Safe Operating Procedure
(Revised 3/14)
UNDERGROUND STORAGE TANKS – SUMMARY OF
RECORDKEEPING REQUIREMENTS
_____________________________________________________________________
The purpose of this SOP is to summarize recordkeeping requirements related to Underground
Storage Tanks (USTs).
Records Required by EPA’s Spill Prevention Control and Countermeasures
(SPCC) Regulations
Table 1 summarizes records that must be maintained in accordance with UNL’s SPCC Plans.
These requirements apply to the City Campus Utility Plant USTs since they are not fully
regulated under Title 159. All other USTs at UNL facilities are not subject to SPCC
requirements. UNL’s written SPCC Plans contains additional information and record-keeping
forms.
TABLE 1 – SPCC Recordkeeping Requirements (5 year Record Retention)
Record Type
Description
Generation and Maintenance
As applicable, check all visible
Annual inspection conducted by EHS with records
maintained in the EHS Office, AND; Monthly
portions of the UST system
Visual
including fuel lines, pumps,
inspections by the UNL UST operator with records
Integrity
maintained in the onsite tank files, AND; Any time
pump houses, secondary
Inspection
containment structures, etc.
the lines or other parts of the UST system are
Inspect for corrosion, damage
uncovered (i.e., repair), with records maintained in
and leaks.
the onsite tank files.
Annual inspection conducted by EHS with records
maintained in the EHS Office, AND; After use
Spill Kit
Evaluation of the amount and
inspections conducted by UNL UST operators, with
Inspections
integrity of spill supplies.
records maintained in the onsite tank files.
Container/
Inspection of the area around
Annual inspection conducted by EHS with records
Tank Area
USTs for security, lighting,
maintained in the EHS Office.
Inspection
record keeping, etc.
Inspections are conducted by the UNL UST
Fuel
Each loading/ unloading event
operators, with records maintained in the onsite tank
Transfers
must be documented.
files.
Training is required at the following frequencies:
initially; in response to spill events or failures; when
the SPCC plan changes significantly or fails in the
Initial and annual refresher via
event of an emergency; when, through observation of
Training
EHS Web-based training
work practices, it is apparent that an individual is in
module.
need of more training; and annually. Generally, initial
and annual training is conducted on-line and records
maintained by EHS.
Releases/
See Table 2
Spills
Records Required by NDEQ’s Release/Spill Regulations
(Created 3/06; Revised 6/06, 8/09, 8/10, 10/11, 8/12)
UNL Environmental Health and Safety · (402) 472-4925 · http://ehs.unl.edu
Table 2 summarizes records that must be maintained in accordance with Nebraska Title 126,
Chapter 18 and/or Title 200. These requirements pertain to all UST systems at UNL (including
those that are not subject to SPCC requirements).
TABLE 2 – NDEQ Release/Spill Recordkeeping Requirements
Record Retention: Until the UST system is permanently taken out of service, removed, clean-up actions
(if applicable) are completed, and Title 200 reimbursement (if applicable) is received
Record Type
Description
Generation and Maintenance
Immediate verbal notification to NDEQ
& UNL’s Building Code Official for any UST operators must immediately notify
release of fuels/ oils below the surface EHS. EHS will make the verbal notification
Notification(s) of
of the ground; any release to a storm
to regulatory authorities. No specific
releases
sewer or other surface water; any
document is required for verbal notification;
release that poses a danger to
however, a record of the telephone call
humans; and any release outside of a should be made. EHS maintains the record.
building of 25 gallons or greater.
A formal, written report as described
EHS submits the written report. The normal
in Nebraska Title 126, Chapter 18
time-frame for submittal is within 15 days of
Follow-up reports describing the events that caused the
the release. NDEQ may require additional
to notifications of release; the volume and type of
reports depending on the nature and
releases
material released and actions taken to
duration of the cleanup. EHS maintains the
clean up the release and to prevent it
record.
from happening again.
Remedial design plans are generally
These plans are generally prepared to
prepared by consultants, under the direction
describe activities that will be taken to
Remedial design
of EHS. They are filed with NDEQ and must
reduce the long-term environmental
plans
be pre-approved by the agency to retain
impact of a release (i.e., source
eligibility for Title 200 reimbursement. EHS
removal, free product removal, etc.).
maintains the record of the plan.
EHS reviews the work product of a
Remedial action
These reports are the product of a
consultant/engineer/contractor for
reports (including remedial design plan and describe
completeness and submits the report to
analytical results) progress in cleaning up a release.
NDEQ. EHS maintains a copy of the report.
EHS or the consultant/engineer/contractor
Title 200
working on UNL’s behalf prepares the
In some cases, UNL may be eligible
reimbursement
documents describing the work done and
for reimbursement of a portion of the
requests
costs associated with it. EHS maintains a
costs for responding to releases from
(including
copy of the submittal and response from
USTs.
financial records)
NDEQ.
Records Required by NE Title 159 UST Regulations
Table 3 summarizes records that must be maintained in accordance with Nebraska Title 159 for
those UST systems at UNL subject to these regulations.
TABLE 3 – UST Recording Keeping Requirements
Record Type
Description
Generation and Maintenance
Record Retention Time
Permits and Notification (See EHS SOP, Underground Storage Tanks –Permits and Notifications
for a list of UST systems that are subject to installation and closure permits and registration)
Application is made
Installation and
Operating permit must
prior to installation;
UNL FMP, tank operator, and
Operating
be maintained until the
permit issued by
EHS.
