Overview of 3rd Party Inspection Program for USTs

1
Overview of 3rd Party Inspection Program for
USTs
2
Why An Inspection Program

• The ADEC observed numerous problems with the
  management of underground storage tank (UST)
  systems throughout the state. 
• These problems were usually the result of poor
  operation and maintenance practices, and/or
  general equipment failure. 

3
Inspection Requirement

• In 1999, the ADEC adopted new regulations which
  required the inspection of regulated UST systems
• Starting in 2000, tank owners were required to
  have an operational inspection of USTs at their
  facility every three years to receive a "tag" to
  operate the tanks.

4
What tanks require inspection?

• Inspection is required for all currently in use
  and temporarily out of use tank systems.
• This includes all government USTs.
• This includes tanks as well as piping.
• Only tanks subject to UST regulations need to be
  inspected. Residential heating oil tanks are
  exempt.

5
When Should Tanks Be Inspected?

• Once every 3 years, an owner or operator must
  hire a certified UST Inspector to ensure the UST
  system is in compliance with release detection,
  spill and overfill prevention and corrosion
  protection.
• "In compliance" means that all your equipment is
  present, maintained and operating properly.
• Tanks may be inspected from April 30th to August
  31st.
• Inspectors can inspect, repair and fill out the
  inspection report.

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How does the "Tag" work?

• Once ADEC reviews your inspection results, we
  will issue you an operating tag or renewal decal
  within 30 days.
• All inspection forms are due to ADEC no later
  than September 30th.
• By November 1st, the tag or renewal decal must be
  posted where your petroleum distributor can see
  it prior to delivery, or you may not permit the
  delivery of fuel into the tank.

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Operational Tag
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How do I find an Inspector?

• ADEC no longer maintains a list of persons
  qualified to perform inspections but provides a
  link to the Division of Occupational Licensing
  at
• http//www.state.ak.us/dec/spar/csp/inspector.htm
  
• It is the responsibility of the UST Owner or
  Operator to pay for the inspector.

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UST Operations and Maintenance Manual

• ADEC has created a UST Operations and Maintenance
  Manual
• This manual provides a comprehensive, easy to
  read list of requirements, a series of
  operational checklists, and general advice on how
  to operate and maintain your UST system on a
  routine basis.
• This can be downloaded from the link
• http//www.state.ak.us/dec/spar/csp/o_m.htm

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What happens if I don't have 12 months of leak
detection records?

• If you pass inspection, but do not have 12 months
  worth of leak detection records, further
  follow-up will be required.
• ADEC has drafted a Fact Sheet with the terms of
  LD Probation. It is available on our web page at
  http//www.state.ak.us/dec/spar/csp/ust.htmproba
  tion

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LD Probation Dont Forget

• Both you and your inspector must sign the LD
  Probation Agreement on the Operational Inspection
  Form Certification Section (See Inspection Form)
• Request that your inspector consolidate and
  review LD records and submit to ADEC in one
  packet.
• Review LD Probation Fact Sheet.

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What happens if my tank cannot pass inspection,
Or if my tank doesn't get inspected?

• Your tank will not be allowed to receive fuel
  after your current tag expires. Once the tank has
  successfully passed all inspection requirements,
  you will receive a decal to renew your existing
  tag.
• You will not need to do an inspection if you
  decommission the tank, in accordance with 18 AAC
  78, prior to the inspection due date.
• If your expired tag is not renewed, your facility
  name will be posted on ADECs Storage Tank web
  site, so that delivery drivers know your tank is
  not permitted to receive fuel.

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Deadlines

• Check your existing tag(s) to see when it
  expires.
• If it expires Oct. 31, 2004, then have your tank
  inspected between April 30 to August 31, 2004
• All inspection forms are due to ADEC no later
  than September 30, 2004.
• Post your renewal tag decal by November 1st in a
  conspicuous location where the fuel driver can
  see it, or you may not permit the delivery of
  fuel.

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What Have We Learned?

• ADEC inspections have shown that many UST
  systems, even those with new tanks, are not being
  operated properly.
• Often equipment is found not functioning, broken,
  or simply missing.
• Many tank owners still cannot detect leaks,
  spills or rust at their UST systems

15
Common Violations

• The first inspection cycle is now complete and
  the most common violations are
• no Leak Detection records
• no Cathodic Protection records
• spill buckets full of debris, water, and fuel
• sumps contain water and
• sump sensors are set too high.

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We have also learned. . .

• Most tank systems have had at least one problem
  discovered during inspection that required
  fixing. The sooner you inspect, the more time you
  have to correct any problems.
• Inspect Early Those who wait until the end of
  the inspection season may have difficulty finding
  an available inspector, and having repairs
  completed timely.
• To save time and , be prepared for the
  inspector. Have as-built drawings, Leak Detection
  and Cathodic Protection records available. Dont
  waste time during the inspection looking for
  paperwork.

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Underground Storage Tank Facility and Leaking UST
Search

• To obtain a list of tanks at your facility, use
  the UST database search at this link.
• http//info.dec.state.ak.us/SPAR/CSP/UST/Search/
• Have this list of tanks ready for the inspector.
  It must be included with the inspection form when
  submitted to ADEC.

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Paperwork Streamlining

• Check your facility print-out to make certain
  information is accurate.
• Some changes can be made on the tank printout,
  such as tank capacity, product or LD method.
• Provide an explanation of the change on the
  print-out.
• Both owner and inspector must initial each
  change.
• Other changes, such as tank status (i.e. TOS or
  closed), or change of ownership will require
  filing new forms which can be obtained at
  http//www.state.ak.us/dec/spar/csp/forms.htmust

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Financial Responsibility

• Starting January 1, 1998, UST owners and
  operators were required to show annual proof of
  Financial Responsibility (FR) to ADEC
• State or federal government owners are exempt
  from showing proof of FR requirements
• An owner is required to have FR to be in
  compliance, but failure to submit FR will not
  cause you to fail your operations inspection

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Financial Responsibility cont.

• If you have not yet submitted proof of FR to
  ADEC, submit ASAP or with your inspection form
• Maintain a copy of your FR documents on-site or
  at the owner/operators work place in case you
  are audited
• For additional information, visit this link
  http//www.state.ak.us/dec/spar/csp/fr.htm

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More Web Page Links Resources

• Storage Tank Home Page http//www.state.ak.us/dec
  /spar/csp/tanks.htm
• Third Party Inspection http//www.state.ak.us/dec
  /spar/csp/third.htm
• Forms http//www.state.ak.us/dec/spar/csp/forms.h
  tmust
• The National Work Group on Leak Detection
  Evaluations (NWGLDE) List of Leak Detection
  Evaluations for USTs is available at this link
• http//www.nwglde.org/

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Agency Phone Contacts

• David Allen (907) 269 - 7537
• Email David_Allen_at_dec.state.ak.us
• Linda Nuechterlein 907-269-7530
• E-Mail Linda_Nuechterlein_at_dec.state.ak.us
• Jackie Poston, Environmental Protection Agency
  (EPA) 271-5083
• If need, Sharon Sadlon at Ahtna Government
  Services, Inc 907-561-2705
• E-Mail ssadlon_at_ahtnagov.com