STORAGE TANK INSPECTION AND COMPLIANCE
PHILLIP BENTON
CERTIFIED TANK INSPECTOR
HDR EOC
PETROLEUM SYSTEMS DIVISION
419 CANYON AVENUE, SUITE 316
FORT COLLINS, COLORADO 80524
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:

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Inadequate venting capacity,
Liquid in the interstitial space,
Using the vent for something other than venting,
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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
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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.
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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 3-460-03F
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
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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.
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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.
10.0 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.
10.2 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.
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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.
11.2 Wiring
Inspect the wiring and the conduits for damage that may allow water to enter the conduit
or junction boxes.
11.3 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 1910.106: 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.
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EPA requirements for inspection and testing of ASTs and associated piping are found in 40 CFR
112.7, 112.8 and 112.12. 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 Bulk Storage Containers
Aboveground
Regularly
40 CFR
“Test each aboveground container for integrity
containers
scheduled
112.8(c)(6)
on a regular schedule, and whenever you make
material repairs. The frequency of and type of
integrity
and
testing must take into account container size
testing,
112.12(c)(6)
and design (such as floating roof, skidfrequent
mounted, elevated, or partially buried). You
visual
must combine visual inspection with another
inspection
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.”
Field-erected
Brittle
40 CFR
“If a field-constructed aboveground container
ASTs
fracture
112.7(i)
undergoes a repair, alteration, reconstruction,
or a change in service that might affect the risk
testing
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.”
Liquid level
Operational
40 CFR
“You must regularly test liquid level sensing
sensing devices test
112.8(c)(8)(v) devices to ensure proper operation.”
and
112.12(c)(8)
Containers
Integrity and 40 CFR
Requires “both periodic integrity testing of the
without
containers and periodic integrity and leak
leak testing
112.7(d)
testing of the valves and piping”.
containment or
diversionary
structures, for
which an
impracticability
determination
has been made
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APPLICABLE SPCC INSPECTION and TESTING REQUIREMENTS
Type of
Regulatory
Equipment
Inspection
Regulatory Requirement
Citation
or Test
Piping
Underground
Inspect
40 CFR
“If a section of buried line is exposed for any
piping
112.8(d)(1)
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.”
Underground
Integrity and 40 CFR
“You must also conduct integrity and leak
piping
leak testing
112.8(d)(4)
testing of buried piping at the time of
installation, modification, construction,
relocation, or replacement.”
Aboveground
Inspect
40 CFR
“Regularly inspect all aboveground valves,
piping, valves
112.8(d)(4)
piping, and appurtenances. During the
and
and
inspection you must assess the general
appurtenances
112.12(d)(4)
condition of items, such as flange joints,
expansion joints, valve glands and bodies,
catch pans, pipeline supports, locking of
valves, and metal surfaces.”
Rainwater Drainage
Rainwater
Inspect
40 CFR
Prior to draining accumulated rainwater,
accumulated
112.8(c)(3)
“inspect the retained rainwater to ensure that
inside diked
and
its presence will not cause a discharge… and
areas
112.12(c)(3)
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 (40 CFR 60.110 through 60.115) 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.
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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 1985.
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:
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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 www.epa.gov/oust/states/statcon 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.
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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 40 CFR
Part 280, 40 CFR Part 281, and 40 CFR Parts 282.50-282.105. The list of hazardous substances is
in 40 CFR Part 302.4.
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 2011 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
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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:
40 CFR, Part 112, Oil Pollution Prevention
40 CFR, Part 279, Standards for the Management of Used Oil
40 CFR, 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-05-001 (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-06-003
EPA, 2006b, Grant Guidelines to States for Implementing the Secondary Containment Provision
of the Energy Policy Act of 2005, EPA-510-R-06-001
EPA, 2007, Grant Guidelines to States for Implementing the Operator Training Provision of the
Energy Policy Act of 2005, EPA-510-R-07-005
EPA, 2009a, State Underground Storage Tank Programs: Available on EPA's Web site at
www.epa.gov/swerustl/fsstates.htm
EPA, 2009b, State Delivery Prohibition Programs: Available on EPA's Web site at
www.epa.gov/swerustl/dp/index.htm
DoD & Air Force Policy/Guidance:
AFI 23-201, Fuels Management, 1 December 2009
AFI 23-204, Organizational Fuel Tanks, 24 June 2009
AFI 32-7044, Storage Tank Compliance, 13 November 2003
AFI 32-1054 Corrosion Control, 1 March 2000
TO 37-1-1, General Operation and Inspection of Installed Fuel Storage and Dispensing Systems
UFC 3-460-03, 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
970-416-4410
Phillip.Benton@hdrinc.com
2011