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

2. UST Inspections

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

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

5. 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%

6. 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

7. 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

8. Corrosion in sump due to water and metal pump

9. Cracked piping in containment sump

10. Improperly set up spill containment

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

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

13. 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

14. 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
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

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

16. UST Operator Training Training is available on the UST webpage at

17. Delivery Prohibition (Red Tag)

18. What is Delivery Prohibition?
IDEM has authority to prevent delivery to a non-compliant UST system per IC 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

19. 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.

20. 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

21. 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

22. 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

23. 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

24. 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

25. 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

26. 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

27. 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

28. 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

29. 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

30. 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

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

32. 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

33. 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

34. 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

35. 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.)

36. 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

37. UST Program Websites
UST –