D NUCKLES TXDOT PST.ppt - Texas A&M University

Outline

Briefing: – TxDOT PST Investigation Preparation

Presentation:– SBLGA Talks About PST Investigations

Closing Remarks and Questions

AST VS. UST ?

Aboveground Storage Tank

Aboveground Storage Tank

4

AST

Underground Storage Tank

5

UST

UST Removal

6

UST

UST INVESTIGATIONS

Getting the dreaded call or email?

You SHOULD expect a TCEQ PST inspection once ever three years.– For underground storage tanks (USTs) only!

Don’t be alarmed!– These are routine inspections, and with your good records and practices in place, it should go

smoothly.

– Call ENV if you need assistance.

Getting prepared!

Two week notice is generally given. – Someone needs to be paying attention to the incoming postal mail!!!

Be positive, and work with the investigator to set up a good time. – Normally they offer a suggested time, but it can be modified if necessary to accommodate your

schedule and is within their time limits.

9

Getting Prepared!

Start getting your paperwork ready before their arrival, and send them any requested items in advance. – This will make the investigation move along faster, since they will be more familiar with your site

beforehand.

While the items are usually the same for what 30 TAC 334 requires, you’ll notice that different TCEQ regional offices send their requested items in differing formats (lists may appear different).– SBLGA will cover the different types of investigations.

10

Prep List is Usually Sent by the Investigator

Get everything on the list ready ahead of time by:

– Gather folders of the information they will be looking at, and place them in a convenient and comfortable area for them to review.

– Ensure the documentation for certain items is present.– Have your local PST operator(s) (for USTs) present during the inspection (and Class A/B/C

Operators)

• These folks have the knowledge and awareness of details they’ll be asking about.

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What to do if you’re missing an item?

–If anything is missing, call ENV or your District Point of Contact (POC) to assist…beforehand if possible.

The District POCs could be:

– Safety Officers– Facilities Coordinators– Business Operations Managers– Environmental Specialists– Director of Maintenance

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NEW: USTs Updates for TxDOT

1. SSD has indicated that over the next several years (long term), that USTs will be removed and replaced with ASTs.

– Goal being to move away from having USTs at most/all locations.– This will occur over time, and not all at once.– Some sections may choose to not maintain fuel at their location based on their

circumstances, and with their District Engineer’s approval.

2. SSD has started programming in every 6 months to have/keep ATGs calibrated.

– District’s still responsible for setting up with a vendor to perform these tests.

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TCEQ’S PST CHECKLIST

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Example of TCEQ’s Records for Review: Items List

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SBLGA PRESENTATION

TCEQ PST Investigations Best Practices and Words of Wisdom for

Success

Danielle Cochran Texas Commission on Environmental Quality Small Business and Local Government Assistance

What is SBLGA?

• Compliance Tools:–Guidance Documents–Webpage: www.texasenvirohelp.org–EnviroMentor Program–Hotline: 800‐447‐2827–The Advocate

Background

• Energy Act of 2005 requires states to inspect facilities with USTs every 3 years

• TCEQ and agency contractors perform investigations

• More than 371 administrative orders were filed by TCEQ in Fiscal Year 2018 with average penalty greater than $6,000

** Best option is to be in compliance before an investigation **

What Happens Before an Investigation?

• Compliance checklists:– Energy Act– CEIMOD– Temporarily out of service

• Announced Investigation– Notice given– Records may be requested at time of notification

• Complaint Investigation– No notice given

What Happens After an Investigation?

• Exit interview form given to facility• Field Citations• If violations are noted, get in compliance and submit documentation ASAP – it could save $$$$

• Many factors go into penalty calculations

PST Requirements

• Self‐certification & registration

• Financial assurance **• Corrosion protection• Tank release detection• Piping release detection• Spill and overfill prevention• Release reporting• Miscellaneous records• Operator training

• Shear valves• Equipment installed after

January 1, 2009• Temporarily out of service

USTs • Stage I and Stage II vapor

recovery

PST Rules/General Info

• TCEQ rules are found in Title 30 of the Texas Administrative Code– Chapter 334 – Underground Storage Tanks– Chapter 37 – Financial Assurance– Chapter 115 – Stage I & II Vapor Recovery– Chapter 113 – Vapor Recovery adopted by reference

• Generally keep records for 5 years or as long as the equipment is in use

Self‐Certification and Registration

What are the requirements?

• Annual self‐certification for USTs containing motor fuel

• Report changes within 30 days• Change of ownership• Tank status• Switching release detection methods• Change in substance stored

Annual Registration & Self Certification Form

How can I use STEERS for Self‐Certification?

• To renew only (not yet for initial self‐certification at a facility)

• No changes to the owner/operator since the previous self‐certification

• Get help to set up your STEERS account at:https://www.tceq.texas.gov/assets/public/comm_exec/pubs/rg/rg‐531a.pdf

Self‐Certification Renewal via STEERS

• Two options for renewing via STEERS:1) Create an account in STEERS at

• https://www3.tceq.texas.gov/steers/• OR

2) Add PST to your existing STEERS account• THEN,

• Submit proof of financial assurance on paper • Allow up to 5 days for processing before using

STEERS to self‐certify

TxDOT Applicability

• This would be a benefit.

