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Compliance Corner: NATSO Toolkit Outlines UST Requirements

Posted in: Fuel and Trucking, Compliance Corner

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Several new requirements related to underground storage tanks (USTs) have taken effect over the past few years. As fuel retailers, most NATSO members own and operate USTs for motor fuels and must comply with state and federal regulations. To help truckstop and travel plaza owners stay current on UST requirements, NATSO has compiled a regulatory toolkit outlining the latest UST standards.

The toolkit outlines a number of key areas for operators. Including:

Secondary Containment. New and replaced tanks and piping must be secondarily contained with interstitial monitoring systems, and new dispenser systems must be equipped with under-dispenser containment that will contain regu- lated substances leaked from the primary containment until they are detected and removed and will prevent the release of regulated substances to the environment at any time during the operational life of the UST system. The rule also includes secondary containment testing requirements.

Walkthrough Inspections. The final rule requires periodic walk-through inspections to detect releases (for example, must check spill preventing equipment and fill caps every 30 days; must check containment sumps annually) and also includes additional requirements for periodic spill, overfill and secondary containment monitoring.

Spill Containment Testing. Spill prevention equipment must be tested every three years.

Overfill Containment Inspections. Ball float valves in vent lines have been eliminated as an option for satisfying overfill prevention requirements for new/replaced flow restrictors.

Tank Compatibility with Alternative Fuels.The final rule generally allows tank owners to demonstrate equipment compatibility with alternative fuels (e.g., blends containing greater than 10 percent ethanol or 20 percent biodiesel) through a listing by a nationally recognized association, such as Underwriters Laboratories, or based upon written equipment manufacturer approval.

Repairs. The final rule contains a number of requirements pertaining to repairs of leaking UST systems. Repaired secondary containment areas of tanks must be tested for tightness within 30 days of the repairs. Repaired spill or overfill prevention equipment must be tested or inspected to ensure it is operating properly within 30 days of the repair. In addition, secondary containment areas of piping used for interstitial monitoring and containment sumps used for interstitial monitoring of piping must be tested for tightness within 30 days of the repair.

The final UST rule represented the first substantial revisions to the federal UST regulations that were originally promulgated in 1988. It is the culmination of a multi-year review of existing regulations and technological advances, as well as data regarding releases that have occurred over the past two decades. 

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// NATSO Members: Get the Full Regulatory Toolkit. NATSO has prepared a document outlining these issues and more. The full document is available to NATSO members here.

(The regulatory toolkit is available for NATSO Members only. If you need any assistance logging in, please contact NATSO Member Services at (703) 549-2100 between the hours of 9:00 a.m. and 5:00 p.m. EST, Monday through Friday, or e-mail us at membership@natso.com.)

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About the Author

David Fialkov

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.