Regulatory Updates for Underground Storage Tanks

 If your facility utilizes underground storage tanks, you may be facing new regulations that take effect this October.

The federal Environmental Protection Agency regulates underground storage tank (UST) systems at 40 CFR Part 280. These regulations include design, construction, operating, release detection, release reporting, cleanup, financial responsibility, and operator training requirements. The Part 280 regulations were significantly revised in 2015, with most of the new requirements becoming effective October 13, 2018.

Many states have applied to EPA to implement their own UST regulations instead of EPA’s regulations. The EPA has granted this authority to 38 states, the District of Columbia, and Puerto Rico. For these locations, only the state regulations apply to UST operations.

Some states do not have EPA-approved UST regulations. In these states, facilities must comply with both the EPA regulations at Part 280 and the state regulations. In some cases, the state regulations may be more stringent than EPA UST requirements.

States with approved UST programs must update their regulations by October 13, 2018 to be at least as stringent as the EPA regulations as revised in 2015, and reapply for state program approval. Some of these states may already have updated their regulations with the updates currently in effect while they go through the EPA approval process.

This map shows which states have approved UST programs and the status of state program approval under the 2015 regulatory updates. 

Source: U.S. EPA website. Accurate as of August 14, 2018

What Does This Mean for Your Facility?

Every facility that has a regulated UST system must evaluate its compliance with the revised UST requirements, as well as any applicable state regulations.  EPA’s Musts for USTs offers a summary of the 2015 regulatory updates. Review the regulations and guidance documents to ensure your UST program is on track to comply with new applicable requirements. Keep in mind that state UST regulations, whether in authorized states or not, can be more stringent than EPA requirements; therefore, be sure to check your state program for additional regulatory requirements.

Help is Available

If you have questions about the UST requirements or how they may apply to your facility, contact me at or (914)712-8109. The EPA publications Musts for USTs and Operating and Maintaining Underground Storage Tank Systems are good resources for additional information.


Becky Corbin Practice Leader Environmental Health & Safety

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