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Underground Storage Tanks (UST)

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October 2003
DHHS (NIOSH) Publication Number 2004-101
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Self-Inspection Checklist

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Guidelines

This checklists covers regulations issued by the U.S. Environmental Protection Agency (EPA) under 40 CFR 280. The purpose of these regulations is to reduce the likelihood of leaks of hazardous substances from these tanks into soil and ground water and to ensure timely detection and abatement of such releases. A yes answer to a question indicates that this portion of the inspection complies with the OSHA or EPA standard, or with a nonregulatory recommendation.

check mark symbol Questions marked with this symbol may require the help of an outside expert.

The regulations require registration and specific spill and leak prevention measures based on the type of UST, age of the tank, and substances stored in the tank system. USTs are any one or combination of tanks (including underground pipes connected to them) used to contain an accumulation of regulated substances. Regulated substances include petroleum products (e.g., gasoline and used motor oil) and certain other hazardous substances. Heating oil if stored and used on the premises is not covered by the Federal regulations.

States typically enforce the Federal regulations as well as adopt their own regulations for USTs. Please consult the appropriate agency in your state about any additional regulations and requirements. This checklist includes some recommended practices that are based on regulations adopted in the State of New Jersey.

Registration

  1. Is the underground storage tank system registered in your State with the appropriate State agency? [40 CFR 280.22]

    Performance Standards and Engineering Requirements

  2. check mark symbol Has corrosion, spill, and overfill protection been installed on all existing USTs? [40 CFR 280.21]
  3. check mark symbol Is corrosion, spill, and overfill protection planned for new USTs that will be installed? [40 CFR 280.20]
  4. check mark symbol Is monthly leak detection monitoring performed on all USTs? [40 CFR 280.40; 280.41 and 280.42]Note: Acceptable leak detection methods include at least one of the following: statistical inventory control, automatic tank gauging, groundwater monitoring, soil vapor monitoring, or interstitial monitoring. Tank tightness with inventory control (or manual tank gauging for small tanks) may be used for ten years or less, depending on the situation.

    Spill and Overfill Control

  5. Are procedures in place to ensure that USTs are not overfilled during delivery? Do procedures include methods to measure available tank volume and to meter delivery volume immediately before delivery? [40 CFR 280.30]

    Release Response Plan

  6. Is a release response plan available for inspection at the school that includes the following items? [recommended]
    1. Emergency telephone numbers of local and State officials.
    2. Emergency telephone number of the person in charge of the school during the emergency.
    3. Name and phone number of any spill cleanup contractor(s).
    4. Procedures to follow in the event of a spill or leak from the UST.

    Release Reporting, Investigation, and Cleanup

  7. Are all employees aware of conditions listed below that may indicate a leak? [recommended]
    1. Inventory records indicating unexplained loss of material
    2. Visible product or product vapors in surrounding soil, surface water, or adjacent well
    3. Erratic behavior by product-dispensing equipment
    4. Water levels greater than normally recorded condensation levels
  8. check mark symbol When any one of the above suspect conditions occurs, is a plan available to investigate the condition that includes the items listed below? [40 CFR 280.50 and 280.52]
    1. Checking inventory records for accuracy
    2. Conducting visual checks for leakage or damage
    3. Collecting and analyzing soil and water samples using appropriate methods
  9. check mark symbol After a release or leak is confirmed, is a plan followed that includes the items listed below? [40 CFR 280.61 through 280.66]
    1. Notify the appropriate State agencies.
    2. Implement the release response plan.
    3. Immediately empty the tank.
    4. Arrange for tank repair.
    5. Conduct a remedial investigation and document findings in a report.
    6. Clean up all impacted soils, surface water, ground water, and other affected media.

    Other Requirements

  10. check mark symbol Are USTs that are equipped with cathodic protection operated and maintained to provide continuous corrosion protection? [40 CFR 280.31]
  11. Are installation and repairs of USTs conducted only by qualified persons? [40 CFR 280.20 and 280.33]
  12. check mark symbol Are all USTs that do not meet Federal and State requirements placed out of service and closed according to Federal and State procedures? [40 CFR 280.21 and 280.70 through 280.74]