5.01 ABOVE GROUND STORAGE TANK (AST)
PROGRAM
The New Mexico Environment Department (NMED) enforces environmental regulations that apply to ASTs at UNM. The Department of Safety, Health and Environmental Affairs (SHEA) coordinates all environmental compliance efforts at UNM, which include those related to ASTs.
A. SCOPE
This program is applicable to
all UNM entities that manage, operate and maintain ASTs. It is also applicable to all contractors that
work on and near AST systems. The goals of the program are listed in priority
as follows:
1. To prevent releases of regulated and hazardous liquids to the environment from
AST systems;
2.
To comply with applicable laws and regulations governing AST systems;
and,
3.
To detect, report, and correct releases from AST systems should they
occur.
Program Limitations: Only
the environmental compliance aspects of ASTs are covered in this program. Only
marginal, if any, mention of related issues involving general safety and
fire-prevention are contained herein. These AST-related issues are covered in
other UNM SHEA programs including Confined
Space Entry, Fire Emergency Action
and Evacuation, and Fire Prevention.
B.
DEFINITIONS
Applicable Regulations - NFPA (National Fire Protection Association) 30 and 40 CFR 264, 265, and
280.
AST - A vessel and
associated piping holding regulated or hazardous liquids, for which 10% of the
combined volume is not buried and is readily accessible for visual inspection.
Regulated or Hazardous Liquids - For the purposes of this program, all petroleum products,
hazardous chemicals, and water/chemical solutions which are liquid at 60 °F and 14.7 psia.
All existing AST systems at UNM
are compliant with both environmental regulations and fire code requirements.
To remain in compliance, the system components must continue to be both
operated & maintained (O&M'd) in accordance with manufacturer
recommendations and visually inspected periodically. The follow listing of AST
system components describes the regulatory requirements and SHEA’s
recommendations:
1. Tank Leak Detection
All
existing AST systems at UNM must be visually inspected periodically for leakage
by the UNM entity that O&Ms the AST. As long as these systems are operating
properly, no tank tightness testing is required. SHEA recommends that the AST
system (tanks, piping, dispensers, etc.) be visually inspected at least monthly
for leaks and proper operation. A record of these inspections must be kept
on-site and made available to SHEA and regulatory agencies upon request.
2. Tanks
No
O&M or inspection should be required for the tanks themselves if they do
not leak. If sludge build-up or fuel
contamination ever becomes an issue, please contact SHEA for assistance with
proper disposal and prevention strategies.
3. Spill Protection
SHEA recommends that fill port catchment basins be cleaned and the drains tested at least semi-annually to ensure proper operation and to prevent fuel contamination. Water intrusion into the catchment basins may also cause fuel contamination problems. A record of these inspections must be kept on-site and made available to SHEA upon request.
4. Overfill Protection
Inspection and testing of overfill protection devices is not currently required. If testing is desired, SHEA does not recommend testing overfill devices in place while filling the tank. Testing can be more safely performed in a water-filled drum or bucket after the device has been removed and cleaned.
5. Piping
a. Pressurized
Piping – Annual tightness testing by
a contractor with a current NMED Certification is recommended for AST systems
with pressurized underground piping. Please refer to the system operations
manual or contact the manufacturer on how to perform system checks.
b. Suction
Piping – Tightness testing is not
required unless leakage is suspected.
6. Corrosion Protection System
If any AST system is equipped with a corrosion
protection system, SHEA recommends that a qualified contractor test the
corrosion protection system within 6 months of installation and every 3 years
thereafter.
D. Record Keeping Requirements
1.
SHEA File:
a.
The most current NM Fire
Marshall (or NMED in future) tank registration certificates;
b.
Copies of the most
recent testing results, if any are warranted (see below);
c.
Records of all spills or
other releases; and,
d.
Copies of documents sent
to EH&S-related regulatory agencies, including any reports, variances,
extensions, laboratory analytical results, notices and proposals from AST sites
under remediation should be kept indefinitely.
2.
O&M File (on file with the UNM entity that O&Ms the
AST):
a.
The most recent of any
tank and piping tightness testing reports, if any are warranted;
b.
Documentation of AST system and component installations,
upgrades and repairs; including component product information including release
detection performance claims, warranties, specifications and other pertinent
system information kept for the life of the equipment;
c.
