Enviro Watch



If you have any questions in regards to the above, please do not hesitate to contact our offices so that we may explain the amendments to the provisions of the Code in more detail. Our address is:


Fiddler González & Rodríguez, P.S.C., P.O. Box 363507, San Juan, PR 00936-3507. Our fax (787) 759-3108.


We welcome your questions and comments.

Juan Carlos Gómez Escarce
(787) 759-3166


María L. González Hernández
(787) 759-3173



Eduardo Negrón Navas

(787) 759-3106


Pedro J. Reyes Bibiloni

(787) 759-3208




The Environmental Quality Board ("EQB") will hold public hearings to receive comments on the proposed adoption of a new Regulation for the Control of Underground Storage Tanks (The “Regulation”) on March 14, 2014. If approved, the Regulation will repeal the currently in effect Regulation for the Control of Underground Storage Tanks of November 14, 1990, as well as any prior interpretative resolution issued by the Governing Board pursuant to it.


The Regulation is a comprehensive revision of the current regulation. It modifies or includes for the first time more than 90 definitions, including the owner and operator definitions. Also, the Regulation establishes training requirements for operators, the training program accreditation process, and the procedures and requirements for permits, notifications, investigations, and leak confirmation. In addition, it imposes new leak detection requirements to be complied with within specific timeframes.


One of the most significant developments is the incorporation of specific clean-up levels for various parameters and by media. Furthermore, the Regulation incorporates the Procedures, Actions and Requirements for Permanent Closure of Underground Storage Tank Systems of May 5, 2011, and also opens the door for EQB to consider corrective actions other than those specifically established in the Regulation, such as Risk Based Corrective Actions. The Regulation does not define clearly the procedure for the owner or operator to request, or a timeframe for EQB to issue, a release letter.


The Regulation also modifies the applicable filing fees for initial registration, permits for the installation, closure and operation of underground storage tanks, as well as for permit renewal and modifications.


If you have any questions regarding this matter or would like to know more of our Firm’s experience in this area please call us. If you know anyone that would like to read the FGR Environmental Watch, please feel free to forward this article. Stay tuned for further updates of FGR ENVIRONMENTAL WATCH.

©2014 FIDDLER GONZÁLEZ & RODRÍGUEZ, P.S.C. Permission is granted to view, store, print, copy or distribute the content of this article for noncommercial or personal use, provided you do not alter it and you give us proper credit.

The content of this article is for informational purposes only. It is not legal advice or advertising. In addition, the above discussion has been provided in general terms and, therefore, should not be relied upon as legal advice applicable to a specific set of facts and circumstances. Before taking legal action, consult a lawyer you trust. Although we will try to be accurate, you cannot rely on its applicability to your specific problem without consulting your lawyer. Fiddler González & Rodríguez, P.S.C. and the members of the Environmental Practice Group assume no responsibility to inform you of additional changes in law or any other legal issues related to matters addressed in this email of which we may become aware after the date hereof.

***IRS CIRCULAR 230 DISCLOSURE: To ensure compliance with requirements imposed by the Internal Revenue Service, we inform you that any United States federal tax advice in this communication (including any attachments) is not intended or written by Fiddler González & Rodríguez, PSC to be used, and cannot be used, for the purpose of (i) avoiding any penalties under the Internal Revenue Code, or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein. ***



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San Juan, PR 00936-3507


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