Underground Storage Tank Management Program | The University of Chicago Environmental Health and Safety

Policy

The University of Chicago shall operate and maintain all underground storage tank systems (“UST systems”) in accordance with regulations promulgated by the Environmental Protection Agency (EPA), the Illinois Office of the State Fire Marshall (OSFM), and the Chicago Department of Public Health (CDPH) to prevent the release of a regulated substance.

Applicability

This policy applies to UST systems located on the University of Chicago (the “University”) and University of Chicago Medicine (“UCM”) Hyde Park campuses.

Scope

The EPA defines an underground storage tank (UST) as any tank that has at least ten percent of its volume underground, including the underground piping associated with the tank. The EPA, OSFM, and CDPH UST regulations apply to tanks storing petroleum or certain hazardous chemicals except as noted below:

Tanks of 110 gallons or less capacity; or
Tanks on or above the floor of underground areas, such as basements or tunnels.

Authority and Responsibility

Environmental Health and Safety (“EHS”) is responsible for:

Facilitating the development and the updating of UST Operations and Maintenance Plans (“UST O&M Plans”) for UST systems located on the Hyde Park campuses of the University and UCM;
Coordinating tank closures and removals in conjunction with appropriate regulatory agencies;
Advising project managers on projects which may be impacted by this Policy or regulations established by the OSFM or CDPH;
Notifying regulatory agencies when regulated substances are released from UST systems;
Coordinating response to suspected and confirmed releases of regulated substances from UST systems;
Investigating confirmed releases of regulated substances from UST systems;
Performing periodic audits to ensure all inspections and maintenance are being completed as required per the OSFM;
Facilitating UST operator training and tracking compliance;
Monitoring UST regulations for changes or updates which may impact the University’s UST operations; and
Accompanying inspectors from the OSFM or CDPH while onsite.

University of Chicago Police Department (“UCPD”) is responsible for the following:

Paging the EHS On-call Officer when notified about releases from UST systems.

Facilities Services and Physical Plant are responsible for:

Understanding and complying with the requirements of the UST O&M Plans;
Performing monthly inspections as required by the UST O&M Plans;
Arranging for contractors who are licensed by the OSFM to perform: maintenance and repairs; testing and inspections as required by the UST O&M Plan; and investigations of suspected releases;
Maintaining printed copies of inspection and maintenance records on site;
Maintaining printed copies of UST system design and specification onsite;
Providing electronic copies of records required by the UST O&M Plan to EHS;
Designating Class A, Class B, and Class C operators for each UST system;
Ensuring that employees designated as Class A, Class B, and/or Class C operators complete required UST operator training;
Immediately notifying UCPD of spills, leaks, or suspected releases from UST systems; and
Immediately notifying EHS when inspectors from the OSFM or CDPH arrive onsite to inspect UST systems.

Project Managers are responsible for:

Notifying EHS about projects which involve disturbing soil or the installation, modification, or removal of UST systems;
Confirming the presence or absence of a UST system before commencing with construction activities that will disturb soil;
Ensuring all areas where soil will be impacted are accessible when scheduling sub-surface surveys to identify the presence of UST systems;
Ensuring only contractors who are licensed by the OSFM will perform work on UST systems;
Scheduling removals of UST systems which may be impacted by project activities; and
Financing the removal of UST systems, including costs associated with site assessments and remediation/disposal of soil contaminated by releases from UST systems.

UST Operations and Maintenance Plans

As required by 41 IAC Part 176.655, a UST O&M Plan is required for each UST system to identify the routine procedures and inspections to ensure UST systems operate properly.

UST O&M Plan Contents

The UST O&M Plans will be specific to each UST and will contain the following information:

Training requirements;
UST equipment and components;
Regulatory requirements for the UST and its associated components;
Inspection and recordkeeping requirements;
Best management practices; and
Emergency and non-emergency procedures.

UST O&M Plan Updates

The UST O&M Plans will be updated:

Every three years; or
Any time there is a change to UST regulations or modifications of the UST system.

UST Operator Training

UST Operator Designations

As defined by the OSFM, there are three (3) classes of UST operators:

Class A operators are employees with primary responsibility to operate and maintain a UST system;
Class B operators are employees who implement the requirements of the UST O&M Plan; and
Class C operators are employees who are responsible for responding to alarms or other indications of emergencies caused by spills or releases of UST systems.

