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Compliance

A Few Words About Compliance...

The Division wants your facility in compliance. The Division is interested in creating the climate necessary for tank owners to get in compliance and remain in compliance. For some that simply means helping educate and inform. For others, it means a more rigorous approach, which may involve enforcement mechanisms possibly including civil penalties. Interestingly, tank owner commitment to the compliance challenge often determines the approach the Division must employ.

Tank owners who approach UST compliance seriously, with careful attention and commitment to required actions are most often closer to full compliance than those tank owners who take a more casual or even careless approach toward compliance. The Division believes that a tank owner who invests the time necessary to learn the requirements for operating and maintaining an underground storage tank safely and within the precepts of the regulations should be able to achieve full compliance with them. We believe that goal is within reach of every tank owner.

Compliance Tool Box

Compliance Tool Box is a collection of documents and references all designed to help tank owners learn about and achieve compliance with the Tennessee Underground Storage Tank rules and regulations. Copies are mailed to all Tennessee tank owners early in each year.

View the toolbox.

Tennessee Underground Storage Tank Owner Compliance Manual

The 2013 Tennessee Underground Storage Tank Owner Compliance Manual is now available. This manual was developed in an effort to help Tennessee tank owners understand the things they must do to achieve and maintain compliance for their underground storage tanks. It is written in easy to understand language, and contains a number of helpful checklists and useful forms. This Manual should provide answers to many of your compliance questions.

Click here for: Printable Version of Manual

Compliance Guidance Documents

CGDs set forth explanations of methods and the Division's expectations, practices, and procedures concerning release detection, corrosion protection and spill and overflow prevention. Their intent is to provide consistency across the State.

Leak Detection

Listing of various methods of leak detection, including Interstitial Monitoring, Manual Tank Gauging, Automatic Tank Gauging (ATG) and more, and how to determine which method you are qualified to use.

Cathodic Protection

Cathodic Protection is needed on tanks and piping that do not already have corrosion protection.

New Spill Bucket and Dispenser Inspection Forms

Effective June 19, 2007 new rules require tank owners to begin inspecting spill buckets and dispensers at UST facilities. Spill buckets must be inspected monthly and dispensers must be inspected quarterly and a record made of those inspections. These records must be maintained showing the last 12 months of these inspections. The Division has developed the following forms which may be used for these inspections.
Monthly Spill Bucket Inspection Log (CN-1286)
Quarterly Dispenser Inspection Log (CN-1287)

E-85 Information and Forms

Prior to putting a UST system designed to store ethanol blended fuels greater than 10% ethanol into service, tank owners must complete and submit an Ethanol Equipment Compatibility Checklist  and a Statement Of Compatibility indicating the UST system components will be compatible with the product stored.

View the E-85 forms

Useful Tools

There are some useful tools on EPA’s website and that of other state agencies. These consist of publications that were developed by those agencies to assist with UST compliance. Please use them for reference purposes. Please also be aware that states may have different requirements and if you have questions about whether a certain required record or action applies in Tennessee, contact the Tennessee Division of Underground Storage Tanks to find out.

Record keeping Requirements

This link will lead you to information you may find useful in trying to understand all the different record keeping requirements.

Line Tightness Testing of Flexible Plastic Piping

The Division of Underground Storage Tanks will not accept line tightness tests performed on or after March 1, 2006, on flexible plastic piping by methods which have not been certified for flexible piping in the evaluations submitted to the National Work Group on Leak Detection Evaluations (NWGLDE).

Important Information on Flexible Plastic Product Piping

At the request of the Petroleum UST Board, in April 2003 the division distributed a Bulletin alerting tank owners and others associated with the petroleum industry to the possibility of potential problems with some flexible plastic product piping. The letter quotes from a similar letter the Mississippi UST program sent their tank owners listing a series of "early warning signs" which could indicate conditions which could cause possible piping problems.

Clarification of Implementation Date in EPA Secondary Containment Guidelines

On November 15, 2006 EPA issued final Guidelines on Secondary Containment as required by the Energy Policy Act of 2005. These Guidelines mandate that states choose between installing secondary containment or requiring financial responsibility on manufacturers and installers as an additional means of protecting groundwater. Tennessee, along with the majority of other states, has chosen to require secondary containment. The Guidelines contain an implementation date of February 8, 2007 which has led to some confusion among tank manufacturers and installers. The Division of Underground Storage Tanks also issued a letter which explains that the February 8, 2007 date is not a federal deadline for secondary containment, and that the Division will be promulgating state regulations which will contain a deadline for implementation of secondary containment. Final EPA Secondary Containment Guidelines

Stan Boyd's letter containing more information.

Inspections

It is important for you to know that Tennessee is conducting an active inspection program and if your facility hasn't been inspected yet, it may be overdue for a visit. Some facilities have been visited more than once, so be aware that someone from the Division will come calling on you eventually.

Preparing for a Compliance Inspection

For some people, notice of a visit from a compliance inspector from the Tennessee Division of Underground Storage Tanks is stressful. Many tank owners or their representatives go into an inspection unprepared. They may spend considerable time while an inspector is on site looking for records or other paperwork. The purpose of this document is to help the tank owner or operator better prepare for a compliance inspection.

View the preparation document (pdf format)

Facility Inspection Form (CN-0983)

This will let you know the kinds of things division inspectors look for and records you will be expected to have.

A Few Words About Inspectors....

If you have never had a UST inspection performed, you may have some apprehension about the inspection itself and about inspectors. Compliance inspectors are trained professionals. They are taught how to identify and recognize compliance violations. You will find inspectors more than willing to go the extra mile to share their knowledge and experience in helping you solve any compliance problems you may have. They will not know every answer but they will be willing to help you contact someone who can answer your questions. Inspectors cannot give you advice on business decisions you must make such as what brand of equipment to purchase or install, or which vendor to use. You should see them as allies and you will find that they can be just that. However, a thorough inspection may turn up violations, and if that happens, just remember that the inspector is simply doing his or her job to the best of their ability.

Enforcement

Complying with environmental regulations is an important part of protecting public health and the environment.  Environment and Conservation offers assistance for complying with the law, monitors compliance and takes enforcement action when necessary to assure compliance with environmental regulations in Tennessee.  Click here for the Departments Enforcement Order page where you can find information on the Divisions current enforcement actions.

Occasionally the Division receives questions regarding site maintenance issues. Our rules address some maintenance issues, but many other many important aspects of good operation of a fueling facility are not addressed in our rules. Such operational issues could be termed "Best Management Practices" (BMPs).

The Division has located several documents that describe some of these BMPs and they are presented below for the information they contain. Some of these documents contain handy checklists which can aid in helping track all appropriate steps.

TDEC-TN's Office of the Attorney General Enforcement Initiative on Underground Storage Tanks - PPT by Karen Stachowski for TSPE/ACEC Annual Meeting on Aug. 25, 2011.

Maintenance and Best Management Practices

The Division has located several documents that describe some Best Management Practices (BMPs) and are presented here. Some of these documents contain handy checklists which can aid in helping track all appropriate steps.