Missouri A/B/C Tank Operators

Missouri’s new UST operator training rule requires that persons with responsibility for the proper operation of USTs and for responding to emergencies and leaks be properly trained by July 1, 2016. When you want to learn about requirements for USTs in Missouri, you’re going to want to read the

Rules of Department of Natural Resources

Division 26—Petroleum and Hazardous Substance Storage Tanks

Chapter 2—Underground Storage Tanks—Technical Regulations


To be a Qualified Class A/B Operator, an individual must:

  • Be certified as a Class A or Class A/B Operator in one (1) of the following states: Arkansas, Oklahoma, Kansas, Iowa, Illinois, Kentucky, or Tennessee; or
  • Pass a test offered by the Petroleum Storage Tank Insurance Fund Board of Trustees, which shall be available via the Internet at no cost to UST owners and operators.

To be a Qualified Class C Operator, an individual must:

  • Be certified as a Class C Operator in Arkansas, Oklahoma, Kansas, Iowa, Illinois, Kentucky, or Tennessee;
  • Be trained by a Qualified Class A/B Operator; or
  • Pass a test offered by the Petroleum Storage Tank Insurance Fund Board of Trustees, which shall be available via the Internet at no cost to UST owners and operators.

Training of certified A/B and C operators must be completed by July 1, 2016.   The MO operator training program is now on-line:  http://www.pstif.org/ust_operator_training.html Free web-based courses and tests are available for you http://optraining.pstif.org/intro/

EPA UST Office Address Change

Effective January 19, 2016, EPA’s Office of Underground Storage Tanks will be located in the Ronald Reagan Building, which is part of the Federal Triangle Complex in Washington, D.C.

EPA’s Office of Underground Storage Tanks (OUST) has moved from its Arlington, Virginia location to the Ronald Reagan Building in Washington, D.C. The new address: Office of Underground Storage Tanks, US EPA, 1200 Pennsylvania Avenue, NW, Mail Code 5401R, Washington, D.C. 20460.  The email addresses of the OUST staff and UST website www.epa.gov/ust, remain the same. You can access OUST employee’s phone numbers through the headquarters contact section on the OUST website http://www.epa.gov/ust/underground-storage-tank-ust-contacts .

Self-Serve Now an Option at Gas Stations in Oregon

Low Population Oregon Counties Allowed Self-Serve Dispensers Overnight

Consumers can purchase gas from 6pm-6am on a self-serve basis

Beginning this year, gas stations in Oregon counties with populations less than 40,000 people are allowed to provide self-serve dispensers, but only between 6 p.m. and 6 a.m. The population threshold included in the new law is set at a level that includes half of all Oregon counties, including most of the counties east of the Cascades. No counties along Interstate 5 are small enough to qualify. Oregon lawmakers approved the measure after hearing from gas station owners in rural areas who said they couldn’t find enough employees to staff their stations overnight. New Jersey is the only other state to ban self-service dispensing of motor fuel.

The legislation, sponsored by State Rep. Cliff Bentz (R-Ontario) and Ted Ferrioli (R-John Day), is intended to make it easier for Oregon drivers to fuel up their cars during after-hours periods in rural stretches of the state, particularly the Southeastern region. The Oregon Senate passed the bill by a vote of 25-5 and Gov. Kate Brown signed the bill into law in June.

See more at:




Oklahoma Corporation Commission Proposed Rules Adopted

Oklahoma Corporation CommissionProposed rules governing fuel inspection, underground storage tanks, aboveground storage tanks, tank indemnity funds and corrective action were adopted February 3 by the Oklahoma Corporation Commission en banc. The proposed rules and related documents pertaining to the rulemakings may be downloaded from the Commission’s website. For quick reference, see the links below:


RM 201500005, CH 15, Fuel Inspection

RM 201500006, CH 25, Underground Storage Tanks

RM 201500007, CH 26, Aboveground Storage Tanks

RM 201500008, CH 27, Indemnity Fund

RM 201500009, CH 29, Corrective Action of Petroleum Storage Tank Releases

PEI Response to RP900 Public Comments

PEI is the leading authority for fuel and fluid handling equipment.

PEI’s Underground Storage Tank (UST) System Inspection and Maintenance Committee met earlier this month and acted on 98 public comments offered to update PEI’s Recommended Practices for the Inspection and Maintenance of UST Systems (PEI/RP900)

Many of the comments were accepted in one form or another. A few suggestions that were not incorporated into RP900 are also of some significance to users of the document.

