2021-2022 Underground Storage Tank Compliance Calendar Owner ID Facility ID Developed and published by the Kansas Small Business Environmental Assistance Program Paid for by the Kansas Department of Health and Environment (KDHE) New testing requirements The July 2020 update to Kansas UST regulations included new requirements for testing that must be performed for the first time by Oct. 13, 2021: • Spill prevention equipment (spill bucket) — must be tested at least once every three years (unless double-walled and inspected no less frequently than every 30 days as required by the walkthrough inspection) and within 30 days of repair. • Containment sumps — if using interstitial monitoring for the piping release detection then (under dispenser containment, pump sump and piping transition sumps) — must be tested at least once every three years and within 30 days of repair. • Overfill prevention (automatic shutoff, ball float valves, or overfill alarm) — must be tested at least once every three years and within 30 days of repair. If you haven’t had these tests performed yet, • Release detection equipment (ATG and schedule them as soon as possible. As the other controllers, probes and sensors; automatic line leak detector; vacuum deadline approaches, scheduling contractors pumps and pressure gauges; and hand- will become more difficult and more expensive. held electronic sampling equipment) — all applicable parts must be tested at least once annually and within 30 days of repair. These tests must be performed by a contractor licensed in Kansas for the testing SBEAP has several new resources to help you with environmental compliance being done. A list of Kansas-licensed including a manual for UST Owners and Operators, a guidance document and two contractors can be found at www.kdheks. short videos explaining how to complete the Walkthrough Inspection Checklist, gov/tanks/download.html. Records of these and a document to help new owners of USTs identify their requirements. Find these inspections must be retained for three years. resources and more at www.sbeap.org/storage-tanks. Technical assistance and site visits are also available — contact SBEAP at 800-578-8898 or [email protected]. AUGUST 2021 Sunday Monday Tuesday Wednesday Thursday Friday Saturday 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 1 2 3 4 Shear Valves Shear valves, also known as fire or impact valves, are a critical piece of safety equipment for USTs. Located beneath the dispenser cabinet, these valves are designed to close off the piping between the tank and the dispenser in case of a fire or impact to the dispenser, preventing further release of product. The Kansas Fire Marshall’s Office requires all dispensers to have shear valves installed. Shear valves should be anchored to the concrete island beneath the dispenser, not to the dispenser itself. Visually inspect the premises daily by checking for obvious signs of a release or indicators that there could be a release soon, such as puddles, active leaks, and wear on equipment such as hoses. Update your Inventory Control records daily by checking the level in the tanks, reading the meters on the pumps, and calculating overs and shorts. SEPTEMBER 2021 Sunday Monday Tuesday Wednesday Thursday Friday Saturday 29 30 31 1 2 3 4 5 6 7 8 9 10 11 Labor Day 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 1 2 Overfill Overfill protection prevents overfilling of the tank by reducing or stopping flow of product during delivery or by sounding an alarm to indicate the tank is nearly full so that the delivery person knows to stop the flow. Typical overfill protection consists of an automatic shut-off device (an in-tank float valve) or an alarm attached to an ATG, which continuously measures the fuel level. Any tank that receives one or more deliveries of more than 25 gallons at a time must be equipped with one of these devices. Overfill protection equipment must be tested by a Kansas-licensed contractor every three years. Check your overfill protection regularly. An impatient delivery driver may obstruct automatic shut-off valves to ensure they can leave their entire load. Have you been trained in the operation of UST’s? Managers in Kansas are required to have Class A/B training, and anyone involved in daily facility operations needs Class C training, including cashiers and anyone whose duties might include watching for problems with equipment such as dispensers or who might need to respond in an emergency. Though ball valves have been used previously, new installations are no longer allowed, and any already in place should be replaced by an approved method upon failure. OCTOBER 2021 Sunday Monday Tuesday Wednesday Thursday Friday Saturday 26 