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Proposed Revisions to LAC 33:XIUnderground Storage TanksLouisiana UST Regulation Revision UpdateJune 14, 2018
DisclaimerThese regulation proposals are subject tochange under DEQ rulemaking and EPAState Program Approval processes
Key Dates Final federal rule– July 15, 2015 Final federal rule effective date– October 13, 2015– Applies to Indian Land and non-SPA States only Rule applies in LA upon promulgation of UT018– Proposed rule (UT018) noticed on June 20, 2018 inLouisiana Register– Public hearing July 25, 2018– Public comment period ends August 1, 2018
State Program Approval (SPA) SPA Application due October 13, 2018– State regulations and statutes– Program description and operating procedures– Demonstrate procedures for adequate enforcement– Attorney General’s statement– Memorandum of Agreement– Letter from Governor requesting SPA 40 CFR 281 Subpart C - Criteria for No LessStringent
Required Changes Secondary containment and operator training– Already in Louisiana UST regulations Walkthrough inspections– Monthly and annual Spill/sump testing and overfill inspection– Every 3 years Release detection equipment testing– Annual Fully regulate deferred UST systems– Emergency generator tanks, field-constructed tanks, airporthydrant systems Other changes and technical clarifications
Operator Training and SecondaryContainment Requirements New Federal OT and SC regulations apply to Indian Landsand non-SPA states Previously promulgated Louisiana LA OT and SC regulationsapply in LA
Periodic Operation and MaintenanceWalkthrough Inspections (LAC 33:XI.513)
Periodic Operation and MaintenanceWalkthrough Inspections (LAC 33:XI.513) Periodic Walkthrough Inspections LAC 33:XI.513– Every 30 days (513.A.1.a) Check spill prevention equipment (513.A.1.a.i) Check release detection equipment (consoles) and records(513.A.1.a.ii)– Must begin in LA within 3 years of effective date of LAregulations (513.A)
Periodic Operation and MaintenanceWalkthrough Inspections (LAC 33:XI.513) Periodic Walkthrough Inspections LAC 33:XI.513– Every 12 months (513.A.1.b) Check containment sumps/areas– Installed after 12/20/08 and/or used for IM (513.A.1.b.i)– Installed on or before 12/20/08 and no IM (513.A.1.b.ii)– STP and under dispenser areas with no sumps (513.A.1.b.iii) Check non-electronic hand held release detection equipment(513.A.1.b.iv)– Must begin in LA within 3 years of effective date of LAregulations (513.A)
O&M Walkthrough Inspections3 Options Minimum inspection requirements (513.A.1)– Outlined in regulations (and following slides) Code of practice (PEI RP900) (513.A.2)– If using RP900, must follow all requirements in RP900 Specific state requirements (513.A.3)– No less protective of HH&E than the 2 items listed above– None at this time but keeping in case we decide to come up withalternative inspection requirements at a later date that can meetState Program Approval
O&M Walkthrough InspectionsRecordkeeping Requirements Maintain the following O&M walkthroughinspection records for 3 years (513.B; 509.B.10)– List of each area checked (513.B.1)– Whether each area checked was acceptable or neededaction taken (513.B.2)– Description of actions taken to correct an issue (513.B.3) Must correct the problem– Delivery records if spill bucket checked less frequentlythan every 30 days due to infrequent deliveries (513.B.4)
O&M Walkthrough InspectionsReporting Requirements for Failed Inspections Requirements when spill prevention equipment andIM containment sumps fail inspection (513.C)– Repair/replace within 30 days, unless alternativetimeframe is granted in writing by DEQ (513.C.1)– Conduct repairs according to repair regulations (513.C.2) Must correct the problem
30 Day Inspections (513.A.1.a)
Spill Prevention Equipment(513.A.1.a.i) Inspect every 30 days– Or prior to each deliveryif deliveries at 30 dayintervals (need deliveryrecords to prove)
(a) Open and visually check for any damage
(b) Remove any liquid and debris
(c) Check for and remove obstructions inthe fill pipe
(d) Check fill cap to make sure it is securedproperly
(e) If DW spill bucket with IM, check forleak in interstitial area
