Reporting And Recordkeeping
In 2015, EPA revised the underground storage tank (UST) regulations. Below you will find reporting and recordkeeping requirements.
Below are the federal reporting and recordkeeping requirements. You should check with your implementing agency (typically your state or local regulatory authority) about particular reporting and recordkeeping requirements in your area.
What Do You Need To Report?
You need to report to your implementing agency or EPA when UST systems are located in Indian country on the following occasions:
- When you install an UST, you have to fill out a notification form and submit it to your implementing agency within 30 days of bringing the UST system into use. This form provides information about your UST, including a certification of correct installation. (You should have already used this form to identify your existing USTs. If you haven't done that yet, be sure you do so now.)
- 2015 Requirement: Beginning on October 13, 2015 when you assume ownership of an UST system, you must fill out a notification of ownership change form and submit it to your implementing agency within 30 days of acquiring the UST system.
- 2015 Requirement: Beginning on October 13, 2015 you must notify the implementing agency at least 30 days before you switch to a regulated substance containing greater than 10 percent ethanol, greater than 20 percent biodiesel, or any other regulated substance identified by the implementing agency.
- 2015 Requirement: Not later than October 13, 2018 owners of airport hydrant systems and field-constructed tanks must submit a one-time notification of existence for these UST systems using the notification form.
- You must report suspected releases to your implementing agency. If a release is confirmed, you must also report follow-up actions you plan or have taken to correct the damage caused by your UST.
- You must notify your implementing agency 30 days before you permanently close your UST.
What Records Must You Keep?
You will have to keep records that can be provided to an inspector during an on-site visit that prove your facility meets certain requirements. These records must be kept as follows:
- You will have to keep records of leak detection performance and maintenance:
- The last year's monitoring results, and the most recent tightness test.
- Copies of performance claims provided by leak detection manufacturers must be kept for five years.
- Records of recent maintenance, repair, and calibration of on-site leak detection equipment.
- 2015 Requirement: Beginning on October 13, 2018 keep records of annual release detection equipment operations tests for three years.
- 2015 Requirement: Beginning on October 13, 2018 keep records of site assessments for groundwater and vapor monitoring methods for as long as the methods are used.
- 2015 Requirement: Beginning on October 13, 2018 keep the most recent tank tightness test, piping tightness test and vapor monitoring result using a tracer compound for airport hydrant systems and field-constructed tanks.
- You will have to keep records of the last three 60 day rectifier inspections and the last two three year tests of your corrosion protection system.
- If corrosion protection equipment is not used for metal tanks and piping, you must keep a record of the corrosion expert’s analysis of the site corrosion potential for the life of the UST system.
- You must keep records showing that a repaired or upgraded UST system was properly repaired or upgraded until the UST system is permanently closed or undergoes a change-in-service.
- For at least 3 years after closing an UST, you must keep records of the site assessment results required for permanent closure. (These results show what impact your UST has had on the surrounding area.)
- You must keep records that document your financial responsibility, as explained in EPA's booklet, Dollars And Sense.
- 2015 Requirement: Beginning on October 13, 2015 keep records demonstrating compliance with the compatibility requirement if storing regulated substances containing greater than 10 percent ethanol, greater than 20 percent biodiesel or any other regulated substance identified by the implementing agency, for as long as the UST system is used to store the regulated substance.
- 2015 Requirement: Beginning on October 13, 2018 keep records of spill bucket testing, containment sump testing, and overfill inspections for three years. If spill bucket or containment sump testing is not conducted, keep documentation showing the equipment is double walled and the integrity of both walls is periodically monitored for as long as testing is not conducted.
- 2015 Requirement: Beginning on October 13, 2018 keep records of walkthrough inspections for one year.
- 2015 Requirement: Beginning on October 13, 2018 keep records of demonstrating compliance with the operator training requirements.
The preceding discussion is summarized from the regulatory language in 40 CFR Part 280.34.