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By Jeryl L. Olson, Kay R. Bonza, and Craig B. Simonsen

Seyfarth Synopsis: New Illinois Office of State Fire Marshall (“OSFM”) regulations, (42 Ill. Reg. 10476, 10662-667, June 15, 2018, effective October 13, 2018), require that periodic operation and maintenance include recorded “walkthrough inspections” for underground storage tank (UST) facilities. 

Under new OSFM rules,…
Continue Reading Periodic Operation and Maintenance Walkthrough Inspections Required for Illinois UST Facility Owners and Operators

By Philip L. Comella and Craig B. Simonsen

iStock_000049177646MediumThe U.S. Environmental Protection Agency has promulgated significant new provisions both to its 1988 underground storage tank (UST) regulations and to its 1988 state program approval (SPA) regulations. 80 Fed. Reg. 41566 (July 15, 2015). This is the first major revision to the federal UST regulations since 1988.

The revisions to the…
Continue Reading EPA Adopts Significant Revisions to Underground Storage Tank Regulations

By Jeryl L. Olson and Craig B. Simonsen

Power Lines and Pulp Mill PollutionIn a busy day for vapor intrusion, last week the U. S. Environmental Protection Agency made several announcements about vapor intrusion.

First, it announced it had submitted a draft rule to the White House OMB seeking to add vapor intrusion to the pathways evaluated under the Hazard Ranking Scoring (HRS) System for…
Continue Reading EPA Takes Positions on Vapor Intrusion

By Andrew H. Perellis and Craig B. Simonsen

The environmental community continues to focus on the vapor intrusion pathway — guidance has been issued by ASTM, ITRC and more than 25 States. Most recently, the U.S. Environmental Protection Agency’s (EPA or Agency) Office of Underground Storage Tanks (OUST) just published an information paper entitled, “Petroleum Hydrocarbons And Chlorinated Hydrocarbons…

Continue Reading EPA Publishes Vapor Intrusion Paper Distinguishing Behavior of Petroleum Hydrocarbons from Chlorinated Hydrocarbons