By Dr. Laura A. Swartz, Practical American Safety Solutions
In the fast-paced, busy world of fuel sales, routine but necessary tasks are often shunted to the back burner in favor of the immediate, pressing needs of the day. It’s easy to fall behind on regular inspection and maintenance tasks, and the time-consuming paperwork that accompanies them, when an overfill occurs or an ATG light is blinking or when you need a fuel delivery but your UST is red-tagged. Yet, we all know that routine inspections and maintenance can prevent overfills, alarms, and violations from occurring in the first place. It’s the stereotypical vicious circle.
These issues are evident in data shared by the Illinois Petroleum Marketers Association in its October 23, 2015 Weekly Bulletin. The “Top Eight Common Violations for Underground Storage Tank (UST) Facilities” include:
• 1,272 citations for spill buckets that had not been maintained or cleaned (1);
• 1,159 citations for failure to perform required quarterly inspections (2);
• 1,145 citations for failure to perform monthly tank monitoring via the ATG (3); and
• 939 citations for failure to have a required Operations and Maintenance Plan (4).
Your state may not require quarterly inspections, but the recently-revised federal regulations, published in the Federal Register on July 15, 2015, will make monthly and annual walk-through inspections mandatory in three years’ time. Owners/operators will be required to inspect spill prevention equipment, sumps, dispenser cabinets, monitoring/observation wells, cathodic protection equipment, and release detection systems at least once every 30 days. Moreover, records of each monthly inspection will need to be retained for one year (5). If you already have difficulty performing regular operation and maintenance tasks and inspections, now is the time to get into the habit.
Getting into the habit of regular inspections and maintenance can also help insure against overfills and alarms, reducing the likelihood that they will occur just as you are busy with another task. Fortunately, PASS can help!
You may have heard about PASS Tools at a trade show or through trade publications, but maybe you’re still left with the question, “What is it, and what does it do?” PASS Tools is an internet-based tool that will help you conduct inspections at your facility and maintain your records. With an internet-connected tablet or smartphone in hand, PASS Tools guides you through the tasks you need to accomplish in an inspection.
These tasks apply across the country, because we base them on the Petroleum Equipment Institute’s (PEI’s) RP900 (Recommended Practices for the Inspection and Maintenance of UST Systems), which is specifically recommended in the revised federal regulations . We are also equipping PASS Tools with the capability to complete and print state-specific forms, such as the Illinois Quarterly Equipment Inspection Checklist. You can take pictures of your equipment using your device and save those pictures in PASS Tools. You can even store pictures of your ATG printouts, so you have a digital copy in case the originals are lost or misplaced. At the end of the inspection, you can print out a complete record of that inspection to keep at the facility. PASS Tools even helps you schedule the next inspection and will send you reminders as the date approaches.
PASS Tools stores all of your facility information securely, and you can access it at any time from any internet-connected device. Beyond that, PASS Tools users are provided with a PASS Book, their customized facility Operations and Maintenance Plan. The PASS Book is a standard three-ring binder with dividers for a Site Map/Diagram, Facility Inventory, Emergency Procedures, Maintenance Schedule, and Inspections and front and back pockets for storing operator training certificates, proof of financial responsibility, and other required paperwork. All of this paperwork can be printed easily from PASS Tools.
PASS Tools makes collecting, storing, and retrieving all of your facility data easy. Even if your state doesn’t require an Operations and Maintenance Plan, the PASS Book provides a central location for maintaining hard copies of your facility information. When a state inspector stops by your facility while you’re in the middle of conducting a new hire orientation, you can hand the inspector your PASS Book and also have all of your records instantly available in digital form through PASS Tools. You truly need not fear any inspection—PASS has you covered.
About the Author: As the Education Director at PASS, Dr. Laura A. Swartz is responsible for researching, writing, and editing PASS’ operator training courses and working with regulators throughout the state approval process. With three degrees in English, Laura is PASS’ go-to wordsmith. Laura can be reached at firstname.lastname@example.org or by phone at 765-281-5588 ext. 910.
- Environmental Protection Agency. 40 CFR §280—Technical Standards and Corrective Action–Requirements for Owners and Operators of Underground Storage Tanks. July 2015.
- Illinois Petroleum Marketers Association/Illinois Association of Convenience Stores. “Top Eight Common Violations for Underground Storage Tank (UST) Facilities.” IPMA/IACS Weekly Bulletin 23 October 2015: 1.
- Petroleum Equipment Institute. UST Systems: Inspecting and Maintaining Sumps and Spill Buckets. Tulsa, OK: Petroleum Equipment Institute, 2005.
(1) Petroleum Equipment Institute. UST Systems: Inspecting and Maintaining Sumps and Spill Buckets. 7-8.
(2) 41 Ill. Adm. Code 176.555(b)
(3) 40 CFR §280.40-44
(4) 41 Ill. Adm. Code 176.655(b)
(5) 40 CFR §280.36