The Days Are Long, But the Years Fly By…Celebrating Ten Years of the Modern-Day UST Program

Posted on Friday, January 30th, 2026 | Carolyn Hoskinson

This past year brought many changes for me both personally and professionally. The best change is that I returned to the UST program! I’m so excited to be back in the Tanks community and can’t wait to reconnect with everyone. This year also marked the 10-year anniversary of a major regulatory update to the UST program. Anniversaries and birthdays are great times to reflect, and in this article, we will reflect on how far the UST program has come and how the 2015 regulations continue to help ensure clean air, land, and water for every American.

In the early days of the national UST program, EPA and partners worked to understand the UST universe and establish a foundational program to protect human health and the environment from UST releases. The 1988 regulations created the framework for a national program. Once the initial program setup was completed, EPA and other stakeholders could focus on refining the program requirements to ensure that it continued to be a safe, sustainable, and protective program that reflected state-of-the-art industry standards and practices.

A major step forward for updating the program happened back in 2005 with passage of the Energy Policy Act. The “EPAct” drove the program forward to incorporate and implement requirements that ensured a stronger UST program. At the same time that EPA was working to implement EPAct requirements in Indian country, we also recognized the need to update and improve operation and maintenance of USTs across the country. In order to ensure a strong yet practical program, we sought out and considered significant stakeholder feedback. Indeed, EPA held more than 100 public meetings as part of this rule making process. Dedicated EPA staff in the regions and at headquarters shepherded the rule making through many years of procedural requirements and other challenges. As a result, the final regulations focused on release prevention, recognized UST industry modernization and improvement efforts, and included new requirements designed to protect the environment while providing flexibility.

The 2015 UST regulations changed certain portions of the 1988 underground storage tank technical regulation. Procedures and practices that today are industry standard and perhaps taken for granted were captured in the 2015 regulations. Major changes included:

• Addition of periodic operation and maintenance requirements for UST systems.
• Addition of requirements to ensure UST system compatibility before storing certain biofuel blends.
• Removal of past deferrals for emergency generator tanks, airport hydrant systems, and field-constructed tanks.
• Updated codes of practice.

Implementing the 2015 regulatory changes has been a relentless effort on many fronts and by many people. Ten years later we are reaping the benefits with a high performing national program that protects the public and our natural resources. EPA has its many program partners to thank for the UST program’s continued success.  

State Implementation…No Small Feat

When it comes to implementing the 2015 UST regulations, no amount of thanks is too much for our state partners. State agencies embraced the painstaking, day-to-day work to update their regulations and work their way through the State Program Approval process. States worked with the public, state legislatures, and EPA to update their regulations to match the federal regulations, while often wrestling with complex systems and situations within their state (e.g., emergency power generators, airport hydrant systems). Today, 40 states and territories have State Program Approval for the 2015 regulations, helping to provide a nationally consistent and environmentally protective program, with several states choosing to go beyond the federal requirements with more stringent standards. 

States also worked with EPA to develop a technical compendium of over 50 questions and answers that address regulatory uncertainties and unique situations. The compendium has been a useful “living” resource for clarity and compliance assistance.

Individual states and organizations representing state implementing agencies contributed to the success of the program. NEIWPCC and ASTSWMO provide invaluable forums to get states and EPA together so that we can continue to collaborate with each other. Just a few months ago we held our 28^th National Tanks Conference, a successful event where we continued to learn from and support one another.  

Today, states still face ongoing challenges from funding constraints to staffing shortages. Despite the challenges, the states have made impressive progress and continue to uphold a rigorous UST inspection cycle with tens of thousands of inspections completed each year. We cannot thank our state partners enough for the day-to-day, often invisible work to make the UST program a success. 

Industry Involvement, Critical to a Modern and Flexible UST Program

Industry also played a big part in the implementation success of the 2015 regulations. Industry got to work right away to develop standards that made sense and that provided flexibility for meeting the intent of the regulations with room for innovation and technology improvements. For example, several industry groups representing UST owners and operators approached EPA and states seeking flexibility on requirements for hydrostatic sump testing. In response, EPA allowed a new standard for sump testing that uses less wastewater, providing an economic and environmental benefit.

The 2015 regulations raised the bar for the sound manufacture, installation, operation, and maintenance of USTs storing petroleum. While decades prior, a single walled steel tank was the norm for an UST, industry made great strides in designing secondarily contained equipment, both steel and fiberglass. In addition, the UST service provider industry flourished, creating jobs, vocational training, and business opportunities all across the country. Technological innovation led to a safer, modern petroleum storage system that keeps our country moving.   

Today, industry remains heavily involved in setting standards, for everything from ongoing leak detection methods to the ASTM Moving Sites to Closure standard. This makes for a stronger regulatory program better in touch with the practical realities of owning and operating tanks.  

Conclusion

In the 10 years since the 2015 regulations, we have seen the fruits of our labor pay off in improved program performance. Since we started tracking compliance rates on a national level, we have seen steady progress and increase in spill, overfill, and corrosion protection compliance rates. The Total Compliance Rate performance measure — which is a combination of a few different measures — has been consistently high and trending higher with each passing year. Compliance testing companies have provided anecdotal data showing their average passing rates for triennial tests improving each 3-year period, and annual confirmed releases continue to trend downward over time. You can explore our semiannual performance measure reports and see the positive trends in data on our website. We continue to get feedback and information formally and informally about the impact of the 2015 regulations, as well as needs for regulatory clarifications and training. If you have any information or insights that you would like to share, please contact OUST.      

USTs are the backbone of our country’s vehicle fueling infrastructure. Nearly every community in the country has a gas station with USTs. Safety and environmental protection are paramount for such a localized and nationalized network of fuel storage. The 2015 UST regulatory requirements led to many advances in equipment, systems, monitoring, and testing that improved release detection, reduced spill and overfill incidents, and empowered owners and operators. Ten years after those regulations, and as the program matures, we continue to see progress and changes. EPA is tracking many issues and coordinating with states, industry, and Tribes to plan and strategize in advance. For example, we are tracking aging infrastructure issues and the challenges associated with demonstrating financial responsibility. We are working with states to plan for program sustainability given transportation sector changes and to reassess exposure threats at UST release sites. Taking a few moments to reflect on 10 years gone by, and many more years of work in this national program, I am so pleased to recognize the tremendous long-term progress due in large part to the day-to-day efforts of those in the amazing UST community.