Point to Point Environmental (P2P) assists our clients with the rules regulating emergency backup power supply generators that use underground storage tank (UST) fueling systems. The Georgia Department of Natural Resources (DNR) Environmental Protection Division’s (EPD) Underground Storage Tank Management Program (USTMP) has implemented the new rules and regulations for UST systems that were a part of the U.S. Environmental Protection Agency (EPA) 2015 revisions to UST regulations. One of the major challenges with these new rules is the compliance and release detection for UST systems that supply emergency backup power supply generators.
In the original 1988 UST rules, emergency backup power supply generator systems were exempt from registration and release detection requirements for the fuel tanks. The 2015 UST rules eliminated this deferral for those emergency generator tanks that store fuel solely for use by emergency power supply generators. These new rules require owners and operators of emergency backup power supply generator systems to comply with all of the same rules and compliance standards that apply to your neighborhood retail gas station. P2P assists our clients with everything needed to comply with these new rules.
Owners of emergency backup power supply generator systems with USTs must register with the Georgia EPD. Owners are to complete and submit the registration form Notification for Underground Storage Tanks form (EPA Form 7530-1; Rev 6-2015), known as the 7530. This documentation provides the EPD with general information related to the location and ownership of the generator and UST system. Part of this registration documentation also includes specifying a trained and certified UST AB Operator to be responsible for the compliance, or to designate a third party to act as your certified operator. P2P can act as your AB Operator for your generator UST.
The 7530 form also requires an owner to select which release detection methods will be used on their UST system, choosing the applicable testing that will work for their specific site configuration including: tank tightness testing (TTT), line (piping) tightness testing (LTT), automatic line leak detector test (ALLD), fuel inventory records, Statistical Inventory Reconciliation (SIR), automatic tank gauge (ATG) reports, corrosion protection and rectifier logs for the cathodic protection system.
The release detection requirements will differ based on the generator and tank installation setup, so consulting with an expert will be necessary. Many systems will require modifications to the tanks and piping to accommodate the new testing requirements. Additionally, maintaining the proper record keeping will be especially important to avoid violations and fines when an EPD inspector comes to your facility. Copies of compliance records must be maintained for up to three years. As these rules are also new for the EPD, many inspectors are will have questions about your particular equipment configuration, and there is room to discuss and negotiate on the specific compliance measures for your facility.
The monthly inspections, regular testing and long term record keeping requirements may seem burdensome, especially for an emergency backup power supply generator system that only operates a few hours per year. Replacing the UST with an above ground storage tank (AST) system is an option that P2P has successfully implemented for many facilities. Closure of the UST system has its own set of requirements, and an AST system is not maintenance free. However, operating and maintaining an AST for your emergency backup power supply generator will not be nearly as onerous as the new UST regulations.
P2P assists our clients with regulatory interface with the Georgia EPD, including the preparation of compliance documentation and corrective action activities. P2P is committed to assisting with these compliance requirements while positioning your company for long term ease of compliance in a cost effective manner. Please call Point to Point Environmental at (678) 565-4435 to discuss your particular situation.