1 massachusetts underground storage tank (ust) program baseline compliance assessment 1 massdep...
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1
MASSACHUSETTS UNDERGROUND STORAGE
TANK (UST) PROGRAM Baseline Compliance Assessment
1MassDEP 8/2/2011
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UST Program• UST program was transferred from DFS to
MassDEP in July 2009
• Between July 2009 and November 2010 MassDEP inspected ≈ 350 randomly selected facilities in order to:
– understand “baseline” compliance status of the sector as a whole
and– aid in the development and implementation of
the regulatory program2
MassDEP 8/2/2011
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Main Discussion Topic
Compliance with EPA “Significant Operational Compliance” Performance Measures (SOCs) related to:
– Release Prevention– Release Detection
NOTE: EPA uses different measures to quantify and evaluate the number of spills or leaks that have occurred.
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UST Program Purpose
• The UST Program ensures that underground storage tanks do not release regulated substances into the environment
• The regulated substances include:
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• Gasoline• Diesel• Fuel oil• Waste oil
• Acids• Bases• Hazardous substances• Solvents
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UST Program Universe• There are:
≈ 3800 active facilities ≈ 9100 registered active tanks
• These facilities include:
fuel dispensers industrial operations hospitals schools military bases
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airports authorities Federal, state and local
government agencies small businesses
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Key Program RequirementsPer the Energy Policy Act of 2005:• Tank and pipe construction and installation must meet
standards that prevent spills and leaks
• Approved leak detection systems must be in place and operated to identify leaks so that they can be addressed before they become a serious problem
• Leak detection and prevention systems must be maintained and tested to ensure their proper operation
• Recordkeeping must be performed to document regulatory compliance
• Facilities are inspected routinely to insure that the regulatory standards are met (In MA, Third Party and MassDEP inspections are used.) 6
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Complexities
• New program for MassDEP
• Regulations currently in force were written by another agency (DFS)
• Regulatory requirements may differ from facility to facility due to the variety of compliance options and UST systems
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Release Prevention SOCs• Spill prevention equipment is present and operating
properly• Overfill prevention equipment is present and operating
properly
• Tanks and pipes are tightness tested within six months of UST system repairs
• Corrosion protection systems are tested for functionality within 30 days of UST system repairs
• Corrosion protection systems are operating and maintained properly
• Impressed current cathodic protection system is inspected every 60 days
• Corrosion Protection is in place for all tanks and pipes
Note: The SOC “Lined tanks are inspected periodically and lining is in compliance” was not included in the analysis because there were no facilities in the sample to which it applied.
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Release Detection SOCs
• Leak detection systems are in place
• Leak detection systems are operating properly
• Leak detection systems meet the applicable performance standards
• Proper response to suspected releases
• All tanks and pipes are monitored at the required frequency and records are kept
Note: The SOC “Hazardous substance USTs meet leak detection requirements” was not included in the analysis because there were no facilities in the sample to which it applied. The SOC “Out of service tanks containing product meet leak detection requirements” was excluded because it is not applicable in MA.
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“Groups” of UST Facilities Assessed
• Gas Stations where owner owns >5 facilities (27% of universe, sample size = 55)
• Gas Stations where owner owns < 5 facilities (36% of universe, sample size = 48)
• Manufacturing / Utilities (10% of universe, sample size = 43)
• Misc. Small Business & Municipalities (18% of universe, Sample Size = 53)
• Institutional/State & Federal Government (9% of universe, sample size = 42)
MassDEP assessed the performance of a random sample of facilities from 6 individual groups:
• each of the above categories and• early submitters (by 7/1/09) of the required Third Party Inspection
reports
USTs facilities were grouped into one of five categories:
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Overall Performance
Based on a weighted average of the five facility categories*
• 85% were in compliance with all EPA Release Prevention SOCs
• 44% were in compliance with the all EPA Release Detection SOCs
42% of the facilities were in compliance with all EPA SOCs (both Release Prevention and Release Detection)
* NOTE: The Third Party Inspection Group was not included in this calculation
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Massachusetts Assessment Results vs Other States’ EPA SOC Performance
• Release Prevention Measures– New England: 69% - 86% – National: 45% - 98% Average: 84%– Massachusetts: 85%
• Release Detection Measures– New England: 68% - 82% – National: 55% - 98% Average: 79%– Massachusetts: 44%
• All SOCs– New England: 54% - 84% – National: 36% - 90% Average: 71%– Massachusetts: 42%
SOURCE: EPA Semiannual Report of UST Performance Measures Mid Fiscal Year 2011 as of March 31, 2011 (5/2011)12
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Overall Facility Performance onEPA Release Prevention SOCS
(Weighted average of the performance of each of the five facility categories)
