### B

- 1

Appendix B: Methodology for Extrapolation from State Databases
I. State Database Survey

 Using EPA’s State and Territorial UST Program Directory as a guide, 1 

### E 2 

### Inc. investigated the UST program Web sites for all 50 states. State UST programs are typical ly

administered through the state’s environmental management department, though in some cases the programs are a service of the state fire marshal’s office or fire department. The purpose of the investigation was to ascertain if the Web site contained a publicl y available downloadable database of regulated USTs with facility, tank, and industry sector information.

 E 2 

### In c. also obtained datasets from Abt Associates Inc. (Abt) that provided information on USTs for 11 states (AL, DE, FL, KS, MA, MD, MN, NY, PA, VA, WI). Abt obtained these data from state agencies in 2005 in order to estimate the SPCC

- regulated universe of facilities to support the SPCC rulemaking activities for EPA’s Office of Emergency Management.

 E 2 

### In c. summarized its findings for each state in a spreadsheet, which identifies the following information: state name, data source, database name, the state’s UST regulatory

requirements, industry

sectors used (if available), data elements included (e.g., tank capacity , contents), the program’ s contact details, and a Web link to the database.

II. Thirteen States Identified for Anal ys is

 E 2 

### In c. identified thirteen states as having accessible databases (either through Abt or state Web sites) that included industry sector breakdowns. Exhibit B

- 1 shows the states that met these criteria.

Exhibit B

- 1. Summary of State Databases Used for Industry Sector Profile Analysis

State Data Source Database Nam e Regulatory Requirem ent Industry Sectors Alabama Abt Data for

Alabama (one of the four states not used in SPCC analysis) "Owners" and

"Utanks" Microsoft Excel spreadsheets Alabama Department of

Environmental Management regulates tanks that are more than 110 gallons in capacity with the exception of farm or residential tanks of 1,100 gallons or less capacity used for storing motor fuel for noncommercial purposes; and tanks used for storing heating oil for consumptive use on the premises where stored. Retail; Bulk Facility; Industrial; Local Government; State/Federal Government; Farm /Residenti al

1 EPA’s State and Territorial UST Program Directory is available at http://www.epa.gov/OUST/states/statcon1.htm

### B

- 2

State Data Source Database Nam e Regulatory Requirem ent Industry Sectors Alaska Alaska

Department of Environmental Conservation Alaska UST

Database An underground storage tank or

underground storage tank system means one or more stationary devices, including any connected underground pipes, designed to contain an accumulat ion of petroleum, of which the volume, including the volume of underground pipes, is 10% or more beneath the surface of the grade. DEC's definition is essentially the same as EPA's. State Government; Federal Military; Commercial; Aircraft Owner; Gas Statio n; Contractor; Petroleum Distributor; Truck/Transporter; Auto Dealership; Farm; Utilities; Local Government; Residential; Industrial; Federal Non

- Military; Railroad; Unlisted

Delaware Delaware

Department of Natural Resources and Environmental Control Lis ting of Recent

Facility, O wner, and Tank Information Delaware's Department of Natural

Resources and Environmental Control regulates all USTs with the following exceptions: any UST system whose capacity is 110 gallons or less; Agricultural/Farm and residential UST systems of 1,100 gallons or less used for storing motor fuels for non

commercial purposes; UST systems containing heating oils of 1,100 gallons or less used for consumptive purposes on the premises where stored. Airport/Aircraft Owner; Apts/Senior Ctr; Auto Dealership; Auto Parts/Service; Bank; Church/Synagogue; Commercial; Contractor; Entertainment; Farm; Federal Military; Federal Non

- Military; Gas Station/Mini

- Market; Health Care Operations; Hotel/Motel; Industrial; Laundry/Garment; Local Governme nt; Manufacturing; Marina; Mom & Pop/General Store; Not Listed; Other; Petroleum Distributor; Post Office; Private School; Railroad; Recreation/Clubs; Recreational; Retail; Shopping Mall/Ctr; State Government; Truck/Bus/Transporter; Utilities
Florida Abt Data

