State Reapplication For Underground Tank Program Approval

In July 2015 EPA published the 2015 underground storage tank regulation and the 2015 state program approval regulation. This was the first major revision to the federal UST regulations since 1988. The revisions were intended to strengthen the 1988 federal underground storage tank (UST) regulations by increasing emphasis on properly operating and maintaining UST equipment. The revisions included provisions to prevent and detect UST releases, which are a leading source of groundwater contamination, and to ensure all USTs in the United States, including those in Indian country, meet the same minimum standards.

Abandoned Underground Tanks Marked During 

Ground Penetrating Radar (GPR) Survey

The 2015 UST regulation changed certain portions of the 1988 underground storage tank technical regulation, added new operation and maintenance requirements, and addressed UST systems deferred in the 1988 UST regulation. The changes:

• Added secondary containment requirements for new and replaced tanks and piping
• Added operator training requirements
• Added periodic operation and maintenance requirements for UST systems
• Added requirements to ensure UST system compatibility before storing certain biofuel blends
• Removed past deferrals for emergency generator tanks, field constructed tanks, and airport hydrant systems
• Updated codes of practice
• Made editorial and technical corrections

The 2015 state program approval (SPA) regulation also updated SPA requirements  and incorporated the changes to the UST technical regulation listed above.

Currently 38 states plus the District of Columbia and Puerto Rico have SPA and have three years to reapply in order to retain their SPA status. UST system owners and operators in these states must continue to follow their state requirements until the state changes its requirements or until the state’s SPA status changes. Under the 2015 state program approval regulation, the 38 states plus the District of Columbia and Puerto Rico, which currently have SPA must reapply by October 13, 2018 in order to retain their SPA status. The remaining 16 non-SPA states and territories may apply for SPA at any time.

Owners and operators in 16 non-SPA states and territories must meet the federal requirements according to the schedule in the 2015 UST regulation. In addition, owners and operators will need to follow their state requirements.




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