UST Program - Part 1 - Preparing for the Inspection
The most organized inspector takes time to prioritize facility inspections to make the most of his available time. The "problem" tank owners - the ones with complaints and the ones who have received notices of violation (NOVS) - deserve more attention than others.
Inspection Priorities
- One-year turnaround - Make sure each facility is inspected at least annually. Ideally, you should inspect higher-risk facilities such as those with single-wall steeltanks more often.
- Single-wall tanks and piping - Because these tanks pose a greater threat of releasing product into the environment than double-wall tank systems, they should be given high priority.
- Complaints - If you have received a complaint about the facility, it may be viewed as a higher priority.
- Past disciplinary actions - Have you issued NOVs? Warnings? Citations? Problem tank owners need frequent unannounced visits.
- Sloppy housekeeping - How does the facility look? Are things looking run down? Does the property look neglected? If the property isn't getting attention, then maybe monitoring is being neglected, too.
Announced vs. Unannounced Inspections
How you handle your initial contact with a tank owner could set the stage for all future correspondence and inspections. If you’re a seasoned inspector, you know that most tank owners and operators are willing to make sincere efforts to stay in compliance with the maze of federal, state, and local requirements imposed on them. Some infractions you find are not because of a disregard for the law, but are oversights resulting from a lack of understanding of the requirements.
Your First Inspection Should be By Appointment
This initial contact will be very important to both of you. The owner will know when and why you’re coming, and will probably appreciate the time you took to call ahead. And you may be able to determine how much cooperation to expect when you arrive at the facility.
Send a Copy of the Inspection Checklist
When you call for an appointment, tell the owner that you will be sending a copy of your inspection checklist so he can be prepared for your visit (see sample checklist in Appendix F). This gesture will be appreciated and recognized for what it is - an attempt to help the owner understand his regulatory responsibilities. This should be a good start in establishing a mutually cooperative relationship. You can also tell the owner that you may be making unscheduled inspections in the future to make sure compliance is ongoing. These surprise visits are not to “catch” the owner out of compliance, but to keep him on his toes - to make sure that laws and regulations are followed routinely and continuously.
Once you’ve made your initial inspection and it’s time for follow up, are you going to schedule an appointment or are you going to use the “I just happened to be in the neighborhood” approach? Some inspectors like to make unannounced visits to facilities that are staffed during normal working hours and save the scheduled visits for those that don’t normally have someone on duty all the time. Most local agencies have policies or preferences based on experiences in the field where inspectors discover what works best and what doesn’t. On the next page are some advantages to both approaches. Remember that if you arrive unannounced, and your agency has a hands-off policy when it comes to removing manhole covers, pulling probes, etc., you may not be able to complete your inspection. You may need to come back when the owner or operator has a maintenance technician on site.
You should become as familiar as you can with the facility you’re about to inspect. The best way to do this is by thoroughly reviewing your facility file. As you do your review, make notes of the questions you have and the issues you want to discuss during your inspection. These are some of the documents that should be in your file (see Appendix H):
- current operating permit, including copy of upgrade certificate
- monitoring program that includes a response plan and type of leak detection equipment
- monitoring results (tank test reports, annual inventory reconciliation summary statements, etc.)
- facility plot plan
- previous inspection reports
- compliance history
- leak/corrective action history
- financial responsibility statement (see Appendix C)
- upgrade/repair/replacement records
You may not want to take the file with you if you’re concerned about losing it. Some inspectors take the file along and leave it in the car. That way, if there’s a discrepancy between what your records show and what the operator is telling you, you have the necessary paperwork to back you up. But if you don’t want to take the file along, you should transfer the information you will need onto a checklist and take the checklist with you as a ready reference. There’s a sample checklist in Appendix F.
What to Take on the Inspection
You probably have a list of things you don’t want to be without when you do your inspections. It’s a good idea to keep these things together in a kit, so nothing gets left behind.
Take the facility file with you or an inspection checklist filled out with the information you were able to get from the file, as well as any notations on specific facility concerns.
You’ll need educational and informational materials for the operator, tools to help you with the physical inspection, materials to document your visit, and safety equipment.
Educational and Informational Materials
Some documents you might want to take on your inspection include:
- Inspector’s identification card or business cards.
- Copy of the regulations in case the operator doesn’t have one.
- Manual Tank Gauging Booklet (LG 137-1).
- MIR /SIR booklet (LG 52-1).
- List of licensed tank testers (LG 105 – periodically updated on the website).
- List of leak detection equipment - (LG 113)
- List of local resources:
- Cleanup contractors
- Service contractors (for monitoring equipment)
- Tank removal contractors
- Cleanup Fund Program information (call (800) 813-FUND for copies of newsletters, application packages, etc.)
The tools you take on an inspection will depend on whether you do the manual labor yourself, or have the operator or maintenance person do it. Tools used around flammable vapors should be spark proof.
Pry
bar |
For lifting manhole covers, you may want an assortment of sizes. |
Hand
tools |
Assorted screwdrivers, wrenches, socket set (for recessed monitoring well cover bolts), and a pocket knife. |
Fill
pipe wrench |
For inspecting old tanks with odd covers or fuel oil tanks, odd waste oil tanks, or pipes in the ground that might have been connected to tanks abandoned long ago. |
Flashlight |
For looking down fill pipes, monitoring wells, sumps, inside dispensers, etc. Make sure it’s explosion-proof! |
Rags |
For cleaning equipment and your hands. |
Explosimeter/vapor
detector |
For checking vapor levels in wells or other confined spaces. Make sure it has been calibrated recently. |
Clear
bailer |
To check for free product in monitoring wells. |
Measuring tape |
To measure the depth of wells. A weight on the end is useful as a sounder or splasher to tell you where the liquid level is. |
A good memory is a wonderful thing, but you can’t rely on total recall so you need to record your visit using a checklist, field notes, and pictures. Some inspectors use voice-activated tape recorders to dictate notes. You want to be able to support your findings, especially if enforcement action is necessary.
| Camera and film | For overall views of the site and to record visible violations. |
| Tape recorder | If you’re going to record anyone other than yourself, be sure to get permission before you begin! |
| Measuring wheel | For drawing site diagrams. |
| Inspection checklists | See samples at Appendix F. |
| Other forms you use | Notices of Violation, “Stop Use” Notice, Citation book, Certificate of Compliance, etc. |
| Clipboard,
notebook, and pen |
DOCUMENT! DOCUMENT! DOCUMENT! |
Chances are that when you do an inspection at a gas station, it will be open for business. This means cars will be driving in and out of your work area. Protect yourself. Here are some items you can use: