EPA Regulations: Spotlight on Inspections

Another change enacted by the EPA in the recent regulatory updates is the monthly and annual walk-through inspection requirement.  As with the new operator training requirements, owners/operators have until October 13, 2018 to comply with the inspection requirements.  Several states (California, Florida, Nebraska, North Dakota, and Utah, to name a few) already require Class A/B operators to conduct monthly walk-through inspections at their UST facilities.  Here's what you need to know about the new UST inspection requirements.

[bs_label type="info"]Implementation Timeline[/bs_label]

No later than October 13, 2018, owners/operators will need to comply with monthly and annual walk-through inspection requirements.

[bs_label type="info"]Monthly Inspections[/bs_label]

40 CFR §280.36(a)(1)(i) requires owners/operators to visually inspect spill prevention equipment and release detection equipment at least once every 30 days.  At a minimum, each inspection must include the following.[bs_row class="row"]
[bs_col class="col-sm-6"]Spill Prevention Equipment:

  • Visually check for damage
  • Remove liquid or debris
  • Check for and remove obstructions in the fill pipe
  • Check that fill pipe cap is secure
  • Check for leaks in interstice (for double-walled equipment with interstitial monitoring)

[bs_col class="col-sm-6"]Release Detection Equipment:

  • Check to ensure equipment is operating with no alarms or unusual operating conditions present
  • Ensure records of release detection testing are reviewed and current


[bs_label type="info"]Annual Inspections[/bs_label]

40 CFR §280.36(a)(1)(ii) requires owners/operators to visually inspect the following at least once each year.[bs_row class="row"]
[bs_col class="col-sm-6"]Containment Sumps:

  • Visually check for damage, leaks to the containment area, or releases to the environment
  • Remove liquid or debris from contained sumps
  • Check for leaks in interstice (for double-walled equipment with interstitial monitoring)

[bs_col class="col-sm-6"]Hand-Held Release Detection Equipment:

  • Check devices such as tank gauge sticks or groundwater bailers for operability and serviceability


[bs_label type="info"]Overwhelmed?  PASS Tools Can Help![/bs_label]

40 CFR §280.36(b) requires that owners/operators maintain records of walk-through inspections for one year.  These records must include a list of each area checked, whether each area was acceptable or needed corrective action, a description of corrective actions taken, and delivery records (for facilities with infrequent deliveries).  If conducting these inspections, gathering all of this data, recording it, and maintaining copies of your records sounds overwhelming, PASS can help!  You can use PASS Tools with any internet-connected device (even your smartphone!) to input, store, and print all of the required inspection data.  And, if a state inspector shows up but you have misplaced your printed records, you can retrieve and print them from PASS Tools from your computer in the office.Get PASS Tools →