Other Spill Prevention Changes Spill buckets shall have liquid-tight sides andbottoms and be maintained free of regulatedsubstances liquid and debris (303.D.3.a.i)– Deleted the no 1” product in spill bucket requirement– Deleted requirement to cite transfer operator if 1”product found in spill bucket These were added to regulations in 2005 instead of spill bucketinspection and testing requirements
Release Detection Equipment(513.A.1.a.ii) Inspect every 30 days Ensure RD equipment is operating with no alarms or other unusualoperating conditions present (513.A.1.a.ii(a)) Ensure RD test records are reviewed and current (513.A.1.a.ii(b))
12 Month Inspections (513.A.1.b)
Containment Sumps Installed 12/20/08 andContainment Sumps Used For IM (513.A.1.b.i) Inspect containment sumps annually (every 12 months)– Applies to STP, UDC, and transition sumps Visual check for sump and equipment damage (513.A.1.b.i(a))Visual check for leaks to the containment area (513.A.1.b.i(b))Visual check for releases to environment (513.A.1.b.i(c))Remove any liquid or debris from sumps (513.A.1.b.i(d))– Must repair if necessary If secondarily contained sump with IM, must also checkinterstitial space for releases (513.A.1.b.i(e))
Containment Sumps Installed 12/20/08 andNot Used For IM (513.A.1.b.ii) Inspect containment sumps annually (every 12 months)– Applies to STP, UDC, and transition sumps Visual check for equipment damage (513.A.1.b.ii(a)) Visual check for releases in containment area and to environment(513.A.1.b.ii(b)) Visual check for cathodic protection if water is present(513.A.1.b.ii(c)) Remove any debris from sumps (513.A.1.b.ii(a)) Water does not have to be removed Sump does not have to be repaired
STP and Under Dispenser Areas WithoutContainment Sumps (513.A.1.b.iii) Inspect STP and UD areas annually (every 12 months) Visual check for equipment damage (513.A.1.b.iii(a)) Visual check for releases to environment (513.A.1.b.iii(b)) Visual check for cathodic protection if water, soil or backfillis present (513.A.1.b.iii(c)) Remove any debris from area (513.A.1.b.iii(d))
STP Containment Sumps/Areas
UDC Sumps/Areas
Transition Sumps/Areas
To Fix or Not to Fix 12/20/08 Sump?Fix SumpDon’t Fix Sump Sump repair cost No repair cost Will contain release Will not contain release– Can save cost of site check– Site check if release occurs Save money on CP Cost of adding/maintaining CP May have to remove waterperiodically Remove water for LTT/LLD testannually anyway
Hand Held Release Detection Equipment(513.A.1.b.iv) Annually (every 12months) Check any nonelectronic RD devices(tank gauge sticks orRDD bailers) foroperability andserviceability
Periodic Testing of Spill Prevention Equipment andContainment Sumps Used for Interstitial Monitoringand Periodic Inspection of Overfill PreventionEquipment (LAC 33:XI.511)
Equipment Testing/InspectionRequirements (511) Test/inspect every 3 years– Spill prevention equipment– Containment sumps used for interstitial monitoring– Overfill prevention equipment Within 3 years of LA rule effective date for systemsinstalled prior to LA rule effective date, then every 3years (511.B.1) At time of install for installs after LA rule effective date,then every 3 years (511.B.2)
Periodic Test/Inspection RecordkeepingRequirements (511.C) Maintain the following testing/inspection recordsfor 3 years of records (511.C; 509.B.9)– All test/inspection records (511.C.1)– If an interstitially monitored DW spill bucket or DWsump, records of IM in lieu of testing (511.C.2)
Periodic Test/Inspection Requirements(511.D) Requirements when spill/overfill equipment and IMcontainment sumps fail test/inspection– Repair/replace within 30 days, unless alternativetimeframe is granted in writing by DEQ (511.D.1)– Conduct repairs according to repair regulations (511.D.2) Added failure to test and failure to repair or replacefailed equipment to LAC 33:XI.403.B.5 [NOPDPletter]
Critical Juncture ChangesLAC 33:XI.1303 Added the following to “installation-critical juncture”:– Installation of containment sumps– Installation of spill and overfill prevention devices Tank tightness testers are not required to be IR certified to re-install overfilldevices when they are removed to perform a tank tightness test (1301) DEQ-certified worker will not be required to performrepairs to spill prevention equipment or containmentsumps
