15 
How to Prepare for an UST 

Compliance Inspection 

Guidance for Owners and Operators of 

Underground Storage Tank Facilities in Oregon 

-<: ^ 

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DEQ 

State of Oregon 

Department of 

Environmental 

Quality 

Land Quality Division 

Underground Storage 

Tank Compliance 

Program 

811 SW Sixth Ave. 

Portland, OR 97204 

Phone: (800) 742-7878 

Fax: (503) 229-6977 

www. deq. state, or. us 

July 2009 

Mitch Scheel 

08-LQ-117 

o 

PRINTED ON RECYCLED PAPER 
Do You Need a Copy of the UST Regulations? 

OAR Chapter 340;^ Division 150 

Access our Web Page at: 

http;//www.deq.state.or.us/lq/tanks/ust/index.ht m 

or 

Call DEQ at: 

1-800-742-7878 toll free In Oregon (message line) 

or 

(503) 229-6652 

Important Note: 

Financial Responsibility records will be reviewed at the time of field 

inspections. The following publications from the U.S. Environmental 

Protection Agency (EPA) may be helpful: 

"Dollars and Sense" 

"List of Known Insurance Providers for UST Owners and Operators" 

http://www.epa.qov/swerustl/pubs/index.htm 

Do You Have Comments or Suggestions for Improving this Guidance? 

Please let us know! 

Send comments and suggested changes to: 

Department of Environmental Quality 

UST Program Policy Coordinator 

811 SW Sixth Avenue 

Portland, OR 97204 
Oregon Department of Environmental Quality 

Underground Storage Tank Program 

How TO PREPARE FOR AN UST COMPLIANCE INSPECTION 

PURPOSE 

The purpose of this guidance is to assist underground storage tank (UST) owners and operators 

in preparing for a compliance inspection by Department of Environmental Quality (DEQ) staff. 

Using this guidance will not only prepare you for an inspection, but may also help you ensure 

that your facility remains in compliance with UST requirements at all times. 

$1,500 FINES 

Inspections should be taken very seriously. Beginning March 10, 2008, DEQ inspectors have the 

ability to issue citations directly to you totaling $1,500 for violation of the UST regulations. If 

certain serious violations are discovered during the inspection, you could be assessed civil 

penalties which may end up costing you thousands of dollars. 

GENERAL INFORMATION 

The UST regulations are contained in Oregon Administrative Rule (OAR) Chapter 340, Division 

150. Oregon has adopted federal Environmental Protection Agency (EPA) regulations (40 CFR 

Part 280) with some modifications. The "Permittee" is the person responsible for the day-to-day 

operation of Underground Storage Tank (UST) system. DEQ issues an UST General Permit 

Registration Certificate to a specific Permittee. 

The Permittee is responsible for maintaining compliance with all state and federal rules and 

requirements associated with the installation, operation, maintenance and repair of an UST 

system. This is an important responsibility, as this work will help prevent leaks from occurring 

that can contaminate soil and groundwater. 70% of Oregon's citizens rely on groundwater as a 

primary or secondary source of drinking water. Failure to properly operate and maintain UST 

system equipment can result in the contamination of drinking water and the loss of a significant 

financial investment. 

WHA T TO EXPECT DURIN G THE INSPECTION 

At the time of your scheduled compliance inspection, you must be prepared to display, 

demonstrate and provide specifications for mechanical and structural UST components. You 

must also provide specific records, receipts and testing results that establish compliance with 

requirements for operation and maintenance of UST systems. You should have your system 

manuals on hand to refer to while operating the equipment. Please be aware that the 

inspector is there to review records and observe operation of equipment - the 

inspector wil l not operate the equipment or open containment covers for you. 

You will also be asked to provide copies of records pertaining to release detection for tanks and 

piping, testing of any and all devices as required by rule, repairs and maintenance activities, and 

an as-built drawing of the UST system. If you have any doubt of your ability to meet the 

requirements of a thorough compliance inspection, DEQ recommends that you contact a licensed 

UST service provider or equipment vendor to assist you during the inspection. The Department 

DEQ UST Inspection Guidance Page 1 of 8 
expects you to make prior arrangement for any such assistance and to be fully prepared to 

complete the inspection on the date scheduled. 

