Montana's UST Compliance Inspection Program

In 1999, the Montana Legislature amended the Underground Storage Tank Act to encourage and emphasize continuing and long-term compliance with state and federal requirements for tank operation and maintenance.  The legislation provided that in order for continued operation, each underground storage tank (UST) must obtain an operating permit. 

Issuance of an operating permit is based on a compliance inspection that indicates that the UST is in compliance with Montana's operation and maintenance requirements.

Licensed private inspectors conduct the compliance inspections.

Amendments to the Underground Storage Tank (UST) Installer Licensing and Permitting Act provide for licensing several categories of inspectors.

The department and designated local governmental unit inspectors will provide oversight of the licensed compliance inspectors.

Compliance Inspector Application

You will need Adobe 5.0 or higher to use this online input form properly.  The form below can be filled out on-line, then printed, signed, notarized and sent to the DEQ.

UST Compliance Inspector Application Form (PDF)

Inspector Categories

The categories for inspectors include:

Compliance inspectors - licensed private sector inspectors who conduct inspections of operating underground storage tanks to determine compliance with spill, overfill, corrosion protection, release detection and recordkeeping requirements. They also verify that all tanks are registered, have the proper tags and operating permit, and meet upgrade requirements.

Compliance inspection oversight inspectors - department or local government officers, such as local health officers, sanitarians, local fire chiefs, or other persons designated or hired by the department, who conduct oversight of the private sector compliance inspectors.

Closure inspectors - department or local government officers that are licensed to conduct inspections of underground storage tank closures.

Installation inspectors- department or local government officers that are licensed to conduct inspections of underground storage tank installations.

Inspection Timing

All regulated underground storage tank facilities were required to have an inspection by January 1, 2002.

After the initial inspection each facility must be inspected every three years.

Inspector Qualifications

The department has determined the training and experience requirements for licensure of inspectors in each of these categories. Compliance inspectors are required to attend a comprehensive classroom and field training course, document previous inspection experience, provide references, and take a written and field examination before licensure. The oversight compliance inspectors are required to attend the same training and take the same examination as the compliance inspector. The closure and installation inspectors are required to pass the closure and/or installation examination(s). Continuing education credits are required of each category of inspector.

There are no minimum education requirements for any of the inspector categories. Each person interested in becoming an inspector must complete an application form and submit an application fee. The application form requests information concerning previous inspection experience and any training courses completed. Three references are also requested from people familiar with the applicant’s work experience for the compliance inspectors and the oversight compliance inspectors.

Testing and Certification for Compliance Inspectors

The licensing of compliance inspectors is handled similar to the way DEQ licenses tank installers and removers. They are licensed after submitting a complete application form and application fee, providing references and passing an examination. The following procedures will be used for testing and certification for each compliance and compliance oversight inspector.

Application Review.   To ensure the competency and effectiveness of potential compliance inspectors, a preliminary review of an applicant’s credentials prior to testing and training will be conducted. The application form asks for relevant experience and training and professional references. Each applicant will be allowed to complete the training and take the examination. Any applicant with minimal experience or no experience will be selected for additional field training and/or oversight.

Training.   The compliance inspector will be required to complete an eight-hour classroom training prior to being certified. An optional field training class will also be offered. Each licensed inspector will also be required to complete 16 hours of continuing education during the three-year licensure period.

Testing.   Each applicant must pass an examination that tests the applicant’s technical understanding. Each applicant must also required to pass a field practical exam. A score of 80% or higher is required to pass the written and practical examinations. The field practical exam will also be used by the DEQ as a tool to indicate where the inspector may need additional training or oversight.

Curriculum for Compliance Inspectors

The compliance inspector curriculum provides all the training material, study guides and references, rules and regulations, etc. necessary for an applicant to recognize and understand the operation of all the components of an underground storage tank system. It also provides necessary tank management and operation information.  Success on the inspector examination is dependent on a thorough knowledge of these materials.

Study Guide Material

  • Owner/Operator Manual
  • Searching for the Honest Tank (compliance inspector guide)
  • PEI/RP 100-00 (Recommended Practices for Installation of UST    Systems)
  • API 1615 (Installation of Petroleum Storage Systems)
  • API 1604 (Removal & Disposal of Used UST Systems)
  • API 1632 (Cathodic Protection of Underground Petroleum Storage Tank and Piping Systems)
  • Basic Course – Appalachian Underground Corrosion Short Course
  • NLPA Standard 631
  • LEAK LOOKOUT
  • STI R892-91

A Study Guide will be provided for each applicant upon receipt of the $210.00 fee. The fee charged for the Study Guide is subject to change and is based on the cost of the materials to the department.

Suggested References

  • SPCC Regulations
  • Red Jacket Line Leak Detectors Manual
  • Manufacturer’s Specifications for Piping & Tank Installations
  • Uniform Fire Code (appropriate sections)
  • Leak Detection Manual for Field Inspectors (Ken Wilcox Assoc.)

Training Material

  • Videos
  • Slide Presentations
  • Owner/Operator Manual
  • Equipment Representatives

Duties of Compliance Inspectors

Compliance inspectors are now responsible for most of the inspection duties previously conducted by state inspectors.  Those duties are as follows:

Pre-Inspection

The inspector should be knowledgeable of a site before conducting the inspection. Important background information includes such things as

  1. the exact site location,
  2. the type of equipment in place (how many tanks, suction or pressure piping, type of overfill devices, etc.),
  3. compliance history,
  4. responsible party (owner vs. operator),
  5. fee and registration status,
  6. permit review/fee status (if applicable), and
  7. on-site contact (essential for un-manned sites).

In addition, it will be necessary for the inspectors to notify the Department in advance of conducting inspections so that oversight inspections can be scheduled.

Inspection

The principal responsibilities of the compliance inspector during the inspection are to assess compliance with the following regulatory requirements:

  1. UST registration/notification/tags;
  2. UST upgrade requirements;
  3. Leak detection system operation, maintenance, testing, recordkeeping; and
  4. Corrosion system operation, maintenance, testing and recordkeeping.

Each inspector will be initially provided with several inspection forms. The inspection form will also be provided in electronic format. In addition to completing the inspection form, the inspector is expected to educate the owner or operator so that the facility's compliance is improved.  The inspector must review the inspection form with the owner/operator and discuss any violations or problem areas.

Post Inspection

Following an inspection, compliance inspectors must:

  1. Immediately notify the Department of any release discovered during the inspection;
  2. Identify methods to correct violations;
  3. Obtain the owner's or operator's signature on the inspection report; and
  4. Provide a copy of the inspection report to the DEQ within 10 days of the inspection date.

DEQ will review the inspection report and determine whether a violation has occurred. The inspector is expected to provide all reports to DEQ for this determination. The inspector may fix the deficiency and note it has been fixed on the inspection report. Inspections must be conducted at least 90 days before the expiration date of the operating permit to allow time to correct deficiencies. This correction timeframe should allow Petrofund eligibility to remain intact in most cases.