Here is a summary:

  • The scope of the recommended practice was NOT expanded to include UST systems and associated equipment other than that used to store and dispense gasoline, diesel and related petroleum products at vehicle fueling facilities. In other words, the document is not intended to apply to marinas, aviation-fueling facilities, farms, emergency generators, etc. The committee did broaden the scope to include the shear valve.
  • The Committee recognized that, in many instances, the new federal inspection requirements that became effective October 13, 2015, were less comprehensive than the inspection practices contained in the 2008 edition of RP900. After reviewing all the inspection requirements of the federal rule, the Committee revised the document to meet or exceed the walkthrough inspection requirements and frequencies contained in the federal regulations. In a few instances, the Committee included recommended procedures for walkthrough inspections in the document that were not included in the federal rule. The Committee also rejected several proposals to increase the frequency of some inspections (e.g., spill bucket drain valves, interstitial space of drain valves).
  • A number of comments dealt with water and the quality of fuel in the UST. The Committee made a few tweaks to Section that now requires the owner to check to see if water is present and, if found, to notify the appropriate person in the company. Section also will direct the owner to a new appendix that will discuss water issues and suggest strategies to keep water out of the tank. The appendix will be available for public review and comment before it is included in the 2016 edition of RP900.
  • All of the testing requirements contained in RP900 were removed from the document and will be considered for inclusion in PEI’s Recommended Practices for the Testing and Verification of Spill, Overfill, Leak Detection and Secondary Containment Equipment at UST Facilities (PEI/RP1200). By this action, the Committee opted to provide one document to use for walkthrough inspections of UST systems (RP900) and another to test the equipment and verify it is working properly (RP1200). As a result of this decision, both RP900 and RP1200 will be released simultaneously, probably sometime this summer.

TAIT’s Dallas Office Keeps Growing

Please join me in welcoming our new Associates in the Texas office!

Shane Cameron, Training & Project Coordinator

Shane joins TES in Texas as a Training and Project Coordinator. Shane is awesome and spends his off time in a band called Sunrise Pilots.

Miguel Vazquez, Petroleum Storage Tank Technician.

Miguel joins TES in Texas as an entry level technician. Miguel is married with two little girls, the youngest is now 3 months old!

Kevin Allen, Sr. Project Manager

Kevin joins TES in Texas as a Sr. Project Manager with 15 years of environmental experience. See Kevin with his youngest daughter in the photo attached. He also has an older daughter and he attributes both of his daughters’ good looks to his wife!

Paul Morgan, Project Coordinator

Paul started in our TX office this morning as a Project Coordinator.  He’s originally from Long Island, NY and has been in Dallas for 20 years with his girlfriend Dianna and 3 dogs. He considers himself a huge NY Yankees and Pittsburgh Steelers fan. He likes to visit Los Angeles and NY as much as possible for the beach.

Dustyn Kilborn, Petroleum Storage Tank Technician

Dustyn joins TES in Texas as an entry level technician and starts his first day today!

Welcome to the TAIT Team!

Dallas Employee Bios


 Andy Tait (Director, Texas)

Andrew “Andy” Tait is a Texas-licensed Professional Environmental Engineer and is the TAIT Operations Manager for Texas. He brings over 25 years of experience in environmental consulting including municipal clients as a project manager, engineer, and business resource manager. Andy has expertise in a diverse array of project and is proficient in a wide range of remedial technologies including soil vapor extraction, groundwater pump and treatment, in-site bio-degradation, and excavation. He has diverse civil and environmental consulting experience and is the Director of our UST Training Services.  He has successfully converted a classroom training of UST operators to an online, e-commerce system to meet the needs of the 2005 UST Energy Policy Act operator training provisions, and also has tracked the development of UST operator training and inspection rules on a state-by-state basis for his clients. With his extensive experience with remedial investigations of hazardous waste sites, performance of feasibility studies, cost estimation, corrective measure studies, and design and construction of remedial systems for hazardous waste sites, he managed subsurface site investigation and remediation projects from initial site assessment through completion of remedial activities to successful site closure.  Mr. Tait has hands-on experience with environmental, health, and safety compliance, including Spill Prevention, Control and Countermeasure Plans (SPCC) and Storm-water Pollution Prevention Plans (SWPPP).

Matt Denison (Director of Operations )

TAIT’s Non-Engineering Environmental Services program for the City of Dallas will be supported by Mr. Matt Denison who is the Director of Operations for TAIT.  Mr. Denison brings to the City over 13 years’ experience managing large-scale compliance programs for complex organizations.  Mr. Denison has successfully managed multiple environmental programs, including but not limited a Fortune 10 Telecom Company and a Fortune 500 Real Estate Holdings Company.

