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Underground Storage Tank Update Small Business & Local Government Assistance. Brian Christian Andy Gardner Division Director Section Manager. SBLGA Offers:. Technical Compliance Assistance One to One Help Compliance Tools Free & Confidential. SBLGA PROGRAMS.

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underground storage tank update small business local government assistance

Underground Storage Tank UpdateSmall Business & Local Government Assistance

Brian Christian Andy Gardner

Division Director Section Manager

sblga offers
SBLGA Offers:
  • Technical Compliance Assistance
  • One to One Help
  • Compliance Tools
  • Free & Confidential
sblga programs
SBLGA PROGRAMS
  • Site Visit Program
  • Regional Staff
  • Advisory and Advocacy Groups
  • The Advocate Newsletter
site visit program
Site Visit Program
  • Free to Business Owner
  • Conducted by contractor hired by the SBLGA Section
  • Completes a 62 point checklist
  • Owner receives a report – Enforcement does not
getting help
Getting Help
  • Hotline
    • 1-800-447-2827
    • M-F 8:00am-5:00pm
  • www.TexasEnviroHelp.org
  • Office & Site Visits
sblga local staff available map of tceq regions
SBLGA: Local Staff Availablemap of TCEQ regions
  • We have Staff available to assist in each of the 16 TCEQ Regions
  • Publication GI-002A has contact information for our region staff
enviromentor program
EnviroMentor Program
  • Technical Assistance
  • Volunteer Professionals
    • Consultants
    • Engineers
    • Lawyers
    • Operators
information resources
Information Resources
  • The Advocate
  • Rule Change Outreach
  • Compliance Initiatives
  • Workshops & Seminars
  • Online & Print Publications
ust current events
UST Current Events
  • Federal UST rule changes
  • Operator Training
  • 3 year inspection cycle
  • Common violations
  • Penalty calculations
  • Stage I & II rule changes
40 cfr part 280
40 CFR Part 280
  • Rule changes proposed in Nov 2011
  • Comment period closed in Apr 2012
  • No news from EPA on when rules will be effective
  • Keep watching EPA & TCEQ websites for updates
operator training
Operator Training
  • Deadline August 8, 2012
  • Training offered on-line
  • Registration letters
  • Make sure TCEQ knows you took the training
3 year inspection cycle
3 Year Inspection cycle
  • Best option is to be in compliance before the investigation
  • Sign up for a site visit before the next investigation
common violations
Common Violations
  • Not doing Inventory Control
  • No proof of tank test results – broken printer
  • No corrosion protection in sumps with water
  • No 3 year cathodic protection test
  • No documentation of tank material
  • No overfill documentation
  • No records
clean and dry
Clean and Dry

Flexible Connector

spill containment
Spill Containment

60 Day Inspection:

    • Removal liquid & debris in 96 hours
    • Document proper disposal of liquid & debris
    • Keep a log sheet to verify
  • Spill bucket & lids must be liquid tight
overfill documentation
Overfill Documentation
  • Visual Verification
  • Original Installation Records
  • 3rd Party Contractor
    • Photographs
    • Letter from 3rd party contractor
delivery certificate
Delivery Certificate
  • Current Delivery Certificate
  • Required to be renewed every 12 months, or within 30 days of change of ownership
  • Penalty for receiving motor fuel without current, valid delivery certificate isup to $500 per fuel drop
penalty calculations
Penalty Calculations
  • Many factors
    • Amount of throughput
    • Compliance History
    • Avoided Costs
    • Good faith reduction (25%)
    • Deferral for agreed order (20%)
stage ii vapor recovery
Stage II Vapor Recovery
  • ORVR declared to be in widespread use by EPA
  • Texas rules are finalized and decommissioning may begin on May 16th!
  • Deadline for removal is August 31, 2018
  • Decommissioning Procedures
stage ii vapor recovery1
Stage II Vapor Recovery
  • Notification required
    • Form 20689 – available on agency websites
    • 30 days prior to decommissioning AND
    • 24 – 72 hours prior to decommissioning
  • Decommissioning completion notice within 10 days
  • FAQs on website
  • Maintain Stage II system until it’s removed – testing, maintenance, daily logs
stage i vapor recovery
Stage I Vapor Recovery
  • Rules proposed earlier this year
  • Improved consistency with federal Stage I requirements
  • Testing requirements
  • Throughput limits
  • Comments due May 12th
quick review
Quick Review
  • 3 year inspections will continue
    • Site visit can help you prepare for an investigation
  • Submit Operator training documentation
  • Watch for federal UST rule changes
  • Look at your compliance records
  • Stage II decommissioning process on website
  • Stage I comments due May 12th
how do i stay in compliance
How do I stay in Compliance?
  • RG-475 – PST Super Guide
  • SBLGA Hotline
  • SBLGA Website
  • Local SBLGA staff
  • Registered UST Contractor/Service Provider