Comm 10 Code Revision Status

The Comm 10 code, which regulates storage tanks, revision work is nearing the final stages. Staff within the Environmental and Regulatory Services Division is nearing completion of the review and response to the public hearing comments. Several public hearing comments pose issues with code readability. The department initiated a workgroup composed of representatives of stakeholder organizations to assess readability. The goal of this workgroup project is to identify the problem areas, such as language ambiguity and subject organization, and identify remedies to the readability problems that can be implemented within the structure of code writing criteria.

The department's review and response to the public hearing comments includes modifications to the proposed code, justification of proposed code requirements and clarification to misconceptions of the proposed code language.

Also included in this phase of the code revision process is a significant overhaul of the tank closure language and closure assessment guidelines. While the tank closure and closure assessment protocols are being better defined and communicated, the technical requirements for tank closure are modified very little. The department has also taken the lead in updating the Tank Closure Guidance booklet. Much of the closure guidance revision is a result of reporting requirements mandated by the Energy Bill of 2005.

-- Sheldon Schall