Finally, you will be asked to document compliance with the financial responsibility requirements 

in OAR Chapter 340 - Division 151. For those facilities buying UST pollution liability insurance 

this means making available for the inspector's review a copy ofthe UST Certificate of Insurance 

form. For those using self-insurance it means providing an appropriately worded letter from the 

Chief Financial Officer. And in a few cases it means providing a trust agreement, standby trust 

agreement or copy of a surety bond. 

Compliance inspections may take as long as 4-6 hours at a large facility and will require your 

uninterrupted attention and assistance for the entire time. Access will be required into all UST 

system hatch covers, manways, sump covers and other entry points. You should have all 

necessary authorization, keys and tools to provide access as required. Again, you must be 

able to open any covers or entry points, as part of a demonstration of your ability to 

operate all components. Advance planning, professional assistance and patience will help 

expedite the inspection process and avoid situations that may be disruptive to normal business 

operations. 

How TO USE THI S GUIDANCE 

Each Permittee is expected to be familiar with the UST system components and equipment at 

their facility as well as the UST regulations. With this knowledge, you can review this guide and 

determine the "Compliance Items" that apply to your facility. Compliance Items are specific 

requirements listed in state and federal rules that the DEQ inspector will be checking. This guide 

provides a listing of specific compliance items for new and existing UST systems, including 

release detection methods, spill prevention, overfill prevention, corrosion protection, and repairs. 

Pages 3 through 8 are labeled A to M by section. All facilities are required to provide the 

information listed in Parts A, B, C, E, F, H, I, J, K, L and M of this document. Depending on the 

type of release detection method(s) in use at your facility, you will need to complete one or 

more sections in Parts G.l through G.6. Each section has been labeled to match the report form 

that DEQ inspectors use in the field. There is no Part D in this guidance at this time. 

TECHNICAL ASSISTANCE 

After the inspection (or during, if appropriate), the UST inspector will be happy to answer any 

technical assistance questions you may have. In addition, each inspector carries copies of a 

number of guidance documents and regulations that they will be glad to provide you with. 

AFTER THE INSPECTION 

If you "pass" the inspection without any problems, DEQ will send you a brief letter to document 

your compliance status at the time of the inspection. Otherwise you will also be notified if any 

violations are observed during the inspection and issued a "Field Citation". The Field Citation will 

include specific actions that must be taken to correct the violations, a schedule for completing 

these actions and a monetary fine for the violations noted. Once these corrections have been 

made and the monetary fine has been paid, DEQ will send you a brief letter to document that 

compliance has been achieved. 

DEQ UST Inspection Guidance Page 2 of 8 
We hope you find this guidance helpful. 

A 

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HAVE ' Ifonj"-

YOU R XievNtc AJ 

Review the information or question for each item listed that pertains to your facihty. 4Check the 

box when you have assembled the required information or understand the requirement and can 

demonstrate compliance. 

Part A Facility and Owner/Operator Information 

Provide the following information regarding property ownership, tank ownership and the person responsible for the day-to-day 

operation of the facility. 

Name, Address, telephone and Fax numbers for the: 

Tank Owner, Property Owner and Permittee 

o Current information is available for all three and ready to be given to DEQ. 

PartB Underground Storage Tank Information 

Provide or verify facility information that includes: UST facility number and Operating Certificate number. For each tank: permit 

number (i.e. ABCD), your tank ID, product stored, tank diameter and length, volume, installation date, tank type and installation date 

for corrosion protection and lining, if applicable. ' 

o Current information is available and ready to be given to DEQ. 

Part e Facility Layout Diagram 

Provide a detailed "as built" diagram of the entire facility. The diagram must include the location of all UST system components 

including all USTs, piping, dispensers, spill prevention devices, overfill prevention devices and all elements of any UST or piping 

corrosion control system. 

o As-built diagram is available and ready to be given to DEQ. 

