Frequently Asked Questions (FAQs)

 

 


 General UST Questions

  1. If tank hold water is removed from my UST site in order to perform repair work, how do I dispose if it?
  2. Does LDEQ approve the installation of the OPW Loop System?
  3. Is Diesel Exhaust Fluid (DEF) a regulated substance, and is an underground storage tank that contains DEF regulated under by the UST regulations?

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UST Standards- Corrosion Protection, Spill & Overfill Protection, Certified Workers

  1. What are the standards for tanks for new underground storage systems?
  2. What are the standards for piping for new UST systems?
  3. Do metal flexible hoses need corrosion protection?
  4. Do submersible pumps need corrosion protection?
  5. Are spill and overfill protection required for the installation of new UST systems?
  6. Who can perform a UST installation?
  7. Does LDEQ retroactively require UST owner/operators to replace their old flexible pipe with new pipe after the new UL 971 standard was issued in 2005?
  8. Does LDEQ require that all of the flexible piping be replaced at a facility that reported a single release at a site, 2 releases, or just the portion of the system that caused the release? What type of criteria was used to require replacement of the old flexible pipe, if any?

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UST Temporary and Permanent Closures

  1. When tanks that were previously closed are now removed and sampling is required, what risk based standards are the soil and groundwater data compared to?

 

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 Internal Lining Inspections

  1. What are the 1998 upgrade requirements?
  2. What are my options if I am approaching the ten year deadline for internal lining inspections and I previously upgraded my steel tanks with an internal liner to meet the 1998 upgrade requirements, but did not install corrosion protection at that time?
  3. If I had an impressed current system installed on my lined tanks without performing a tank integrity assessment, what are my options?
  4. Does the internal lining inspection require a person to physically enter the UST?
  5. Why is soil testing required if I am having an internal lining inspection on my UST?  
  6. Can I use my ATG or SIR to perform the tank tightness that is required under the Louisiana Alternative Assessment Procedure?

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    Stage I and II Vapor Recovery

  1. What information should be included on pump decals for a Stage II Recovery system?  
  2. Based on the recent change in the Ozone Standard, are Stage I Vapor Recovery upgrades to UST Systems in the new non-attainment areas required?
  3. What are the new Stage I requirements, when do they take effect, and how do I know if they apply to my UST facility? 
  4. How do I know if I must use drop tubes and Stage One Vapor Recovery?
  5. Who is required to use Stage II Vapor Recovery Systems?

 

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 Alternative Fuels 

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General UST Questions

 
 
A UST or underground storage tank is defined as any one or combination of tanks (including underground pipes connected thereto) that are used to contain an accumulation of "regulated substances," and the volume of which (including connected underground piping) is 10% or more beneath the surface of the ground. The term underground storage tank does not refer to any of the following tanks nor does it refer to any pipes connected to any of these tanks:
 
  • farm or residential USTs (1,100-gallon capacity or less) storing motor fuel for noncommercial purposes
  • USTs storing heating oil for consumptive use on the premises where stored
  • septic tanks
  • pipeline facilities (including gathering lines) regulated under the Natural Gas Pipeline Safety Act of 1968, or Hazardous Liquid Pipeline Safety Act of 1979, or which is an intrastate facility regulated by the state
  • surface impoundments, pits, ponds, or lagoons
  • storm-water or wastewater collection systems
  • flow-through process tanks
  • liquid traps or associated gathering lines directly related to oil or gas production and gathering operations
  • tanks situated in an underground area (such as basement, cellar, mineworking, drift, shaft, or tunnel), if the tanks are situated upon or above the surface of the floor
 
The following UST systems are excluded from the requirements of the regulations that apply to underground storage tank systems:
 
  • any UST system holding hazardous wastes listed or identified in the DEQ’s Hazardous Waste Regulations, or a mixture of such waste and other regulated substances
  • any tank that is part of a wastewater treatment facility regulated under Section 402 or 307(b) of the Clean Water Act
  • equipment or machinery containing regulated substances for operational purposes such as hydraulic lift tanks and electrical equipment tanks
  • any UST system with a capacity of 110 gallons or less
  • any UST system that has never contained more than a de minimis concentration of regulated substances
  • any emergency spill or overflow containment UST system that is expeditiously emptied after use
  • wastewater treatment tanks systems
  • any UST system storing radioactive materials regulated under the Atomic Energy Act of 1954 (42 U.S.C. 2011 et. seq)
  • any UST system that is part of an emergency generator system at nuclear power generation facilities regulated by the Nuclear Regulatory Commission under 10 CFR 50, Appendix A
  • airport hydrant fuel distribution systems
  • UST systems with field-constructed tanks
  • any UST System that stores fuel solely for use by emergency power generators are exempt from release detection requirements (emergency power generator tanks need to be registered and must meet all UST requirements except release detection) if installed prior to 8/20/09. Emergency power generator tanks and piping installed after 12/20/08 and before 8/20/09 are required to be secondarily contained, but are still exempt from release detection. Emergency power generator tanks and piping installed after 8/20/09 are required to be secondarily contained and are required to have interstitial monitoring release detection.

