What are the Requirements for Storage Tank Records?
There are an estimated half million underground storage tanks (USTs) in the US today, with most utilized to store petroleum, petroleum derivatives, or other potentially hazardous substances. Owners of storage tanks are subject to strict controls on adding, moving, and shutting down storage tanks. There are also records required for regular inspections, reporting of leak detection, testing processes, and more.
These standards are constantly being updated, including the requirements for record retention and storage. Adding to the responsibilities of storage tank owners are the varying rules for recordkeeping from state to state, while still complying with federal Environmental Protection Agency (EPA) mandates.
New EPA rules were issued in 2015 and provide for strengthened regulations related to UST operations and maintenance. The goal is to prevent and detect releases from USTs to minimize contamination of groundwater resources while also standardizing minimum requirements.
Owners of USTs must provide training for operators of storage tanks and must report actual or suspected releases or spills. UST shutdowns or closures must also be reported, and detailed records of operation and maintenance must be retained.
What Storage Tank Records Must Be Retained?
There are multiple records that must be created and retained by UST owners:
- Notification forms for installing a new UST, including certificates of proper installation
- Notification of ownership – this is reported for assuming ownership of an existing UST
- Reporting of suspected releases. If the suspected release is subsequently verified, additional reporting is required to confirm any follow-up actions that were taken or planned to correct any impact caused by the UST release.
- Notification of UST closure – this must be reported to the agency with jurisdiction 30 days before closing the UST
Retention of Storage Tank Records
UST inspectors must have certain records available to them, requiring retention by the UST owner. These include:
- Leak detection maintenance and performance including the last year’s results of monitoring and the most recent tightness test
- Any leak detection performance claims must be retained for a five-year period
- Records of activities relating to repair, maintenance, or leak detection equipment calibration
- Release detection operations tests must be retained for three years
- If vapor monitoring methods are utilized for assessment of groundwater at the UST site, these records must be retained as long as that method is in use
New requirements for 2015 have special considerations for field-constructed tanks and airport hydrant systems. This requirement means owners of such tanks and systems must keep the most recent records of tank tightness testing, piping tightness tests, and vapor monitoring test results utilizing a tracer compound.
Additional Record Retention Requirements:
- Last three 60-day rectifier tests, and the last two 3-year tests of corrosion protection systems
- Written corrosion expert’s analysis of corrosion potential for the life of the UST system, where corrosion protection equipment is not in use for metal tanks and piping equipment
- All records of repairs or upgrades showing the work was properly completed. These records must be retained until the system is either closed or has a change in service.
- After permanently closing a UST, records must be retained for at least 3 years showing the site’s assessment results at the time of closure. This demonstrates any environmental impact of the UST.
- Records documenting the owner’s financial responsibility
- Another document required after 2015 updates pertains to USTs utilized to store substances related to ethanol, biodiesel, or other regulated substances. When this applies, records must be retained that prove compliance with storage of those specific substances.
- Records related to spill bucket tests, containment sump tests, and overfill inspections must be retained for a period of three years. There are exceptions for these records where such testing is not conducted, but this also requires specific documentation indicating UST integrity and that periodic monitoring is in practice.
- Walk-through inspection results must be retained for one year
- Operator training compliance documentation must also be retained
Maintaining Compliance with Storage Tank Records Retention
Non-compliance with record retention requirements can result in penalties and additional inspections under increased scrutiny. In addition to US EPA record retention policies, there may be additional record retention requirements imposed by state and local jurisdictions. Check with local agencies for any specific reporting and retention specifications in your area.