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Overview of 3rd Party Inspection Program for USTs

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Title: 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.

6
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.

7
Operational Tag
8
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.

9
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

10
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

11
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.

12
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.

13
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.

14
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.

16
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.

17
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.

18
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

19
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

20
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

21
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/

22
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
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