Part D Reserved for Future Use 

PartE Spill Prevention 

Compliance Items. 

o Are spill devices required on all tanks? 

o Is the fill pipe fitted with spill containment? 

o Is the turbine pump fitted with spill containment? 

o Are the dispensers fitted with spill containment? 

o Are all the containment devices clean and dry so that a spill can be contained? 

o Is there any visual sign of soil impacted by spills? If so, was the release reported to DEQ? 

DEQ UST Inspection Guidance Page 3 of 8 
PartF Overfill Prevention 

Compliance Items ' •., ' 

o Are overfill devices required on all tanks? 

o Do tanks have fill pipe shutoff devices? 

o Do tank vents have ball float valves? 

o Do tanks have high level alarms? 

Release Detection Methods 

The release detection method used at your facility should be listed below. Find your method for USTs and 

piping, then refer to the corresponding section (Parts G.l through G.6) for a listing of Compliance Items for that 

method. 

Method for USTs 

o Automatic Tank Gauging - G.l 

o Interstitial Monitoring - G.2 

o Statistical Inventory Reconciliation (SIR) • 

o Inventory Control & TTT - G.3 

o Manual Tank Gauging - G.4 

o Manual Tank Gauging & TTT - G.4 

G.3 

Methods for Pressurized Piping 

o Interstitial Monitoring - G.2 

o Automatic line leak Detector - G.5 

o Annual Line Tightness Test - G.5 

Methods for Suction Piping 

o Interstitial Monitoring - G.2 

o Line Tightness Test (3yr) - G.5 

o None Needed - Safe Suction - G.6 

o None needed - No underground piping 

Part G.l Automatic Tank Gauging (ATG) 

Compliance Items • 

o What is the make and model ofthe ATG and sensing probe? 

o Who installed the ATG and sensing probe? 

o Is the ATG manufacturer's information available at site? 

o Has the ATG been installed, calibrated and repaired as per the manufacturer's instructions? 

o Has the ATG received third party verification of device performance? Have documentation available. 

o Can the presence of tank probes be verified in each tank? 

o Is the ATG control unit connected and operating? 

o Is the tank test conducted at the required product volume and time? 

o Are 12 months of test records available? 

o Has the ATG ever indicated a release? If so, was the release reported to DEQ? 

Part G.2 Interstitial Monitoring- USTs and Piping 

Compliance Items 

o Is monitoring performed manually or electronically? 

o Is monthly monitoring performed? 

o Are sensing devices 3"" party certified? 

o Has equipment been installed, operated and maintained as per manufacturer's instructions? 

o Can the equipment detect a leak from any portion ofthe UST that contains product? 

b Is there a record of monthly monitoring conducted for each ofthe last twelve months? 

o Has the monitoring device ever indicated a release? If so, was the release reported to DEQ? 

DEQ UST Inspection Guidance Page 4 of 8 
Part G.3 Inventory Control, Tightness Testing and Statistical Inventory Reconciliation 

Compliance Items 

NOTE: As of December 22,2008 Inventory Control cannot be used as a primary release detection 

method. As of 12-22-08, one ofthe other methods listed^herein must be used as the primary release 

detection method. Inventory Control may be used as a secondary or backup method of release detection 

at the discretion of the permittee and tank owner. 

o Are readings recorded each operating day and reconciled monthly? 

o Is the correct calibration chart used to determine volume to the nearest 1/8 inch of product depth? 

o Are tank inventory readings recorded before and after each delivery? 

o Can gauge stick be read to nearest 1/8 inch and measure full height of product in tank? 

o Are monthly water readings measured to the nearest 1/8 inch and used in the inventory calculation? 

o Does each dispenser have a totalizer with a currently calibrated meter? 

