Storage Tank Plan
Storage Tank Plan
© 2018 Resource Training & Solutions
Introduction
This management plan is designed to help the St Cloud School District comply with the rules and regulations related to the safe storage of regulated petroleum in both underground and above ground storage tanks. The agency regulating these containers is the Minnesota Pollution Control Agency. Detailed information can be found on their website at: http://www.pca.state.mn.us.
As written this plan is intended to guide the district in its efforts to provide a safe and healthy environment in which to learn, but will need to be reviewed and modified on a regular basis. The St Cloud School District is responsible for the enforcement and updating of the plan. Actual use of the plan is limited to Resource Training & Solutions and to the St Cloud School District which it represents.
Plan Review and Updated Report
Storage Tanks Management Plan Review and Update Report
Program review and changes are documented below. Documented reviews indicate that the plan continues to meet the needs of the District, or has been modified to do so more effectively.
| Date | Updates/Notes | Reviewer |
| 04/23/21 | Updated designated person name to Dan Buchholz | Wayne Warzecha |
| 10/05/22 | Updated designated person name to Chad Emery | Wayne Warzecha |
Overview of Storage Tank Regulation
Underground (UST) and aboveground storage (AST) tanks have the potential to seriously damage the environment polluting soil and water with a large release of petroleum if not properly maintained. To avoid the serious consequences associated with an accidental release of petroleum, St Cloud School District will follow State and Federal regulations as administered by the Minnesota Pollution Control Agency (MPCA) and the Environmental Protection Agency (EPA).
Definitions
Aboveground Storage Tank (AST) - a container or vessel situated above ground used to store liquid petroleum products
Corrosion protection - a system designed to protect the tank (UST) or floor of the tank (AST) from degradation, required since December 22, 1998
Labeling - all regulated above ground tanks are required to be labeled with contents
Monitoring - routine monitoring required to ensure tanks are not leaking, must be visually inspected monthly
Overfill protection - an automatic shutoff device, alarm or ball flow valve, required on all ASTs
Piping system leak detection - required for all systems
Regulated volume - 1100 gallons or more
Secondary containment - area surrounding the tank that can hold 100 percent of the content of the largest tank located in the area must meet permeability matrix requirements
Spill protection - spill buckets or catchment basins to catch spills
Tank system leak detection - a variety of methods to monitor tank tightness
Underground Storage Tank - any container ten percent or more beneath the surface of the ground
Underground Storage Tank System (UST) - any one or combination of containers including tanks, vessels, enclosures or structures and underground appurtenances connected to them that is used to contain or dispense an accumla of regulated substances, and the volume which, including the volume of under ground pipes connected to them, is ten percent or more beneath the surface of the ground.
Designated Person
The St Cloud School District has appointed Chad Emery to be the designated or contact person relative to the management of UST/AST. Responsibilities for this position include, but are not limited, to ensuring that:
- applicable policies and procedures are followed;
- all regulated tanks are properly registered with the MPCA;
- the State Fire Marshall reviews AST installation;
- all tanks are visually inspected monthly;
- product release is promptly reported to the MPCA;
- tanks are regularly monitored for leaks; and,
- required records are completed and maintained.
- any steel "stiP3" UST has documented testing of the cathodic protection system done every 3 years or more often as required to maintain the UST's warranty.
Compliance
The St Cloud School District will ensure that all underground/aboveground storage tanks meet the following requirements:
- All tanks greater than 1100 gallons will be registered with the MPCA. Tanks less than 1100 gallons used for products other than heating oil will be registered with the MPCA.
- Tanks will be installed or removed only by MPCA certified contractors.
- The MPCA will be notified within thirty days of any change in tank status.
- The MPCA will be notified ten days in advance before an underground storage tank removal project.
- Any new underground storage tank installed will have corrosion protection.
- All regulated aboveground storage tanks will have secondary containment, corrosion protection and overfill protection.
- All regulated aboveground storage tanks will be labeled for contents.
- All regulated tanks will be monitored for leaks and regularly inspected.
- Tanks will be properly closed when taken out of service.
- Any product release will be promptly reported to the Minnesota Duty Officer phone number 1-800-422-0798.
Recordkeeping
All registration numbers, monitoring and inspection records will be maintained by the designated person and stored in the St Cloud School District office. (Appendix D)
Annual Review
The Superintendent or designee will present a summary of this program to the St Cloud School Board for review and approval.
