NOVEMBER 1, 2007 PERFORMANCE STANDARDS FOR
UST SYSTEM
SPILL CONTAINMENT
Question:
I want to place a regular (single-walled) spill bucket inside a
containment sump at the fill end of
the tank with a liquid sensor
in the containment sump. Will this meet
the new standards for secondary
containment
for spill buckets? (January 18, 2008)
Answer: Yes, this arrangement will meet the new performance standards.
Question:
I have an existing UST system that has a broken spill bucket.
Will the replacement spill bucket
have to meet the new
standards for secondary containment?
(January 18, 2008)
Answer: Yes, the replacement spill bucket is required to meet the new
performance standards including continuous interstitial monitoring
using an electronic liquid level
sensor or vacuum, pressure or hydrostatic interstitial monitoring
methods.
UNDER DISPENSER CONTAINMENT
Question:
When is under dispenser containment (UDC) required? (January 18, 2008)
Answer: All new motor fuel dispenser systems must have UDC that meets
the new performance standards including continuous interstitial
monitoring using an
electronic sump sensor or vacuum, pressure or hydrostatic interstitial
monitoring methods. A motor fuel
dispenser
system is considered new when:
• A dispenser is installed at a location where there previously was no
dispenser (new UST system location or new dispenser location at an
existing UST system), or
• An existing dispenser is removed and replaced with another dispenser
and the equipment used to connect the dispenser to the UST system
is replaced. This
equipment may include unburied flexible connectors or risers or other
transitional components
that are beneath the
dispenser and that connect the dispenser to the piping.
(Please note that any time piping or a piping component below or
including a shear valve or vertical check valve at a dispenser is
installed
or replaced, UDC must be added.)
Question:
If a dispenser is knocked over by a careless driver or a severe storm,
will the new or replacement
dispenser have to meet
the new performance standards? (January 18, 2008)
Answer: Yes, if the dispenser is replaced and the equipment used to
connect the dispenser to the UST system is replaced.
Question:
Will replacement of a shear valve or vertical check valve at an
existing dispenser trigger the requirement
for UDC? (January 18, 2008)
Answer: Yes, replacement of any piping component or component used to
connect the dispenser to the piping including a shear valve or
vertical check valve, will require
installation of UDC.
Question:
If I already have a containment sump beneath the dispenser, but have to
replace a piping component
or transition
component, what do I need to do? (January 18, 2008)
Answer: The UDC will have to meet the new performance standards. If not
already doing so, you will have to begin continuous interstitial
monitoring
using an electronic
sump sensor or vacuum, pressure or hydrostatic interstitial monitoring
methods. If using an electronic
sump sensor, you will
have to perform an integrity test of the sump every three years. Also,
you will have to
visually inspect the sump annually.
Question:
Will replacement of parts or maintenance items within a
dispenser trigger the requirement for UDC?
(January 18, 2008)
Answer: No, so long as you do not replace any piping component or
component used to connect the dispenser to the piping. If you
replace any component below and
including a shear valve or vertical check valve, you are required to
install UDC.
Question:
To install UDC for an existing UST system that has single-walled rigid
pipe, I have to cut the pipe
outside of the area
where the containment sump will be located, install
the sump, and then splice in a
section of new pipe. If I am only installing or
replacing a dispenser,
do I also have to replace the entire piping
run with pipe meeting the new performance standards? (January 18, 2008)
Answer: No, you do not have to replace the entire piping run so long as
you replace no more than two feet of piping outside the footprint
of the containment sump. Metal
components may not be used to connect spliced piping to existing piping
unless they are placed
in a
monitored containment sump. All other piping replacements or repairs
will require that the entire
piping run be replaced with pipe
meeting the new performance standards.
Question:
I am installing a new fueling system with an underground tank and
aboveground piping between
the tank and the dispenser.
Will UDC meeting the new performance
standards be required? (January
18, 2008)
Answer: Yes, UDC is required. Since 10 percent or more of the volume of
the fueling system is beneath the surface of the ground, the entire
fueling system is
considered a UST system. According to the new rules, when installing or
replacing a UST system, UDC is
required.