Statistical Inventory Reconciliation (SIR) 

Compliance Items 

o Has the SIR method received third party approval for tanks? Have documentation available. 

o Have two consecutive monthly inconclusive results occurred in the last 12 months? If so, was the release reported to DEQ? 

Tightness Test 

Compliance Items 

o Has the tightness test method been third party approved? Have documentation available, 

o Did an Oregon licensed Service Provider for Tightness Testing perform the tightness test? 

o Has the ten-year exemption from advanced leak detection expired? 

All Methods 

Compliance Items 

o Are 12 months of monitoring data available? 

o Is the monthly reconciliation calculation performed each month? 

o Does the fill pipe drop tube extend to within one foot ofthe tank bottom? 

o Did all tanks pass the last tightness test? 

o Has a release or a suspected release ever occurred? If so, was the release reported to DEQ? 

Part G.4 Manual Tank Gauging 

Compliance Items 

o Do records show that level measurements are taken at start and end of a 36-, 44- or 58-hour period? 

o Is product added or removed during the gauging period? 

o Are measurements recorded weekly? 

o Is the monthly reconciliation calculation performed correctly? 

o Is the tank inventory product height at the start and end ofthe gauging period the average of two stick readings? 

o Is the weekly and monthly variation between start and end less than standard for tank size and test period? 

o Can gauge stick be read in 1/8 inch increments to full height of tank volume? 

o Is MTG the sole leak detection method for a tank with a volume of greater than 1,000 gallons? 

o Is Tank Gauging and Tightness Testing the sole method for a tank greater than 2,000-gallon tank? 

o Has the 10-year exemption from advanced leak detection expired? 

o Has a tightness test been completed in the last 5 years? 

o Are 12 months of monitoring records available? 

o Has a suspected release occurred? If so, was the release reported to DEQ? 

DEQ UST Inspection Guidance ' Page 5 of 8 
Part G.5 Pressure Piping Release Detection 

Automatic Line Leak Detectors 

Compliance Items 

o What is the line leak detector make and model? 

o Is the detector connected to an automatic shut off device? 

o Is the detector connected to an automatic flow restrictor? 

o Is the detector connected to a continuous audible or visual alarm? 

o Did all detectors pass the last annual test? 

o Is the detector 3"^ party approved? 

o Is the detector installed, operated and maintained as per the manufacturer's instructions? 

o Do any ofthe detectors indicate a release? If so, was the release reported to DEQ? 

Annual Line Tightness Testing 

Compliance Items 

o Is annual line tightness testing required as element of release detection? 

o Is a conventional line tightness test performed? 

o Is the tightness test 3'''party approved? 

o Was the fightness test performed by an Oregon certified tester? 

o Is an electronic tightness test performed? 

o Is the electronic line leak detector 3"* party certified at 0.1 gph? 

o Has the electronic device been installed, operated and maintained as per the manufacturer's instructions? 

o Do any ofthe detectors indicate a release? If so, was the release reported to DEQ? 

Daily Monitoring in Lieu of Annual Line Tightness Test 

Compliance Items 

o Is daily "in pipe" monitoring performed? 

o Is daily sump monitoring performed? 

o Can monitoring detect a leak in a portion ofthe piping that contains product? 

o Is monitoring equipment 3'^'' party certified? 

o Has monitoring equipment been installed, operated and maintained as per the manufacturer's instructions? 

o Are the results of daily monitoring being kept in a written log? 

o Are 12 months of daily records available? . • ' 

o Has the daily monitoring indicated a release? If so, was the release reported to DEQ? 

Part G.6 Safe Suction 

Compliance Items 

o Does the piping system slope to the tank and operate at atmospheric pressure? 

o Is only one check valve used? 

o Is the check valve located directly under the dispenser? 

o How were these requirements verified? Have documentation available. 

o Is a monthly monitoring method used? 

o Is a line tightness test performed every 3 years? 

o Is the tightness test 3'^'' party approved? 

o Was the tightness test performed by an Oregon certified tester? 

o Has the monitoring indicated a release? If so, was the release reported to DEQ? 

