UST Program - Local Guidance (LG) 139-2

May 19, 2003

To: Local Agencies and SIR Providers:

Enclosed are revised forms that SIR providers and tank owners/operators may use to comply with reporting requirements of sections 2646.1(c) and (j) of title 23 of the California Code of Regulations (CCR). The forms are designed to include all pertinent information that an owner/operator or local agency need to review. Forms provided for SIR providers and tank owners/operators use are the:

• Monthly Statistical Inventory Reconciliation Report : a form for SIR providers to use for reporting results of monthly tests to owners/operators.
  
  
• Annual Statistical Inventory Reconciliation Summary Report: a form for owners/operators to report SIR results to the local agencies annually.
  
  

SIR Reporting Requirements

The SIR provider/vender must report leak threshold, minimum detectable leak rate, and calculated leak rate for each tank every month. The test results must be reported as follows (see chart on the back of enclosed forms):

• If the absolute value of the calculated leak rate is less than the leak threshold and the minimum detectable leak rate is less than or equal to the certification performance standard (i.e., 0.1 or 0.2 gallons per hour), the test result is "pass."
  
  
• if the absolute value of the calculated leak rate is greater than or equal to the leak threshold, the test result is "fail."
  
  
• If the minimum detectable leak rate is greater than the certification performance standard (i.e., 0.1 or 0.2 gallons per hour) and the absolute value of calculated leak rate is less than the leak threshold, the test result is "inconclusive." Minimum detectable leak rates might exceed the certification performance standard due to lack of reliable data (i.e., inaccurate dipsticking or meter calibration errors).
  
  

Response to Fail/Inconclusive SIR Results

Any test result that is not conclusive ("pass" or "fail") must be reported as "inconclusive." Tank owners/operators must take all of the following actions when a report showing "fail" or "inconclusive" is received or reported by the SIR vendor:

• Notify the local agency within 24 hours [Cal. Code Regs., tit. 23, § 2646.1 (d)(1)];
  
  
• Review inventory records for errors [Cal. Code Regs., tit. 23, § 2646.1 (d)(2)];
  
  
• Inspect all accessible portions of the UST system for leaks [Cal. Code Regs., tit. 23, § 2646.1 (d)(3)];
  
  
• Check and recalibrate dispenser meters for accuracy within 48 hours of receipt of the failed or inconclusive test results [Cal. Code Regs., tit. 23, § 2646.1 (d)(4)]; and
  
  
• Send a copy of the failed or inconclusive test result(s) to the local agency within 10 days of receiving the results [Cal. Code Regs., tit. 23, § 2646.1 (d)(1)].
  
  

Additional Requirements

A piping tightness test and, if necessary, a tank integrity test must be performed within 15 days if SIR results for two consecutive months show a “fail” or “inconclusive” test result [Cal. Code Regs., tit. 23, § 2646.1 (h)].

A tank integrity test is required every two years when SIR is used as the primary leak detection for the tank. The first tank integrity test must be performed within the first year of implementation of a monitoring program that includes SIR [Cal. Code Regs., tit. 23, § 2646.1 (g)].

Dispenser meters must be inspected annually and recalibrated by the County Department of Weights and Measures or a device repair person as defined in Division 5, Chapter 5.5, of the Business and Professions Code [Cal. Code Regs., tit. 23, § 2646.1 (k)].

Local agencies may reject a test result if it is not properly reported. It is the owner's/operator’s responsibility to choose a SIR provider whose reports meet California’s regulatory and reporting requirements. If you have questions regarding this letter or the attached forms, please call Mr. Raed Mahdi at (916) 341-5871.

Sincerely,

[Original signed by]

Elizabeth L. Haven, Manager
Underground Storage Tank Program

Enclosures (2)
Enclosure 1 - Monthly Summary
Enclosure 2 - Annual Summary