Synergy Environmental, Inc.
Robert J. May, PE, CHMM

May 6, 2015

NJDEP recently published proposed rule changes concerning underground storage tanks (USTs). These proposed rules were published in the New Jersey Register on May 04, 2015. Comments are requested by July 03, 2015 providing a 60 day comment period.

In general, the proposed regulations are implementing requirements and guidelines by USEPA.

The most significant proposed changes are:

• Under-dispensing containment systems must be inspected every 30 days for the presence of water and or product.
• All spill prevention equipment such as spill buckets must be tested every 12 months using vacuum, pressure or liquid testing within the first year of the adopted regulations.
• The electronic and mechanical components of the UST system such as the Automatic Tank Monitor (ATM), probes, sensors, line leak detectors must be tested annually starting with 12 months of the rules being adopted.
• UST owners must have training providing Class A, B and C Operators. NJDEP will determine if Class A or B certification from another state (such as PA which has had the training for the last three years) is reciprocal. The Class C Operator must be trained by the Class A or B Operator. The Class A or B Operator must conduct a walk through inspection of the UST system at least once every 30 days reviewing spill detection and prevention equipment is working properly.

Currently UST systems used to store motor fuels for emergency power generator do not have to comply with release detection monitoring. The proposed regulations required the monitoring with 3 years after the adoption of the new regulations.

All new tanks and piping must have secondary containment and interstitial monitoring but European (safe) suction piping will still be exempt.

Overfill devices restricting the vent lines, “ball floats”, will need to be replaced to another overfill device within 3 years. All overfill prevention devices must be tested once every 3 years.

NJDEP has also proposed new monetary penalties for violations.

Many of these regulations mirror regulations including the 30 day visual inspection in states such as Tennessee, Florida & Massachusetts.

Synergy Environmental stewards and performs these inspections for several of our clients in these states.

Robert May is a Senior Engineer with Synergy Environmental, Inc. As Director of Compliance, Bob’s group provides monitoring and compliance reporting for over 700 gas stations nationwide. He also provides Class A, B & C Underground Storage Tank Operator Training.