Post on 10-Mar-2018
NYSDEC is Auditing You Tomorrow – Are You Ready?
Presented By: Mary Passaretti, M.S., Hydrogeologist
Aztech Technologies, Inc.
Managing Gas Station Environmental Compliance
Paperwork (Inside) Considerations
Is your registration clearly posted and all information correct?
Paperwork (Inside) Considerations
Is your Facility Information Report (FIR) Correct?
Paperwork (Inside) Considerations
Accurate as-built plans are required and should be kept at the site
for the duration of the tanks.
Must have a Certification
Statement.
Installed in accordance with
6 NYCRR Part 614.
Paperwork (Inside) Considerations
Tanks and underground piping installed after December 27, 1986
must be corrosion resistant.
Tested annually by a “qualified CP tester”.
Test results maintained for a minimum of one year.
Paperwork (Inside) Considerations
NYSDEC regulated USTs installed after December 27, 1986 must have secondary containment.
Monitored weekly with one year of records maintained on site.
Paperwork (Inside) Considerations
All pressurized piping must have two forms of leak detection.
1. Automatic Line Leak Detector (ALLD).
Tested annually with one year of records on-site.
2. and ONE of the following methods:
Annual line test -OR-
Groundwater and vapor monitoring wells -OR-
Interstitial monitoring of double walled piping -OR-
Statistical inventory reconciliation.
Paperwork (Inside) Considerations
Inventory Reconciliation
Loss or gain of greater than 0.75% over a ten day cycle.
Keep records for five years.
Aztech recommends one year of records on-site.
Paperwork Summary
PBS registration – Current and valid at all times, posted at
facility and updated every 5 years (or when modifications are
made).
As-builts – located at the facility for life of the tanks.
Cathodic Protection (tanks and/or piping) – tested annually
and one year of records at the facility.
ALLD – tested annually with one year of records kept at the
facility.
Paperwork Summary
Monitoring of any leak systems – tested weekly, and one
year of records at the facility.
Secondary containment and leak detection systems must be
monitored monthly for functionality and records kept at the
facility for one year.
Inventory reconciliation – Daily and 5 years of records
made available upon request (Aztech recommends that one
year be at the site).
Outside Considerations
Make sure that all fill ports, vapor
recovery points and monitoring
wells are accurately and freshly
painted.
Fuel extends (ethanol) must have a
contrasting boarder typically black
and white.
Outside Considerations
Are the spill buckets or catch basins around the fill
ports maintained.
Outside Considerations
Are Submersible Transfer Pump (STP) Sumps being
properly maintained?
Outside Considerations
Are you monitoring your pressurized piping? Do you
have two forms of leak detection?
Automatic Line Leak Detector (ALLD)
and ONE of the following methods:
a) annual line test, b) groundwater and vapor monitoring
wells, c) interstitial monitoring of double walled piping
must be monitored weekly and records for the past year
kept on site or d) statistical inventory reconciliation.
Outside Considerations
Are the dispenser shear valves secure?
The NFPA requires an annual functionality test of shear
valves – Aztech recommends that one year of records be
kept on site.
Outside Considerations
Are the shear valves properly positioned?
Are your containment sumps maintained?
Mary Passaretti, M.S., Hydrogeologist, President
Aztech Technologies, Inc.
www.aztechtech.com
Petroleum Spills and Reporting
Presented By: Michael Maegerle, PG
Groundwater & Environmental Services, Inc.
Managing Gas Station Environmental Compliance
NY Spill Reporting Requirements
All petroleum spills that occur within New
York State must be reported to the NYS Spill
Hotline (1-800-457-7362) within 2
hours of discovery, except for spills which
meet all of the following criteria:
NY Spill Reporting Requirements
A spill does not need to be called into the Spills Hotline if:
The quantity is known to be less than 5 gallons; and
The spill is contained and under the control of the spiller; and
The spill has not and will not reach the State’s water or any
land; and
The spill is cleaned up within 2 hours of discovery.
NY Spill Reporting Requirements
A gasoline or oil spill absolutely should be called into the Spill
Hotline, regardless of quantity, if it:
Has impacted soil, grass, or a landscaped area,
Has been discharged into a well or vault,
Has been discharged into a storm water or septic system
Has been discharged to the subsurface via cracks in the
asphalt/pavement.
For spills not deemed reportable, it is strongly recommended
that the facts concerning the incident be documented by the
facility and a record maintained for one year.
