NYS Department of Environmental Conservation petroleum bulk storage requirements - by Nathan Edeson

Most if not all building owners who have oil heat in New York City are aware of the fact that they must have a combustible material bulk storage permit from the FDNY. What some are not aware is that the NYS Department of Environmental Conservation (NYS DEC) requires that all bulk storage tanks (above and below ground) be registered over 1,100 gallons in volume. There are currently several thousand facilities in the five boroughs listed on the NYS bulk storage database as active whose bulk storage tank registrations have expired. DEC inspectors have conducted inspections of premises whose addresses are on the database and issued notices of violation for those with expired registrations. If the notices are ignored, the DEC has initiated administrative enforcement proceedings against building owners seeking penalties in the thousands of dollars depending on the number of violations cited. What should I do? If you own or manage a building with a petroleum bulk storage tank, verify that it is currently registered and that the registration is active. One can do this by either looking for the registration certificate which should be mounted at or near the tank or checking the location on the NYS bulk storage database www.dec.ny.gov/cfmx/extapps/derexternal/index.cfm?pageid=4. If there is no registration on record, obtain the necessary form on the NYS DEC website and complete the form, send it in with the necessary fee. The form has instructions for paying fees for past due registrations. What if the tank was removed? If the tank was removed but is still listed as active on the NYS bulk storage database, it is necessary to submit a revised registration form indicating that the tank was removed. Documentation should be kept on file as to the fact that all petroleum was removed and the interior of the tank cleaned and rendered gas free. For underground tanks it is necessary to sample the soil on the sides of the tank and below the tank to ensure that the tank has not leaked. If there is an indication of leakage, it is necessary to report the leak to the NYS spill hotline 800 457-7362. If no leak is detected, analytical results must be forwarded to the DEC indicating this fact along with the necessary registration revision form showing the tank was removed or closed in place. What should I do if my tank is still in use? Conduct monthly inspections of above and below ground tanks (underground tanks require leak monitoring) to verify there are no leaks. Yearly tightness tests are required for underground tanks. All tanks must have signage showing design and operating capacity and type of oil being stored. Furthermore the fill port must be marked depending on the type of oil being stored. This article summarizes the key requirements for petroleum bulk storage but is by no means complete. If you have any questions seek outside help from a competent consultant. Nathan Edeson is the principal of Nathan Edeson, PE, Brooklyn, N.Y.