Petroleum Bulk Storage at Syracuse University
Tank Compliance Procedures Manual


Table Of Contents

  1. Introduction
  2. Registration Requirements
  3. Minimum Standards for Underground Petroleum Bulk Storage Tanks
    1. Labeling
    2. Spill Prevention
    3. Overfill Prevention
    4. Vapor Recovery
    5. Corrosion Prevention
  4. Minimum Standards for Aboveground Petroleum Bulk Storage Tanks
    1. Labeling
    2. Spill Protection
    3. Overfill Protection
    4. Secondary Containment
    5. Vapor Recovery
    6. Corrosion Protection
  5. Valves for Petroleum Bulk Storage Tanks
  6. Inspections
    1. AST Inspections
    2. UST Inspections
    3. Underground Piping Testing
    4. Cathodic Protection Testing
    5. Routine Maintenance
  7. Product Delivery and Transfer
  8. Spill Response
  9. PBS Tank Closure
    1. Bid Requests
    2. Tank Discovery
    3. UST Closure
    4. AST Closure
    5. Registration Modification
  10. New and Substatially Modified PBS Systems
  11. Temporary and Portable PBS Tanks
  12. Appendices
    1. Monthly AST Inspection Form
    2. Monthly UST Inspection Form
    3. After Hours Spill Protocol
    4. API Color Coding and Symbols

I. Introduction

The SU Petroleum Bulk Storage (PBS) Tank Compliance manual is intended for use by personnel at Syracuse University (SU) responsible for the inspection, care and maintenance of aboveground storage tanks (AST) and underground storage tanks (UST) which store petroleum products. This manual and the procedures contained in it are designed to assist University personnel in achieving and maintaining compliance with related Federal and State petroleum bulk storage tank regulations. Implementation of requirements and recommendations provided in this manual will help to ensure protection of the environment from release of petroleum product.

If you have any questions regarding the procedures or requirements contained in this manual, please contact the Environmental Health Office at X-4132.

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II. Registration Requirements

Facilities with a combined storage capacity of greater than 1,100 gallons must be registered with the NYS DEC. NYS registrations must be renewed every five years from the date of the last valid registration. The Syracuse University Environmental Health Office (EHO) files, modifies, and updates all registrations as required. Information necessary to complete the registration application is provided by university tank owners / managers and from information provided on previous registrations. New tanks must be registered 30 days prior to being put into service. Tank design projects and tank purchases must be reviewed by the EHO for regulatory compliance, prior to purchase and/or installation. All registration fees are the responsibility of the owner (department) of the tank system.

Requirements for Registration

  1. Display certificate : The NYSDEC Petroleum Bulk Storage Regulations specify that a copy of the tank registration certificate be displayed on the premises at all times. The tank registration should be displayed in the immediate vicinity of the tank or the tank's monitoring system. A copy of each registration will also be maintained at EHO.
  2. Notification of Product Change: Each tank registration is issued for a single stored substance. Prior to changing the contents of any UST or AST, the EHO must be notified so the required registration modifications can be made.
  3. Notification of Major Modification: Major tank or tank system modifications require EHO and NYS DEC review and approval thirty (30) days prior to beginning work. The EHO will review the proposed tank modifications to ensure compliance with the NYS DEC regulations and make the proper registration revisions. Then, the EHO will complete the necessary forms and submit them for NYS DEC approval. Examples of major modifications are: installation of a spill bucket, addition of secondary containment, changing the piping material, etc.
  4. Labeling: The registration requires that each tank be labeled. See section III & IV of this Manual for the labeing requirements for ASTs and USTs respectively.
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III. Minimum Standards for Underground PBS Tanks (USTs)

  1. Labeling
    Underground tanks must have a permanent stencil, label, or plate on the tank which contains the following information:
    1. Manufacturer's statement that, "This tank conforms with 6 NYCRR Part 614;"
    2. Year manufactured and the name of the manufacturer;
    3. Standard of design by which the tank was manufactured;
    4. Product compatibility with the tank material;
    5. The identification number and;
    6. Dimensions, design and working capacity, and manufacturer's model number.

    UST's must also possess a second label with identical information as above. The second label must be imbedded in concrete, welded to the fill port or otherwise permanently affixed so it is visible to the carrier, person, or vendor transferring the product to the tank.

    In addition, the tank's fill port must have the proper API color-coding and symbol identifying the product in the tank (See Appendix C). During monthly inspections, personnel must be sure that these labels are intact. If any deficiencies are found they must be corrected as soon as possible.

  2. Spill Prevention
    To eliminate fill port spills, the product carrier and an authorized SU employee must closely monitor every delivery (See Section VII). In locations with applicable SPCC requirements, a delivery procedure must be reviewed and approved by the EHO. Once approved, it must be adhered to every delivery.

