NJDEP Outlines UST Training Requirements for Class A & B Operators

UST / AST Examination
NJDEP UST Training for Class A & B Operators

The EPA has established new minimum training requirements for designated Class A, Class B, and Class C operators to ensure that those who own and operate regulated underground storage tanks understand how to operate and maintain their UST systems properly. The federal regulations dictate that all operators must be trained by October 13, 2018.

How can you become a Class A or Class B Operator?

 In order to become a Class A or Class B operator you will need to attend a class at Rutgers  that will be administered by the NJDEP and pass an ICC examination.  Click here to see view the NJ State’s document for details and links for the Rutgers’ classes and ICC examination.

 

The John W. Kennedy Company appreciates your business and continued support!

 

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Are You Ready For 2018?

OmntecNew EPA Regulation 40CFR, part 280, requires sumps to be tested every 3 years, starting in 2018.

Omntec sump tester price listOmntec offers the CLD Series portable containment sump tester, available in 3, 4, 6 , and 8 probe versions.

CLD Kit List Prices:

CLD3: Three Probe Sump Tester Kit- $11,537

CLD4: Four Probe Sump Tester Kit- $12,656

CLD6: Six Probe Sump Tester Kit- $16,203

CLD8: Eight Probe Sump Tester Kit- $19,080

Click here for more details on the CLD Series, and be sure to call us at 1-800-451-4021 with any questions.

 

The John W. Kennedy Company appreciates your business and continued support!

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MassDEP Stage I Enforcement Discretion Directive: OPW 723V PV Vent Approval

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The following is reproduced from an OPW newsletter.

 

The Massachusetts Department of Environmental Protection (MassDEP) is proposing to amend 310 CMR 7.24(3) Distribution of Motor Vehicle Fuel, to update the tables of Stage I systems certified by the California Air Resources Board (CARB) since January 2, 2015, the date the current Stage I regulation was last revised.

The existing regulations at 310 CMR 7.24(3) is part of the Massachusetts Ozone State Implementation Plan (SIP) and the regulatory amendments will be submitted to the U.S. Environmental Protection Agency (EPA) for approval into the SIP.  A public hearing will be held to receive comments on the proposed amendments on:

August 1, 2017
10am – 12pm
Conference Room A
MassDEP Boston Office
1 Winter Street, Boston 02108

Testimony may be presented orally or in writing at the hearing. MassDEP will accept written comments until 5:00 p.m. on August 31, 2017.  Written comments must be submitted by email to: DEP.Talks@state.ma.us or by mail to: Tom DeNormandie, MassDEP, One Winter Street, Boston, MA 02108.  A copy of the proposed amendments and technical support document is available on MassDEP’s website at mass.gov/dep/public/publiche.htm.

Stage I Vapor Recovery Enforcement Discretion Directive
for Owners/Operators of Motor Vehicle Fuel Dispensing Facilities Subject to
310 CMR 7.24(3)

OPW 723VAttached is an Enforcement Discretion Directive, effective immediately, allowing the installation of Stage I enhanced vapor recovery (EVR) systems and components that are contained in California Air Resources Board (CARB) Orders issued since January 2, 2015 prior to the effective date of revisions to 310 CMR 7.24(3).

 If you have any questions concerning the proposed amendments to 310 CMR 7.24(3), or the conditions of the above directive, please call the MassDEP Stage I hotline at 617-556-1035, ext. 1, or Jeff Gifford at 617-556-1144; jeffrey.gifford@state.ma.us.

 

To learn more about the 723V pressure vacuum vent, Download the 723V Data Sheet/Flyer.  Or call us at 1-800-451-4021.

 

The John W. Kennedy Company appreciates your business and continued support!

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Morrison Brothers CO. – California Proposition 65 Notice

Morrison-Bros_logoCAUTIONThe following has been reproduced from a Morrison Brothers email blast from the desk of Rick Zillig, Manager QCCS
June 6, 2017:

Subject: California Proposition 65 Notice

Morrison Bros. Co. (MBC) has recently been made aware of several MBC products being made available “online” and/or through retail outlets in the state of California. California’s Proposition 65 requires formal, public notice through proper warning labels for individual items, such as the one shown below, and MBC will immediately begin including warning labels for products that contain brass.

