STORAGE TANK INSPECTION AND COMPLIANCE PHILLIP BENTON CERTIFIED TANK INSPECTOR

Transcription

1 STORAGE TANK INSPECTION AND COMPLIANCE PHILLIP BENTON CERTIFIED TANK INSPECTOR HDR EOC PETROLEUM SYSTEMS DIVISION 419 CANYON AVENUE, SUITE 316 FORT COLLINS, COLORADO INTRODUCTION Various policies, regulations, and codes such as the Unified Facilities Criteria (UFC), Military Handbooks, Air Force Instructions (AFI), and federal and state regulations require aboveground storage tanks (ASTs) and underground storage tanks (USTs) storing flammable and combustible liquids located within the United States to be inspected weekly and/or monthly and annually by the owner/operator/custodian. This paper provides important information about tank inspections for building a solid foundation for tank compliance, a more detailed explanation of the typical AST monthly and annual checklist items, a more practical approach to inspecting tanks, an overview of federal UST and AST environmental compliance requirements, and common compliance deficiencies. This paper is intended to provide guidance for those personnel responsible for managing and inspecting tanks storing petroleum products with capacities less than or equal to 50,000 gallons. The strategies for building a solid foundation for tank compliance outlined in this paper can be applied to both ASTs and USTs; however the review of check lists focuses on ASTs only. INSPECTING DEFICIENCIES In a 2007 Certified Formal External Tank Inspection Report that covered more than 70 ASTs located on one Air Force installation, only nine of the tanks were found to be in compliance with current standards and regulations. None of the significant findings outlined by the certified tank inspectors were items normally found on the monthly or annual inspection checklists. The majority of the tanks that were inspected are Category I tanks, as defined in the inspection standard, with capacities less than or equal to 5,000 gallons. Category I tanks that are less than or equal to 5,000 gallons do not ever require a formal inspection to be performed by a certified inspector and therefore many of the installation errors are not identified during periodic inspections. In 2010, five USTs were inspected at a Shoppette facility located on a Department of Defense installation. None of the five USTs had a drop tube installed in the fill riser. The facility custodian and the delivery driver were unaware of this condition. This is a serious hazardous condition because the gasoline being delivered to the site is free-falling into the tanks and can cause static electricity build up and ignite fuel. Checking the functionality of drop tubes and overfill prevention equipment should be part of a periodic UST inspection. The most common findings from formal inspections that are not on the monthly or annual checklists are: Inadequate venting capacity, Liquid in the interstitial space, Using the vent for something other than venting,

2 No anti-siphon device on tanks, No electrical grounding, No overfill-prevention device or means to determine the level of fuel, and No secondary containment or inadequate capacity. The monthly checklist used by most operators was created as a guide to check for leaks, maintain the tank systems free of foreign liquids, and help recognize progressive tank shell aging that may lead to catastrophic failure. The industry standard checklists were not created to identify code deficiencies and do not adequately address federal, state, and local regulatory compliance. Most deficiencies are overlooked during the periodic inspections simply because personnel have not been trained to identify various regulatory non-compliance and code deficiencies. Many tanks, especially smaller shop-built tanks, were not installed in a manner that met the fire code requirements and industry standards. Some work needs to be completed before compliance can be achieved. A FRESH START BASELINE INSPECTION A one-time inspection and summary completed by an experienced and certified inspector is critical to identify and correct significant problems and build a solid foundation for tank management and compliance. Once the tank is upgraded to meet regulatory and code requirements, very little will change and the usual inspection checklists can be used for their original purpose. The baseline inspection does not need to be a formal inspection and can be performed in conjunction with training for tank management personnel (another requirement of the SPCC rule and Energy Policy Act). Usually a general look at the tank system from the experienced inspector s point of view is enough to identify the items that are being overlooked. Like anything else, tank management is only as strong as the foundation on which it is built. Most of the deficiencies exist from when the tank is installed and get overlooked every month thereafter. TECHNICAL GUIDANCE Specific tank system technical guidance is another critical step for developing a tank management program. Develop guidance documents specific to your tank systems. The guidance document should have inspection forms, a site diagram, tank diagrams, tank system information, and a summary of requirements specific to the tank system. A guidance document prepared specifically for a particular tank system will enable new employees to be trained more efficiently. TANK SPECIFIC TRAINING Significant deficiencies are overlooked each month because personnel have not been specifically trained to recognize certain situations. Provide training using the guidance document for the specific tanks the technician will be inspecting. Review the site and tank diagrams to familiarize the technician with the system. The training should also satisfy the requirement to train personnel who will perform the annual inspection and comply with the Energy Policy Act when applicable. Keep a training record for all personnel and facilities. RECORD KEEPING Tank inventory and records pertaining to testing, repairs, and inspections should be kept in one location and managed by a very limited number of personnel. A simple database managed by one person should be created and utilized to manage tank information. Multiple spreadsheets with all