    To prevent spills, USTs must be equipped with catchment basins, containment manholes, or spill buckets designed to contain spills from delivery hoses. Installed properly, they surround the fill port and collect small amounts of product that may be released when the truck's hose is disconnected.

    There are several methods for removing liquid that accumulates in catchment basins. One involves a manual pump installed within the basin and the other is simply a drain that empties the liquid into the tank. Unless the basin contains pure product, it should not be drained into the tank. If a water / product mixture is present, it must be pumped into a container, sealed, labeled, and placed in an appropriate SAA for removal and proper disposal by the EHO. Inspection of the spill buckets must be performed monthly.

    Contact the EHO with any questions regarding catchment basin liquid disposal.

  3. Overfill Prevention
    Overfills are releases that can occur as a result of equipment failure or careless product deliveries. The NYS DEC has mandated engineering controls to stop product flow, trigger audible alarms, or visually signal the operator before overfills have a chance to occur. See Sections VII and VIII for more information on prevention of and response to overfills.

    All registered USTs must have the following:
    1. Product level gauge or an overfill alarm and
    2. Automatic shutoff device or a ball float valve

    Descriptions
    1. Product level gauges:
      The product level gauge must be readily accessible to the product deliverers during delivery. If there is any doubt about the level gauge accuracy, a qualified SU employee must manually verify the tank capacity before filling begins. Tank charts are available to decipher the specific tank capacity with a simple tank stick measurement.
    2. Overfill alarms: An alternative to a product level gauge is the overfill alarm. Overfill alarms are installed to alert the product deliverer when a tank is 90% full or within one minute of being full. The device must be installed where the product deliverer can see or hear the alarm easily and have enough time to terminate delivery. Alarms are often installed as part of an automatic tank gauging system but can also consist of a vent whistle that uses tank pressure during filling. Various size visual overfill lights are also associated with overfill alarms to help in noisy areas, assist the hearing impaired, or serve as a backup for a malfunctioning audible alarm.
    3. Automatic shutoff devices:
      An automatic shutoff device is typically installed in the fill pipe and stops the product delivery when a predetermined tank level is reached (usually 95% capacity). Below are three different types of automatic shutoffs.

      An alternative method alerts the operator when the tank is no more than 90% full, by restricting the flow or by triggering a high level alarm.

      On larger tanks (> 4,000 gal.), flow is sometimes restricted 30 minutes prior to an overfill. Then, either an alarm sounds at 1 minute before the designated fill capacity or an automatic shutoff valve completely stops the flow.
    4. Ball float valves:
      Ball float valves are placed in the tank vent line below the top of the UST (distance depends on tank size). When installed properly, the device floats on the product and rises with the product level during delivery. The float valve restricts vapor flowing out the vent line and creates backpressure. This restricts product flow into the tank and alerts the driver to shut off delivery. Manufacturers do not recommend using ball float valves with suction piping, pressurized delivery or coaxial Stage I vapor recovery.

  4. Vapor Recovery
    Vapor recovery is the process of recovering volatile organic compounds (VOCs, Ex: gasoline vapors) from the storage tank and returning them to the supply vehicle. The NYS DEC requires that gasoline dispensing systems with an annual throughput exceeding 120,000 gallons must have stage I vapor recovery, an onsite vapor control system, or an equivalent control system.

    IMPORTANT: The product deliverer must have a sealed connection on the fill port when using automatic shutoff valves, float vent valves, and stage I vapor recovery. If there is not a sealed connection when an automatic shutoff valve or float vent valve closes, the product will spray out of the fill port. If the tank has stage I vapor recovery, the system will not pressurize properly and the Vapor Recovery will not function.

    All Fill Caps Must Have Locks and Emergency Spill Kits Must be Readily Available at the Fill Port of All SU Tanks.

    The NYS DEC has mandated all gauges, valves, and other spill prevention equipment be kept in good working order. Therefore, SU tank owners / operators are responsible for maintaining all overfill / spill prevention devices on all SU tanks.

  5. Corrosion Prevention
    Federal and state regulations have become stringent with the design criteria for USTs to minimize the amount of corrosion related leaks. USTs and associated underground piping must have one of the following protective measures to protect against corrosion:
    1. Corrosion-resistant coating and cathodic protection (steel construction)
    2. Non-corrodible construction material (NYS approved)
    3. Non-corrodible cladding (fiberglass on steel construction)
    4. Uncoated exterior surface with non-corrodible interior.
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IV. Minimum Standards for Aboveground PBS Tanks (ASTs)

  1. Labeling
    All ASTs require labels at the tank and site gauge identifying the following:
    1. ID numbers as shown on the registration
    2. Chemical/common name of substance stored
    3. Proper color coding and symbol (See Appendix C) of the product
    4. Design Capacity
    5. Working Capacity

    In addition, the tank's fill port must have the proper API color-coding and symbol identifying the product in the tank (See Appendix C). During monthly inspections, personnel must be sure that these labels are intact. If any deficiencies are found they must be corrected as soon as possible.