Appendix B: Aboveground Storage Tank Systems
There are more than 20,000 regulated above-ground storage tanks (ASTs) currently in use across Minnesota.
Product types in the tanks can range from food-based to petroleum to hazardous materials. When properly designed and operated, ASTs are very safe. However, ASTs and their associated piping are subject to construction flaws, corrosion, stress, cracking, weld and valve failures, overfills, spills during transfers, and occasionally tank rupture.
When ASTs leak or spill, the stored substances may flow into lakes and rivers, migrate through the soil to the water table, or catch fire, thereby contaminating soil, ground water, or surface water and creating hazards to aquatic life and human health.
ASTs which store liquid substances that may pollute the waters of the state are regulated by Minnesota Rules, Chapter 7151, if site capacity is less than one million gallons. Larger facilities (facilities with a capacity of one million gallons or more) are regulated by permits negotiated with MPCA. The goal of regulating ASTs is to prevent spills and leaks by providing storage tank owners with various safeguard options. These options include safeguards such as: secondary containment to minimize the impact of a release, corrosion protection and overfill prevention to prevent releases, and tank monitoring for leak detection. The level of protection needed depends on the type of product stored, the size of the tank, and the date that the tank was installed.
Which ASTs are Subject to MPCA Regulation?
Most tanks located above ground containing liquid substances (i.e., not gaseous or solid at ambient temperature and pressure) are subject to the MPCA’s rules for design and operation of ASTs. Tank appurtenances such as piping, valves, containment areas, and loading areas, are also covered. Definitions in the rules can be found at this link. Minnesota Rules, Chapter 7151.1200
Some types of ASTs are exempt from the regulations. They include:
- ASTs with a capacity of 500 gallons or less;
- farm ASTs;
- residential ASTs storing 1,100 gallons or less of motor fuel used for noncommercial purposes;
- ASTs holding 1,100 gallons or less used to store heating oil for on-site consumption;
- wastewater treatment equipment including a wastewater clarifier, wastewater treatment basin a tank regulated by a National Pollutant Discharge Elimination System permit (NPDES), Sewage Disposal System permit (SDS), or another pretreatment system permit;
- equipment holding substances used for operational purposes like integral hydraulic lift tanks, lubricating oil reservoirs for pumps and motors, and electrical equipment;
- ASTs containing hazardous wastes subject to a treatment or storage permit;
- stormwater collection systems and septic systems;
- ASTs containing agricultural chemicals regulated under Minnesota Statutes Chapter 18B, Chapter 18C, Chapter 18D;
- a vehicle like a tank truck or a railroad car designed to transport substances from one location to another unless it remains in the same location more than 30 days;
- ASTs containing drinking water, filtered surface water, demineralized water, noncontact cooling water, or water stored for fire or emergency purposes;
- ASTs with a capacity of 1,100 gallons or less that are not located within 500 feet of Class 2 Surface Water;
- tote tanks (See Tote Tanks fact sheet)
- indoor tanks (See Indoor Storage Tanks Fact Sheet)
- compressed gas tanks
- stainless steel tanks containing any substance that is not a petroleum product or hazardous substance; and
- a surface impoundment, pit, pond, or lagoon.
Federal Requirements
At the federal level, the Environmental Protection Agency requires non-transportation- related facilities with a total above-ground oil storage capacity of greater than 1,320 gallons to meet Spill Prevention, Control, and Countermeasure (SPCC) requirements. Both petroleum and non-petroleum oils (e.g. vegetable oil) are regulated according to SPCC. Other federal requirements relate to spill response and spill reporting.
Appendix A: Underground Storage Tank (UST) Systems
In Minnesota, there are about 18,000 regulated underground storage tanks (USTs) currently in use. The Underground Storage Tank Program was created to help prevent contamination caused by leaking tanks. The program focuses on technical assistance and compliance to achieve this objective.
Rules
- New UST rules became effective on March 24, 2008. The UST program Web page has been revised to reflect the new rules. All UST program forms and fact sheets are being revised to reflect the new rules and will be posted here as they become available. The following fact sheets summarize what's new for tank owners and tank contractors:
- What Tank Owners Need to Know about the New UST Rules
- What Tank Contractors Need to Know about the New UST Rules
- Copy of final adopted rule language
- Additional proposed changes to Chapter 7150 to reflect the Operator Training requirement of the Energy Policy Act can be viewed on the rule making web page. On that page you can find scheduled meetings, updates on the rule making process, and preliminary drafts.