3 of the tanks located on the installation can be changed and copied so many times that the updated information becomes invalid. Information should be stored in one location with limited access. TANK INSPECTION The most nationally recognized standard for inspection of tanks with capacity less than or equal to 50,000 gallons is the STI SP001 Standard. The standard does not require Category I tanks with capacities of 5,000 gallons or below to have a certified inspection, so the owner/operator has the option of self-performing the monthly and annual inspections. The tank system will never require a certified inspection if the SP001 Standard is followed and all other requirements are satisfied. The inspection checklists included in the standard are intended to act as a guide for recording inspection data. Completing the inspection checklists or recording inspection data requires only a little knowledge of AST systems, however inspecting the tanks and identifying serious conditions that may lead to catastrophic failure requires additional understanding of ASTs. The following sections provide further explanation of the checklist items for the most popular inspection checklists in the industry today. MONTHLY TANK INSPECTION A monthly tank inspection checklist for shop-built tanks or tanks having capacities less than or equal to 50,000-gallons usually consists of a visual inspection following specific checklist items. The inspection is primarily visual with the exception of physically checking for the presence of water in the tank and liquids inside the interstitial space (the area between the primary and secondary tank). The following section provides an explanation of the typical items on the SP001 monthly inspection checklist. 1.0 Tank Containment The containment should be looked at closely to find cracks in the concrete and other damage that may affect the containment performance or capacity. 1.1 Water in primary tank, secondary containment, interstice, or spill container Water inside tanks and containments can be a serious problem. Water should not be in contact with steel or fuel. Petroleum products containing ethanol or bio fuels especially do not mix well with water. Microbial Induced Corrosion (MIC) is normally a result of fuel (typically diesel) and water mixing inside tanks. The presence of water should be checked in primary tanks and interstitial spaces at least monthly. Each operator or facility should have proper tools and equipment to monitor tanks for water. Ask your local petroleum distributor or service company to provide the right water indicating paste. Gauging sticks for checking tank volume come in various sizes and designs to accommodate different tank locations. A tape measure works well to check for water in tanks located inside buildings. (Refer to the STI Pamphlet Keeping Water Out of Your Storage System.) Remove water or liquids from the spill container as well. 1.2 Debris or fire hazard in containment Keep the containment free of debris and flammable materials. Drums and pallets are examples of items normally improperly stored in containment structures. 1.3 Drain valves operable and in a closed position Check the drain valves to make certain they will function when needed. Make certain drain valves are actually closed. Many times drain valves on smaller containments are left open to prevent precipitation accumulation. This is not allowed. Check the valves and lock them in the closed position. 1.4 Containment egress pathways clear and gates/doors operable The pathways and doors should be clear for emergency responders or if a quick exit is necessary.