  2. Spill Protection
    To eliminate fill port spills, the product carrier and an authorized SU employee must closely monitor every delivery (See Section VII). In locations with applicable SPCC requirements, a delivery procedure must be reviewed and approved by the EHO and must be adhered to every delivery.

    Several ASTs at the University are located inside buildings and their fill ports are piped outside for easy access to delivery personnel. These fill ports must be fitted with spill buckets serving the same purpose as UST catchment basins. If liquids accumulate in the buckets they must be emptied, placed in a sealed container, properly labeled, and placed in an appropriate SAA for removal and proper disposal by the EHO. Inspection of the spill buckets must be performed monthly.

  3. Overfill Protection
    Overfills are releases that can occur as a result of equipment failure or careless product deliveries. The NYS DEC has mandated engineering controls to stop product flow, trigger audible alarms, or visually signal the operator before overfills have a chance to occur. See Section VII and Section VIII for more information on prevention of and response to overfills.

    All registered ASTs must be equipped with the following:
    1. Product level gauge or overfill alarm and
    2. Automatic shutoff device

    NOTE: See Section III for full descriptions on 1and 2 above. Ball float valves are not designed for use on ASTs, therefore they are not listed above.

  4. Secondary Containment
    Any AST with the probability of releasing product to the waters of NYS or containing 10,000 gallons or more must be provided with a form of secondary containment. At the University, any tank in the vicinity of a storm drain, floor drain, or any other means of potential release to the municipal sewer system must also have secondary containment. Containment may consist of a double wall tank or any combination of dikes, liners, impoundments, ditches, etc. NYS mandates that accumulation of storm water, product, or debris in a containment area must be prevented. Therefore, product or storm water with sheen must be removed from the containment, placed in a sealed container, properly labeled, and given to the EHO for disposal.

  5. Vapor Recovery
    Vapor recovery is the process of recovering volatile organic compounds (VOCs, Ex: gasoline vapors) from the storage tank and returning them to the supply vehicle. The NYS DEC requires that gasoline dispensing systems with an annual throughput exceeding 120,000 gallons must have stage I vapor recovery, an onsite vapor control system, or an equivalent control system.

    Important: The product deliverer must have a sealed connection on the fill port when using automatic shutoff valves, float vent valves, and stage I vapor recovery. If there is not a sealed connection when an automatic shutoff valve or float vent valve closes, the product will spray out of the fill port. If the tank has stage I vapor recovery, the system will not pressurize properly and the Vapor Recovery will not function.

    ALL FILL CAPS MUST HAVE LOCKS AND EMERGENCY SPILL KITS MUST BE READILY AVAILABLE AT THE FILL PORT OF ALL SU TANKS

    The NYS DEC has mandated all gauges, valves, and other spill prevention equipment be kept in good working order. Therefore, SU tank owners / operators are responsible for maintaining all overfill / spill prevention devices on all SU tanks.

  6. Corrosion Protection
    The NYS DEC mandates that the exterior surfaces of all registered ASTs must be protected and properly maintained. AST exteriors must be painted with at least one primer coat, one bond coat, and two or more final coats. If an AST is built to rest on or in the ground , the bottom must be cathodically protected or designed with an impervious barrier.

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V. Valves For Petroleum Storage Tanks

The NYS DEC requires that certain valves be used on PBS systems. Tanks equipped with motor fuel dispensers require either shutoff or check valves depending on the type of dispenser and its location. Specialized valves are also needed for controlling normal flow, backflow, and siphoning. The different valves and their applications are listed below.

  1. Shutoff Valves For Remote Pumping Units at Motor Fuel Dispensers
    If a dispenser is under pressure from a remote pumping system, it must be equipped with a shear valve (impact valve) on the supply line at the inlet of the dispenser. This valve is designed to snap shut if a dispenser is dislodged due to accidental impact.

  2. Shutoff Valves For Gravity-fed Motor Fuel Dispensers
    All Tanks which cause a gravity head on a dispenser unit must have a solenoid valve (anti-siphon valve) to avoid motor fuel release due to pump failure or hose failure. This valve must be installed adjacent to and downstream from the operating valve mentioned below (D).

  3. Check Valves For Pump Filled Tanks
    Pump filled tanks must be fitted with a check valve in the fill pipe to eliminate the possibility of backflow. This valve is only needed when the fill piping is arranged such that backflow from the receiving tank is possible.

