One of the major changes in the EPA 2015 rules are requirements for UST owners/operators to perform and log monthly walkthrough inspections, and to maintain those logs for at least one year. Previously, some states only required quarterly or annual inspections, but now all states must require monthly inspections. Let’s take a moment to run through some of the new requirements.
Spill Prevention Equipment
- Check for damage
- Remove liquid or debris
- Remove obstructions in the fill pipe
- Check the fill cap to make sure it is secure
- Check containment sumps annually
- Check for leaks in the interstitial area of any double-walled spill prevention equipment
Release Detection Equipment
- Ensure it is operating with no alarms or other unusual operating conditions
- Ensure records of release detection testing are reviewed and current
- Check for damage, leaks into the containment area, or to the environment
- Remove any liquid or debris
- Double walled containment sumps with interstitial monitoring
- Check for a leak in the interstitial area
Handheld Release Detection Equipment
Examples of such equipment would be tank gauge sticks or groundwater bailers. These items should be checked for operability and serviceability.
Airport Hydrant Systems
In addition, owners and operators must inspect airport hydrant systems at least once every 30 days. If confined space entry according to the OSHA is not required monthly but may be required annually.
- Hydrant pits – Check for damage; remove liquid or debris; check for leaks
- Hydrant piping vaults – Check for hydrant piping leaks
Owners and operators must maintain the most recent year’s walkthrough inspection records, including:
- a list of each area checked
- whether acceptable or needed action taken
- a description of actions taken to correct issues
- delivery records if spill prevention equipment is checked less frequently than every 30 days due to infrequent deliveries
If this seems like a daunting task, we can help. Contact us to learn more about PASS Tools, our inspection and compliance management platform.
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Currently, there are no Underground Storage Tank (UST) facilities in the path of the fissures and lava flows from the Kilauea Volcano on Hawaii’s Big Island.
Kilauea erupted on May 3 resulting in several homes and businesses being destroyed, and more than 2,000 residents evacuated as fissures and lava flows continue to move further into the island. Earthquakes and aftershocks continue to rock the island.
According to a Hawaiian official, who oversees USTs in the island, the situation is “constantly changing but at last look, it was about five miles away (from the nearest UST facility).
“Years ago, lava was moving closer to a Pahala gas station. The owners/operators were asked to empty their tanks at that time but luckily that particular lava run did stop progressing towards that location.”
If the lava-flow advances, the department advises:
- Remove/pump out remaining gasoline, diesel or other petroleum products from underground storage tanks. Store in movable containers such as drums, tote tanks or tankers.
- Once the tanks are emptied they must be properly vented and capped
- Check with local distributors to see if they will accept the products for resale
- While the tanks are empty, release detection is not required.
Hawaiian officials are protective of their unique environment. Beginning in 2045 no UST facilities can be constructed within 100 yards of the shoreline. Existing USTs in this zone will still be permitted and operate.
PASS Training and Compliance is in the process of integrating new individual state Underground Storage Tank (UST) regulations with updated EPA rules. EPA rules, adopted in 2015, go into effect Oct. 13, 2018. Individual states have completed their updates or are in the process.
EPA rules stipulate that states must, at a minimum, comply with federal regulations. Many states have more stringent rules than the EPA. Several states, such as Illinois, had regulations in place that already comply with the new EPA rules.
In most states, current certifications and those issued in the interim are honored until new testing is in place then the certifications are valid until retraining is mandated or there is a violation. Check with state regulators if unsure.
PASS training structure is simple and easy to follow. The test is straightforward, with questions designed to enforce important information
EPA rules are the backbone of PASS training, with state-specific information inserted in each training. Every PASS chapter also contains questions specific to both federal and local regulations. The test also includes state-specific forms and information available to print out and use.
State regulators review PASS training, and either approve or suggest edits.
PASS tests offer convenience because they are online 24/7 and afford test-takers the ability to take the test at any location they choose. After taking and completing PASS Training, test takers are issued a certificate that meets state requirements.
In addition to the inexpensive tests for A/B owner and operators, PASS has a comprehensive training for C operators with specific information about the basics of a facility, and how to respond to emergencies. This training also includes certification.
For further information about PASS Training, check out our Training Marketplace.
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PASS Training & Compliance is recommending SIR as a backup system to reach compliance, according to Steve Roy, TotalSir. “If you want consistent and low-cost leak detection, SIR as a secondary reporting system is the way to go.”
It cuts across state lines for companies that are in several geographic regions and is a reliable source of reporting, Raymond Rees, PASS COO, said.
Federal and state regulations require that all underground tanks meet monthly monitoring requirements. Ninety-nine percent of all tank owners meet requirements in one of two ways:
- Automatic Tank Gauge (ATG)
- Statistical Inventory Reconciliation (SIR)
ATG’s monitor tanks, and sometimes fuel lines. This system conducts tests during the month to determine if the tank is leaking. There are a number of factors that can lead an ATG fail, an, are costly. Low-volume in a high throughput probe malfunction is one example.
SIR programs analyze monthly inventory data to find leaks or losses in the fuel delivery system or through the dispenser. The most common reason for a SIR to fail is poor inventory reporting. Accurate inventory is essential, and easy to do.
Why use SIR as Primary Compliance?
A large number of multi-site C-store chains choose SIR as their leak detection method, for multiple reasons:
- Uniform Compliance: Stores have various brands/models of ATG’s. SIR gives these companies a uniform compliance program.
- Low Cost: SIR requires no capital investment with service provided at a low monthly fee
- No extra work required: SIR use inventory data already available.
