GTEC 2019 UST Management & Compliance Assistance Seminar

1. GTEC 2019 UST Management & Compliance Assistance Seminar August 2019 UST Management Program

2. Compliance Inspections Shaheer Muhanna, RCU 1 Unit Manager

3. Compliance inspections • Email Notification • Owner emails compliance records in advance • Physical Inspection • Equipment • Records • Outcome: • NOC or Additional InfoRequest • NOV if additional info not provided within 30 days

4. Compliance inspections Release Detection Release Prevention Financial Responsibility Stage I Enhanced Vapor Recovery (EVR)

5. Compliance inspections • Equipment condition • Spill Bucket • Overfill prevention • Sump conditions • Line leak detectors • Entry boots • STP Sump • Under dispensers • Rectifier • Stage I EVR (13 metro Atlanta counties)

6. Compliance inspections • Compliance records review • Current tank registration • A/B/C Operator Training • Financial Responsibility • Tank monthly Release Detection reports for past 36 months (no history reports) • Piping test reports (monthly or annual) for past 36 months • Annual Automatic Line Leak Detector tests for the past 3 years • Annual Sensor Functionality tests for the past 3 years • 3-Year Cathodic Protection tests (last 2 tests) • Rectifier logs for the past 36 months • Stage I EVR tests (once every 24 months) Emailing records prior to the inspection is recommended

7. Questions about inspections?

8. Most common violations Shaheer Muhanna, RCU 1 Unit Manager

9. Failure to monitor tanks monthly • Automatic Tank Gauge • Interstitial Monitoring • Statistical Inventory Reconciliation

10. History reports for monthly monitoring • History Reports are not acceptable

11. acceptable monthly monitoring reports Interstitial Monitoring for Tanks and Lines CSLD 0.2 gph

12. ACCEPTABLE MONTHLY SIR REPORT SIR data must be analyzed on a monthly basis

13. Failure to monitor Dw piping monthly • Failure to monitor sumps with double-walled (DW) piping (sensors or visual) “LIQUID” or “SENSOR” STATUS REPORT Sump Sensors *Piping installed on or after April 7, 2008 must use interstitial monitoring

14. Failure to conduct annual sensor functionality tests • Interstitial sensors and sump sensors: • Annual test report and • Simulated “alarm” printout

15. STAGE I ENHANCED VAPOR RECOVERY (evr) • Failure to test Stage I EVR every two years

16. PROOF OF OVERFILL PREVENTION • Ball Float Valves cannot be viewed by EPD inspector *Have overfill documented during annual line and leak detector testing

17. CATHODIC PROTECTION • 3-year CP testing • 60-day rectifier log

18. Spill buckets and sumps • Spill buckets and sumps with water, fuel, debris

19. Dispenser ACCESs • No keys available to open dispensers

20. Financial responsibility • Failure to provide proof of Financial Responsibility • Missing GUST invoices • General liability insurance not addressing USTs • Insurance certificates must address UST system and include specific language related to corrective action and damages caused by releases.

21. Operator retraining • Release detection/prevention violations • Financial responsibility violations • Classroom or in-person training only

22. Questions about ust violations?

23. enforcement Chad Hall, Enforcement Unit Manager

24. Enforcement process Informal Enforcement Notice of Violation (NOV) Call to Request Jobber’s Aid Expedited Consent Order (ECO) Formal Enforcement Administrative Order: Fuel Delivery Prohibition & Revocation of GUST Trust Fund Eligibility

25. IF YOU RECEIVE A Proposed Order… • Review Attachment A • Contact Enforcement Officer listed on letter • Provide missing compliance documents: penalties may be reduced • Complete required tests and repairs • Sign CO and remit penalty payment

26. IF YOU RECEIVE AN Order… If you can provide missing test reports or compliance documents, penalties may be reduced.

27. penalties • Most Common Violations/Penalties: • Monthly monitoring on tanks • Monthly monitoring on lines • Annual testing (lines, leak detectors, sensors) • $500 per year ($1500 for 3 year cycle) We are hopeful that email reminders in the future will increase compliance

28. penalties • Most Common Violations/Penalties: • 3-year Cathodic protection test ($1500) • 60-day rectifier log ($250) • 2-year Stage I EVR testing ($1000) • Financial Assurance ($500) • General repairs/maintenance/access ($500) • Annual Tank Registration ($500)

29. example • Average facility with no testing records for 3-year cycle: • $1500 – No monthly monitoring for tanks • $1500 – No line tightness testing • $1500 – No leak detector testing • $1500 – No cathodic protection testing • $1000 – No Stage I EVR testing • $7000

30. What’s working/what’s not working • Tank Owners not involved in compliance • Not responding until ECO is issued (NOV gives 30 days to respond) • Jobber assistance • Administrative Orders

