Ronda Johnson | TDEC UST Field Office Manager | Jackson, TN

• UST Webpage– https://www.tn.gov/environment/program-areas/ust-underground-storage-tanks/ust/new-

rules.html

• Monthly Newsletter- TN Tank Talk– Send name and email to: Mitzie.Berry@tn.gov to subscribe

• 2021 UST Owners Compliance ToolBox– https://www.tn.gov/environment/program-areas/ust-underground-storage-

tanks/ust/operator-training/educational-tools.html

• 2018 TN Federal Rule Change Quick Reference Guide– https://www.tn.gov/content/dam/tn/environment/underground-storage-

tanks/documents/new-rules/UST_NewRules2021_Tri-4d_FINAL_20200131.pdf

• State of TN Draft Forms– https://www.tn.gov/environment/program-areas/ust-underground-storage-tanks/ust/new-

rules.html

2018 Rule Changes - New Requirements

New Requirements for Tank Owners

1) Spill and Overfill Prevention Equipment Testing

2) Sump Integrity Testing - IM

3) Release Detection Equipment Testing

4) Monthly and Annual Walkthrough Inspections

5) Compatibility

6) Release detection for Emergency Generators

These requirements apply to all new UST system installed on or after October 13, 2018 and to all existing facilities beginning October 13, 2021.

Testing Requirements

• All testing requirements must be conducted by a “qualified person” as defined by U.S. EPA:– Licensed Contractor certified by device manufacturer

– Approved by authority having jurisdiction (Division of UST)

– Conducted in accordance with Division guidance and can demonstrate adequate experience

– Obtain certification from nationally recognized organization (PEI)

• All tests must be conducted and recorded in accordance with:– Device manufacturer’s instructions

– Nationally recognized practice (PEI)

– Format established by the Division

Spill and Overfill Devices- Three-year testing requirement

Spill Prevention Devices

• Action: Conduct a spill prevention device integrity test every 3 years completed on the Division Form or use a double-walled spill bucket with interstitial monitoring.

• Tank Owner Responsibility: Maintain a passing spill prevention device integrity test conducted within the last 3 years or documentation the prevention equipment is double walled and is monitored continuously. Integrity Test must be conducted by October 13, 2021.

Spill Prevention Devices

• Spill Prevention- Double wall spill bucket

– Electronic sensor – if monitored with IM records no operability testing required.

– Standalone sensor – if monitored monthly no operability testing required.

– Liquid Float Gauge – will require operability testing.

– Not part of monthly leak detection by rule

Overfill Prevention Devices

• Action: Inspect overfill prevention equipment every 3 years.

• Tank Owner Responsibility: Maintain records demonstrating overfill functionality testing conducted within the last three years. Applies to all forms of overfill and documentation must be maintained for three years. Overfill Test must be conducted by October 13, 2021.

The 3 Types overfill prevention:

Automatic Shutoff (sometimes called ‘flapper valves’)– Set to fully engage at 95% of tank volume

Flow Restriction (sometimes called ‘ball floats’)– Set to fully engage at 90% of tank volume

– Cannot be replaced or repaired after October 13, 2021

Overfill Alarm (sometimes called ‘high level alarms’)– Set to alarm at 90% of tank volume

– Must be visible or audible or both to delivery driver

➢ An automatic shutoff device or “flapper valve” slows down and stops product flow when the product has reached a certain level in the tank.

➢ Automatic shutoff

devices are located

in the fill pipe.

As the tank fills during a delivery, a ball in the valve rises and restricts the flow of vapors out of the tank.

The flow rate decreases and alerts the delivery person to stop thedelivery.

*If ball floats are found damaged or non-functional during overfill functionality testing then a new method of overfill must be installed.*

• An overfill alarm uses a sensor in the tank located on the automatic tank gauge (ATG) probe.

• An overfill alarm provides a warning when the tank is close to being full (90%) that can be seen or heard (or both) by the delivery person.

• When the alarm activates, the delivery person should stop the flow of product to the tank immediately.

Spill and Overfill Equipment Repairs

• Action: Test or inspect components within 30 days after a repair or replacement of spill or overfill prevention equipment.

• Tank Owner Responsibility: Maintain documentation of testing conducted within 30 days of a repair or replacement of spill and overfill equipment.

Interstitial Monitoring (IM) Sump Integrity Test

• Action: Systems using interstitial monitoring (IM) for piping release detection must conduct a sump integrity test every three years.

• Tank Owner Responsibility: Maintain a passing sump integrity test conducted within the last three years. Sump integrity test records must be maintained for three years.

Sump Integrity Testing must be conducted by October 13, 2021 for all sumps using IM for its primary release detection method

Interstitial Monitoring- Tank and Sump Repair

All tanks, piping or sump repairs must be integrity tested within 30 days of completion of repair (if used for IM)

Tests conducted in accordance with:1. Manufacturer’s instructions

2. Division guidance

3. Code of practice developed by a nationally recognized association

4. Requirements determined by the Division to be no less protective of human health and the environment

• Maintain test records for 3 years

• Maintain repair records for operational life of the UST system

Hydrostatic Testing – Water Disposal

• The UST Division does not regulate the disposal of petroleum contaminated test water. WHO DOES??????

Test water should be properly disposed. Please contact the following Divisions for proper disposal

– Division of Solid/Hazardous Waste Management--hazardous substance requires characterization- “reclamation of hazardous material”

– Division of Water Resources- NPDES permit required for onsite disposal to surface water- stormwater disposal through local municipality- wastewater treatment plants may receive locally generated water

Release Detection Equipment Operability

• Action: Annual testing of electronic and mechanical release detection components

• Tank Owner Responsibility: Maintain the three previous annual tests of release detection components.

