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Dear UST Community –
Some of you may have already seen that ASTM recently published a new standard for spill bucket and sump testing https://www.astm.org/Standards/E3225.htm. We received several inquiries on whether this new standard meets the requirements of the federal UST regulation for spill prevention equipment or sump testing (40 CFR § 280.35). The 2015 UST regulation requires spill prevention and sump testing be done using a liquid, pressure, or vacuum test. The ASTM E3225-20 is visually based, and while a thorough visual check can always be beneficial, these procedures do not meet the requirements in 40 CFR § 280.35.
If owners and operators follow this standard and do not perform the correct testing requirements, they will be in violation of the regulatory requirements, and subject to appropriate enforcement. I am personally very concerned that some in our community might get confused by this. Please help us in spreading the word that these procedures do not meet the requirements in 40 CFR § 280.35.
To address this matter, we added two new questions and answers to OUST’s web-based UST Technical Compendium about the 2015 UST Regulation at https://www.epa.gov/ust/underground-storage-tank-ust-technical-compendium-about-2015-ust-regulation#spillbuckets (click on “Spill buckets, under dispenser containment sumps, containment sumps”).
We appreciate the continued dedicated effort and work by state and tribal UST programs; owners and operators; and others in the UST community in meeting all regulatory compliance requirements. As always, I thank you for all that you do to help us keep our environment safe from petroleum UST releases, which are a leading source of groundwater contamination.
If you have questions about this, or feedback on what EPA can do to better assist you in achieving compliance, please contact Carolyn Hoskinson (Hoskinson.Carolyn@epa.gov) or Tony Raia (firstname.lastname@example.org) at 202-566-1021).
Please click here and you will be re-directed to our PMCA website for COVID-19 resources & updates.
Due to the Coronavirus Situation, the April Operator Training Classes scheduled on 4/8/20 Leawood & 4/9/20 Manhattan, have been postponed until a later date. As soon as the dates are finalized, we will send an email to all those previously enrolled in the April classes informing them of the rescheduled dates.
We're experiencing very fluid times and things can change very quickly. If further developments occur we will re-evaluate the situation & Notify You Of Any Changes.
If your certificate is expiring before you can attend a class, KDHE is allowing some extension of time. You can view their criteria at the following link and file for that extension:
Call Lori at 800-530-5683 or Dixie at 785-845-4510 if you have any questions or concerns.
The new UST regulations for owners & operators of UST systems are still at the AG’s office and waiting for approval. If approved, KDHE will hold a 60-day Public Comment period and meet with the Legislative Research Committee. KDHE will keep the regulated community apprised of progress and will let you know as soon as possible. However, make sure you’re preparing yourself for the upcoming testing & inspections as they will be in effect and due on October 13, 2021. Contact your service provider to have these new testing requirements scheduled as soon as possible.
KDHE is also working on implementing a new database system called KEIMS (Kansas Environmental Information Management System).
Don’t Forget: AST information has also been sent out and is due to KDHE by 12/31/19.
UST monthly monitoring forms were also sent out to owners and operators. These forms, along with your inventory control forms, are due back to KDHE after the 1st of the year. Don’t forget to include the additional supporting information that is required to be turned in with these forms.
And lastly, the Walkthrough Inspections will be enforced and due by April 30, 2020 so make sure you’re doing these now. Also note that KDHE will ONLY except their Monthly Inspection Form and NO other.
IMPORTANT INFORMATION FOR UST OWNERS/OPERATORS:
The effective date of October 13, 2021 is a firm deadline required by KDHE and the EPA. Implementation of this new requirement is highly encouraged in order to avoid associated penalties for non-compliance. A penalty matrix is being developed and will be shared with facility owners and operators as soon as it is available. Please contact the KDHE Storage Tank Section at (785) 296-1678 if you have any questions or would like additional information concerning the new requirements.
The Storage Tank Section website can be found at www.kdheks.gov/tanks. The forms associated with the Walkthrough Inspection, and various other forms; including information for storage tank owners, owner/compliance forms as well as contractor forms can be found at: www.kdheks.gov/tanks/download.html.
The 2020 Jan-June UST Operator Training Schedule
Don't be caught out of compliance !!
Register as soon as possible as classes will fill up quickly !!
The Kansas Department of Health and Environment (KDHE) has a new requirement with regards to your UST Operator Training Certificate. Attendees in each class must now either fax (785-559-4260) or email (email@example.com) their certificate to KDHE after they have completed the class. In addition, they must also attach a list of facilities the certified person is responsible for. You can write them on the certificate or attach a separate list.
UST permits expire every year on July 31st.
A valid A/B Operator Training Certificate is required in order to get your UST permit.
Don’t get caught being out-of-compliance!!!
Check your certificate’s expiration date or call TMS to verify that your certificate is valid.
If you took the class in 2012 or after, you need to re-certify every 4 years from the exact date you took the last class.
TMS schedules 24 classes per year at locations all over Kansas. Classes are filling up quickly so schedule your class today. To find a class in your area go to our website at www.tankmgmt.net.
