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The Stepwise Tutorial to Business Owneroperator Identification County Of San Diego Sdcounty Ca

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Guidelines with regard toBusiness Owneroperator Identification County Of San Diego Sdcounty Ca

good morning everyone so this is the.first time presenting so fair with us.but how many of you guys are new to the.field new to underground storage tanks.so okay good a lot of beginners we are.going to cover the basics we'll go into.some detail at any point if you guys.have questions please just raise your.hand or any audio issues just let me.know and how many of you guys are here.just for icc hours okay so hopefully.this won't be too boring but you know.it's always a good comprehensive review.so like i said if you have questions a.long way just just let me know.interrupted at any time okay so here's.our agenda it looks looks lengthy but we.are going to cover a lot of material we.have some breaks thrown in of course you.guys need to get up at any time please.do so depending on how we go how quickly.we go we might deviate a little bit from.this but this is the the general.guideline so first before we get into.anything we'll talk about definitions so.we all are on the same page I will.review laws regulations Steve will.discuss ust inspections go into.operational requirements whether it be.paperwork or the physical inspection.recordable and reportable releases.monitoring and response plan and then.I'll come back in and talk about.corrosion protection and within the USD.system will also discuss spill.containment overfill prevention under.suspensor containment and that type of.monitoring tank monitoring requirements.will be a big section so we'll do that.right before lunch and then we'll break.before we talk about pipe monitoring.which is another big section as well as.vph tanks the post-2014 another break.which is always nice and then we'll.finish with testing requirements.licensing and certification and red tag.and alternative fuels just to wrap it up.okay.and if I use any acronyms or any words.you guys are unfamiliar with just let me.know some of these words we just become.second nature to us okay so before we.get started let's talk about what an.underground storage tank is so we're on.the same page here it means any one or.combination of tanks including the pipe.that's connected that is used for the.storage of hazardous substances and is.substantially beneath the surface of the.ground so you might ask well what does.that mean what is substantially or.totally beneath the surface of the.ground mean substantially beneath the.surface of the ground is an actual.definition in title 23 CCR and it means.that at least ten percent of the.underground tank system which is the.entire system volume including the.connected piping is below the surface of.the ground so what's an underground tank.system so that's going to include the.underground storage tank as well as.connected piping plus any ancillary.equipment and secondary containment.let's define what a pipe is in terms of.underground storage tanks basically it.means that all parts of any pipeline or.system of pipelines that's used in.conjunction with the storage of.hazardous substances okay here's just a.quick overview so you have a visual of.what we're talking about during our.whole presentation if this is a good.picture it shows what you as a consumer.might see the gas station but also.what's what's underneath the ground so.you have your dispenser and then you're.done ur dispenser containment and piping.which will go into lots of detail and of.course the tank here you can see in the.background you have a fuel truck.dropping fuel and we'll get into details.on all parts of this system and the.different components and monitoring as.well.okay and here's a schematic just so that.we can kind of get to me on the same.page with what we're talking about.regarding equipment containment so on.the bottom here you have the tank and.the orange piping that's the product.piping that's going to the dispenser.okay so that's going to deliver the fuel.to the car and then you have your vapor.recovery pipe which is that dashed.yellow line now it's going to bring the.vapors back to the tank which will.condense in the tank and then you have a.typical setup where you have a STP some.st p stands for submersible turbines.thump also called the piping sump and.then you have your fill sump so here's.just some basic components and we'll go.into details on on each of these along.the way so any questions before we move.on no okay okay here's will get this out.of the way a little bit talk about laws.and regulations so the question is what.is law what is regulation we hear these.terms all the time in the field as as.regulators so law is a binding or.enforceable rule at the state level.these laws are enacted by state.legislatures and it empowers agencies to.create regulations okay so regulations.are written to implement the authority.of the laws and they are.the words I guess or the basis that will.provide the details and procedures to.implement that law ok and all the.regulations are subordinate they also.have the force of law and I know from.personal experience I reference.regulations way more than I do law but.that's where you find the details it's.going to tell you what you need to do to.be in compliance with the law and which.which laws and regulations are.applicable to the USC program here in.state of California first and foremost.you have Code of Federal Regulations CFR.title 40 this is going to affect the.entire United States okay here in.California we work with Health and.Safety Code Chapter six point seven.which is the law and then our regulation.document is california code of.regulations title 23 and then most.Koopas have their own local ordinance.that also has some additional.information I'm going a little bit of.detail about each one of those so at the.federal level e of title 40 and this