Underground Storage Tank Walkthrough Inspection Requirements: Arkansas Oil Marketers Association Canopy Article

Mitchell, Williams, Selig, Gates & Woodyard, P.L.L.C.
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Mitchell, Williams, Selig, Gates & Woodyard, P.L.L.C.

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Arkansas Department of Environmental Quality (“ADEQ”) staff authored an article in Issue 3 of the Arkansas Oil Marketers Association (“AOMA”) publication The Canopy titled:

Walkthrough Inspection Requirements (“Article”)

ADEQ states that the Article is intended to provide an inspector’s perspective on the new underground storage tank (“UST”) requirements for monthly walkthrough inspections.

USTs are utilized at hundreds of thousands facilities nationwide to store petroleum and chemical products. A variety of design changes and installation techniques have been developed over the years to minimize the chance of leaks or spills.

The United States Environmental Protection Agency (“EPA”) published certain revisions to the petroleum UST regulations in 2015. These were the first comprehensive revisions of the federal UST rule since 1998.

The changes included:

  • added secondary containment requirements for new and replaced USTs and piping;
  • added operating training requirement;
  • added periodic operation and maintenance for UST systems;
  • added requirements to UST system capability before storing certain biofuel blends;
  • removed past deferrals for emergency generator tanks, field construction tanks, and airport hydrant systems; and
  • updated codes of practice.

Arkansas has primacy and has been delegated UST regulatory authority for many years. Therefore, as a delegated state, Arkansas was required to amend its rules to meet the federal baseline requirements. Arkansas’s UST regulations are found in Arkansas Pollution Control and Ecology Commission Regulation 12. As ADEQ notes, this regulation is being revised to reflect the 2015 federal changes.

October 13, 2018, is the deadline for meeting the remaining UST requirements found in the 2015 UST revisions. However, ADEQ states in the AOMA Article that:

Although Regulation 12 will be revised to meet the federal October 13, 2018, deadline, ADEQ is exercising discretion, as a state approved program, and is providing until October 13, 2021, to comply with the new requirements. Any new equipment or procedures must be in operation prior to October 13, 2021, to avoid being red tagged. ADEQ is eager to assist with any questions you may have. Contact your district inspector or call us at 501-682-0999.

The ADEQ AOMA Article undertakes a review of the walkthrough inspection that must be conducted every 30 days. The benefits of this inspection are addressed, which are stated to include:

  • Detection of problems associated with equipment that is prone to degradation, damage and malfunctioning
  • Detecting small problems before they become big problems
  • Many items are already being checked

Detail is also provided on the items associated with the walkthrough inspection, such as:

  • Release detection system
  • Spill buckets
  • Water in USTs
  • Site-appropriate response supplies
  • Sumps

A number of other items are also addressed.

As to who can conduct the walkthrough inspection, ADEQ staff notes:

The new federal UST regulation language is not specific about who can and cannot conduct 30-day walkthrough inspections, allowing state programs to use discretion. The person who would know the most about your facility would be the trained class A/B operator. Some facilities may choose to hire a qualified third-party contractor to conduct the walkthrough. Facilities that already use a third-party contractor for monthly release detection monitoring can add the new 30-day walkthrough inspection requirements for an additional cost. Anyone with sufficient knowledge, training, and experience is able to do the 30-day walkthrough inspection.

Also addressed is the type of forms that can be used and how long they should be kept. A sample checklist is also provided.

A copy of the Article can be found here.

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