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February 15, 2016
USTs: Inspections 101
By Emily Remmel, JD, Legal Editor

Aging tanks, muddled inspections, and inadequate recordkeeping can increase the probability for underground storage tank (UST) spills and releases. The U.S. Environmental Protection Agency (EPA) confirms that more than 6,000 releases are discovered annually, and as of 2015, more than 525,000 total releases from USTs have occurred. UST owners and operators that fail to conduct adequate inspections or keep orderly inspection records can face hefty enforcement penalties.

In June 2015, the EPA issued the first revisions to the federal UST regulations in almost 27 years. In addition to the customary monthly and annual inspection and testing requirements, these new EPA regulations require owners and operators to conduct periodic walkthrough inspections.

Using a comprehensive inspection checklist will help keep your facility’s inspection records organized.

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How to conduct the 30-day “monthly” walkthrough inspection

Although this walkthrough inspection is referred to as occurring “monthly,” it is required every 30 days. When conducting a 30-day walkthrough inspection of spill prevention equipment, the owner and operator must:

  • Visually check for damage;
  • Remove any liquid and debris;
  • Check for and remove obstructions in fill pipe;
  • Check fill cap and ensure it is securely on the fill pipe; and
  • Check for leaks in the interstitial area (only applies to double-walled equipment with interstitial monitoring).

When conducting a 30-day walkthrough inspection of release detection equipment, the owner and operator must:

  • Check that release detection equipment is functioning with no alarms or unusual conditions, and
  • Ensure records of release detection testing are reviewed and current.

Owners and operators of UST systems that are unmanned and in remote sites can use release detection equipment monitoring only if the detection system is in communication with the equipment.

How to conduct an annual walkthrough inspection

This walkthrough inspection occurs annually and is for equipment that is more cumbersome to inspect. Each year, owners and operators are required to inspect containment sumps and handheld release detection equipment. When conducting an annual walkthrough inspection of a containment sump, the owner and operator must:

  • Visually check the sump for damage;
  • Check for leaks in the containment area and potential releases to the environment;
  • Remove any liquid and debris; and
  • Check for leaks in the interstitial area (only applies to double-walled equipment with interstitial monitoring).

When conducting an annual walkthrough inspection of handheld release detection equipment, the owner and operator must inspect handheld release detection devices for operability and serviceability (e.g., tank gauge sticks and groundwater bailers).

Who can conduct a walkthrough inspection?

Walkthrough inspections can be carried out by a facility’s owner and Class A or Class B operator or by a qualified, independent third party. It is imperative to conduct the inspection according to a standard code of practice developed by a nationally recognized association or an independent testing laboratory or to check with the implementing agency for a specific inspection standard.

How do I keep my records?

Owners and operators should keep comprehensive checklists of all inspected tank systems for at least 1 year. The records must include a list of each area inspected, must indicate whether the area was deemed acceptable or if corrective action was warranted, and must contain a description of the corrective action. Owners and operators of UST systems that receive less than one delivery per month must keep the dates of regulated substance delivery and dates of the walkthrough inspections.

UST owners and operators should refer to these checklists for a comprehensive inspection regime. In addition, owners and operators should check with their implementing agency for supplementary inspection requirements.

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