of effective date of letter of credit Insurance Policy End of policy period Surety Bond Anniversary of effective date of surety bond Certification of Financial Responsibility Annually, or when changed Standby Trust Fund None, provided no changes

121 Section 15 Recordkeeping Acronyms
List of Acronyms AHFS Airport Hydrant Fueling Systems ALLD Automatic Line Leak Detection ALTT Annual Line Tightness Testing API American Petroleum Institute AST Above Ground Storage Tank ASTM American Society of Testing and Materials ATG Automatic Tank Gauge BOCA Building Officials and Code Administrators CERCLA Comprehensive Environmental Response, Compensation and Liability Act CFR Code of Federal Regulations CP Cathodic Protection DEQ or VDEQ Virginia Department of Environmental Quality DMV Division of Motor Vehicles

122 Section 15 Recordkeeping Acronyms
List of Acronyms FID Flame Ionization detector FA Financial Assurance FR Financial Responsibility GCS Ground water Characterization Study GM Groundwater Monitoring IC Inventory Control IC + TTT Inventory Control and Tank Tightness Testing ICCP Impressed Current Cathodic Protection IM Interstitial Monitoring IR Voltage = I(current) x R(Resistance) LLD Line Leak Detector LOA Letter of Agreement LTT Line Tightness Testing

123 Section 15 Recordkeeping Acronyms
List of Acronyms LUST Leaking Underground Storage Tank MTG Manual Tank Gauging MV Millivolt NACE National Association of Corrosion Engineers ODCP Oil Discharge Contingency Plan OFA Office of Financial Assurance OSHA Occupational Health and Safety Administration OSRR Office of Spill Response and Remediation (DEQ) PC# Pollution Complaint Number (a DEQ tracking number) PID Photo Ionization Detector QAPP Quality Assurance Project Plan RCRA Resource Conservation and Recovery Act (federal hazardous & solid waste law) RO Regional Office

124 Section 15 Recordkeeping Acronyms
List of Acronyms RPB Release Prevention Barrier SIR Statistical Inventory Reconciliation Sti-P3 Steel Tank Institute (P3 = 3 protections) Tank STORMS Storage Tank Management Subsystem (UST database) STP Submersible Turbine Pump SWCL State Water Control Law TTT Tank Tightness Testing UCL Upper Concentration Limit UDC Under Dispenser Containment UST Underground Storage Tank UL Underwriters Laboratories USBC Uniform Statewide Building Code USC United States Code

125 Section 15 Recordkeeping Acronyms
List of Acronyms VAC Virginia Administrative Code VPDES Virginia Pollution Discharge Elimination System VM Vapor Monitoring VPSTF Virginia Petroleum Storage Tank Fund

126 Thank You!


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