5.06 UNDERGROUND STORAGE TANK (UST) PROGRAM

This program contains requirements for practices designed and implemented to protect the environment from the risks of hazardous material releases from underground storage tanks, and to ensure compliance with federal, state and local environmental regulations.

A. SCOPE

This program is applicable to all UNM staff and UNM contractors who manage, operate and maintain USTs. It is also applicable to all contractors who work on or near UST systems.

B. INTRODUCTION

The New Mexico Environment Department (NMED) enforces environmental regulations that apply to USTs at UNM. The Department of Safety, Health and Environmental Affairs (SHEA) coordinates all environmental compliance efforts at UNM, which include those related to USTs.

The goals of this program are listed in priority as follows:

• To prevent releases of regulated and hazardous liquids to the environment from UST systems

• To comply with applicable laws and regulations governing UST systems

• To detect, report and correct releases from UST systems should they occur

Program Limitations: Only the environmental compliance aspects of USTs are covered by this program. No or only marginal mention of related issues, such as fire-protection, flammable storage or air emissions are contained herein. Those UST peripheral issues are covered in other SHEA programs.

C. DEFINITIONS

Applicable Regulations - The New Mexico Environmental Improvement Board's Underground Storage Tank Regulations, and the U.S. Environmental Protection Agency's regulations found at 40 CFR 264, 265, and 280.

Regulated or Hazardous Liquids - All petroleum products, chemicals, and water/chemical solutions which are liquid at 60° F and 14.7 psia.

Underground Storage Tank (UST) - A vessel and associated piping that holds regulated or hazardous liquids, for which 10% of the combined total volume is buried and/or not readily accessible for visual inspection.

D. Operation, Maintenance and Inspection of UST Systems

All three existing UST systems at UNM's Albuquerque Campus, serving the Ford Utilities Center, Health Sciences Service Building (HSSB) and the University Hospital (UH) Helipad are compliant with environmental regulations, including the December 1998 upgrade requirements. To remain in compliance, the system components must be operated and maintained in accordance with manufacturer recommendations. They must also be inspected and tested periodically.

The following list describes both the regulatory requirements and SHEA’s recommendations:

1. Tank Leak Detection - All existing UST systems have automated leak detection systems with alarms. As long as these systems are operating properly, no tank tightness testing is required. The automated leak detection systems should be checked monthly for proper operation. Refer to the system operations manual or contact the manufacturer on how to perform the recommended system checks.

2. Tanks - No maintenance or inspection should be required for the tanks themselves if they do not leak. If sludge build-up within the tank or fuel contamination ever becomes an issue, please contact SHEA for assistance with proper disposal of contaminated materials and prevention strategies.

3. Spill Protection - Fill port catchment basins should be cleaned and the drains tested periodically to ensure proper operation and prevent fuel contamination. Water intrusion into the catchment basins may also cause fuel contamination problems. Water intrusion can usually be corrected by replacing the lid gasket or elevating the basin vault relative to the surrounding grade.

4. Overfill Protection - Inspection and testing of overfill protection devices is not required. 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 by a qualified contractor.

5. Piping -

1. Pressurized Piping – Annual tightness testing by a contractor with a current New Mexico Environment Department Certification is required. The automatic line leak detector system should be inspected and tested monthly. Refer to the system's operation manual or contact the manufacturer directly regarding how to perform system checks. Note: UH's Helipad UST system has a pressurized piping system.
2. Suction Piping – Piping tightness testing is required every 3 years by a contractor with a current New Mexico Environment Department Certification if either:

1. the piping does not slope back to the tank; or,
2. the check valve is not located directly under the pump.

Note: The UST systems serving the Ford Utilities Center and the HSSB have suction piping which does not slope back to the tank, and therefore must have piping tightness tests performed every 3 years.

6. Corrosion Protection System - The all-fiberglass and fiberglass encased steel USTs serving the UH Helipad and the Ford Utilities Center, respectively, are protected from soil corrosion and do not require additional corrosion protection. The HSSB UST and associated steel piping are protected from corrosion by a sacrificial anode system. This system must be inspected by a qualified UST corrosion protection inspector every 3 years.

E. RecordKeeping Requirements

1. On Location near the UST - The most current annual tank registration certificates must be posted in a visible location.
2. On File at SHEA-

2. Most recent tank and piping tightness testing reports;
3. Results of the last 3 corrosion protection systems tests;
4. Proof of financial responsibility;
5. Copies of all tank closure notifications and site assessment results; and,
6. Records of spills and releases. Any reports, variances, extensions, laboratory analytical results, notices and proposals from UST sites under remediation due to a release.

