A Basic Checklist For UST's

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UST Checklist UST Checklist (in PDF format) EPA - Musts for USTs EPA Notification Form UST Publications

The information and checklist that follow can help you evaluate your underground storage tank systems (USTs). You can use the checklist to see how closely you meet the Federal regulations for USTs (40 CFR Part 280). The checklist can also help you prepare for official inspections of USTs.

Please note that this checklist covers only Federal regulations for operating USTs properly. The checklist does not cover requirements for corrective action in response to UST leaks. Be sure you check with your State and local agencies to see if they have additional or different requirements for your USTs. States and industry organizations may provide you with their own checklists. You can use this hotlink to identify State contacts--or call EPA's Hotline at 800-424-9346 to identify appropriate State contacts or to ask questions about the UST requirements.

Filling Out The Checklist

The checklist provides columns for up to four USTs. Make as many additional copies of the checklist as you need to cover all your USTs as you periodically evaluate their compliance status.

Use The Checklist Periodically

Many of the following items need to be reevaluated periodically to ensure your USTs that may be in compliance at one point in time STAY in compliance over time. Do not fill out the checklist once and then forget about it. At a minimum, you should update your checklist response at least once a year or whenever your make changes to USTs, repair equipment, or respond to any operational problems. You need to make sure you follow all operation and maintenance procedures that can keep your USTs in compliance, protect your investment, and protect human health and the environment from costly leaks. Avoid violations and penalty fees by constantly keeping USTs in compliance.

Need More Information To Answer Questions?

You may find you need more information as you fill out the checklist. You may need to know more about release detection choices and their restrictions, for example. Each section of the checklist refers you to a corresponding section in EPA's Musts For USTs: A Summary Of Federal Regulations (July 1995). You may also want to refer to other EPA publications on release detection requirements, such as Straight Talk On Tanks, Doing Inventory Control Right, Manual Tank Gauging, and Introduction To Statistical Inventory Reconciliation. All EPA publications on USTs are easily retrieved without cost from this hotlink to publications or call EPA's Hotline at 800-424-9346 or publications distributor at 800-490-9198.

Some Basic Information On Federal UST Requirements Follows Below

Implementing Agency

Some items refer to "the implementing agency." The "implementing agency" is simply the agency that has jurisdiction over your USTs. The state environmental agency is usually the implementing agency--use this hotlink to find State implementing agencies. If your USTs are in Indian Country, contact your Regional U.S. EPA--you can use this hotlink to find Regional EPA contacts.

Release Detection

• Long-term "Monthly Monitoring" methods: These methods include interstitial monitoring, automatic tank gauging systems, groundwater monitoring, vapor monitoring, and other methods approved by an implementing agency to work equally well, such as statistical inventory reconciliation (SIR). Be sure you check pages 8-11 in Musts For USTs (or the other publications noted above on release detection) to make sure you understand the various restrictions and limitations of each method when used at your UST.
• Temporary release detection methods: For 10 years following installation of a new UST or the upgrading of an old UST, you can often use a combination of periodic tank tightness testing with either inventory control or manual tank gauging. Be sure you check pages 8-11 in Musts For USTs (or the other publications noted above on release detection) to make sure you understand the various restrictions and limitations of each method when used at your UST.
• Don't forget about the additional requirements for your UST's piping. Pressurized piping and suction piping have different requirements (page 11 in Musts For USTs).

Corrosion Protection

All tanks and piping must be protected from corrosion, but USTs installed before December 22, 1988 can use some retrofit approaches not allowed for USTs installed on or after December 22, 1988. Be sure you know the corrosion protection requirements for each of your USTs.

Spill Protection

All USTs must be protected from spills by having devices such as "spill buckets" or catchment basins that can contain spilled product.

Overfill Protection

All USTs must be protected from overfills by using such devices as automatic shutoff devices, overfill alarms, or ball float valves.

Recordkeeping

As a rule of thumb, keep records of reports, tests, repairs, and other actions or know where these records are kept at an off-site location. In some cases, such as closure site assessments, records may be kept by implementing agencies.

Notification

You should have filed a notification form with your implementing agency for all USTs at your facility. Notification forms for USTs installed after December 22, 1988 must include a certification of correct installation.

Closing USTs

You can temporarily close an UST by meeting the requirements for temporary closure (page 25 in Musts For USTs), which at a minimum can involve continuing operation of release detection and corrosion protection methods. Permanent closure of an UST requires several steps intended to ensure the safety of those closing or removing tanks and to determine if contamination from your UST is present in the surrounding environment (page 25 in Musts For USTs).

Financial Responsibility

You must demonstrate your financial responsibility for the cost of cleaning up a leak and compensating other people for bodily injury and property damage. Financial responsibility levels depend in part on the number of USTs you have and if you are a marketer or nonmarketer. Please refer to EPA's Dollars And Sense for a full explanation. All EPA publications on USTs are easily retrieved without cost from this hotlink to UST publications or call EPA's Hotline at 800-424-9346 or publications distributor at 800-490-9198.

Corrective Action

This checklist does not address requirements for reporting and responding to an UST leak. The steps you need to take in responding to an UST leak are usually dictated by site-specific conditions and the procedures established by the implementing agency. Be sure you check with your State implementing agency or U.S. EPA Regional contact on steps to take.

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