EPA's Final Rule Revising Underground Storage Tank Regulations

On June 22, 2015, the Environmental Protection Agency (“EPA” or the “Agency”) finalized a number of revisions to its underground storage tank (“UST”regulations (“final rule”). The revisions are focused on spill prevention and properoperation and maintenance, imposing new requirements for secondary containmentand operator training. EPA asserts that the revisions will improve the detection andprevention of UST releases.
 
As of the date of this memorandum, the updated UST regulations have notbeen published in the
Federal Register. The date that the final rule appears in the Federal Register starts the clock running on the compliance deadlines contained inthe updated UST regulations.
 
As a general matter, the final rule contains a number of improvements fromthe proposed rule that was released in 2011. These improvements come primarilyin the form of requiring UST equipment testing and inspections to occur lessfrequently, and making compliance easier without seriously compromising the Agency’s environmental objectives. NATSO had urged the Agency to make these changes.
 
This memorandum provides an overview of the final rule that are of most concern to NATSO members.

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