Are a monasterys two 500-gallon underground storage tanks subject to UST regulations?
[September 19, 1989 letter from Senator Howell Heflin] Answer: No, as long as they store motor fuel that is non commercially used only by the monastery’s residents. The monastery is considered a residence and, therefore, the regulatory exclusion for farm and residential USTs of 1,100 gallons or less storing motor fuel used for noncommercial purposes applies. [October 6, 1989 letter to Senator Heflin (PDF) (2 pp, 10K)] Question 7: Are owners of USTs primarily responsible for ensuring compliance with certain section of Part 280 (e.g., 280.21, 280.22, and 280.34) [December 27, 1989 letter from Alan Campbell of Dow, Lohnes & Albertson] Answer: The regulations do not provide that the owner will be held “primarily” responsible for complying with these requirements. Some provisions impose requirements on owners exclusively and some on both owners and operators. A careful reading is necessary to determine whether only one or both parties may be liable in the event of noncompliance. [January 19
