UST Common Compliance Violations Reports

The UST Task Force solicited information from all States in an effort to determine which violations are most often encountered during UST compliance inspections and other verification activities. The intent of this report is to provide a national perspective with regard to which UST violations are discovered in greatest frequency and may require additional attention. The data could impact where States allocate resources and how they perform onsite UST inspections, where the regulated community can best allocate their resources to improve compliance, and future decisions regarding the long-term direction of State and federal programs.

The UST Task Force plans to update these reports on a biennial basis to identify any trends across the UST programs.
UST Common Compliance Violations Report – FY 2014
UST Common Compliance Violations Report – FY 2012

ASTSWMO Policy Position on UST Open Bermed Containment Systems

This position paper addresses open bermed containment systems that are used to meet the spill prevention equipment requirements for underground storage tanks (USTs) outlined in 40 CFR 280.20(c). Bermed containment systems are configured with small concrete berms or curbing that surround the fill riser(s) for a UST system and are typically used at high volume facilities. The floor of the bermed containment systems are generally constructed of concrete and most of these systems have a drain that diverts any spilled liquid, rainwater, or melted snow, to an oil/water separator.

Compatibility Considerations for Underground Storage Tank Systems

The Emerging Fuels Task Force developed this report as an update and replacement to the 2013 ASTSWMO Alternative Fuels Workgroup’s Compatibility of UST Systems with Biofuels report. This document serves as a resource for State and Territorial underground storage tank (UST) program staff, UST owners and operators, equipment manufacturers, and contractors and consultants for the evaluation of equipment compatibility pursuant with EPA’s compatibility requirement (40 CFR 280.32) specifically when storing motor fuels. The document includes information product and operational compatibility, properties of biofuel blends, and considerations for the storage of biofuel blends. Also included are several policy and technical resources, a template for creating a compatibility evaluation checklist for State programs, and a compilation of case summaries from several States.

An Analysis of UST System Infrastructure in Select States

In 2014, ASTSWMO formed the Aging Tanks Workgroup to examine issues related to aging UST systems and the potential impacts to owners, operators, and State UST programs. The Workgroup’s objective was to analyze whether aging UST infrastructure poses a higher risk of leaks, thus creating higher risks for State tank funds and private insurers and, ultimately, higher costs for tank owners/operators. The final report includes an analysis of UST system data from eight participating States as well as information on potential risk factors of fuel leaks, State policies and initiatives for mitigating risks of aging tanks, and State fund and financial insurance considerations.

An Analysis of UST System Infrastructure in Select States

In 2014, ASTSWMO formed the Aging Tanks Workgroup to examine issues related to aging UST systems and the potential impacts to owners, operators, and State UST programs. The Workgroup’s objective was to analyze whether aging UST infrastructure poses a higher risk of leaks, thus creating higher risks for State tank funds and private insurers and, ultimately, higher costs for tank owners/operators. The final report includes an analysis of UST system data from eight participating States as well as information on potential risk factors of fuel leaks, State policies and initiatives for mitigating risks of aging tanks, and State fund and financial insurance considerations.

State Approaches to Managing Institutional Controls and Ensuring Long-Term Protectiveness at LUST Sites

The document is the result of recent discussions at ASTSWMO meetings and an information request sent to all States, Territories, and the District of Columbia (States) that focused on how State tanks programs manage institutional controls and ensure long-term protectiveness of remedies at LUST sites. Included in the report are policies, tools, and practices from the 35 States that responded to the request for information, and brief summaries where applicable.

Lead Scavengers Survey Report

In 2013, the Tanks Subcommittee’s LUST Task Force requested information from all States and Territories to determine what activites the tanks programs are taking to identify and remediate the lead scavengers 1,2-dibromoethane (EDB) and 1,2-dichloroethane (1,2 DCA). Thirty-five States responded and the Task Force found that there continues to be great variation from State to State on how lead scavenger issues are addressed, which is summarized in this report.