With the final updated UST regulations scheduled to be published in the Federal Register this month, there’s a lot of discussion on the internet about what is in the updated regulations and what they mean for those of us in the petroleum industry. One of the most cogent and helpful discussions out there is by Robert Renkes, Executive Vice President of the Petroleum Equipment Institute. His article appeared in the June 30, 2015 of PEI’s Tulsa Letter, and you can read it here (click on the link to Vol. 65, No. 12).
Parts of the article I found especially useful include Mr. Renkes’ breakdown of implementation time frames or, in other words, which requirements will be effective 90 days from the date of publication (date of publication + 90 days = the “effective date”) in the Federal Register and which ones will take effect three years from the effective date. Mr. Renkes also succinctly covers the different walk-through inspections and the concerns surrounding groundwater and vapor monitoring.
If you do read through the pre-publication version of the updated regulations, keep in mind that the actual regulations begin on page 226, so head there if you just want to read the updated text of 40 CFR §280 and 40 CFR §281. Pages 1 through 226 contain a discussion of the changes proposed, the public comments received, the EPA’s rationale for addressing those comments, and the changes ultimately made. Expect minor editing–removal of the header disclaimer, addition of dates–in the published version.
As always, check our blog regularly for updates on the Federal Register publication and other UST news. You can also subscribe to PASSing Notes, our monthly newsletter, for important updates delivered right to your inbox.