OPW invites you to attend their UST EVR Training Certificationclass.
Description:The OPW EVR live certification course provides attendees a hand’s on opportunity to install and service all of the OPW UST EVR Phase One System Components listed on the California Air Resources Board (CARB) Executive Order. Attendees will use the tools provided in class while performing basic installation and routine maintenance of phase one components. There is no experience necessary and the class is free. There will be an open book test at the conclusion of the class and with a passing grade you will receive a 2 year certification.
When:Wednesday, December 12, 2018
Where:Hilton Garden Inn – 800 Hall of Fame Ave. – Springfield, MA 01105
IMPORTANT: Please contact us at 1.800.451.4021 or email us here ASAP to reserve a spot with the attendee name, company name & email address. Please note: all (3) bits of information are needed in order to officially register the attendee for the training class.
Enrollment will be on a first come first serve basis. If registration is low there is a possibility that training sessions may be cancelled.
The John W. Kennedy Company appreciates your business and continued support!
Our friends at OPW would just like to kindly remind everyone that the EPA’s new Environmental Testing Regulations go into full effect on October 13, 2018, and OPW has a full line of products that are compatible with the 4 major regulatory requirements for new and existing Underground Storage Tank (UST) systems.
OPW has put together a quick reference guide for everything you need to know to be compliant with the new EPA testing requirements.
Download OPW’s EPA Regulations guide to gain access to information from brochures, videos and articles to help you prepare for the October 13, 2018 compliance deadline. Please be sure to indicate the specific OPW EPA-Compliant testable products for which you would like to receive additional information.
Aside from getting some background on why the new regulation exists, who and what it affects, specifics about testing and what happens for non-compliance, it also includes 7 Ways Your Underground Fueling System Can Save You Money.
When Simple Energy of West Lebanon, NH was looking to expand their business to become their own bulk-storage facility with the latest technology to monitor at the rack, distribute and track inventory to not just Simple Energy’s fleet but to other commercial fleet customers Simple Energy was looking to attract as they expanded, they turned to Brian Devereaux, Vermont Sales Representative of the John W. Kennedy Company to do the job. Brian’s biggest concern was not just the simplicity of the installation process but the simplicity of using, maintaining and expanding the the system as well its reliability on a day to day basis.
As Brian stated, “The reason we went with OPW equipment was maximum compatibility and seamless integration. With these integrated systems from OPW, Simple Energy would be able to control its fuel inventory in real time and streamline fueling operations overall.”
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:
Registered Stage I / II facilities:
The spreadsheet lists Stage I or Stage II facilities that are registered in the MassDEP Stage I / II database.
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,
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.
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.
Calculating Due Dates:
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:
Bureau of Air & Waste
Stage I / II Vapor Recovery Program
1 Winter St., 7th floor
Boston, MA 02108
The John W. Kennedy Company appreciates your business and continued support!
In 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.
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 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’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!
Technical Standards and Corrective Action Requirements for Owners and Operators of Underground Storage Tanks
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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 firstname.lastname@example.org.
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!