Department of Environment & Conservation
Robert Martineau, Commissioner

Compliance Corner is a new feature of the Tennessee Division of Underground Storage Tanks Web Page and will highlight items of interest in UST Compliance.

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.

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).

>>> Click for memo from UST Assistant Director Lamar Bradley with more information (pdf format)

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.

>>> Click for more details, including the full text of the original letter.

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.

 

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.