 

 

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The following information can be located on this page:
  • General information including links for an organizational chart, a regional map, and UST contact information
  • Surveillance links for UST related items such as information regarding installations, upgrades, and renovations; single point of contact (SPOC) procedures; online incident reporting; and Stage II information
  • Enforcement links to UST related items such as owner/operator training schedule
  • Registration links for UST related information such as UST registration and forms; motor fuel information; certified worker information; and response action contractor (RAC) information
  • Remediation links for UST related items such as Leaking UST QAPP, UST Closure/Change-in-service documentation
  • information about Motor Fuels Trust Fund (MFTF) including Cost Control Guidance documents, forms, and instructions
 
For a training schedule, follow this link:

 

 

 

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All tanks that fit the definition of a UST must be registered with the DEQ's UST Division, unless:
• the UST was filled with a solid inert material before January 1, 1974
• the UST was removed from the ground prior to May 8, 1986

 Click here for more information 

 

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All owners of new and existing UST systems are required to register his/her system with the LDEQ. It is also the responsibility of the owner of the system to maintain current and accurate information with the department. Maintaining current and accurate information with the department includes notifying the department of changes in ownership or of changes in the UST system descriptions resulting from system upgrades. Any owner who knowingly fails to register or submits false information shall be subject to a civil penalty. An owner is defined as the following: 
                         
  • the current owner of the land under which the tank is or was buried
  • any legal owner of the tank
  • any known operator of the tank
  • any lessee
  • any lessor

 

 

 

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At least thirty (30) days before bringing the tanks into use, the owner must register the system with the LDEQ by submitting the completed the UST Registration Form (UST-REG-01). The Registration Form for Technical Requirements (UST-REG-02) must be submitted within 60 days of introducing product into the tank. A Certificate of Underground Storage Tank Registration will not be submitted until a completed UST-REG-02 form is received by the Department and fees are paid. 

 

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All existing UST systems previously registered with the DEQ shall be considered to be in compliance with the registration requirements if the information on file with the DEQ is current and accurate. Therefore, an amended registration must be filed within 30 days for the following:
  • change in ownership and/or facility information, including name and address changes (UST-REG-01 and UST-REG-02)
  • change in status of the UST system; i.e., temporary closure (UST-REG-01)
  • change-in-service; i.e., change in tank contents (UST-REG-01 and UST-REG-02)
  • additional or replacement tanks have been installed (UST-REG-01 and UST-REG-02)
  • when the UST system has been upgraded, after any equipment changes, or after a change of the release detection method (UST-REG-02)
  • when errors or omissions have been discovered in previously provided information (UST-REG-01 and/or UST-REG-02)

 

 

 

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  •  Any person who sells a UST system is required to notify the DEQ in writing within 30 days after the date of the transaction. The notice should include a bill of sale and the new owner's name, contact person, address and telephone number.
  • Any person who acquires a UST system shall submit a registration form (UST-REG-01) within 30 days of the acquisition.
  • A current copy of the registration forms (UST-REG-01 and UST-REG-02) must be kept on-site or at the nearest staffed facility.
  • No owner or operator shall accept a regulated substance into a new UST system that has not been registered.

 

  

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9. Are there fees associated with registering a UST system?

 
Yes, there are fees associated with registering a UST system. The standard fee for all registered UST systems is $54 per tank; however, additional charges may apply for certain types of stored substances and also certain facility types.
Fees must be submitted to the DEQ upon the submission of a new registration. Payment shall be made by check, draft, or money order payable to the Department of Environmental Quality and mailed to the department address provided on the invoice.

Annually thereafter, the site UST Billing Party will receive an itemized invoice for applicable fees for the State of Louisiana's fiscal year (July 1 through June 30). All fees must be paid regardless of whether the tanks will be installed, are out of service, or are permanently/temporarily closed during the fiscal year. 

 

The owner of record of the UST system on the date of invoicing by the department is responsible for registration fees. 
Yes, a 5 percent late payment fee will be assessed for all payments not received within fifteen (15) days of the due date. An additional 5 percent late payment fee will be applied at thirty and sixty days past the due date.   Failure to pay the prescribed fees within ninety (90) days constitutes a violation of UST regulations and shall subject the person responsible person to enforcement actions. 

 

 

 

 

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No, aboveground storage tanks are regulated by the Louisiana State Fire Marshall’s Office (http://www.dps.state.la.us/sfm/ or 1-800-256-5452).

Aboveground storage tanks are regulated by LDEQ Water Quality Regulations under LAC 33:IX.Chapter 9. Spill Prevention Control if over 660 gallon capacity.

 

 

 

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The calibration of dispensers (gas pumps/fuel pumps) is regulated by the Louisiana Department of Agriculture, Department of Weights and Measures. For more information call (225)925-3780.
 
Air emissions from dispenser hoses are regulated by LDEQ Air Quality Regulations under LAC 33:III.2132.Stage II Vapor Recovery Systems for Control of Vehicle Refueling Emissions at Gasoline Dispensing Facilities.

 

 

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Please submit any further questions regarding registering USTs to _DEQ-wwwUST@LA.gov.

 

 

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Please follow this link to obtain all contact information for individual contact information as well as contact information for the UST Division. This includes the phone numbers, fax numbers, and addresses for all LDEQ Regional Offices. 
 

 

http://cms/portal/Portals/0/UndergroundStorageTank/UST%20Contacts%20Info%202%206%202014.pdf

 

 

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16. If tank hold water is removed from my UST site in order to perform repair work, how do I dispose of it?

Once the water has been removed from the tank hold, it cannot be discharged back into the tank hold.  Here are some options to properly dispose of the removed tank hold water:

  • Discharge the water via LDEQ General Permit.  Click here to obtain permit information for tanks, tank beds, new tanks and excavations.
  • Discharge the water to a Public Owner Treatment Works (POTW) that has agreed to take it.
  • Dispose of the water at a commercial Wastewater Treatment facility.
  • Recycle the water at a used oil recycling facility for its fuel content. 
 

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17. Does LDEQ approve the installation of the OPW Loop System?

LDEQ does not have an equipment approval program. All UST systems installed in Louisiana have to conform to the installation regulations specified in LAC 33:XI.303.  