was.developed and published by the united.states environmental protection agency.also known as EPA they're going to force.subtitle one of the Resource.Conservation Recovery Act also known as.Rick row a term you you all probably.have heard of and parts 282 281 is where.you can find the UST technical.requirements California we have health.and safety code like I said which is law.and it provides the basic framework for.the California USD program the.applicable chapters would be six point.seven which is the underground storage.of hazardous substances in chapter six.point seven five which is going to.discuss the USD financial responsibility.those that have petroleum in their tanks.and then title 23 that's our regulation.california code of regulations the.official term and it's going to give you.the specific requirements ok this is.what's going to allow you to comply with.chapter 6.7 of Health and Safety Code.and then of course your local ordinance.then for example us being from San Diego.we reference san diego county code of.regulatory ordinances title six division.eight chapter 10 and the specifics that.you can find in our ordinance is going.to be the operation permits permitting.and any delinquency items okay this is.just a visual to show you have the.federal CFR that's going to cover the.entire United States as you go up the.pyramid it gets more specific you have.your California laws and regs and of.course at the top of the pyramid you.have your local ordinances or guidances.the other interesting thing to note.about this pyramid is that you could.never be less stringent than the level.below so California can be more.stringent than federal which it is and.local can even be more stringent than.California law so some koopas might have.requirements that are not necessarily.found at another Koopa which is always a.real treat for all the tank testers and.service technicians as they move from.the different jurisdictions but you can.be more stringent you just cannot be.left stringent so this is just a visual.to show that here's a summary chapter.six point seven will address some of.these different aspects as we go.throughout the presentation you're.always going to have definitions in the.beginning in both 6.7 and title 23 and.we'll get into some of those as we.proceed you can have exemptions and.we'll definitely go into some detail and.no exemptions whether it be piping.exemptions or tank exemptions this is.where you find information on your.operation permits as well designing.construction requirements this is going.to tell you what you need at the design.level depending on the install date for.your tank systems financial.responsibility is also addressed here in.Chapter 6.7 enhanced leak detection.release reporting and and penalties as.well.seidel 23 filled with articles you're.going to find your definitions your.general provisions and then article 3 &.4 will go into detail on new usts and.existing usds and those requirements.relief reporting repair and upgrade.requirements article 7 talks about.closure whether it be temporary closure.or permanent closure site-specific.variances can be found at article 8.article 9 talks about local agency.request for additional design and.construction requirements article 10.will be quarterly reports and trade.secrets as well as prone applications a.little bit of detail on red Telegraph.Authority which we will address at the.end of the presentation at article 10.5.and article 11 is corrective action and.12 will be electronic submission of lab.data so as you can see some of these we.don't refer to quite as often as they.article 3 an article for you all might.have already figured out which ones you.you know have tabbed then of course.there's various appendices that you can.refer to as well for additional.information ok so I've highlighted at.least in our experience the most.frequently used statutes and regs and.these for address basically but tank.installation and the dates that's when.we're trying to figure out what's going.on with the system the first question we.ask usually is what is the install date.the install date will let you know where.you fall within the regs and what.requirements this particular system.would need so from chips chapter six.point seven we have 25 292 and those are.going to dress the tanks that were.installed on or before january first.1984 so as i mentioned we've used the.term existing these are existing tanks.and we'll get to that a little bit as.well after january first 84 he have your.requirements for those tanks not can be.found in 25 291 25 to 90.2 and point one.involve the tanks that had some changes.in.in July of oh 3 and 0 4 so we'll get.into details and then of course you know.after july first 2004 you're going to.we're going to talking in great detail.about v ph systems or continuous.monitoring systems title 23 article 32.for are the most popular the most used.article 3 is the new tank they talk.about construction and monitoring.requirements and new underground storage.tank means an underground storage tank.which is not an existing storage tank so.that's easy enough but what's an.existing underground take uninstalled.honor before january first 84 or if.you're on a farm an existing tank would.also be a tank thousand stall before.january first 87 but also need to have a.capacity greater than 1,100 gallons and.stores motor vehicle fuel for purposes.of that business the agricultural you.know equipment.so of course with every law every.regulation we have exemptions so I'm.going to go into a little bit of detail.about that so what does it mean if you.have an exempt tank what does that.really mean if you USC is exempt from.either chapter six point seven or title.23 that means it's not subject to these.regulations or the law toggle 23 section.2621 will go into detail on the.exemptions and then chapter six point.seven you have these three sections.which will go into detail and I'll.describe the tank exemptions and some of.the piping exemptions as well okay so.we'll