Equipment Testing/Inspection3 Options Manufacturer testing requirements (511.A.1.b.i)– Must test tightness of equipment (spill prevention and IM sumps)– Must measure that overfill device is set to activate at correct level andwill activate when product reaches that level Code of practice (511.A.1.b.ii)– PEI RP1200 Specific state requirements (511.A.1.b.iii)– No less protective of HH&E than the 2 items listed above– DEQ will allow sump testing to the level that trips sensor if sensor is setup to shut down the STP/dispenser (DEQ will issue as a policy memo)
Spill Prevention Equipment TestingLAC 33:XI.511.A.1 Test every 3 years to ensure liquid tight (511.A.1.b) Vacuum, Pressure, or Liquid Test (511.A.1.b) Not required for double-walled spill bucket with periodic interstitial monitoringbetween the spill bucket walls at least once every 30 days (511.A.1.a)
Spill Prevention Equipment Testing Hydrostatic or vacuum spill bucket test methods (PEI RP1200)
Overfill Prevention EquipmentInspection LAC 33:XI.511.A.3
Overfill Prevention EquipmentInspection LAC 33:XI.511.A.3 Inspect every 3 years Inspection must ensure that theoverfill prevention equipment is setto activate at the correct level (95%for automatic shut off; 90% for flowrestrictor or alarm) and will activatewhen regulated substance reachesthat level PEI RP 1200 requires removal ofdevice to inspect
Testable Overfill Prevention Valves Manufacturer requirements forinspection– Acceptable if manufacturerrequirement includes a way to verifythat equipment is set at correct leveland will activate when productreaches that level– Known OPV’s that are testable w/oremoval OPW 71SO-T Franklin Fueling Defender Series OPV
Testable Overfill Prevention Valves Allowed for 3 year inspection if manufacturerrequirement includes a way to verify thatequipment is set at correct level and will activatewhen product reaches that level Overfill prevention devices must be inspected byremoval in accordance with LAC 33:XI.511.A.3 and511.A.1.b.ii (PEI RP 1200) within 7 days of any tankoverfill event (501.D)
Elimination of Flow Restrictors in Vent Lines(Ball Floats) LAC 33:XI.303.D.3.c Ball floats no longer allowed whenoverfill prevention is installed orreplaced after the effective date ofthe LA regulations If fails inspection and cannot berepaired, it must be removed andreplaced with another form ofoverfill Must remove entire assembly andinstall another overfill device
Periodic Testing of Containment SumpsUsed for Interstitial Monitoring (511.A.2)
Periodic testing of containment sumps used forinterstitial monitoring (511.A.2) Test containment sumps usedfor IM once every 3 years(511.A.2.b) Vacuum, pressure, or liquid test(511.A.2.b) Applies to tank top (STP), UDC,and transition sumps used assecondary containment for IM Excludes DW sumps that haveperiodic or continuous IM(511.A.2.a)
Secondary Containment Testing Containment sump integrity testing (PEI RP 1200)
Secondary Containment Testing Containment sump integrity testing (DEQ-approvedmethod) (DEQ USTD will issue a policy memo to allowthis alternative method) (511.A.1.b.iii)– Liquid level sensor is mounted in the lowest part of the sumpand the periodic test is performed by adding liquid to a pointthat will ensure activation of the sensor Sensor manufacturer must list in writing the minimum amount ofliquid that will activate the sensor, and The STP automatically shuts off when the liquid activates the sensor,or The dispenser automatically shuts off when liquid activates thesensor and the facility is always staffed when the pumps areoperational
Spill Bucket and Containment SumpHydrostatic Test Water May reuse test water at multiple sites– Not a waste as long as reused Reclaimed– Can be sent off to a fuel recycling facility for recovery Disposal– HW rules apply and the waste must be characterized andmanaged appropriately Discharged– General permit for hydrostatic test water discharge(LAG670000)