  4. Operating Valves For Gravity Drained Tanks Each connection to the tank to which petroleum can flow must be fitted with an operating valve to stop the flow.
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VI. Inspections

Qualified SU employees must periodically inspect both Petroleum ASTs and USTs (See Appendix A for examples of Inspection Forms). Records of inspections must be copied and sent to the EHO for filing. In the event a loss of inventory or a leak is discovered, EHO must be notified immediately so the proper actions can be taken.
  1. Aboveground Petroleum Storage Tanks
    AST monthly inspection records and Ten-Year inspection records must be maintained and made available to the NYS DEC upon request for at least ten (10) years.

    1. Monthly Inspection
      The NYS DEC PBS regulations require that monthly inspections be performed on all registered ASTs and the inspection records maintained for a minimum of ten years. Trained SU personnel perform monthly inspections on University PBS tanks. The inspection checklist (Appendix A) includes the following inspection items:

      1. Tank Exterior Integrity
      2. Tank Area / Foundation
      3. Tank Supports
      4. Piping
      5. Interstitial Space
      6. Overfill / Spill Protection Devices
      7. Safety Equipment

    2. Annual Audit
      Regular AST inspections and compliance documentation reviews are performed by EHO personnel to verify that the University's petroleum ASTs are in compliance with NYS PBS regulations and confirm that the monthly inspections are being properly performed (Annual Audit Forms - Appendix A). In addition, the inspection also addresses identified routine maintenance recommendations and mandatory repairs. The EHO personnel will supply a summary of the inspections results to the appropriate personnel.

    3. Ten - year Inspection
      As mandated by the NYS DEC a ten-year inspection must consist of a tightness test or a thorough integrity test. 10-year inspection records must be maintained for a minimum of 10 years after completion. An outside consultant with the proper certification, training, and equipment for the procedure should perform the actual inspection. ASTs exempt from the ten-year inspection are the following:

      1. entirely above ground (cradles, racks, etc.) or
      2. storing Nos. 5 or 6 fuel oil or
      3. contain less than 10, 000 gallons and unlikely to enter the NYS waters

  2. Underground Petroleum Storage Tanks

    1. Daily Inventory Reconciliation
      Daily inventory monitoring for the purpose of detecting leaks is required on registered USTs. The inventory records must account for all variables that would affect losses / gains of product and they must be kept current by a qualified SU employee. The daily inventory reconciliation records must be maintained for a minimum of five years by the SU tank owner / operator. Each tank inventory must include the following variables:

      1. bottom water levels
      2. sales
      3. use
      4. deliveries
      5. inventory on hand
      6. losses or gains

      If the UST contains petroleum for consumptive use on the premises or is not metered, an annual standpipe analysis (See Appendix E) or other acceptable method (per NYS DEC) can be performed in lieu of daily inventory monitoring.

      If inventory monitoring shows: inventory loss, a recurring accumulation of water in the bottom of the tank during any ten day period, apparent product losses or gains exceed three-quarters (3/4) of one (1) percent of the tank volume, or apparent losses or gains exceed seven and one-half (7.5) gallons per one-thousand (1,000) gallons delivered, the EHO must be notified immediately and an investigation will be initiated to identify the cause. If, within 48 hours the cause can not be attributed to something other than leakage, the NYS DEC will be notified by the EHO and the tank will be taken out-of-service (in accordance with 6 NYCRR §613.9 (a)). A tightness test will then be performed to determine the cause, and necessary repairs, replacements, etc. will be made. All associated costs will be the responsibility of the owner (department) of the tank system.

    2. Monthly Inspections
      The NYS DEC requires that monitoring systems for USTs be inspected monthly to insure proper working order (See Inspection Forms Appendix A). SU has trained personnel who are responsible for the UST monthly inspections. Once the inspection is completed, the forms must be sent to the EHO where they will be maintained for at least one (1) year. If at any time the system fails, it must be reported to the EHO and repaired within thirty (30) days. If the monitor is not repaired within thirty (30) days, it must be tightness tested within one (1) year and every five (5) years there after. All associated costs will be the responsibility of the owner (department) of the tank system.

    3. Annual Audit
      Regular UST inspections and compliance documentation reviews are performed by EHO personnel to verify that the University's petroleum USTs are in compliance with NYS PBS regulations and confirm that the monthly inspections are being properly performed (Annual Audit Forms - Appendix A). In addition, the inspection also addresses identified routine maintenance recommendations and mandatory repairs. The EHO personnel will supply a summary of the inspections results to the appropriate personnel.

      Annual inspections of the cathodic protection system must also be performed. It is recommended that a certified contractor perform this test to insure accuracy and proper documentation.

