The notice in the federal register identifies Manufacturing Sector NAICS codes 31-33 (that's us!) as potentially affected by the proposed changes.
EPA's proposal revises the UST technical regulation in 40 CFR part 280 by:
- Adding secondary containment requirements for new and replaced tanks and piping
- Adding operator training requirements for UST system owners and operators
- Adding periodic operation and maintenance requirements for UST systems
- Removing certain deferrals
- Adding new release prevention and detection technologies
- Updating codes of practice
While we don't see this update as unreasonable (its been 24 years since the 1988 UST regs first came into effect) we could see how the updates could result in large expenses by small manufacturers if they are required to update secondary containment and interstitial montitoring for their USTs.
Federal Register Notice UST
EPA UST Proposed Regs Page
If you would like to comment- here's the link: UST Proposed Reg Comments
Need training in this area? Rutgers is offerring a UST training course on March 6, 2012
Why this rule?
Editor's Note: CR4 would like to thank Milo for sharing this blog entry, which originally appeared here.
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Re: EPA Revising UST Regulations