Release Detection O&M Requirements(703.A.2.d) Electronic and mechanical RD equipment must betested every 12 months to ensure proper operation– Must begin in LA within 3 years of LA regulationseffective date (703.A.2.d)– Maintain records for 3 years (705.A.4) List the components tested Date of test Whether each component tested meets the results of thecriteria in 703.A.2.d or needs to have action taken Description of any action taken to correct an issue
Release Detection Equipment O&M Testing3 Options (703.A.2.d) Manufacturer testing instructions Code of practice– PEI RP1200 Specific state requirements– No less protective of HH&E than the 2 options listed above– None at this time but keeping in regulations in case wedecide to come up with alternative testing requirements thatmeet State Program Approval
Release Detection Equipment O&M Testing Tested in accordance with one of the 3 options, plus A test of operation must be performed at leastevery 12 months and, at a minimum, as applicableto the facility, cover the following components andcriteria:
ATG and Alarm Consoles (703.A.2.d.ii(a))-Test alarm-Verify system configuration-Test battery back-up
ATG Probes and Sensors (703.A.2.d.ii(b))ATG ProbesSensors
ATG Probes and Sensors (703.A.2.d.ii(b)) Inspect for residual build-up Ensure floats move freely Ensure shaft is not damaged Ensure cables are free of kinks and breaks Test alarm operability and communication with controller
Line Leak Detectors (703.A.2.d.ii(c) and 701.B.1)Simulate leak which determines capability to detect a leak of 3 gph at10psi line pressure within 1 hour (703.A.2.d.iii and 701.B.1)– Added additional requirement that annual test ensures that STP is notcontinuously running (701.B.1.c)
Vacuum Pumps and Pressure Gauges(703.A.2.d.ii(d)) Ensure propercommunication withsensors and controller
Hand-Held Electronic Sampling Equipment(703.A.2.d.ii(e))Ensure proper operation
Periodic Inspection of Shear Valves (515)At Install and Once Every 12 MonthsMake sure properly anchored and works (manually trip)Current NFPA 30A requirement but DEQ will enforce 3 years after promulgation
Shear Valve Test/Inspection Requirements(515) Test/inspect shear valves every 12 months (515.A.1) Within 3 years of LA rule effective date for systemsinstalled prior to LA rule effective date, then every12 months (515.B.1) At time of install for installs after LA rule effectivedate, then every 12 months (515.B.2) Maintain the shear valve testing/inspection recordsfor 3 years (515.C; 509.B.11)
Shear Valve Test/Inspection Options(515.A.1) Manufacturer testing instructions Code of practice– PEI RP1200 Specific state requirements– No less protective of HH&E than the 2 options listedabove
UST Systems with Field-Constructed Tanks andAirport Hydrant Fuel Distribution Systems(Chapter 8)
AHS and FCT Systems (Chapter 8) 2015 federal UST regulation removed the deferral, howevergiven the unique nature of these systems EPA created morespecific and appropriate requirements for these systems– Exceptions to secondary containment requirement for some FCT & AHSpiping (803.A)– Unique options for meeting corrosion protection (803.B), walkthroughinspections (803.C), and release detection requirements (803.D)– One-time notification by 3 years from effective date of LA rule forpreviously deferred systems– Implementation depends on requirement– Partial exclusion of aboveground tanks associated with these systems(101.C) Excluded from all requirements except 305 and 715
Definition of Field-Constructed Tank (103)A tank constructed in the field.For example, a tank constructedof concrete that is poured in thefield, or a steel or fiberglass tankprimarily fabricated in the field chnologytanks are not considered fieldconstructed tanks.
Definition of Airport Hydrant FuelDistribution System (103)Also called airport hydrant system, is a UST system which fuels aircraftand operates under high pressure with large diameter piping thattypically terminates into one or more hydrants (fill stands). The airporthydrant system begins where fuel enters one or more tanks from anexternal source such as a pipeline, barge, rail car, or other motor fuelcarrier.
