Notification to Contractors and Dispensing Facility Owners/Operators
Questions have been asked regarding language in our Motor Fuel Dispensing Facilities regulations pertaining to the shear valves required under dispensers, as found at 175.450(e)(12): Shear Valve. Pressurized piping systems require a listed rigidly anchored emergency shutoff (shear) valve installed in the supply line at the base of each individual dispenser. The valve hall incorporate a fusible link or other thermally activated device, designed to close automatically in the event of severe impact or fire exposure. The questions were often in reference to the requirement for dispensing facilities found in 175.210, 175.220, 175.230, 175.240 & 175.250 that 'all shear valves (shall be) visually inspected, at least annually to ensure that they are functioning properly and that the dispenser is mounted properly" 175.210(i). Like the Emergency Shutoff Switch annual test in the same section, the annual "visual inspection" can be done by the owner/operator or a contractor so designated to perform the inspection. This Notification serves the purpose of clarifying what criteria to use to "ensure that (the shear valves) are functioning properly." These criteria match what OSFM and Chicago Dept. of Public Health UST inspectors use:
- All shear valves shall be mounted using a listed rigid anchor.
- All shear valves shall be mounted securely to the listed rigid anchor.
- All shear valves shall be mounted at the proper height relative to grade following the shear valve manufacturer's installation instructions.
- All shear valves shall be maintained in proper working condition.
- In addition, the dispensers themselves will also be inspected when the shear valves are checked to confirm that each dispenser is properly and securely mounted to its island.
This is not a change to our regulations, just a clarification of what our inspectors use to determine proper shear valve mounting and placement. To further clarify the point about placement relative to grade, as in any equipment installation, manufacturer's specifications must be followed. Most models of shear valves need to be mounted with the shear point within 1" or 1/2" of grade using the top of the dispenser island as the reference for grade. If your approved shear valve has mounting criteria outside of those common parameters, have documentation available from the manufacturer to show the inspector so he knows that the mounting is acceptable. This must be from the manufacturer. A letter from a contractor alone will not suffice.
A form has been added to UST Applications and Forms to assist you in documenting this required annual visual inspection. The completed signed form will stay with the station records for our inspectors to check during an inspection to document and verify that all shear valves have been inspected annually.
Notice to UST Contractors Posted: October 28, 2013
Since the promulgation of our current UST regulations on September 1, 2010, there has been the requirement for a hydrostatic test on all containment sump installations:
Updates at our website will be seen on the Applications & Forms page to the following forms:
A permit must be obtained for installation or repair of any containment sump, as per 175.300(f)(11)(B). If work being done on a spill sump falls under like-for-like replacement criteria, a permit is not required but a hydrostatic test is. That will require submission of a "Required Job Schedule for Testing" form, and if indicated, a 'Failed Test Results Report" form. Evidence of spill sump like-for-like replacement without the required test schedule form will be a violation.
First Notice regarding Contractor Scheduling
P&CS is wrapping up a project which includes a software application developed for licensed UST contractors to use. In this first stage, they will only be establishing on-line access with P&CS in order to schedule jobs and request Emergency Permits. The scheduling will be done electronically, with the software application allowing automatic scheduling with the correct STSS for the job location by coordinating the inspectors' schedules with the scheduling requests. We plan to build further contractor-related applications on this foundation in the near future.
Notice regarding Emergency Rules concerning USTs serving Emergency Power Generators
On April 4, 2013, emergency rules concerning USTs serving emergency power generators were filed and became effective. These rules require USTs serving emergency power generators to substitute a local alarm for the automatic shutoff or flow restriction of the fuel supply upon the detection of a release. Further information is found in the attached policy, notices, and rule documents posted below.