If there is:– Stability in local staff (low turnover)– Certainty in getting renewal certificates on time is a plus!

– Streamline the process– Immediate/Same Day

What Records Should I Keep?

• Registration/self‐certification forms submitted in the past 60 months

• Registration certificate• Delivery certificate • Temporary delivery authorization (if applicable)

Note: Tanks and compartments should be physically numbered

Annual Registration & Self Certification Form

Delivery Certificate Example

Financial Assurance

Why is “Financial Assurance” not required at TxDOT?

You should expect this item to be requested by TCEQ or their contractors each time they perform an inspection.

It is part of their set list of items, and it can’t be changed.

Have this item printed out, so the inspector can more quickly understand why TxDOT (as a STATE GOVERNMENT ENTITY) does not require this.

30 TAC 37.801

Corrosion Protection


• Protect all underground/underwater metal components from corrosion

• Test all cathodic protection systems• At installation• 3 – 6 months after installation• Every 3 years

• Read rectifier every 60 days for impressed current systems


• Cathodic protection system:– Initial cathodic protection system testing (at installation and 3‐6 months later)

– 3 year test results– 60 day rectifier inspection log for impressed current systems

• Fiberglass tanks/piping:– Visual proof– Installation records OR…– Statement from corrosion specialist


• Composite/clad/jacketed steel tanks:– Installation records/original invoice for tank– Statement from corrosion specialist

Certified Contractors for Verification

• TxDOT relys on TCEQ licensed vendors to verify our piping material, tank type, joint materials, safe suction/pressurized system, etc.

What Do Your Sumps Look Like?

FRP Tank “Ribs” from Camera Survey

Tank Release Detection


• Release Detection for Tanks• Monitoring (0.2 gph) conducted at least once

every 30 days• Conduct in accordance with 3rd party certification

requirements/limitations• 3rd party certifications may be found at:

www.nwglde.org


• By January 1, 2021, perform 30‐day walkthrough inspections for release detection equipment:– Check for alarms– Test alarms, if possible to make sure they will sound

– Review records• Release detection tests• Inventory control


• By January 1, 2021, perform annual walkthrough inspections of handheld release detection equipment– Check for operability– Examples: tank gauge sticks, groundwater bailers


• By January 1, 2021, annually test release detection equipment for proper operation– Tested for proper operation– Keep records for 5 years– Examples: ATG/controllers, alarms,

battery backup, ALLD, probes/sensors, vacuum pumps/pressure gauges, etc.

What Records Should I Keep?• Automatic tank gauging (ATG) & inventory control

– One passing ATG test at least every 30 days– Inventory control with reconciliation


• Interstitial monitoring– Log sheet showing status of the sensor

• Groundwater/vapor monitoring– Statement from well installer that a release will be detected in at least 30 days

– Results of monitoring well


• 30‐Day tank gauging– Records showing periodic monitoring results

• Secondary containment barriers– Records showing periodic monitoring results

• Manual tank gauging– Records showing periodic monitoring results


• 30‐day walkthrough inspection records• Annual walkthrough inspection records• Records of annual testing for release detection

Piping Release Detection

What are the requirements?• Release detection for Piping

• Pressurized piping• Automatic line leak detector (3 gph)• Monitoring every 30 days (0.2 gph) or annually

(0.1 gph)• Suction piping

• Monitoring every 30 days (0.2 gph) or every 3 years (0.1 gph)

• Conduct in accordance with 3rd party certification requirements/limitations


• For pressurized piping systems:– Automatic line leak detector function test AND– Annual piping tightness test results OR– Vapor or groundwater monitoring results OR– Interstitial monitoring OR– SIR and inventory control OR– Electronic leak monitoring


• Suction Piping– 3‐ year piping tightness results OR– Vapor or groundwater monitoring results OR– Interstitial monitoring OR– SIR and inventory control

• Suction piping with no more than one high mounted check valve located at the suction line– Provide as‐built drawings or written documentation from registered UST contractor

Spill and Overfill Prevention


• Spill prevention– Tight fill fitting– Liquid tight spill bucket

• Current rule: visually inspect at least every 60 days • Begin conducting 30‐day walkthrough inspections by January 1, 2021

• Remove debris and liquid within 96 hours

• Sumps– Walkthrough inspections conducted every year


• Overfill device– Automatic shutoff or– Flow restrictor (ball floats)– Triennial test to ensure the overfill device will activate at the correct level

• Flow Restrictors (ball floats)– New rule effective September 1, 2018– Ball floats not allowed to be repaired or replaced at existing UST systems

– New systems installed on or after effective date must use automatic shutoff valves

What are the requirements?• Periodic testing of spill buckets and sumps using IM:

– Monitor integrity during 30‐day walkthrough inspection, OR – Test for liquid tightness every 3 years

• Testing deadlines:– Existing Facilities prior to September 1, 2018:

• Test by January 1, 2021– New facilities on or after September 1, 2018:

• Test when brought into service

• Test within 30 days of repairs to:– Spill prevention and overfill equipment– Secondary containment used for interstitial monitoring


• Wastewater disposal options from testing– Pump and Haul– Hydrostatic Test Water General Permit (GP)– Petroleum Fuel or Petroleum Substances GP

• See TCEQ’s webpage: Available Water Quality General Permits

What Records Should I Keep?• Spill buckets

– Spill bucket inspection log sheet– Records/ waste manifests for spill bucket waste

• Sumps– Annual walkthrough inspection log– Waste disposal records/manifests

• Periodic testing– Test results– Records indicating proper disposal of wastewater

Annual Sump Inspection

What Records Should I Keep?• Overfill protection (2 methods)

– Automatic shutoff device• Visually verifiable by investigator• Installation records• Repair records and test results within 30 days of repairs

• Triennial test results

– Flow restrictor• Installation records• Triennial test results• May not be installed or replaced after Sep 1, 2018

Release Reporting

What are the requirements?For suspected releases:• Report within 24 hours to TCEQ’s remediation division:

– Date of suspected release– Date the owner/operator became aware of the suspected release

– Results of investigation steps taken– Date and results of system tightness test (required within 30 days of the suspected release)

• Investigate (conduct a system tightness test) within 30 days

• Submit Release Determination Report within 45 days

Miscellaneous Records


• Copies of construction notification forms• Receipts and invoices for repairs and maintenance

Operator Training

What are the requirements?• Designate and train A/B and C operators for each facility

• List of approved A/B operator training courses: https://www.tceq.texas.gov/remediation/pst_rp/ust_training

• Training certificate expires after 3 years• Must take an Operator Training course that has been

submitted and approved by the agency after April 1, 2018• Certified Class A and Class B operators must be re‐

trained by January 1, 2020• Post sign at unmanned facilities with instructions of what

to do in an emergency


• A/B Operator certificate• Current list of C operators• Ensure at least one certified operator on site during hours of operation

• If fuel is dispensed when operator is not present:– Procedures for addressing a spill– Location of emergency shutoff button– When to call “911”– Contact information for the A/B Operator

Training Certificate

Class “C” Operator Form


• Documentation of re‐training– If applicable and if facility was previously determined to be in significant noncompliance

• If a licensed UST contractor is serving as your facility’s A/B Operator , you need a signed agreement

Shear Valves

What are the Requirements?• Ensure shear valves are properly anchored• Investigator will visually verify proper installation

NEED NEW EQUIPMENT?

Equipment Installed After January 1, 2009

Cracked Piping →

What are the Requirements?

• Secondary containment required for all new equipment

• Interstitial monitoring• Annual inspections of all sumps and manways used for release detection

• Tightness testing every three years for sumps and manways that are part of secondary containment

• Liquid sensing probe for sumps and manways that are part of secondary containment


• Annual inspection logs of all sumps and manways used for release detection

• 3 year tightness test results for sumps and manways that are part of secondary containment

• 30‐day interstitial monitoring sensor readings


• If piping has been replaced:– Installation records documenting no more than 35% of total original length of an existing line has been replaced with single walled line

• Secondary containment:– Visual verification– Installation records for new components

• Interstitial monitoring records

Texas Department of Agriculture

TEMP OUT OF SERVICE USTS

Temporarily Out of Service USTs


• Update PST registration within 30 days• Keep vent lines open and functioning• Ensure tank system is locked/secured• Maintain corrosion protection• Operator Training• Financial assurance unless:

– Tank is empty and– A site check and necessary corrective actions have been performed according to release investigation and confirmation steps


• Copies of Registration/Self‐Certification forms• Visual Verification that:

– Vent lines are open and functioning– Fill caps are locked or other evidence that tank system is secure

• Corrosion protection• Operator training


• Release detection records – Not applicable if tank is empty– Empty means liquid has been removed from tank and no more than an inch of sludge remains

• If empty, verification that tank is empty– Manifest, invoice, etc.

• Financial Assurance

What are Stage I requirements?• Applicability determined by facility’s location and monthly throughput

• Control requirements• Inspections during gasoline fuel deliveries • Annual testing• Recordkeeping requirements


• Stage I documentation:– Monthly gasoline throughput (inventory control records)

– If applicable based on location and throughput:• verification of a submerged fill tube• Annual test results for the past two years

What are Stage II requirements?

• No longer required• Deadline for decommissioning existing stage II equipment was August 31, 2018

• Keep records of proper decommissioning


• Stage II documentation:– Decommissioning notification– Test results– Report

What if I am missing information?• For additional forms:

– https://www.tceq.texas.gov/search_forms.html

• Search TCEQ’s Central Registry– Information about known PSTs and LPSTs– http://www15.tceq.texas.gov/crpub/

• Contact TCEQ regional office• Request records from our Central File Room

– File reviews– Request copies of records

For More Information…

• Contact regional SBLGA staff• www.texasenvirohelp.org• 1‐800‐447‐2827 – hotline

Any Questions???

D NUCKLES TXDOT PST.ppt - Texas A&M University

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