    4. Tightness Testing
      Tightness testing must be performed on all USTs without installed or properly operating leak detection systems (or monitoring system). The monitoring system must be capable of detecting a leak of at least 0.2 gal / hr or greater to be exempt from tightness testing. The testing schedule for USTs is specified in 6 NYCRR Part 613.5, Table 1. Only qualified and experienced tightness testers may conduct the procedure and the test report must be kept by the EHO for at least five years. Tanks exempted from tightness testing requirements include:

      1. Corrosion resistant tanks with a leak monitoring system or any new tank installed in conformance with §Part 614
      2. Nos. 5 or 6 fuel oil tanks
      3. Tanks containing less than 1,100 gallons unless the NYS DEC determines that the tank system could reasonably leak into NYS waters.
      4. Tanks constructed of corrosion resistant material (NYS approved) with a leak detection system
      5. Tanks containing more than 50,000 gallons or are technically impossible to tightness test.

  3. Underground Piping

    Underground piping and fittings must be made of cathodically protected steel or iron, fiberglass reinforced plastic, or other non-corrodible material (NYS approved). Access ports must be installed to allow for tightness testing without having to excavate. Other testing requirements for pressurized and suction piping are listed below.

    1. Pressurized: Annual line leak testing
    2. Suction: Line leak testing every 3 years

    NOTE: Both pressurized and suction piping have exemptions in accordance with the US EPA regulations (40 CFR Part 280). Call the EHO with clarification on the exemptions for testing of underground piping.

  4. Cathodic Protection

    Corrosion resistant tanks and pipes exempt from tightness testing must have the adequacy of their cathodic protection systems monitored annually. If at any time the system fails to supply the proper electrical current, it must be restored within 30 days. Any tank with a non-working cathodic protection system after thirty (30) days has lapsed must be taken out-of-service (in accordance with §613.9) and tightness tested within a year then every five years thereafter. All associated costs will be the responsibility of the owner (department) of the tank system. Monitoring records for cathodic protection systems must be given to the EHO where they will be maintained for at least one year.

  5. Routine / Periodic Maintenance
    All maintenance records must be maintained by the tank supervisor for a minimum of 5 years. It is recommended that a copy of the maintenance records also be provided to EHO.

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VII. Product Delivery and Transfer

An authorized SU employee must be present and maintain joint responsible with the carrier for the transfer of petroleum product. The following procedure must be followed for all bulk petroleum product transfers.

Prior to Transfer

Syracuse University Employee Responsibilities

  1. A qualified SU employee, trained in the content of the University's Spill Prevention Control and Countermeasures Plan and knowledgeable in the proper operation and transfer of the fuel product, must be present during the entire transfer process.

  2. The qualified SU employee must provide spill protection (i.e. drain mats, drain plugs, etc.) for all drains (floor, storm water, etc.) to which the transfer product may flow into in the event of a discharge (i.e. in the vicinity of the tank and fill port).

  3. The qualified SU employee must determine the available fill capacity of the tank and communicate this with the vendor.

    Steps for determining Tank's Available Fill Capacity
    • Determine the capacity of the tank (should be posted on the tank)
    • Determine current volumeof product in the tank. If this is determined other than by direct measurement, allow for a 10% safety factor (i.e. increase volume estimate by 10%) to avoid overfill conditions.
    • Determine maximum available fill capacity: Tank capactiy - current volume

  4. The qualified SU employee must verify that the product to be delivered is the same as the product contained in the tank.

  5. qualified SU employee must verify that the vendor's representative is qualified, knowledgeable and trained in the proper operation and delivery of the fuel product.

  6. The qualified SU employee must ensure that traffic in the immediate vicinity of the transfer process is effectively controlled or eliminated during the transfer process.

  7. The qualified SU employee should verify that the vendor's vehicle is appropriately grounded during the transfer process.

  8. The qualified SU employee must assure adequate communication with the vendor during the transfer process (i.e. 2-way radios set at a designated frequency, etc.)

  9. Once all of the above steps are completed, the qualified SU employee should then unlock the tank's fill port.

  10. The qualified SU employee must monitor the tank site during the entire fill procedure to ensure that the tank is not over filled and/or that pipes are not leaking.

Prior to Transfer

Vendor Responsibilities

  1. The vendor may not hook up or transfer any petroleum product unless a qualified University representative who is trained in the proper operation and delivery of the fuel product is present during the entire transfer process.

  2. The vendor may not hook up or transfer any petroleum product unless a qualified vendor representative who is trained in the proper operation and delivery of the fuel product is present during the entire transfer process.

  3. The vendor's qualified representative must verify the integrity of the tank and its storage location.

  4. The vendor's qualified representative must verify that the tank vent is open and unobstructed.

  5. The vendor's qualified representative must determine available fill capacity of the tank and then verify it with the SU employee.

