Regulatory Developments

Are You Prepared for the UST O&M Deadline?

October 2018 is the final deadline for complying with the remaining requirements of the federal 2015 underground storage tank (UST) amendments. If you are not already in compliance with these amendments, it is time to start preparing. Today we will look at the operation and maintenance (O&M) requirements for which you must conduct the first test or inspection by October 13, 2018.

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According to the EPA, while information on sources and causes of releases show that releases from tanks are less common than they once were, releases from piping and spills and overfills associated with deliveries have emerged as more common problems. The Agency attributes the lack of proper operation and maintenance of UST systems as a main cause of release from these areas. The final 2015 UST regulation places an emphasis on ensuring that equipment is properly maintained and working.

O&M

The 2015 UST regulations add requirements for periodic walkthrough inspections, testing of spill prevention equipment, inspections of overfill prevention equipment, testing of containment sumps, and testing of release detection equipment. Operators must conduct:

  • Walkthrough inspections that look at spill prevention equipment and release detection equipment every 30 days and containment sumps and handheld release detection equipment annually.
  • A spill prevention equipment test for liquid tightness; alternatively, operators may use a double-walled spill bucket with periodic interstitial monitoring. Tests must be conducted at least every 3 years.
  • An overfill prevention equipment inspection to ensure that equipment is set to activate when regulated substances reach the appropriate level in the tank. Inspections must be conducted at least every 3 years.
  • Testing of containment sumps used for piping interstitial monitoring for liquid tightness; alternatively, a double-walled containment sump with periodic interstitial monitoring may be used. Tests must be conducted at least every 3 years.
  • Testing of release detection equipment, including line leak detectors, to ensure proper operation. This is an annual requirement.

Walkthrough Inspection

When you conduct walkthrough inspections of your USTs, there are a number of required inspections you must perform. Make sure you can check off and date these inspections. Remember, your first inspection must be performed by October 13, 2018.

Every 30 Days. You are required to perform these inspections every 30 days unless your UST system receives deliveries at intervals greater than 30 days. In that case, you may check your spill prevention equipment before each delivery.

  • Visually check spill prevention equipment for damage. Remove liquid or debris.
  • Check for and remove obstructions in fill pipe.
  • Check fill cap to ensure it is securely on fill pipe.
  • For double-walled spill prevention equipment with interstitial monitoring, check for a leak in the interstitial area.
  • Check release detection equipment to ensure it is operating with no alarms or unusual operating conditions present.
  • Review and keep current release detection records.

Annually. You are required to perform these inspections annually.

  • Visually check containment sumps for damage and leaks to the containment area or releases to the environment. Make sure to remove debris and liquid in containment sumps.
  • For double-walled containment sumps with interstitial monitoring, check for leaks in the interstitial area.
  • Check handheld release detection equipment, such as groundwater bailers and tank gauge sticks, for operability and serviceability.

Recommended. In addition to the required activities in the walkthrough inspections, it is recommended that you:

  • Inspect all fill or monitoring ports and other access points to make sure that the covers and caps are tightly sealed and locked.
  • Inventory and inspect the emergency spill and overfill response supplies. If the supplies are low, restock the supplies. Inspect supplies for deterioration and improper functioning.
  • Look for significant corrosion on the UST equipment in containment sump areas.
  • Inspect dispenser hoses, nozzles, and breakaways for loose fittings, deterioration, obvious signs of leaks, and improper functioning.

You must keep O&M walkthrough inspection records for 1 year. Records must include a list of each area checked, whether each area checked was acceptable or needed action taken, a description of actions taken to correct an issue, and delivery records if spill prevention equipment is checked less frequently than every 30 days because of infrequent deliveries.

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