4 2.0 Leakage This includes a monthly visual inspection of the piping, valves, and appurtenances. If the piping is covered by grates or some kind of cover and cannot be inspected, then technically the piping is underground and requires additional integrity testing. The Air Force adheres to UFC F for leak testing of piping. This UFC requires annual pressure testing of above and belowground pipelines, and hydrostatic pressure testing of underground piping every five years. In addition, integrity testing of underground piping must be performed in accordance with API 570 whenever piping is installed, modified, constructed, relocated, or replaced. 2.1 Visible signs of leakage Check the surface of the tank, concrete pad, containment, ringwall, and ground for leaks and pay close attention to the areas underneath tanks and piping joints for stains or evidence of leaks. Some leaks are only visible during warmer weather so evidence of leaks should be noted in addition to identifiable leaks. 3.0 Tank Attachments and Appurtenances 3.1 Ladder and Platform Structure Visually inspect the ladder and platforms for signs of corrosion or damage to connecting points. Steps should be installed according to OSHA standards. 3.2 Tank Liquid Level Gauge Verify the tank level gauge is readable and in good condition. Verify the reading is accurate. There should be little to no difference between a stick reading in the same opening as the level gauge or an adjacent opening in a small tank. 3.3 Tank Openings Verify all tank openings are sealed and no components have been removed or replaced with incompatible materials. Tank openings should be sealed with steel fittings. Plastic or non-threaded tin fittings should not be used to seal tank openings. ANNUAL INSPECTION An annual tank inspection consists of the monthly inspection with additional items to verify functionality of systems such as tank monitors, leak detection devices and vents. The following list has been adapted from the SP001 Annual Inspection Checklist and provides further explanation. The monthly inspection checklist should be completed when the annual inspection is performed. 1.0 Secondary Containment 1.1 Leak Sensing Equipment Leak detection equipment such as liquid sensors and site gauges need to be checked during the annual inspection. The leak detection equipment needs to function properly. Remove the equipment, clean it and inspect it. Check with the manufacturer of the equipment for maintenance and inspection recommendations. 1.2 Containment Structure The containment structure should be inspected for cracking or spalling concrete, settling, and holes. The containment should be impervious and constructed of materials with at least a two-hour fire rating. Wooden containments with rubber liners are flammable and should not be used. 1.3 Containment Conditions The containment should be cleaned. There should not be any debris or trash inside the containment or flammable materials stored in the vicinity of the tank. Include inspection and maintenance for piping trenches, chases, and diversion structures. 1.4 Drainage Pipes/Valves

5 Drain valves should be inspected for operability and any maintenance should be performed during the inspection. 2.0 Tank Foundation and Supports 2.1 Tank Settlement or Foundation Washout There should be no settling around the tank. The foundation of the tank should be even and there should not be any areas of wash out where vegetation can grow or dust and debris can accumulate against the tank surface. 2.2 Cracking or Spalling Concrete Cracks can be pathways for the product to enter the environment in the event of a release. Inspect the foundation for spalling and repair if necessary to prevent removing the tank for future repair. 2.3 Corrosion The tank foundation and supports are part of the tank and should not have any distortions or evidence of corrosion. The coating should be in good condition. Repaint spots where paint has chipped as soon as practical. 2.4 Drainage Drainage should be away from the tank and its foundation. Check for signs of drainage under the tank. Precipitation should not be allowed to collect around the tank foundation. 2.5 Grounding Strap The grounding strap must be adequate, secure and in good condition. 3.0 Cathodic Protection 3.1 System Functioning The system should be checked by a qualified technician to verify proper operation. Check the visible wiring and junction boxes to make sure wires are secure and in good condition. 3.2 Rectifier Readings Record the rectifier readings during the inspection and review the rectifier log. Verify the readings are above zero. A zero amperage or voltage reading is an indication the system is not functioning properly. Verify readings using a volt meter or multi-meter. 4.0 Tank Coating 4.1 Paint Failure Check for paint or coatings failure on all surfaces especially the roof and sides of horizontal tanks. Check around concrete saddle supports for horizontal tanks. Moisture and debris collect in areas on top of the saddles. 4.2 Insulation Condition Check the condition of the insulation. Moisture should not be allowed to impact the insulation. Check areas where moisture can impact the insulation thoroughly. Wet insulation should be removed and replaced. 5.0 Tank Shell/Heads 5.1 Distortions, Buckling, Denting or Bulging Look at the tank from all sides and angles. Tank deformities can occur slowly over time and can go unnoticed until it is too late to save the vessel. Improper venting normally causes these problems. 5.2 Corrosion or Cracking Evidence of corrosion should be investigated further. Spots where paint has chipped or peeled should be cleaned and re-coated.

