An Easy Recordkeeping Checklist for USTs

Here’s a UST checklist to help you out with the paperwork:

1. Have owners and operators kept on file the following information (40 CFR 280.34(b)):
   • Corrosion expert’s analysis of site-corrosion potential if corrosion-protection equipment not used
     (40 CFR 280.20)?
   • Documentation of operation of corrosion protection equipment (40 CFR 280.31)?
   • Documentation of UST system repairs (40 CFR 280.33(f))?
   • Recent compliance with release-detection requirements (40 CFR 280.45)?
   • Results of the site investigation conducted at permanent closure (40 CFR 280.74)?
2. Are these records kept either at the UST site and immediately available for inspection, or at a “readily available alternative” site where they could be provided on request (40 CFR 280.34(c))?
3. Have you also kept the following release-detection records in your files (40 CFR 280.45)?
   • All written performance claims pertaining to release-detection system, and the manner in which these claims have been justified or tested by the equipment manufacturer or installer, for 5 years or other period established by the implementing agency?
   • Results of sampling, testing, and monitoring, maintained for 1 year; tank-tightness testing results kept until the next test is conducted?
   • Written documentation of all calibration, maintenance, and repair of release-detection equipment that are permanently located on-site, maintained for at least 1 year after servicing work is completed (or another period of time established by regulating agency)?
   • Schedules of required calibration and maintenance provided by the release-detection equipment manufacturer retained for 5 years from the date of installation?
4. Have you kept records of all financial mechanisms used to demonstrate “financial responsibility” for regulated USTs (40 CFR 280.111)?
5. Have you kept these records at the UST site or owner/operator’s place of business (40 CFR 280.111)?