Fall25UST

You and UST's
Are You Ready?

By Ashley Grooms, Environmental Compliance Specialist
Is your Underground Storage Tank (UST) System "inspection ready?" Have you recently been caught unprepared for an EPD Inspection?

You are not alone, but luckily, Petroleum Services Group (PSG) is here to help. With everything that goes into maintaining a site, whether it be a convenience store or agriculture (this includes emergency generators, they are now regulated by the EPD!!!), environmental compliance for your underground storage tanks may be the furthest thing from your mind. However, this oversight can lead to costly repairs, hefty fines from the EPD, and possible placement on the Fuel Delivery Prohibition List. Fines for environmental compliance violations can range from $100 to $500 per violation. These violations can include not registering the tanks with the state, not maintaining monthly monitoring, or not having the system tested properly, to name a few. First, the Owner and/or AB Operator of the site needs to be familiar with the UST system that is present. Characteristics such as the construction material and piping system can affect the types of compliance needs that will have to be maintained. Staying up to date with the ever changing EPD regulations is necessary as well. Checking the GA EPD website periodically can help ensure that a tank owner stays aware of new regulations coming into effect.

As of December 15th, 2020, a new set of environmental regulations became mandatory in Georgia for all UST systems installed prior to December 15, 2017. For any systems installed on or after December 15, 2017, these requirements have been in place since initiation of fueling operations. In addition to previously required environmental testing, all UST systems are now mandated to have their Spill Buckets, Containment Sumps (for sites that use interstitial monitoring) and Overfill Prevention systems evaluated every three years. Sites using a tank monitor for monthly monitoring must have the monitor, probes, and sensors (if applicable) tested annually as well. The new 2020 regulations have also mandated that Annual and Monthly walkthroughs be conducted.

There are two parts to the EPD Compliance Inspection: a physical inspection of the site and a document review. These EPD Compliance Inspections are now occurring every two years.

For the physical inspection, a representative of the site will need to be present to assist the EPD inspector with opening manways, opening dispenser cabinets, and answering questions regarding the UST system. The document review portion will consist of the inspector completing an audit of the last three years of environmental records for the site. The minimum records required for the inspection (depending on the type of system installed, installation date, and type of monthly monitoring in use) are:

Records Required for UST Inspection

Current UST Registration Certificate (this is to be posted in a visible location, such as front glass)
A/B/C Operator Certificates
Proof of Financial Responsibility, whichever is applicable:

◊ GUST Trust Fund (Fuel Invoices)
◊ Private Insurance Policy Certificate
◊ Proof of Self-Insurance

Last three years of 30-day Walkthrough inspections
Last three years of passing monthly tank release detection records, whichever are applicable: ◊ Statistical Inventory Reconciliation

◊ Automatic Tank Gauge (i.e., SCALD, CSLD, Leak Test)
◊ Interstitial Monitoring, required for tanks installed
on/after April 7, 2008 (i.e., sensor report for interstitial sensors)
◊ Groundwater Monitoring

Last three years of passing monthly line release detection records, whichever are applicable: ◊ Statistical Inventory Reconciliation

◊ Interstitial Monitoring, required for piping installed on/after April 7, 2008 (i.e., sensor report for STP and UDC sumps)
◊ Electronic Line Leak Detector
Last three years of Annual Interstitial Monitoring Sensor Functionality Tests, if required: ◊ Tank Interstice Sensors
◊ STP sump sensors (and UDC sump sensors, where required)

Last three years of Annual Release Detection Equipment Tests

◊ Automatic Tank Gauge/Probes (tank monitor)
◊ Vacuum Pumps/Pressure Gauges
◊ Hand-Held Vapor Monitoring Equipment

Last three years of Annual line testing records:

◊ Line Tightness Test
◊ Mechanical Leak Detector Test
◊ Electronic Leak Detector Test, if applicable

Last three years of Annual Walkthrough Inspections
Last two passing Triennial Cathodic Protection tests, if required:

◊ For Impressed Current systems, the last three years of rectifier box readings

Most recent Triennial Spill Prevention Equipment Test
Most recent Triennial Overfill Device Equipment Test

◊ Ball floats, Flapper Valves, or Alarm system (Ball Floats cannot be repaired. If failing, they must be replaced with Flapper valves or an Alarm system)

Most recent Triennial Containment Sump Testing, required for sites using Interstitial Monitoring as the type of monthly inventory control
Most recent Stage I or Stage I EVR test, if required
Any maintenance and/or repair information regarding the underground storage tank system

It is the responsibility of the registered tank owner to ensure that these tests are completed and that the records are retained and made available at each EPD Compliance Inspection.

PSG is equipped to conduct all required annual and triennial environmental testing, except for Stage I and Stage I EVR testing. PSG also works with 7G Environmental to provide a monthly and annual walkthrough service to better help our clients stay compliant. In addition to testing and walkthrough services, PSG offers a comprehensive Environmental Consulting service as well. If interested in any of our Environmental Services or to see how PSG can help you, please contact our office for more information and pricing.

For more detailed information regarding UST Regulatory Compliance, please visit https://epd.georgia.gov/about-us/land-protection-branch/land-protection-branch-technical-guidance/underground-storage-1.

Make sure when the time comes, you are ready. Here at PSG, we are happy to help you meet your environmental compliance needs.

If you should have any compliance issues or questions, please feel free to contact PSG’s Environmental Department at (866) 291-6606 or via email at [email protected].

You and UST'sAre You Ready?

You and UST's
Are You Ready?