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UST O&M—Changes in the Works
Historically, the Environmental Protection Agency’s (EPA) UST regulations were focused on improved equipment, with not a lot of attention given to O&M practices. However, based on more than 20 years of regulatory experience, the EPA acknowledges that a higher level of O&M, in addition to better equipment, is required to protect the public and the environment.
One of the most fundamental O&M practices the EPA is revising in the regulations is walkthrough inspections, which are already adopted as a monthly requirement in 12 states. One state, California, has had the requirement longer than any other and indicated that, according to UST inspectors and industry sources, “the monthly inspections decreased the number of violations found, reduced the frequency and duration of release detection alarms, prompted better record keeping, and resulted in overall better operations at the UST facility.”
As a result, the EPA proposed walkthrough inspections at least once every 30 days, beginning immediately after the effective date of the final rule. The EPA based its new requirements on the Petroleum Equipment Institute’s Recommended Practice 900, Recommend Practices for the Inspection and Maintenance of UST Systems, and provides the following three options.
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Option 1 – Conduct O&M walkthrough inspections that, at a minimum and as appropriate to the facility, check the following equipment:
Spill Prevention Equipment
- Open and visually check for any damage;
- Remove any liquid or debris;
- Check each fill cap to make sure it is securely on the fill pipe; and
- If secondarily contained with continuous interstitial monitoring, check for a leak in the interstitial area.
Sumps and Dispenser Cabinets
- Open and visually check for any damage, leaks to the containment area, or releases to the environment;
- Remove any liquid (in contained areas) or debris; and
- If contained areas are secondarily contained with continuous interstitial monitoring, check for a leak in the interstitial area.
Monitoring/Observation Wells
- Check covers to make sure they are secured.
Cathodic Protection
- Check to make sure impressed current cathodic protection rectifiers are on and operating; and
- Ensure records of 3-year cathodic protection testing and 60-day impressed current system inspections are reviewed and current.
Release Detection
- Check to make sure the release detection system is on and operating with no alarm conditions or other unusual operating conditions present;
- Check any devices, such as tank gauge sticks, groundwater bailers, and handheld vapor monitoring devices, for operability and serviceability; and
- Ensure records of release detection testing are reviewed monthly and are current.
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Option 2 – Conduct O&M walkthrough inspections according to a standard code of practice developed by a nationally recognized association or independent testing laboratory that are comparable to the specific requirements listed above.
Option 3 – Conduct O&M walkthrough inspections developed by the implementing agency that are comparable to the specific requirements listed above.
In addition, the EPA also proposed that UST owners and operators keep records of O&M walkthrough inspections for 1 year. Each of these records should include:
- A listing of each area that was checked;
- The status of each area checked (i.e., whether the area was acceptable or required some action be taken); and
- A description of any actions taken to correct issues or problems found during the O&M walkthrough inspection.
Because these are proposed requirements, the EPA requested comments on a number of related issues, such as whether the 30-day frequency is adequate, effective date to begin walkthrough inspections, requirements for specialized training, additional appropriate codes of practice, appropriateness of the requirements, and other issues related to specific equipment-related requirements. Although no exact date for the Final Rule is set, the EPA anticipates promulgation in late 2014.