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 Underground
Storage Tanks (UST) 1998
Tank Upgrade Requirements
Remote Fill Upgrade Requirements
This document is intended to present the
New Jersey Department of Environmental Protection’s policy
regarding the technical requirements for remote fills at
regulated underground storage tanks.
What is normally considered to be piping
associated with USTs would be the piping that takes product
from the UST to the dispenser or boiler. However, most USTs
have associated underground piping that directs product
from a tanker truck into the tanks. Most USTs have a direct
fill pipe for this purpose which is located immediately
over the UST; we are concerned here, however, with remote
fills which transfer product from some distance away from
the tank.
If they are to be regulated as any other
piping, remote fills would be required to have leak detection
and to be corrosion protected. However, leak detection for
this type of piping presents problems. This piping typically
is not double-walled, so there could be no interstitial
monitoring; it’s not under pressure, so none of the pressure
style monitoring systems are applicable; tightness testing
would not work because there is no access manway; etc. Only
SIR or some other external method (if applicable to the
site) would provide a method to monitor the “entire system”
including the remote fill. In addition, by design remote
fills are installed such that they slope towards the tank.
Similar to “safe” suction piping, if the remote fill were
to develop a hole, most of the product passing through the
piping would end up in the tank. SIR may not pick up small
releases overtime since the remote piping does not hold
product continuously.
Unlike leak detection, corrosion protection
for remote fills would be appropriate. This piping would
be considered as “routinely contain product”, and would
be in contact with the ground. (Direct fills, on the other
hand, typically have a drop tube. The drop tube is the part
of the tank system that routinely contains product, but
the drop tube is not in contact with the soil. Therefore,
direct fills with a drop tube would not require cathodic
protection.)
In summary, the DEP’s policy is that remote
fills for regulated tanks are required to have appropriate
corrosion protection; however, although leak detection using
an external monitoring method (if applicable to the site)
is prudent, it will not be required. This policy is consistent
with EPA’s position that leak detection is not required
for fill pipes. EPA took this position, in part, to give
the UST owner and operator maximum flexibility to select
a leak detection method to monitor the UST system.
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