On August 9, UST Training’s President Ben Thomas hosted a six-person webinar panel to discuss industry tips on how to keep your UST inspector happy. In other words, how to have a successful UST compliance inspection. The speakers included:
- Ed Kubinsky of OWL/Crompco, Plymouth Meeting, PA
- Nicole Okino of US EPA Region 3, Philadelphia, PA
- Don Reeves of Mascott Equipment, Portland, OR
- Javed Surani of Your Environmental Specialist, Beaumont, TX
- Jon Tuttle, Stinker Stores, Boise, ID, and
- Brett Smith, MT DEQ, Helena, MT
Attendees heard from UST inspectors, service technicians, and operators about the do’s and dont’s of getting ready for and conducting yourself during a UST government compliance inspection. Plus they learned how to avoid penalties, enforcement actions, and red tag shut down.
From the philosophical to the practical, there was something for everyone. With over 500 registrants and almost 300 attendees, clearly this is an important topic to the UST industry.
In fact, there were so many comments and so much feedback that we weren’t able to answer everyone during the webinar. But here’s some promised follow up.
Q: I often see sensors not at the lowest point and not vertical. Sometimes pulled up out of liquid because the alarms are ‘annoying’.
A: Correct. A great way to avoid a serious violation is to ensure your sensors are properly positioned beforehand.
Q: We had a small diesel leak inside one of our pumps that ended up being a bad seal on a new filter. but we are not allowed to work on our system we have to call in for any repairs.
A: Correct. Based on the jurisdiction you’re in, you may be required to only use certified or licensed UST workers. Unless you are already skilled and experienced in this area, this rule is in place for a good reason.
Q: Some violations I see are not getting testing done on time, not having required paperwork in the compliance binder, not being up to date on class c training, no emergency signs.
A: Thanks. We see these as common violations as well. And ones that can be easily corrected.
Q:Massachusetts inspectors usually conduct unannounced inspections. What about other states?
A: We had quite a spirited discussion amongst all the speakers and a lot of attendees chimed in. The general consensus was that announced inspections seem to be the best and cause the least amount of disruption. However, UST inspectors should reserve the right to do unannounced inspections to keep operators on their toes.
Q: Hall Tank Company in North Little Rock, Arkansas. Anything that the group would suggest that we tank manufacturers consider to be helpful to the customers?
A: That’s a great question. Ironically, with Underground Storage Tanks, inspectors are looking at virtually everything but the tanks themselves. The compliance inspection is mostly on the parts and appurtenances attached to the tank. With steel tanks probably the most important thing is to impress upon owners that corrosion protection is an essential part of maintaining the warranty and lifetime. Best use of the tank.
Q: Operators need to pay attention to the double wall spill bucket gauge!! Please give input on the procedure if the gauge is RED
A: Thanks for that. As we see more and more double wall spill buckets, operators need to be very aware of the signal that could be be sent about a breach of the interstitial space of the spill bucket.
Q: Where can i find the pre-inspection check list?
A: WA’s Preparing for an UST Inspection
A: OR’s Preparing for a smooth inspection
Q: We use CSI out of Oregon to do quarterly inspections for all sumps and pumps
A: Thanks. Any of our UST operators in the Pacific Northwest will appreciate this recommendation.
Q: I’m in Seattle. Where did Don Reeves get that last pump that he showed us?
A: Home Deport
Remember: never ever use an electric shop vac.
Q: Oregon DEQ is actively working on “Your DEQ Online” for the UST community for FR submittals, compliance documents, etc.
A: Ben Thomas mentioned in the webinar that more states are developing online portals to simplify reporting for UST operators.
Q: For false alarms or alarms that are waiting to be repaired (in this case wiring needed to be fixed) how should we mark that it is being worked on/waiting for an approved vendor?
A: There may be some variation among states or even inspectors, but we would recommend documenting the alarm and any sort of outreach efforts you have been trying to locate a vendor for repair work. Remember: suspect release alarms must be responded to within 24 hours.
Q: How can I get a better seal in the heavy metal lid so i can keep water out better.
A: That’s a tough one. At a minimum your site should have a sump cover below grade and a lid on ground grade. Showing you have a very tight seal at grade is important. As well, the type of gravel below grade surrounding the sump opening should be porous to allow rainwater to get through.
Q: I represent a private school with onsite tanks. We do not provide fuel to the public, we are private use only. Fuel is not our full time operation, seems like we are always challenged with inspections and inspectors. Are there options for private use?
A: Even though your tank is for private use, it is considered regulated and all the UST regulations apply. In a situation like that I might advise you to outsource your compliance to a third-party vendor. Contact us for some recommendations.
Q: I use Grainger for our purchasing, I have had a real hard time finding signage like what is suggested in the UST training. Any part#’s you might have would be great.
A: great, great question. Please reach out to us at [email protected] and we can research.