365 Days in 180 Minutes – EPA Three-Hour Calls Provide Insight Into the State of the Tanks Prevention Program

Posted on Wednesday, August 26th, 2026 | Carolyn Hoskinson

A few months after the conclusion of each fiscal year, my office has lengthy discussions with each EPA regional tanks program. These discussions are colloquially known as the “three-hour calls.” The calls are a great opportunity to discuss priorities and evolving needs. It helps us to shape the year ahead and to report out and understand the previous year. We identify trends, gaps, and success stories. These conversations are invaluable to understanding the program at a national level.

We also use the three-hour calls to get our finger on the pulse of how our state program partners are doing. Our regional counterparts continually interact with the states and have a strong sense of the challenges that states are facing and the pioneering efforts they undertake to address those challenges. The conversations help us identify needs for additional guidance, outreach, and training. The calls also help us understand the story behind the data we receive on program performance measures, providing a richer view of overall program health. In this article, I describe some of the issues we heard about for prevention programs across the country and the innovative approaches that states are taking to address their challenges.

State tanks programs truly are the front line for preventing UST releases and have numerous responsibilities. The states implement and enforce regulatory standards, requiring proven prevention measures such as corrosion protection, spill and overfill prevention, secondary containment for tanks and piping, and reliable release detection. State agencies mandate periodic testing, monitoring, and walkthrough inspections, verify performance through onsite inspections and records reviews, and use enforcement tools to correct noncompliance before it leads to a leak. States also train and support Class A/B/C operators, provide technical assistance and outreach, and maintain data systems to track equipment, testing results, and violations. In addition, many states also certify installers and testers, and oversee installation, repairs, and upgrades to ensure proper construction and compatibility with the stored fuel. Through these many prevention-focused activities, agencies reduce the likelihood of releases that threaten soil, groundwater, and public health.

I listed all these activities to illustrate the sheer volume and complexity of state tank program responsibilities, and the above is not even an exhaustive list. It was confirmed on our three-hour calls that many states are doing all this while continuing to experience staffing shortages, and funding constraints. Their tanks program staff have to cover multiple programs. Affected states are using cross-training and work-sharing to cover multiple programs to handle activity surges or slowdowns. For example, in Texas, this is impacting the ability to conduct inspections. In the case of New Jersey, their business tax saw a significant reduction in recent years, so collected penalties help make up some of the difference to fund their UST program.

Likewise, through the three-hour calls we confirmed how UST owners and operators continue to face the many pressures of running a business while trying to understand and implement technical requirements. Protecting the environment and complying with all requirements is no small feat. Some of the most common underground storage tank violations noted during our annual calls this year (covering fiscal year 2025, October 2024 – September 2025) include:

• Recordkeeping issues, such as missing monitoring records, and failure to keep required testing and maintenance records.
• Testing issues, such as line leak detectors not being tested and piping tightness tests not done after repairs or modifications.
• Release detection issues, such as not conducting required monitoring for tanks or piping, failing to test release detection equipment, mispositioned or inoperative sensors, ignored or unresolved alarms, and missing monitoring records.
• Issues with containment sumps, including ones that do not hold liquid, are unsealed or damaged, and water or product present in sumps.
• Walkthroughs not performed or documented, including failure to keep required records.
• Spill and overfill testing issues, including cases of spill buckets and overfill devices not being inspected or tested at required intervals.

In addition to violations, state programs encountered challenges with respect to contractor availability, diesel and ethanol corrosion, and temporarily out-of-service tanks. While persistent problems remain and new challenges crop up, the state tanks programs are working diligently and resourcefully to make things work. In our end of year discussions, we heard about some great examples of enhanced communication, compliance assistance, and service provider requirements. I will briefly describe some illustrative examples of state efforts to reach program goals, and again often in the face of diminishing resources.

Several states continue to enhance their outreach efforts to the regulated community. Where feasible and where it makes sense, states engage in individual outreach to owners and operators. For example, Michigan makes it a practice to conduct in-person outreach meetings to regulated entities and contractors. Vermont has made an investment in outreach and compliance materials related to testing requirements and operator training. They also send out reminders to owners and operators 30 days before required annual and triannual testing. EPA Regions do this as well and have found it effective for UST owners and operators in Indian Country. Business owners, and especially small businesses that make up a significant portion of the regulated community, have many stresses and demands for time and attention. Providing and reviewing facility-specific information can make a real difference in compliance and increased understanding. Our regions also find that advance planning helps to make the most of in-person support. For example, several regions have a phone call prior to a visit and follow-up calls as necessary after a visit.

At times, travel budget and logistics do not allow for individual face-to-face interactions, so states have online resources available for owners and operators to reference on their own time. Some states add office hours and online training webinars to supplement online resources with more personal and interactive opportunities. More and more, states are incorporating technology to improve their program and the data they handle to understand program performance. A significant number of states have ongoing database projects. In general, states continue to look for opportunities to use electronic processes — including tablets for inspections, electronic data submission to see data ahead of inspections, and sending automatic notifications to the regulated community.

In addition to working directly with owners and operators, many tanks programs have found success by requesting additional information and standards from service providers in their state. For example, Utah has additional requirements for service providers and requires them to submit data on repairs and testing to the state as well as to the owner/operator. Oklahoma added a requirement for UST service provider/contractor licensing (i.e., certification) which over time will improve compliance with better quality testing and work. These enhancements will also help with recordkeeping, a prevalent type of violation.

My staff and managers are visiting various states and regions throughout the country. One thing is clear — the tanks workforce continues to innovate and to remain dedicated to running the best and safest environmental programs in the country. Despite significant challenges, I am encouraged by the level of dedication to the tanks program across the country. It is wonderful to see the states come together at venues such as the all-states meetings that our EPA regions host each year. Our partners such as ASTSWMO and NEIWPCC also offer training and events to facilitate information sharing and problem solving. My office is committed to promoting information sharing in a variety of venues and methods. Through the years we have maintained awareness of common issues related to compliance so that we can focus efforts on guidance documents, training, and other resources that may be of use. For example, in response to what we heard from regional inspectors and Tribes, we recently developed additional guidance for the EPA notification form for USTs. Inspectors, owners, and operators can refer to this guidance to address common errors in filling out the notification form. We hope the availability of this guidance leads to improved compliance, better environmental protection and data, and smoother on-site inspections.

I am so encouraged by the mindset of continuous improvement in the prevention program across the country. We have heard about all these improvements, in some cases directly from states, and in other cases via our regional EPA managers and staff. In my next article, I will detail some of the challenges and approaches that we saw on the cleanup and revitalization side of the tanks program. If you would like to share details about your approach, successes, or lessons learned in a future LUSTLine article, please contact James Plummer.