  6. The vendor's qualified representative must verify with the SU employee that the product to be delivered is the same as what is presently in the tank.

  7. The vendor's qualified representative must inspect their vehicle and all equipment to be used during the transfer procedure (i.e. vehicle drain, outlet connections, transfer hose, equipment, etc.) to assure that they are functioning properly.

    Note: All liquid transfer equipment (hoses and piping) must contain valves which close automatically and provide a dry disconnection or other means or preventing a release of the product to the environment when transfer hoses or pipes are disconnected.

  8. The vendor's qualified representative must appropriately ground the vehicle. It is the policy of Syracuse University that vehicles must be grounded at all times during the transfer of petroleum products.

  9. The vendor's qualified representative must be readily able to communicate with the SU employee during the fill process.

  10. The vendor's qualified representative must remain at the fill location during the entire transfer process.

Prior to Departure

Syracuse University Employee Responsibility

  1. The qualified SU employee must ensure that all of the vendor's fill equipment has been removed from the fill port.

  2. The qualified SU employee must inspect the fill area to ensure no residual product remains in or around the fill area. If any is found the qualified SU employee must notify EHO (X-4132) and the vendor's representative immediately.

  3. The qualified SU employee must recap and lock the fill port.

  4. The qualified SU employee must retrieve the drain protectors and them place back in their appropriate storage area(s)

Vendor Responsibilities
  1. The vendor's qualified representative must properly disconnect all transfer hoses and provide assurance for the capture of residual product without discharge to the environment.

  2. The vendor's qualified representative must inspect the fill area to ensure no residual product remains in or around the fill area. The vendor is responsible for delivery related spill clean up.

Note: Petroleum product transfers should be made during normal SU operating hours to help ensure appropriate response in the event of a discharge/spill.
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VIII. Spill Response

In the event of a petroleum spill orleak the following procedure should be followed.

  1. Immediately evaluate the situation for an ignition source or other fire or explosion hazard. If such a hazard exists evacuate the area immediately and call Public Safety at X-711.

    Flash Points for SU Petroleum Products
    Product Flash Point oF
    No. 2 Fuel Oil 126 - 204
    Diesel Fuel 100 - 130
    Mineral Oil 300 - 450

  2. Identify the source of the leak/spill and terminate the flow if possible (i.e. shut off supply lines, close valves, etc.)

  3. Cover floor drains and/or storm water drains in the vicinity of the spill/leak with appropriate drain plugs or covers if available (appropriate drain protection should be available at every petroleum product storage tank).

  4. Contain the leak or spill if possible with appropriate materials (i.e. oil absorbents, spill pads, dike, etc.). Don appropriate protective clothing prior to containing the spill if there is a potential for contact with the petroleum product.

  5. Contact the Environmental Health Office (EHO) at 443-4132. EHO will provide assistance and/or advise on proper clean up and/or containment. EHO will also provide notification to the appropriate regulatory agencies as necessary.

  6. Collect petroleum contaminated debris (i.e. gloves, dikes, soil, etc.) in containers for proper disposal. EHO will provide assistance in determining proper disposal of contaminated items.
If EHO considers the spill to be small and easily remedied, you may do the following: Remember:: Wear appropriate protective clothing whenever working with petroleum products and never smoke or use an open flame.

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IX. PBS Tank Closure

Note: No Tank Should Ever Be Moved or Removed From Its Location Without Consutling EHO

Closure of all PBS tanks must be conducted in accordance with OSHA, NYS DEC, US EPA, and other associated regulations, as applicable. An EHO representative will ensure that the tank removal process is completed properly, act as the primary liaison with government agencies, and compile the necessary documentation for submittal, as necessary.

  1. Tank Closure Bid Request

    Tank closure bid requests that occur at the University must be reviewed by the EHO. The selected tank closure contractor must be knowledgeable of safe tank closure / cleaning procedures and all the applicable state and federal regulations. The EHO has formulated a preferred list of contractors that meet both University and NYS criteria. Language used in a bid request for a tank closure should include the following information:

    • Request for field sampling and related equipment
    • Request for soil / water sample collection and STARS laboratory analysis for excavation site (consideration for the expense of a "quick" turn-around of results should be made)
    • Request for disposal of contaminated soil, sludge, and water at an EHO approved facility (can be arranged prior to commencement of project)
    • Request for sampling and laboratory analysis of waste materials (typically specific by disposal facility)

  2. Tank Discovery

    The University must notify the NYS DEC within two (2) hours of discovery of a previously unknown and / or unregistered tank. If during construction, demolition, excavation, etc., a tank is discovered on University property, notify EHO immediately (x 4132). Before the tank is removed, the site must be evaluated by EHO personnel for possible petroleum releases and site specific documentation must be obtained. Once the tank is discovered and the DEC is notified, the closure process can begin. All costs of the closure process will be added to the associated project.