6 6.0 Piping 6.1 Leakage The piping should be inspected monthly. Below ground piping must be tested as mentioned above and in accordance with any local regulations. 6.2 Supports Piping supports should be inspected for corrosion. Piping supports should be replaced prior to failing. Supports should be insulated from the piping to prevent damage from vibration. 6.3 Anti-siphon Verify an appropriate anti-siphon device exists where required. Follow the manufacturer s recommended maintenance. 6.4 Insulation Check the piping insulation for damage. The insulation should be covered by a weatherproof covering and remain water-tight. Wet insulation should be removed and replaced. 7.0 Tank Openings 7.1 Flanged Connections Check to ensure all of the long-bolted manways for emergency venting are still longbolted properly. Make sure the long-bolted manways are stamped or properly labeled if being used for emergency venting. All other flanged connections should be tightly closed. Replace worn out gaskets. 7.2 Manways Manways should be closed tight and locked when not in use. 8.0 Tank Top 8.1 Standing Water There should not be any standing water on the roof. Standing water on a roof can be an indication of a more serious problem. 8.2 Damage Look for cracks in insulation or damage to the coating. Repair cracks or paint damage according to industry standards or the tank manufacturer s recommendations. 9.0 Vents 9.1 Obstructions Tank vents should be in the clear ; there should be no obstructions. Remove and clean the vent cap. 9.2 Emergency Vent Operability Verify the operability of the emergency vents. Open the vents and clean the screens if present. Apply lubricant to the o-rings or replace worn out or broken o-rings. Remove paint from the vents if they have been painted. Double-walled tanks should have emergency venting installed for the primary and the secondary Level Gauge and Overfill Prevention 10.1 Level Sensing Device Calibration Calibrate the level sensing equipment according to industry standards or the manufacturer s recommendations Overfill Prevention Device Verify the operability of the overfill prevention device or test the audible alarm. Pushing the test button on the annunciator should be done monthly. Testing the alarm device functionality should be performed.

7 11.0 Electrical Equipment 11.1 Grounding Condition Check the ground to make sure there is still a secure connection to the tank. Verify the ground is adequate according to national standards Wiring Inspect the wiring and the conduits for damage that may allow water to enter the conduit or junction boxes Lighting Verify lighting around the tanks and piping systems is adequate and functioning properly. OTHER TANK DAMAGE According to the SP001 standard, an AST subjected to damage caused by the following conditions requires evaluation by an engineer experienced in AST design or a tank manufacturer who will (jointly with the owner) determine if an immediate formal external or internal inspection is required: Fire - AST exposed to fire or flame impingement Natural disaster - AST exposed to flooding, hurricane force winds, etc. and has been lifted or damaged Excessive Settlement - AST that has experienced excessive settlement Overpressure - AST exposed to excessive internal pressure caused by overfill or failure of venting devices or another reason Damage from Cracking - AST with evidence of cracking of welds or the AST surface If a leak is discovered at any time by the owner or the inspector, the tank must be repaired, replaced or closed and removed from service in accordance with good engineering practice. The inspection checklists are to be used only as a guide for recording inspection data. Following the monthly checklist is a great way to keep water out of your tank and containment and a great guide to monitor the condition of the tank and piping. The annual inspection checklist is a great maintenance guide. Inspection checklists are guides and tank specific checklists should be developed for each tank system after a certified inspection is performed and the deficiencies are corrected. ABOVEGROUND STORAGE TANK COMPLIANCE There is no single stand-alone federal set of regulations for ASTs. The SPCC regulation under the Clean Water Act, 40 Code of Federal Regulations (CFR) part 112 and the U.S. Department of Labor, Occupational Safety and Health Administration (OSHA), 29 CFR : Occupational Safety and Health Standards; Flammable and Combustible Liquids regulation, are the closest thing to specific federal requirements for ASTs, however many states have specific requirements based on the fire codes and industry standards. New SPCC rule amendments further defined tank integrity testing and inspection requirements in 2002, 2006, and 2008, and industry standards, such as API 653 and STI SP001, were suggested to the owners of smaller tanks to satisfy the requirements. STI SP001 includes the following instruction for certified inspectors: There are numerous AST configurations and components and it is the responsibility of the certified inspector to identify and properly inspect them to conform to the owner s requirements and/or industry standards. All other applicable industry standards and codes apply to the SP001 Inspection Standard and it is the job of the inspector to identify where other standards are not met.