- ATG’s fail monthly leak detection without notice. SIR has no moving parts that can fail and only requires reliable inventory data.
- SIR tracks fuel from delivery to the dispenser, alerting management to leaks and losses, which can occur from meter drift, blenders settings, theft, or short deliveries.
SIR for backup Leak Detection Compliance
For those who want to use ATG for primary leak detection, TotalSIR can serve as a backup.
- If your ATG fails, many states allow a passing SIR report to be submitted in lieu of a tank tightness test, saving time and money.
- Since SIR tracks fuel from delivery to the dispenser, it alerts management to leaks and losses.
- Having a backup demonstrates to insurance companies, government regulators, your commitment to protecting the environment.
- It makes sense to have low -cost backup.
PASS is partnering up with TotalSir to include SIR in PASS Tools. Interested in more information contact PASS
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State Program Approval (SPA) is a difficult concept at first. But is not so hard once you wrap your head around it. Simply, SPA-approved states, take the lead. Non-SPA states rely on the EPA.
SPA is vitally important now because of revised federal and state rules going into effect this fall. Underground Storage Tank (UST) owners and operators need to know what SPA means and how it impacts their state regulations and ultimately their facility.
From the EPA’s website: “The state program approval (SPA) regulations set criteria for states to obtain the authority to operate in lieu of the federal program. State programs must be at least as stringent as EPA’s.”
States that have applied for and received federal SPA status will not have conflicting regulations. Once the state program is approved by the EPA, the state’s regulatory body has the lead role in UST program enforcement. In states without SPA approval, states work with the EPA on enforcement.
By law, all states and commonwealths, plus the District of Columbia, must have UST leak prevention and release detection regulations, spill response and cleanup programs, and an enforcement agency.
In states without SPA status, the state has a grant or cooperative agreements with the EPA. The state program is designated as the implementing regulatory body. While federal and state regulations apply in states without SPA, state regulations are generally just as stringent as, and often more stringent than EPA’s regulations.
So what does that mean for you concerning your state and the October deadline?
Basically, it allows enforcement deadlines to change. For example, the monthly inspection requirement can be pushed back to 2020 opposed to this October.
How do you know if this is going on in your state?
The EPA has created a list of entities with SPA status, which are the majority. However, most have to reapply for SPA status due to new 2015 regulations, and they have three years to complete their application as of October 2018. You can view the EPA’s list here, or for those more visually inclined, here is a SPA map:
If you need more information concerning your state or the guidelines contact your regulatory agency.
PASS UST operator training has these details for each state included in our training. Also remember, that PASS Tools is a complete UST compliance management software that to help navigate these waters.
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In July 2015, the EPA published its’s latest UST regulations and gave the local authorities and facilities three years for implementation. Some states have already put the regulations into place, but many states are still working the proposed new regulations through their systems; the state legislature or administrative body, public comment, and then publication.
These new rules go into effect October 13, 2018.
According to the EPA: “The revisions strengthen the 1988 federal underground storage tank (UST) regulations by increasing emphasis on properly operating and maintaining UST equipment. The revisions will help prevent and detect UST releases, which are a leading source of groundwater contamination. The revisions will also help ensure all USTs in the United States, including those in Indian country, meet the same minimum standards. This is the first major revision to the federal UST regulations since 1988.”
The 2015 UST regulations changed certain portions of the 1988 UST technical regulations. These current changes added new operation and maintenance requirements and addressed UST systems deferred in the 1988 UST regulation. Among the changes:
- Added secondary containment requirements for new and replaced tanks and piping
- Added operator training requirements
- Added periodic operation and maintenance requirements for UST systems
- Added requirements to ensure UST system compatibility before storing certain biofuel blends
- Removed past deferrals for emergency generator tanks, field-constructed tanks and airport hydrant systems
PASS Training is working with state regulators to update training, incorporating new federal and state regulations to prepare owner/operators for the October deadline. Additionally, PASS Training has an inexpensive Class C on-line operator training.
PASS has recently begun to roll out new training offerings, in conjunction with 360training, an online Austin, TX, national and international employee training/certification company, starting with tobacco seller training
This course addresses tobacco regulations focusing on keeping tobacco away from minors due to health risks. This training also discusses regulatory standards, as well as laws regarding the advertising and promotion of tobacco products.
Worried about your certificate? Don’t be, upon successful completion of the course and passing of the final exam, your certificate will be available for print.
PASS Training is easy to use: You can manage, order, and maintain your certificates easily. Whether you need Underground Storage Tank (UST) training; or alcohol, food management, or tobacco training, PASS has it.
Go to www.passtesting.com to sign up or take your training. The website is easy to navigate, and the trainings are inexpensive and address important necessary information.
If you want more information one of PASS’s specialists will be happy to help, just contact support.
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Our updated Georgia UST Operator Training courses are now live!
We received approval from the Georgia Department of Natural Resources this week to release out updated UST operator training courses. Both the Class C and Class A/B courses have been updated to reflect the new regulations going into effect this fall so please be sure to take our updated courses to make sure that you’ll be ready.
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The M-PACT Show is being held in Indianapolis again this year at the Indiana Convention Center, March 13-15th. PASS will be in attendance along with our partner MyTankInfo. If you’ll be at the show please be sure to stop by and visit Raymond and Kyle in Booth 921.
We are looking forward to talking about the new regulations going into effect this year, and how PASS Tools can help you stay on top of it all.
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I know not everyone is subscribed to our changelog, so I wanted to take a minute to highlight some of the updates we’ve gotten out the door over the last few months.
We are constantly launching new features, so if you would like to get notified about these updates as they are launched, subscribe to our changelog.
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