-

Florida Department of Environmental Protection Storage Tank

Facility Information Florida Department of Environmental

Protection regulates all non

- residential USTs whose capacity exceeds 110 gallons with the exception of storage tank systems used sol ely for tem porary storage of mixtures of pesticides and diluents for reapplication as pesticides; storage tank systems with a storage capacity of less than 30,000 gallons used for the sole purpose of storing heating oil for consumptive use on the premises where stored; and agricultural storage tank systems of 550 gallons capacity or less. Agricultural; Chemical User; Collection Station; Condo Residential; Contamination Site; County Government; Fuel user/Non

- retail; Indian Land; Local Government; Marine/Coa stal Fueling Location; Other Regulated Facility; Residential; Retail Station; State Government; Terminal/NonReg Tanks; Waterfront Fueling Location

### B

- 3

State Data Source Database Nam e Regulatory Requirem ent Industry Sectors Georgia Georgia

Environmental Protection Division of the Department of Natural Resources List of Georgia

Und erground Storage Tanks, Facilities/Owner Data; List of Georgia Underground Storage Tanks, Tank Data The GA DNR regulates all USTs

whose capacity exceeds 110 gallons with the exception of farm or residential tanks of 1,100 gallons or less capacity used for storing motor fuel for noncommercial purposes; and tanks used for storing heating oil for consumptive use on the premises where stored. Gas Station; Petroleum Distributor; Federal Military; Truck/Transport; State; County; City; Local; Other; Not marked; Co mmercial; Industrial; Airline; Aircraft Owner; Contractor; Auto Dealership; Educational; Farm; Federal Non

- Military; Hospital; Railroad; Residential; Utilities Maryland Abt Data

-

Maryland Department of Environment UST Oil

Operations Database Maryland Dep artment of

Environment's Oil Control Program regulates all petroleum USTs with the exception of tanks that are 1,100

- gallon capacity or less and used to store petroleum products at a private residence or farm. Air Taxi (Airline); Auto Dealership; Commercial; Contractor; Educational; Farm; Federal Military; Federal Non

Military; Fire/Rescue/Ambulance; Gas Station; Industrial; Local Government; Marina; Not Listed; Office; Other; Petroleum Distributor; Railroad; Residential; State Government; Store; Truck/Tran sporter; Utilities
Massachusetts Abt Data for

Massachusetts (one of the four states not used in SPCC analysis), which is same data as found through Massachusetts Department of Fire Services Web site UST Database The UST program regulates all USTs with the exception of farm or residential tanks of 1,100 gallons capacity or less used for storing motor fuel for noncommercial purposes, and residential or commercial tanks storing or having stored heating oil (fuel oil) for consumptive use on the premises. Gas S tation; Municipal; Industrial; Vehicle Dealer; Truck/Transport; Utilities; Other; Farm; Petr. Distr; Contractor; Federal/Military; Aircraft Owner; Hotel; State; Country Club/Golf Course; Marina; etc. (There are about 100 categories in all)

Minnesota Abt D ata

-

Minnesota Pollution Control Agency (MPCA) Tanks Database Petroleum and “Other.” Registration is required for petroleum USTs covered by EPA's UST program. Landfill/Rubbish, State Government, Family Farm, Refinery, Food Processing, Utility, Agricultural, Construction, Autocare/Autoparts Missouri Missouri

Department of Natural Resources UST Summary

Database Any UST containing regulated

substance excluding farm or residential tanks less than 1,100 gallons containing fuel for non

commercial purposes. Owner Class: City, Federal, Government Owner, Hospital, Local, Marketer, Non

- Marketer, County, Private Owner, State, Unclassified, School
Nevada Nevada Division

of Environmental Protection Registered

Underground Storage Tank List Nevada has adopted 40CFR28 0, the

Federal UST Regulations. Private; Commercial; Federal, State; Local Government

### B

- 4

State Data Source Database Nam e Regulatory Requirem ent Industry Sectors Tennessee Tennessee

