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The U.S. Environmental Protection Agency (EPA) recommends conducting these inspections at least monthly and, while not as thorough as an operations and maintenance (O&M) inspection, each inspection should be recorded by date and initialed.
9 Steps for Inspecting Your USTs
Step 1. Release Detection System—Check the release detection system to ensure it is working properly. The EPA recommends running a self-test of the automatic tank gauging system (ATG) to verify that it is functioning properly or checking the manual dipstick for wear or warping.
Step 2. Spill buckets—Check all spill buckets to ensure each is clean, empty, and in good operational condition.
Step 3. Spill and overfill response supplies—Perform an inventory and inspection of all emergency spill response supplies, including checking for deterioration and malfunctions. Restock any supplies that are low to ensure an adequate supply is on hand.
Step 4. Overfill alarm—Test the alarm to ensure it works correctly and that it can be seen or heard by a delivery person.
Step 5. Impressed current cathodic protection system— Confirm that the system is turned on and that the rectifier is checked at least every 60 days.
Step 6. Fill and monitoring ports—Inspect all fill and monitoring ports and any other access points to ensure covers and caps are sealed tight and locked.
Step 7. Dispenser hoses, nozzles, and breakaways— Inspect the condition of each hose, nozzle, and breakaway looking for signs of deterioration, obvious leakage, and improper functioning.
Step 8. Dispenser and dispenser sumps—Open and inspect each dispenser, including visible piping, fittings, and couplings, for signs of leakage. If any water or product is found, it should be removed and disposed of properly. Any debris found in sumps should also be removed.
Step 9. Pumping sumps—Inspect all visible piping, fittings, and couplings for signs of leakage. Remove any debris, water, or product found and dispose of properly.
Join us for the UST Repairs, Inspection, Maintenance and Testing webinar on June 3 to learn how to satisfy UST monthly inspection requirements. Learn more.
UST Inspection Requirements
The following Table outlines the federal inspection requirements and the required frequency for USTs. Keep in mind that your state or local municipality may have additional requirements.
Table: Federal UST Inspection Requirements
| Corrosion Protection | All cathodic protection systems must be tested within 6 months of installation and every 3 years thereafter, and within 6 months of a repair, according to a nationally recognized association code practice. UST systems with compressed current cathodic protection systems must also be inspected every 60 days to ensure equipment is running properly. |
| Repairs | The repaired portion of the UST system must be monitored monthly for releases. |
| New Tank Installation | Owners and operators of new UST systems must ensure that all new tanks and piping are properly installed by providing a certification of compliance on the UST notification form within 30 days of bringing such tank into use that the installation has been inspected and certified by a registered professional engineer with education and experience in UST system installation, or the installation has been inspected and approved by the regulatory agency, or another approved method of ensuring compliance. |
| Leak Detection—Tanks | Product inventory control, interstitial monitoring, automatic tank gauging, vapor monitoring, groundwater monitoring, and UST piping inspection must be conducted monthly for leak detection.
Manual tank gauging. Tank liquid level measurements must be taken at the beginning and ending of a period of at least 36 hours during which no liquid is added to or removed from the tank. |
| Leak Detection—Piping | A UST piping line tightness test must occur every 3 years. |
Understand Your UST Insurance Coverage
Every now and then a carrier will drop its line of underground storage tank (UST) coverage. When that happens, if you own or operate a UST, you may pause to consider if any current policies you hold or any new policies you seek provide the needed coverage.
Insurance is one of the primary ways UST owners/operators meet their financial responsibility (FR) for release response and corrective action under the Resource Conservation and Recovery Act (RCRA) and the U.S. Environmental Protection Agency’s (EPA) implementing regulations. But research by EPA’s Office of Underground Storage Tanks (OUST) reported that many holders of UST insurance have an incomplete understanding of the coverage their policies provide and become aware of the details only after a claim is made against them.
One area that appears to be elusive for policyholders is the retroactive date, or the date after which an accidental release will be covered under an in-force claims-made insurance policy. Retroactive dates in some policies are the date of the UST installation. But others may be long after installation—OUST found one policy where the retroactive date was 40 years after installation! Any release that occurs before a retroactive date will not be insured, a fact that comes as a shock to too many UST policyholders.
Tip: It is essential to carefully discuss your policies with your insurance agents or brokers to make sure you fully understand the coverage you are purchasing or have purchased.
UST Repairs, Inspection, Maintenance and Testing: Best Practices for Ensuring UST Operator Compliance
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Where Can I Get UST Insurance?
The EPA provides a booklet listing insurance companies, agents, and brokers that provide UST insurance.
UST insurance coverage can be provided as a new policy or as an endorsement to an existing policy. A new policy must conform to certificate-of-insurance standards at 40 CFR 280.97. An endorsement must conform to EPA’s endorsement criteria, also described at 40 CFR 280.97. EPA’s booklet provides model language for both types of insurance documents.
The Agency states that the lists were developed based on information provided by entities that are “willing to deal with UST insurance.” The lists are not intended to be comprehensive because there are other companies, agents, and brokers that have not yet identified themselves to the EPA. The EPA also notes that the lists do not constitute endorsements by the Agency of the products or services provided by the insurance entities.
Note: UST coverage must meet both federal and state requirements. You should contact your state insurance regulatory agencies to be sure that any insurer, broker, or agent is authorized by the state to provide the type of insurance you are seeking.