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Underground Storage Tank Update Small Business & Local Government Assistance

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

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  1. Underground Storage Tank UpdateSmall Business & Local Government Assistance Brian Christian Andy Gardner Division Director Section Manager

  2. SBLGA Offers: • Technical Compliance Assistance • One to One Help • Compliance Tools • Free & Confidential

  3. SBLGA PROGRAMS • Site Visit Program • Regional Staff • Advisory and Advocacy Groups • The Advocate Newsletter

  4. 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

  5. Getting Help • Hotline • 1-800-447-2827 • M-F 8:00am-5:00pm • www.TexasEnviroHelp.org • Office & Site Visits

  6. 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

  7. EnviroMentor Program • Technical Assistance • Volunteer Professionals • Consultants • Engineers • Lawyers • Operators

  8. Information Resources • The Advocate • Rule Change Outreach • Compliance Initiatives • Workshops & Seminars • Online & Print Publications

  9. UST Current Events • Federal UST rule changes • Operator Training • 3 year inspection cycle • Common violations • Penalty calculations • Stage I & II rule changes

  10. 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

  11. Operator Training • Deadline August 8, 2012 • Training offered on-line • Registration letters • Make sure TCEQ knows you took the training

  12. 3 Year Inspection cycle • Best option is to be in compliance before the investigation • Sign up for a site visit before the next investigation

  13. 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

  14. Clean and Dry Flexible Connector

  15. Corrosion Protection

  16. 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

  17. Overfill Documentation • Visual Verification • Original Installation Records • 3rd Party Contractor • Photographs • Letter from 3rd party contractor

  18. 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

  19. Penalty Calculations • Many factors • Amount of throughput • Compliance History • Avoided Costs • Good faith reduction (25%) • Deferral for agreed order (20%)

  20. 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

  21. 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

  22. Stage I Vapor Recovery • Rules proposed earlier this year • Improved consistency with federal Stage I requirements • Testing requirements • Throughput limits • Comments due May 12th

  23. 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

  24. How do I stay in Compliance? • RG-475 – PST Super Guide • SBLGA Hotline • SBLGA Website • Local SBLGA staff • Registered UST Contractor/Service Provider

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