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The Petroleum Marketers Association of America (“PMAA”), National Association of Truck Stop Operators, National Association of Convenience Stores, and Food Marketing Institute (collectively “Group”) sent a June 20th letter to the Administrator of the United States Environmental Protection Agency (“EPA”) asking that a compliance deadline for the 2015 federal Underground Storage Tank (“UST”) revisions (“Rule revisions”) be extended.
The Arkansas Oil Marketers Association is a State Chapter of PMAA.
The Group requests a delay in the compliance deadline for a component of the Rule Revisions that requires testing for sumps, spill buckets and overfill prevention devices.
By way of background, EPA published certain revisions to the federal petroleum UST regulations in 2015. These were the first comprehensive revisions to the federal UST rules since 1988.
The changes included:
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Added secondary containment requirements for new and replaced USTs and piping
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Added operator training requirement
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Added periodic operation and maintenance requirements for UST systems
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Added requirements to ensure UST system capability before storing certain biofuel blends
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Remove past deferrals for emergency generator tanks, field construction tanks, and airport hydrant systems
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Updated codes of practice
States that have delegation of the federal petroleum UST programs (which include Arkansas) have three years to reapply in order to retain their delegated status.
The Group asks EPA to extend the testing deadline for sumps, spill buckets and overfill prevention devices from October 13, 2018, to a delayed date of October 13, 2024.
The organizations submit in support of the request:
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There are too few qualified contractors available to install the upgraded equipment (the large number of active UST sites [553,000] cannot be retrofitted for compliance in the three years currently provided due to the limited number of contractors and weather conditions)
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Extension of the deadline would provide enough time for small business petroleum marketers and truck stop operators to find qualified contractors
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In light of the 10-year compliance period previously provided for the initial 1988 UST upgrade requirements a six-year deadline extension is reasonable and necessary
A copy of the letter can be downloaded here.
