The U.S. Environmental Protection Agency (EPA) on June 22 issued final underground storage tank system testing and inspection regulations, marking the first significant revision to the regulations since they were issued in 1988.
NATSO currently is reviewing the 468-page rule. On initial review, it appears that the final rule has improved upon the proposed rule in several ways that will be beneficial to tank owners, including limiting the burdens associated with monitoring interstitial areas and limiting the frequency of inspections.
In issuing the rule, EPA said the revised requirements include: adding secondary containment requirements for new and replaced tanks and piping; adding operator training requirements; adding periodic operation and maintenance requirements for UST systems; removing past deferrals for emergency generator tanks, airport hydrant systems, and field-constructed tanks; adding new release prevention and detection technologies; updating codes of practice; and updating state program approval requirements to incorporate these new changes.
In 2012, NATSO recommended ways that EPA could structure its new requirements to minimize regulatory burdens on UST owners and operators without any increased risk to human health and environment.
NATSO recommended that EPA: refrain from adding a new monthly walkthrough inspection requirement; exempt truckstop and travel plazas that have continuous monitoring of tank sumps from a 30-day tank sump inspection; and move the spill prevention tests to three years instead of annually. NATSO also told EPA that the agency's cost estimates to comply with the changes were understated. To read a copy of NATSO's comments click here.
NATSO will evaluate the rule and update members on its full implications.
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