Notice to Facilities with Emergency Power Generators Supplied from USTs
On April 4, 2013, an Emergency Rule Change went into effect in Illinois which affects facilities with Emergency Power Generators which are supplied with fuel from underground storage tanks (USTs). Prior to that Emergency Rule Change, all USTs were required after September 1, 2010 to have interstitial monitoring sensors immediately shut off the submersible pump in pressurized piping systems or the suction pump in American suction systems. When this requirement is applied to Emergency Power Generators, though, which primarily are installed at facilities which must maintain services during power outages, such as hospitals, airports and communication centers, all power would be lost to the facility if a sensor was activated. Additionally we saw that automatic line leak detectors installed on pressurized piping could also be programmed to shut off submersible pumps if they were electronic line leak detectors, or restrict fuel flow if they were mechanical line leak detectors. Neither the pump shut off nor the flow restriction can be allowed to occur at a critical services facility maintaining operations with their Emergency Power Generator during a power outage.
Having identified the problem, we set about to correct the situation. Prior to filing the Emergency Rule Change, staff in the Division of Petroleum and Chemical Safety in the OSFM started contacting UST contractors and owners of facilities where our database showed an Emergency Power Generator had been worked on since September 1, 2010. That was the date the original regulation went into effect. This was done statewide. Language for the Emergency Rule Change was crafted by legal, technical and senior staff at OSFM and Petroleum and Chemical Safety. At the time the Emergency Rule Change was filed, notification went out by mail to all OSFM licensed contractors and the contact identified at each facility on our list, and this Notice was posted at our website. Rule Policy/Interpretation 13-PCS-001 was included with the notification letters, and was also posted at our website on the Commercial page.
Notice to Owner Operators regarding Operator Training
An August 8, 2012 deadline affecting owners/users of Underground Storage Tanks (USTs) is approaching. This deadline pertains to training requirements for the three classes of UST operators: A, B and C Operators, and derives from a federal mandate all states are required to implement. Completion of training through a course approved by the Office of the State Fire Marshal (OSFM) for the different levels of operators is required by the August 8, 2012 date, with certification to show proof of completion.
The OSFM website (www.sfm.illinois.gov) has links under Petroleum and Chemical Safety which provide specific information about this matter. Click on Petroleum and Chemical Safety and choose Operator Training to access more information, including the required components of training programs for all three classes of UST operators. This can give UST owners some insight into the issues, requirements and relative lengths of the different training programs for A, B and C operators.
The OSFM's Division of Petroleum and Chemical Safety has been working with test providers to approve training programs in anticipation of the August deadline. Ultimately, UST owners will be able to access and choose from the approved programs on the OSFM website for use with their employees. We anticipate having some providers' training programs approved and listed for UST owners to choose from before July. As additional programs are approved, they will be listed on the OSFM website. You are encouraged to check the OSFM website for updates.
OSFM Responses to Public Comment
OSFM Responses to Public Comment on Rulemaking to Consolidate, Reorganize, and Update Underground Storage Tank Rules
(Consolidating Parts 170 and 171 into new Parts 174, 175, 176, and 177
Final Regulatory Flexibility Analysis on Rulemaking to Consolidate, Reorganize, and Update Underground Storage Tank Rules
(Consolidating Parts 170 and 171 into new Parts 174, 175, 176, and 177)
Underground Storage Tank Operator Training: Industry Outreach Summary and Proposed Draft Regulations
In an effort to solicit additional industry and stakeholder comments, OSFM is posting all industry and stakeholder comments on underground storage tank Operator Training to date and the OSFM responses to these comments. OSFM is also posting the Proposed Operator Training Rules to implement Operator Training in Illinois. OSFM invites all affected parties and stakeholders to submit any additional comments before the formal rulemaking process begins. These additional comments may be submitted in the next 21 days, or by not later than June 29, 2011. Comments can be e-faxed to 217-524-9284 or mailed to OSFM, Division of Petroleum and Chemical Safety, at 1035 Stevenson Drive, Springfield, IL 62703.
- Operator Training Outreach Responsiveness Summary final draft June 2, 2011
- Operator Training Regs, Final Draft, June 9, 2011