Work Order No. 1004, Task 2, Subtask a
Quick Turnaround Request (QTR) No. 1

State Walkthrough Underground Storage Tank (UST) Inspections

Using contact information found at http://epa.gov/oust/wheruliv.htm, Skeo Solutions contacted nine states: New Hampshire, Rhode Island, Delaware, South Carolina, Wisconsin, New Mexico, Utah, Colorado, and California, to confirm that the state requires periodic walkthrough inspections. In addition, Skeo Solutions asked the following questions:

   1. What are the areas at the facility the operators must inspect during the walkthrough inspection?
   2. How long would the state estimate it takes operators to conduct a single facility walkthrough inspection?
   3. Are walkthrough inspections typically performed by the facility operator or by a third-party contractor?
   4. Does the state require owners/operators to keep records of the walkthrough?
   5. If yes to question 4, how long does the state require owners/operators to keep a record of the walkthrough inspection?
   6. If yes to question 4, how much detail is in the walkthrough inspection record? [For example: Is it a checklist?  Or just a piece of paper saying that the walkthrough was conducted?]
   7. If yes to question 4, is the state seeing significant compliance issues with owners/operators having the required walkthrough inspection records during their inspections?
   8. Does the state believe their walkthrough inspection program is effective?  Why or why not? [Seek examples of how or why the state believes their program is or is not effective (for example, compliance rates increased or the state is seeing fewer releases).]

Table 1 provides the detailed responses from each state. All states contacted require periodic walkthrough inspections. In general, the states require similar areas to be checked during walkthrough inspections and estimated that the amount of time to conduct a single facility inspection would depend on the size of the facility. Walkthrough inspections in these states are performed by both facility operators and third-party contractors. Smaller operators tend to do the inspection themselves. All states contacted require walkthrough inspection records to be kept. Most of the states contacted require records to be kept for 12 months, while others require records to be kept for 3 years. The walkthrough inspection records are mostly checklists, with varying levels of detail across the states. The states experience different levels of compliance with inspection record requirements, and states with more recent implementation of the requirements seem to experience lower compliance. Most states believe their walkthrough inspection programs are effective, but some states with newer programs believe it is too soon to assess effectiveness.

