Fuel storage facilities can have underground or aboveground storage tanks. Federal and state regulations require facility operators to follow specific procedures intended to prevent spills or seepage of fuel into the environment. The U.S. Environmental Protection Agency (EPA) has authority over fuel storage facilities. In most cases, the EPA delegates oversight to state agencies. Check the regulations for exact guidelines for conducting inspections in your state.
Regulations require facility owners to keep certain records concerning the fuel storage facilities. Place the state environmental protection registration placard, certification of financial responsibilities and current local government permit in a location for easy display. Keep the following records on file for a minimum of two years: monthly detection results, electronic release detection equipment function checks, monthly maintenance visual examination and results, presence of regulated substance’s odor sheen or free product. In addition, keep all data results, tightness pressure and integrity tests, repair operation and maintenance records and Certificate of Financial Responsibility.
In addition, keep the following records for the life of storage tanks: manufacturer’s performance claims for the leak detection system and dates of improvement/replacement storage systems, internal inspection results, installation/maintenance/inspections/ testing for cathode protection systems, storage system installations/replacement/upgrades, closure assessment report for facilities still in operation and written Release Detection Response Level information.
Internal Leak Detection
Facilities need internal or external release detection equipment, including automatic tank gauges, Statistical Inventory Reconciliation (SIR) for underground storage tanks (UST), Interstitial monitoring for all double-walled USTs and underground piping. The facility owner must perform inventory reconciliation each month for single-wall USTs. If the system does not have an inventory reporting, use a dipstick to check the fuel inventory. Avoid using a deteriorated dipstick; it can yield inaccurate readings.
External Leak Detection
Conduct monthly check on groundwater or vapor monitoring wells; record the results. Use a screwdriver to check the grouting to ensure it’s solid. Ensure well caps provide a watertight fit; secure them with clips or locks. Keep all lock keys available at the facility. The well-monitoring pipe must extend a minimum of 1 inch above the grout surface. Clean bailer/cord between samplings, which prevents cross contamination of tanks. Some facilities use disposable bailers. When using monitoring well probe, check the wire and connections.
Conduct an inspection of the dispenser and assembly for defects. Record the results in a log for proof of inspections. Regular inspections help detect problems in the early stages and limit leaks and emissions. Examine the vapor recovery breakaway valve for connections for leaks. Look at hoses for flattened areas or tears and cuts. Listen to ensure the vacuum works. Examine continuous automatic leak detection sensor connections. Verify the height of the sensor from the secondary containment bottom. The system should sound the alarm if the fuel leaks or excess liquid accumulates in the dispenser pump.
Perform checks on the fuel filter, cathode protection system wires/connections and the valve lever and connection on the emergency shutoff or shear valve. If accessible, view the flex pipe connection for breaks or tears. The primary and secondary containment pipes should slope back to storage tanks.
Perform a monthly visual inspection of sumps, the areas containing submersible pumps. If the sumps have a sensor, a periodic inspection will suffice. Covers should provide a tight fit. Check covers for cracks or holes and inspect them for water tightness. Look for sweat or leaks on all connections. Verify flex and semi-rigid connectors do not have ballooning, swelling degradation or other defects.