October 13 UST Regulatory Deadline Approaching

NATSO members are advised that Oct. 13, 2018,(just five weeks away) is the deadline for meeting the remaining underground storage tank (UST) requirements in the 2015 revised UST regulation. Key takeaways about the compliance deadline are:
  • UST owners and operators in states without UST state program approval (see below) must meet the remaining 2015 federal UST requirements on or before the federal deadlines.
  • UST owners and operators in states with program approval must continue to follow their states' requirements, which may be different from the 2015 federal UST requirements.
Click here to see a map indicating which states have UST state program approval. 
To view NATSO's detailed member-only summary of the updated 2015 regulations, click here.

It’s important for NATSO members to be aware that as many as 30 states have been working with EPA to draft UST regulations. State UST program's can tell truckstop and travel plaza members if and when a state’s requirements and associated compliance deadlines may change. EPA’s state UST program web page provides state contact information.

States that already have program approval are required to reapply by Oct. 13, 2018, to retain program approval status, either by adopting and receiving approval of the updated regulatory requirements.

EPA’s website provides further information about SPA and the October 2018 deadline.

NATSO recently sent a letter to EPA asking for a delay of certain testing requirements. NATSO believed the extension was necessary because in many states there are not enough qualified contractors to install upgraded equipment required to satisfy the new regulations' testing standards.  In addition, many tank owners may be forced to replace expensive equipment that has not yet reched the end of tis useful life but was not designed for the new testing techniques. 

Unfortunately, shortly after NATSO sent its letter, EPA officials announced that they will not be delaying new rules for testing of underground storage tanks and associated equipment.
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David Fialkov

David Fialkov is the Vice President of Government Relations, as well as the Legislative and Regulatory Counsel, at NATSO. In this capacity, Mr. Fialkov directs NATSO's legislative, regulatory, and legal strategy on a range of issues, including transportation, energy and fuels, labor, data security, and taxes. Mr. Fialkov also oversees NATSO's political engagement program, including individualized legal and political counsel to member companies. Prior to joining NATSO, Mr. Fialkov was the senior associate in the Government Affairs and Public Policy practice at the law firm of Steptoe and Johnson in Washington, D.C. At Steptoe, Mr. Fialkov advised clients on legislative, regulatory, and political issues, as well as legal concerns. His primary clients included trade associations representing the motor fuel wholesale and retail industries, including the National Association of Convenience Stores and the Society of Independent Gasoline Marketers of America. Mr. Fialkov's focus was not only on the motor fuels business, but also the litany of other issues that retailers confront, including labor matters, foodservice issues, healthcare and employment issues, tax matters and data security. Prior to joining Steptoe, Mr. Fialkov graduated with honors from George Washington University Law School. He received his B.S. Summa cum laude with highest honors from Clark University in Worcester, MA. He lives in Washington, D.C. with his wife Allison and daughter Lilah. More
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