Table 1. State Responses Regarding Walkthrough Inspections
State
Responses
New Hampshire
Matthew Jones
Oil Compliance and Enforcement Subsection Chief
Contacted on January 10, 2013
   1. The inspection checklist requires operators to look at the vents, vent caps, spill buckets, fill adaptors, fill adaptor caps, dry break adaptor, dry break adaptor caps, dry break poppet valve, dispenser hoses, dispenser nozzles, dispenser cabinets, oil transfer and dispensing areas, and the release detection/leak monitoring consoles.
   2. The length of time it takes for a walkthrough inspection depends on the size of the facility, but the average time should be 10 to 15 minutes.
   3. Walkthrough inspections are typically performed by the facility operator.
   4. Yes, the state requires owners/operators to keep records of the walkthrough inspections.
   5. The inspection records are required to be kept on file for a minimum of 3 years.
   6. The walkthrough inspection record is a checklist that can be used for multiple tanks. On the checklist, operators can also indicate whether repair is necessary and whether corrective action was completed. 
   7. Most facilities are conducting these inspections and they have the records readily available when requested.
   8. Yes, the walkthrough inspection program is effective. If owners/operators are able to conduct these inspections, then they decrease the chance of a potential spill or release. The inspections help examine easily accessible areas where releases can occur as well as the monitoring system for the tanks.  Unfortunately, the state does not have any real data specific to these particular inspections, but the overall sentiment is that these can only help. 
Rhode Island
Jillian Thompson
Sanitary Engineer
Contacted on January 22, 2013
   1. During a walkthrough inspection, owners and operators must check the leak detection system; spill containment basins; dispenser hoses, nozzles and breakaways; dispenser and dispenser sumps; overfill alarm; cathodic protection system; alarm conditions; groundwater monitoring wells and tank pad observation wells; and spill and overflow response supplies.
   2. A single facility walkthrough inspection would take about 20 minutes.
   3. Walkthrough inspections must be done by the Class A/B certified operator designated for the facility. This may be the owner, the operator, or a third-party contractor.
   4. Yes, the inspection checklists must be kept as routine records at the facility. 
   5. The state requires the inspection records to be kept for 3 years. 
   6. The walkthrough inspection record is a detailed 11-item checklist, with space to make comments and list any corrections made. 
   7. The state estimates that it has had a 40 percent compliance rate with its monthly inspection record requirement. This number has been generated from inspections done since September 2012.
   8. The requirement was initiated on August 1, 2012, so it is too soon for the state to assess the program's effectiveness. The state hopes to have a better sense of the effectiveness by August 1, 2013. 
Delaware
Suzanne Halter
Environmental Scientist
Contacted on January 14, 2013
   1. During a walkthrough inspection, owners and operators must monitor the condition of all dispensers, dispenser sumps, access ports, and sumps. Inspections must include the removal of dispenser covers; checking of all fittings, couplings, and filters; and checking for the release of regulated substances. Sump covers must also be removed to check for an indication of release of regulated substances, and all access ports need to be inspected to make sure that covers, caps, and adaptors are tightly sealed. Finally, all spill bucket covers must be removed to ensure that all of them are empty and free of debris, water, and regulated substances.
   2. The length of time it takes for a single facility walkthrough inspection depends on the facility.
   3. Walkthrough inspections are typically performed by the facility operator.
   4. Yes, the state requires walkthrough inspection records to be kept.
   5. The state requires the walkthrough inspection records to be kept for 3 years.
   6. The inspection record consists of a table, with columns for dispenser buckets, sumps, access ports, and spill buckets.
   7. No, the state is not seeing significant compliance issues with owners/operators having the required walkthrough inspection records during their inspections.
   8. It is too soon to tell if the walkthrough inspection program is effective.
South Carolina
Trey Morgan
Technical Advisor
Contacted on January 10, 2013
   1. Operators must check their leak detection methods, whether through statistical inventory reconciliation (SIR) or with an automatic tank gauge (ATG). They also need to test the product pipe through product testing. Operators must also inspect their cathodic protection techniques every 3 years for galvanic reactions and every month for impressed current systems. Operators must also open and/or check all dispensers, the tank top, vapor recovery units, spill buckets, and vent lines.
   2. For the average 3-tank, 3 to 4 dispenser facility, the state estimates that it would take 1 hour for the inspection. For larger facilities with around 25 dispensers, the state estimates the inspection process would be 3 to 4 hours.
   3. Approximately 85 percent of the inspections are performed by the owner's representative, and 15 percent of them are performed by a third-party contractor.
   4. Yes, the state requires owners/operators to keep records of the walkthrough inspections.
   5. The owners/operators are required to keep inspection records for the previous 12 months.
   6. The walkthrough inspection record is a state-provided checklist and log. 
   7. Yes, the state is seeing significant compliance issues with owners/operators having the required walkthrough inspection records during their inspections because they are still in the first year of this requirement. Many people still have not opened the packet of materials regarding these required inspections, and the familiarity with the requirement is still fairly low. Mr. Morgan expects compliance to take 2 to 3 years.
   8. Yes, the walkthrough inspection program is effective for those who participate. The state has not seen a significant increase in compliance rates, but it had a fairly high compliance rate to begin with, due to its strong rapport with owners and operators. Rather than performing inspections every 3 years, the state conducted annual inspections and the inspectors know the owners by name.
Wisconsin
Sheldon Schall
Chief of Storage Regulatory Services
Contacted on January 10, 2013
   1. For walkthrough inspections, the operators follow the Petroleum Equipment Institute (PEI)'s RP500 "Recommended Practices for Inspection and Maintenance of Motor Fuel Dispensing Equipment" and RP900 "UST Inspection and Maintenance" documents. 
   2. The length of time required for a walkthrough inspection varies with the size of the facility, and may range from an hour at a small site with a couple tanks to a whole day for a truck stop.