Which USTs Are Subject To Regulation?
USTs which contain petroleum or hazardous materials are subject to the MPCA’s design and operating rules for USTs. Tank appurtenances such as piping and dispensers are also covered. Definitions in the rules are found at Minnesota Rules, Chapter 7150.0030.
Some types of USTs are exempt from the regulations. They include:
- tanks of 110 gallons or less capacity
- farm and residential tanks of 1,100 gallons or less capacity storing motor fuel for non-commercial purposes
- tanks of 1,100 gallons or less capacity storing heating oil for consumptive use on the premises
- tanks that contain a minimum concentration of regulated substances
- flow-through process tanks
- oil-water separators
What Are The Requirements?
Design and operating rules for regulated USTs include tank and piping corrosion protection, overfill prevention, dispenser and pump containment, cathodic protection system testing, release detection, and other requirements. A brief summary of each requirement and links to forms and fact sheets follows. The complete rules are available at Minnesota Rules, Chapter 7150, Underground Storage Tanks.
New installations
Prior installing or replacing any UST system or component, owners must provide 10-day pre-notification to the MPCA. A Certified Contractor must oversee all work, which must be in accordance with applicable codes.
*NEW* After March 24, 2008, all new and replacement UST systems (tank, piping, submersible pumps, dispensers) must be secondarily contained with interstitial monitoring. Pressure piping must have an automatic line leak detector or a sump sensor design. Fill pipes must have a drop tube, a liquid-tight spill catchment basin, and employ an overfill prevention device. Gasoline tanks must have Stage 1 vapor recovery (metro area only). Owners need to submit a post-installation notification to the MPCA, and retain appropriate design documentation from installation contractors.
For more information:
Corrosion protection for tanks and piping
Tanks and piping are required to use a corrosion protection design, to prevent degradation and rusting of metal components and leaks to the environment.
*NEW* After March 24, 2008, all new and replacement tanks and piping must use a secondary containment design with interstitial monitoring, except for heating oil tanks and piping, and safe suction piping. Acceptable secondary containment designs:
- Double-walled fiberglass-reinforced plastic (FRP)
- Double-walled steel with cathodic protection
- Double-walled steel with a composite FRP jacket
- Single-walled steel with a composite FRP jacket designed to contain and detect leaks through steel wall
- Double-walled flexible nonmetallic (piping)
For more information:
- Secondary Containment for Underground Storage Tanks (t-u3-19) (pending)
Acceptable materials for UST systems installed prior to March 24, 2008:
- FRP
- Steel with cathodic protection
- Steel with a composite FRP jacket
- Steel with an internal lining (tank)
- Flexible nonmetallic (piping)
- Secondary containment design
Internal lining inspections
USTs with an internal lining as the sole method of corrosion protection must be internally inspected within ten years after being lined, and every five years thereafter.
*NEW* The MPCA has now specified inspection procedures for these tanks, intended to ensure that these tanks are structurally sound with the lining still performing to original design specifications. Required procedures include: pre-notification to the MPCA, designated inspection code, inspector qualifications, manned entry with visual evaluation, specific tests such as holiday testing, ultrasonic testing, and hardness testing, post-inspection leak testing after repairs, and report submittal to the MPCA. Minor abnormal lining conditions may be repaired; however if more extensive lining failure occurs, the tank must be permanently closed.
For more information: www.pca.state.mn.us/sites/default/files/t-u6-01.pdf
*NEW* Dispenser and submersible pump containment
After March 24, 2008, new and replacement dispensers must have secondary containment underneath the dispenser, and submersible pumps must have secondary containment surrounding the pump head, in order to prevent contamination from leakage at these locations. Dispenser containment is not required where an existing dispenser is replaced and no work is performed beneath the shear valve. Containment must be made of synthetic materials (not concrete or metal) and have liquid-tight sides, bottom and points of piping penetration.