Department of Environment and Conservation Petroleum

Underground Storage Tank Database Tennessee Department of

Environment and Conservation regulate s all petroleum USTs that are
mo re than 110 gallons in capacity with the exception of farm or residential tanks of 1,100 gallons or less capacity used for storing motor fuel for noncommercial purposes; and tanks used for storing heating oil for consumptive use on the premises where stored. Air Taxi (Airline); Aircraft Owner; Auto Dealership; Commercial; Contractor; Farm; Federal Military; Federal Non

Military; Gas Station; Industrial; Local Government; Not Listed; Other; Petroleum Distributor; Railroad; Re sidential; State Government; Truck/Transporter; Utilities

Virginia VA Department

of Environmental Quality UST & AST

registered petroleum storage tanks The Virginia regulation is very similar to

the federal regulation, except it requires notifications from owners of all regulated USTs that remain in the ground. Commercial; Autodealer; Utility; Aircraft; Fuel Station; Contractor; Industrial; Local

Wisconsin Wisconsin

Department of Commerce Storage Tank

Database Registration required for all USTs

larger than 60 gallons and storing petroleum or CERCLA hazardous substances. Assembly; Business; Educational; Factory/Industrial; Hazardous; Institutional; Mercantile/Commercial; Residential; Storage; Bulk Plant Storage; Retail Fuel Sales; Industrial



### III. Preparing Databases for Anal ys is

 E 2 

### In c. imported the thirteen databases into Microsoft Excel format.

 E 2 

### In c. refined/filtered the thirteen databases to include only active (designated as either currentl y in use or temporaril y out of use), regulated underground storage tanks. This process involved removing any aboveground storage tanks; tanks with non

- active status such as closed, removed, or abandoned; and tanks that are not federally

regulated. Non

- regulated tanks were identified as being either less than 110 gallons in capacity , storing heating oil, or storing less than 1,100 gallons of motor fuel and being a farm or residential tank. Additional non

- regulated tanks were identified and removed on a state

- specific basis. For example, tanks with contents li sted as “other non

- regulated” were removed from Florida’s database.

 E 2 

### In c. compared the number of active, regulated tanks in the thirteen databases and the corresponding numbers from EPA’s End

- of

- Year Activity

Reports as shown in Exhibit B

- 2 below. 2 

### This was performed to ensure that the subsequent industry sector anal ys is was based on the set of tanks affected by the delivery prohibition regulations. E 2 

### In c. used the FY 2004 End of the Year report for databases received from Abt, which had been gathere d from state agencies in 2005, and the FY 2006 report for the databases obtained online.

2 The FY 2004 End

- of

- Year A ctivity Report is available at http://www.epa.gov/OUST/cat/ca_043_4.pdf ; and the FY 2006 report is available at http://www.epa.gov/OUST/cat/c a_06_34.pdf

### B

- 5

Exhibit B

- 2. Comparison of EPA’s End

- of

-Year Activity Reports Data with State Databases

EPA Data fromEnd

- of

- Year Reports State Databases

States Number of

Acti ve Tanks in 2004 Number of

Active Tanks in 2005 Number of

Active Tanks in 2006 Number of

Active Tanks Source of State

Data Year for State

Data Alabama 18,153 18,021 19,063 18,144 Abt 2004 Alaska 1,081 1,065 1,142 1,145 State Web site 2006 Delaware 1,566 1,598 1,606 1,585 State Web site 2006 Florida 32,236 31,109 30,051 29,028 Abt 2004 Georgia 38,437 30,320 30,081 29,057 State Web site 2006 Maryland 9,423 9,439 9,317 9,418 Abt 2004 Massachusetts 11,441 11,368 11,211 11,758 State Web site 2006 Minneso ta 14,129 14,328 14,414 14,236 Abt 2004 Missouri 10,281 10,305 10,274 9,997 State Web site 2006 Nevada 3,677 3,688 3,721 4,080 State Web site 2006 Tennessee 16,279 16,147 17,575 17,637 State Web site 2006 Virginia 26,994 25,464 22,101 21,824 State Web site 2006 Wisconsin 13,744 13,721 13,757 12,651 State Web site 2006



