Issue link: https://read.dmtmag.com/i/703158
20 Oil Prophets Mark S. Morgan PMAA Regulatory Counsel The U.S. EPA published the final UST system testing and inspection rule on June 15, 2015. PMAA worked closely with the Small Business Administration (SBA), The White House Office of Management and Budget (OMB), key members of Congress as well as EPA's Office of Underground Storage Tanks to reduce compliance costs on tank owners to the greatest extent possible. The PMAA UST Task force was largely successful in this effort reducing annual costs of the final rule from $6,966 per site to $2,377 per site. Overall, total annual compliance costs on the industry as a whole were reduced from $1,533,172,720 billion to $530,444,189 million as a result of PMAA's efforts. One of the major provisions of the rule is a ne new requirement for monthly inspection of UST system components. The EPA initially proposed to have the walkthrough inspections start 90 days after the rule was finalized. PMAA was able to push the compliance date out three years to October 13, 2018 and reduce the scope and complexity of the inspections. In addition, PMAA is helping to revise the Petroleum Equipment Institute's RP- 900 industry standard for walkthrough inspections with the goal of making it a flexible and cost effective inspection guide for the petroleum marketing industry. While the walkthrough inspection requirement doesn't kick in for more than 2 years from now, petroleum marketers should start to become familiar with its requirements to plan future implementation. U.S. EPA UST System Walkthrough Inspection Requirements Beginning on October 13, 2018 owners and operators must conduct walkthrough inspections at their UST facility. The walkthrough inspection must meet one of the following options: Option 1: Every 30 days inspect spill prevention equipment and release detection equipment. IMPORTANT! The EPA walkthrough regulations only requires annual inspection of containment sumps and any hand held release detection equipment. When conducting the walkthrough inspection, inspect the following: Spill prevention equipment • Inspect for damage • Remove any liquid or debris • Inspect for and remove any obstructions in the fill pipe • Inspect the fill cap to make sure it is securely on the fill pipe Double walled spill prevention equipment with interstitial monitoring • Inspect for a leak in the interstitial area Release detection equipment • Ensure it is operating with no alarms or other unusual operating conditions present • Ensure records of release detection testing are reviewed and current Containment sumps (Inspect only once per year) • Inspect for damage, leaks into the containment area, or releases to the environment • Remove any liquid or debris Double walled containment sumps with interstitial monitoring • Inspect for a leak in the interstitial area Hand held release detection equipment (for example tank gauge sticks or groundwater bailers) • Inspect for operability and serviceability Option 2: Conduct walkthrough inspections according to a standard code of practice developed by a nationally recognized association or independent testing laboratory. The code of practice must inspect equipment comparable to option 1 above. The U.S. EPA regulations specifically cite PEI RP-900 as a suitable walkthrough standard. However, see IMPORTANT! Below. IMPORTANT! PEI RP-900 is the only walkthrough inspection standard currently available. PEI RP-900 requires a far more comprehensive walkthrough inspection than the new EPA regulations. If state implementing agencies adopt RP-900 as their walkthrough inspection standard, it will be significantly more burdensome on tank owners. It is important that state implementing agencies fully understand that although the EPA rule allows use of RP-900 to satisfy walkthrough inspections, they are not required to do so. REGULATORY CORNER New U.S. EPA Underground Storage Tank