I have done a fair share of facility inspections and compliance audits throughout the years. One of the most common themes I have run across is disorganization of paperwork. The last few years have seen an increase in the number of Notices of Violation and penalty fines to the gasoline retailers targeted by the Regulatory Agencies. This increase of NOV’s and fines is due generally to an increase of focus on compliance which leads to an increased number of facility inspections. One of the most common violations includes the Monthly/Weekly Release Detection record keeping. These are the printouts generated from your automatic tank gauging system. Some of the tasks a State Regulator will do will be to - Unexpectedly arrive at your facility - Review all required paperwork including the release detection records - Observe the general condition of the facility - Ask the operator questions.

Organization is a key factor. Keeping your records organized, in chronological order and accessible goes a long way towards avoiding any fines. Typically if an inspector views the condition of the record keeping of release detection records as indicated by the photo, he will more apt to be dissatisfied and become increasingly critical during his inspection. This could potentially lead to NOV’s and fines. This is a common compliance issue that is a fairly easy fix.

There are many ways to do this. One is to place the monthly/weekly printouts in an envelope in chronological order by calendar year and save them in an accessible area for inspections. Another method that I was extremely impressed with was a retailer had purchased a three ring binder. The binder was clearly marked “Release Detection Records” Inside the 3 ring binder were collector card sleeves like the ones used to collect baseball cards. These clear plastic 3 ring sleeves each had 12 pouches that were used to hold the monthly release detection printouts by month. Each sleeve pouch was marked with month and year. And the 3 ring binder held 5 sleeves for the last 5 years. This doesn’t have to be your method, but you get the picture. Organization of record keeping is an easy way to avoid fines.

Third party management with remote monitoring of the automatic tank gauging systems is just one of ECS/eclipse’s specialties. We can take the headaches away. Please call for more information.

-Lorenzo DiBacco

Field Services Manager