LAC 33:XI.303 specifies that tanks and piping must be installed in accordance with the manufacturer’s instructions and a code of practice developed by one of the nationally-recognized associations that are listed in LAC 33:XI.599.Appendix.A.

General statements regarding piping slope with regards to interstitial monitoring, burial depth of piping, and testing of piping systems found in PEI RP100, API RP 1615, and NFPA 30A. All of the above issues listed in the guidance documents are qualified by statements such as “piping may slope”, or “as a general rule”. PEI, API, NFPA, and Louisiana UST regulations all state that UST equipment must be installed, operated, maintained, and tested in accordance with the manufacturer’s instructions. OPW has provided information verifying that a product release from any portion of the piping will travel to the nearest containment sump to allow detection. Ken Wilcox Associates has reviewed the Loop System and has stated that line leak detectors will work with this type system. 

After careful review of the guidance documents listed above, information provided by OPW,  and information provided by PEI and Ken Wilcox Associates (KWA) regarding these issues, LDEQ has no objection to the installation of the OPW Loop System for use as an underground storage tank system in Louisiana.

This approval not intended and should not be construed to be an endorsement of a particular product or an official equipment approval letter, as LDEQ does not have an equipment approval program.         

LDEQ will closely monitor OPW Loop Systems installed in Louisiana. If after installation, operational problem occur with this system that result in compliance issues with existing UST rules and regulations, LDEQ may withdraw this approval. Also, since LDEQ is an EPA authorized state, and if EPA determines that the use of this system is not approved, LDEQ may withdraw this approval. Click here to see OPW's memo regarding the differences between the Loop System and traditional piping system.

 

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18. Is Diesel Exhaust Fluid (DEF) a regulated substance, and is an underground storage tank that contains DEF regulated under by the UST regulations?

Diesel Exhaust Fluid (DEF) does not meet the regulatory definition of a regulated substance and underground storage tanks that contain DEF are not regulated underground storage tanks. See the attached EPA memo regarding the regulatory status of underground diesel exhaust fluid tanks. [attach DEF UST Memo.pdf]

  

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 UST Standards- Corrosion Protection, Spill & Overfill Protection, Certified Workers

 
 
Each tank must be properly designed and constructed, and any portion that routinely contains product must be protected from corrosion in accordance with Louisiana law. Please refer to Table 1.
 
 
TABLE 1

 

Tank Material
Acceptable Corrosion Protection
Fiberglass Reinforced Plastic
No corrosion protection is necessary
Metal with Cathodic Protection
Dielectric coating
OR
Field-installed cathodic protection system designed by a corrosion expert
OR
Impressed current system
OR
Cathodic protection system
Composite
(Steel with Fiberglass Reinforced Plastic)
No corrosion protection is necessary
Metal without Corrosion Protection
Corrosion expert has determined no leak will occur due to corrosion
Other
Must be approved by the department
 
 
Piping that routinely contains regulated substances and is in contact with the ground or water must be properly designed, constructed, and protected from corrosion in accordance with Louisiana law. Please refer to the Table 2.
 
TABLE 2

 

Piping Material
Acceptable Corrosion Protection
Fiberglass Reinforced Plastic
No corrosion protection is necessary
Metal with Cathodic Protection
Dielectric coating
OR
Field-installed cathodic protection system designed by a corrosion expert
OR
Impressed current system
OR
Cathodic protection system
Metal without Corrosion Protection
Corrosion expert has determined no leak will occur due to corrosion
Other
Must be approved by the department
 
Yes. Metal flexible hoses are used to connect rigid fiberglass piping to the dispensers and the submersible pumps. If metal flexible hoses are touching soil or water, they need protection from corrosion. Metal flexible hoses can be protected from corrosion in several ways:
  • Isolating the metal flexible hoses from soil or water by installing water-tight under-dispenser containment sumps and submersible pump containment sumps
  • Isolating the metal flexible hoses by covering them with a protective covering or “boot”
  • Protecting the metal flexible hoses from corrosion with either a cathodic protection system (anodes) or with an impressed current system

 

 

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Yes. If submersible pumps are touching soil or water, they need protection from corrosion. Submersible pumps may be protected from corrosion in several ways:
  • Isolating the submersible pump from soil or water by installing water-tight submersible pump containment sumps
  • Protecting the submersible pump from corrosion with either a cathodic protection system (anodes) or with an impressed current system
 

 

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Yes, both spill and overfill protection are required for the proper installation of new UST systems unless approval is granted by the department. The spill prevention equipment must prevent the release of product to the environment when the transfer hose is detached from the fill pipe (i.e. spill catchment basin). In order to meet the minimum requirements that are stipulated in the regulations, overfill protection equipment must meet at least one of the following requirements: automatically shut off flow 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 flow into the tank or triggering a high level alarm; restricting the flow 30 minutes prior to overfilling, or alert he operator with a high-level alarm one minute before overfilling, or automatically shut off flow into the tank. Typical overfill devices include overfill prevention valves that are installed in the drop tubes (often called butterfly or flapper valves), ball float valves, and overfill alarm systems.

 

 

 

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Only an individual certified in UST installation and repair may exercise supervisory control over the installation of a new UST system. 

 

 

  

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7.   Does LDEQ retroactively require UST owner/operators to replace their old flexible pipe with new pipe after the new UL 971 standard was issued in 2005?

No.  Louisiana does not require the removal or replacement of existing flexible pipe eith new pipe, unless that piping has damage.

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8.  Does LDEQ require that all of the flexible piping be replaced at a facility that reported a single release at a site, 2 releases, or just the portion of the system that caused the release? What type of criteria was used to require replacement of the old flexible pipe, if any?

LDEQ requires replacement of only the damaged piping, not all of the piping at the facility. After Jan 1, 2006, any replaced or new flexible piping installed has to meet the new UL971 standard.