A good filing system is a must ...
A spill on a dirt or gravel parking lot is considered to
have impacted the environmental and is reportable to the
Spills Hotline, regardless of volume.
Key Components of a Spill Cleanup
Petroleum Spill Cleanup
Speedy Dry 55 Gallon Drum
Failure to Report a Spill
Per the Navigation Law, Failure to
report a spill can result in fines up to
$37,500 per day, per Navigation Law.
Don’t be, “Penny Wise and Pound Foolish”
$5,000 Fine = 100,000 Gallons @ 5cpg
Inventory Reconciliation
Call to Spill Hotline also required when:
Results of any inventory, record or test or inspection shows
a facility is leaking.
Inventory records can be wrong and facility may not
actually be leaking.
Records may show a potential problem.
Call it in and can get it reconciled easily.
Who is Required to Call In a Spill ?
Per PBS Regulations, any person with knowledge of a spill,
leak or discharge is required to call the spill into the
NYSDEC Spills Hotline.
1-800-457-7362
Michael Maegerle, PG
Groundwater & Environmental Services, Inc.
www.gesonline.com
Managing Gas Station Environmental Compliance
SUMMARY OF MAJOR CHANGES to
6 NYCRR PART 613: Petroleum Bulk Storage
(PBS) Tanks
Jen Kotch, HRP Associates, Inc.
UST Definition
The definition of underground storage tank (UST)
system is being modified to match the corresponding
definition in the federal UST regulations (40 CFR Part
280) (10% or more under ground). Aboveground
storage tank (AST) system is being defined as the
converse of UST system.
Overview of Proposed Changes to Part 613
Categories of USTs.
Changing testing frequency for USTs.
As-Built requirements.
Spill Requirements, Investigation, and Remediation.
Potential Delivery Prohibition.
Operator training requirements.
Three Categories of USTs (based on date of tank install).
C1 = Prior to December 1986, C1 UST’s will require annual
tight test and line testing for suction piping;
C2 = 1986 through the new regulation effective date; and
C3 = Tanks installed once the new regulations are in effect.
As-Built Plans/Site Drawings
DER 25/ Petroleum Bulk Storage (PBS) inspection Handbook
regulates as-built drawings for USTs installed after December
27, 1986.
Its new in that it will now appear in the proposed regulations –
so really, it is kind of new. And is now….. Enforceable!
The inspector must make sure that facilities with USTs
installed after December 27, 1986 meet the minimum
requirements for accurate site drawings/as-built plans, as
required by proposed 6 NYCRR 614.7(d).
Subpart 6: Spill Reporting,
Investigation, and Remediation
Requirements from 40 CFR Part 280 Subparts E, F, and G
that address spill response, investigations, and remediation
are being incorporated in this subpart.
Potential Delivery Prohibition
Tier 1 violations that will prohibit deliveries include:
Tanks that are leaking or suspected to be leaking.
Noted equipment violations.
Tier 2 the NYSDEC may prohibit deliveries for:
Leak detection results indicating a leak to inability to contain a
spill if one was to occur.
Operational violations
Circumstances and Process for Imposing a
Delivery Prohibition
When the Department finds that a Tier 1 or 2 condition exists
at a facility:
The Department may affix a tag on the fill pipe of the
relevant tank system that will stop delivery.
Tier 1 tags will be placed at the time the circumstance is
observed by the state, tags associated with Tier 2 will be
attached after a letter is sent to the facility informing the
facility of the relevant condition(s).
Circumstances and Process for Imposing a
Delivery Prohibition
When the Department finds that a Tier 1 or 2 condition exists
at a facility:
At the time that it affixes a tag, the Department will
provide to the facility operator, if one is present, a written
notification of the imposition of the delivery prohibition
that will include the finding of the relevant condition(s) at
the facility.
Operator Training
NYSDEC is incorporating federal training requirements
into state requirements.
Operators will have one year from the date the regulations
are issued to complete initial training and testing.
Category A, B, and C Operators.
Proposed Regulations Probable Timeframe
When will the Phase 1 of the changes take effect?
Comments and public meetings/hearings in January 2014
Regulations will be effective at the earliest in Spring 2014
Phase II drafting will begin after Phase I and EPA part 280
Regulations are completed and in place….
Jen Kotch,
HRP Associates, Inc.
www. hrpassociates.com
Thank You