Staying in Compliance Inventory Control Bill Greer GTEC

Inventory Control and Tightness Testing Regulatory Requirements: Inventory control can be used as a temporary method (10 years after new installation or upgrading an UST with Cathodic Protection) but it must be combined with tightness testing.

Inventory Control and Tightness Testing Regulatory Requirements: Tightness testing when combined with Inventory Control as a Release Detection Method should be performed once every 5 years for 10 years. A monthly monitoring method (S.I.R., ATG, etc.) is required after 10 years.

Inventory Control Regulatory Requirements:  Must record:  Volume measurements for inputs and withdrawals.  Volume amount still remaining in the tank each operating day.

Inventory Control Regulatory Requirements:  Must be capable of:  Measuring the product level over the full range of the tank’s height.  To the nearest 1/8 inch.

Inventory Control Regulatory Requirements:  Inputs:  Inventory must be measured before and after delivery.  Reconciled with delivery receipts.

Inventory Control Regulatory Requirements:  Deliveries must be made through a drop tube that extends to within one foot of tank bottom.

Inventory Control Regulatory Requirements:  Product dispensing must be metered and recorded within local standards.

Inventory Control Regulatory Requirements:  Must check for water once a month to the nearest 1/8 inch.

Inventory Control Inventory Control Considerations: Use an accurate tank chart and a good quality tank stick.

Inventory Control Inventory Control Considerations: Use the correct forms. Daily Inventory Worksheet Monthly Inventory Record (or use your own Computer Generated Forms)

Forms can be found in:

Web Site to Download Inventory Publication

Inventory Control NOTE: If your reconciliation is not within the allowable limits for 2 consecutive months, you must notify your regulatory agency ASAP that your tank may be leaking (suspected release).

Inventory Control If the overage or shortage is greater than or equal to 1.0 percent of the tank's flow-through volume plus 130 gallons of product, the UST may be leaking.

Inventory Control Example: Monthly thruput = 10,000 gallons: 1% gallons = = 230 gallons

GROUNDWATER MONITORING Groundwater must be within 20 feet of the surface Monitoring wells are used to sense the presence of liquid product floating on the surface Tank Leak Detection Other Methods – Groundwater Monitoring

SOIL VAPOR MONITORING Tank Leak Detection Other Methods – Soil Vapor Monitoring

New EPA Reg Requirements Perform Walkthrough Inspections Every 30 Days Perform Walkthrough Inspections Every 30 Days –Spill Buckets, Overfill Prevention, and Release Detection –Must Keep Records of Walkthrough Inspections Perform Annual Inspections of Containment Sumps and Hand Held Release Detection Equipment Perform Annual Inspections of Containment Sumps and Hand Held Release Detection Equipment Spill Buckets must be tested every 3 years for tightness, unless double walled with periodic interstitial monitoring Spill Buckets must be tested every 3 years for tightness, unless double walled with periodic interstitial monitoring Overfill Prevention Equipment must be inspected every 3 years Overfill Prevention Equipment must be inspected every 3 years

New EPA Reg Requirements Containment Sumps must be tested every 3 years for tightness, unless double walled with periodic interstitial monitoring Containment Sumps must be tested every 3 years for tightness, unless double walled with periodic interstitial monitoring Under Dispenser Containment Sumps (UDC) are now required when installing new dispenser systems Under Dispenser Containment Sumps (UDC) are now required when installing new dispenser systems Ball Float Valves no longer approved for overfill prevention on new UST installations Ball Float Valves no longer approved for overfill prevention on new UST installations –Existing Ball Float Valves can continue to be used for OFP, must be tested every 3 years –If an existing Ball Float Valve fails an operability test it must be replaced with one of the other approved overfill prevention devices (automatic shutoff device or overfill alarm)

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