Overview of 3 rd 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.htm#probation

11. LD Probation – Don’t 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 ADEC’s 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. Don’t 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.htm#ust

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/operator’s 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.htm#ust • The National Work Group on Leak Detection Evaluation’s (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@dec.state.ak.us • Linda Nuechterlein: 907-269-7530 • E-Mail: Linda_Nuechterlein@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@ahtnagov.com