AHS and FCT Sites Existing On or Before LARule Effective Date (801.A.1.a) Upgrading UST systems, general operatingrequirements, operator training, release detection– Within 3 years of effective date of LA rule Release reporting, response and investigation;closure– Upon effective date of LA rule Notification and financial responsibility– Must submit UST-REG within 3 years of effective date ofLA rule
AHS and FCT Installed After LA RuleEffective Date (801.A.1.b) All requirements take effect upon installation
Other Changes
Applicability (101) Previously deferred UST systems now regulated Airport hydrant distribution systems and fieldconstructed tanks regulated in Chapter 8 (101.A.1.a) Emergency generator tanks installed before 8/9/09must have release detection within 3 years ofeffective date of new regs (101.A.1.b)– Reminder - Emergency generator tanks installed on orafter 8/9/09 must have secondary containment and IM(101.A.1.c)
Applicability (101) Reworded the De Minimis exclusion (101.B.5)– Any UST system that contains or has never containedmore than a de minimis concentration, as determined bythe department , of regulated substances is excludedfrom the requirements of these regulations– Deleted the De Minimis definition Now allows us to determine to regulate/not regulate ahead oftime instead of after a release happens
Applicability (101) Replaced “Deferrals” with “Partial Exclusions”(101.C) Excluded from all regulations except 305 and 715 Applies to:––––Non-excluded WWT tanksASTs associated with AHS and FCTRadioactive material USTs regulated under AEAEmergency generator USTs at nuclear power plants
Definitions (103) New definitions– Airport Hydrant Fuel Distribution System– Change-In-Service– Containment Sump– Dispenser– Dispenser System– Field-Constructed Tank– Registration Certificate– Renovation
Definitions (103) Revised De Minimis Concentration (deleted)Install or InstallationMotor FuelsOperatorPermanent ClosureRegistered TankRegulated SubstanceRelease DetectionRepairReplace or ReplacementSecondary ContainmentTemporary ClosureUST
UST-REG Form Combination of UST-REG-01 and UST-REG-02 forms Will take effect when regulations are promulgated More detailed form All tank, piping, sump, flex hose, dispenser information New registration process Built in QA steps to ensure all form and DEQ database info iscorrect
Registered Tank (103) A UST system for which an owner/operator has filedthe required current and accurate UST registrationforms (UST-REG-01 and 02) with the department.After [date of promulgation], a UST system forwhich the owner/operator has filed the requiredregistration form (UST-REG) with the department.
Registration Certificate (103) An annual certificate provided to the UST systemowner by the department after all current annualfees, all unpaid annual fees, and any late paymentfees for the UST system are paid. The currentregistration certificate also serves as documentationof financial assurance for UST owners that elect theLA MFUSTTF as their mechanism for meeting theUST financial assurance requirements of LAC33:XI.1107.
