TDOT Underground Storage Tank Compliance UST Compliance – Review Revised August 2007 Veeder Root Certificate Files Dispenser Annular probe Tank probe Fill

TDOT Underground Storage Tank Compliance

UST Compliance – Review

Revised August 2007

Veeder Root

Certificate

Files

Dispenser

Annular probe

Tank probe

Fill pipe

Line

Tank sump

Card Reader

Spill bucket

Dispenser sump

Note: pumps are either submersible (in tank) or suction (in dispenser)


Underground Storage Tank (UST) compliance is mandatory.

USTs are regulated by the Tennessee Department of Conservation (TDEC) under the Division of Underground Storage Tanks (DUST). Compliance is mandatory. (It does not depend upon your waste generator status.) Violations = Fines.

Fines

Revised August 2007


A current UST Certificate must be posted.

A facility may not operate USTs without a current certificate. It is unlawful to put or receive fuel in a tank without a valid certificate. Both fuel delivery and facility personnel are at risk for violation.

UST certificates are issued by TDEC and forwarded to each garage. If the posted certificate is expired, or will soon expire, contact appropriate personnel immediately.

Fines

Revised August 2007


Monthly tank leak tests are required.

Monthly tank leak tests are required for all USTs. TDOT uses the automatic tank gauge (ATG) and the Veeder Root system to conduct the tests for all fuel tanks. Most Veeder Roots are programmed for weekly testing to provide for at least four opportunities for a “pass test”. Occasionally, tests do fail for valid reasons (covered later). However, should a failure be unexplainable, contact appropriate personnel immediately.

Fines

Revised August 2007


Documentation of monthly tank leak tests is mandated.

Documentation must be maintained to verify the last 12 months of valid tank leak tests. Although the Veeder Root stores this information (barring a lightening strike), TDEC does not accept this record. There must be a valid test in paper form for each month maintained in a file/envelope/etc. Additionally, there should be some written indication on the test showing results were reviewed (initials, date). Again, TDEC does not accept that there were no leaks without proper documentation.

Fines

Revised August 2007


Tank leak tests are also required for used oil tanks.

Used oil tanks must also have tank leak tests. Generally, these tanks do not contain sufficient volumes to use the standard tank leak test method. Instead, the used oil tanks at the Knoxville and Nashville regional garages must follow the alternative method using interstitial monitoring.

This interstitial monitoring method requires verifying the sensors and system are operating by observing an “All Functions Normal” reading on the Veeder Root. Observe this reading weekly, note on the appropriate form, and maintain the records. Fines

Revised August 2007


Renovation tank leak testing is mandatory.

During facility renovations tank leak testing must continue. Without power, a secondary method is required (interstitial monitoring). Please contact appropriate personnel (Susan Christians or Mike Fitzgerald) to assist with the necessary amendment notification to DUST and with monitoring during the renovation period to maintain full compliance.

Fines

Revised August 2007


Inspections of spill buckets and dispenser sumps are now required.

Based on new 2007 regulations, TDOT must now conduct regular visual inspections of spill buckets and dispensers. Inspect these monthly, record results on the form provided by the Environmental Compliance Office, and maintain all documentation. Visual inspections for spill containment buckets (for fuel tanks) shall assure the “integrity” of the spill bucket . The spill bucket should remain “free of water, dirt, debris”, etc., and there should be no cracks or torn connections. Visual inspections for dispenser sumps shall be conducted to identify “leaks, seeps, or drips” by opening the dispenser side panels. Clean all potential sources of leaks and clean the dispenser sumps, if required. For any concerns or for sites without dispenser containment sumps, contact the Environmental Compliance Office for assistance. Fines

Revised August 2007


Line tests are required for all pressure and U.S. suction systems.

Pressure systems require annual line testing. U.S. suction systems are tested every three years. Safe suction lines don’t require tests. Line tests are scheduled through the environmental compliance office. Service records will indicate the last test. Pressure systems (Arlington, Belfast, Gallatin,Jackson, Knoxville, Morristown, and Nashville)U.S. suction systems (McEwen, Johnson City, Newport) Fines

Revised August 2007


TDEC DUST inspections will occur.

