Virginia Regulatory Town Hall
Department of Environmental Quality
State Water Control Board
Underground Storage Tanks: Technical Standards and Corrective Action Requirements [9 VAC 25 ‑ 580]
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5/9/23  2:15 pm
Commenter: John Sieger, Sheetz, Inc.

Periodic Walkthrough Inspections and months with 31 days


Lists the requirements for periodic O&M walkthrough inspections to be conducted on a 30-day cycle. The fact that EPA set a 30-day requirement for what was supposed to be a "monthly" walkthrough inspection is cumbersome to the regulated UST community/Owner-Operators, considering that there are 7 months in the year with 31 days in them. We strongly urge VADEQ to consider mimicking what Florida did (as a suggestion) with this requirement in their state and change the language of this statute to mandate it be known as a "Monthly" inspection, and set the limit on the maximum # of days to elapse between each inspection to be no more than 35 (or a number VADEQ is comfortable with) days. The resulting statute will permit one inspection to occur for each "month" of the year, avoid O/O from paying for 13 inspections, and provide for inclement weather delays, manpower issues and other routine negative factors to not affect compliance. We would also be in favor of retaining the language in the current statute, requiring spill prevention equipment receiving deliveries at intervals of longer than 30 days to receive an inspection prior to each delivery.

CommentID: 216929