Work Order No. 1004, QTR #1 - Walkthrough Inspections 1

Work Order No. 1004, Task 2, Subtask a

Quick Turnaround Request (QTR) No. 1

State Walkthrough Underground Storage Tank (UST) Inspections

Using contact information found at http://epa.gov/oust/wheruliv.htm, Skeo Solutions contacted nine 

states: New Hampshire, Rhode Island, Delaware, South Carolina, Wisconsin, New Mexico, Utah, 

Colorado, and California, to confirm that the state requires periodic walkthrough inspections. In 

addition, Skeo Solutions asked the following questions:

1. What are the areas at the facility the operators must inspect during the walkthrough inspection?

2. How long would the state estimate it takes operators to conduct a single facility walkthrough 

inspection?

3. Are walkthrough inspections typically performed by the facility operator or by a third-party 

contractor?

4. Does the state require owners/operators to keep records of the walkthrough?

5. If yes to question 4, how long does the state require owners/operators to keep a record of the 

walkthrough inspection?

6. If yes to question 4, how much detail is in the walkthrough inspection record? [For example: Is it 

a checklist? Or just a piece of paper saying that the walkthrough was conducted?]

7. If yes to question 4, is the state seeing significant compliance issues with owners/operators 

having the required walkthrough inspection records during their inspections?

8. Does the state believe their walkthrough inspection program is effective? Why or why not? 

[Seek examples of how or why the state believes their program is or is not effective (for 

example, compliance rates increased or the state is seeing fewer releases).]

Table 1 provides the detailed responses from each state. All states contacted require periodic 

walkthrough inspections. In general, the states require similar areas to be checked during walkthrough

inspections and estimated that the amount of time to conduct a single facility inspection would depend 

on the size of the facility. Walkthrough inspections in these states are performed by both facility 

operators and third-party contractors. Smaller operators tend to do the inspection themselves. All states 

contacted require walkthrough inspection records to be kept. Most of the states contacted require

records to be kept for 12 months, while others require records to be kept for 3 years. The walkthrough 

inspection records are mostly checklists, with varying levels of detail across the states. The states 

experience different levels of compliance with inspection record requirements, and states with more 

recent implementation of the requirements seem to experience lower compliance. Most states believe 

their walkthrough inspection programs are effective, but some states with newer programs believe it is 

too soon to assess effectiveness.
Work Order No. 1004, QTR #1 - Walkthrough Inspections 2

Table 1. State Responses Regarding Walkthrough Inspections1

State Responses

New Hampshire

Matthew Jones

Oil Compliance and 

Enforcement Subsection Chief

Contacted on January 10, 2013

1. The inspection checklist requires operators to look at the vents, vent caps, spill buckets, fill 

adaptors, fill adaptor caps, dry break adaptor, dry break adaptor caps, dry break poppet valve, 

dispenser hoses, dispenser nozzles, dispenser cabinets, oil transfer and dispensing areas, and the 

release detection/leak monitoring consoles.

2. The length of time it takes for a walkthrough inspection depends on the size of the facility, but the 

average time should be 10 to 15 minutes.

3. Walkthrough inspections are typically performed by the facility operator.

4. Yes, the state requires owners/operators to keep records of the walkthrough inspections.

5. The inspection records are required to be kept on file for a minimum of 3 years.

6. The walkthrough inspection record is a checklist that can be used for multiple tanks. On the 

checklist, operators can also indicate whether repair is necessary and whether corrective action was 

completed. 

7. Most facilities are conducting these inspections and they have the records readily available when 

requested.

8. Yes, the walkthrough inspection program is effective. If owners/operators are able to conduct these 

inspections, then they decrease the chance of a potential spill or release. The inspections help 

examine easily accessible areas where releases can occur as well as the monitoring system for the 

tanks. Unfortunately, the state does not have any real data specific to these particular inspections, 

but the overall sentiment is that these can only help. 

Rhode Island

Jillian Thompson

Sanitary Engineer

Contacted on January 22, 2013

1. During a walkthrough inspection, owners and operators must check the leak detection system; spill 

containment basins; dispenser hoses, nozzles and breakaways; dispenser and dispenser sumps; 

overfill alarm; cathodic protection system; alarm conditions; groundwater monitoring wells and 

tank pad observation wells; and spill and overflow response supplies.

2. A single facility walkthrough inspection would take about 20 minutes.

3. Walkthrough inspections must be done by the Class A/B certified operator designated for the 

facility. This may be the owner, the operator, or a third-party contractor.

4. Yes, the inspection checklists must be kept as routine records at the facility. 

5. The state requires the inspection records to be kept for 3 years. 

6. The walkthrough inspection record is a detailed 11-item checklist, with space to make comments 

and list any corrections made. 

 

1

Answer numbers in Table 1 correspond to question numbers on page 1.
Work Order No. 1004, QTR #1 - Walkthrough Inspections 3

State Responses

7. The state estimates that it has had a 40 percent compliance rate with its monthly inspection record 

requirement. This number has been generated from inspections done since September 2012.

