May 2002 presentation

Introduction to Regulation of Underground and Above Ground

Storage Tank Systems

Petroleum Storage Tank Bureau

Our Missionis to reduce, mitigate and eliminate the

threats to the environment posed by petroleum products or hazardous material or wastes released from petroleum storage

tanks.

• Currently regulated by:– Federal (US EPA 40 CFR)

Underground Storage Tank Program

– State (NMED 20NMAC5) Petroleum Storage Tank Bureau

• Currently regulated by:– Federal (US EPA) currently no one

Federal Regulatory Program Governing ASTs is active. HOWEVER, there are existing statutes & regulations that apply directly or indirectly to ASTs. So Federal Reg’s are in the works from US EPA just like the…

– State (NMED) Petroleum Storage Tank Bureau, currently in progress of being created........

Underground Storage Tank (UST)

Aboveground Storage Tank (AST)

NMED REGULATORY BACKGROUND

• Hazardous Waste Act, NMSA 1978

• Ground Water Protection Act, amended, NMSA 1979

• Environmental Improvement Act, NMSA 1979

• Senate Bill 333, Legislative Session, 2001

Aboveground Storage TankRegulations

Are being generated with the assistance from the following: • Several states with existing regulations governing ASTs• State NMED PST Bureau Inspector’s experience• Industry Standards and Codes

Petroleum Equipment Institute (PEI) National Fire Protection Association (NFPA)

Steel Tank Institute (STI)

others

Types of Petroleum Storage Tank Systems:

Underground Storage TankAboveground Storage Tank

• tanks are constructed of: Steel• single wall • double wall

Underground Storage Tank

• tanks are constructed of: Fiberglass Reinforced Plastic (FRP)

• single wall • double wall

Underground Storage Tank

• tanks are constructed of a Composite- steel tank with clad layer

• single wall • double wall

Underground Storage Tank

Aboveground Storage Tank

Field Erected

Aboveground Storage TankShop Fabricated

ASTField-

Erected

• various designs and configuration;

• parts are in contact with surface of the ground either: soil bedding, ringwalls, concrete pads or special foundation.• usually the underside of the ground contact area not readily available for visual inspection;

• corrosion damage major concern and other forms of bottom-plate failures. • general volumes comprise of large, high-volume/capacity AST, found at industrial or refining settings (over 50,000 gallons).

ASTShop-

Fabricated

• various designs and configuration;

• are supported ABOVE the surface of the ground and;

• all parts of tank are readily accessible for visual inspection;

• corrosion damage are of minimal concern;

•general volumes of tanks are under 50,000 gallons.

Comparison of

UST and AST Systems

UST AST

• contains regulated substances

• 10% or more below the surface of the ground

• contains regulated substances

• permanently installed

• 1,100 gallons or more

• vaults and special enclosures

Storagecapacity:

Up to 50,000gallons

Up to 500,000gallons

Shape: Horizontal Horizontal orVertical

AST UST

Safety & Security:

Minimal fire & security

concerns due to location of tank

Considerable fire, security concern and vandalism

AST UST

•Performance standards for storage tank systems

UST systems

AST systems

•Spill and overfill equipment

• Special requirements for storage tank systems at marinas

• Deadline for Closing or Upgrading AST systems July 1, 2006

20 NMAC 5 PART 4New and Upgraded Storage Tank Systems:

Design, Construction and Installation

20 NMAC 5 PART 5General Operating Requirements

Operation and Maintenance of:• Storage Tank Systems

• Secondary Containment

• AST- Vaults

• Venting Systems

• Spill and Overfill Control

• Corrosion Protection

• Repairs and Modifications

• Reporting & Recordkeeping

• Inspections, Monitoring and Testing