31. Questions about enforcement?

32. UST Rule Amendments Shaheer Muhanna RCU I, Unit Manager

33. 30+ Years of evolving regulations • 1988 UST regulations • 1998 required upgrades • Energy Policy Act of 2005 • 2012 Operator Training • 2015 Federal regulation updates • 2017 State adoption • Implementation schedule

34. 2017 GA UST Rule amendment • July 2015 – EPA published changes to the 1988 UST Regulation • State Program Approval (SPA) requires adoption of federal requirements • No less stringent requirement • Adopted by reference • Two additional state-specific requirements • Rule Implementation schedule can be found: https://epd.georgia.gov/underground-storage-tank-technical-guidance

35. New FEDERAL requirements Requirements effective December 15, 2017: • Ball Floats may no longer be used for overfill prevention • Within 30 days after repair, secondary containment, spill and overfill equipment must be tested • Closure of internally lined tanks that fail the internal lining inspection and cannot be repaired according to code of practice • Demonstrate compatibility for systems with greater than 10% ethanol and greater than 20% biodiesel

36. New FEDERAL requirements • Requirements effective December 15, 2017 (cont’d) • Containment sump testing for sumps ad UDC used for piping interstitial monitoring, spill prevention equipment test and overfill prevention equipment inspection are required at time of installation • For airport hydrant fuel distribution systems and USTs systems with field-constructed tanks: • Notification and financial responsibility • Release reporting • Closure

37. New FEDERAL requirements • Requirements effective December 15, 2017 (cont’d) • For previously deferred UST systems • Release detection for emergency generators (new installs) • Subpart K for airport hydrant fuel distribution systems and field-constructed tanks

38. New FEDERAL requirements Requirements Due by December 15, 2020: • Site assessment records for groundwater and vapor monitoring • Containment sump testing for sumps used for piping interstitial monitoring, spill prevention equipment test and overfill prevention equipment inspection (once every three years) • Sump testing • PEI, RP 1200, the test water should be a minimum. 4 inches above the highest penetration or sump site wall seam. Whichever is higher • PMAA test only applicable if the sensor activates positive shut off. Minimum height of test water should be at the level of positive shut off activation of the sensor.

39. New FEDERAL requirements • Requirements Due by December 15, 2020: • UDC testing: Single wall valves, flanges, couplings, etc…located inside the UDC are part of the piping system, because of the single wall components the UDC is the required secondary containment and must be monitored monthly as part of the release detection method and tested every 3 years. • If the UDC is DW and monitored monthly the 3 year testing is not required.

40. New FEDERAL requirements Requirements Due by December 15, 2020: • UDC testing

41. New FEDERAL requirements Requirements Due by December 15, 2020: • Release detection equipment testing (once per year) • Emergency generator-release detection required

42. New FEDERAL requirements Requirements Due by December 15, 2020: Walkthrough Inspections • Once every 30 days • Spill prevention equipment inspection • Release detection equipment inspection (e.g. ATG, records review ) • Form is under development • Annually • Containment sump inspection (all sumps) • Handheld release detection equipment inspection (e.g. gauge stick, bailers)

43. New STATE requirements • Record retention minimum of 3 years • Annual Tank Registration deadline is December 31

44. Questions about the new rules?

45. UST TESTING Shaheer Muhanna, RCU 1 Unit Manager

46. UST TESTING • Know your UST system • What is the construction material of tanks/lines? • Was your system installed after April 7, 2008? • Was your system installed after Dec 15, 2017? • The type of required testing depends on your tank /piping construction, installation date(s), and equipment

47. UST TESTING • Construction Material • Fiberglass, composite, epoxy • Steel Galvanic/STIP-3 • Steel with Impressed Current System • Steel Galvanic/STIP-3 and Steel Impressed Current systems require cathodic protection testing once every 3 years

48. UST TESTING • Installation Date • Tanks/piping installed after April 7, 2008 must use Interstitial Monitoring • Monthly tank sensor reports • Monthly sump sensor reports or visual log • Annual sensor functionality test APRIL 7 • Automatic tank gauging (ATG) and line tightness testing is not acceptable for these tanks

49. UST TESTING • Installation Date • Tanks/piping installed after December 15, 2017 have additional requirements at installation: • Containment sump testing (high-level) • Spill bucket testing (unless double-walled) • Overfill inspection 2017 FORMS MAY BE FOUND AT: https://epd.georgia.gov/underground-storage-tank-forms

50. Testing Forms • EPD forms must be used for • Containment Sump Integrity • Spill Bucket Integrity • Overfill Prevention • Compatibility Demonstration • Cathodic Protection FORMS MAY BE FOUND AT: https://epd.georgia.gov/underground-storage-tank-forms