The Environmental Protection Agency (EPA) has recently released new revisions to the 1988 Regulations (40 CFR part 280) which encompass multiple changes to inspection requirements. One of the most notable changes is the requirement for monthly inspections of facilities and components to ensure the proper operation and maintenance of UST systems.
Walkthrough inspections must be conducted every 30 days and include:
- Visual checks of the spill prevention equipment for damage and to remove liquid or debris; checking for and removing obstructions in fill pipes; checking for leaks in the interstitial area for double wall spill prevention equipment with interstitial monitoring; checking release detection equipment to ensure there are no alarms or unusual operating conditions; reviewing release detection testing records to ensure they are current. These inspections are to help protect owner(s) and operator(s) by detecting potential defects and failures in their UST systems before an actual failure or release of product occurs.
- New requirements to test spill prevention equipment (using vacuum, pressure, or liquid methods) every three years unless the equipment is double wall spill prevention equipment and both walls are periodically monitored for integrity. Integrity monitoring must be performed at least once every 30 days.
- For overfill equipment, the rule requires that the equipment be inspected to determine if it is operating properly and that it will activate at the correct level of fill. Inspections must be performed once every three years.
- New rules require annual operation and maintenance tests on electronic and mechanical components of release detection equipment to ensure they are operating properly. This includes automatic tank gauge systems and other controllers, probes and sensors, automatic line leak detectors, vacuum pumps and pressure gauges, and handheld electronic sampling equipment associated with vapor and groundwater monitoring.
- The rules include a three-year testing requirement using one or more methods including vacuum, pressure, or liquid for containment sumps used for interstitial monitoring of piping unless the containment sumps are double wall and the integrity of the walls is periodically monitored. Visual integrity monitoring must be performed at least once every 30 days.
These inspections are to be documented and the current condition of the devices recorded. This provides a baseline for future inspections and can help determine a maintenance schedule before any parts fail.
On top of the monthly inspections there are also new annual inspections that are required. These inspections include:
- Checking containment sumps for damage and leaks to the containment area or releases to the environment; removal of liquid and debris; and checking for leaks in the interstitial area for double wall containment sumps with interstitial monitoring.
- Checking hand held release detection equipment (e.g., groundwater bailers and tank gauge sticks) for operability and serviceability.
For full details of all the new revisions visit http://www.epa.gov/oust/fedlaws/revregs.html
InterSpec LLC can help you stay in compliance with these new regulations. InterSpec LLC’s trained and certified technicians are experts on UST systems and how each component in the system works. By performing monthly inspections for you, InterSpec LLC can evaluate, track and record any changes in your system that maybe out of compliance and that could cause a release. Data is collected along with photographs of each part so that there is proper documentation. The data and photos are put into a report format that’s easy to understand and satisfies federal, state, and local reporting requirements. InterSpec’s UST experts can review your specific requirements, determine the specific implementation timeframes and record-keeping obligations, and provide your with recommendations on how best to meet regulatory requirements and avoid spills, releases, and fines. We can and will tailor our recommendations to your facility’s specific UST systems and applicable legal and regulatory requirements.
For more information please contact InterSpec LLC here, at firstname.lastname@example.org or call 757-622-6299 (or 1-800-546-7853).