 

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  UST Temporary and Permanent Closures 

 
1. Ensure that all underground storage tanks that are present at facility are registered with the DEQ prior to the UST closure or change-in-service. If the removal is an emergency, please contact the appropriate LDEQ Regional Office prior to the closure. You can find this contact information at the following link: http://www.deq.louisiana.gov/portal/tabid/2688/Default.aspx.
 
2. If the tank(s) are unregistered tanks:
Submit a completed UST Registration Form (UST-REG-01) and associated registration fees to the DEQ. A hard copy of this form may be requested from the department, or this form may be accessed online at http://www.deq.louisiana.gov/portal/tabid/2674/Default.aspx. When completing this form be sure to check the box “Registering to Close Tank” under Reason for Registration.
 
3.  If the tank(s) are registered:
Obtain a LDEQ Certified UST Closure Contractor to perform the closure. A complete list of certified workers is available at the following link:  http://www.deq.louisiana.gov/portal/tabid/2674/Default.aspx
 
4. At least thirty (30) days prior to the scheduled closure* submit a completed “Notification of Intent to Perform Closure or Change-In-Service to an UST System” form (NOI) to the appropriate LDEQ Regional Office. Although NOI forms are not available on the website, they can be obtained from any LDEQ Regional Office or from the LDEQ UST Support Group.
*Note: 30 day period may be waived by LDEQ Regional Office personnel if extenuating circumstances exist (expedited tank closure necessary, tank found during construction project, etc.).
         
5. At least seven (7) days prior to implementing the UST closure or change-in-service the UST Owner and/or the UST Certified Worker must contact the appropriate LDEQ Regional Office to inform the office of the schedule for closure. 
 
6. During the closure/change-in-service the LDEQ Certified UST Closure Contractor must adhere to the most current LDEQ Underground Storage Tank Closure/Change-In-Service Guidance Document. This document is available at the following website: http://www.deq.louisiana.gov/portal/tabid/2674/Default.aspx
At that time LDEQ UST Division personnel will usually be present to witness the UST closure sampling, and may request to be present during any UST closure critical juncture.
 
7. Within 60 days following the closure or change-in-service a UST Closure Assessment Form and Report must be submitted to the appropriate LDEQ Regional Office.   UST Closure Assessment Forms can be obtained from any LDEQ Regional Office or the LDEQ UST Support Group. NOI forms are four-page carbon forms and are not available on the LDEQ website.
If any UST closure sample result is above the UST Soil Screening Standards listed in Appendix K of the most current LDEQ Underground Storage Tank Closure/Change-In-Service Guidance Document, then LDEQ Single Point of Contact (SPOC) must be notified. SPOC notification can be made by phone, fax, or email. SPOC procedures can be found at the following website:
 
 
 
 
 
 
Underground Storage Tanks properly closed, either by removal or closed in-place by filling with a solid-inert material prior to 1974, are not required to be registered by the Department. If there is evidence of contamination, then samples should be collected. If contamination is discovered, it would be considered a solid waste site and further evaluation and/or remediation may be required.
 
 
 
 
 
  
 
Underground Storage Tanks properly closed prior to 1974 with a solid inert material do not require sampling upon removal unless there is evidence of contamination. Any solid material generated from the tank removal should be profiled for disposal (industrial solid waste) or a one time soil re-use via RECAP should be proposed. However, owners/operators of these sites may have liability should it be shown that a release to the environment did occur.  
 
 
 
 
October 20, 2003 RECAP standards.
 
 
 
 
Typically no. However, LDEQ will allow sampling of any solid material (i.e. solidified drilling mud) in the tanks to determine if it is inert, rather than requiring removal of the tanks.
 
 
 
 
Yes. Owners or operators of underground storage tanks taken out of service on or after January 1, 1974, were required to notify the Department of existence of such tanks on or before May 8, 1986, unless the owner or operator knows the tank was subsequently removed from the ground prior to that date. 
 
 
 
 
 
Sampling of pea gravel backfill during UST closure sampling is only required if the pea gravel appears to be saturated with product.
 
 
 
Temporary Closure is defined in LAC 33:XI.103.Definitions as “the temporary removal from service of a UST.” So anytime you take a UST system out of service, LDEQ considers this tank to be in temporary closure.
 
LAC 33:XI.903 allows underground storage tanks that have been upgraded with corrosion protection to remain in temporary closure indefinitely provided that all regulatory requirements are met. Continuous operation and maintenance of corrosion protection equipment on all metal components must be maintained. In addition, monthly release detection must be maintained for tanks that contain more than one inch of product (LAC 33:XI.903.A).
 
For example, for a STI-P3 tank, the anodes need testing every three years (LAC 33:XI.503). For a steel tank with an impressed current system, the impressed current system must remain on, be tested every three years, and the rectifier inspected every 60 days to ensure that the equipment is running properly (LAC 33:XI.503). Also, all other metal components (piping, metal flexible hoses, and submersible turbine pump components) that are in contact with soil or water need continuous corrosion protection while in temporary closure.
 
When a UST system is temporarily closed for three months or more, the vent lines must be open and functioning, all lines, pumps, man ways, and ancillary equipment must be capped and secured, and an updated Registration form (UST-REG-01) must be submitted to LDEQ indicating the date the tanks were temporarily closed (LAC 33:XI.903.B).
 
USTs systems that have been temporarily closed for three months are more that are brought back into service must have tightness testing performed within five (5) days returning into service (LAC 33:XI.903.E).
 
UST systems that have not been upgraded with corrosion protection must be permanently closed after being in temporary closure for more than six months (LAC 33:XI.903.C).
 
