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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 .
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 126.96.36.199 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 188.8.131.52 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.
2015 Revised Underground Storage Tank Regulations
We’ve been waiting for years for the update to finally be announced, and here it is: The requirements implemented on the effective date of the final UST regulation are those that either do not require significant education and outreach or apply to new installations, repairs, or releases. EPA is allowing up to three years for owners and operators to implement the requirements that require significant outreach, equipment to be upgraded or installed (such as for previously deferred UST systems), or scheduling and testing. During those three years, the regulatory/implementing agencies shall educate owners and operators about today’s new requirements and allow owners and operators to schedule testing. The exception to implementing the requirements immediately or in three years is that EPA is implementing the secondary containment requirement 180 days after the effective date of the UST regulation.
Keep in mind, we do not have the effective date, yet. We do know it will be soon, maybe tomorrow!
Here are the Implementation Time Frames for the New Requirements in an easy to read chart – Immediately, 180 days or Three Years
9 Note that EPA is requiring owners and operators to also submit a one-time notification of existence for these UST systems within 3 years of the effective date of today’s final UST regulation.
States with Approved UST Programs are going to have to incorporate the changes to the UST technical regulations. They will have three years to reapply in order to retain their SPA status. Owners and operators in these states must continue to follow their state requirements until the state changes its requirements or until the state’s SPA status changes.
That means there will be three years grace period before we start seeing enforcement/NOVs for some of the required changes.
The owners and operators in 16 non-SPA states and territories must meet the federal requirements according to the schedule in the 2015 UST regulation. In addition, owners and operators will need to follow their state requirements. Indian country UST owners and operators must meet the federal requirements according to the schedule in the 2015 UST regulation.
Here is a Comparison that shows the 2015 Revised UST Regulations versus the 1988 UST Regulations. It’s a 10 page PDF Spreadsheet showing the highlights of the full 468 page document, called the Prepublication version of the final UST regulations. Some forms you may want to review are the New Ownership Change Notification Form and the Updated Notification Form. TAIT recommends all Owners and Operators download and read the updated MUSTs for USTs which provides a nice straightforward explanation of requirements when owning and working with underground storage tanks.
TAIT is an expert in and has been working with fueling systems and Underground Storage Tanks for over 50 years. Our Regulatory Affairs Manager Brian Harmon focuses on the regulatory environment and upcoming changes and his comments are integral to regulation changes such as this. ASK US your questions. Allow us to bid on your tank projects. Before making any quick decisions, let’s discuss your situation and your tanks and we can provide guidance on the most cost effective way to move forward to get you in compliance with the current and new regulations.
Visit the EPA’s Underground Storage Tanks 2015 Revised Underground Storage Tank Regulations page for all the details
In June 2015, EPA issued the 2015 underground storage tank regulation and the 2015 state program approval regulation. The revisions strengthen the 1988 federal underground storage tank (UST) regulations by increasing emphasis on properly operating and maintaining UST equipment. The revisions will help prevent and detect UST releases, which are a leading source of groundwater contamination. The revisions will also help ensure all USTs in the United States, including those in Indian country, meet the same minimum standards. This is the first major revision to the federal UST regulations since 1988.
Do you remember where you were 30 years ago this month when you received word that President Reagan signed amendments to the Resource Conservation and Recovery Act (RCRA)? Robert from PEI recaps UST regulation history:
Subtitle I of those amendments specifically provided for regulation of underground storage tank (UST) systems. The Environmental Protection Agency’s Office of Underground Storage Tanks (OUST) was created the following year (1985) to carry out the Congressional mandate to develop and implement a new regulatory program for USTs. It resulted in the most comprehensive regulatory program PEI members have ever participated in.
Leaking tanks became a problem before 1984. PEI predicted in 1975 that state and federal controls related to tank and piping leaks would proliferate. At about the same time, the American Petroleum Institute’s (API’s) Operations and Engineering Committee recognized that UST leaks presented a growing industry problem and formed a task force to recommend procedures for detecting and dealing with them. By 1981, less than 10 percent of all USTs in the ground were protected from corrosion.
Emphasis shifted in the early 1980s from tank regulations for safety reasons (i.e., fire codes) to regulations for protecting the environment and public health. Pressure to deal with the impact of leaking USTs on groundwater mounted when 60 Minutes aired a disturbing segment on leaking underground service station tanks. Shortly after that, Congress stepped in with the 1984 Subtitle I RCRA amendments.
There were over two million USTs in 1984. Many of them were bare steel that were corroding and leaking fuel into the ground. When President Reagan signed the law, more than 85 percent of the USTs were still made of unprotected steel. By 1988, somewhere from 10 to 48 percent of existing tanks failed a tank tightness test, depending on which study you believed. And when you consider that from 8 to 20 percent of all USTs had releases, UST regulators back then had their hands full.
The U.S. EPA’s UST program has made significant contributions to the environment during the last 30 years. The program’s accomplishments are real, and there is much that regulators and the regulated community can point to with pride.