###  After E 2 

### Inc. verified the numbers of active regulated tanks, E 2 

### In c. filtered the databases further to include only tanks containing petroleum products. E 2 

### Inc. compiled a separate dataset of all the individual facilities associated with these tanks for each state. Both of these datasets are used for the subsequent industry sector analysis.

IV . Selection of Industry

Sectors for Analy sis

 E 2 

### In c. examined the particular industry s ector breakdowns, which varied from state to state, to select seven industry sectors that were most frequentl y represented. These seven industry sectors are:
o Retail Motor Fuels Sales;
o Agricultural;
o Institutional (hospitals only);
o Commercial (includes Wholesale Trade, Retail Trade, Accommodation and Food Services, excluding gas stations);
o Industrial/Manufacturing;
o Transportation (excluding railroads); and
o Utilities and Phone.

 E 2 

### In c. reviewed the typ es of companies represented in the state databases for each industry

sector. E 2 

### Inc. then identified appropriate NAICS codes to represent these sub

- sectors. For example, the commercial sector included sub

- sectors such as automobile dealerships, hotels, and restaurants.

### B

- 6

 It is important to note that not al l sectors are represented in all state databases. Exhibit B

- 3 shows the states that were used to analyze each industry sector.

Exhibit B

- 3. States Used to Calculate Industry Sectors

Industry Sector NAICS Codes NAICS Definitions Number of States Used t o Calculate Sector States Used to Calculate Sector Retail Motor Fuels Sales 447 Gasoline Stations 9 Alaska, Delaware, Florida, Maryland, Massachusetts, Minnesota, Tennessee, Virginia, Wisconsin Agriculture 111 Crops Production 9 Delaware, Florida, Georgi a, Maryland, Massachusetts, Minnesota, Tennessee, Virginia, Wisconsin 112 Animal Production Industrial/Manufacturing 31

- 33 Manufacturing 10 Alabama, Alaska, Delaware, Georgia, Maryland, Massachusetts, Minnesota, Tennessee, Virginia, Wisconsin Transpo rtation 481 Air Transportation 8 Alaska, Delaware, Georgia, Maryland, Massachusetts, Minnesota, Tennessee, Virginia 483 Water Transportation 484 Truck Transportation 485 Transit and Ground Passenger Transportation
486 Pipeline Transportation 48811 Airport Operations Utilities and Phone 2211 Electric Power Generation, Transmission, and Distribution 9 Alaska, Delaware, Georgia, Maryland, Massachusetts, Minnesota, Tennessee, Virginia, Wisconsin 5171 Wired Telecommunications Carrier

Co mmercial (excluding 447) 42 Wholesale Trade 10 Alaska, Delaware, Georgia, Maryland, Massachusetts, Minnesota, Nevada, Tennessee, Virginia, Wisconsin 44

- 45 Retail Trade 72 Accommodation and Food Services Institutional (Hospitals) 622 Hospitals 3 Ge orgia, Massachusetts, Missouri



### V. Industry

Sector Analysis (Calculations)

 E 2 

### In c. calculated the number of individual USTs and facilities associated with each industry

sector for the set of states relevant to that sector.

 E 2 

### In c. used the total numb ers of USTs and facilities to calculate and UST to facility ratio for each of the seven industry sectors.

### B

- 7

 As show in Exhibit B

- 4 below, the UST to facility ratios were largel y consistent with those calculated using the results of the 1988 rulemaking for the seven sectors. The overall UST to facility ratio calculated from the state data was 2.865, and the ratio calculated from the 1988 rulemaking was 2.728.