MBC California Proposition P65

Click above warning image to read full notice from Morrison Brothers

MBC  products  are  not  intended  for  applications  involving  potable  water  or  any  form  of  human  or  animal consumption. They are designed and manufactured exclusively for use in fuel and chemical handling. The Morrison catalog and product specification sheets include the materials of construction. Please take necessary precautions when designing systems, specifying products, and selling these products. If you have any questions on an application, contact MBC immediately.

MBC products are sold exclusively through authorized distributors. Distributors are trained and kept aware of product specifications, applications, and regulatory status. MBC cannot control the retail sales and end use of the products, but will immediately send notice, such as this, to distributors when the company is made aware of any situation in the field. It is important to read and understand the notice, comply with the warnings, and take corrective action when necessary in cases involving noncompliance.

Thank you for your attention.

If you have any questions in regards to any of these Morrison products, please feel free to contact us at 1.800.451.4021.

We appreciate your continued business and support!

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Questions And Answers About The 2015 Underground Storage Tank Regulation As Of May 2017

EPA

Check out the May 2017 updated version of the EPA’s  PDF document :

Questions and Answers about the 2015 Underground Storage Tank Regulation

And please be sure to call us at 1.800.451-4021 for all your underground storage tank needs.

We appreciate your continued business and support!

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A Word From Universal Valve About Spill Prevention

Universal Spill PreventionThe following has been reproduced from Universal Valve email dated 12/15/2016

Unfortunately, environmental Hazards are located all over the forecourt, not just the fill area. By using a spill container, we can protect the environment at the fill location. But what about all the other tank risers, and access points? In a perfect world, every tank fill situation will go as planned and not a drop of fuel will hit the environment. Yet history shows that proper planning is needed for when things do not go as planned.

The new EPA rules help make sure sites are checked and operated properly. But what happens when a tank is overfilled and the perfect storm arises? There are other access points to contend with that could leak petroleum directly into the environment. Here are three common tank access risers that need attention.Universal Valve 70C Spill Container

  • Vapor recovery risers. Typically, a spill container with no drain is the ideal solution. Eliminating the drain is ideal. There is less of a chance of water entering the tank with no drain.
    • Check Out Universal Spills such as the 70C-1212

 

 

  • Tank Monitoring risers. Standard spill containers are not the ideal solution here. Using a tank monitoring spill container offers electrical conduit hookups while creating water tight solutions for incoming ground water and environmental protection from tank overfills.

 

 

 

 

  • Universal JH69-4 Stick Port FlapperStick Port Risers. Standard spill containers work well here. Like the vapor recovery container no need for a drain valve. Be sure to use a cap and adapter on the riser that is clearly marked “DO NOT FILL”. Installing a stick port flapper helps reduce vapors through the riser when removing the cap.

 

 

 

 

  • Be sure to mark all of these spill containers clearly for their purpose. Marking the lids is not the only place you’d want to mark the container. Adding a concrete marker next to the unit is a safe bet. It eliminates the problem of the lids being crossed up and/or replaced with a non-marked lid.

The John W. Kennedy Company appreciates your business and continued support!
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Update: MassDEP Stage I/II Registered Facilities’ Compliance

massdep-logo

Dear Stage I/II Facility Owner/Operators and Stakeholders,

 

An updated spreadsheet, “Massachusetts Stage I & II Facilities’ Compliance Certification Due Dates & Status”, is now posted on our MassDEP Stage I / II Vapor Recovery website.

 

Please note the revised spreadsheet was posted on 9/9/16.  An updated spreadsheet will be posted in October.

 

The spreadsheet can be viewed and downloaded at this link:

 

http://www.mass.gov/eea/agencies/massdep/air/programs/stage-ii-vapor-recovery.html

 

The spreadsheet is located in two sections on the website;

 

  • “Stage I Vapor Recovery Certification Forms” section, and

 

  • “Stage II Vapor Recovery Certification & Decommissioning Forms” section.

 

 

Please Review the Following:

 

 

  1. Registered Stage I / II facilities:

 

The spreadsheet lists Stage I or Stage II facilities that are registered in the MassDEP Stage I / II database.

 

 

  1. Reasons you cannot find a facility or certification form on the report:

 

There are a number of scenarios why you cannot find a facility or current certification form on the report:

 

  • A Stage I / II facility has not registered with the MassDEP Stage I/II program.

 

  • The annual Stage I or Stage II certification form, or Stage II decommissioning form, was not received by the Stage I/II program.