For UST systems that have been upgraded with corrosion protection and have been in temporary closure for more than 24 months, LAC 33:XI.903.D requires UST owners or operators to perform a site assessment in accordance with LAC 33:XI.907. The reference to LAC 33:XI.907 requires the sampling locations of the site assessment to be consistent with the UST closure-in-place site assessment sampling requirements.
 
The 24-month site assessment is only required one time as long as the UST system remains empty of product. If the tanks are never returned into commerce and are permanently closed at a later date, then the 24-month site assessment sampling can be used as permanent closure sampling as long as the tanks have remained empty during temporary closure. Additional permanent closure samples could be required if any contamination discovered during permanent closure was not identified during the temporary closure site assessment. Please coordinate performance of the 24-month temporary closure assessment with the appropriate LDEQ Regional Office. LDEQ Regional Office contacts are available at this web address: http://www.deq.louisiana.gov/portal/tabid/2659/Default.aspx
 

 


  Internal Lining Inspections

 1. What are the 1998 upgrade requirements?

 
LAC 33:XI.303.C.3 states that all steel tanks were required to either be upgraded (in accordance with LAC 33:XI.303.A) with corrosion protection or permanently closed by 12/22/98.
The following three methods of upgrade options were allowed:
1) Addition of an internal liner.
2) Addition of a cathodic protection system
3) Combination of an internal liner and a cathodic protection system
Regulations:
 
LAC 33:XI.303.C.3.a
Internal Liner
The internal liner requirements are as follows:
 
Within 10 years after lining, and every 5 years thereafter, the lined tank is internally inspected and found to be structurally sound with the lining still performing in accordance with the original design specifications (LAC 33:XI.303.C.3.a.ii)
 
LAC 33:XI.303.A lists all the codes of practices developed by nationally recognized organizations that are to be used to comply with the UST regulations. LAC XI.303.A requires the internal lining inspection to meet one of these recommended practices:
NLPA 631 - Requires a visual inspection of the lining and a determination of the metal thickness through the lining by ultrasonic testing. This method required physical entry into the tank.
 
API 1631 – Requires physical entry into the tank for both a visual inspection of the lining and a tank metal thickness determination. A video inspection following the KWA method is allowed under API 1631.
 
KWA method – Requires a permanently recorded internal video inspection of the tank lining and a non-invasive external assessment for predicted structural integrity of the tank. The non-invasive test is a prediction model as described in ASTM G158-98, Section 11.3.5.1. Site specific parameters that are needed for the prediction model include stray currents, soil resistivity, structure-to-soil potential, soil pH, electrical continuity, REDOX potential, soluble chloride ion concentration, sulfide and sulfate ion concentrations, and any other tests deemed necessary by the corrosion specialist that is doing the predictions.
 
LAC 33:XI.303.C.3.b
Cathodic Protection
 
A tank may be upgraded with cathodic protection (anodes or an impressed current system) if the CP system meets these requirements:
 
1) CP system is designed by a corrosion expert
2) Current operating status can be determined by rectifier inspections (every 60 days)
3) CP system is operated continuously and tested every 3 years by a qualified CP tester
 
In addition, to the requirements listed above, the tank integrity must be ensured using one of the following methods:
 
1)  Tank is internally inspected and assessed to ensure that the tank is structurally sound and free of corrosion holes (NLPA 631) before the CP system is installed (LAC 33:XI.303.C.3.b.i).
2)  Tank is less than 10 years old and has met the release detection monitoring requirements (LAC 33:XI.303.C.3.b.ii).
3)  Tank is less than 10 years old and is assessed for corrosion holes by conducting 2 tightness tests. One tightness test before the addition of the CP system, and one tightness test between 3 and 6 months after the first operation of the CP system (LAC 33:XI.303.C.3.b.iii).
4)  Tank is assessed for corrosion holes by a method determined by the Department to prevent releases in a manner that is no less protective of human health and the environment than the methods listed above (LAC 33:XI.303.C.3.b.iv).
 
LAC 33:XI.303.C.3.c
Internal Lining Combined with Cathodic Protection
 
No lining inspections are required if either the CP is added at the same time as the lining is installed, or a tank integrity assessment is conducted prior to addition of the CP system, and as long as the CP system meets these CP system requirements:
 
1) CP system is designed by a corrosion expert
2) Current operating status can be determined by rectifier inspections (every 60 days)
3) CP system is operated continuously and tested every 3 years by a qualified tester
 
 
  
 
 
 
Tank owners must either perform the 10-year internal lining inspection or perform a tank integrity assessment prior to installing a corrosion protection system (usually an impressed current system). Below is a list of tank integrity assessment options allowed by LDEQ:
 
Tank Integrity Assessment Options Allowed by LDEQ:
 
Tank owners that add corrosion protection to previously lined tanks do not have to perform the 10-year lining inspections, provided that a tank integrity assessment is performed. Listed below are three tank integrity assessment options approved by LDEQ. Tank integrity assessments can be either invasive (Option A) or non-invasive (Options B and C).
 
