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 2018 UST Common Compliance Violations Report – FY 2014 UST Common Compliance Violations Report – FY 2012

Comparing EPA UST Regulations and NFPA Fire Codes

This document provides UST managers a breakdown of where EPA’s Office of Underground Storage Tanks (OUST) UST Regulations and the National Fire Protection Association Fire codes are aligned/misaligned. Most US states adopt NFPA 30 (Flammable and Combustible Liquids Code) and 30A (Code for Motor Fuel Dispensing Facilities and Repair Garages) to include the IFC, but very few of those states enforce or write UST regulatory orders pertaining to Fire Codes. When enforcing, or trying to enforce a particular issue, state UST programs may not be aware of what NFPA Fire Codes include, so this document can be used by tank owners or legislatures so as to not encounter issues when creating legislature/regulations.

UST Open Bermed Containment Systems at Retail Fueling Facilities

This position paper addresses open bermed containment systems at commercial retail fuel facilities that are used to meet the spill prevention equipment requirements for underground storage tanks (USTs) outlined in 40 CFR 280.20(c), and replaces ASTSWMO’s July 2016 position on these systems. The new document clarifies that ASTSWMO’s position addresses open bermed containment systems at retail fueling facilities, includes additional details about the construction and design of spill buckets vs open bermed containment systems, and new and updated references and resources.

COVID-19 Impact to State UST Cleanup Funds

In efforts to slow down the spread of the COVID-19 pandemic in March 2020, many states across the US issued “Stay at Home” orders and other travel restrictions. As a result, demand for transportation fuels declined significantly in March and April. It is likely that many states will see 50 to 70% reductions in gasoline fuel consumption during this time. According to the US Energy Information Administration reports released on April 23, 2020, the COVID-19 mitigation efforts resulted in the lowest U.S. petroleum consumption in decades. The most significant declines in the last four weeks (March 13 through April 17) were in motor gasoline and jet fuel.

EPA National Database for UST and LUST – Webinar

Working with State partners, EPA has developed the first comprehensive national database on underground storage tank facilities, underground storage tanks, and leaking underground storage tanks. This data, including geospatial data, will assist States and stakeholders in identifying facilities that may be prone to flooding and assessing potential risk to ground water and vapor intrusion from LUST sites as well as in prioritizing cleanup efforts. Additionally, this database provides key data on the tanks infrastructure nationally, including the tank age and type. On October 10, 2019, ASTSWMO hosted a webinar to share the application with States. EPA will make the database publicly available at a later date.

ASTSWMO Policy Position on UST Open Bermed Containment Systems

This paper has been replaced by the document located here. 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.

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.

Operator Training Resource Guide and Spreadsheet

The ASTSWMO UST Task Force has developed the Operator Training Resource Guide as an information tool for States and Territories, as well as operators. It contains core information on each State UST operator training program such as the method States choose to conduct operator training, limitations imposed, how training programs and trainers are approved, and the name, phone number, and program website for each State/Territory operator training program. The UST Task Force will conduct periodic updates in order to keep the Guide up to date with new or revised information. Operator Training Resource Guide Operator Training Spreadsheet Operator Training Spreadsheet (separated by decision points, 12 pages)