Results of the last 3
corrosion protection systems tests, if such tests are needed;
d.
Records of all spills
and releases.
e.
Records of visual
inspections for leaks, proper operation, and of fill port catchment basins as
described in C1 and C3 above.
SHEA performs all AST-related
environmental compliance reporting for UNM. SHEA will need information from the
UNM entities which O&M the ASTs including:
1. Registration with the State Fire Marshall’s Office or the
NMED.
2. New system
installations and existing system modifications -30 days prior to construction.
3. Spills, Leaks, and/or Suspected Leaks - >25 gallons may
be reported to the NMED.
4. System
closure and leaking tank or buried piping removals require 30-day advance
notice to the NMED.
New AST systems and upgraded
existing systems must have the same devices described in the O&M section
above. SHEA recommends that only
contractors with a current NMED UST Installer Certification qualify for work
installing AST systems with buried components (e.g., piping). Design and
construction of new AST systems and existing system modifications with buried
components must have prior approval from SHEA. Additional, new installation
requirements and recommendations are described below.
1. Corrosion Protection
For AST systems with corrodible metal tanks or piping which are not completely protected from contact with soils, SHEA recommends installation of a corrosion protection system. A qualified party must test a corrosion protection system within 6 months of initial installation and every 3 years thereafter.
2. Tank Construction
SHEA
recommends the following tank constructions in order of preference:
a.
Double-walled tank with
monitored interstitial space; such as a
steel or reinforced concrete outer tank and a steel or fiberglass inner tank;
b.
Double-walled steel
tanks elevated above grade on saddles; or,
c.
Single wall tank with
>3/8” thick steel walls mounted on saddles
All
ASTs must be protected from vehicles by stout traffic barriers or ballards, where
appropriate.
3. Leak Detection
All
AST systems should have a leak detection system. SHEA’s preference in leak detection systems
is as follows:
a.
Interstitial monitoring
with automatic alarm;
b.
Automatic tank gauging
with 0.2 gal/hr loss detection alarm
mode capability; or,
c.
Visually inspectable
system, including piping, which is visually inspected at least once a month.
4. Piping
No
line leak detectors are required. If underground piping is either pressurized,
or does not slope back to the AST in a suction pumped system, SHEA recommends
that piping tightness tests be performed at least once every 3 years.
a.
Tightness Testing Fittings- SHEA recommends that valves be installed on both ends of underground
product piping at accessible locations and that a blanked “T” be installed on
the high end to facilitate piping tightness testing.
b.
Underground Piping Material – SHEA recommends the following piping materials in order of preference:
1. Product
compatible plastic piping with solvent-welded joints; or,
2. Fiberglass
piping with solvent-welded joint; or,
3. Metal piping
with cathodic protection.
c.
Accessible Aboveground Piping Material – SHEA recommends the following piping materials in order of
preference:
1. Galvanized steel piping; or,
2. Coated/painted black steel piping.
5. Location
For AST systems from which there is a possibility for 660 gallons of spillage or leakage of petroleum products or hazardous chemicals to enter a storm sewer or other conveyance leading to a natural water body, UNM will need to develop a Spill Prevention, Countermeasure and Control Plan (SPCCP). SHEA highly recommends locating all new AST systems that are greater than 660 gallon in size sufficiently far away from, or at an elevation below, storm sewer inlets and other conveyances.
All AST system or component
closures and removals require SHEA notification.
1.
Qualified Contractors
Only – Contractors or maintenance personnel should have a current NMED
Installer Certification in order to qualify for work closing ASTs, piping,
monitoring systems, especially those with directly buried components or ones
with known leakage problems.
2.
Release confirmation
soil sampling should be performed for any tank and underground piping removals
or closures, and is required for systems with known leak problems.
3.
30-day advanced closure
notice to NMED is required to close or remove leaking tanks or underground piping.
1. Reporting Requirements
If an
AST system release of any amount is discovered or suspected, inform SHEA
immediately. Call 911, if appropriate, for spills or releases of 25 gallons or
more. Also, spills or releases of 25 gallons or more may require reporting to
the NMED. SHEA will make the reporting determinations and inform the
appropriate regulatory authorities.
2. Corrective Action
If corrective action is required for an AST system release, SHEA will coordinate all associated activities. All NMED-required remediation activities will be performed in accordance with an NMED-approved corrective action plan.