TDEC (DUST) will conduct an inspection at your facility. Each UST facility has been inspected at least once; some more than once. DUST is on a continuing rotation of inspections. Please contact appropriate personnel (Environmental Compliance Director or Susan Christians) immediately if you have been notified of an upcoming inspection.

Fines

Revised August 2007


UST system alarms and failed tank leak tests must be addressed.

System alarms may occur for a variety of reasons and are usually minor. Please contact appropriate Susan Christians for assistance in addressing. Failed tank leak tests (or “errors”) generally occur for one of three reasons: 1) fuel levels are too low for a valid test (although fuel remains for pumping), 2) fuel pumping occurred during the weekly scheduled test (e.g., salt truck fueling in the winter), or 3) a recent fuel drop has occurred and the temperature of the fuel in the tank has not stabilized. (Because the tank gauge corrects for temperature, a small change may result in a failed test). Should there be any questions or concerns, please contact Susan Christians.

Revised August 2007


TDOT oversight during tank filling operations is required by TDOT policy.

A TDOT employee must physically oversee all tank filling operations conducted by fuel delivery personnel. This policy is a spill prevention measure and is included in all Spill Prevention Control and Countermeasure Plans (SPCCs) at TDOT facilities.

Revised August 2007


Diesel pump labels (stickers) are required to reflect the sulfur content of the diesel.

The federal government is mandating the production of ultra-low-diesel fuel (ULSD). In addition, all fuel retailers are required to label diesel pumps clearly identifying the type of diesel, either low-sulfur-diesel fuel (LSD) or ULSD.

Revised August 2007


Two (2) TDOT UST facility Points of Contact are necessary.

Each facility should have two (2) designated points of contact fully aware of UST compliance requirements. With only one point of contact, any event such as illness, retirement, redistribution of job assignments, etc., can significantly impact a facility’s UST compliance and may lead to fines. This practice is the result of several such potential situations across the state.

Fines

Revised August 2007


TDOT & Fuelman have distinct responsibilities.

As a review, TDOT “owns” the tanks and systems (dispensers, pumps, lines, Veeder Root, etc.) And, TDOT “operates” the UST system.

Fuelman owns the card reader systems and maintains the cardreaders. Fuelman also owns and supplies the fuel, which is then sold to TDOT through the Fuelman cards on a consignment basis.

Revised August 2007


Interesting Fact - fuel is cheaper when purchased at TDOT sites.

The cost of fuel for state vehicles with Fuelman cards is as follows. Fuel from TDOT sites is 3¢ less than from retail sites.The retail sale price (3¢ more) is constant. It does not depend upon which retailer, nor does it depend on the retailer’s posted price for the public. This applies to both unleaded and to #2 diesel.

Revised August 2007


Fuelman/Fleetcorp Contacts

Mansfield Oil – servicing all TDOT facilities (July 2014)

Card Reader service – Scarlett Skinner (678) 450-2340

Fuel Deliveries – Shontae Randolph (800) 843-0134 (ext. 2187) or Christy Williams (800) 843-0134 (ext. 2095)

Revised August 2007


TDOT & SAIC Contacts

TDOT Environmental Compliance Office

Barry Brown (Director): Crossville Office (931) 484-2817 Cellular phone (615) 969-6580

John Nichols: (615) 741-4732 (Office) (615) 804-4978 (Cell)

TDOT Fleetcorp/Fuelman Contract Administration

Steve Kirby (TDOT): (615) 741-5277

Environmental Compliance Questions/Concerns

Greg Olin (EnSafe) (615) 252-2815 or Kevin Louis (EnSafe) (615) 717-5892

Revised August 2007

Documents

TDOT Underground Storage Tank Compliance UST Compliance – Review Revised August 2007 Veeder Root Certificate Files Dispenser Annular probe Tank probe Fill