8. The requirement was initiated on August 1, 2012, so it is too soon for the state to assess the 

program’s effectiveness. The state hopes to have a better sense of the effectiveness by August 1, 

2013.

Delaware

Suzanne Halter

Environmental Scientist

Contacted on January 14, 2013

1. During a walkthrough inspection, owners and operators must monitor the condition of all 

dispensers, dispenser sumps, access ports, and sumps. Inspections must include the removal of 

dispenser covers; checking of all fittings, couplings, and filters; and checking for the release of 

regulated substances. Sump covers must also be removed to check for an indication of release of 

regulated substances, and all access ports need to be inspected to make sure that covers, caps, and 

adaptors are tightly sealed. Finally, all spill bucket covers must be removed to ensure that all of 

them are empty and free of debris, water, and regulated substances.

2. The length of time it takes for a single facility walkthrough inspection depends on the facility.

3. Walkthrough inspections are typically performed by the facility operator.

4. Yes, the state requires walkthrough inspection records to be kept.

5. The state requires the walkthrough inspection records to be kept for 3 years.

6. The inspection record consists of a table, with columns for dispenser buckets, sumps, access ports, 

and spill buckets.

7. No, the state is not seeing significant compliance issues with owners/operators having the required 

walkthrough inspection records during their inspections.

8. It is too soon to tell if the walkthrough inspection program is effective.

South Carolina

Trey Morgan

Technical Advisor

Contacted on January 10, 2013

1. Operators must check their leak detection methods, whether through statistical inventory 

reconciliation (SIR) or with an automatic tank gauge (ATG). They also need to test the product pipe 

through product testing. Operators must also inspect their cathodic protection techniques every 3 

years for galvanic reactions and every month for impressed current systems. Operators must also 

open and/or check all dispensers, the tank top, vapor recovery units, spill buckets, and vent lines.

2. For the average 3-tank, 3 to 4 dispenser facility, the state estimates that it would take 1 hour for the 

inspection. For larger facilities with around 25 dispensers, the state estimates the inspection 

process would be 3 to 4 hours.

3. Approximately 85 percent of the inspections are performed by the owner’s representative, and 15

percent of them are performed by a third-party contractor.

4. Yes, the state requires owners/operators to keep records of the walkthrough inspections.

5. The owners/operators are required to keep inspection records for the previous 12 months.
Work Order No. 1004, QTR #1 - Walkthrough Inspections 4

State Responses

6. The walkthrough inspection record is a state-provided checklist and log. 

7. Yes, the state is seeing significant compliance issues with owners/operators having the required 

walkthrough inspection records during their inspections because they are still in the first year of this 

requirement. Many people still have not opened the packet of materials regarding these required 

inspections, and the familiarity with the requirement is still fairly low. Mr. Morgan expects 

compliance to take 2 to 3 years.

8. Yes, the walkthrough inspection program is effective for those who participate. The state has not 

seen a significant increase in compliance rates, but it had a fairly high compliance rate to begin with, 

due to its strong rapport with owners and operators. Rather than performing inspections every 3

years, the state conducted annual inspections and the inspectors know the owners by name.

Wisconsin

Sheldon Schall

Chief of Storage Regulatory 

Services

Contacted on January 10, 2013

1. For walkthrough inspections, the operators follow the Petroleum Equipment Institute (PEI)’s RP500 

“Recommended Practices for Inspection and Maintenance of Motor Fuel Dispensing Equipment”

and RP900 “UST Inspection and Maintenance” documents. 

2. The length of time required for a walkthrough inspection varies with the size of the facility, and may 

range from an hour at a small site with a couple tanks to a whole day for a truck stop.

3. Large, multi-station operators tend to hire third-party contractors, and some of them are 

contracting with third parties to serve as their A/B operator.

4. Yes, the state requires walkthrough inspection records to be kept.

5. The state requires inspection records to be kept for a minimum of 12 months.

6. The walkthrough inspection record is a checklist, and is complemented by the annual 10778 

inspection form. The 10778 inspection is a test done by a contractor to test the functionality of the 

overfill prevention, drop tube, ATG, emergency valve, and sump sensors.

7. Wisconsin has had the walkthrough inspection requirement in place for several years, and

compliance is much better than it was 2 years ago. Now, owners/operators expect inspectors to ask 

for records. Further, the state made 3-ring binders available to any facility that wanted them for 

record keeping.