At least one of each operator class must be designated for each UST system, and employees may be designated for multiple classes of operators.

Training Requirements

The minimum training requirements for employees involved in the operation of UST systems are:

Supervisors with direct reports who maintain and operate UST systems must complete Class A operator training;
Employees who maintain and operate UST systems must complete Class B and Class C operator training; and
Employees who may respond to spills or releases from UST systems must complete Class C operator training.

In most cases, EHS will recommend Class A, B, and C Operator training for all employees involved with the implementation of the UST O&M Plan.

The content and examinations used to train UST operators must be approved by the OSFM. EHS will identify third-party providers who have OSFM-approved training materials.

Training Frequency

The initial training requirements are:

Employees who will be designated as Class A and/or Class B Operators must complete training within 30 days of assuming operations and maintenance responsibilities for a UST system; and
Employees who will be designated as Class C Operators must complete training prior to being assigned responsibility for spill and release response.

Retraining is required for UST Operators every four years and within 60 days of the issuance of a Notice of Violation from the OSFM.

EHS will maintain the following training records:

A list of employees designated as Class A, Class B, and/or Class C Operators; and
Copies of training certificates for each active UST Operator for the duration of their employment.

Operations and Maintenance

Operator Inspections and Checks

The following will be performed by the Class A or B operator for each UST system:

Class A or Class B daily and weekly checks;
Monitoring of monthly leak detection system tests (currently, all University and UCM UST systems are equipped with Veeder -Root leak detection systems);
Class A or Class B Operator 30-Day Walkthrough Inspections; and
Recording impressed current system readings in a monthly log (when specified by the UST O&M Plan).

Periodic Equipment Testing and Inspections

The following annual and triennial maintenance activities will be performed by contractors licensed by the OSFM:

Annual Walkthrough Inspection
Annual Line Pressure Test (if applicable)
Annual Leak Detector Test
Annual Sensor Testing
Annual Emergency Shut-Off Switch Testing
Triennial Spill Bucket Containment Testing
Triennial Overfill Prevention Equipment Inspection
Triennial Piping Containment Sump Testing
Triennial Stage 1 & 2 Testing- PV Vent Cap & Static Pressure (if applicable)
Triennial Stage 2 Certification (if applicable)
Triennial Annual Anode Testing (if applicable)

Recordkeeping

To ensure compliance with the OSFM regulations, printed copies of all applicable required operator inspections/ checks and all periodic equipment testing/ inspections must be maintained at each location of a UST system. These records must be kept on-site for at least two (2) years or include the last two recorded tests for all triennially required tests.

Electronic copies of these records must also be submitted to EHS for permanent recordkeeping. Instructions for submitting electronic records to EHS are provided in the UST O&M Manuals.

The respective work tracking systems for Facilities Services and Physical Plant will be used to document the completion of monthly inspections. Separate work requests must be generated whenever deficiencies are found during the monthly inspection.

Projects

Project Design Phase

Project managers should complete the Project Planning and Design Review Checklist and notify EHS when the project scope includes:

Activities that will disturb the soil, such as excavations; and
Removals, installations, upgrades, or repairs of UST systems.

EHS will advise the project manager on the CDPH and OSFM regulations that apply to these construction activities.

Environmental Site Assessments

Soil contamination can occur when regulated substances are released after a UST is inadvertently struck during construction activities, such as excavations. To prevent releases from UST systems, an environmental site assessment (ESA) must be completed prior to construction activities that will disturb the soil to confirm the absence or presence of UST systems at the project site (see Environmental Assessment of Real Estate Transfers for further information).

UST Systems which are present must be addressed prior to commencing construction activities.

Removal of UST Systems

When the project scope includes the removal of UST systems:

Removals of UST systems must be coordinated with the CDPH;
Environmental consultants will be hired to oversee UST system removals to ensure work is completed in compliance with CDPH and OSFM regulations;
Environmental contractors who are licensed by the OSFM will perform the UST removals and obtain and submit the appropriate OSFM and CDPH permits and notifications;
Soil remediation will be required if the soil surrounding the UST system is found to be contaminated with the contents of the UST (see Soil Remediation section);
EHS will assist project managers in selecting environmental consultants and environmental contractors; and
All costs associated with the removal of UST systems, including soil remediation, will be the responsibility of the project.