start with title 23 and there's.about I forget how many exactly but.about 15 or 16 exemptions and I like to.think of chapter I'm sorry section 26 21.discusses the exemptions based on.definition this type of tank either is.or is not exempt whereas with health and.safety code I feel like there's more.criteria that need to be met so it's not.quite as cut and dry I'll just run.through them right here but you'll.notice that most of these are.highlighted and the reason they're.highlighted is that these actually have.definitions in Title 23 so if you're.uncertain if you do have this type of.tank you can look it up and get a little.bit more detail and information on these.types of tank liquid asphalt tank there.was no definition but it's fairly.self-explanatory so we're looking at.farm tanks heating oil tanks hydraulic.lifts tanks liquefied petroleum gas.tanks liquid asphalt septic tank a sump.pit ponder lagoon and there's more so.wastewater treatment tank and then like.I said these are also highlighted.because these are defined because they.might not be completely clear when.you're first reading into this you're.not you might not be sure if you have.this type of tank so storm water or.wastewater collection system and then.tanks containing radioactive materials.there.so going to be exempt and then emergency.containment tanks and those must be kept.empty at all times we get of the Koopa.waste or storm water wastewater.collection systems emergency containment.tanks we get quite a few projects coming.from businesses trying to figure out if.they actually meet that definition and.oftentimes I get pulled into our special.project assistance program so we can.work with them to help them determine if.they've they meet those requirements and.it can be a lengthy process it's not.quite as cut and dry as you might think.so but we do offer that service we can.bring people in and have them go through.the process with us to help help them.meet that exemption and make sure they.have certain SOPs in place so that they.can continue to maintain this exemption.oh and there's more so okay so I was.right there's about 16 of them so of.course drums locating basements and.contain 55 gallons or less are exempt.hazardous waste as defined in Section 25.316 of Health and Safety Code and then.of course your tanks and associated.piping locating a vault or basement and.those exemptions are in 25 23.5 and.we'll go into some detail on those is.kind of a little bit of a hot topic and.then of course anything I specifically.exempt / 2521 y of Health and Safety.Code okay so now we're starting to get.some pictures to liven things up here.but here's an example of an exam tank.any any guesses what this might be you.didn't well yeah that's right so heating.oil tank and this is a definition that.can be found if you wanted more detail.so this is gonna be a tank located a.personal residence and it's going to.hold no more than 1,100 gallons of home.heating oil but it needs to be used.consumptive Lee at the premises where.the tank is located okay so because this.type of tank is exempt as I mentioned.before it's not subject to title 23 or.chapter six point seven so we often get.calls.heating oil tanks whether they need a.permanent with San Diego County to.remove them and the answer is no because.they are exempt but we often recommend.that they pull a permit just so that.they have record a lot of it gets lost.and it becomes important when they're.trying to resell the property so.sometimes exempting still come through.our plan check process just so that they.can have records of what was actually.done with the tank okay so I'm going to.talk a little specifically about the 25.to 83.5 exemption and some examples of.these just to give you a visual are.going to be tanks and a vault or tanks.located in the basement because don't.forget these types of tanks are still.below the surface of the ground and most.of the time substantially beneath the.surface of the ground so depending on.how their builds and how they're set up.they can get out of those regulations.even though they are beneath the surface.of the ground with this exemption and.like I mentioned before I feel like.title 23 gives you you know specific.definitions for an exempt tank whereas.25 23.5 gives you a list of criteria so.your goals that your tank meets this.criteria so I'll go over them quickly.here all exterior surfaces of the tank.including the connected piping must be.monitored by direct viewing including.the bottom of the tank and the structure.that it's in must provides for secondary.containment for the contents of the tank.and with this criteria the owner.operator must conduct weekly inspections.and maintain a log for review by the.local agency and of course the UST must.meet requirements are equal to or more.stringent than those imposed by the.chapter but excuse me by chapter six.point seven so it can be especially with.number four it can be a little bit of a.case-by-case basis they're all just a.little bit different some are easier to.exempt than others and we've had.situations where they almost meet the.exemption criteria but.the piping that might not be visual and.they have gone through plan check to.correct that so they they could meet.this exemption and here's just an.example this is that a typical oil.change facility and these tanks are in a.below grade structure and they do meet.all the criteria and they actually went.through like I mentioned we have our.special projects assistance program and.they came to us so they could work with.us to make sure that their tanks met.these exemption criteria because for a.lot of their sites they actually had to.move some tanks around so that they.could meet the criteria but if you.notice here it's hard to tell a little.bit but you have sufficient distance for.direct feeling whether it's the size of.the tanks and then of course on the.bottom it's not very large but it's big.enough you'll know if there's a leak.coming from the bottom of that tank and.then