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RCRA Subtitle I: The Federal Underground Storage Tank Program

February 1994

Citation: ELR 10057

Author: Laura J. Nagle

Editors' Summary: Congress first addressed the problem of leaking underground storage tanks (USTs) in 1984, by enacting Subtitle I of RCRA. The UST regulatory program addresses, inter alia, corrosion protection, reporting, corrective action, and financial responsibility. In this Article, the author provides an overview of the federal UST program. The author outlines the program's significant elements and explores specific regulations in the context of the technical problems they are intended to address, giving particular attention to how, to what, and to whom the regulations apply. The author concludes that UST owners and operators can avert unnecessary exposures to liability and expense by developing compliance strategies that fit their particular situation and make sense within the context of the applicable regulations.

Laura J. Nagle is an attorney with Gorsuch, Kirgis, Campbell, Walker & Grover in Denver, Colorado. She is also an Adjunct Faculty Member of the University of Denver where she teaches a course in Regulation of Underground Storage Tanks in the Environmental Policy and Management master's degree program. Ms. Nagle received her J.D. from the University of Denver in 1989.