New Registration Requirements (301) Existing systems section (301.A) After effective date, all existing systems comply with 301.C New systems (301.B) Applies to installs between July 20, 1990 and effective date All UST systems (301.C) All installs after effective date use UST-REG form (301.C.1) Phase-in for all UST systems to use UST-REG (301.C.2-3)
New Registration Requirements (301) (301.C.2) All UST owners: Submit updated and accurate UST-REG formwithin 30 days of any changes on their currentforms Updated form filled out completely (except forCW if no CW needed for the change) Owners of multiple sites must submit a separateform for each facility
New Registration Requirements (301) All owners to submit updated and accurate USTREG form within 60 days of first CEI after regs gofinal or before 3 years of reg effective date,whichever occurs first (LAC 33:XI.301.C.3) Inspectors will help explain new forms to owners duringCEIs
New Registration Requirements (301) To-scale site diagram showing all tank, product piping,vent piping, and dispenser locations on all newinstallations and new renovations (301.C.1.c) All current and unpaid tank registration fees and alllate fees must be paid prior to any owner getting acurrent registration certificate (301.C.6) Current copy of current registration certificate shallbe kept on-site or at nearest staffed facility (301.C.8)
New Registration Requirements (301) No owner or operator shall allow a regulatedsubstance to be placed into a UST that has notbeen registered (301.C.9) No person shall place a regulated substance into aUST that has not been registered with thedepartment (301.C.10)
New Registration Requirements (301) No owner or operator shall allow a regulatedsubstance to be placed into a UST that does nothave a current registration certificate (301.C.11)(Act 521, 2016) No person shall place a regulated substance into aUST that does not have a current registrationcertificate (301.C.12) (Act 521, 2016)
New Notification Requirements Upon effective date of LA regulations– Notify within 30 days if currently storing regulatedsubstance containing 10% ethanol or 20% biodiesel(505.C)– Notify at least 30 days prior to switching to a regulatedsubstance containing 10% ethanol or 20% biodiesel(505.C)
New Notification Requirements Owners of previously deferred airport hydrantsystems and field constructed tank systems mustnotify within 3 years of effective date of final LAregulations (801.B) New AHS and FCT systems installed after effectivedate of LA regulations must notify prior to install(801.A.1.b)
Standards for UST Systems (303) Clarified that UST systems installed within 50 feet ofa water well between 12/22/88 and 12/20/08 hadto meet hazardous substance secondarycontainment requirements (303.B)– Made change to clarify. This is not a new requirement.
Standards for UST Systems (303) Clarified that all UST systems installed after12/20/08 must have secondary containment anduse interstitial monitoring for tanks and piping(303.C)– Made change to clarify. This is not a new requirement.
Standards for UST Systems (303) Added new technologies in tank and piping sections– Clad and jacketed tanks (303.D.1.c), flex piping(303.D.2.a) Prohibit reuse of existing single-walled piping whenreplacement tank is installed (303.D.2.j and 905.B)
Standards for UST Systems (303) Changed “ground or water” to “soil, backfill, orwater” in 303.D.2, 303.E.4, 503.A.1 Changed “liquid-tight sides and bottoms” to “liquidtight on its sides, bottoms, and at any penetrations”in 303.D.4.b and 303.D.5.b
Standards for UST Systems (303) Installation– Replaced “tanks and piping” with “UST system, spill andoverfill prevention devices, product pumpingequipment, and emergency shutoff valves” (303.D.6.a) UST system defined as underground storage tank, connectedunderground piping, underground ancillary equipment, andcontainment system, if any
Standards for UST Systems (303) Installation/Renovation/Upgrade– The UST owner and/or certified worker responsible forthe installation (303.D.6.d) or upgrade (303.E.7) shallnotify the appropriate regional office of the Office ofEnvironmental Assessment by phone, mail, email, fax, oronline (when available) seven days prior to commencingthe installation and before commencing any installationcritical juncture
Standards for UST Systems (303) Added two more installation-critical junctures(1303)– Installation of containment sumps– Installation of spill and overfill prevention devices Added definition for Renovation (103)– To make non-repair changes to a UST system, forexample adding new product piping and additionaldispensers at an existing site. Renovations are regulatedas installations.