  3. UST Closure

    1. Notification
      Registered / known USTs being taken out-of-service (closed) must be reported to the NYS DEC at least 30 days prior to closure. After notifying the DEC of the UST closure event, the EHO will begin to collect site specific data for the Tank Site Assessment. The site assessment must be performed even if no materials are contaminated.

    2. Tank and Piping Assessment
      Once notification to EHO is made, steps must be taken to determine the content status (empty, full, liquid, solid, etc.). If the tank contains a liquid substance, the substance must be identified. The liquid must then be removed by a qualified contractor and properly disposed of or recycled at an EHO approved facility. If the tank is full of a solid material upon discovery it is possible that the tank was previously closed and the EHO or the NYS DEC will determine further action to take at the site.

      The tank should then be excavated from the site. Closure of a tank in place is typically not allowed at SU except in extreme circumstances (i.e. tank removal will effect utilities, structural stability, etc.). Following tank excavation, the tank must be analyzed for structural integrity, sized, and rendered free of petroleum vapor (if applicable). The tank should then be properly cleaned by a contractor knowledgeable in safe tank cleaning procedures. Once the cleaning is complete, the tank and all associated decontamination / cleaning liquids must be properly disposed of at an EHO approved facility. The contractor must provide certification that the tank was properly cleaned.

      All piping associated with the tank (i.e. fill pipes, vent pipes, supply and return pipes, etc.) should be removed whenever possible. Removed piping must be emptied, cleaned and properly disposed or recycled. All petroleum contaminated materials removed from the piping or generated during the cleaning process must be properly disposed of at an EHO approved disposal facility. If, due to extreme circumstances, the piping must be left in place, it must be emptied, cleaned, securely capped, and documented.

      Remember, all waste / recycling sites must be approved by EHO prior to use for disposal of University generated wastes (See Sampling below for TSDF information).

    3. Site Assessment
      Once the tank has been removed, a visual assessment of the surrounding soils and ground water (if present) must be performed to evaluate if contamination has occurred. Typically a photo-ionization detector (PID, HNu, or other similar meter) can be used to field screen the soil at the excavation site for the presence of volatile organic compounds (VOC's / petroleum vapors). The results of all field screening tests must be documented (i.e. Site Assessment Form). If contaminated soil is present using the field screen, the soil will be excavated until there is no longer detectable limits on the PID. If excavating becomes inhibited and the soil is still contaminated, the EHO will collaborate with the NYS DEC regarding further remedial measures. All contaminated soil removed from the tank excavation site must be place on an impermeable surface (i.e. polyethylene sheeting) and covered with impermeable material to avoid recontamination of the surrounding soil. Uncontaminated soil can be separated.

      If groundwater is contaminated, the water must be removed from the excavation site and disposed of at an EHO approved disposal site. If contamination exists in the water table, the EHO will coordinate with the NYS DEC and establish the extent of contamination and future remediation plans.

    4. Sampling and Waste Disposal
      Once the PID indicates no / minimal residual contamination is present, endpoint samples must be collected as directed by the on-site EHO representative. This will typically include composite sample of all 4 sides of the excavation site and the site bottom. The samples must be analyzed by a certified, third party laboratory and they must meet NYS DEC STARS Memo #1 guidance levels. The excavation site will need to remain open and secured (SU ODC, Physical Plant, or Safety) until the analytical results are obtained (typically 24 hours). Approval to backfill will be given by the EHO or the NYS DEC.

      All contaminated soils must remain on site until arrangements have been made for proper disposal at an EHO approved Transfer, Storage, and Disposal Facility (TSDF). All TSDF's must be approved by the EHO prior to shipping of any University generated wastes.

    5. Tank Closure Report
      A closure report will be generated by the EHO or designated contractor. The EHO will submit the closure report and the site assessment report to the NYS DEC. The NYS DEC will evaluate the report and determine if further remediation activities are needed, if the site can be officially closed, or if any other activities need to be addressed per their request.

  4. AST Closure

    1. Notification
      Registered / known ASTs being taken out-of-service (closed) need to be reported to the NYS DEC within 30 days prior to closure. The EHO will notify the NYS DEC and will designate when removal can begin.

    2. Tank and Piping
      Any liquid or sludge in the tank must be identified and properly removed from the tank. The liquid and waste materials must be collected and disposed of or recycled at an EHO approved facility. Once the tank is empty, it must be rendered free of petroleum vapors. If the AST meets the NYS DEC standards for a new tank, it can be cleaned tested and reused. If the tank is to be disposed or recycled it must be retested for petroleum vapors and cleaned by a contractor knowledgeable in safe tank cleaning procedures. The contractor must supply certification that the tank was cleaned properly. Prior to leaving the site for disposal the tank should also be stenciled with the date of permanent closure and punctured with holes to guarantee no future usage.

