UST Best Management Practices
Written by: Brian Pottebaum, Director of Training Services
With the New Year here, it’s time to figure out a New Year’s resolution, right? One option to consider is best management practices (BMP) on your underground storage tank system.
BMPs include important operational and maintenance responsibilities of the UST system. More specifically, BMPs involve routine cleaning, monitoring, inspecting, and testing of spill prevention, overfill prevention, corrosion protection, and release detection equipment. EPA collects technical compliance data for active UST facilities across the country and publishes a compliance report twice a year based on those specific performance measures.
The EPA fiscal year (FY) 2023 compliance report was published this past November. Click HERE to access that report as well as a history of previous reports. A technical compliance rate is calculated for each state, which is the percentage of facilities that are following all four of these BMP categories: 1) Spill Prevention, 2) Overfill Prevention, 3) Corrosion Protection, and 4) Release Detection Requirements.
In that November report, EPA indicates that nationally 58% of all operational UST facilities are in compliance with all four categories. The top 5 states in that report are Wyoming, Colorado, Delaware, New Jersey, and Texas. They reported technical compliance rates of 96%, 95%, 92%, 90%, and 86% respectively.
Iowa, on the other hand, did not report an attractive overall compliance rate; unfortunately, we ranked very near the bottom with only 20% of our facilities in compliance with all four categories. Much of that, however, is a result of operators starting later or misunderstanding the new (2015 EPA) UST requirements.
Based on the EPA report, the category that creates the biggest problem for operators in every state is release detection. It is important to understand that there are monthly and annual operational requirements involved with release detection. The method of release detection that is used at the UST facility determines the specific monthly and annual tasks.
This is a basic list to follow to help stay in compliance with release detection:
- Monthly – Check release detection monitor and equipment, such as the ATG, to make sure it is not in alarm or indicating a petroleum release from your UST system, such as a leak alarm or failed tightness test. All alarms must be corrected immediately. Make sure to record every system check and associated correction as part of the required 30 Day walkthrough routine.
- Monthly – Retrieve “passing” leak detection records for the tanks and associated piping. This could be as simple as pulling a leak test printout or liquid sensor status printout from the ATG. This must be filed along with the previous eleven months of release detection records.
- Annually – Release detection system and associated components, such as the ATG, ATG probe, line leak detectors, and/or liquid sensors must be inspected and tested to confirm functionality. Records of this testing, along with any repairs or adjustments must be filed in your records.
Simply put, you must check every month to make sure that you have not had a petroleum release from the UST system, as well as document every month that the system is “tight” by passing some form of test or continuous monitoring. Additionally, the release detection system that you are checking every month must be inspected and tested annually by a qualified person to make sure it is installed and functioning properly. This documentation must be filed in your records and made available to regulators for a compliance inspection or review.
Keep in mind that regulatory compliance inspections occur randomly, so you always need to be compliant, not just at the end of the year. Quite often, despite the release detection method being conducted, the associated records are not being documented properly. If you are not certain you are conducting release detection properly, then you should be consulting in a professional or attending an approved UST operator training course.
Best management practices should not only be a New Year’s resolution, it should also be a standard for a solid business plan. Corrective action and cleanup related to petroleum releases can cause thousands of dollars in avoidable expenses to you. Don’t wait for a release to get you back on track.