Option A:     Ensure tank integrity by using a method in accordance with a standard code of practice developed by a nationally recognized association or independent testing laboratory:
1)   NLPA 631 - Requires a visual inspection of the lining and a determination of the metal thickness through the lining by ultrasonic testing. This method required physical entry into the tank.
Results:
·    Average tank metal thickness shall be at least 75% of original tank metal thickness to pass.
·    Tanks not meeting wall thickness of 75% fail and shall be closed.
·    If average tank metal thickness is between 75% and 85%, a CP system (impressed current) shall be installed within 1 year of inspection date. At that time, no more lining inspections are needed.
·    If average tank metal thickness is >85%, addition of external CP is not required
2)   API 1631 - Requires physical entry into the tank for both a visual inspection of the lining and a tank metal thickness determination. A video inspection following the KWA method is allowed under API 1631
3)   KWA Method - Requires a permanently recorded internal video inspection of the tank lining and a non-invasive external assessment for predicted structural integrity of the tank. The non-invasive test is a prediction model as described in ASTM G158-98, Section 11.3.5.1. Site specific parameters that are needed for the prediction model include stray currents, soil resistivity, structure-to-soil potential, soil pH, electrical continuity, REDOX potential, soluble chloride ion concentration, sulfide and sulfate ion concentrations, and any other tests deemed necessary by the corrosion specialist that is doing the predictions.
Results:
·    If the tank fails the prediction model, it cannot be re-lined unless tank integrity and wall thickness are determined adequate by a manned entry procedure.
·    CP can only be applied if both the lining inspection and structural integrity modeling passes.
·    If the lining inspection fails, it has to be repaired or replaced before an impressed current system is added.
4)   ASTM G 158 – Requires either non-invasive statistical modeling (based on soil sampling), invasive ultrasonic thickness testing with external corrosion evaluation (physical internal inspection and soil sampling), or invasive permanently recorded visual inspection and evaluation including external corrosion assessment (video camera or physical inspection and soil sampling).
 
Option B:        Ensure tank integrity by using a vendor supplied procedure that has been successfully evaluated and certified by a qualified independent third party to meet specified performance criteria regarding detection of perforations and detection of either internal or external damage (A list of integrity assessments is outlined in a 2/09/99 EPA memo):
1)  Mean Time to Corrosion Failure (MTCF) – Requires soil sampling and statistical prediction modeling
2)  Tank Environmental Profiling (TEP) - Requires soil sampling and statistical prediction modeling
3)  Petroscope – Requires video camera inspection with soil sampling and statistical prediction modeling
4)  Tank Suitability Study (TSS) - Requires soil sampling and statistical prediction modeling
 
Option C:        Ensure tank integrity by using an alternative integrity assessment method approved by LDEQ, herein called the Louisiana Alternative Assessment Procedure (LAAP). Use of this option will not relieve the facility of any compliance issues associated with missed deadlines or improper evaluation prior to the deadline. To be eligible to use the LAAP, all of the following procedures must be adhered to without exception:
1)   Tank tightness test performed prior to the installation of an impressed current system. If a tank fails the tightness test, it must be either adequately repaired or upgraded prior to installation of the CP system, or permanently closed.
2)   Tank tightness test performed between 3 and 6 months after the installation of an impressed current system. If a tank fails the tightness test, it must be adequately repaired, upgraded, or permanently closed.
3)   Perform monthly release detection by one of the release detection methods outlined in LAC 33:XI.701.A.3-8 only. Inventory control or manual tank gauging release detection methods are not allowed on tanks assessed using LAAP.
4)   Perform annual tank tightness testing. Annual tank tightness testing must be conducted starting from the date of the 3 to 6 month tank tightness test. If a tank fails any tank tightness test, it must be adequately repaired, upgraded, or permanently closed.
5)   Facilities that installed corrosion protection systems to lined tanks without performing a tank integrity assessment may begin using this option by performing a tank tightness test immediately, then annually thereafter. The facility must immediately begin using one of the monthly release detection methods outlined in LAC 33:XI.701.A.3-8 only. Inventory control or manual tank gauging release detection methods are not allowed on tanks assessed using LAAP.
 
 
 
 
Facilities that have installed corrosion protection systems on lined tanks without performing a tank integrity assessment must either have a tank integrity assessment performed or have the internal lining inspected. Any of the three tank integrity assessment options approved by LDEQ can be performed. If the LAAP option is selected, a tank tightness test must be performed as soon as possible, and annual tank tightness testing performed thereafter, and a monthly release detection method other than inventory control or manual tank gauging must be performed. Performance of these actions will not relieve the facility of compliance issues related to regulatory deadlines that have been missed or improper evaluations prior to the deadline.
 
 
 
 
 
 
It depends on the inspection method chosen.  Physical entry into the tank will enable the inspector to perform an integrity assessment of the internal lining and to determine the tank metal thickness by ultrasonic testing.
 
The use of a video camera to determine the tank lining integrity is allowed, but must be used in conjunction with soil sampling. Since the tank metal thickness cannot be determined using the video camera, soil sampling is required to allow for a determination of how long it will take the steel tank exterior to corrode given the specific soil conditions at your site.
Examples:
 
NLPA 631 - Requires physical entry into the tank to perform a visual inspection of the lining and a determination of the metal thickness through the lining by ultrasonic testing.
 
API 1631 – Requires either physical entry into the tank for both a visual inspection of the lining and a tank metal thickness determination, or a video inspection following the KWA method.
 
KWA method – Requires a permanently recorded internal video inspection of the tank lining and a non-invasive external assessment for predicted structural integrity of the tank. The non-invasive test is a prediction model as described in ASTM G158-98, Section 11.3.5.1. Site specific parameters that are needed for the prediction model include stray currents, soil resistivity, structure-to-soil potential, soil pH, electrical continuity, REDOX potential, soluble chloride ion concentration, sulfide and sulfate ion concentrations, and any other tests deemed necessary by the corrosion specialist that is doing the predictions.
  
 
If the internal inspection method chosen is the KWA Method (video camera), then soil testing is required. The video camera is used to assess the integrity of the internal liner. The soil testing is used to determine how long it will take the steel tank exterior to corrode given the specific soil conditions at your site.
 
If an internal inspection of the tank lining is conducted using the NLPA 631 Method (physical entry into the tank), then no soil sampling is required. The internal lining is assessed physically by the inspector that enters the tank. The tank metal thickness is determined by ultrasonic testing from inside the tank.
 