Part of the reason this governmental program works so well after three decades is because Ron Brand and other founders of the UST program involved everyone in the process of protecting our environment from UST releases. States, territories, tribes, industry, owners/operators, service providers, equipment manufacturers and trade associations were called partners. PEI and its members were treated that way back then and continue to feel that way today. This is a unique program with unique relationships that has produced quantifiable results.
I think successful managers and leaders should continuously focus on what can be, rather than what is. And I also believe that the best leaders are always focused on improving. From the equipment and contractor side of this unique partnership—and in that spirit—this is what I see still needs to be addressed to make a great UST program even greater:
- Let’s figure out what is causing the metal components of our UST systems to corrode in the presence of ultra low sulfur diesel fuel.
- Let’s get that last 25 percent of underground tank systems in the U.S. into compliance with release prevention and leak detection requirements. That will reduce the number of newly confirmed releases.
- Let’s work together to determine why equipment is deteriorating in sumps containing ethanol and/or ethanol vapors.
- Let’s find ways to clean up the releases in the backlog before state cleanup funds sunset or are diverted.
- And let’s kick off an inspection and testing program that will identify equipment that no longer works as it was supposed to work.
Here’s to another 30 years. Let’s continue the good work.
TAIT is a longstanding member of PEI. Learn more about the Petroleum Equipment Institute and all they do by visiting their website http://www.pei.org/.
Looking for updates on the EPA UST Regulations?
We expect to hear more later this year. Here is an article that explains more. Copied from: http://pcmala.org/2014/04/epa-pushes-back-final-regulation-on-usts-to-fall-2014/ TAIT’s 50 year experience with USTs and all fuel system related regulations and work can help answer many questions for you. Reach out to us for additional information.
EPA Pushes Back Final Regulation on USTs to Fall 2014
“We consciously developed our 2011 proposed underground storage tank (UST) regulation to avoid provisions that would require costly retrofits to UST systems,” the agency said April 16. “We are carefully considering all of the comments as we develop the final UST regulation.”
Industry groups and members of Congress have consistently and repeatedly criticized the proposed regulation as underestimating the compliance costs and impacts it would have on small businesses (74 DER A-21, 4/18/12).
EPA proposed revisions to underground storage tank requirements in November 2011 and previously said it expected to finalize the regulations in summer 2014. The proposed rule would apply to tanks holding petroleum or hazardous chemicals that are regulated under Subtitle I of the Resource Conservation and Recovery Act. Tanks regulated under Subtitle C of RCRA would not be affected.
According to the agency, there are more than 590,000 underground storage tanks around the country at 210,000 sites. Compliance costs for the proposed rule were $210 million, according to the regulatory impact analysis, but it said the regulation would lead to $300 million to $740 million in annual avoided remediation costs.
The 2011 proposed rule (76 Fed. Reg. 71,708) would create rules for backup containment of the substances in tanks and extend training requirements to more tank operators and owners. EPA says the proposed rule would enable better prevention and detection of leaks in storage tanks, which can cause groundwater contamination.
If finalized, the rule would be the first major revision to federal underground storage tank regulations since 1988.
Longstanding Concerns About Cost
Despite EPA assurances that it had taken into account the impact the proposed rule would have on small businesses, both industry groups and Congress have adamantly disagreed.
The Petroleum Marketers Association of America says EPA’s estimate of $900 in average annual compliance costs per facility is drastically wrong. The group estimates annual compliance costs would actually be $6,100.
Bipartisan groups of 11 senators and 58 House members sent separate letters in July 2013 raising concerns about the cost of the proposed regulation (144 DER A-31, 7/26/13).
“We are concerned that the Agency’s estimated annualized compliance costs of $900 may be significantly underestimated,” the Senate letter said.
New Hawaii UST regulations
Program’s new UST rules went into effect on August 9, 2013
The State of Hawaii’s Underground Storage Tank (UST) Program’s new UST rules went into effect on August 9, 2013. Some of the changes are specified below, and many more are listed on the Summary of Changes. If you have any questions about the regulations, Contact Us now to ensure you are and will be staying in compliance.
Class A, B, and C operators need to be trained, certified, and designated by December 9, 2013. Hawaii UST Regulation HAR 11-281-46 requires owners and operators to submit the Initial UST Operator Designation Form which lists the Class A and B Operators designated for each UST site within 120 days of December 9, 2013.
The New regulations include:
Annual sump testing must be conducted during your next scheduled annual maintenance.
All USTs or UST systems installed on or after the effective date of the rules must be provided with secondary containment (be double walled) AND use interstitial monitoring for release detection on the tank(s) and piping. If a portion of single walled piping is replaced, the replaced portion must be provided with secondary containment and interstitial monitoring. If you have any questions regarding these requirements, contact us – TAIT provides tank services and consulting and we are happy to help explain this in more detail.
Permits for UST Systems will be required within three years for those facilities that still do not have one yet. Permits for operating shall be submitted on the Application for an Underground Storage Tank Permit form with a $150 fee and will be effective for five (5) years, then will require renewal.
Retraining for Class C Operators will be required annually. Retraining for Class A and B operators will be required every 5 years. TAIT and UST Training offer these training courses online and can offer classroom courses as required for large groups. Contact us for more information.
