In recent years, OPS has taken steps to improve our protection of the environment from tank spills, and to retool our requirements to maximize efficiency while minimizing the burden on industry. Our efforts are meant to pave the way to revise our 1971 memorandum of understanding (MOU) with the Environmental Protection Agency (EPA) to end the problem of overlapping federal jurisdiction over tanks. On February 4, 2000, Richard Felder signed a joint policy memorandum with his counterpart at EPA, that represents the first step along this path. This policy memorandum is not the end of a process, but the beginning.

The following paragraphs explain the significance of the policy memorandum in the broader context of our work with EPA to move toward our ultimate goal of eliminating overlapping tank regulations.

The policy memorandum is not a new Memorandum of Understanding. It is simply a clarification of some of the jurisdictional issues that the existing MOU left unclear. During 1999, OPS incorporated a number of API and NFPA standards into our regulations. In early 2000, we trained our inspectors on these standards and how OPS uses them to conduct inspections of facilities with breakout tanks. We will soon implement an outreach program to ensure that facility operators are familiar with our regulations and jurisdiction.

OPS has engaged EPA on several other fronts. We included EPA staff in our OPS tank inspection training courses, and intend to open other Transportation Safety Institute courses to EPA staff as well. We plan to conduct six to ten joint inspections of tank farms with EPA during 2000 to familiarize them with our regulations and inspection methods. We are participating in EPA's Regional Response Team and Inland Area Committee meetings. We are building a breakout tank database, as part of the National Pipeline Mapping System that will enable us to focus the most attention on the facilities which pose the greatest threat to people and the environment. Also, we appointed an EPA official as a member of our Technical Hazardous Liquid Pipeline Safety Advisory Committee.

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