27 28 29 30 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Columbus Day 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Halloween 31 KEIMS KDHE is now using an online data management system called KEIMS for permitting, forms and other paperwork previously submitted via mail or email. Facilities can set up their accounts to allow access to owners, operators, contractors and more, so that different parties can submit forms such as repair certifications by contractors. Fees can also be paid online. For more information, instructions or to access the system, go to www. kdheks.gov/bar/doe-keims-panels.html. Use of KEIMS is not currently required for permitting and other compliance paperwork but may be in the future. Different bureaus use KEIMS SBEAP has several new resources to help you with environmental compliance differently — the processes including a manual for UST Owners and Operators, a guidance document and two may look different for short videos explaining how to complete the Walkthrough Inspection Checklist, different bureaus and setting and a document to help new owners of USTs identify their requirements. Find these your account up with one resources and more at www.sbeap.org/storage-tanks. Technical assistance and site bureau does not mean it is visits are also available — contact SBEAP at 800-578-8898 or [email protected]. set up with others. NOVEMBER 2021 Sunday Monday Tuesday Wednesday Thursday Friday Saturday 31 1 2 3 4 5 6 7 8 9 10 11 12 13 Veterans Day 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Thanksgiving Day 28 29 30 1 2 3 4 Hanukkah begins Inventory control (and what it can do for you) Good inventory control benefits your business as well as the environment. It helps you to identify losses and other issues in your tanks, whether they are leaking or not, and it allows you to catch the leaks quickly, whereas relying on SIR alone could mean you don’t find out until weeks later. Inventory control is also required by KDHE regardless of your release detection method — SIR records are not a substitute for proper inventory control records. Documented inventory control doesn’t just show you don’t have a release — it proves that you are actively monitoring your system for leaks. If you have more than a 0.5% difference in your inventory control, you should start looking at possible sources of loss. Temperature differences, theft, meters or ATGs in need of calibration, or even parking a delivery truck such that it is not level can cause discrepancies. Always use gross gallons for inventory control. Net gallons The most common reason for discrepancies in inventory is temperature-corrected to 60 degrees Fahrenheit, so it control is meters in need of calibration, and calibration could be very inaccurate with varying temperatures. issues can show a loss of product in your records. Note: Effective October 2021, Inventory Control will no longer be required for standby generator tanks, but these tanks are required to have monthly monitoring. Acceptable methods of monthly monitoring include the use of an automatic tank gauge (ATG), interstitial monitoring of tanks with secondary containment, or statistical inventory reconciliation. Manual tank gauging can also be used for tanks with a capacity of 2,000 gallons or less, though periodic tank tightness testing is also required for tanks with a capacity of over 1,000 gallons. An ATG or interstitial monitoring equipment must be installed by a Kansas-licensed contractor. Lists of contractors and SIR vendors are available on KDHE’s website at www.kdheks.gov/tanks/download/currently_licensed_ust_installers_removers_tightness_testers.pdf and www.kdheks.gov/tanks/ download/SIR_Vendors.pdf. Tip: Interstitial Monitoring must be used for monthly monitoring for USTs installed after July 2013. DECEMBER 2021 Sunday Monday Tuesday Wednesday Thursday Friday Saturday 28 29 30 1 2 3 4 5 6 7 8 9 10 11 Hanukkah ends 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Christmas Eve Christmas Day 26 27 28 29 30 31 1 New Year’s Eve Walkthrough Checklist The Walkthrough Inspection Checklist must be completed for every active UST in Kansas. This is required to renew the permit for a tank, and failure to complete inspections and documentation could prevent the permit from being renewed. Some tasks on the checklist are required monthly, meaning they must be completed no more than 30 days apart, and some are only required annually. The inspection must be conducted by an A/B operator or by a C operator under the supervision of an A/B operator. The operator should initial each task as it is completed. Not all tasks on the checklist will apply to each tank, so be sure you understand which ones apply to your system.