The Aging Tanks Workgroup (“Workgroup”) of the Association of State and Territorial Solid Waste Management Officials Tanks Subcommittee (“ASTSWMO”) issued an October 2015 report titled An Analysis of UST System Infrastructure in Select States (“Report”).
The Report states that in October 2014 the organization was asked to examine issues related to:
… aging underground storage tanks (USTs) and the potential impacts to owners, operators, and State UST programs.
A Workgroup was formed whose objective is stated to have been 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 Report notes that various states face different challenges and the available data varies considerably due to unique programs that have developed over the last 25 years. The Report states it has examined:
… data provided to ASTSWMO by some States, reports on policy decisions made by States in response to concerns about aging USTs, and suggests issues for consideration as States consider similar policy choices.
Some of the questions examined by the Workgroup were:
- Is the nation’s UST infrastructure getting older?
- If so, to what extent does this affect the risks shouldered by insurers and State tank funds that serve as the predominant financial responsibility mechanisms for owners/operators?
The Report notes that based on additional data collected additional questions included:
- Are States collecting data in a way that informs risk management decisions needed in the future?
- How do a State’s policies impact owners’ and operators’ decisions related to upgrading, replacing, or closing their USTs?
The Report provides an analysis of UST data from eight states which include:
- Age of USTs
- Age of UST Piping
- UST Material and Construction
- UST Piping Material and Construction
- ULSD Storage
- Ethanol-Blended Fuels Storage
The Report also addresses UST infrastructure and risk management issues such as:
- Risk Factors
- Source and Cause of Leaks
- State Policy Choices and Initiatives
- Private Market Forces as Drivers for UST Removal and Replacement
- UT Owners’ Initiatives
- Actuaries’ Opinions
Click here to download a copy of the Report.
The Between the Lines blog is made available by Mitchell, Williams, Selig, Gates & Woodyard, P.L.L.C. and the law firm publisher. The blog site is for educational purposes only, as well as to give general information and a general understanding of the law. This blog is not intended to provide specific legal advice. Use of this blog site does not create an attorney client relationship between you and Mitchell Williams or the blog site publisher. The Between the Lines blog site should not be used as a substitute for legal advice from a licensed professional attorney in your state.