The Background and the Requirements of the 30-Day UST Walkthrough Inspection
In 2015, the United States Environmental Protection Agency (EPA) updated the 1988 underground storage tank (UST) technical regulations. The 2015 UST regulation changed certain portions of the 1988 regulation including the addition of periodic operation and maintenance requirements for UST systems. Among those requirements was the walkthrough inspection. The EPA stated that the walkthrough inspection must meet one of the following options.
Option 1: Every 30 days (except spill prevention equipment at UST systems receiving deliveries at intervals greater than every 30 days may be checked prior to each delivery), check your spill prevention equipment and release detection equipment. Annually, check your containment sumps and any handheld release detection equipment.
When conducting the walkthrough inspection, check the following:
Spill prevention equipment
Check for damage
Remove any liquid or debris
Check for and remove any obstructions in the fill pipe
Check the fill cap to make sure it is securely on the fill pipe
Double walled spill prevention equipment with interstitial monitoring check 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
Check for damage, leaks into the containment area, or releases to the environment
Remove any liquid or debris
Double walled containment sumps with interstitial monitoring check for a leak in the interstitial area
Handheld release detection equipment (for example tank gauge sticks or ground water bailers)
Check 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 check equipment comparable to Option 1 above.
Option 3: Conduct walkthrough inspections according to requirements developed by your implementing agency. These requirements must be comparable to the requirements described in Option 1 above.
Link to the U.S. EPA - Walkthrough Inspection Requirement on the EPA website
What are the benefits of state program approval?
Owners and operators in states that have an approved UST program do not have to deal with two sets of statutes and regulations (state and federal) that may be conflicting. Once their programs are approved, states have the lead role in UST program enforcement. In states without an approved program, EPA will work with state officials in coordinating UST enforcement actions.
All 50 states, 5 territories, and the District of Columbia have a comprehensive set of UST leak prevention and release detection regulations and a program to implement those regulations. Additionally, all states have cleanup programs. Even for states without SPA, EPA enters into grant or cooperative agreements with state programs, and the state program is designated as the primary implementing agency. While both federal and state regulations apply in states without SPA, the state regulations are generally just as stringent as, and oftentimes significantly more stringent than, EPA's regulations.
Not all states have USEPA approved programs!
As of September 2021, 39 states, the District of Columbia, and the Commonwealth of Puerto Rico had state programs approved under the 1988 UST regulation. States are now applying for their state programs to be as stringent as the 2015 UST regulation.
Approved Program under the 1988 regulation Approved Program under the 2015 regulation