   3. Large, multi-station operators tend to hire third-party contractors, and some of them are contracting with third parties to serve as their A/B operator.
   4. Yes, the state requires walkthrough inspection records to be kept.
   5. The state requires inspection records to be kept for a minimum of 12 months.
   6. The walkthrough inspection record is a checklist, and is complemented by the annual 10778 inspection form. The 10778 inspection is a test done by a contractor to test the functionality of the overfill prevention, drop tube, ATG, emergency valve, and sump sensors.
   7. Wisconsin has had the walkthrough inspection requirement in place for several years, and compliance is much better than it was 2 years ago. Now, owners/operators expect inspectors to ask for records. Further, the state made 3-ring binders available to any facility that wanted them for record keeping.
   8. Yes, the walkthrough inspection program is very effective. In particular, the 10778 functionality assessment gets the contractor on site to examine and document everything to eliminate non-compliance issues. Compliance has always been pretty high in Wisconsin, with 88.4 percent of facilities in compliance with all release prevention requirements, 84 percent in compliance with all release detection requirements, and 77 percent in compliance with both sets of requirements. For these statistics, compliance applies to items beyond what is required at the federal level, and also includes tanks that are temporarily out of service.
New Mexico
Kalvin Martin
Program Manager
Contacted on January 11, 2013
   1. During the walkthrough inspection, operators must inspect the ATG and cathodic protection rectifier, which are usually located indoors. They must also look inside dispenser doors, inspect tank top appurtenances by looking in all manholes, look in tank risers that are accessible, and check for water in tanks. 
   2. A single facility walkthrough inspection would take around an hour. An inspection could take twice that long at a larger facility, such as one with large manhole lids, or one with 4 or 5 tanks.
   3. Walkthrough inspections are typically performed by the owner, who is usually the operator.
   4. Yes, the state requires walkthrough inspection records to be kept.
   5. The state requires walkthrough inspection records to be kept for 12 months.
   6. The walkthrough inspection record is a checklist with specific items such as piping and tank release detection, tank water levels, overfill alarms, and water in sumps to be checked.
   7. Of the facilities that have been inspected recently, over 50 percent have had the previous 12 months of records on file.
   8. If the owner/operator actually conducts the walkthrough monthly, it seems to be moderately effective, as the state staff has heard stories about owners/operators finding seeping flexible piping and sumps full of water by conducting the walkthroughs. However, it is hard to correlate compliance with the number of releases. 
Utah
David Wilson
Environmental Scientist
Contacted on January 10, 2013
   1. The physical inspection includes visual inspection of spill containment, overfill, vapor recovery ports, containment sumps (i.e., dispenser, submersible, and transition), submersible pumps, and all dispensers. The facility's current leak detection and corrosion protection records are also verified.
   2. Inspection of an average-size facility should take 30 to 45 minutes.
   3. It is the B operator's responsibility that the inspection is accurate and done correctly, whether it is completed by themselves, another employee, or a third-party contractor. 
   4. Yes, the state requires owners/operators to keep records of the walkthrough inspections.
   5. The length of time these records need to be kept is not addressed in the rule. This is probably an oversight that will be addressed in a future rule change. These records needed to be kept beginning January 2012.
   6. A specific checklist created by the State of Utah must be used for all monthly inspections.
   7. It has taken a while to get the majority of facilities to start doing the monthly inspections and doing them correctly. Those doing the inspections are generally in significant operational compliance (SOC).
   8. Yes, the walkthrough inspection program is effective. Those who do the monthly walkthroughs seem to be able to identify problems and have them resolved more quickly than those who do not. Containment sumps and spill buckets that Mr. Wilson personally inspected have had fewer problems with debris and water when the operator has completed monthly inspections.  Overall compliance rates have increased overall from about 10 percent to about 85 percent in the last year.
Colorado
Zach Hope
Petroleum Compliance Supervisor
Contacted on January 18, 2013
   1. During a walkthrough inspection, the tank area must be visited in order to check spill buckets, measure for water in the tank, and check vapor recovery equipment (if applicable). The dispenser area must be visited to check hanging hardware. The ATG must also be checked for functionality and alarm status.
   2. The length of time it takes to conduct a single facility walkthrough is 30 minutes.
   3. Small owners/operators tend to do their own inspections, while larger facilities hire third-party contractors. 
   4. Yes, the state requires walkthrough inspection records to be kept.
   5. The state requires walkthrough inspection records to be kept for 12 months.
   6. The walkthrough inspection record is a 2-page checklist. 
   7. No, the state is not seeing significant compliance issues with owners/operators having the required walkthrough inspection records during their inspections.
   8. Yes, the walkthrough inspection program is effective because compliance rates are increasing and releases are being discovered more quickly. 
California
Sean Farrow
Leak Prevention Regulatory Unit
Contacted on January 10, 2013
   1. The operators must inspect the monitoring system and alarm history, tank-top containment sumps, spill containment structures, and under-dispenser containment areas. As part of the walkthrough inspection, the operator also needs to verify that all facility employees have been properly trained.
   2. The amount of time it takes for a walkthrough inspection is dependent on the number of tanks, alarms, and spill buckets at the site and the number of dispensers that the designated operator must open.
   3. Most facilities hire a third-party contractor for these inspections.
   4. Yes, the state requires inspection records to be kept.
   5. Inspection records must be kept on-site for the previous 12 months. If an enforcement case is brought up, the state or county can use up to 3 years of retained records. 
   6. The walkthrough inspection record is a detailed checklist.
   7. In California, local agencies perform the inspections, so the state is unclear about overall compliance issues with record maintenance.
   8. The walkthrough inspection program seems to be working, as it allows owners/operators to understand what is happening on site, and actually do something about it. 

