EPA Issues UST Guidance Documents

The Environmental Protection Agency released two documents associated with the recently revised underground storage tank (UST) regulations. 

The first document, "MUSTs for USTs," summarizes federal UST requirements for installation, reporting, spill and overfill prevention, corrosion protection, release detection, walkthrough inspections, compatibility, operator training, repairs, financial responsibility, release response, and closure.
 
The second document, "UST System Compatibility With Biofuels," discusses UST compatibility requirements for tank systems storing biofuels (such as biodiesel) and petroleum-biofuel blends. It also presents actions for minimizing the risk of a release from UST systems due to incompatibility.
 
NATSO has prepared a brief summary of the EPA's new UST regulations, which is available here. NATSO has also prepared a more detailed legal memorandum discussing the new rules, which is available here
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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 direct's 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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