 

  • Tanks were removed at a facility, and the Stage I/II account was closed, but the Stage I/II program was not notified that new tanks were installed.

 

For example, a facility removes an underground storage tank (UST), but does not register a newly installed aboveground storage tank (AST) with the Stage I program.  ASTs are applicable to the Stage I Vapor Recovery Program and must register with MassDEP by submitting the applicable Stage I certification form, either a Stage I Form A or Stage I Form C,

 

 

  1. Data Fields and comments:

 

Facility ID:                                            The “Facility ID” is Stage I/II ID number, NOT the UST ID number.

 

Company Name:                              Company name, facility name, and facility address currently on record in the Stage I / II database.

Facility Name:

Facility Address:

Facility Town/State/Zip

 

Tank Type:                                          Indicates if an underground storage tank (UST) or aboveground storage tank (AST) is installed.

 

Class:                                                     Indicates if the facility is registered as a Stage I facility (STG1), or Stage II facility (STG2).

 

CARB #/Sys Type:                            Indicates the Stage II CARB number, Stage I CARB number, or Stage I system type.

 

Test Cycle:                                          Stage II facilities have three test cycles; Third Annual, First Annual, and Second Annual.

 

Stage I facilities have one test cycle, First Annual, since the same tests are required every year.

 

Form Sent:                                          The date the applicable Stage I/II form was generated by MassDEP.

 

Form:                                                    The type of form sent to the facility or received.

 

Form C –              Stage I or Stage II Form C (refer to “Class” type)

Form D1 –            Stage II Form D1 (no test required)*

Form D2 –            Stage II Form D2 (test required)**

Decom –               Stage II Decommissioning form

 

*             Facilities eligible for Stage I Form D1’s will be generated starting in 2017.

**           Facilities eligible for Stage I Form D2’s will be generated starting in 2018.

 

Test Date:                                           Most recent Stage I/II compliance testing date.

 

Postmark Date:                                 Date the completed form was mailed or emailed to the MassDEP Stage I/II program.

 

Due Date:                                            Compliance Due Date for the applicable Stage I/II annual certification form.

 

Form Rcvd & Complete?               Complete –         Form was received and is complete.

Incomplete-       Form was received but sections of the form are Incomplete.

Not Received –  Form has not been received.

Suspended –      Form has not been received and enforcement was issued.

 

 

  1. Calculating Due Dates:

 

 

Decommissioned Facilities:

 

Facilities that have submitted Stage II decommissioning forms can be calculated as follows:

 

Decommissioning test date + 60 days + 1 year = First Stage I Form C due date.

 

For example, if MassDEP received a decommissioning form with a  test date of 12/22/15 the next due date will be…

 

12/22/15 + 60 days + 1 year = 2/22/17

 

For decommissioned Stage II facilities the Stage I/II database will generate the first Stage I Form C based on this formula.

 

 

Next Due date for certification forms received:

 

A certification due date is determined by the postmark date on the envelope of your previous year’s certification submission to MassDEP.  This approach ensures that all Stage I and Stage II systems are certified at least once every 12 months.

 

For example, if a facility’s Year 1 certification is postmarked March 23, the facility will be required to mail its next certification to MassDEP by March 23 of Year 2.  If, however, the facility mails its Year 2 certification more than 30 days before the facility’s currently applicable due date (for example on February 20), the due date for its Year 3 certification will be February 20, and not remain March 23. Future certification due dates for certifications mailed less than 30 days before their currently applicable due date will remain unchanged.

 

If maintaining your facility’s current certification due date is important to you, simply schedule your compliance tests for no more than 30 days in advance of that date.  You may also schedule your tests and submit your certification at any time before your due date if you wish.

 

If you have any questions, please contact:

Jeff Gifford

MassDEP

Bureau of Air & Waste

Stage I / II Vapor Recovery Program

1 Winter St., 7th floor

Boston, MA 02108

 

Phone: 617-556-1144

 

The John W. Kennedy Company appreciates your business and continued support!

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New OPW 723V Pressure Vacuum Vent

OPW Corporate Logo

 

 

 

OPW 723VOPW has announced the release of the new 723V Pressure Vacuum Vent, which is designed specifically to meet all California Air Resources Board Enhanced Vapor Recovery (CARB EVR) requirements and is certified for use on all existing standard gasoline Phase 1 Vapor Recovery Certification Phase 1 EVR Executive Orders.  In addition, it also complies with the Nation Fire Prevention Association’s (NFPA) 30 requirements for venting gasoline vapors.    The 723V comes in both 2″ and 3″ NPT thread models, and is available for stocking now.  For more information, check out the official distributor bulletin and product datasheet from OPW.