Installation, Upgrades, and Repairs of UST Systems

UST systems must meet the performance standards for tank fabrication, corrosion protection, spill and overfill prevention equipment, operation, and release detection equipment described in 41 IAC, Part 175. Employees must not operate the UST System if any of the performance standards are not met.

When the project scope includes installation or modification of UST systems:

Installation of UST systems must be coordinated with the CDPH; and
Contractors installing, upgrading, or repairing UST systems must be licensed by the OSFM and obtain and submit the appropriate OSFM and CDPH permits and notifications prior to commencing work.

Note: Installations or modifications of UST systems may require further permitting as described in the Title V Air Permit Policy.

Release Notification and Investigation

Above-Ground Releases

Examples of above-ground releases from UST systems include:

Spills during deliveries;
Overfills and spills when dispensing fuel to vehicles; and
Leaks from above-ground components of the UST system.

Immediately report above-ground releases from a UST system to the UCPD by calling 773.702.8181 or 123 to ensure EHS is paged.

Only employees who have completed Class C operator training are authorized to respond to above-ground releases from UST systems (please refer to the UST O&M Plan for specific spill response procedures).

Suspected Underground Releases

The following are signs of suspected releases from the underground components of a UST system:

Failing results of a monthly Veeder Root test;
Presence of product or vapors in soils, basements, sewer or utility lines, or nearby surface water;
Erratic behavior of dispensing equipment;
Sudden loss of product from the UST;
Dead vegetation, such as grass or bushes, located around the UST system; or
Unexplained presence of water in the UST.

Immediately report suspected releases to the UCPD by calling 773.702.8181 or 123 and ask for EHS to be paged.

Notifications to Regulatory Agencies

EHS shall notify the appropriate regulating agencies upon discovery of a suspected release from UST systems.

Within seven (7) calendar days of the discovery of the suspected release, EHS will submit follow-up communications to the appropriate regulating agencies to provide updated information and results of investigations.

Investigation

All suspected releases will be investigated to confirm the presence or absence of a suspected release from the underground components of a UST system:

EHS will lead and coordinate investigation efforts;
Investigations of suspected releases may consist of tank and line tightness testing and/or site assessments;
Tank and line tightness testing must be performed by a contractor licensed by the OSFM;
If the tank and line tightness test results indicate a leak exists, then the appropriate repairs must be immediately initiated to address the leak, and a site assessment must be conducted;
Site assessments must be performed by an Illinois-licensed Professional Engineer (PE) or Professional Geologist (PG);
The department operating the UST system, Facilities Services or Physical Plant, will arrange for tank/line tightness testing when required;
EHS will assist the operating department or project manager in arranging for an environmental consultant to conduct site assessments when required;
The operating department will be responsible for scheduling and funding tank/line tightness testing and site assessments and providing access to the UST systems; and
EHS will submit required follow-up communications with regulatory agencies.

Soil Remediation

A corrective action plan must be developed when the presence of suspected releases are confirmed, or soil contamination is found during UST removals:

The corrective action plan will consist of short-term actions to prevent the spread of soil contamination and long-term soil remediation, such as the treatment or removal and disposal of contaminated soil;
EHS will assist the operating department or project manager in arranging for an environmental consultant to develop and oversee the implementation of the corrective action plan;
The department operating the UST system or the project manager assigned to the project will be responsible for scheduling and funding the remediation of soil from UST in operation; and
Soil remediation performed in conjunction with removals of UST systems will be the responsibility of the project.

Closure of Underground Storage Tanks

Contact EHS prior to closure (permanent or temporary) or removal of any underground storage tank. EHS shall support Project Managers with tank closures and removals to ensure these activities will be completed in compliance with EPA, OSFM, and CDPH regulations.

Note: Project Managers will be responsible for coordinating the disposal of UST system contents. Please refer to the Hazardous Waste Disposal Procedures policy for further information. EHS will sign all manifests for contaminated soils transported to permitted facilities.

Reviewed: September 2024