 
 
    
 
 
An automatic tank gauge (ATG) or statistical inventory reconciliation (SIR) can be used for the annual tank tightness testing requirement of the Louisiana Alternative Assessment Procedure as long as the annual ATG or SIR test meets a 0.1gph leak rate with a probability of detection of at least 95% and a probability of false alarm of less than 5%, and the manufacturers’ instructions and/or third party certification are followed for the tests. The tank tightness testing required before installation of the impressed current system and 3 to 6 months after installation of the impressed current system must be conducted using a precision volumetric or non-volumetric tank tightness test method (not ATG or SIR ) that follows the manufacturers’ instructions and/or third party certification. All tank tightness testing methods (precision tank tightness test, ATG, or SIR) must be capable of detecting a 0.1 gallon per hour leak rate from any portion of the tank that routinely contains product. For example, if a precision volumetric tank tightness test is conducted at a 20% product level, but the tank routinely contains product at the 50% level, the tank tightness test will not be valid because it did not test the area of the tank between the 20% and 50% product levels.
 
 
 

 


Stage I & II Vapor Recovery

 
 
Pump decals for Stage II Recovery system shall include the following language:
 
This fuel dispenser is equipped with a system that is designed to recover vapors from gasoline during refueling. Warning: Continued attempts to dispense gasoline after the system indicates that the vehicle tank is full (“topping off”) may result in spillage or recirculation of gasoline.
  
If you have any questions, problems or concerns regarding the operation of this vapor recovery system please contact the Louisiana Department of Enviromental Quality at (225) 219-3181. 
  
 

 

   
 
 
Although Stage I may eventually be required in any new nonattainment areas, it is not required at this time. LDEQ has until March 12, 2009 to make our official attainment/nonattainment recommendations to EPA and they have until March 12, 2010 to make them official. LDEQ will make certain that affected facilities have adequate notice and input into any rulemakings associated with this change. In addition, there will likely be a compliance period associated with any new rule. 
   
 
  
 
 
On January 10, 2008, EPA published new National Emission Standards for Hazardous Air Pollutants (NESHAP) rules in the Federal Register that apply to gasoline dispensing facilities (GDF).
 
Compliance Dates:
Existing sources, facilities constructed before November 11, 2006, have to meet the new requirements by January 10, 2011.
 
New sources, facilities constructed after November 11, 2006, have to meet the new standards by January 10, 2008, or upon start-up.
 
EPA has primary enforcement responsibility for these rules at this time.
 
Standards for facilities with <10,000 gallon per month throughput and all USTs under 250 gallons:
     Minimize spills
     Clean up spills expeditiously
     Keep tanks closed with gaskets on all fill-pipe covers
     Have records available within 24 hours of request to prove throughput
 
Standards for facilities with >10,000 gallon per month throughput:
     Meet <10,000 requirements plus:
     If UST installed on or before 11/9/06 - Drop tubes <12" from bottom
     If UST installed after 11/9/06 - Drop tubes <6" from bottom
     Notification to EPA by May 9, 2008 (not required if required controls were installed prior to 1/10/08)
 
Standards for facilities with >100,000 gallon per month throughput:
     Meet the >10,000 requirements plus:
     Vapor balancing is required
 
 
Vapor balance system means a combination of pipes and hoses that create a closed system between the vapor spaces of an unloading gasoline cargo tank and a receiving storage tank such that vapors displaced from the storage tank are transferred to the gasoline cargo tank being unloaded.
 
A brochure outlining the above information can be accessed here:
     
 
   
 
 
 
a)      What drives the use of drop tubes and Stage One Vapor Recovery on Underground Storage Tanks are the Air Regulations, LAC 33: III.2103 and LAC 33:III.2131.
 
1)      LAC 33:III.2103.A - states that in all parishes of the state of Louisiana, either drop tubes to within one (1) foot of the bottom of the tank or vapor loss control systems (i.e. - Stage One Vapor Recovery) is required for all underground storage tanks with a capacity of 250 gallons or greater, storing all types of gasoline only, with the exception of JP-4 fuels.
 
2)       LAC 33:III.2131.A - states that the transfer of gasoline from any delivery vessel (i.e. – bulk distributor vehicle) to an underground storage tank (UST), with a capacity of 250 gallons or greater, is required to be equipped with drop tubes to within one (1) foot of the bottom the tank and a vapor recovery systems (i.e. - Stage One Vapor Recovery), which reduces emissions by at least 90 percent, unless one of the following exemptions are met.
 
a)      There is an exemption from the regulation, for all parishes in the state of Louisiana except Bossier, Caddo, Beauregard, Calcasieu, Livingston, Pointe Coupee, East Baton Rouge, West Baton Rouge, Iberville, Lafayette, St. Mary, Ascension, St. James, St. John the Baptist, St. Charles, Lafourche, Jefferson, Orleans, St. Bernard, and Grant.
 
b)      There are further exemptions from the regulation for:
 
1)              for any gasoline outlet in the parishes of Ascension, Calcasieu, East Baton Rouge, Iberville, Livingston, Pointe Coupee, and West Baton Rouge whose throughput is less than 120,000 gallons per year or any gasoline outlet in the parishes of Beauregard, Bossier, Caddo, Grant, Jefferson, Lafayette, Lafourche, Orleans, St. Bernard, St. Charles, St. James, St. John the Baptist, and St. Mary whose throughput is less than 500,000 gallons per year. 
 
