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Texas Commission on Environmental Quality

Texas Commission on Environmental Quality. Underground Storage Tanks Preparing For An Investigation. Small Business and Local Government Assistance. Brian Christian Andy Gardner Division Director Section Manager. Small Business and Local Government Assistance Offers.

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Texas Commission on Environmental Quality

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  1. Texas Commissionon Environmental Quality Underground Storage Tanks Preparing For An Investigation

  2. Small Business and Local Government Assistance Brian Christian Andy Gardner Division Director Section Manager

  3. Small Business and Local Government Assistance Offers • TechnicalAssistance • One to One Help • Compliance Tools • And It’s Free & Confidential

  4. What To Expect During A PST Investigation • It depends upon who is investigating • Focused investigations are conducted to meet Federal requirements • But you could be subject to a more comprehensive TCEQ investigation

  5. Federal Energy Act of 2005 • Required states to inspect facilities with USTs every 3 years • Texas must inspect at a rate of 6,000 facilities per year • UT Arlington has conducted past focused investigations

  6. How to Prepare for a PST Focused Energy Act Investigation • This only cites Category A violations, but other rules still apply; and • Be in compliance with all applicable rules because TCEQ investigators are still looking for compliance with all rules

  7. What is a Category? • Category A violations are major and immediately referred to Enforcement • Category B violations are issued as a Notice of Violation and are given a time period for correction • Category C may be for partial compliance and must be corrected

  8. If You Are Issued a Violation • If you receive an “A” violation-even if you pay a fine, you still must show that you have complied afterwards • If you receive a Category B or C violation and do not correct and respond you may then still end up in enforcement

  9. PST Things to Do List • Meet deadlines for testing and recordkeeping throughout the year-you can’t “go back to the future” • If possible find out what time they are coming and be there with all your records in order • Find out the who, when, and where of the investigation

  10. Self Certification • Is your delivery certificate current? • Applies to USTs containing motor fuel • Self certification is required annually • Submit on time to allow for processing • Delivery prohibition for USTs without a delivery certificate

  11. Delivery Certificate • This delivery certificate must be posted and renewed every year!

  12. Self Certification • In order to submit your annual self certification you must attest that facility operators have been trained • Training providers must be approved by the Agency • Don’t forget this operator training must be renewed every 3 years

  13. Financial Assurance • Is your insurance current? • Don’t forget to renew when it expires • Submit the certificate of insurance with self certification form • Do you have documentation?

  14. Corrosion Protection • Are all underground (and underwater) metal components protected from corrosion? • All of these must be protected: • Steel tanks and lines • Buried metal components • Metal components in sumps which are exposed to water

  15. Corrosion Protection • All cathodic protection systems must be tested at installation and every three years thereafter • For impressed current systems, you must read the rectifier every 60 days and keep a log sheet

  16. Corrosion Protection • FRP Tanks and Composite Tanks don’t require a cathodic protection system • Metal connections do • Do you have documentation?

  17. Release Detection • Are you checking for leaks? • Tanks • Monthly method capable of detecting a 0.2 gph leak rate (ATG & SIR) • Inventory control required if retail or if your method requires it • Accurate, daily readings • Reconcile at the end of each month

  18. Inventory Control • Non-blended systems pull from a single blend of gasoline, they are usually less complex • Blended systems pull gasoline usually from two different gas grades that are blended to make a midgrade -these calculations are more involved

  19. Release Detection • Piping • Pressurized • Must have an automatic line leak detector and be function tested annually • Monthly or annual test • Suction or Gravity • Monthly or triennial test • Do you have documentation?

  20. Spill & Overfill Prevention • Tight fill fitting • Spill bucket -Inspect every 60 days to ensure they’re liquid tight • Overfill Device • Automatic shut-off valve – in fill port • Automatic flow restrictor – in vent line • Do you have documentation?

  21. Sump Filled With Water

  22. Release Reporting • Did you report and investigate any suspected releases? • Exceeding inventory control reconciliation amount 2 months in a row • Inconclusive or failing SIR or ATG result • Do you have documentation?

  23. Records • Document. Document. Document. • Are you maintaining records to determine compliance • It doesn’t count if you can’t prove it

  24. Common Violations • Not doing inventory control • No proof of tank test results • No 3 year cathodic protection test • No documentation of tank material • No overfill documentation • Insufficient records

  25. Things You Should Know • Your facility must be overseen and staffed by workers with operator training • Your tanks must be identifed and match records • You must have installation and repair records

  26. Tanks Must Be Labeled

  27. More Considerations • Sumps and fill buckets are not repositories for soil, rags, and liquids • You must properly display your delivery certificate • You should know that your rectifier is working, what your ATG does, and how to do inventory reconciliation

  28. What happens after the investigation • Exit interview form • If violations are noted, get in compliance and submit documentation ASAP – it could save you $$$$

  29. Penalty Amounts • Average penalty amount is about $6,000 for those in non-compliance • At 3 year intervals, the penalty adds $2,000 per year to costs • It’s less expensive to be in compliance before the investigation

  30. There Are Worse Penalties • Leaking Tanks • Down Time • Remediation • Reporting • Replacement Costs • Traffic Obstruction • Appearance

  31. Costs To Clean Up a Leak • If “only” soils are affected, major leaks average about $100,000 • If groundwater is affected it can cost $1,000,000 or even more • Not to mention the stress on you and your business to accommodate remediation

  32. Free Confidential Visit • If you meet the definition of a Small Business or Local Government you may be eligible for a free site visit to help you identify areas that you need to improve • The visit is confidential, first come, first served depending on when funds are available

  33. How to get Assistance • www.texasenvirohelp.org • 1-800-447-2827 • Free, confidential site visit (if you’re a small business and not in enforcement)

  34. Small Business and Local Government Assistance Jack Holsomback 903-535-5158 Tyler Region

  35. Take Care of Texas

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