Compliance fails in the records room long before it fails in the soil.

EPA counts 534,189 active underground storage tanks at approximately 190,224 facilities, as of March 2026.

The technical compliance rate — facilities in compliance with release prevention and release detection together, at initial inspections — was 60.9% for April 2025 through March 2026. In the six months from October 2025 through March 2026, 1,997 new releases were confirmed. 52,859 releases were still waiting to be cleaned up.

None of those numbers is about one bad operator.

A 40-year-old underground tank at a downtown gas station leaked nearly 2,500 gallons of gasoline to groundwater. On September 14, 2023, a hotel and parts of the downtown business district were evacuated. Gasoline and vapors were found in the hotel basement and in two nearby buildings.

The Washington Department of Ecology said the station’s routine inventory checks showed fuel shortages before the release was found. Leak detection alarms did not trigger, and follow-up testing over the next two and a half months did not confirm a release.

Ecology issued a $738,000 penalty and ordered $4.1 million in cost recovery for spill response and pollution mitigation. In the April 2026 settlement, the owner agreed to pay $275,000 within 30 days, with the full penalty and cost recovery amount held in suspension.

In 1996, Santa Monica learned that two of its drinking-water wellfields, Charnock and Arcadia, were contaminated with MTBE, a gasoline additive. Levels at Charnock ran as high as 610 parts per billion.

The wellfields, representing 50 percent of the city’s drinking water supply, were shut down, and the city began buying replacement water. The city traced the Charnock contamination to leaking underground gasoline storage tanks owned by various oil companies.

EPA and the Los Angeles Regional Water Quality Control Board pursued a joint enforcement action at the Charnock wellfield. EPA calls the incident the first major water contamination that brought public attention to MTBE. Separately, following litigation, the city and various oil companies reached a settlement agreement in December 2003.

Part 613 is specific. Inventory is reconciled at 10-day intervals. Electronic monitoring is checked for connectivity every 30 days, and ATGs, probes, sensors, and line leak detectors are inspected for operability every year. Walkthrough inspections cover catch basins and leak detection equipment every 30 days, and containment sumps every year. Tightness test records are kept for three years or until the next test, whichever is later.

Then the rule says when the records have to be produced. Records must be made available to DEC within three business days of a request — except the last 30 days of leak detection monitoring, which must be immediately available at the time of request. DEC’s recordkeeping guidance says where: the last 30 days of leak detection records must be kept at the facility.

DEC’s PBS inspection enforcement policy lists the failures by name: failure to reconcile every 10 days, tank not tightness tested, no leak detection performed, monitoring records not being maintained on premises. None of those is a spill. Each is a test not done, or a record not there when someone asked.