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June 27, 2014
Avoid these top five UST inspection violations
By Dave Leiper, Legal Editor

The most common violations found during underground storage tank (UST) inspections involve deficiencies in release detection for piping and tanks, according to a recently released report by the Association of State and Territorial Solid Waste Management Officials’ (ASTSWMO) Tank Subcommittee UST Task Force.

The ASTSWMO UST Task Force solicited information for fiscal year 2012 from all 50 states, five territories, and the District of Columbia in an effort to determine the violations most often encountered during UST compliance inspections. Responses were received from 35 states and territories, covering nearly 59,000 UST inspections and more than 37,000 violations. A review of the data identified the following top five inspection violation issues:

 

  1. Release Detection—Piping: 9,174 total violations, 51 percent of which were for failure to annually test the automatic line leak detector, with an additional 19 percent for failure to perform an annual line tightness test.
  2. Release Detection—Tanks: 6,826 total violations, 41 percent of which were for failure to maintain proper records, and 39 percent for failure to perform monthly monitoring.
  3. Spill Prevention: 4,258 total violations, 64 percent of which were for a nonfunctional spill device, and 34 percent for failure to clean and maintain the spill device.
  4. Corrosion Protection:  2,811 total violations, 49 percent of which were for failure to perform the 3-year cathodic protection (CP) test, and 20 percent for failure to maintain and operate the CP system properly.
  5. Operator Training: 2,697 total violations, 48 percent of which involved the Class A/B training requirement, 23 percent involved the general training/testing requirement, and 12 percent involved the Class C training requirement.

The federal Energy Policy Act of 2005 added requirements for the EPA and states receiving funding under Subtitle I of the Solid Waste Disposal Act to conduct on-site inspections of each regulated UST at least once every 3 years. With inspections on the rise, it’s a good time to review your UST system(s) compliance to avoid common violations. This Basic Checklist for USTs, Leak Detection for Underground Piping Guidance, and BLR’s Class C UST Operator Training Guidance audio presentation can help prepare you in advance of your next inspection.

View the ASTSWMO UST Task Force report here.
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