December 22, 1998, was a crucial deadline for the owners of underground storage tanks. Pursuant to United States Environmental Protection Agency mandates, which have been adopted by the Office of the Illinois State Fire Marshall, That was the deadline for completing upgrades to petroleum and hazardous substance underground storage tank systems installed before December 22, 1988. By December 22, 1998, petroleum and hazardous substance underground storage tank systems installed before December 22, 1988, must meet one of the following requirements:

1. Meet the performance standards required for new underground storage tanks contained in § 170.420 of the Office of the Illinois State Fire Marshall's Regulations (41 Ill.Admin.Code § 170.420);

2. Meet the upgrading requirements of Title 41, § 170.430 of the Illinois Administrative Code. These regulations require corrosion protection and the installation of spill and overflow prevention equipment;

3. Meet the requirements for and obtain a temporary Out-of-Service certification from the State Fire Marshall (41 Ill.Admin.Code § 170.620) or meet the requirements of 41 Ill.Admin.Code § 170.670 which addresses removal or abandonment-in-place of underground storage tanks. Under either § 170.620 or § 170.670, the owner must also meet the applicable requirements of 41 Ill.Admin.Code §§ 170.600 and 170.610, which address requirements for the initial response to a release, abatement measures, and site assessment.

The Office of the Illinois State Fire Marshall plans on sending letters to owners and operators of underground storage tanks reminding them that the deadline is near. By press release, the State Fire Marshall ominously warns that the United States Environmental Protection Agency will not extend the December 22, 1998, upgrade deadline and that the State of Illinois does not have authority to extend the deadline. In order to assist owners, the Office of the State Fire Marshall has issued a "Quick Compliance Check List" to advise underground storage tank owners and operators of the major components of the upgrading requirements for tanks which were installed prior to December 22, 1988. As the regulations are quite lengthy and complex, the assistance of an environmental or engineering professional would be recommended.