Secondary Containment for Underground Storage Tanks (t-u3-19) (pending)
Spill and overfill prevention
Tanks are required to have a catchment basin (spill bucket) surrounding the fill pipe, to catch spills that may occur when the delivery hose is disconnected from the fill pipe. Spill buckets must be kept clear of debris and storm water, and spilled product must be removed. Tanks are also required to have an overfill prevention device to minimize the chances of delivering more product to a tank than the capacity of the tank allows. Three options for overfill prevention include an automatic shutoff device (flapper valve), flow restrictor (ball float valve), and a high level alarm.
Cathodic protection systems
Cathodic protection systems protect metallic UST system components buried in soil from corrosion. Two types of cathodic systems are commonly used on UST systems, impressed current and sacrificial anode.
Cathodic systems must be properly maintained and tested periodically to ensure effectiveness. Sacrificial anode systems must be tested every 3 years by a qualified Cathodic Protection Tester. *NEW* Impressed current systems must be tested annually by a qualified Cathodic Protection Expert. *NEW* Cathodic system test results must be submitted to the MPCA within 30 days on one of the following forms:
- Cathodic Protection System Evaluation – Sacrificial Anode Type
- Cathodic Protection System Evaluation – Impressed Current Type
Minnesota accepts certification of Cathodic Protection Experts and Testers from the National Association of Corrosion Engineers (NACE) and the Steel Tank Institute (STI). Individuals must have education, experience, and documented competence in topics relating to soil resistivity, stray current, structure-to-soil potential, and component electrical isolation measurements of buried metal piping and tank systems.
More information about certified cathodic protection testing and testers can be found at the NACE and STI Web sites. Please be aware, however, that not all of the individuals included on these lists provide cathodic protection testing services for hire. The MPCA suggests contacting your tank service provider who may be able to direct you to individuals in your area that are certified to conduct cathodic protection testing, and many tank service providers are certified to conduct the test themselves.
- Cathodic Protection of Aboveground and Underground Tanks (pending)
Release detection for tanks
Tank owners must provide a method that can detect a release from any part of the tank, and the connected piping, pumps, and dispensers, that routinely contains regulated substances. Systems must either be monitored continuously or checked every 30 days for leaks.
*NEW* For secondarily contained tanks installed after March 24, 2008, monitoring of the interstitial space for leaks is required, using an automatic leak sensor or a monthly manual check. Any sensor must be function tested annually.
Acceptable release detection methods for tanks installed prior to March 24, 2008:
- Automatic tank gauging
- Inventory control (first 10 years only, tightness testing at 5 years)
- Statistical inventory control (SIR)
- Manual tank gauging for 1000-2000 gallon capacity tanks (first 10 years only, tightness testing at 5 years)
- Manual tank gauging for less than 1000 gallon capacity tanks
- Interstitial monitoring (secondary containment tanks)
For more information, use the following fact sheets on leak detection methods.
- Automatic Tank Gauging for Underground Storage Tanks (t-u3-03)
- Inventory Control for Underground Storage Tanks (t-u3-20)
- Statistical Inventory Reconciliation (SIR) for Underground Tanks and Piping
- Tightness Testing for Underground Storage Tanks (t-u3-21)
- Secondary Containment for Underground Storage Tank Systems (t-u3-19) (pending)
Release detection for piping
*NEW* Pressurized piping installed after March 24, 2008, must be secondarily contained, and the interstitial space must use a gravity drain design to a sump. The interstitial space must be monitored using one of the following options:
- Continuous interstitial monitoring (sump sensor with alarm, flow restrictor, or shutoff).
- Continuous automatic line leak detector plus monthly sump monitoring.
Pressurized piping installed prior to March 24, 2008, must use one of the following options:
- Continuous automatic line leak detector plus annual line tightness testing;
- Continuous automatic line leak detector plus monthly SIR;
- Continuous automatic line leak detector plus monthly sump monitoring; or
- Continuous interstitial monitoring.
Automatic line leak detectors and sump detectors must be function tested annually.
Release detection is not required for properly designed "safe suction" piping. Other suction piping (any installation date) must use one of the following options:
- Line tightness testing every three years;
- Monthly SIR;
- Continuous interstitial monitoring; or
- Monthly interstitial monitoring.
The following fact sheets provide further information:
- Leak Detection for Pressure Piping (t-u3-12)
- Leak Detection for Suction Piping (t-u3-13)
*NEW* Sump checks
All spill catchment basins (spill buckets), dispenser sumps, and submersible pump sumps must be visually checked on a monthly basis for leaks, water, and debris. A secondarily contained submersible pump sump with an automatic leak sensor need only be checked on an annual basis. Any leaked or spilled product, water, or debris must be cleaned out.
