I’ve spent much of the last week wading through hundreds of pages of material published by the US EPA, trying to familiarize myself with the new UST Law of Land, made available Monday, June 22, 2015, exactly 26 and a half years to the day when the first batch of UST regulations hit the streets.
And when you look at the new tables of contents for the Federal rule 20 CFR 280, it looks simple enough. A few new sections on operation, maintenance and testing plus two new Subparts: one on operator training and another on field-constructed and airport hydrant tanks. Plus some miscellaneous edits.
But the truth is there’s lots going on here, mostly for the better. Mandatory secondary containment. Mandatory operator training. Mandatory 30-day walk through inspections. Mandatory equipment testing on the parts most likely to leak but least likely to be tested. Inclusion of emergency power generator, airport hydrant and field constructed tanks. Banning certain legacy technologies and recognizing new ones. There’s a few disappointments but more on that later.
Some of these rule take affect very soon, this summer even. Some kick in in 6 months and the bulk in three years, when, hopefully many/most/all state agencies will tweak their own regulations to be consistent with federal law. And I expect it’ll take us all in the UST community 5-10 years to get through it all. Like last time.
Meanwhile, don’t panic. Take a deep breath. All will be revealed over time.
In fact, on July 29, I’ll be offering a free 1-hour webinar to help you understand what the new rules mean, what’s different, and how to get ready.