Chapter 58 – Underground Storage Tanks

DRAFT

Contents

Approved by Jim Buehler
Revised 1/24

58.1 Policy
58.2 Scope
58.3 Applicability
58.4 Exceptions
58.5 Roles and Responsibilities
58.6 Definitions
58.7 Required Work Process
58.8 Source Requirements
58.9 Reference Documents

Note:
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58.1 Policy

The Underground Storage Tanks (UST) Program ensures that Berkeley Lab remains in compliance with federal and state UST laws by:

• Ensuring that Berkeley Lab’s Designated UST Operators within the Facilities Division perform visual inspections on the USTs every 30 days.
• Maintaining and implementing a UST Monitoring Program/Plan that is capable of detecting an unauthorized release from any portion of the UST system at the earliest possible opportunity, which includes, but is not limited to, coordinating monitoring certifications, and spill container, secondary-containment, and tank and line leak testing, at their required intervals.
• Maintaining a permit with the City of Berkeley for each UST system.
• Notifying the City of Berkeley when certification testing will be performed and when any changes are made to the UST systems.
• Submitting certification results and test reports to the City of Berkeley upon completion.
• Maintaining and implementing a UST Emergency Response Plan.

58.2 Scope

This policy covers UST systems located at Buildings 2, 76, and 85; and between Buildings 55 and 90.

58.3 Applicability

This policy applies to all Berkeley Lab employees involved in the operation of UST systems, including but not limited to employees performing inspections, ordering fuel, filling tanks, creating/maintaining UST records, and responding to spills.

58.4 Exceptions

Berkeley Lab obtained a waiver from the City of Berkeley for the overfill prevention equipment requirement for the USTs at Building 2 and Building 85 under the condition that Berkeley Lab continues implementing the “FA Procedure for UST Fuel Fill Operating Procedure for Building 2 and Building 85.”  

58.5 Roles and Responsibilities

Regulatory Agencies

Designated UST Operator	Performs visual inspections, and records results on the “Designated Underground Storage Tank Operator Visual Inspection Report,” and submits a written report to Facilities Division Tank Owner/Operator within 48 hours of completing the inspection Provides EHS 0681 – UST Facility Employee Training for facility employees in the proper operation and maintenance of the UST system at least once every 12 months or within 30 days of assuming the duties of a facility employee Maintains a current “California UST System Operator” certification issued by the International Code Council (ICC), which is tracked via EHS 0682 – Designated UST Operator Training
Employees	Follow applicable UST laws, regulations, and policies Are fully aware of the environmental impact of their activities, and comply with all requirements that govern those activities Perform activities within acceptable written operating standards, and maintain current records whenever required Take immediate action to stop unplanned releases to the environment and report all instances of unplanned environmental releases to either 911 (if a life-threatening emergency) or Security & Emergency Services (SES) by calling 510-486-6999 (or x6999) (SES will then route the issue to the EHS Division) Complete all required training (EHS 0681 – UST Facility Employee Training)
Environmental Services Group	Develops and maintains laboratory policies and procedures to assure that operations are conducted in an environmentally safe manner and in full compliance with all applicable UST laws and regulations Assesses current and planned Berkeley Lab programs, and assists in defining UST compliance upgrades and corrective actions Makes presentations and participates in discussions regarding UST compliance matters with Berkeley Lab employees and regulatory agencies Manages the preparation of UST operating permit applications and UST modification permits Curtails or suspends any operations that pose an immediate danger to members of the public or the environment Investigates reports of unplanned environmental releases, and notifies federal, state, and local authorities in a timely manner, as required Coordinates and represents Berkeley Lab activities during UST audits and inspections by the City of Berkeley and other regulatory agencies Assists in the removal and closure of UST systems Provides updated information regarding the UST Program to the City of Berkeley via the California Environmental Reporting System, including but not limited to providing updated copies of the Designated UST Operator Identification Form Manages official training records, with the assistance of EHS Training Group for course credit for EHS 0681, UST Facility Employee Training and EHS 0682,   Designated Underground Storage Tank Operator
Facilities Division	Coordinates periodic certifications and testing of the underground storage tanks with external vendors who meet the UST service technician requirements for the duties to be performed   Responds to UST alarms Ensures applicable Facilities UST procedures are followed Performs corrective action to bring UST systems back into operation after system failures, which includes coordinating with external UST contractors/vendors Maintains consistent communications with the Environmental Services Group regarding UST concerns and issues
Facilities Division Management and Facilities Compliance Specialists	Ensure that UST laws, regulations, and policies are followed Request assistance from the Environmental Services Group for technical advice on what UST requirements apply to their operations and what appropriate compliance strategy should be developed Ensure that the Designated UST Operator within the Facilities Division provides training for employees in operational requirements pertaining to USTs, prepares the “Facility Employee Training Certificate” for each training, and transmits it to ESG (environment@lbl.gov) and EHS Training (training@lbl.gov) for course credit Ensure that activities are performed within acceptable written operating standards and that any required records are current Notify the EHS Division immediately of any unauthorized releases or systems issues that could negatively impact the environment Ensure that the Designated UST Operator maintains state certification and is recertified every two years Ensure that the Designated UST Operator conducts visual inspections every 30 days and coordinates annual certification and testing Ensures, in coordination with FA Vendor Services, that only state-certified UST service technicians and operators perform work on UST systems Manage and prepare budget requests for UST upgrades and corrective actions for institutional projects

