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A BASIC CHECKLIST FOR USTs Checklist Page 1 The information and checklist that follow can help you evaluate your underground storage tank systems (USTs). State and industry organizations may provide you with their own checklists. Cortland County follows the NYSDEC regulations. You can go to www.dec.state.ny.us/website/der/bulkstor for information on the petroleum bulk storage program. EPA’s website, www.epa.gov/OUST, offers further information and an assortment of useful publications. Please note that using this checklist does not guarantee that you are in fact in compliance with UST requirements. Only an official site inspection can confirm your compliance status and reveal potential violations and penalty fees. 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 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 www.epa.gov/OUST 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 Cortland County Health Department is the implementing agency for facilities in Cortland County. Cortland County has been delegated the PBS program by NYS DEC. Release Detection • While the EPA requires Long-term Monitoring, NYS requires weekly monitoring. The acceptable 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). EPA’s Musts For USTs, pages 8-11, describes 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. 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). ---PAGE BREAK--- A BASIC CHECKLIST FOR USTs Checklist Page 2 If you cannot answer any of the following questions or find that you are missing something, you must take action quickly to remedy the situation. If not, you may be cited for violations and subject to penalty fees during official UST inspections. Note: This checklist covers most Federal regulations, Changes have been made to take state regulations into account. Answer by entering: for Yes or NA for Not Applicable Please note that filling out this checklist does not guarantee that you are in fact in compliance with UST requirements. Only an official site inspection can confirm your compliance status. Facility name or ID#: Date of today’s evaluation: Your USTs have RELEASE DETECTION? (Weekly inspections require by NYS) Need at least one check in each column UST #1 UST #2 UST #3 UST #4 UST uses Interstitial Monitoring at least weekly? UST uses Automatic Tank Gauging at least weekly? UST uses Vapor Monitoring at least weekly? UST uses Groundwater Monitoring at least weekly? UST uses Manual Tank Gauging alone (only for tanks <1001 gallons)? UST uses Manual Tank Gauging & Tank Tightness Testing (only for tanks <2001 gallons and 10-year maximum use)? UST uses Inventory Control and Tank Tightness Testing ? Specify any other release detection method, such as SIR: If UST has PRESSURIZED PIPING: Need at least one check in each column Piping has automatic flow restrictor? Piping has automatic shutoff device? Piping uses continuous alarm system? If UST has PRESSURIZED PIPING: Need at least one check in each column Piping uses annual line tightness testing? Piping uses weekly monitoring ? If UST has SUCTION PIPING: Need at least one check in each column Piping uses weekly monitoring ? Piping uses line tightness testing every 3 years? Piping has no release detection requirements? You keep RECORDS OF RELEASE DETECTION? Respond in all columns & rows You keep records at least 1 year showing the results of repairs and of weekly testing, and monitoring of release detection (except for tank tightness testing records, which you keep until the next test)? You keep records at least 5 years of calibration and maintenance of release detection ---PAGE BREAK--- A BASIC CHECKLIST FOR USTs Checklist Page 3 equipment? Put NA in the box if you use manual tank gauging, inventory control, or tank tightness testing. You keep vendor’s performance claims and results of third-party evaluations for 5 years for interstitial monitoring, automatic tank gauging, vapor monitoring, groundwater monitoring, tank tightness testing, or other applicable approved methods? Your USTs have CORROSION PROTECTION? Need at least one check in each column UST #1 UST #2 UST #3 UST #4 Tank is fiberglass? Tank is coated & cathodically protected steel? Tank is steel clad (or jacketed) with noncorrodible material? Tank retrofitted with cathodic protection? Tank retrofitted with interior lining? Specify any other method used to achieve tank’s corrosion protection: Corrosion protection for PIPING? Need at least one check in each column Piping is fiberglass? Piping is coated & cathodically protected steel? Piping retrofitted with cathodic protection? Specify any other method used to achieve piping’s corrosion protection: You have RECORDS FOR CATHODIC PROTECTION? Respond all columns & rows If you have sacrificial anodes, you have the documentation of the last 2 inspection results conducted by a qualified cathodic protection tester within 6 months of installation, at least every year thereafter, and within 6 months of a repair? If you have an impressed current system, you have documentation of the last three rectifier readings that need to be taken every 60 days to show that the rectifier is working properly? (Most USTs will share one rectifier.) Your UST has SPILL PROTECTION? Respond all columns UST has spill protection equipment, such as catchment basin? Your UST has OVERFILL PROTECTION? Need at least one check in each column UST has automatic shutoff device? UST has overfill alarm? UST has ball float valve? OTHER REQUIREMENTS for entire facility: Respond in each row for entire facility You keep records of all UST system repairs for the operating life of the UST system ? If you have permanently closed any USTs, you satisfy the requirements for permanent closure and keep site assessment results? If you have temporarily closed any USTs, you satisfy the requirements for temporary closure? You have evidence of “Financial Responsibility” ?