An Overview of the 30-Day UST Walkthrough Inspection
Background
In 2015, the United States Environmental Protection Agency (EPA) updated the 1988 underground storage tank (UST) technical regulations. The 2015 UST regulation changed certain portions of the 1988 regulation including the addition of periodic operation and maintenance requirements for UST systems. Among those requirements was the walkthrough inspection.
Federal (EPA) Requirements
The Federal walkthrough inspection requirements, to be conducted every 30 days (except spill prevention equipment at UST systems receiving deliveries at intervals greater than every 30 days may be checked prior to each delivery), required an owner/operator to check their spill prevention equipment and release detection equipment. In addition, the containment sumps and any handheld release detection equipment are to be checked annually.
State Requirements
The state program approval (SPA) regulations set criteria for states to obtain the authority to operate in lieu of the federal program. State programs must be at least as stringent as the EPA’s program.
Owners and operators in states that have an approved UST program do not have to deal with two sets of statutes and regulations (state and federal) that may be conflicting. Once their programs are approved, states have the lead role in UST program enforcement. In states without an approved program, EPA will work with state officials in coordinating UST enforcement actions.
As of September 2021, 39 states, the District of Columbia, and the Commonwealth of Puerto Rico had state programs approved under the 1988 UST regulation. States are now applying for their state programs to be as stringent as the 2015 UST regulation.
Why do some states use the term 30-Day Walkthrough Inspection and others Monthly Walkthrough Inspection?
Federal regulations state that UST walkthrough inspections must be conducted at a frequency of no greater than 30 days, hence the term 30-Day Walkthrough Inspection.
However, many states require that a walkthrough inspection be conducted each calendar month and at a frequency of no greater than 30 days, hence the term Monthly Inspection.
Note: Federal regulations originally used the term monthly inspection; however, the concern was that it could be interpreted as any day in that month. For instance, January 3rd and February 20th - which would exceed the 30 days and thus was changed to the 30-Day Walkthrough Inspection. Many state agency walkthrough inspection forms are designed for an entire calendar year, with an inspection being conducted each calendar month (at a frequency of no greater than 30 days). It is possible that the month of February could be missed if the January inspection was conducted on one of the last days of the month.