The Facility Operations Inspection (FOI)
Commonly Asked Questions by Storage Tank Owners Concerning Facility Operations Inspections (PDF)
Who
The FOI is considered a regulated inspection activity. To meet DEP’s inspection requirements, the FOI must be performed by a DEP-certified individual holding Underground Storage Tank (UST) Inspector (IUM) certification. The following search can help you find a DEP-certified storage tank company employing UST inspectors.
Certified Storage Tank Companies Search
The facility owner should plan to be present or designate a Class A or Class B operator to be present during the FOI inspection. You may find more information about the operator training program here: UST Operators
What & Where
On October 11, 1997, DEP adopted regulations pertaining to periodic inspections of UST systems. These inspections have been called Facility Operations Inspections (FOI) and are used to determine the tank system’s integrity and suitability for continued use. The FOI includes the review of records pertaining to the installation, release detection monitoring, and maintenance of the UST system. The FOI also includes a physical inspection of all equipment which can be examined and observed aboveground, through manways, or other access methods.
As a storage tank owner or operator, you should have your UST system prepared for physical inspection on the date agreed upon with your IUM.
You should also prepare the following records for your inspector:
- Release Detection Records
- Monthly tank and piping release detection checks
- Periodic evaluations
- Examples of the evaluation forms can found here: 2018 Revisions to Pennsylvania’s Storage Tank Regulations in the Underground Storage Tank Testing Forms section.
- Spill Prevention and Overfill Prevention Evaluations
- Your spill bucket and overfill devices require periodic evaluation, you can find more information on this here: New Requirements for Underground Storage Tank Systems (PDF)
- Modification Reports
- Any previous modifications to your USTs should be documented on a UST Modification Report Form.
- Corrosion Protection records
- Corrosion Protection Evaluations should be documented on this UST Cathodic Protection System Evaluation Form (PDF)
- 60-day Rectifier Check if you have an Impressed Current Cathodic Protection system
- Tank and Piping Construction records
- Operator Training Certificates and List of Designated Class A/B and C operators
- Records of participation in the Underground Storage Tank Indemnification Fund (USTIF)
- Copies of other records relevant to your USTs
When
| Events Triggering FOIs | Time until FOI |
|---|---|
| Installation | No earlier than 6 months after installation. No later than 12 months after installation. |
| FOI is completed | Maximum of 3 years after Date of First Site Visit (found on page 1 of your FOI Report form) You can also find your due date on your registration certificate. |
| Property or UST changes ownership | No earlier than 6 months after change of ownership. No later than 12 months after change of ownership. |
Inspection Forms
- UST Facility Operations Inspection
DEP Led Inspections
DEP may conduct inspections at your facility with or without notice.
Please note: DEP Inspections do not replace your required 3rd party Facility Operations Inspection.
These inspections may occur in response to information reported on your most recent FOI, compliance history trends, or to verify DEP records are accurate and complete.
DEP inspectors may examine the accessible physical components of your UST system, operation of release detection equipment, operation of overfill alarms, and request review of records pertinent to your UST system. DEP Inspectors may also interview Class A, Class B, and Class C operators to ensure the UST system is being operated in compliance with pertinent regulatory requirements.
At the completion of a DEP inspection, you or your designated operators will receive an inspection report that notes the compliance status of your facility during that inspection.
More Information
For more information or for printed copies of UST Inspection forms, write or call:
DEP, Bureau of Environmental Cleanup and Brownfields
Division of Storage Tanks
P.O. Box 8762
Harrisburg, PA 17105-8762
Email: tanks@pa.gov
Phone: 1-800-42-TANKS (within PA) or 717-772-5599