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New Monthly Inspection Form
Wyoming Solid and Hazardous Waste Rules and Regulations, Chapter 1 Storage Tank Program, Storage Tanks (Chapter 1), Section 13(d), requires monthly inspections. The monthly inspections are to be conducted by a licensed Storage Tank Tester or by the facility’s licensed Class A or Class B Storage Tank Operator. During the monthly inspection, the current leak detection records must be reviewed.
Recently, a tester informed the STP that while they were doing monthly inspections the leak detection records were not onsite for review. Chapter 1 requires that leak detection records be kept onsite, readily available at a site located within the state of Wyoming, or readily available electronically on an onsite computer (cell phones do not suffice). If the monthly inspection is conducted by a licensed tester and the leak detection records are not available for review, the facility’s designated licensed Class A or B operator is required to review the leak detection records and this must be documented on the monthly inspection form. Any condition discovered during the monthly inspection is to be reported to the facility owner and/or operator. The documentation of the monthly inspections are to be kept onsite, readily available at a site located within the state of Wyoming, or readily available electronically on an onsite computer (cell phones do not suffice). Copies of the monthly inspection records are required to be submitted to the STP along with the operator’s annual inspection. A new version of the form can be found online (Click Here).
Operator’s Annual Inspections (OAIs)
There have been recent changes to the regulations concerning the operator’s annual inspections (OAIs). The records that are to be submitted to the STP are to be reviewed by the facility’s licensed Class A or B Storage Tank Operator and their name and license number are to be included on the OAI form. The OAI’s are to be documented on a form that has been approved by the STP (Click Here). All testing is to be conducted by a tester that has been licensed by the STP. The following information is to be submitted with the OAI form:
- Copies of all tank leak detection records for the 12 months preceding the OAI
- Copies of line leak detection testing results (if required), to include
- leak detector function testing (mechanical line leak detectors, electronic line leak detectors, and sump sensors)
- line tightness testing (if required)
- electronic line leak detector monthly .2 GPH test results
- Copies of monthly inspection reports for previous 12 months
- Copies of CP testing results (if testing conducted during OAI).
Owners and/or operators have told STP personnel that they have not completed their OAI on time because they have a “90 day grace period”. There is no “grace period”. Chapter 1, Section 13(g), states: “This annual inspection shall be conducted by the owner, the operator, or a licensed tester within 1 year of the previous inspection.”. What is confusing people is Chapter 1, Section 44. This authorizes the DEQ to issue a Fuel Delivery Prohibition or “Red Tag” Order when a facility is 90 days past due for their OAI. People who falsely believe there is a “Grace Period” for completing their OAI on time, should be aware Wyoming Statute 35-11-901(a) states: “Any person who violates, or any director, officer or agent of a corporate permittee who willfully and knowingly authorizes, orders or carries out the violation of any provision of this act, or any rule, regulation, standard or permit adopted hereunder or who violates any determination or order of the council pursuant to this act or any rule, regulation, standard, permit, license or variance is subject to a penalty not to exceed ten thousand dollars ($10,000.00) for each violation for each day during which violation continues…”.
The results of the OAI are to be submitted to the STP within 60 days of completion of the OAI. These records can be submitted by mail, fax at 307-635-1784, or by email to deq.stp@wyo.gov .
Guidance Documents
The STP has created Guidance Documents to assist owners, operators, testers and installers with interpreting the regulations. You can find our Guidance Documents online (Click Here).
Forms
The STP has a webpage specifically for forms used for required testing and monitoring (Click Here). If you have any questions regarding these forms, you can contact STP personnel at (307)777-7097.
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