Additional resources: Summary of Changes, Hawaii Administrative Rules Title 11 Chapter 281, the letter from Steven Y.K. Chang, Hawaii’s Chief of Solid and Hazardous Waste Branch regarding the Energy Policy Act of 2005, upcoming requirements and Summary of USTs in HI. More information about the training, the regulations and UST forms can all be found on the UST page of Hawaii’s DOH website. The Solid & Hazardous Waste Branch website contains additional information such as their Mission Statement, as well.
In preparing for the test, it will be very helpful to review the Technical Guidance Manual for UST Closure & Release Response which can be viewed and some sections can be downloaded. Be aware that revisions are expected to be made.
TAIT has been installing, working on, testing, repairing, removing and closing tank sites since the 60’s and we do projects in Hawaii on a regular basis. If you have any consulting or contracting needs, Contact Us today. We’d love to help answer questions and/or direct you to any other resources you may need.
2013 PEI/NACS show
Dennis Tweedy, Billy Watroba and Melanie Nelson attended the NACS show this year, and were joined by a close subcontractor of ours, Katie Seaborn from American Containment Services, Inc.
The 2013 PEI/NACS show, the biggest exposition of fuel handling equipment in the world, lasted from October 12-15 in Atlanta, Georgia. This was the largest NACS show in their history, with 1,050 companies in a attendance making it the 48th largest trade show this year. Over 20,000 people gathered to view and buy the latest advances not only in the convenience store industry, but also in the petroleum business. Every year PEI members convene to discuss, display, and market innovative technologies and services, keeping the industry on the cutting edge. As a bonus, the connections made throughout the convention help to expand and improve businesses, which leads to a greater, more efficient petroleum industry, and where better to have it than in the middle of the #1 buying show in the country. The educational sessions at the NACS show provided extensive information about the highly competitive and illustrious convenience industry. Topics covered in these sessions included:
- traditional vs. digital marketing
- good financing
- data-driven product positioning
- the impacts of health care reform
- customer engagement
- social media, and much more!
To read more about the topics covered in these sessions visit NACS Educational Sessions, and to learn more about the PEI/NACS Show visit their website. Click here to learn more about the Petroleum Equipment Institute (PEI). For those who are interested, the following is a video preview of what the PEI/NACS show is all about:
Are you attending the PEI Convention OCTOBER 12th – 15th, 2013 at the NACS Show? Come see TAIT in booth #4552!
This weekend, TAIT associates Melanie Nelson, Al Throckmorton and Dennis Tweedy head to Atlanta, Georgia from around the country to meet with more than 24,000 industry professionals from 65 countries — all seeking or offering the newest innovations, education and conversations about today’s important industry trends and issues.
The Petroleum Marketers Association of America (PMAA) has held its Fall Meeting as part of the NACS Show since in 1995 and the Petroleum Equipment Institute (PEI) has held its annual meeting as part of the NACS Show since in 2002. Last year’s event the NACS Show 2012, was great and we expect this year’s turnout and events to be even better!
A few events we are looking forward to and hope to see you at are:
PEI After-Hours Lounge – Saturday, October 12, 5:30 p.m.-7:30 p.m. – Sunday, October 13, 5:30 p.m.-7:30 p.m. – Westin Peachtree Plaza, Lobby Bar PEI’s After-Hours Lounge is the perfect place to come and unwind after a day at the show. Catch up with old acquaintances or make new ones before venturing off to dinner or nightlife in Atlanta.
PEI’s Membership Breakfast
PEI Industry Reception – Monday, October 14, 5:30 p.m.-7:00 p.m. – GWCC, Building B, Level 2 Concourse, top of escalators outside of Fuel Equipment & Services area The PEI Industry Reception is the number one networking event of the week! This event provides the best opportunity to socialize with PEI friends while enjoying complimentary food, live music and beverages. Your PEI badge is your ticket. No extra charge to attend.
Here is PEI’s full Schedule of Events
Here is NACS full Schedule of Events
NACS Show Kickoff Party
NACS Closing General Session featuring Hillary Rodham Clinton
As convenience and fuel retailing’s premier industry event, the NACS Show offers unmatched opportunities for buyers and sellers to come together, conduct business and learn from one another — all in an environment rich with new ideas and new partnerships.
Tim Ericsen, COO of Tait Environmental Services, featured in the “O&A” Oil &Automotive Marketing News – for presenting “Contracted Designated Operator – Managing a Successful Program” at the 2013 Pacific Oil Conference in Los Angeles California September 3-5. Here are images from the article:
Newspaper Cover Image
54th Annual Pacific Oil Conference Heading for L.A. Live
Tim featured in the article
Tim’s Title Slide
Contracted Designated Operator – Managing a Successful Program
Example Slide from the Presentation
Common Errors and Omissions
To request this presentation at your event, contact Tim Ericsen. For any questions about our DUSTO program and the similar Operator Inspections TAIT performs throughout the US, contact us today! TAIT is pleased to serve you in either capacity, and we do much more.