Temporary and permanent closure
Certain requirements must be followed by owners when leaving a tank inactive for a period of time (“temporary closure”) or taking the tank out of service permanently (permanent closure).
- If a tank is not being actively used for more than 90 days, the owner must notify the MPCA of temporary closure status, empty the tank, lock out fill lines, and continue to maintain cathodic protection.
- *New* Temporarily closed tanks must be permanently closed at the end of one year, unless the owner has received written MPCA approval to continue in temporary closure.
- *New* A tank that has been temporarily closed more than one year needs written MPCA approval to return to service. Temporary closure may not extend beyond 5 years. If temporary closure requirements are not met, the tank is considered an active tank and normal operating requirements should be followed.
The MPCA must receive advance notice of permanent tank closure. Permanent closure involves emptying and cleaning the tank and piping, and either removing the tank and piping from the ground or filling them with an inert substance.
- Temporary and Permanent Closure of Underground Storage Tanks (t-u1-38)
- Planning Ahead for an Underground Storage Tank Removal (t-u2-20)
- Application for Extension of Temporary Closure of Underground Storage Tanks (t-u5-07)
Heating oil tanks
Tanks larger than 1100 gallons containing new fuel oil or waste oil which are used solely for heating purposes on the premises, are subject to notification and corrosion protection requirements, but are exempt from most other requirements including spill and overfill prevention and release detection.
- Heating Oil Underground Storage Tanks (t-u1-08)
Emergency generator tanks
Tanks containing new fuel oil or waste oil which are used solely for emergency power generation purposes on the premises, or which are used for both emergency power generation and heating (dual-use), must follow all UST requirements except that tanks installed prior to March 24, 2008, are exempt from release detection. Tanks installed after March 24, 2008, must be secondarily contained and use interstitial monitoring.
Used oil tanks
Used oil (waste oil) tanks are regulated and must follow all applicable UST design and operating rules. If a used oil tank is used solely for heating purposes on the premises and no used oil is pumped from the tank for recycling or re-use elsewhere, it must follow the requirements for heating oil tanks (see Heating Oil Underground Storage Tanks).
Vapor recovery for metro gasoline USTs
Stage 1 Vapor Recovery is the process of recovering hydrocarbons that are emitted during the transfer of gasoline from the delivery vehicle into the underground storage tank (UST) holding petroleum products. Vapors in the tank are displaced as the gasoline fills the tank. During Stage 1 Vapor Recovery, the vapors are routed through a hose back into the tanker instead of venting directly into the atmosphere.
All retail locations selling gasoline to automobiles in the Twin Cities seven-county metro area must perform State 1 Vapor Recovery. The seven-county metro area includes the following counties: Anoka, Carver, Dakota (excluding the city of Northfield), Hennepin (excluding the city of Hanover), Ramsey, Scott (excluding the city of New Prague), and Washington.
Underground Storage Tank Quality Assurance Program Plan
This document provides general guidance for our internal staff as well as our external clients. Please review the document:
UST Contractor Certification
Installation, repair and closure of regulated underground storage tanks, piping, and dispensers must take place under the oversight of a contractor certified by the MPCA. A Certified Supervisor who is in the employ of a Certified Contractor must be present on-site during any work. It is unlawful for an owner or operator to employ a contractor that is not certified by the MPCA in the tank discipline (installation, repair or closure) for which work is contracted. Applicable rules are available at:
Selecting a Certified Contractor
The fact sheet below provides guidance on choosing a Certified Contractor.
A list of MPCA-certified underground storage tank contractors is available. Companies are arranged in the list alphabetically by city, and the list is updated monthly. The MPCA is not endorsing these companies nor providing testimonials about the work quality of these companies. This list is supplied as a public service and only includes companies which have completed certification requirements.
Becoming a Certified Contractor or Certified Supervisor
In order to become a Certified Contractor, an application form must be completed and submitted with proof of insurance and an application fee of $50. In order to become a Certified Supervisor, an application form must be completed and submitted together with a photocopy of the diploma received after successfully completing an MPCA approved (re)certification course and an application fee of $50. Contractor training sponsored by the MPCA is available on a regular basis. Further information is contained in the fact sheet below.
Appendix C: Storage Tanks Inventory Form