– Automatic line leak detector test

– All IM tank and sump sensors

– Automatic tank gauge and other controllers- test alarm; verify system configuration; test battery backup

– Probes- inspect for residual buildup; ensure floats move freely; ensure shaft is not damaged; ensure cables are free of kinks / breaks; test alarm operability and communication with controller

– Vacuum pumps and pressure gauges- ensure proper communication with sensors and controller- Uncommon method in TN.

Release Detection Components to be Tested

ATG Console

IM SensorATG Probe Line Leak Detectors

Monthly/ Annual Walkthrough Inspections

Monthly Walkthrough Inspections

• Action: Monthly Walkthrough inspections of spill buckets, flapper valves, release detection equipment and records every 30 days.

• Tank Owner Responsibility: Maintain records of monthly walkthrough inspections conducted every 30 days and consists of the following:

– Inspect spill prevention for liquid, debris and damage.

– Visually inspect the tank fill riser drop tube and flapper valve (if present) for damage.

– Operability of release detection equipment,

– Presence of alarms or other unusual operating conditions.

– Review of current release detection records.

Monthly walkthroughs must be conducted by October 13, 2021 and maintained a minimum of 12 months.

Monthly Walkthrough Inspections- Spill Prevention

Every 30 days:

Inspect Spill Buckets– Remove liquid or debris

– Check for cracks or damage

– Remove fill pipe obstructions

– Inspect fill cap for proper fitting and gasket

– Record results on Division form or pre-approved alternate format

Monthly Walkthrough – Release Detection

Every 30 days: Inspect Release Detection Records

Statistical Inventory Reconciliation (SIR):

- Review data and accuracy of daily fuel level readings

- Check tank Monthly for water (water finding paste)

- SIR Reports received every 30 days from vendor

- Review results and report suspected releases

Monthly Walkthrough - Release Detection

Every 30 days: Inspect Release Detection Equipment and Records

Automatic Tank Gauge (ATG)

– No alarms or unusual operation conditions

– Review monthly release detection results

– Report all suspected releases

– Conduct static test if no monthly result is available

Monthly Walkthrough-Release Detection

Every 30 days: Inspect Release Detection Equipment and Records

Interstitial Monitoring (IM)

– Document and attach at least monthly sensor status and alarm report to the form

– All sensors normal, no alarms

– Document alarms and response to alarms on monthly inspection form

– Report all suspected releases

Walkthrough Inspections- Requirements

Must be conducted in accordance with one of the following:

1. Device manufacturer’s instructions

2. Nationally recognized practice (PEI)

3. Format established by the Division (drafted)

Annual Walkthrough Inspection

• Action: Annual Walkthrough Inspection

• Tank Owner Responsibility: Annual walkthrough inspections are conducted once every 12 months and consist of the following:

– Visually check for damage, leaks to the containment area, or releases to the environment. (Contained and non-contained Dispenser, STP and Transition sumps)

– Remove liquid (in contained sumps) or debris.

– For double walled sumps with interstitial monitoring, check for a leak in the interstitial area.

– Check devices such as tank gauge sticks for operability and serviceability.

Annual Walkthrough Components to be inspected

Gauging Stick (SIR)

Contained STP SumpUncontained STP Sump

Contained Dispenser Sump

Uncontained Dispenser Sump

Walkthrough Inspections- Recordkeeping

Maintain monthly and annual walkthrough inspection records for one (1) year, including:

1) A list of each area checked

2) If each area was acceptable or needed action taken

3) Description of actions taken to correct an issue

4) Delivery invoices if spill buckets are checked less than every thirty (30) days due to infrequent deliveries.

• 12 months of leak detection results

• Annual Line Leak Detector test results*

• Release Detection Operability*

• Annual Line Tightness Test or 12 months of piping monthly monitoring results

• 12 months of Monthly Walkthrough inspections

* Required to keep the last three years records beginning October 13, 2021.

• Annual Walkthrough inspection conducted in the last 12 months.

• Spill Bucket test conducted in the last 3 years

• Overfill test conducted in the last 3 years

• Sump integrity test conducted in the last 3 years (IM only)

• Corrosion Protection (CP) Test conducted in the last three years and previous 3 years CP Test (Metallic Tanks and Piping Only)

• 60 Day Rectifier Log (Corrosion Protection- Impressed Current Only)

• Non safe suction line tightness test results must be kept for at least 3 years.

• Records of all leak detection system maintenance, service, or repairs 1 year from date of repair.

• Documentation of tank and/or line repair must be kept for the remaining life of the UST system.

All UST records need to be transferred to a new owner if the store is sold

Compatibility

• Action: UST systems used to store regulated substances blended with greater than 10% ethanol or greater than 20% biodiesel must comply with requirements for fuel compatibility.

• Tank Owner Responsibility: Notify the Division 30 days prior to storing biofuels greater than 10% ethanol or 20% biodiesel. Provide documentation showing compatibility of all UST system components including tank, piping, containment sumps, pumping equipment, release detection equipment, spill equipment, and overfill equipment using the Division approved compatibility checklist.

• Compatibility Checklist-– https://tdec.tn.gov/etdec/DownloadFile.aspx?row_id=CN-1285

• Statement Of Compatibility-– https://tdec.tn.gov/etdec/DownloadFile.aspx?row_id=CN-1283

2018 Rule Change: USTs for Emergency Generators

All emergency generators are required to begin performing

tank and piping release detection by October 13, 2021.

*Safe suction piping does not require piping release detection*

USTs for Emergency Generator Systems – General Updates

Please contact your local Field Office with any questions regarding your Emergency Generator requirements.

EPA Guidance for Emergency Generator Release Detection-Currently in development

Changes to NFPA code for EGT- no mechanical leak detectors for pressurized piping at level 1 facilities

Contact Information: Field Offices

Any Questions or Comments on the New Rules?