Joe Stapinski Senior UST Inspector (317) 727-6775 jstapins@idem.IN.gov UST Inspections Joe Stapinski Senior UST Inspector (317) 727-6775 jstapins@idem.IN.gov

UST Inspections

UST Inspections Issues UST Program Statistics UST Inspector Pre-inspection work and items checked during inspection Operator Training Most common compliance issues Delivery prohibition

UST Program Inspection Statistics FFY2015 Total number of Active and Temporary Closed UST’s in Indiana: 13,397

TOP 5 UST Violations for Fiscal Year 2015 1)Failure to Notify/ Register: 9.47% 2)Failure to provide proof of Financial Responsibility: 8.71% 3)Failure to provide Rel. Det. : 8.52% 4)Failure to provide proof of Fin. Resp.: 5.84% 5)Failure to Desig. UST Class A or B Op.: 4.69%

Pre-Inspection Preparation 1) VFC check on records for UST facility 2) Internal database check (ULCERS) 3) Research County GIS Online Sites for current owner information

What does the UST Inspector check during the UST inspection? Under dispenser containment and sensors All sumps and sensors Overfill protection and spill prevention equipment Leak detection equipment and records Other records of testing and maintenance Tank Lining inspection Tightness testing Corrosion Protection results, when required Equipment Repairs/replacement

Corrosion in sump due to water and metal pump

Cracked piping in containment sump

Improperly set up spill containment

Examples of Spill buckets that need replaced Cracked/damaged spill bucket Failing spill bucket

What does the UST Inspector check during the UST inspection? Tank fee registration Certification of Financial Responsibility Updated Notification Form- 45223 Secondary Containment, when required Interstitial monitoring test results, when required UST certified Operator Training Certificates for Class A, B, and C operators

Who must have Operator Training? All facilities must have an: A Operator B Operator C Operator, when required. A single person may be the A, B and C Operator At least one Certified Operator must be present during all times of UST operation The Operator(s) may be an employee or contractor Unattended and partially attended facilities are not required to have C Operators

How does someone become a Certified Operator in Indiana? Operators must be certified by creating an account and completing the on-line training on the IDEM’s Regulatory Services Portal at https://eauth.idem.in.gov/eAuth/eauthlogin.aspx?AAID=9002w.in.gov/idem/4999.htm IDEM does not give reciprocity for Certified Operators from other States IDEM offers only the certificate for C Operators. The training must be implemented by the A and/or B Operator, who then logs in to their account to create the C Operator certificates Make mention that training is free

Changes coming to UST Operator Training Ability to take and complete UST Operator Training 30 days prior to certificate expiring E-mail notification sent 30 days before owners/ operators A and B certificates expire. These changes will go into effect soon.

UST Operator Training Training is available on the UST webpage at https://eauth.idem.in.gov/eAuth/eauthlogin.aspx?AAID=9002w.in.gov/idem/4999.htm

Delivery Prohibition (Red Tag)

What is Delivery Prohibition? IDEM has authority to prevent delivery to a non-compliant UST system per IC 13-23-1-4 in two ways: 30-day Warning Letter followed by Red-tag with Temporary Emergency Order (TEO) for failure to maintain, failure to submit UST notification form, or failure to pay UST fees Immediate Red-Tag with TEO for failure to install equipment – corrosion protection, leak detection, overfill protection or spill prevention

Revisions to the Underground Storage Tank (UST) Regulations Signed on June 19, 2015 Effective October 13, 2015 unless your state has state program approval (SPA) with the USEPA - Indiana is an SPA state. Revisions will go into effect in Indiana after rule writing and public comment period have concluded and new revisions are adopted.

Operating Training Same as current rules from the 2005 Energy Act that went into effect in Indiana in 2009 Must designate A, B and C Operators and they must be trained

Secondary Containment 2015 Update is the same as 2005 Energy Policy Act- which requires new & replaced Double walled tanks & piping New dispensers require under-dispenser containment

Walkthrough Inspections Every 30 days on Spill Prevention Equipment & Release detection Equipment Annually Containment Sumps Hand held release detection equipment Keep Records 1 Year Implementation: Meet requirements no later than October 13, 2018

Spill Prevention Equipment Testing Tightness test every 3 years; or Use double-walled spill bucket and monitor interstitial space monthly Keep Records for 3 Years Implementation: Once rule revisions have been adopted by the state

Overfill Prevention Equipment Inspection Ensure overfill operates as intended Once every 3 years Keep to records for 3 years Implementation: On new Installations after state rulemakers have adopted new 2015 Energy Policy Act revisions

Containment Sump Testing Interstitial monitoring sumps Testing Tightness test every 3 years; Or Double –walled sump with monthly interstitial monitoring Keep Records for 3 years Implementation: Immediately after new 2015 Energy Policy Act revisions have been adopted by state rulemakers

Release Detection Testing Test Release detection equipment annually Ensure proper operation Keep Records for 3 years Implementation: First test must be conducted by October 13, 2018

Emergency Generator UST’s Deferred status removed Owners/operators must now perform release detection Implemention: Installations after 2015 Energy Policy Act revisions have been adopted by our state rulemakers

Field-Constructed Tanks (FCT) and Airport Hydrant Systems (AHS) Deferred status removed Release detection required New Subpart K Added Definitions of FTC & AHS Exceptions to secondary containment for some piping Partially excludes aboveground tanks

Product Compatibility Specific requirements for: >10 % Ethanol >20% Biodiesel Other fuels identified Notify implementing agency (IDEM) 30 days prior to storing fuel Keep records as long as product is stored Implementation: Begins after state rulemakers have adopted new 2015 Energy Policy Act revisions

Groundwater and Vapor Monitoring Site assessment Keep as long as groundwater or vapor monitoring is used for release detection Implementation: Must have record of site assessment by October 13, 2018

Flow Restrictors (Ball Floats) Not allowed on new installations Not allowed as a replacement for a defective overfill protection device

Internal Lining Permanently Close UST’s If a Periodic lining test fails; and Cannot be repaired according to a code of practice Applies to linings used as the sole method of corrosion protection No change of current UST policy/ rules in Indiana

Repairs Removed link that a repair must be associated with a release Added additional UST components that can be repaired Test within 30 days after repair Spill Overspill Secondary Containment equipment

Notification New Owners (should be doing this already) Notify implementing agency (IDEM) Within 30 days of becoming a UST Owner Previously deferred FCT’s and AHS’s Previously deferred UST’s must submit a notification if they hadn’t already Implementation will begin after state rulemakers have adopted 2015 EPA revisions

Interstitial Monitoring Results Interstitial monitoring alarms added as unusual operating condition under release reporting Interstitial monitoring can be used for release investigation and confirmation Implementation: Will occur following the adoption by state rulemakers of the 2015 Energy Policy Act revision ( However should be addressed if alarm is showing issue- ie) fuel alarms, etc.)

Reasons for 2015 Revisions Added newer technologies to the rule Updated codes of practice Removed references to old compliance deadlines Made editorial and technical corrections

UST Program Websites UST – www.IN.gov/idem/4999.htm