3. On File at the UST Owner/Operator's Facility -

1. Documentation of UST system and component installations, upgrades and repairs, must be kept for the life of the equipment;
2. Results of the monthly release detection system checks on the tank and/or piping with monitoring data, kept for at least one year until the tests are again performed; and,
3. All UST system and component product information including release detection performance claims, warranties, specifications and other pertinent system information, must be kept for the life of the equipment.

Note: The Owner/Operator’s Facilities are University Hospital’s Facilities Engineering Office, UNM Physical Plant Department’s Ford Utilities Center Office, and UNM Physical Plant Department’s Area 2 Office.

F. Required Reporting to the NMED

SHEA performs all UST-related environmental compliance reporting for UNM. SHEA will need information from the Owners/Operators that operate and maintain the USTs.

1. Annual Registration and Fee Payment - UNM must pay the NMED $100 per UST per year to re-register the USTs on campus.
2. Periodic Testing & Inspection Reporting – SHEA transmits the following reports to the NMED:

1. Tightness testing for both tanks and piping
2. Corrosion protection system testing

3. New System Installations and Existing System Modifications – these require notice to the NMED at least 30-days prior to construction.
4. Spills, Leaks, and/or Suspected Leaks - all releases greater than 25 gallons must be reported by SHEA to the NMED immediately.
5. System Closure and Tank or Piping Removals - these require at least 30-day advance notice to the NMED.

G. New UST Systems and Existing System Upgrades

New UST systems and upgraded existing systems must have the same devices described in Section D above. Only contractors with a current NMED Installer Certification qualify for work installing USTs, piping, monitoring systems, etc. Design and construction of new UST systems and existing system modifications must have prior approval from SHEA. Additionally, new installation requirements and recommendations are described below:

1. Corrosion Protection - Corrosion protection systems are required for all USTs which have a metal tank or associated components not completely protected from contact with soils. These systems must be tested by a qualified contractor within 6 months of initial installation and every 3 years thereafter.
2. Tank Construction - SHEA recommends the following tank constructions in order of preference:
   1. Double-walled tank with monitorable interstitial space; fiberglass outer tank and steel or fiberglass inner tank; or
   2. Double-wall coated steel tanks (STI-P3) with monitorable interstitial space.
3. Leak Detection - All UST systems must have a compliant leak detection system. SHEA’s preference in leak detection systems is as follows:
   1. Interstitial monitoring with automatic alarm; or,
   2. Automatic tank gauging with 0.2 gal/hr loss detection alarm mode capability.

Other compliant leak detection systems provide warning only after the pollutants have substantially impacted the environment, are monitoring/maintenance intensive, and are less reliable. Additionally, the other compliant systems may require annual tank tightness testing as confirmation.

4. Piping -

1. Pressurized: Automatic line leak detectors are required; or,
2. Suction: No line leak detectors are required. Note: If the piping does not slope back to the UST or if the check valve is not located directly under the suction pump, then line tightness testing is required every three (3) years.
3. Tightness Testing Fittings: SHEA recommends that valves be installed on both ends of the product piping at accessible locations and that a blanked "T" be installed on the most accessible end to facilitate piping tightness testing.
4. 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.

H. Closure or Removal of USTs and Piping

All UST system or component closures and removals must have prior approval from SHEA.

1. Qualified Contractors Only - Contractors or maintenance personnel must have a current NMED Installer Certification in order to qualify for work closing USTs, piping, monitoring systems, etc.
2. Soil Testing - Release confirmation soil sampling is required for any tank and piping removals or closures.
3. Advance Notification - 30-day advanced closure notice to NMED is required to close or remove tanks or piping.

I. Spills, Releases or Suspected Releases

1. Reporting Requirements - If a UST system release of any amount is discovered or suspected, inform SHEA immediately. Spills or releases of petroleum products 25 gallons and larger will require reporting to the NMED. SHEA will make the reporting determinations and inform the appropriate regulatory authorities. When required, SHEA will submit the 24-hour, 7-day, and 21-day reports.
2. Corrective Action - If corrective action is required for a UST system release, SHEA will coordinate all associated activities. Correction Action Plan: All NMED-required remediation activities will be performed in accordance with a NMED-approved corrective action plan.