Question:
How do I perform a hydrostatic test of a containment sump? (January 18,
2008)
Answer: Request written instructions from the manufacturer of the
containment sump. If there are no written instructions, perform the
hydrostatic
test described in
Petroleum Equipment Institute Recommended Practice 100 PEI/RP100,
“Recommended Practice for
Installation of Underground
Liquid Storage Systems.” A copy can be obtained from PEI, PO Box 2380,
Tulsa,
OK 74101-2380.
Question:
To meet the interstitial monitoring requirements for UDC, can I use a
stand-alone liquid sump sensor
that will cut off electrical
power to the pump when liquid in the sump
is detected? (January 18, 2008)
Answer: No, the new rules require a tank owner or operator to have a
printed record of release detection monitoring results and an alarm
history for
each month.
Therefore, the sump sensor must be connected to a leak detection
console with a printer.
PIPING
Question:
If I have a failure of one piping run, do I have to replace all of the
piping runs at my UST facility
with piping meeting
the new performance standards? (January 18, 2008)
Answer: No, only the failed piping run must be replaced with piping
meeting the new performance standards including continuous interstitial
monitoring using an
electronic sump sensor or vacuum, pressure or hydrostatic interstitial
monitoring methods.
Question:
The new rules specify that “piping that is buried underground must be
constructed with a device
or method that allows it
to be located once it is installed.” Can I use
a surveyed site plan to meet
this
requirement? (January 18, 2008)
Answer: No, a surveyed site plan cannot be used to meet this
requirement. The trace tape used by natural gas companies is the
preferred method.
Question:
Does the addition of a dielectric union to the dispenser end of a flex
connector trigger the requirement
to install a containment
sump or UDC? (January 18, 2008)
Answer: No, piping is not being replaced, so there is no requirement to
install a containment sump or UDC.
Question:
If adding or replacing a siphon bar between manifolded tanks, will the
siphon bar have to meet
the new performance
standards? (January 18, 2008)
Answer: Yes, a new or replacement siphon bar must meet the new
performance standards. Containment sumps must be installed at each end
of the siphon bar and
the sumps must be continuously monitored using an electronic sump
sensor or vacuum, pressure or
hydrostatic
interstitial monitoring
methods.
Question:
Is it necessary to upgrade other piping to the new performance
standards, if only a siphon bar
is installed or replaced?
(January 18, 2008)
Answer: No, only the siphon bar must meet the new performance standards.
Question:
Can I patch a puncture in single-walled product line by adding a flex
connector or fitting, or by splicing
in a length of
single-walled piping? (January 18, 2008)
Answer: No, the entire piping run must be replaced with double-walled
piping meeting the newperformance standards. Any time a section of
single-walled piping has
to be replaced, the entire pipingrun must be upgraded to meet the new
performance standards including
double-walled construction andcontinuous interstitial monitoring using
an electronic sump sensor or
vacuum, pressure or hydrostatic monitoring methods.
Question:
I want to extend piping from an existing dispenser to a new dispenser.
Will the existing piping
(piping from the tank to the
existing dispenser) have to be upgraded to
meet the new performance standards?
(January 18, 2008)
Answer: Yes, the entire run of piping all the way back to the tank is
required to meet the new performance standards. However, in the event
that the existing piping
(from tank to first dispenser) already meets the new performance
standards except for the trace tape,
the trace tape does
not need to be added to the existing portion of pipe.
CONTAINMENT SUMPS
Question:
A containment sump is cracked and must be replaced. Is the replacement
sump required to meet
the new performance
standards? (January 18, 2008)
Answer: Yes, the replacement containment sump is required to meet the
new performance standards including continuous interstitial monitoring
using an electronic sump
sensor or vacuum, pressure or hydrostatic interstitial monitoring
methods.
