A Quick Summary of the Legal Changes:
The Florida Department of Environmental Protection (FDEP) published the new changes on August 27th, 2018 based on the June 20th Rule Development Workshops.
The new law states that “Any visual inspection of any part of a storage tank system, dispenser, pipe, valve, pump, or other wetted portion of the system containing regulated substances that reveals uncontrolled pitting corrosion, structural damage, leakage, or other similar problems”. In other words, the FDEP has specifically included “pitting corrosion” as an incident under 62-761.430.
What Does that Mean for You and Why Does this Matter Right Now?
For our present and future Florida clients who no longer inspect the inside of their sumps, owners are now required to report pitting corrosion as an incident and investigate it. If pitting corrosion is identified within the sump, the owner is responsible for the repairs.
How Can You Prevent Additional Overhead Costs?
Thankfully, our team is prepared to handle any potential sump corrosion. Out team uses the Zerust (https://www.zerust.com/) product to fix corrosion issues, reducing overhead costs, and enhancing overall customer experience.
We foresee this ruling change becoming an issue if sumps are not inspected for pitting corrosion. Our inspectors provides a 5-day notice of an inspection between our sump inspections. When the inspector opens the sumps, there could be an incident for pump head and other components that are pitting from the corrosion. Consequently, a NCL could be issued and the client would have 14 days to have it resolved under the new law.
For Further Reading Taken from the FDEP Website:
Chapter 62-761, Florida Administrative Code (F.A.C.):
- Chapter 62-761, F.A.C., August 2018 Coded Draft Rules to be Amended
- Form 62-761.900(2) Storage Tank Facility Registration Form August 2018
- Form 62-761.900(3) Financial Mechanisms for Storage Tanks August 2018
- Instructions for Conducting Sampling During Underground Storage Tank Closure, August 2018
Chapter 62-762, F.A.C., August 2018 Coded Draft Rules to be Amended
- Form 62-762.901(2) Storage Tank Facility Registration Form August 2018
- Instructions for Conducting Sampling During Aboveground Storage Tank Closure, August 2018
Additional Rulemaking documents located on the Storage Tank Systems Rulemaking
webpage from the June 20, 2018, Rule Development Workshops did not have additional changes after the workshops.