New UST life expectancy rules for CT

The Department of Energy and Environmental Protection (DEEP) recently issued an "Approval of an Alternative Life Expectancy For Certain Underground Storage Tanks" that extends the life expectancy of some tanks to 40 years from the date of installation. Prior to this approval most USTs had a life expectancy of 30 years. USTs that have reached their 30 year anniversary 30 days before the issuance of this extension are eligible to obtain the additional 10 years of life — in other words, eligible tanks that are 30 years and 30 days old prior to June 22 may obtain the extension. Any USTs older than 30 years and 30 days do not qualify for the extended life. Below are some FAQ’s to help tank owners determine if their tanks are eligible for the extension. For more information and the forms to apply for the extension, click here . And watch for information on an upcoming CEMA seminar with presenters from DEEP who will give you all the details you need to know and answer your questions.Q1: Are composite steel, buffhide and stip3 tanks all the same:A1: Composite tanks such as Buffide are potentially eligible for the alternate life expectancy, STI-P3 are not.Buffide was a popular brand name for a type of composite steel UST. The best way for me to define a composite steel tank is the Steel Tank Institute single wall ACT 100 specification. The basic difference between the STI-P3 and ACT 100 specification is the external corrosion protection method. STI-P3 uses a dielectric coating and cathodic protection. The ACT 100 does not rely on a cathodic protection system for external corrosion protection and has a jacketed coating, usually made of fiberglass. Here's a link to the Steel Tank Institute webpage that describes the different construction standards/methods.Q2: Are STI-P3 tanks excluded? (One of our vendors interpreted the regulation as excluding all STiP3 tanks).A2: STI-P3 tanks are not eligible for an extension.Q3: For purposes of an Aquifer Protected Zone, is there a method using GPS to determine if a UST system is included in that zone?A3: Currently there is not. I have contacted our GIS and aquifer protection staff in anticipation of this. They are working on an internet map to make the determination easier. For now there are small scale maps available here Q4: Having just been informed that HO tanks are not eligible for an extension, is there any window for their removal, if they have just reached their life expectancy?A4: I'm not sure of the ask on this one. Heating oil tanks used for onsite heating can't be operated beyond their life expectancy (typically 30 years) and are not eligible for the extension. They must be properly closed (removed or abandoned properly) before they reach 30 years old.Q5: Understanding the definition of "new under-dispenser containment sump" in Section 22a-449 (d)-101 (d) of the UST regulations requires the sump contain a liquid-level sensor, does this requirement also apply when requesting an alternative life expectancy for an existing UST system.A5: Yes it does.Q6: Specifically looking for answers on which tank types qualify for extensions (example: buffhide)A6: Single wall fiberglass, double wall fiberglass, composite steel (typically a fiberglass wrapped steel tank)Q7: Is buffhide tank composite steel?A7: YesQ8: Heating oil tanks undergrounds, our understanding is they do not qualify?A8: Correct. Heating oil ust’s used for onsite heating are not eligibleQ9: Heating oil tank underground Double Wall Fiberglass with interstitial space, does this qualify?A9: No.

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