ANCILLARY EQUIPMENT
Question:
I have to replace the submersible turbine pump (STP) on a UST. Will the
new STP have to be
placed in a containment sump
meeting the new performance standards?
(January 18, 2008)
Answer: Yes, the replacement STP will have to be placed in a
containment sump meeting the requirements of the new performance
standards
including continuous
interstitial monitoring using an electronic sump sensor or vacuum,
pressure or hydrostatic interstitial
monitoring methods.
Question:
To install a containment sump at the STP for an existing UST, I have to
cut the pipe outside of
the area where the containment
sump will be located, install the sump,
and then splice in a section of new
pipe. If I am only installing or replacing the STP, do I also
have to
replace the entire piping run with pipe
meeting the new performance standards? (January 18, 2008)
Answer: No, you do not have to replace the entire piping run so long as
you replace no more than two feet of piping outside the footprint of
the containment sump. All other
piping replacements will require that the entire piping run be replaced
with pipe meeting the new
performance standards.
Question: If I am just replacing the motor within the STP, will I have
to add a containment sump meeting
the new performance
standards? (January 18, 2008)
Answer: No, replacing a motor within a STP will not trigger the
requirement for a containment sump.
Question:
If I am just replacing my automatic line leak detector (ALLD), will the
replacement ALLD have to
be placed in a containment
sump meeting the new performance standards?
(January 18, 2008)
Answer: No, if only the ALLD is replaced, it will not have to be
installed in a containment sump. However, if the STP is also replaced,
then the
ALLD and STP will have
to be placed in a containment sump meeting the requirements of the new
performance standards
including continuous interstitial monitoring using an electronic sump
sensor or vacuum, pressure or
hydrostatic interstitial monitoring methods.
SITING NEW UST SYSTEMS
Question:
Can I install an UST system in an area of contaminated groundwater?
(January 18, 2008)
Answer: If the groundwater in the area of the proposed UST system
installation is close to the surface and is contaminated with free
product, then the
UST system cannot be
installed at that location. The new UST system will have to be located
in another area of the site
where it will not be in contact
with free product.
NOTIFICATION REQUIREMENTS
Question:
When preparing UST system design plans, do the utilities on the site
have to be surveyed?
Answer:
The professional engineer preparing the design plan will make
this determination.
Question:
If I am
replacing piping that met the new performance standards with the exact
same piping, do
I
have to submit another
UST-6A, have a piping inspection and then submit
another UST-6B?
Answer: Yes, the rules require that notification be submitted when
tanks and piping, just tanks or just piping are installed or replaced.
The purpose of
this requirement is to
update the state’s records on the site and to ensure that the new
piping is constructed, installed and
tested correctly. If the
UST Section has previously approved the design plans for the site, then
the
subsequent review should take less time.
Question:
If I am adding or replacing a siphon bar between manifolded tanks, do I
have to submit a UST-6A,
have a piping inspection and
then submit a UST-6B?
Answer: Yes, a siphon bar is considered part of the piping system and
notification and inspection is required.
Question:
If I am adding UDC to an existing UST system and will not be replacing
the piping or the tank,
do I have to submit a UST-6A to
DWM for approval?
Answer: No, you do not have to submit a UST-6A to DWM if you are only
installing UDC for an existing UST system.
Question:
Do I have to pay a fee for DWM to review my UST-6A and UST-6B?
Answer: No, there is no fee.
Question:
Do the as-built plans submitted with the UST-6B have to be prepared by
a NC Professional Engineer
(PE)?
Answer: No, as-built plans do not have to be prepared by a PE. However,
a PE must approve (in writing) any modifications to the original design
plan.
UST SYSTEMS WITH ABOVEGROUND PIPING
Question:
If I am replacing the aboveground piping run at a marina from a
transition sump out to the end
of a dock, will the
replacement aboveground piping be required to meet
the new performance standards?
Answer: No, aboveground piping associated with a UST system does not
have to meet the new performance standards; however, UDC is required
under the dispenser.
1646 Mail Service Center, Raleigh, NC 27699-1646
(919)508-8400
