DEEP: UST Notice of Violation

Underground Storage Tank Notice of Violation (NOV)
 
Below are action steps for timely and appropriate response to UST NOV: 
  1. Read and make sure you understand the alleged violations and required corrective actions listed in the NOV.
  2. Stop all activities that might result in further environmental harm (i.e. causing spills and leaks into the soil and/or groundwater).
  3. Perform immediately the corrective actions listed in the NOV.
  4. Fill out and sign the Compliance Statement Form associated with the NOV.
  5. Within 30 days of receipt of the NOV, submit to the UST NOV Compliance Office the following:
    • A signed compliance statement;
    • An action plan and a time schedule to reach compliance if more than 30 days are required to perform corrective actions; and
    • All other documents supporting the corrective actions taken including, but not limited to test results and photographs.
Submittals by email are encouraged, DEEP.USTNOV@ct.gov, or by fax at (860) 424-4061, or by CD or paper to:
   UST NOV Compliance Office
   DEEP
   79 Elm Street
   Hartford, CT 06106-5127 
 
Other documents related to UST NOV:
 
Commonly observed UST violations and the appropriate corrective actions:
 No. Violation Description  Corresponding Citation  Corrective Action 
 1 Failure to perform annual cathodic protection test on tanks and/or piping. 103(b)(2)(A) & (e)(2)(A) Cathodic protection tests are required annually. Impressed current cathodic protection systems shall be inspected and readings recorded monthly. 
 2 Failure to perform annual LLD test.  104(f) Line leak detectors require an annual test of operation.
 3 Failure to perform annual tightness test for pressurized piping. 104(f) & 104(c)(2)(A) Line tightness tests are required annually if this is primary method of line release detection.
 4 Failure to perform a compliant release detection method.  104(e) Compliant monthly release detection for tanks is required.  View the regulatory citation for acceptable methods.
 5 Failure to make available records of release detection compliance.  104(g) Release detection records shall be maintained on-site and immediately available for inspection.  With written approval, records greater than 5 years old may be kept off-site.
 7 Failure to maintain a sensor containing sump free of liquid.  104(f)(3) Clean sump and keep the sump free of liquid and debris in order to maintain interstitial line leak detection.
 6 Failure to perform daily measurements and weekly reconciliation.  104(e)(4)(B) Daily measurements & weekly reconciliation instructions and UST Inventory Reconciliation Form.  
 
Please do not hesitate to contact the UST NOV Compliance Office with any questions regarding an NOV or appropriate response.  You may contact the UST NOV compliance Office by phone at (860) 424-3886, fax at (860) 424-4061 or email at DEEP.USTNOV@ct.gov.  For any information that is to be submitted to the UST NOV Compliance Office, include the associated NOV number.
 
Content Last Updated on April 4, 2012