Are You Missing a Required O&M or Emergency Plan? Some States Say “Yes.”
In the world of Underground Storage Tank (UST) compliance, daily tasks like inspections, monitoring, and maintenance can feel routine—until a spill happens. That’s when having a clear, site-specific plan in place becomes not just helpful, but essential. And in some states, it’s the law.
While federal UST rules require training and basic emergency protocols, several states have taken things further by requiring written Operations & Maintenance (O&M) Plans and/or Emergency Response Plans that must be kept on site.
Why Do These States Require Written Plans?
State regulators aren’t just checking a box—they’re trying to protect drinking water, soil, and the environment from costly and preventable fuel releases. By requiring documented procedures for everything from routine inspections to major emergencies, these states aim to ensure:
Consistent maintenance practices
Clear emergency roles and response actions
Faster, more effective spill containment
Better training for employees and contractors
Improved inspection readiness
Here’s a look at how a few key states handle it:
📍 California
Before a new UST system can operate, owners must submit a Monitoring Plan and an Unauthorized Release Response Plan to local agencies. These documents outline how the system will be monitored and what actions will be taken in the event of a leak or spill. Title 23 of the California Code of Regulations, §2632 and §2634
Why? California prioritizes proactive environmental protection. These plans demonstrate to regulators how you’ll contain spills and notify authorities quickly.
📍 Illinois
Illinois goes all in: every UST site must maintain a comprehensive Facility O&M Plan. It includes inspection schedules, emergency shutdown procedures, and instructions for how to handle spills or leaks. 41 Illinois Administrative Code §176.655(e)
Why? The state fire marshal wants to make sure operators know how to run their site safely and how to respond when something goes wrong. It’s about prevention and preparedness.
📍 New Mexico
A written O&M plan is required for all active USTs. It must cover everything from daily checks to emergency response actions, including site-specific procedures and contact lists. New Mexico Administrative Code 20.5.107.701
Why? In a state where groundwater is especially precious, New Mexico wants to make sure every operator is actively protecting it—not just reacting to emergencies.
📍 Washington
While not all USTs in Washington require an O&M plan, the Department of Ecology can mandate one if a site has compliance issues. All sites, however, must post clear emergency signage explaining what to do in case of a release.WAC 173-360A-0545 & WAC 173-360A-0550
Why? Washington believes that even a good plan isn’t helpful if it’s not visible when things go sideways. That’s why they focus on emergency response readiness at every site.
📍 New Jersey
There’s no broad O&M plan requirement, but if your site is unmanned, you must post emergency procedures that tell first responders and customers what to do if something goes wrong. N.J.A.C. 7:14B-5.13
Why? The state wants to prevent confusion—and environmental damage—when trained personnel aren’t around to take control.
📍 Pennsylvania
If your facility has significant storage capacity (especially ASTs), you’ll need both an O&M Plan and a Spill Prevention Response Plan (SPRP). These plans show how your site stays in compliance and how you’ll respond to emergencies. 25 Pa. Code §245.511
Why? Pennsylvania regulators want a full picture of your day-to-day operations and your emergency game plan, especially at larger or riskier sites.
What This Means for You
If you’re operating in one of these states—or expanding into them—it’s worth checking whether you’re required to have a written O&M or emergency plan in your compliance binder. Even if not strictly required, many operators choose to create one as a best practice.
PASS can help. Whether it’s bundling emergency procedures into your site documentation or building out a custom inspection plan inside PASS Tools, we’re ready to support your compliance efforts—on paper and in practice.
If your state requires an Operations & Maintenance Plan or Emergency Response Plan—or if you simply want to be better prepared—PASS can help.
Our PASS Book Digital Compliance Binder inside PASS Harmonics includes built-in templates and secure storage for these plans. You can assign, update, and track your site-specific O&M and emergency response documentation all in one place—accessible to inspectors, technicians, and emergency responders when it matters most.
Need help building your plan or adding it to your PASS Book? Contact us Today
