DNR Releases Proposed Form for 30-Day Walkthroughs

The Iowa Department of Natural Resources Underground Storage Tank Section has completed a draft copy of the form that owners and operators will be required to fill out to satisfy the upcoming 30 day walkthrough requirement. The 30 day walkthrough requirement was included in the Environmental Protection Agency’s 2015 Underground Storage Tank Revisions. Compliance with the 30 day walkthrough requirements will be voluntary until Iowa finalizes its rule and the rulemaking process, including public comment periods, are complete. FUELIowa anticipates that Iowa’s rule will be implemented sometime in the spring of 2020 at which point the 30 day walkthrough requirement will become mandatory.

The requirements of the 30 day walkthrough include a sensory inspection of the spill containment area, overfill prevention equipment, and release detection equipment.  The 30 day walkthrough inspection should be completed by a person with knowledge of the UST system including an A,B, or C trained operator. Release detection records, signage, emergency contact information, operator training certificates, and cathodic protection rectifier readings are also included within the required inspection activities mandated by Iowa’s 30 day walkthrough form. Iowa’s 30 day walkthrough form also includes a section labeled Recommended Activities.  These recommended activities are not required to be completed during the 30 day walkthrough. They are included on the form as a best practices reminder for owners and operators in areas of importance.  No documentation is required to be completed in the recommended activities aection of the 30 day walkthrough form. Completed 30 day walkthrough forms should be kept on site for a minimum of one year. Documentation of completed walkthroughs must be provided upon the request of your insurance provider or the Iowa DNR.

FUELIowa suggests reviewing the draft form and implementing a plan to incorporate the new requirements into your oversight at your facility. Compliance with the 30 day walkthroughs is voluntary until Iowa finalizes implementation of EPA’s federal rule.  FUELIowa will continue to update members as that date approaches.