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Get Prepared for the 30-Day Walkthroughs of UST Systems

 

By October 2021, Iowa UST system owner/operators will be required to test their spill buckets, containment sumps, overfill prevention devices, and release detection equipment (periodic testing of these components is required on a three-year basis). With testing already occurring in other states, we know that a certain percentage of these system components will fail testing and require repairs and/or replacement. Many owner/operators have already started preparations for the inevitable replacement of spill buckets and overfill prevention devices by upgrading now.

Although Iowa’s rule has yet to start its journey through the formal rulemaking process, Iowa’s rule is very close to being finalized. FUELIowa, interested stakeholders, and the Iowa DNR have been cautious in the approach used to draft a rule that maximizes its benefit to human health and the environment while managing the impact on the small business owner/operators that provide the essential goods and services that literally fuel Iowa’s economy. 

The first change that owner/operators will see from Iowa’s adoption of EPA’s rule will be the requirement to conduct 30-day walkthrough inspections at your facility. The walkthroughs may be conducted by an employee (Class A, B, or C operator) or a for-hire service provider.  Records from the 30-day walkthroughs will be required to be kept on site or made readily available upon request. Records of 30-day walkthroughs will be reviewed on an annual basis by a third-party provider as part of EPA’s annual walkthrough criteria. For many FUELIowa members, this means that PMMIC will be requiring your 30-day walkthrough records as part of their annual inspection of your facility.  FUELIowa members that are not insured with PMMIC will need to contact an Iowa licensed UST professional to perform their annual walkthrough. Annual walkthroughs will not be required until one year after Iowa formalizes its rule.

What’s required in a 30-day walkthrough? EPA’s 30-day walkthrough requirement is a sensory based inspection conducted by a person with knowledge of the UST system. The person conducting the walkthrough inspection will be looking to confirm the operating conditions in the areas of spill containment equipment, overfill prevention equipment, and release detection systems. Additionally, the 30-day walkthrough inspection will inspect for any abnormal operating conditions in the fueling forecourt.

The 30-day walkthrough form should be finalized soon and will be distributed to retailers shortly thereafter. FUELIowa anticipates that voluntary compliance with the 30-day walkthrough requirement will begin in the fall and remain voluntary until the rule is finalized in the spring of 2020. FUELIowa members should begin developing a plan to implement the 30-day walkthrough inspections. 

During implementation, FUELIowa reminds its members to keep employee safety at the forefront.  Walkthrough inspections should be conducted during times of low traffic while balancing the availability of natural lighting. Persons conducting the inspections should wear bright colored clothing and the use of safety cones or safety tape to secure the are being inspected is encouraged. In talking with companies that perform other UST system inspections, the use of two-person teams during inspections has been suggested as a means to improve safety for the employees conducting the inspection.

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