March 26, 2009 1

Task Order No. 3003 – Task 2. Subtask a – EPAct Key State Decisions – Secondary 

Containment

Technical Directive No. 13

Summary for EPAct Key State Decisions – Secondary Containment

This report summarizes the methodology and findings of the review of state and territory

regulatory decisions for secondary containment of underground storage tanks (USTs). The 

attached spreadsheet contains two appendices:

 Appendix A – Detailed State Requirements for Secondary Containment

 Appendix B – State Requirements for Sump Testing, Interstitial Integrity Testing, and 

Interstitial Monitoring Frequency

Methods

E

2 Inc. researched state and territory (hereafter referred to as state) UST program Web sites and 

online publications of state and territory rules and regulations for requirements related to

secondary containment of USTs. Rules were reviewed for information pertaining to the 

questions provided by OUST, as listed in the Results section. 

Results

Where is secondary containment required?

Thirty-three states require, or propose to require, secondary containment for all new and 

replacement tanks and piping. New York requires secondary containment for all new tanks only. 

Eleven states require, or propose to require, all tanks within 1,000 feet of a community water 

supply or public drinking water well to be secondarily contained. Alaska, New Jersey, and Ohio 

only require secondary containment in sensitive areas and Missouri requires secondary

containment on a tank-by-tank basis. Requirements for seven states and territories were not 

located online. 

Table 1. Summary of secondary containment requirements

Secondary Containment Requirement Number of States

All new and replaced tanks/piping Final 32

Draft 1

Within 1,000 feet of a CWS or PDWW Final 9

Draft 2

New tanks only 1

Only in sensitive areas 3

As determined by the state 1

Requirements not available 7
March 26, 2009 2

When does repair become replace?

Twenty states do not specify a threshold for requiring piping to be replaced. The remaining 36

states specify requirements for replacement with secondarily contained piping (Table 2). 

Table 2. States with thresholds for prohibiting repairs and requiring replacement

Repair/Replace Requirement State/Territory

Do not allow repairs to single-walled 

piping New Hampshire, New York, Wyoming

Repairs require pre-approval Kansas, Massachusetts, Rhode Island, 

Tennessee

Specified length of piping may be 

repaired (5 – 25 feet)

Alabama, Arkansas, Iowa, Minnesota, New

Mexico, North Dakota, South Dakota

Specified percentage of piping may be 

repaired (20 – 50 percent)

Arizona, Georgia, Indiana, Louisiana, 

Maryland, Michigan, Montana, Pennsylvania, 

South Carolina, Texas, Virginia, Wisconsin

Specify a length and percentage of 

piping, whichever is less

(10 – 50 feet; 10 – 50 percent)

Colorado, Illinois, Nebraska

Allow repairs up to 100 percent of 

piping Idaho, Mississippi, Nevada, Utah

State must be notified if more than 20 

feet of piping is to be replaced Vermont

Only the major component replaced will 

need to meet the rule’s design and 

installation requirements for new and 

replacement facilities

Maine

Each contiguous stretch of piping Oregon

Are submersible turbine pump sumps specifically required?

Twenty-two states specifically require submersible turbine pumps to be contained within a sump. 

Thirty-four states do not require submersible turbine pump sumps.

Is periodic sump testing required?

Sixteen states require periodic testing or inspection of sump areas (Table 3). Illinois, Wisconsin, 

and New Mexico only specify testing be performed at installation and New Hampshire and New 

Jersey only specify testing be performed within 30 days of installation. Thirty-five states do not 

specify periodic sump testing requirements. 
March 26, 2009 3

Table 3. States that require sump testing

Testing Requirements State/Territory

Annually Alabama, Delaware, Georgia, 

Mississippi, North Dakota, Utah

At installation, repair, and every five years

(test not specified) Maryland 

Manufacturer test at installation, repair, or replacement Pennsylvania 

Below-grade piping and dispenser sumps: every three years

Spill containment systems: not exceeding every 12 months

(test not specified)

Florida 

Visual inspection every 60 days Texas

Annual visual inspection; 

tightness test every three years North Carolina, Ohio

Visual inspection every two years Iowa

Monthly visual inspection;

annual sensor test;

quarterly inspection of double wall piping sumps

Wyoming 

Monthly visual inspection; 

annually if system has a submersible pump sump with liquidtight containment and a liquid sensor alarmMinnesota 

Quarterly visual inspections of dispenser and under-dispenser 

containment sumps Tennessee 

Is interstitial integrity testing required?

Forty-three states do not require interstitial integrity testing. South Carolina, Texas, and 

Wisconsin specify testing be performed at installation. Ten states do require periodic interstitial 

integrity testing (Table 4). 

Table 4. States that require interstitial integrity testing

State/Territory Test Frequency

Delaware, Mississippi, Ohio Annually

Iowa Two years

California, Florida, Illinois, 

North Carolina Three years

Minnesota Monthly visual inspection;

annually with sensor in place

Rhode Island

Tightness test once the tank has been installed 

for a period of twenty years, and once every 

two years thereafter
March 26, 2009 4

Is monthly or continuous interstitial monitoring required?

Forty-eight states require monthly interstitial monitoring. Six states require continuous 

interstitial monitoring (Table 5). New York and Vermont require weekly interstitial monitoring.

Table 5. States that require continuous interstitial monitoring

State/Territory

California

Connecticut

Massachusetts

Montana

New Hampshire

North Carolina