Exhibit B

- 4. Comparison of Tank to Facility Ratios from 1988 Rulemaking and State Databases

Indu stry Sector Tank/Facility Ratio from1988 Rulem ak

ing Tank/Facility Ratio Calculated fromState Databases Retail Motor Fuels 3.503 3.131 Agriculture 1.593 1.812 Industrial/Manufacturing 2.500 1.648 Transportation 2.320 1.769 Communication and Utilities 2.053 1.466 Commercial 2.088 2.300 Institutional (Hospitals) N/A 1.636

Total 2.728 2.865



###  E 2 

### In c. consulted the 2002 Economic Census 3 

### to obtain total numbers of establishments for each industry sector. E 2 

### In c. used these data to extrapolate

n ational numbers of facilities and tanks for each sector with the following two formulas:

o National number of regulated facilities = 2002 Census national number of establishments x (total number of regulated facilities calculated from the appropriate state databases /total of 2002 Census number of establishments for the same states)
o National number of regulated tanks = National number of regulated facilities calculated above x Tank to facility ratio that was calculated above for this sector

 As shown in Exhibit B

- 5 below, E 2 

### In c. found the extrapolated national number of facilities associated with retail motor fuels sales (141,776 facilities) to be in between the 2002 Census national number (121,446 facilities) and the national number estimated b y the American Petroleum Institute (API) (169,000 facilities) and the National Association of Convenience Stores (NACS) (168,000 facilities).

 E 2 

### In c. found the total number of facilities associated with retail motor fuels sales for the appropriate states (27,302 faci lities) to be higher than the 2002 Census

3 2002 Economic Census is available at http://www.census.gov/econ/census02/data/us/US000.HTM . The following NAICS codes were used: Retail Motor Fuel Sales

- 447; Agriculture

- 111,112; Commercial

- 42, 44

- 45, 72 (excluding 447); Institutional (Hospitals)

- 622; Manufacturing/Industrial

– 31

- 33; Transportation

- 481,483

- 486, 48811; Utilities and Phone

- 2211, 5171.

### B

- 8 total for those same states (23,387), though potentially consistent with a 2003 NACS survey

that reported 19,465 gas stations at convenience stores alone.

Exhibit B

- 5. Comparison of State Retail Fuels Sales Fac ilities Totals

State Number of Retail

Motor Fuel Sales Facilities Calculated fromState Databases 2002 Census Numbers of Gas Station Establishments (NAICS 447) Numbers of

Convenience Stores with Gas (fromNACS 2003 Fact Sheet) Tennessee 4,023 3,339 3,335 Maryland 1,703 1,735 901 Wisconsin 3,232 2,667 2,181 Delaware 314 312 233 Alaska 240 229 163 Florida 8,076 6,544 6,470 Virginia 4,315 3,623 2,945 Minnesota 2,810 2,605 2,162 Massachusetts 2,589 2,333 1,075 Total 27,302 23,387 19,465 National Total 141,776 121,446 101,823



### Limitations

 A key limitation of our approach is the fact that we used a small subset of data to develop estimates for the entire country , and relied on the assumption that these states are in fact representative of the entire country

.  Prior to this analy sis E 2 

### Inc. did not cleanse or verify the state databases through any sort of quality

assurance process investigation. This resulted in erroneous retail motor fuels sales facility

totals for certain individual states (as compared to corresponding 2002 Census numbers). It is possible that in some states multiple facility identification numbers (used in this anal ysis to identify unique facilities) have been assigned to individual sites. Facility identification numbers should be further refined and clarified as to what exactly they represent.

 Other general drawbacks of the databases include missing records, and the fact that industry sector categories used by the states agencies are limited and inconsistent across all states.

 E 2 

### In c. could not check the other six industry sectors against the 2002 Census on a state

- by

- state basis. (The Retail Motor Fuels Sales sector can be checked because of the fact that virtuall y all establishments in this sector have one or more underground storage tanks. The state database numbers can therefore be compared to the Census numbers on a one

- to

- one basis.)