Petroleum Bulk Storage Compliance Issues within Transportation Agencies Nationwide

Focus Area

Construction and Maintenance Practices


Environmental Process, Natural Resources






1-2 years

Research Idea Scope

Petroleum Bulk Storage (PBS) is a necessary component of every State DOT’s operations.  DOTs maintain large fleets of vehicles and equipment that must be fueled and maintained.  However, the regulatory requirements for storing of fuels and other petroleum products also place considerable demands on DOTs.  PBS regulations require extensive commitments in both monetary and personnel resources.  Penalties for failing to comply with PBS regulations can be extremely costly.  The environmental consequences of non-compliance, or even accidental releases at compliant facilities, can place an undue strain on both fiscal and natural resources.  Eliminating PBS storage and switching to the use of privately-owned facilities can eliminate liability, but can add problems such as limited fuel supplies and limited access to refueling facilities.  Also, some DOTs provide fuel for other government agencies, which is a pivotal role in the state’s emergency management structure.  For the purpose of this study, State DOT’s across the United States will be queried concerning Petroleum Bulk Storage (PBS) compliance issues and solutions.  The synthesis will seek to learn differences and similarities in how state DOTs provide fuel for fleets and how they meet the requirements of various regulations including EPA Underground Storage Tank standards, EPA Spill Prevention Control and Countermeasures Plan, and State requirements for aboveground and underground storage tanks.  Future requirements such as the expected operator training certification requirements for UST expected by EPA shall also be considered to the extent that agencies know how they will accomplish them. The study will also look at which state DOTs provide fuel to other agencies, and if not, where other agencies obtain their fuel in both emergency and non emergency situations.   

Urgency and Payoff

State DOTs, as well as other public entities that must store fuel to support their primary activities, will benefit from knowing what challenges other agencies are facing and how they are dealing with those challenges.  It will also be beneficial for agencies to see how the regulatory structures of each state work, enabling them to propose regulatory changes in their states in instances where change is needed.

Suggested By

Carl R. Kochersberger, New York State DOT, Telephone: 518-485-9161

[email protected]