How to file a Storage Tank Incident Report: A Guide to Florida Regulatory Compliance:
Managing storage tank systems requires more than just operational oversight; it demands strict adherence to Florida Administrative Code (F.A.C.) to protect both the environment and your business. One of the most critical steps in maintaining compliance is knowing when and how to file an Incident Notification Form (INF).
Failure to report an incident within the state-mandated timeframe can lead to significant fines, loss of insurance coverage, and increased liability. Below is a comprehensive guide to understanding your reporting obligations.
What Triggers an Incident Notification?
According to Rules 62-761.600, 62-762.601, and 62-762.602, F.A.C., facility owners must notify the County when specific “positive responses” or “unusual operating conditions” are detected.
1. Release Detection & Visual Alarms
You must file an INF if you encounter any of the following:
- Visual Evidence: Regulated substances found in piping, dispensers, or sumps, or visual inspections revealing uncontrolled pitting, corrosion, or structural damage.
- Electronic Alarms: Any alarm indicating that liquid, vacuum, or pressure levels are not being maintained, or if a sensor detects liquid in a normally dry interstice or sump.
- Pressure/Vacuum Changes: A 50% pressure change from one month to the next, or a complete loss of vacuum.
- Interstices Issues: Presence of groundwater, surface water, or regulated substances in the interstitial space.
- Mechanical Shutdowns: Instances where a line leak detector restricts flow or an electronic monitor shuts off power to the pump.
2. Failed Integrity Tests
If any of the following components fail a certified integrity test, it is considered a reportable incident:
- Double-walled tanks (including field-erected double bottoms).
- Double-walled integral piping.
- Piping, dispenser, spill containment, or hydrant sumps.
3. Unusual Operating Conditions & Environmental Signs
Even without a technical alarm, you must report:
- Erratic behavior of dispensing equipment or sudden loss of product.
- Odors of regulated substances in nearby soil, groundwater, basements, or utility lines.
- Large-scale leaks: Losses exceeding 500 gallons within a dike field (ASTs) or 100 gallons on impervious surfaces like asphalt or concrete.
- A failed Closure Integrity Evaluation.
The 72-Hour Rule: Deadlines You Can’t Miss
Timing is everything when it comes to FDEP compliance.
- Submission Window: The Incident Notification Form must be delivered to the County within 72 hours of discovery or before the close of the next business day.
- Where to Send: Forms should be faxed, emailed, or hand-delivered to the County. If the incident occurs at a County-owned facility, notify the local DEP District Office instead.
- The “False Alarm” Exception: If you investigate and prove within that 72-hour window that a discharge did notoccur (e.g., a faulty sensor), the form is not required.
The Investigation Timeline
Once an incident is discovered, the clock starts on the mandatory investigation.
| Milestone | Requirement |
| 14 Days | Deadline to complete the investigation to determine if a discharge occurred. |
| 45 Days | If the investigation is not resolved within 45 days, the tank system must be placed out-of-service. |
| Extensions | Extensions beyond 14 days require written approval from the Department or County. |
Pro Tip: Always notify your insurance carrier simultaneously. Most policies have strict “notice of claim” provisions that align with state reporting timelines.
Record Keeping for Long-Term Protection
Florida law requires that the Incident Notification Form, along with all supporting test results and investigation reports, be maintained on-site or digitally until the permanent closure of the storage tank system.
Expert Environmental Consulting
Navigating F.A.C. requirements can be daunting. If you’ve detected a leak, failed an integrity test, or need assistance managing a County inspection, our team is here to help you mitigate risk and ensure environmental safety.
Contact us today for a compliance audit or emergency incident support.
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