MassDEP 8/2/2011
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
SOC: Spillprevention
present andfunctional for all
tanks
SOC: Overfillprevention
present andfunctional for all
tanks
SOC: Systemstightness testedwithin 30 days of
repair
SOC: Corrosionprotection
systems testedwithin 6 months of
UST systemrepair
SOC: Corrosionprotection
systems properlyoperated andmaintained
SOC: Impressedcurrrent cathodic
protectionsystems are
inspected every60 days
SOC: Corrosionprotection in
place for all tanksand pipes
% o
f fa
cilit
ies
in c
om
plia
nce
(w
eig
hte
d a
vera
ge
)
1414
Overall Facility Performance on EPA Release Detection SOCS
(Weighted average of the performance of each of the five facility categories)
MassDEP 8/2/2011
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
SOC: Releasedetection method
present for all USTsystems
SOC: All primaryrelease detection
systems are operatingproperly
SOC: All releasedetection systemsmeet performance
standards
SOC: Properresponse to
suspected releases
SOC: All tanks andpipes are monitored atthe required frequency
and records kept
% o
f fa
cil
itie
s i
n c
om
pli
an
ce
(w
eig
hte
d a
ve
rag
e)
15
Each Group’s Performance on EPA Release Prevention SOCs
MassDEP 8/2/2011
0.00%
10.00%
20.00%
30.00%
40.00%
50.00%
60.00%
70.00%
80.00%
90.00%
100.00%
SOC: Spill preventionpresent and functional
for all tanks
SOC: Overfillprevention present
and functional for alltanks
SOC: Systemstightness testedwithin 30 days of
repair
SOC: Corrosionprotection systems
tested within 6months of USTsystem repair
SOC: Corrosionprotection systems
properly operated andmaintained
SOC: Impressedcurrrent cathodic
protection systemsare inspected every
60 days
SOC: Corrosionprotection in place for
all tanks and pipes
We
igh
ted
Av
era
ge
Co
mp
lia
nc
e R
ate
Gas Station: Owner owns >5 facilities (sample size = 55) Gas Station: Owner owns <6 facilities (sample size = 48)Manufacturing / Utilities (sample size = 43) Institutional / State & Federal Government (sample size = 42)Misc. Small Business & Municipalities (Sample Size = 53 facilities) Facility submitted TPI before July 2009 (sample size = 55 facilities) 15
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Each Group’s Performance on EPA Release Detection SOCs
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Requirements Generally Achieved
• Required Leak Detection Systems are installed and turned on
• UST systems have adequate corrosion protection
• Cathodic corrosion protection systems are operating
• Properly sized spill buckets are installed
• Overfill protection is installed
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How Many Individual Requirements Did Facilities Violate?
• The average facility violated 21% of the requirements that applied to the facility
• 88% of facilities violated at least one of all of the requirements included in the assessment
• 58 % of facilities violated at least one SOC
Based on a weighted average of the performance of each group
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Average Facility Violation Score for Each Group
% of applicable requirements the facility violated)
Gas Station: Owner owns >5 facilities 13 %
Gas Station: Owner owns <5 facilities 22%
Manufacturing / Utilities 19%
Institutional / State & Federal Government 22%
Misc. Small Business & Municipalities 28%
Facility submitted TPI before July 2009 20%MassDEP 8/2/2011
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Facility can document that excess water in tanks was removed and managed as required 43%
The past 12 months of release detection records are available for review* 37%
Tank inventory records are reconciled monthly 35%
Automatic line leak detection systems (catastrophic leak detection) have passed the annual functionality test and been certified within the past year*
33%
Spill buckets are clean and free of debris 31%
Facility can document that overfill devices are operable 31%
The sumps at facilities with interstitial monitoring systems are clean and free of debris and water 29%
Facility can document that interstitial monitoring and tank release detection systems have been properly operated, calibrated and maintained*
28%
Facility monitors for spills/overfills during fuel deliveries 27%
Spill bucket waste is properly managed 16%
Frequently Violated Requirements% of Facilities in Violation
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Violation Rates for Frequently Violated Requirements by Group
MA Wtd Average
Gas Station: Owner
owns >5 facilities
Gas Station: Owner
owns <5 facilities
Manufac-turing / Utilities
Institutional /
State & Federal Government
Misc. Small Business & Municipali-
ties
Facility submitte
d TPI before
July 2009
% of facilities violating the requirement Facility can document that excess water in tanks was removed and managed as required 43% 33% 41% 63% 30% 59% 63%
Release detection records for the past 12 months are available* 37% 21% 42% 43% 30% 53% 38%Tank inventory records are reconciled monthly 35% 10% 43% 25% 53% 54% 41%Automatic Line Leak Detection systems (catastrophic leak detection) have passed the annual functional test and been certified within the past year*
32% 23% 25% 60% 50% 35% 14%
Spill buckets are clean and free of debris and water 31% 31% 30% 27% 34% 37% 16%Facility can document that overfill devices are operable 31% 22% 33% 22% 38% 46% 27%The sumps at facilities with interstitial monitoring systems are clean and free of debris and water* 29% 22% 31% 11% 21% 48% 22%
Facility can document that interstitial monitoring and tank release detection system have been properly operated, calibrated and maintained*
28% 15% 30% 23% 30% 41% 21%
Facility monitors for spills / overfills during product delivery 27% 19% 38% 44% 10% 18% 46%Spill bucket waste is managed properly 16% 9% 26% 9% 14% 13% 9%*Contributes to an SOC MassDEP 8/2/2011
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