8 EPA requirements for inspection and testing of ASTs and associated piping are found in 112.7, and They are summarized in the following table. Phrases indicating triggers for or frequency of inspection and testing are underlined. APPLICABLE SPCC INSPECTION and TESTING REQUIREMENTS Type of Regulatory Equipment Inspection Regulatory Requirement Citation or Test Aboveground containers Field-erected ASTs Liquid level sensing devices Containers without containment or diversionary structures, for which an impracticability determination has been made Regularly scheduled integrity testing, frequent visual inspection Brittle fracture testing Operational test Integrity and leak testing Aboveground Bulk Storage Containers 112.8(c)(6) and (c)(6) 112.7(i) 112.8(c)(8)(v) and (c)(8) 112.7(d) Test each aboveground container for integrity on a regular schedule, and whenever you make material repairs. The frequency of and type of testing must take into account container size and design (such as floating roof, skidmounted, elevated, or partially buried). You must combine visual inspection with another testing technique such as hydrostatic testing, radiographic testing, ultrasonic testing, acoustic emissions testing, or another system of non-destructive shell testing. You must keep comparison records and you must also inspect the container's supports and foundations. In addition, you must frequently inspect the outside of the container for signs of deterioration, discharges, or accumulation of oil inside diked areas. If a field-constructed aboveground container undergoes a repair, alteration, reconstruction, or a change in service that might affect the risk of a discharge or failure due to brittle fracture or other catastrophe, or has discharged oil or failed due to brittle fracture failure or other catastrophe, evaluate the container for risk of discharge or failure due to brittle fracture or other catastrophe, and as necessary, take appropriate action. You must regularly test liquid level sensing devices to ensure proper operation. Requires both periodic integrity testing of the containers and periodic integrity and leak testing of the valves and piping.

9 APPLICABLE SPCC INSPECTION and TESTING REQUIREMENTS Type of Regulatory Equipment Inspection Regulatory Requirement Citation or Test Underground piping Underground piping Aboveground piping, valves and appurtenances Rainwater accumulated inside diked areas Inspect Integrity and leak testing Inspect Inspect 112.8(d)(1) 112.8(d)(4) 112.8(d)(4) and (d)(4) Piping Rainwater Drainage 112.8(c)(3) and (c)(3) If a section of buried line is exposed for any reason, you must carefully inspect it for deterioration. If you find corrosion damage, you must undertake additional examination and corrective action as indicated by the magnitude of the damage. You must also conduct integrity and leak testing of buried piping at the time of installation, modification, construction, relocation, or replacement. Regularly inspect all aboveground valves, piping, and appurtenances. During the inspection you must assess the general condition of items, such as flange joints, expansion joints, valve glands and bodies, catch pans, pipeline supports, locking of valves, and metal surfaces. Prior to draining accumulated rainwater, inspect the retained rainwater to ensure that its presence will not cause a discharge and keep adequate records of such events Federal/State Air Pollution Control Requirements ASTs are normally considered sources of air emissions included in air emissions permits and subject to specific air emissions permit conditions, recordkeeping, and reporting requirements. Federal air quality regulations ( through ) provide specific construction and vapor recovery system requirements for some petroleum liquid ASTs. Fire Codes AST and UST installations must be approved by the Authority Having Jurisdiction (AHJ). There are three main fire codes adopted by the AHJ varying by region. The installer or inspector should confirm whether the local authority has adopted the Uniform Fire Code, International Fire Code, or National Fire Protection Association Code. Various fire codes apply to particular installations and the applicable codes will depend on the tank use and size. UNDERGROUND STORAGE TANK COMPLIANCE An underground storage tank system (UST) is a tank and any underground piping connected to the tank that has at least 10 percent of its combined volume underground. The federal UST regulations apply only to underground tanks and piping storing either petroleum or certain hazardous substances. In 1984, Congress responded to the increasing threat to groundwater posed by leaking USTs by adding Subtitle I to the Resource Conservation and Recovery Act (RCRA). Subtitle I required EPA to develop a comprehensive regulatory program for USTs storing petroleum or certain hazardous substances.