Note: Once the rolling 30 day average throughput exceeds 10,000 gallons for a facility in the parishes of Ascension, Calcasieu, East Baton Rouge, Iberville, Livingston, Pointe Coupee, and West Baton Rouge or 42,000 gallons for a facility in the parishes of Beauregard, Bossier, Caddo, Grant, Jefferson, Lafayette, Lafourche, Orleans, St. Bernard, St. Charles, St. James, St. John the Baptist, and St. Mary that facility becomes an affected facility and does not revert to an exempt facility when or if the throughput drops back below the throughput exemption level.
 
2)              For tanks with a capacity of 2,000 gallons or less installed before January 1, 1979, and new tanks with a capacity of 250 gallons or less installed after December 31, 1978.
 
3)              For tanks with drop tubes having a capacity of less than 550 gallons used exclusively to fuel farm implements.
 
4)              For transfers made to storage tanks with a capacity greater than 40,000 gallons and equipped with controls as required by LAC 33:III.2103 of these regulations.
 
c)      The Owner/Operator of an affect facility that is required to comply with the regulations shall maintain records to verify compliance.
   
 
  
 
 
 
What drives the use of Stage II Vapor Recovery Systems on Underground Storage Tanks is the Air Regulation, LAC 33:III.2132.
  
1)  All motor vehicle fuel dispensing facilities in the parishes of Ascension, East Baton Rouge, Iberville, Livingston, Pointe Coupee, and West Baton Rouge are affected and must use Stage II Vapor Recovery Systems.
 
2)  All existing motor vehicle fuel dispensing facilities when the rules were promulgated and all new motor vehicle fuel dispensing facilities constructed since the rules were promulgated that dispense greater than 10,000 gallons per month (50,000 gallons per month in the case of an independent small business marketer of gasoline) are subject to this regulation and must use Stage II Vapor Recovery Systems.
 
 

   


 Alternative Fuels

 
 
 
Ethanol produced from corn, sugar cane, and other biomasses is blended with gasoline. E10 is a blend of 90% gasoline and 10% ethanol. E85 is a blend of 15% gasoline and 85% ethanol. Another type of alternative fuel is biodiesel. Biodiesel, designated as B100, is refined methyl ester made from vegetable oils or animal fats and meets ASTM D 6751 specifications. Biodiesel can be used as a pure fuel (B100), or blended with petroleum diesel. The most common blend is B20 (20% biodiesel and 80% petroleum diesel). Biodiesel is also blended in B5 and B10 blends.
 
 
 
 
 
 
 
Yes, some of the common problems associated with UST systems that store and dispense alternative fuels are:
 
1)      Releases due to incompatibility of the UST system with the product stored
2)      Phase separation of the product due to water intrusion into the UST system
3)      Accelerated corrosion of UST system equipment
 
 
 
 
 
 
When converting an existing UST system for use with any alternative fuel, UST Owners and Operators are responsible for the following:
 
1)      Determine UST system compatibility (LAC 33:XI.505.A). Determine that the UST system is compatible with the material that is going to be stored in the UST system. The following equipment, components, and materials must be compatible with the regulated substance stored in the UST system:
 
a.         Tank
b.        Internal tank lining
c.         Piping material
d.        Pipe adhesives and glues
e.         Flexible connectors, fittings
f.         Fill pipe and drop tube
g.        Spill and overfill prevention equipment
h.        Submersible pump, all submersible pump components
i.          All gaskets, bushings, couplings
j.          Line leak detectors
k.        Leak detection equipment (ATG probes, floats, sensors)
l.          Dispensers
m.      Dispenser filters
n.        Hoses (including breakaway couplings and fittings)
o.        Nozzles
p.        Spill containment sumps
 
LAC 33:XI.505.A requires UST owners and operators to use a UST system made of or lined with materials that are compatible with the substance stored in the UST system.
 
Although LDEQ regulations do not have specific recordkeeping or reporting requirements dealing with UST system compatibility, UST owners and operators should compile and maintain UST system compatibility records in the event that a release from the UST system occurs. If LDEQ determines that a release of a regulated substance occurs as a result of incompatibility, an enforcement action (order and/or penalty) is possible.
 
2)      Follow recommended practices for storage and handling (LAC 33:XI.505.B). Follow the recommended practices outlined in API Recommended Practice 1626, “Storing and Handling Ethanol and Gasoline-Ethanol Blends at Distribution Terminals and Service Stations” for proper storage and handling of ethanol-gasoline blends.
 
LAC 33:XI.505.B requires UST owners and operators storing alcohol blends to do so in accordance with LAC 33:XI.501.A (Follow the guidelines in API Recommended Practice 1626, “Storing and Handling Ethanol and Gasoline-Ethanol Blends at Distribution Terminals and Service Stations”).
 
API 1626, Section 3.2, provides an example of an acceptable method of converting an existing UST system storing other products to storing ethanol blends. Conversion documents are available on the internet from many different sources (web links below), and are also available from most fuel suppliers.
 
The conversion steps listed below are present in most conversion documents and should be followed:
a.         Determine and ensure UST system compatibility
b.        Inspect entire system for water intrusion
c.         Clean tank of all water and sediment
d.        Replace all dispenser filters with appropriate filters
e.         Determine and ensure dispenser equipment compatibility
f.         Calibrate dispensing and leak detection equipment
g.        Properly label all dispensers and fill ports
h.        Inspect system regularly for leaks and/or water intrusion
 
3)      Update registration information (LAC 33:XI.301.A.3 and 301.B). Update UST-REG-01 form to reflect the change in the regulated substance stored in the UST system.
 
LAC 33:XI.301.B and LAC 33:XI.301.A.3 requires UST owners and operators to update the Registration Form UST-REG-01 for all UST system changes. This includes the type of regulated substance stored in the UST system.
 
 

 


 

 
 
 
 
 
 

 

 

 

 

 

 

 

 

 

 

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