58.6 Definitions

Term	Definition
Environmental occurrence	A sudden or sustained deviation from a regulated or planned performance at an operation that has environmental protection and compliance significance
Underground storage tank (UST)	“Any one or combination of tanks, including pipes connected thereto, that is used for the storage of hazardous substances and that is substantially or totally beneath the surface of the ground.”  (HSC Division 20. Ch. 6.7, Section 25281).

 

58.7 Required Work Process

The general requirements for the work process pertaining to UST systems management at Berkeley Lab are as follows:

Compliance

USTs and UST systems are stringently regulated by federal and state laws. Regulatory elements address the following aspects of UST systems management:

• Registration and operating permits
• Construction standards – double containment and overfill protection
• Monitoring and leak detection
• Integrity testing
• Release recording and reporting
• Closure – temporary and permanent
• Cleanup of contaminated sites

The City of Berkeley enforces the UST regulatory program through consolidation of federal, state, and local UST requirements.

Implementation

The Environmental Services Group (ESG) provides UST compliance support and maintains a documented program, through UST permits, a UST Monitoring Plan, and a UST Emergency Response Plan. The Facilities Division ensures that LBNL’s Designated UST Operators maintain state certification, which is required every two years.

The Facilities Division, as the tank operator, plays a major role in implementing plans and procedures to ensure compliance with UST and City of Berkeley regulations. The Facilities Division schedules the following implementation activities:

• annual monitor certification
• annual product precision line testing
• annual mechanical line leak detection testing
• annual spill bucket testing
• triannual secondary-containment testing and overfill testing
• annual training for specific facility employees who support UST systems

Designated UST Operators within the Facilities Division are responsible for conducting Designated Operator inspections of the UST systems. The Facilities Division also monitors and responds to any incidents or issues.

Berkeley Lab currently has six operating UST systems: Four of them store diesel fuel for emergency/standby generators, and the other two are used for unleaded and diesel fuel storage at the Building 76 motor pool.

58.8 Source Requirements

• California H&SC 25284
• 23 CCR 2610 et seq., Underground Tank Regulations
• 23 CCR 2712, Underground Tank Regulations – Permit Application, Quarterly Report, and Trade Secret Request Requirements – Permit Conditions
• 23 CCR 2715(f), Underground Tank Regulations – Permit Application, Quarterly Report and Trade Secret Request Requirements – Certification, Licensing, and Training Requirements for Underground Storage Tank Owners, Operators, Installers, Service Technicians, and Inspectors

58.9 Reference Documents

Title	Type
UST Monitoring Plan	Plan
UST Emergency Response Plan	Plan
FA Procedure (MA.MG.PRC.358):  Underground Storage Tank (UST) Fuel Fill Operating Procedure for Building 2 and Building 85 (Tanks TK-3-2, TK-4-2, and TK-1-85)	Procedure

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