10 Congress directed EPA to publish regulations that would require owners and operators of new tanks and tanks already in the ground to prevent, detect, and clean up releases. At the same time, Congress banned the installation of unprotected steel tanks and piping beginning in In 1986, Congress amended Subtitle I of RCRA and created the Leaking Underground Storage Tank (LUST) Trust Fund, which is to be used for two purposes: 1. To oversee cleanups by responsible parties. 2. To pay for cleanups at sites where the owner or operator is unknown, unwilling, or unable to respond, or which require emergency action. The 1986 amendments also established financial responsibility requirements. Congress directed EPA to publish regulations that would require UST owners and operators to demonstrate they are financially capable of cleaning up releases and compensating third parties for resulting damages. The Energy Policy Act of 2005 amended Subtitle I of the Solid Waste Disposal Act. The UST provisions of the Energy Policy Act focus on preventing releases. It expands the use of the LUST Trust Fund and includes provisions regarding inspections, operator training, delivery prohibition, secondary containment and financial responsibility, and cleanup of releases that contain oxygenated fuel additives. The following USTs do not need to meet federal requirements for USTs: Farm and residential tanks of 1,100 gallons or less capacity holding motor fuel used for noncommercial purposes; Tanks storing heating oil used on the premises where it is stored; Tanks on or above the floor of underground areas, such as basements or tunnels; Septic tanks and systems for collecting storm water and wastewater; Flow-through process tanks; Tanks of 110 gallons or less capacity; and Emergency spill and overfill tanks. Some state/local regulatory authorities, however, may include these tank types; be sure you check with these authorities. The underground storage tank program is primarily implemented by states and territories. Your first point of contact is the state or territorial regulatory agency that has jurisdiction where the USTs are physically located. See for a list of contacts. In 1988, EPA issued UST regulations divided into three sections: technical requirements, financial responsibility requirements, and state program approval objectives (as described below). Technical Requirements for USTs EPA's technical regulations for USTs are designed to reduce the chance of releases from USTs, detect leaks and spills when they do occur, and secure a prompt cleanup. UST owners and operators are responsible for reporting and cleaning up any releases. The Office of USTs (OUST) produced a 36-page booklet called "Musts for USTs" that clearly presents the UST regulatory requirements. Financial Responsibility Regulations for USTs The financial responsibility regulations were designed to ensure that, in the event of a leak or spill, an owner or operator will have the resources to pay for costs associated with cleaning up releases and compensating third parties. OUST produced a 16-page booklet called "Dollars and Sense" that clearly presents these regulatory requirements.