although you can't see I just so.you know it does meet the criteria all.the connected piping is contained within.the basement and they have they put in.place operating procedures that allow.them to maintain their exemption to be.equally stringent to chapter six point.seven okay and then I also wanted to.discuss a more recent addition to.chapter six point seven and at section.25 21.6 and this is going to be an.exemption for emergency generator tank.systems that are located in a below.grade structure so they have a different.set of exemption requirements and.they're actually in my opinion a little.bit less strict similar to 25 23.5 they.still need to have um exterior surfaces.the tank piping in the floor need to be.inspected however they have the option.of direct viewing they have the option.of cameras or other visual aids such as.video equipment so they don't have to.actually have a person present as you.would with the previous exemption okay.also they need to provide secondary.contain.for the tank contents and then they also.must do visual inspection but it's not.as frequent it's once a month or when.they operate the tank however also to.meet his exemption you need to have a.cumulative capacity of 1,100 gallons or.less of diesel fuel so it's slightly.different but it is specific to.emergency generator tanks okay and then.some additional exclusions I wanted to.bring up just because we have had.questions but you have your vent lines.your vapor recovery lines and your fill.pipes that are designed to prevent and.do not hold standing fluid in the pipe.your line so they are exempt as well.unburied fuel delivery piping at marinas.are exempt and then unburied fuel piping.connected to an emergency generator tank.system also are exempt however like I.said we'll get into some detail on.underground tank systems that were.installed after july first of a three.but those tank systems the portions of.vent lines and vapor recovery lines and.fill pipes that are beneath the surface.or ground do not meet this exclusion so.post 2003 tank installs these three.types of piping are now part of the pipe.definition so when they're not going to.meet that exclusion so that's where it.becomes real important to know the data.the installation date of your system so.if you have a single wall vent line.you're going to hope or assume that it.was install before july first 2003.because you would expect the postal i.first 2003 tank to have a double wall.vent line similar to the product piping.so like I said that's where the dates I.was probably the most important piece of.information you could start with in.terms of determining the requirements.for a system okay and here's just some.pictures pictures of this is marina.piping we have quite a few marinas down.in San Diego and we have one inspector.who's dedicated to doing these types of.inspections and you'll notice this the.single while piping and this is not a.problem.here's another view of that same piping.so like I said this was one of the other.exemptions that you could have for the.for piping that's more of an unusual.system and some of you might not have.these in your jurisdictions obviously.well here's an example of and I forgot.to mention when I was talking about laws.and regs although we have our ust.program laws and regs they're still.potentially other jurisdictions that.will have some requirements such as fire.departments and here's one example of.where this is emergency generator piping.and although is visually it's able to be.visually monitored it didn't actually.need to be double walled because it does.meet the exemption definition but / fire.code they wanted it double walled at.least in san diego city of san diego.within our County I'm not super familiar.with fire code issues but our fire.inspectors in San Diego wanted to have.this double wall and I'm not someone.might you know let me know that's.actually a requirement per fire code or.that was just specific at in Diego level.but here's just a visual example of.emergency generator piping that is above.grade and able to be visually monitored.okay we're gonna have a series of.quizzes just to keep you guys on your.toes keep you awake so California just.shout out the answer California usts are.regulated by what two bodies of law.if you guys don't tell me I'm gonna pick.on the few San Diego people I see in.here health and safety code what else.title 23 that's right okay can a local.ordinance such as our San Diego.ordinance can it be less stringent than.state law no that's right however it.can't be more stringent so keep that in.mind a couple more questions is a septic.tank regulated as a ust in california no.it's exempt per section 2621 that's in.title 23 okay if a tank is exempt per.Section 25 283 of Health and Safety Code.and remember that was the vaulted tank.exemption how often must it be inspected.that's right i once week and those.inspections must be logged okay ust.inspections i'm gonna turn this over to.Steve con so before we move on any.questions no yeah.uh-huh yes.well / I mean we've gotten hands and.knees flashlight and look underneath.that's good enough for the San Diego in.theory yes and to login as well I mean.you know as with any requirement that.does not involve our oversight I mean.that's that's what they need to do to.stay compliant but I mean most tanks are.on those skids where you get the one or.two inches and are getting some feedback.here we feel that that's enough we we.can take a peek under with a flashlight.and and you'll see and you'll see it I.mean that's the bottom line it's going.to run out its you're going to get it I.think insufficient time yes.right we make sure that it's not an.automatic sump pump because it does need.can you guys hear the question good we.make sure that it's not an automatic.sump pump that they would actually have.to activate it to get it to work so okay.okay sure okay so here's Steve colonies.going to talk about ust inspections.

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