8. Yes, the walkthrough inspection program is very effective. In particular, the 10778 functionality 

assessment gets the contractor on site to examine and document everything to eliminate noncompliance issues. Compliance has always been pretty high in Wisconsin, with 88.4 percent of 

facilities in compliance with all release prevention requirements, 84 percent in compliance with all 

release detection requirements, and 77 percent in compliance with both sets of requirements. For 

these statistics, compliance applies to items beyond what is required at the federal level, and also 

includes tanks that are temporarily out of service.
Work Order No. 1004, QTR #1 - Walkthrough Inspections 5

State Responses

New Mexico

Kalvin Martin

Program Manager

Contacted on January 11, 2013

1. During the walkthrough inspection, operators must inspect the ATG and cathodic protection

rectifier, which are usually located indoors. They must also look inside dispenser doors, inspect tank 

top appurtenances by looking in all manholes, look in tank risers that are accessible, and check for 

water in tanks. 

2. A single facility walkthrough inspection would take around an hour. An inspection could take twice 

that long at a larger facility, such as one with large manhole lids, or one with 4 or 5 tanks.

3. Walkthrough inspections are typically performed by the owner, who is usually the operator.

4. Yes, the state requires walkthrough inspection records to be kept.

5. The state requires walkthrough inspection records to be kept for 12 months.

6. The walkthrough inspection record is a checklist with specific items such as piping and tank release 

detection, tank water levels, overfill alarms, and water in sumps to be checked.

7. Of the facilities that have been inspected recently, over 50 percent have had the previous 12

months of records on file.

8. If the owner/operator actually conducts the walkthrough monthly, it seems to be moderately 

effective, as the state staff has heard stories about owners/operators finding seeping flexible piping 

and sumps full of water by conducting the walkthroughs. However, it is hard to correlate 

compliance with the number of releases.

Utah

David Wilson

Environmental Scientist

Contacted on January 10, 2013

1. The physical inspection includes visual inspection of spill containment, overfill, vapor recovery 

ports, containment sumps (i.e., dispenser, submersible, and transition), submersible pumps, and all 

dispensers. The facility’s current leak detection and corrosion protection records are also verified.

2. Inspection of an average-size facility should take 30 to 45 minutes.

3. It is the B operator's responsibility that the inspection is accurate and done correctly, whether it is 

completed by themselves, another employee, or a third-party contractor.

4. Yes, the state requires owners/operators to keep records of the walkthrough inspections.

5. The length of time these records need to be kept is not addressed in the rule. This is probably 

an oversight that will be addressed in a future rule change. These records needed to be kept 

beginning January 2012.

6. A specific checklist created by the State of Utah must be used for all monthly inspections.

7. It has taken a while to get the majority of facilities to start doing the monthly inspections and doing 

them correctly. Those doing the inspections are generally in significant operational compliance 

(SOC).

8. Yes, the walkthrough inspection program is effective. Those who do the monthly walkthroughs 

seem to be able to identify problems and have them resolved more quickly than those who do not. 
Work Order No. 1004, QTR #1 - Walkthrough Inspections 6

State Responses

Containment sumps and spill buckets that Mr. Wilson personally inspected have had fewer 

problems with debris and water when the operator has completed monthly inspections. Overall 

compliance rates have increased overall from about 10 percent to about 85 percent in the last year.

Colorado

Zach Hope

Petroleum Compliance 

Supervisor

Contacted on January 18, 2013

1. During a walkthrough inspection, the tank area must be visited in order to check spill buckets, 

measure for water in the tank, and check vapor recovery equipment (if applicable). The dispenser 

area must be visited to check hanging hardware. The ATG must also be checked for functionality 

and alarm status.

2. The length of time it takes to conduct a single facility walkthrough is 30 minutes.

3. Small owners/operators tend to do their own inspections, while larger facilities hire third-party 

contractors. 

4. Yes, the state requires walkthrough inspection records to be kept.

5. The state requires walkthrough inspection records to be kept for 12 months.

6. The walkthrough inspection record is a 2-page checklist.

7. No, the state is not seeing significant compliance issues with owners/operators having the required 

walkthrough inspection records during their inspections.

8. Yes, the walkthrough inspection program is effective because compliance rates are increasing and 

releases are being discovered more quickly.

California

Sean Farrow

Leak Prevention Regulatory 

Unit

Contacted on January 10, 2013

1. The operators must inspect the monitoring system and alarm history, tank-top containment sumps, 

spill containment structures, and under-dispenser containment areas. As part of the walkthrough 

inspection, the operator also needs to verify that all facility employees have been properly trained.

2. The amount of time it takes for a walkthrough inspection is dependent on the number of tanks, 

alarms, and spill buckets at the site and the number of dispensers that the designated operator 

must open.

3. Most facilities hire a third-party contractor for these inspections.

4. Yes, the state requires inspection records to be kept.

5. Inspection records must be kept on-site for the previous 12 months. If an enforcement case is 

brought up, the state or county can use up to 3 years of retained records. 

6. The walkthrough inspection record is a detailed checklist.

7. In California, local agencies perform the inspections, so the state is unclear about overall 

compliance issues with record maintenance.

8. The walkthrough inspection program seems to be working, as it allows owners/operators to 

understand what is happening on site, and actually do something about it.