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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.