The EPA's 2015 revisions to federal UST regulations set a wave of compliance deadlines that many facility owners are still catching up on. The biggest ones hit in October 2018, but the ripple effects are ongoing. States continue tightening their own requirements, and enforcement is picking up, not slowing down.
If you own or operate a facility with underground storage tanks, here's what's actually changed and what it means for your operation.
The 2015 federal UST rule revisions were the first major update in over 25 years. The key changes that still catch facility owners off guard:
The Federal Rules That Changed Everything
Operator training requirements are now mandatory in all states. Every facility must have designated Class A, B, and C operators who have completed state-approved training. This sounds simple until you realize the training requirements vary by state, certifications expire, and regulators are actively checking compliance during inspections.
Secondary containment is required for new and replaced tanks and piping. If you're installing a new tank or replacing a significant portion of your piping, single-wall systems no longer meet federal requirements. Retrofitting existing systems is expensive, $20,000 to $50,000 or more depending on the configuration — but the alternative is failing your next inspection.
Walkthrough inspections must now be performed every 30 days by the facility. These aren't the same as the periodic testing done by licensed contractors. They're visual checks of spill prevention equipment, release detection systems, and corrosion protection that the facility operator is responsible for documenting.
States Are Going Further
Release detection requirements expanded to include containment sumps, which were previously exempt at many facilities. If your facility has sumps that aren't being monitored, that's a compliance gap regulators are specifically looking for.
Federal rules set the floor, not the ceiling. Several states have imposed requirements that exceed the federal baseline. California, New Jersey, and Florida have some of the strictest UST programs in the country. Other states like Texas and Pennsylvania have large UST populations and active enforcement programs that keep facility owners on a short leash.
The practical impact: a facility owner operating tanks in multiple states can't assume one compliance approach works everywhere. License types, testing frequencies, reporting requirements, and even the definition of what triggers a "release" vary from state to state.
What This Means for Hiring Contractors
Tighter compliance requirements mean more frequent interaction with licensed UST contractors. Routine testing, system upgrades, operator training verification, and inspection preparation all require contractors who hold the right credentials in the state where the work is being done.
The mistake facility owners make is waiting until an inspection is scheduled or a deadline is imminent to start looking for a contractor. Licensed UST contractors in active enforcement states are often booked weeks or months out during peak compliance seasons. Starting the search early and confirming the contractor holds the specific license type your project requires, avoids the scramble.
The EPA and state agencies have increased UST inspection rates over the past several years. Significant Operational Compliance rates are published annually, and facilities that fall short face escalating consequences from warning letters to administrative orders to fines that can run $10,000 or more per violation per day.
Enforcement Is Real
The facilities that get hit hardest aren't usually the ones with catastrophic failures. They're the ones with paperwork gaps, missing operator training records, undocumented walkthrough inspections, expired testing certifications. These are fixable problems, but only if they're addressed before the inspector arrives.
Whether you need routine testing, system upgrades, or help preparing for an inspection, the starting point is the same: confirm your contractor is properly licensed in your state for the specific work you need done.