Permits (NA to
system is permanently
UNL’s Building Code
certain USTs)
taken out of service.
Official.
One-time
Farm, residential,
UNL’s Building Code Official and
Until the UST system is
(Created 3/06; Revised 6/06, 8/09, 8/10, 10/11, 8/12)
UNL Environmental Health and Safety · (402) 472-4925 · http://ehs.unl.edu
registration forms
heating oil tanks with
tank operator
permanently taken out
a storage capacity of
of service and notice is
less than 1,100
filed with UNL’s
gallons, and
Building Code Official.
permanently
abandoned tanks.
The permit is issued
when UNL’s Building
Code Official
Until closure is
approves the intent to The UNL Building Code Official
complete and Title 200
Closure permits
generates the permit
close request. The
reimbursement (if
permit must be
applicable) is received.
obtained at least 10
days prior to closure.
This report describes
Until closure is
actions taken to
Closure
approved by NDEQ and
UNL Building Code Official
remove an UST or
assessment
Title 200
any part of the
reports
reimbursement (if
system from
applicable) is received.
operation.
Integrity and Leak Testing/Inspection: Requirements vary depending on the type of UST system.
Refer to the EHS SOP, Underground Storage Tanks- Summary of Regulatory Requirements.
Inspection
Record of tests
reports for
performed to
The UST operator generates the record at
impressed
determine if the
least once every 60 days. The UST
6 months
current systems
system protecting the
operator maintains the record.
(fully regulated
UST from corrosion is
tanks only)
working properly.
Testing of
A certified contractor
impressed
A qualified contractor conducts the test
must test the
current systems
annually. The record is maintained by the 2 years
impressed current
(fully regulated
operator.
system.
tanks only)
Testing of
Record of tests
galvanic or
performed to
A qualified contractor conducts the test
sacrificial anode
determine if the
once every 3 years. The UST operator
6 years
cathodic systems system protecting the
maintains the record.
(fully regulated
UST from corrosion is
tanks only)
working properly.
Any repair to any part
Records of repair
of an UST system
to any parts of
Until the UST
must be documented.
A qualified contractor completes the work.
the UST system
system is
Note that any repair
The UST operator maintains the record.
(all UST systems,
removed.
to tanks or lines must
except those that
be followed by a
are exempt)
tightness test.
Inventory
Monthly tank gauging
Control/Tank
Monthly test by the UNL UST operator
records to
Gauging Records
with records maintained in the on-site tank 5 years
demonstrate that the
(all UST systems,
files.
system is not leaking.
except exempt)
Written
Pertaining to any
The contractor installing the equipment
5 years from the
performance
release detection
furnishes the documentation to the UST
date of
claims
system used, and the operator. The UST operator maintains
installation
manner in which
the record.
though EHS
(Created 3/06; Revised 6/06, 8/09, 8/10, 10/11, 8/12)
UNL Environmental Health and Safety · (402) 472-4925 · http://ehs.unl.edu
these claims have
been justified or
tested by the
equipment
manufacturer or
installer
Tank tightness
testing records
Calibration and
Maintenance
records
Inspection
reports/orders
and subsequent
follow-up
correspondence
This documentation is
for the detection of
releases.
Records of
manufacturer’s
scheduled calibration
and maintenance of
release detection
equipment
permanently located
on-site.
This report is the
result of periodic
regulatory
inspections.
recommends
they be
maintained for
the life of the
system.
A qualified contractor generates the
report. Testing is required prior to
beginning of operation of any UST and
following repairs. The UST operator
maintains the record.
Installation/testing/calibration by a
qualified contractor on an annual basis.
The UST operator maintains the record.
The UNL Building Code Official generates
and maintains the record.
Until the UST
system is
permanently
taken out of
service.
5 years.
5 years
Records Required by EPA Clean Air Act (CAA) Regulations
Table 4 summarizes recordkeeping requirements for each UST that is located at a Gasoline
Dispensing Facility. A Gasoline Dispensing Facility is defined as any stationary facility which
dispenses gasoline into the fuel tank of a motor vehicle, motor vehicle engine, non-road vehicle,
or non-road engine, including a non-road vehicle or non-road engine used solely for
competition. These facilities include, but are not limited to, facilities that dispense gasoline into
on- and off-road, street, or highway motor vehicles, lawn equipment, boats, test engines,
landscaping equipment, generators, pumps, and other gasoline-fueled engines and equipment.
TABLE 4 – EPA CAA Recording Keeping Requirements (Gasoline USTs only)
Record
Record Type
Description
Generation and Maintenance
Retention Time
Monthly throughput is
total gallons of
UST operators must be able to produce
Monthly
gasoline received (or
records to support monthly throughput
5 years
throughput
dispensed) during the
calculations.
past 365 days divided
by 12.
November 17, 2008, EHS submitted both
One-time Initial
If monthly throughput Initial & Compliance Notifications
Notification &
pursuant to 40 CFR 63 subpart (6) C for
is ≥ 10,000 gallons,
Keep copies
Compliance
then Notifications are two gasoline USTs at CC Trans Services.
Each tank observes submerged filling as
Status
required.
required.
(Created 3/06; Revised 6/06, 8/09, 8/10, 10/11, 8/12)
UNL Environmental Health and Safety · (402) 472-4925 · http://ehs.unl.edu