11 State Program Approval Objectives EPA recognizes that, because of the large size and great diversity of the regulated community, state and local governments are in the best position to oversee USTs. Subtitle I of RCRA allows state UST programs approved by EPA to operate in lieu of the federal program, and EPA's state program approval regulations set standards for state programs to meet. States may have more stringent regulations than the federal requirements. If you are interested in requirements for USTs, contact your state UST program for information on state requirements. Code of Federal Regulations The federal regulations concerning underground storage tanks (USTs) are contained in Part 280, Part 281, and Parts The list of hazardous substances is in Part COMMON COMPLIANCE DEFICIENCIES Common UST compliance deficiencies found at Air Force installations include inadequate spill buckets, failure to test and maintain cathodic protection, inoperable release detection monitoring/alarms, improper tank closure, and inadequate recordkeeping. Without adequate recordkeeping, it is not possible to document compliance with monitoring, testing, and maintenance requirements. Common AST compliance deficiencies identified at Air Force installations include inadequate secondary containment, inoperable alarms, lack of visual inspections, lack of an integrity testing program, failure to obtain state registration permits, and inadequate recordkeeping. Without adequate recordkeeping, it is not possible to document compliance. VIOLATIONS AND POTENTIAL FOR FINES According to the EPA website, the budget includes approximately $618 million for the EPA s Enforcement and Compliance Assurance program, representing the highest enforcement budget ever and an $18-million increase over EPA s fiscal year 2010 enacted level. EPA s enforcement priorities include five specific goals: (1) Clean Air and Global Climate Change; (2) Clean and Safe Water; (3) Land Preservation and Restoration; (4) Healthy Communities and Ecosystems; and (5) Compliance and Environmental Stewardship. Goal (2) Clean and Safe Water represents 45.7 percent of the budget. CONCLUSION SPCC rule amendments in 2002, 2006, and 2008 have further defined tank integrity testing and inspection requirements. A significant percentage of the ASTs will not require a certified inspection although a baseline inspection is critical to identify deficiencies that have been overlooked since the tanks were installed. Deficiencies must be identified and corrected as the first step to comply with tank integrity testing and inspection requirements. This paper has indentified some common non-compliant or regulatory deficiencies associated with USTs and ASTs with capacity below 50,000 gallons. Additionally, it has provided a framework to develop a baseline inspection, create system specific checklists, and to conduct base-level training. As was noted previously, at one recent inspection at an Air Force Base, only nine of more than seventy ASTs were in compliance. With the EPA s new enforcement budget at the highest level ever, it is imperative to begin a more rigorous AST inspection program. Most of the items mentioned in this paper can be implemented by Base personnel. However, if constraints or manpower availability are such that it would be difficult to implement the recommendations in this paper, then the Base should look to outside help to reinvigorate their tank program, develop

12 the baseline inspection, update the system specific checklists, and to conduct the training so that they can internalize the requirements and maintain compliance for all of their tanks under 50,000 gallons. This paper has provided tank managers with important strategies to build a solid foundation for tank compliance. REFERENCES Federal Regulations and Guidance:, Part 112, Oil Pollution Prevention, Part 279, Standards for the Management of Used Oil, Part 280, Technical Standards and Corrective Action Requirements for Owners and Operators of Underground Storage Tanks EPA (U.S. Environmental Protection Agency), 2005, SPCC Guidance for Regional Inspectors, Version 1.1: Office of Emergency Management, EPA 550-B (Including 2006 revisions to Sections 1 and 7) EPA, 2006a, Grant Guidelines to States for Implementing the Delivery Prohibition Provision of the Energy Policy Act of 2005, EPA-510-R EPA, 2006b, Grant Guidelines to States for Implementing the Secondary Containment Provision of the Energy Policy Act of 2005, EPA-510-R EPA, 2007, Grant Guidelines to States for Implementing the Operator Training Provision of the Energy Policy Act of 2005, EPA-510-R EPA, 2009a, State Underground Storage Tank Programs: Available on EPA's Web site at EPA, 2009b, State Delivery Prohibition Programs: Available on EPA's Web site at DoD & Air Force Policy/Guidance: AFI , Fuels Management, 1 December 2009 AFI , Organizational Fuel Tanks, 24 June 2009 AFI , Storage Tank Compliance, 13 November 2003 AFI Corrosion Control, 1 March 2000 TO , General Operation and Inspection of Installed Fuel Storage and Dispensing Systems UFC , Operation and Maintenance: Maintenance of Petroleum Systems, January 2003 Disclaimer The opinions and conclusions in this paper are the author's alone and do not necessarily reflect those of the United States Air Force, or the Federal Government. Author s Contact Information: Phillip Benton Service Area Manager Petroleum Systems Division HDR EOC [email protected]