 

 

 

The John W. Kennedy Company appreciates your business and continued support!

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Reminder: Universal Compliance Products

Universal logoIn light of new EPA guidelines, Universal Valve Co. has forwarded details about several of their compliance products, designed to be easy to remove for testing without damaging the components attached to them, as well as to reliably protect against water intrusion.

Made in USA

 

 

 

Spill Containers

Universal Spill Containers

Due to new EPA guidelines, all spill containers are required to be tested before being put into service.  All Universal spill containers, both single and double wall, are made with a metal construction, which is found to be 40% more durable than containers made of polyethylene.  In addition to the increased durability, the Universal containers can be removed easier when being replaced, without breaking concrete, allowing for quicker repair.

 

 

 

Overfill Protection Valves

Universal Overfill Valves

Universal overfill valves are designed to be easily removable without damaging the float on which they’re attached.  With only a single moving part, they are among the most reliable valves on the market.  This is convenient due to the frequent testing required by EPA regulations (every 3 years at minimum).  The Model 49 valve is also the only UL approved device on the market compatible with both gravity and pressure fill products.

 

 

 

Sump Retrofit Lids

Universal Retrofit Lids

Universal’s retrofit sump lids allow for both fast, easy installation in under 30 minutes per sump and maximum protection against water intrusion.  Offered in various standard sizes as well as custom sizes, the lids feature a double seal as well as an inspection port for simplified testing.

 

 

 

 

 

 

Check out this video highlighting the simple, quick installation process for the retrofit lids:

 

The John W. Kennedy Company appreciates your continued business and support!

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10 Things You Need to Know About the Revised EPA UST Rules

The following has been reproduced from an article posted by Joel Hershey on http://www.ecsconsult.com

Technical Standards and Corrective Action Requirements for Owners and Operators of Underground Storage Tanks

USTs_cropped

Late last month, the USEPA published the long-awaited revisions to the Underground Storage Tank (UST) rules under 40 CFR 280 and 281.  The full 120-page rule is available on the EPA Office of Underground Storage Tanks website (http://www.epa.gov/oust/fedlaws/revregs.html) and has just been published to the Federal Register.  If you do not have the time to delve into the document, we have put together this summary of 10 key things you need to know about the 2015 rule rewrite.  This is not an exhaustive list, and the full rule text should be consulted for a comprehensive understanding and evaluation of owner/operator obligations.

