Underground storage tanks: the environmental health role.

Chapter 40, Parts 280 and 281 of the Code of Federal Regulations is the driving force in the modernization of the nation's underground storage tanks (USTs) used for motor fuels and oils. In order to accomplish such a massive task, the EPA delegated the authority to states which, in turn, contracted local environmental health departments for assistance. In Las Vegas, the Clark County Health District is the implementing agency for the upgrading and retrofitting of approximately 1,400 facilities with USTs. The job involves the following aspects of regulation and oversight: 1. UST registration; 2. permanent UST closure; 3. site remediation; 4. UST installation; and 5. leak detection compliance inspection.

Phase I: Notification

The first phase of Clark County's UST program was to locate abandoned and non-registered USTs, in order to establish an accurate database. Our approach was to register all USTs into the State Petroleum Fund, so that corrective action or upgrading would not create an undue financial burden to business owners. The State of Nevada supports business and provides an excellent $10,000 deductible insurance for petroleum clean-up at $50 per year per tank. Clark County Health District entered Phase I by combing industrial and commercial zoned areas for USTs. Classified advertising and public seminars were used to inform the community of the potential problems with old UST systems and the importance of system registration. Since compliance deadlines were approaching, businesses needed to budget funds and to make decisions for the future use of their USTs.

Phase II: UST Permanent Closure and Release Remediation

Businesses, that decided it was best to discontinue use of their UST or that discovered potential problems, took action to permanently close their tanks, following recommended guidelines and established state and federal regulations. Tanks, which had been out-of-service for periods over one year, were required to permanently close, in accordance with the Uniform Fire Code, Section 79.115(f) and 40 CFR 280.70(c). To protect businesses that owned or operated USTs, Nevada established certification requirements for companies, providing UST closure and environmental assessment services.

Phase II involved developing a permitting and inspection program for permanent closure operations. Memoranda of Understanding were established with the local fire departments to eliminate dual inspection responsibilities. Health district permit application procedures included:

1. completion of an application form identifying responsible parties and their representatives:

2. proof of Nevada Certification for Environmental Managers and UST Handlers;

3. completion of air pollution notification form:

4. provision of map with:

a) location of tanks, lines, ancillary equipment, and nearby buildings;

b) estimation of groundwater gradient and depth;

c) prediction of direction and height of hydrocarbon venting; and

d) identification of a safe area to center operations (leeward control point);

5. provision of supplemental information identifying:

a) UST contents and additives and their final disposition;

b) tank cleaning rinsate and sludge disposal method;

c) method of tank transportation, storage, destruction, and disposal;

d) final disposition of piping and ancillary equipment;

e) contaminated soil transportation, storage, and disposal methods;

f) UST purging or inerting method;

g) oxygen and explosimeter factory calibration dates;

h) laboratory and environmental analysis used; and

i) a site safety plan.

An on-site inspection checklist was developed to verify the above information and compliance with the Uniform Fire Code 79.115 (d). Tank removal procedures follow the guidelines set forth by American Petroleum Institute-Recommended Practice 1604.

The closure report must provide:

1. laboratory analysis reports:

2. map or narrative indicating the location and depth of environmental samples;

3. documentation for the final disposition of the tank and lines:

4. documentation for the final disposition of the tank contents, sludge and/or rinsate;

5. documentation for the final disposition of contaminated soil stockpiles or ground-water discharge;

6. a narrative describing activity chronology and conclusions; and

7. an updated EPA Form 7530-1 indicating permanent UST closure.

In the event that a significant release of petroleum product is discovered during permanent closure activities, then 40 CFR 280, Subpart E and F must be followed. All site characterizations, corrective action plans, and closure reports are reviewed and approved by Clark County Environmental Health.

Phase III: UST Installation Plan Review and Leak Detection Compliance Inspection

In order to be considered no less stringent than corresponding federal requirements, Clark County Health District requires a permit for tank and line installation or replacement, corrosion control upgrades, leak detection retrofits, overfill prevention device and containment sump retrofits, or major repairs on regulated UST systems. A permit application, plans, and specifications must be submitted as follows:

1. plans that include:

a) a site map of USTs, lines, and buildings;

b) a top and side view of tank identifying:

(1) overfill prevention devices,

(2) spill containment manholes or sumps,

(3) tank leak detectors, sensors or gauges,

(4) leak detector monitoring boxes,

(5) line leak detectors for pressurized lines, and

(6) a check valve, slope, and cover for suction lines;

2. specifications that provide:

a) the method of tank leak detection;

b) the method of line leak detection;

c) material or corrosion protection for lines and tank;

d) overfill devices; and

e) spill containment systems;

3. an original or updated EPA Form 7530-1; and

4. a site safety plan.

When the application, plans, and specifications are submitted, the environmental health office issues a self-inspection checklist and a fire department checklist. Installation activities do not begin until the responsible party has received the Health District's approval. The fire department inspection checklist must be posted on-site to receive their inspections.

After the UST is installed, the environmental health office conducts a final inspection with the owner/operator and the UST installer. The self-inspection checklist and manufacturer's leak detector operating manual must be presented. This inspection is to verify that proper leak detection and prevention devices are utilized and that the leak detection records will be kept in accordance with EPA standards.

Leak detection compliance inspections are also a function of Phase III. Initially, the Health District mailed the owners of registered UST systems in Clark County a letter requesting that they identify their present methods of leak detection, corrosion control, and overfill/spill prevention. Page 5 of the revised (9/89) EPA Form 7530-1 was used for this purpose. On-site inspections are conducted for each facility to verify compliance. Greater emphasis is exerted for non-compliant UST systems.

Conclusion

The three phases of the Clark County UST Program were incorporated because of limited funding and personnel. Consideration of business budgets was emphasized during the program development. Under the guidance of EPA and the Nevada Division of Environmental Protection, Clark County has experienced considerable success modernizing the methods of underground petroleum storage and cleaning up past petroleum releases. Subsequently, we are confident that the improvement to our out-of-site, subsurface environment will contribute to the better health, well-being, and safety of our community and will provide our many tourists with an enjoyable place to visit.

References

1. Code of Federal Regulations, Chapter 40, Parts 280 and 281. Government Institutes, Inc., Rockville, MD.

2. "Hazardous Materials-Storage Tanks." Nevada Revised Statutes, Chapter 459, 459.800-459.856, Legislative Counsel Bureau, Carson City, NV.

3. "Hazardous Materials-Storage Tanks." Nevada Administrative Code, Chapter 459, 459.9921-459.999, Legislative Counsel Bureau, Carson City, NV.

4. API/RP 1604, "Recommended Practice for the Removal of Used Underground Storage Tanks," American Petroleum Institute, Washington, DC.

5. PEI/RP 100-90, "Recommended Practices for Installation of Underground Liquid Storage Systems," Tulsa, OK.

6. Uniform Fire Code, Section 79.115, International Code Institute, Whittier, CA.

7. Controlling UST Clean-up Costs, U.S. EPA. Office of Solid Waste and Emergency Response, Washington, DC.

8. Information on Ordering UST Materials, U.S. EPA, Superintendent of Documents, Pittsburgh, PA.

Steve Henke, RS, CEM, Sr. Environmental Health Specialist, Environmental Health Division, Clark Co. Health District, P.O. Box 4426, Las Vegas, NV 89106