If you have questions please contact Lori Desch-Ranallo, Education Coordinator for TMS, or Dixie Challacombe at 785-233-1414.
Volume 27 Number 1 1st Quarter 2017
What Can We Do to Prevent Microbial Corrosion?
Reprinted from L. U. S. T. Line December 2015
Mahesh Albuquerque, Director of the Colorado Division of Oil and Public Safety column: ULSD’S DIRTY LITTLE SECRETS
If there was just one thing you could do, I would suggest taking an aggressive approach to preventing water buildup in tanks storing ULSD. This means ensuring that all tank-top fittings are tight, drain plugs in spill buckets are closed, and surface drainage prevents water from ponding over spill buckets or other tank-top sumps. It also means checking for the presence of water in tanks periodically, a few hours after every delivery to allow water to settle out, as well as daily after heavy precipitation events, or in areas with shallow groundwater. Water can be detected by certain ATG probes or by the old fashioned way with water-finding paste smeared on the end of a tank gauge stick. Any water accumulation over a quarter of an inch should be removed promptly. Here are some best management practices related to the operation of ULSD UST systems:
Prevent Cross-Contamination Transport Store ULSD in dedicated tanker compartments if possible to prevent cross contamination with ethanol blended gasoline.
Conduct Periodic Inspection and Maintenance Monitor daily for the presence of water in tanks, and conduct monthly walk-through inspections of dispenser cabinets, spill buckets, and sumps.
Conduct Periodic Internal Tank Inspections At least once every three years remove drop tubes, ATG probes, the STP, and line leak detectors to check for the buildup of corrosion and the functionality of monitoring equipment.
Minimize Stagnant Product in Tanks Emergency generator tanks and other tanks with low throughput are more susceptible to microbial growth as aged product degrades. The addition of appropriate stabilizers that contain antioxidants, biocides, and corrosion inhibitors may be necessary in these tanks.
UST systems storing ULSD provide a favorable environment for microbial growth, especially when the fuel is contaminated with water or ethanol or other food sources for microbes. Microbiologically influenced corrosion likely plays a significant role in the prevalence of the corrosion seen in ULSD UST systems across the country. The corrosion of metal presents a risk to the functionality of metal components. Through aggressive water management and the implementation of simple best management practices, microbial growth can be effectively managed to minimize the risk to UST functionality.
TMS UST Inspections Under Way
As part of the loss prevention program for the 3rd party liability insurance TMS annually conducts 150 UST facility inspections. The facilities are selected at random by region. As of this newsletter TMS has completed 26 of the 150 inspections for this year.
The purpose of the inspection is to aid the operator in understanding what a UST facility needs to do to be in compliance. Here are the four most cited issues we find during our inspections.
TMS sends out a inspection notice more than a week in advance of the inspection, telling the owner/operator the day we will be at the facility. The notice states what reports or documents we will need to see when we get there. If unattended facility we ask that the reports be sent to us.
Kansas Department of Health and Environment (KDHE) requires all UST operators to be certified as level A/B operators within 30 days of taking over operation of a UST facility. If you took the class in 2013 or after, you need to recertify every four years from the exact date you last took the class.
Below is a list of dates and location of the classes scheduled for 2017. You will find the full class schedule and registration on our website at tankmgmt.net.
April 4 City Limits Convention Center
2227 S. Range Avenue - Altir Room
April 5 Fort Hays State University
Memorial Union – Black & Gold Room
600 Park Street
April 6 Hilton Garden Inn Conference Center
410 South 3rd Street
May 3 Atrium Hotel & Conference Center
1400 North Lorraine Street
May 4 The Eldridge Hotel
June 6 Dodge City Community College
2501 North 14th
Student Union Board Room
Dodge City, KS
June 7 Best Western Wichita North
915 East 53rd Street North
June 8 Holiday Inn South
3145 South 9th
WHAT IS TANK MANAGEMENT SERVICES?
TMS provides loss control and risk management assistance to UST owners who have third party liability insurance through Great American Custom as part of the Kansas Underground Storage Tank Liability Plan.
TMS can provide you with information on USTs –leak detection methods, and Federal and State regulations. Call TMS toll free at 800-530-5683 during normal Central Time Zone office hours (8-5). In the Topeka area, please call 233-1414. On the web go to tankmgmt.net. David Engelken is available to answer your questions. This Service is free.
Tank Management Services, Inc. (TMS) has provided the written information in this newsletter for educational purposes to assist UST owners and operators in complying with current UST regulations and to assist them in reducing losses associated with releases from UST’s. The information is an outline and may not be complete. Owners and operators are responsible to insure that they are in compliance with all applicable laws. The Kansas Department of Health and Environment can provide detailed information on compliance. The application or use of the information provided is the responsibility of the individual user.
Tank Management Services, Inc.
115 SE 7th
Topeka, KS 66613
Tank Management Services, Inc.
P.O. Box 678
Topeka, KS 66601