Standards for UST Systems (303) Removed old upgrade deadlines (303.E)– Upgrading systems that never met the 1998 deadline nolonger allowed (DEQ can allow on case by case basis) EPA does not expect states to allow upgrading tank that had noCP, but ok allowing install of spill or overfill instead of makingowner permanently close system– AHTs and FCTs will be allowed to upgrade (801.A.1.a)
Standards for UST Systems (303) Permanently close UST if lining inspection fails andcannot be repaired per code of practice (API 1631,NLPA 631, API 1631, NACE RP-02-85, KWA RP)(303.E.3.a.ii) Will no longer be able to add impressed currentsystem to lined tank (303.E.3.a.iii) Previously allowed under alternative integrityassessment (LAAP) without inspecting the lining
Standards for UST Systems (303) For tanks 10 years old when CP was added, tanktightness test must be conducted every 12 monthsunless:– Current owner has documentation that tank integrityassessment done when CP was added (regardless of whoowned tank at the time), or– CP and internal liner were installed at same time(303.E.3.b.vi)
Standards for UST Systems (303) Shear Valves on Existing UST systems– Installed according to code of practice andmanufacturer’s instructions (303.E.6)
Installation Requirements for PartiallyExcluded UST Systems (305) Applies to UST systems partially excluded under101.C.1.a, b, and c– Prevent releases due to corrosion– Must have CP or be constructed of non-corrodiblematerial– Compatible with material stored
Fee Schedule (307) Clarified fee names to match statutes and registrationform The owner of the UST system is responsible forpayment of the annual fee, any late payment fees, andall outstanding fees and late payment fees (307.B.3)– Made change to address old-owner back fees Fee increases adjusted in MM018 Amended registration fee of 60 for change ofownership only (307.C)
Delivery Prohibition (Chapter 4) Old Name– 2005 Federal Underground Storage Tank ComplianceAct Mandated Requirements New Name– Delivery Prohibition
Delivery Prohibition (Chapter 4) Increased automatic red tagging (403.A)– No RD (deleted “or installation of release detectionequipment”) (401.A.3)– No CP on tanks and piping (403.A.4)– New and existing unregistered tanks (403.A.5)– No current registration certificate (403.A.6) No “green tag” to get fuel delivered
Delivery Prohibition (Chapter 4) Increase automatic red tagging (403.A)– Upon evidence of a below-surface release from an USTsystem, not conducting a system test within thetimeframe established in LAC 33:XI.711.A.1, not takinginitial response actions required by LAC 33:XI.715.B.2and 3, or not conducting the initial abatement measuresrequired by LAC 33:XI.715.C.1.a-d and g (403.A.7)– Failed tanks that remain in temporary closure (403.A.8)
Delivery Prohibition (Chapter 4) Increase NOPDP (30 day letter) red tagging (403.B)– No FR and no FR demonstration (internal processchange) (403.B.3)– No CP on metal flex hoses and components (403.B.4) Deleted “piping”, added piping to 403.A– Not conducting periodic testing of spill/overfill/IMsumps and failure to correct failed equipment (403.B.5)– Not conducting periodic O&M walkthroughs and failureto correct failed equipment (403.B.6)
Delivery Prohibition (Chapter 4) Increase NOPDP (30 day letter) red tagging (403.B)– Storing 10% ethanol or 20% biodiesel withoutdemonstrating UST system compatibility (403.B.7)– Upon evidence of a release or a suspected release from aUST system, except for the notification requirements of LAC33:XI.713 and 715, initiation by the UST owner or operator ofrelease investigation and confirmation steps in accordancewith LAC 33:XI.711, cleanup of spills and overfills as requiredby LAC 33:XI.713, or compliance with the release responseand corrective action requirements of LAC 33:XI.715(403.B.8)
Spill and Overfill Control (501) Overfill prevention devices must be inspected byremoval in accordance with LAC 33:XI.511.A.3 and511.A.1.b.ii (PEI RP 1200) within 7 days of any tankoverfill event (501.D) Tank overfills caused by tank or piping manifoldsmust not occur– If occurs, must with either repair, replace, temporarilyclose, or permanently close tank (501.E)
Operation and Maintenance ofCorrosion Protection (503) O/O must comply with CP until UST system ispermanently closed or undergoes CIS (503.A) CP test every 36 months or another timeframeestablished by DEQ (503.A.2.a) CP testing accordance with the guidelinesestablished by the department (503.A.2.b)– DEQ CP testing guidance document will go final whennew regs take effect
Compatibility (505) Owners storing fuel with 10% ethanol or 20%biodiesel must demonstrate compatibility of USTsystem (505.D.1)– Use equipment/components that are certified or UL listed foruse with the fuel stored, or– Use equipment/components that are approved by themanufacturer
PEI RP 1200 requires removal of device to inspect . Testable Overfill Prevention Valves Manufacturer requirements for inspection –Acceptable if manufacturer requirement includes a way to verify that equipme
