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How a Compliance Inspection Worksinspection

Inspections are normally conducted on a 12 month basis. The inspector will call the tank owner 7 to 10 days prior to schedule the inspection.

One part of the inspection process will be records review. The following is a list of the minimum records that will be needed for the review (dependent upon equipment in place, methods in use, and manufacturer specifications):

  • Current Registration Certificate posted in a visible location
  • Current Financial Responsibility Certificate
  • Most recent twelve months of passing tank release detection records:
    • Automatic Tank Gauge (ATG)
    • Statistical Inventory Reconciliation (SIR)
    • Interstitial Monitoring (IM)
    • Groundwater Monitoring (GM)
    • Vapor Monitoring (VM)
    • Manual Tank Gauging (MTG)
  • Most recent twelve months of passing line release detection records:
    • Electronic Line Leak Detector (ELD)
    • Interstitial Monitoring/Sump Sensors (IM,SS)
    • Statistical Inventory Reconciliation (SIR)
  • Most recent testing records:
    • Line tightness test
    • Mechanical Line Leak Detector function check
    • Electronic Line Leak Detector function check
    • Sump sensor function check
  • Cathodic protection records:
  • Most recent twelve months of complete Class A/B operator log
  • List of all trained Class C operators
  • Any maintenance and/or repair information
  • Current fuel supplier name and address

The second part of the inspection process is a complete walk-through of the associated tank system equipment. It is the tank owner’s responsibility to make sure there is someone present to assist the inspector in accessing all equipment and that all keys to locked equipment are available. The following items will be inspected:

  • Spill buckets & Fill ports
  • Vapor recovery ports (if present)
  • Submersible turbine pumps and corresponding equipment (if present)
  • ATG ports (if present)
  • Underneath all dispensers
  • Vent lines
  • Rectifier box (if present)
  • Cathodic protection wiring throughout parking lot (if present)

Even though the Division does not directly regulate them, inspectors will gather information about the following items:

  • Aboveground storage tanks (if present)
  • Closest water supply well (both public and private)

Once the information gathering is complete, the inspector will issue one of the following:

  • An In Compliance Letter, or
  • A Notice of Alleged Violation

If an In Compliance Letter is issued, it means that everything is in compliance with the regulations and no follow-up is needed.

If a Notice of Alleged Violation (NOAV) is issued, it means that follow-up in some form may be required. The NOAV will instruct the tank owner on what must be done to become in compliance again. It will also give a due date. Once the due date has been reached, if the facility is still not in compliance, the Division will begin the delivery prohibition process.

Another requirement to gain compliance after an NOAV is issued, is for the A/B operator to complete retraining. This is required per the Operator Training requirements (Part 280.35). If the Class A/B operator is present at the time of the inspection, the inspector may perform retraining at that time. Otherwise, the NOAV will instruct the tank owner to have the A/B operator contact the Division prior to the due date to complete retraining


For more information please contact the Bureau of Land & Waste Management at (803) 898-2000 or visit our offices (note new location).