Part H Corrosion Protection for Steel 

Galvanic Corrosion Protection - Tanks and Piping 

Compliance Items 

o When'was the corrosion protection system installed? 

o Has the tank passed the NACE RP-0285 evaluation? 

o Has the piping passed the NACE RP-0285 evaluation? 

o What was the date ofthe 6-month inspection? 

o When is the first 3-year inspecfion due? 

o When was the last 3-year inspection performed? 

DEQ UST Inspection Guidance . Page 6 of 8 
o When is the next 3-year inspection due? 

o Are all corrosion protection tests on file? 

Impressed Current Corrosion Protection - Tanks and Piping 

Compliance Items 

o When was the corrosion protection system installed? 

o Is the system connected to power and turned "ON"? 

o Is the 60-day inspection log present and current? "^ 

o Has the tank passed the NACE RP-0285 evaluation? 

o Has the piping passed the NACE RP-0285 evaluation? 

o What was the date of the 6-month inspection? 

o When was the first 3-year inspection due? 

o What was the date ofthe last 3-year inspection? 

o When is the next 3-year inspection due? 

o Are the results ofall corrosion protection tests on file? 

Internally Lined Tanks (No External Corrosion Protection) 

Compliance Items 

o Was an internal inspection completed prior to lining? What method of inspection was used? 

o When was the lining installed? 

o When is the 10-year inspection due? 

o When is the first 5-year inspection is due? 

o What is the date of the last inspection? 

o When is the next inspection due? 

Note: Under certain conditions where external corrosion protection is in place internal lining inspections 

may not be required. Does your system qualify for this exemption? If you are uncertain, discuss this 

matter with the UST Inspector. 

Part I Cathodic Protection System Testing 

Provide the results of all required cathodic protection system tests. Make sure that the test contractor provides a detailed report that 

includes a diagram with the location of reference electrode(s) used during rheasurement of soil-to-structure potentials clearly marked. 

o Current information is available and ready for DEQ to review. 

Part J Temporary Closure 

Compliance Items 

o Are any tanks currently not in use? 

o On what date was the use ofthe tanks discontinued? 

o Have any tanks been out of use longer than three months? 

- o Ifthe tanks have been closed more than three months, has the system been capped and secured as required? 

o Is there still product in any tank that is not currently used or is in temporary closure? 

o Are all corrosion protection systems operating on closed tanks? 

o Are corrosion protection systems operated, maintained and tested as required? 

o Are closed tanks with internal lining inspected as required? 

o Is leak detection for piping performed as required? 

o Has the monitoring indicated a release? If so, was the release reported to DEQ? 

Part K Facility Upgrade and Repair History 

The Permittee must notify DEQ prior to any upgrade work and document work performed. You must also keep records ofany repairs 

made to system components and specifically list significant problems associated with equipment or materials. 

o Current information is available and ready for DEQ to review. 

DEQ UST Inspection Guidance Page 7 of 8 
Part L Financial Responsibility 

The Permittee must provide documentation to demonstrate compliance with the financial responsibility requirements. Most frequently 

this will be a ''Certificate of Insurance for Underground Storage Tanks". Please note that an ''ACORD" certificate IS NOT acceptable 

documentation. Facilifies relying on self-insurance must have a specifically worded letter from the Chief Financial Officer. 

o Current information is available and ready for DEQ to review. 

Part M UST System Operator and Emergency Response Information 

The Permittee of a facility that dispenses a regulated substance from an UST to a motor vehicle must employ trained personnel who 

can properly operate and maintain the UST system and must provide emergency response information to any person that dispenses a 

regulated substance from the UST system. 

I 

o A current training certificate was available for the designated USTSystem Operator? 

o A copy ofthe emergency response written instructions provided to persons dispensing regulated substances was available for 

review, 

o Emergency Response signage is posted in prominent areas that are easily visible to persons dispensing a regulated substance. 

o Current information is available and ready for DEQ to review. 

DEQ UST Inspection Guidance Page 8 of 8