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State Leak Detection Inspections
What You Need To Do To Have a Successful Inspection
Preparing for leak detection inspections can be a headache if you don't have all your paperwork in order. Here is a breakdown of the records you should have available for the inspector.
Records you should have available for the inspector
Notification
- Current year tank tags : proof that your tanks are in compliance with UST rules
- EPA Notification form: which details type of tank material, product stored, date of installation and upgrades, if any, etc.
UST System Repairs and Maintenance
- Manufacturer's schedule of required calibration & testing
- Dates and details of any repairs or maintenance
- Dates and details of upgrades: corrosion, spill or overfill protection
Corrosion Protection Test Results
Even if you have fiberglass reinforced plastic (FRP) tank and lines there may be metal parts, i.e. flex connectors that will need to be protected.
- Test results - 6 months after installation and every three years thereafter
- Sacrificial anode system - last 2 tests
- Impressed Current system - last 2 tests and last 3 rectifier operation checks performed every 60 days
Release Detection Records for Lines
- Pressurized Piping: annual test results for leak detectors - to verify they are functioning properly; results of annual line tightness test or results of monthly monitoring method (ATG with electronic line leak detection, SIR, interstitial monitoring...) for last 12 months and 3rd party certification
- Suction Piping (with foot valve - product stays in line): results of line tightness test every 3 years or results of monthly monitoring method for last 12 months and 3rd party certification
- Suction Piping (without foot valve- product does not stay in line when not pumping) also known as "safe suction":
Release Detection Records for Tanks
- Inventory Control/Tank Tightness Test
(Can only be used for 10 years after the tank has been installed or upgraded with corrosion protection)
- Tightness test every 5 years
- Daily inventory records (inputs, withdrawals) for last 12 months
- Delivery receipts
- Monthly reconciliation calculations for last 12 months
- Appropriate conversion chart (1/8 inch increments to gallons)
- Water reading every 30 days
- Record of reporting any "suspected" or "confirmed" release
- Manual Tank Gauging (1000 - 2000 gallon tanks)
(Can only be used for 10 years after the tank has been installed or upgraded with corrosion protection)
- Tightness test every 5 years
- Weekly stick readings for last 12 months
- Monthly reconciliation calculations for last 12 months
- Appropriate conversion chart (1/8 inch increments to gallons)
- Record of reporting any "suspected" or "confirmed" release
- Manual Tank Gauging (1000 gallons or less)
- Weekly stick readings for last 12 months
- Monthly reconciliation calculations for last 12 months
- Appropriate conversion chart (1/8 inch increments to gallons)
- Record of reporting any "suspected" or "confirmed" release
- Interstitial Monitoring
- Written documentation of installation, calibration, and set-up
- Record of maintenance or repairs
- Device documentation (operator's manual)
- Record of monthly monitoring for last 12 months (sensor status reports, manual inspections, etc.)
- Details of any alarms and justification if not reported
- Automatic Tank Gauging
- Written documentation of installation, calibration, and set-up
- Record of maintenance or repairs
- Device documentation (operator's manual)
- Results of valid leak test for last 12 months
- Details of any "failed" tests and justification if not reported
- Statistical Inventory Reconciliation (SIR)
- SIR vendor reports
- Inventory records (inputs, withdrawals) for the last 12 months
- Delivery receipts
- Appropriate conversion chart (1/8 inch increments to gallons)
- Water readings as required by method (every 1-2 weeks)
- Details of any "inconclusive" or "failed" test results and verification that the data was reverified the following month.
3rd party certification:
An evaluation performed by a third party (someone who is independent of the manufacturer or vendor of the leak detection system) shows that a leak detection system can work as designed. The evaluation follows required evaluation procedures and often takes place in a laboratory. EPA and third parties have developed evaluation procedures for all leak detection systems.
Although an evaluation and its resulting documentation are technical, you should be familiar with the evaluation's "results" form and, when provided, its "description" form. You should obtain these forms from the leak detection vendor and keep them on file. They contain a signed certification that the system performed as described, as well as documenting any limitations of the system. This information is important to your compliance with the UST requirements. For example, if a tank tightness test was evaluated and certified only for tests taking 2 hours or more, then your tank must be tested for at least 2 hours or it would fail to meet the leak detection requirements.
