EMA this week cast a negative ballot on a proposed ASTM standard that could result in the mandatory use of professional inspectors to conduct a visual inspection of secondary containment areas for UST sumps prior to required integrity testing under federal UST regulations. The use of professional inspectors to conduct visual inspections of sump containment is not required under current federal UST regulations. EMA successfully fought against professional inspector requirements in the 2015 EPA UST amendments so that marketers could perform sump containment inspections and testing in-house, as a cost saving measure. EMA was also able to win approval of a low liquid level integrity test for sump containment in the 2015 UST amendments that limits liquid testing to the area below penetration points that are difficult and expensive to make liquid tight.
While the ASTM E3225-20 proposed standard would not be binding, many states incorporate ASTM standards as regulatory requirements. The standard was initially approved by ASTM in 2020 as a visual test for sump containment testing. The standard would have required a professional inspector with sophisticated optical equipment to conduct the integrity test. However, the EPA refused to recognize the ASTM visual integrity test because the federal regulations allow only vacuum or hydrostatic integrity testing for sump containment. Now, ASTM has reintroduced the standard as a visual integrity inspection procedure prior to conducting a liquid integrity test. In effect, the proposed standard simply changed the visual integrity test to a visual integrity inspection prior to hydrostatic testing; adding a costly inspection procedure that marketers can do under current UST regulations with the naked eye. The proposed standard also recommends stringent qualification for inspectors, including; two years of UST installment or system compliance experience; inspector training and examination requirements; 8 hours of annual continuing education applicable to UST systems; experience testing at least 50 sumps annually, at a minimum of 25 different locations; maintaining one million dollars in professional liability insurance and disqualification of owners and operators from conducting inspections due to conflict of interest.
ASTM standards are adopted by consensus which requires EMA objections to be addressed before a final standard is issued. EMA will report on developments as they occur.