  1. OPERATOR TRAINING IS REQUIRED FOR EVERYONE – The Energy Policy Act of 2005 only required training for operators in states that received monies from the EPA.  This change ensures that all operators across the country and in states without operator training requirements, and in Indian Country, have training. The EPA is attempting to ensure that all operators across the country are trained to prevent and respond to releases.  The EPA has provided a 3 year timeframe for implementation.
  2. WALKTHROUGH INSPECTIONS ARE REQUIRED FOR ALL FACILITIES – Monthly (30) day inspections are required for all facilities that consist of a visual evaluation of spill prevention equipment and release detection equipment. Containment sumps such as for STPs, piping must be viewed at least annually.  The purpose is to ensure that owners are looking regularly at their equipment to catch problems early and prevent releases.  The EPA is allowing a 3 year adoption period for these inspections.
  3. TESTING REQUIREMENTS FOR SPILL PREVENTION EQUIPMENT, OVERFILL PROTECTION EQUIPMENT, CONTAINMENT SUMPS, AND RELEASE DETECTION – Owners/operators are required to test spill prevention equipment, containment sumps used as secondary containment for piping  and overfill protection equipment every three years, and release detection devices must be tested annually.  This testing will ensure that all components of a UST system that are designed to detect and prevent a discharge are operating properly.  Some components, such as spill buckets, will fail. This rule modification will help operators catch issues early. The EPA is requiring testing within 3 years of the adoption of the rule.
  4. EMERGENCY GENERATORS ARE NO LONGER EXEMPT FROM PERFORMING RELEASE DETECTION MONITORING – With technology now available to monitor tanks and detect releases at remote locations, the EPA has lifted the deferral on this requirement.  Owners/operators of emergency generator tanks are now required to equip tanks with release detection monitoring.  The EPA is allowing 3 years for the upgrades to take place.
  5. FIELD CONSTRUCTED TANKS AND AIRPORT HYDRANT FUEL DISTRIBUTION SYSTEMS MUST PERFORM RELEASE DETECTION – The 1988 UST Regulations deferred release detection for hydrant systems and field constructed tanks because there was not sufficient technology or information available to effectively test these systems.  With technology changes in the marketplace, methods are now available to monitor and detect releases at alternative leak rates and frequencies.  To address the uniqueness of these systems, EPA has added in an entirely new subsection (Subpart K) that outlines the general requirements and exceptions.  As for an adoption timeframe, various provisions are phased in anywhere from immediately to over a seven year period.
  6. VENT LINE FLOW RESTRICTORS ARE NO LONGER AN OPTION TO MEET OVERFILL REQUIREMENTS – UST systems used to be able to rely on flow restrictors on vent lines (ball floats) as a means to meet the overfill prevention requirements of the 1988 UST rule.  Several inherent weaknesses had been identified with the use of this technology, which included in the over-pressurization of tanks.  Owners/operators are required to use alternate overfill prevention measures listed in the rule (Subpart B) on all new systems and replaced vent lines.  This portion of the rule goes into effect immediately.
  7. INTERNAL LINING NO LONGER ACCEPTABLE AS A SOLE MEANS OF CORROSION PROTECTION  -In the past, UST systems that relied on an internal lining as the sole method of corrosion protection could add another internal lining, cathodic protection, or both when internal lining failed a periodic inspection and could not be repaired. The new rule requires tanks using internal lining as the only method of corrosion protection to be permanently closed if the internal lining fails inspection and cannot be repaired according to a code of practice.  This portion of the rule is effective immediately.
  8. OWNER NOTIFICATION PRIOR TO SWITCHING TO REGULATED SUBSTANCE CONTAINING >10% ETHANOL, 20% BIODIESEL, OR THAT MEETS COMPATIBILITY CONCERN REQUIREMENTS – With the increased use of biofuels in the marketplace, there is an increasing concern regarding tank material compatibility.  The rule revision addresses this concern by requiring owners/operators to notify the regulatory agency at least 30 days prior to switching to a regulated substance containing greater than 10 percent ethanol, greater than 20 percent biodiesel, or any other fuel that the agency identifies as a concern.  The owner/operator must demonstrate material compatibility through a listing by a nationally recognized testing laboratory, equipment manufacturer approval, or other method that the agency deems to be no less protective.  This change is effective immediately.
  9. INTERSTITIAL MONITORING RESULTS NOW REPORTABLE – As interstitial monitoring becomes a more widely used method of release detection, the EPA has clarified the rule to include its use.  Specifically, interstitial alarms are now considered an unusual operating condition under release reporting.  EPA adds an option to test secondary containment when present as a means of investigating and/or confirming a release.  The rule also adds an option for system closure if a test confirms a leak.   This portion of the rule revision is effective immediately.
  10. STATE PROGRAM APPROVAL REQUIREMENTS – States that receive monies from the EPA are required to address the changes made to 40 CFR 280 within 3 years of adoption.  Specifically, states must meet the delivery prohibition, operator training, and groundwater protection requirements contained within the Energy Policy Act of 2005.

As stated at the beginning of this article, this list is not a comprehensive or complete summary of the rule changes.  There are other key provisions and clarifications that are contained in the rule text and preamble.  Should you have any questions regarding your tank system and whether or not your facility is in compliance with the new rule, we suggest you contact our Eclipse Division for an evaluation and consultation.

Joel Hershey is the Director of Environmental Compliance Services, Inc. (ECS’) Eclipse Fuel System Management Division.  He has worked exclusively in the field of petroleum liquid storage systems since 1989.  His expertise includes compliance testing, diagnostics, petroleum construction, maintenance, and upgrades for both UST and AST systems.  During his career, Joel has held various positions, including Senior Petroleum Specialist, Operations Manager, and four years as Senior Vice President for Tanknology.  There he managed and executed upgrades for more than 6,800 facilities to meet the 1998 federal UST systems upgrades. He can be reached at (800) 789-3530 or jhershey@ecsconsult.com.

As always, feel free to contact us at 1.800.451.4021 with any questions.


We appreciate your business and thank you for your continued support!

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