The Petro Pulse - DEP's Northwest District Petroleum Storage Tank Newsletter
Florida Department of Environmental Protection sent this bulletin at 10/12/2022 12:15 PM EDT
October 2022
The Petro Pulse Newsletter is a source of information that can help you maintain compliance with the rules and regulations of operating and maintaining aboveground and underground storage tank facilities in Northwest Florida. We hope you find this information useful.
Florida Department of Environmental Protection (DEP) staff are available to assist. Please reach out to any of our contacts listed below with questions or concerns.
Florida's storage tank rules require tank owners to notify the state when changes are being made to the tank or its related components, such as installations, closures, incidents, discharges or a change in type of regulated fuel.
Proper notification of these events allows an inspector time to discuss upcoming changes with owners, operators and contractors and to ensure that equipment planned for construction is listed on the department’s approved equipment list (see web link below). This contact allows for discussion and submission of a scope of work by the contractor so that proper closure procedures and sampling is performed for closures. Timely notification also allows the inspector to schedule a site visit during the activity and verify that all equipment and procedures follow the state’s rules and/or manufacturer’s recommendations.
The department has established specific forms and reporting requirements to document storage tank system activities. See below for a list of required notifications, forms and reports for each activity.
Installation Requirements
Notifications: A written notification should be submitted to the appropriate county office 30 to 45 days before the work will be initiated. Many counties have their own form that can be completed and submitted for this notification.
At minimum, the written or emailed notification should contain the following: • Facility identification number. • Facility name. • Facility location. • Description of work to be done. • Work start date.
Another written or emailed notification must be submitted to the county 48 to 72 hours prior to the installation work to confirm the date and time of the scheduled activities.
Forms: Storage tank registration requires that an updated registration form be submitted for installations.
New Facility - no later than 30 days prior to the installation.
Existing Facility - no later than seven days prior to fuel being placed into the new system.
This form must also be completed by a PSSC for any aboveground storage tank (AST) system components that are in contact with the soil, such as piping, dispenser liners, piping sumps or spill containment systems.
The certified contractors form should be submitted in paper or electronic format to the county no later than 21 days after installation.
Removal and Closure Requirements
Notifications: A written notification should be submitted to the appropriate county office 30 to 45 days before the closure work will be initiated. Another written or emailed notification must be submitted to the county 48 to 72 hours prior to the closure work to confirm the date and time of the scheduled activities.
Forms: A closure integrity evaluation (CIE) must be completed no more than 45 days before a UST system or component that is in contact with soil are to be closed. The results of this evaluation are captured on the CIE form, which must be submitted to the county at the time of the initial closure notification.
Storage tank registration requires that an updated registration form be submitted within 10 days of a facility’s closure.
A certified contractors form must be submitted by a PSSC for closure or removal of any UST system/component and for any AST system component that is in contact with the soil. The certified contractors form should be submitted in paper or electronic format to the county no later than 21 days after installation.
Scope of Work: It is suggested that a consultant provide the county a scope of work for any sampling of an incident, discharge or closure. Details such as the tank components, locations of soil borings, depth of OVA readings or if groundwater sampling is required should be included. This information is used to ensure that the sampling process is following the department’s closure instructions.
Reports: Depending on the type of closure activity, results of the CIE or other factors, one of the following reports must be submitted to the county. Make sure to discuss the situation with your county inspector to determine which document is needed for your closure activity.
Closure Report with sampling and analysis results completed according to the “Instructions for Conducting Sampling During Storage Tank Closure, July 2019.” • USTs • ASTs
Incidents and Discharges
Incidents: An incident is where a release or a discharge may have happened at your facility and requires an incident notification form (INF) to be submitted to the county.
Incidents can result from: • Overfilling a tank. • A failed integrity test. • Loss of vacuum or pressure in a gauge. • Fuel in a sump. • A sensor in alarm. • A line leak detector is restricting or shutting power off to the pump. • unusual operating conditions. • A failed CIE.
Discharges: Discharges must be reported to the department on a discharge report form (DRF) no more than 24 hours after the discovery of the release. A discharge also requires a notice of pollution to be submitted to the State Watch Office.
Additional Information: The owner/operator/contractor must verify that the storage tank system will not be installed within a wellhead protected area or within 500 feet of a potable water well.
Owners/operators are required to list on the storage tank registration form and provide to the county the approved equipment installed on the tank system.
This list includes the DEP equipment number for the tank, components, and the release detection methods and systems.
A signed and sealed survey drawing of newly installed tanks and underground integral piping must be submitted by a professional land surveyor or professional engineer licensed in the state of Florida.
The drawing should include all construction and equipment design specifications, including exact dimensions and locations of the tanks and integral piping.
Florida rule requires operability and integrity testing to be completed for the tank, integral piping, sumps, spill buckets and shear valves.
Calibration or testing should be done for all storage tank components according to PEI/RP 100-17 for USTs, PEI/RP-13 for ASTs, or the manufacturer instructions.
All owners/operators are required to complete and submit DEP Form Part P.
If insurance is the mechanism of assurance used for your facility the insurance company will need to complete a DEP Form Part C, Insurance Endorsement or DEP Form Part D, Certificate of Insurance.
The department has established a method for regulated entities to submit Public Notices of Pollution (PNP) for reportable releases to the State Watch Office.
Section 403.77, Florida Statutes, defines a “reportable release” as any “release or discharge of a substance from a facility to the air, land, or waters of the state which is discovered by the owner or operator of the facility, which is not authorized by law, and which is reportable to the State Watch Office within the Division of Emergency Management pursuant to any department rule, permit, order, or variance.”
Notification Tracking
Use the table below to keep track of when a notification is due to the county and what forms or reports will be required for the activity. Failure to provide notification, submit a completed form or provide the required information may lead to the citation of a violation with a possible penalty.
Storage Tank Equipment Approved/Registered List (EQ List):
This list shows the storage tanks, spill containment, dispensers, dispenser sumps, piping sumps, overfill devices, and electronic and mechanical release detection devices that have been approved and registered with the department. The following are exempt from registration: dispensers, dispenser islands, nozzles, hoses, maintenance hole covers, fillbox covers, valves, ball float valves, cathodic protection test stations, integral piping (USTs)or small diameter piping (ASTs) not in contact with soil, unless the piping extends over or into surface waters, metallic piping (for AS’s), vent lines, AST vents and vacuum or pressure monitoring gauges.