Melanie Nelson (Business Development Manager)

Mrs. Nelson develops relationships with TAIT clients and is a program point of contact to clients for TAIT and brings over 7 years of working with environmental consulting specializing in USTs to the group. She has extensive practical experience in people and project management of a variety of heavily regulated, compliance driven industries. She also has expertise in Microsoft SharePoint architecture and UST Operator Training and is skilled in the field of photographic construction documentation services. Mrs. Nelson is the Business Development Manager at TAIT Environmental Services and is a Certified Environmental and Safety Compliance Officer (CSEM), Associate Environmental Professional (AEP) and Certified Safety Environmental and Emergency Manager (CESCO).  She also assists in communications with clients and internally works as a business resource manager.

Key Personnel

Bill Duree (Fuel System Designer)

Mr. Duree has been working in the design and engineering business since 1973 and has been working for TAIT since 1984. He has experience in anything that involves fueling motor vehicles, aircraft, emergency generators and locomotives, as well as some construction management & business development/marketing. He has a hands-on, working knowledge of the operations and maintenance requirements of the latest equipment used in petroleum storage and distribution systems, including spill containment fill boxes, containment sumps, overfill prevention devices, tank monitoring systems, underground and aboveground storage tanks, pumps, dispensers, vapor recovery systems, fuel management systems, and fiberglass and flexible piping systems. ** Bill is lauded across the industry for his attention to detail in his designs such as drawing to scale all the components in a UST sump. He is a hands-on mechanically inclined person resulting in his having a mechanical understanding of how the components work together as well as head logic/knowledge that make him an ideal resource for any fueling system designs needed.

Key Field Personnel – Construction Managers / Technicians / Others

Robert Kimberlin

Tim Norman

Mr. Norman has been working in the environmental industry for municipalities, private and public companies since 1978. After working alongside TAIT over that time, he joined the company as a full time employee and has been an Environmental Technician at TAIT for the last few years. His breadth of experience in the industry spans all aspects of petroleum fuel tank work, from installation through maintenance, including removal. He is a licensed A and B installer/remover and is also certified as a UST AB Operator.

Eric Durham

Eric Durham has been employed by TAIT Environmental Services for 12 years performing multiple UST services focusing on compliance testing and repairs of USTs for both municipal and private clients. His years of hands-on experience performing inspections, conducting testing events, making repairs to UST systems, and installing UST components have allowed him to develop into a well-rounded technician skilled in all aspects of field UST work. Mr. Durham has a plethora of manufacturing-specific certifications as well as ICC & state certifications.

**States we do work in – perhaps list by person? can do fuel design in all 50, etc.

Renewal of Texas Industrial Stormwater Permit

TCEQ is in the process of renewing the TPDES Multi-Sector General Permit for industrial facilities, TXR050000[3], which expires August 14, 2016. A public meeting will be held on November 16, 2015.

A quick synopsis of the changes include:

  •  Changed the Standard Industrial Classification (SIC) code to clarify what facilities are regulated under the general permit.

  •  Added narrative and numeric effluent limitations guidelines for airport and airplane deicing operations.

  •  Changes to benchmark values and sampling.

  •  Added SIC code 7699 to Sector R.

  •  Clarified permit language in Part V, Sector P, pertaining to the storage of crude oil.

  •  Clarified permit language in Part V, Sector I (Oil and Gas Extraction Facilities) when facilities qualify for permit coverage under the EPA NPDES permit, or when they qualify under the MSGP.

  •  Clarified permit language in Part II, Section C.1(a) for above ground storage tanks (ASTs) requirements.

  •  Added language to Part III, Section D.1 (c) to clarify how permittees should document zero rainfall totals, or no rain for sampling requirements.

  • Added clarification to the section “Impaired Water Bodies and Total Maximum Daily Load Requirements” to address when discharges are considered discharging to an impaired water body.
  • Draft permit was similarly revised to clarify that an applicant who owns or operates a facility classified as an “unsatisfactory performer” is entitled to a hearing before the commission prior to denial or suspension of authorization.

You can view the full permit at: http://www.tceq.state.tx.us/assets/public/permitting/stormwater/txr050000_factsheet.pdf

Written public comments must be received by 5:00 p.m. on November 16, 2015 and may be submitted to:
Office of the Chief Clerk (MC 105)
P.O. Box 13087
Austin, TX 78711-3087
Or electronically

UST Secondary Containment and Interstitial Monitoring Requirements

Are you responsible for ensuring site or corporate environmental compliance or for implementing a site environmental management system that includes fueling systems? Whether you’re an environmental manager, a plant engineer, plant/general manager, facility manager, site manager or other role, if you’re involved with underground fuel storage tanks, the new rules regarding secondary containment should be of interest.