      All piping associated with the tank (i.e. fill pipes, vent pipes, supply and return pipes, etc.) should be removed whenever possible. Removed piping must be emptied, cleaned and disposed of with the tank. All petroleum contaminated materials removed from the piping or generated during the cleaning process must be properly disposed of at an EHO approved disposal facility. If, due to extreme circumstances, the piping must be left in place, it must be emptied, cleaned and securely capped. The project manager must document the rationale for leaving pipe in place.

    3. Tank Closure Report
      A closure report for all ASTs will be generated by the EHO or designated contractor. The EHO will submit the closure report and the site assessment report to the NYS DEC. The NYS DEC will evaluate the report and determine if the site can be officially closed or if any other activities need to be addressed per their request.


  5. Registration Modification

    If a registered SU tank is closed, the EHO will modify the registration to indicate the tank closure. When the new registration is received from the NYS DEC, the EHO will redistribute it for proper placement, where applicable.
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X. New and Substantially Modified Petroleum Bulk Storage Systems



  1. Notification
    The NYS DEC requires notification a minimum of 30 days prior to the installation of a new PBS System or any substantial modifications. Furthermore, the Syracuse Fire Marshal needs to be notified at least 24 hours before any tank installation, major modification, or closure. The EHO should be notified as soon as a modification or new system installation is considered so the EHO can make all of the applicable contacts.

  2. Project Approval
    New and substantial modifications must meet or exceed standards set by the NYS DEC regulations (6 NYCRR §614). The EHO will review for approval new installations and modifications before construction.

    See Section II for Registration Requirements for new and substantially modified PBS systems.

    See Section VIII for proper spill procedures that may occur during a PBS modification.

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XI. Temporary and Portable PBS Tanks

  1. Temporary Tanks
    A temporary tank is a tank that is rendered immobile by affixing it to one location (i.e. wired, plugged in, hard piped, etc.).

    The EHO must be notified of the intent to place, use, or install any temporary tanks prior to placement on University owned or operated property. No tank may be placed without prior EHO review and approval. The EHO will verify if the temporary tank requires NYS DEC registration and as necessary will submit applicable documentation to the NYS DEC. A temporary tank must be registered with the NYS DEC when it is at a facility with an aggregate bulk petroleum storage capacity exceeding 1,100 gallons. If the addition of a temporary tank causes a facility to exceed a 1,100 gallons aggregate bulk petroleum storage capacity, all of the tanks at that facility (permanent and temporary) will require registration in accordance with the NYS DEC regulations (6 NYCRR §612).

    While in service, a registered temporary tank must have the ancillary equipment required for a NYS DEC registered tank (See Section IV and Section V). The EHO will conduct and document an initial inspection of all registered temporary tanks. In addition, a trained SU tank inspector appointed by the department responsible for use of the tank, will perform routine monthly inspections on temporary tanks used, placed, or operational for a thirty (30) day period or greater (See Section VI). Unregistered temporary tanks must also have the ancillary equipment required for NYS DEC registered tanks wherever feasible.

    All temporary tanks with a capacity of 55 gallons or greater, that are used or stored in areas which require oil SPCC Plans (i.e. Main Campus and Ainsley Drive facilities), must meet all applicable SPCC Plan requirements and have a product transfer / delivery procedure reviewed and approved by the EHO.

  2. Portable Tanks and Containers
    The NYS DEC classifies a petroleum bulk storage tank as portable when it is designed to be moveable and has no connections affixing the tank to one location. Truck bed tanks and skid tanks are two examples of portable tanks. Portable petroleum storage tanks and containers do not need to be registered with the NYS DEC but must still be properly handled while at the University. Portable tanks and containers with a capacity of 55 gallons or greater that are used or stored in areas with an oil SPCC Plan (i.e. Main Campus and Ainsley Drive facilities) must be provided with adequate secondary containment. As a recommended practice, portable tanks less than (fifty-five) 55 gallons or larger tanks in areas without an oil SPCC Plan should also be provided with an adequate form of secondary containment where feasible. All portable tanks must be transported in compliance with all Department of Transportation (DOT) requirements.

    The SU Spill Response protocol must be followed for any petroleum spill at the University (See Section VIII). If there is a petroleum spill of any quantity associated with portable tanks, containers, or temporary tanks, the EHO must be contacted immediately.

    SU Safety should be contacted at X-5474 for additional Fire and Safety matters concerning temporary tanks and portable containers.

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    Last Modified: September 01, 2005