Federal UST Secondary Containment and Interstitial Monitoring Requirements

The 1988 requirement and criteria required secondary containment and interstitial monitoring for hazardous substance tanks only (280.42). The EPA is implementing secondary containment with interstitial monitoring and under-dispenser containment (UDC) as additional measures to protect groundwater. States that have already implemented secondary containment regulations that meet or exceed the federal regulations will not have to change their requirements. There are significant changes to the federal requirements and implementation which are summarized below. The implementation timeframe for secondary containment is 180 days. States with approved programs still have three years to reapply, and depending on which state you are in, you may still be governed by the state program rather than the EPA regulations.

Owners and operators are required to install tank and piping secondary containment that will contain regulated substances leaked from the primary containment until they are detected and removed and that will prevent the release of regulated substances to the environment at any time during the operational life of the UST system, and must be  monitored for leaks at least once every 30 days using interstitial monitoring.


Owners and operators are now required to install secondary containment and interstitial monitoring for ALL (including petroleum) new and replaced tanks and piping. There are still some exceptions like safe suction piping and piping associated with field-constructed tanks over 50k gallons, and airport hydrant systems.


Owners and operators must replace the entire piping run when 50% or more of the piping (excluding connectors) is removed and other piping is installed.


All new dispensers need to have under-dispenser containment.

Interstitial Monitoring

Interstitial Monitoring of new and replaced secondarily contained tanks and piping must occur at least once every 30 days as a release detection requirement.

The EPA reviewed data from release sites and the higher number of releases from single walled tanks and piping when compared to secondarily contained systems was considered in the decision for new requirements to prevent regulated substances from reaching the environment and ensure a consistent level of environmental protection for regulated USTs across the USA.


Fueling System Compliance Violations

What happens when your fueling systems are out of compliance? Sometimes they leak. Often Notices of Violations (NOVs) will be given and fines may be assessed. Below are two examples recently shared by the Petroleum Equipment Institute (PEI), one from Texas – regulated by the TCEQ and one from California – regulated by the California State Resources Board (and individual CUPAs throughout the state). The PEI Convention at the NACS Show is coming up this October in Las Vegas, NV. TAIT will be there and will have a booth #7012 . Stop by and see us or contact us to learn more about keeping your fuel system in compliance. We have been working with fueling systems for over 50 years as a consultant and contractor and can answer questions and offer trusted advice on your particular situation.
TheTulsaLetter is the official newsletter of PEI and focuses on industry and association news. Regularly published by PEI since 1951, the TulsaLetter is relied upon by industry insiders for the latest information and updates on state and federal regulations, equipment standards, industry trends and personnel changes.
From PEI’s Newsletter:

Nicholas Petroleum, Inc.
learned of a possible leak in 2006, when the Texas Commission on Environmental Quality (TCEQ) asked the company to inspect its underground gasoline tanks (USTs) after reports of subsurface contamination. The company conducted the initial environmental investigation—but not the subsurface assessment TCEQ requested—and it ignored further inquiries by the agency until 2008, when a TCEQ inspector located a leak in an unleaded gasoline line. At the agency’s direction, Nicholas then hired a licensed contractor to investigate the release, and well water samples confirmed the contamination. TCEQ formally advised Nicholas on February 5, 2009, that it was a potential responsible party (PRP). Nicholas filed a claim with its insurance company, Mid-Continent Casualty. Co., Inc., on April 10, 2009, and the insurer denied it. Mid-Continent cited a provision in its policy stating that the insured had 30 days after receipt of the claim from TCEQ for filing a written claim with Mid-Continent, and that Nicholas had failed to do so.A Texas appeals court held that contracts must be enforced as written, and the notice requirement in the policy trumped the fact that Mid-Continent admittedly suffered no prejudice by the late filing.
The San Francisco Municipal Transportation Agency
negotiated a $1.35 million agreement to resolve alleged UST violations at four facilities, the California State Water Resources Board said July 27. Specific allegations accused the transportation agency of failing to ensure monthly inspections and testing of various equipment; recordkeeping failures; failure to adequately maintain spill containment systems and equip USTs with overfill protection; and making false statements to authorities. The settlement requires the agency to pay $425,000 in penalties and $100,000 for reimbursement of enforcement costs. State officials agreed to suspend $850,000 in penalties and other payments if, over the next five years, the agency completes several enhanced compliance projects and remains in compliance with the laws and terms of the final consent judgment.