April 2009 1

Task Order No. 1010

– Subtask A1
- 06C Technical Directive No. 36

Summary of Key Data from State Public Record Postings E2 Inc. compiled available data from 45 state and territory public record postings into an Excel file (Appendi ces 1 through 9 ) and calculated overall totals and percentages from these data. Data on federally

regulated USTs were included in this anal ys is. This report provides a summary of key results and includes the following appendices:
1. General Information 2. Source of Release 3. General Ca

use of Release 4. Cause of Release from Tank 5. Cause of Release from Piping 6. Cause of Release from Dispenser 7. Cause of Release from STP 8. Cause of Release from Delivery 9. Cause of Release from Other
Methods Public record data from the following 1 1 states and territories were not available for this anal ys is: Alaska, American Samoa, Florida, Guam, Iowa, Massachusetts, Nevada, New Mexico, Oklahoma, Puerto Rico, and Wyoming. With available public records, the numbers of USTs and facilities, inspections, compliance, and confirmed releases for each state and territory were compared to values from EPA’s Corrective Action Measures

- Fiscal Year 2008 End of Year Activity Report. In addition, for each state or territory, source and cause information for releases was categoriz ed and analyzed. The following general rules were applied to assign data to source and cause categories:

 The OUST Subject Matter Expert was consulted when source and cause categories provided in public records did not match those included in this analysi s.
 For public records that do not report “unknown” sources and reported a number of confirmed releases greater than the source total, the difference between the number of confirmed releases and the source total was assigned as “unknown” sources.

 All releas es caused b y spills and overfills from tanks were moved to the delivery problem source. Results for General Information (Appendix 1 ) Total and average values for inspections, compliance, and confirmed releases from the public record data are provided in Table 1. Inspection frequency was calculated by

dividing the number of facilities b y the number of inspections; facilities in compliance was calculated by multiplyingApril 2009 2

the number of facilities by the compliance rate; and the release rate was calculated by dividing the number of confirmed releases by the number of USTs

.
Table 1: Total and Average Values from Public Record Analysis Total Number of USTs Total Number of Facilities Average

Number of USTs per Facility Total

Number of Inspections Average

Inspection Frequency Total

Number of Facilities in Compliance Total

Number of Confirmed Releases Average

Release Rate

520,371 190,236 2.74 69,537 2.74 123,529 5,751 1.1 3 % There were some discrepancies between the values in public records and the EPA FY08 Corre ctive Action Measures; overall, these differences were small. The public records for New Jersey and Wisconsin did not include the information needed to complete Appendix 1. Comparison of the number of USTs reported in public records with those from the FY08 Corrective Action Measures revealed that most values were similar between the two reports. The largest difference was for Colorado, which reported 4,469 (56 percent) more USTs on its public record than in the FY08 Corrective Action Measures. This dis crepancy likel y resulted from the reporting periods used in the Colorado public record, which are greater than fiscal ye ar 2008 (up to 20 years). Because of these reporting period issues, the difference between the number of confirmed releases is also si gnificantly different between the Colorado public record (7,016) and the FY08 Corrective Action Measures (164). Because of this difference, the number of confirmed releases reported in Colorado’s public record was not included in this analysis. Several other states (Idaho, Indiana, Louisiana, Maryland, North Carolina, Ohio, and Tennessee) had significant differences between the number of confirmed releases on the two reports. For the number of inspections conducted, there were also several significant di fferences between the public record and FY08 Corrective Action Measures values. The Commonwealth of Northern Mariana Is lands, Idaho, Maine, and New York values differed by greater than 100 percent, although Idaho’s difference is likely the result of a rep orting period difference between the two reports. Differences for Colorado, Rhode Island, and the Virgin Islands were all around 75 percent or greater. Once again, Colorado’s difference is likely a result of reporting period issues. With the exception o f Indiana, differences between the compliance rates in the public record and FY08 Corrective Action Measures were small for all states and territories included in this anal ys is. The Indiana public record reported a combined compliance rate of 93 percent, whereas the FY08 Corrective Action Measures report a combined compliance rate of 65 percent. Results for Source and Cause Information (Appendices 2 through 9 ) Results from combining all public record data indicate that the most prevalent sources of releases are tank (2 6.1 percent), unknown (2 1 .0 percent), other (1 9.1 percent), piping (1 2.0 percent), andApril 2009 3

dispenser (1 1.8 percent) (Table 2). Specific release cause and source data were not available in the California, Commonwealth of Northern Mariana Islands , New Hampshire, and Virgin Islands public records

. Because of the reporting period issues , specific release and cause data from the Colorado public record were not included in this analys is.

Table 2: Total Release Source Results from Public Records Rel ease Source Tank Piping Dispenser STP Delivery Problem Other Unknown
2 6.1 % 1 2.0 % 1 1.8 % 0.9 % 9.1 % 19.1 % 2 1 .0 %
Results from combining all public record data indicate that the most prevalent causes of releases are unknown ( 63.1 percent), corrosion ( 9.2 percent), and physical/mechanical damage ( 8.0 percent) (Table 3). When combined, spill ( 5.5 percent) and overfill ( 7.6 percent) are the causes for 1 3.2 percent of releases reported in the public records.

Table 3: Total Release Cause Results from Public Re cords Release Cause Spill Overfill Phys/Mech Damage Corrosion Install Problem Other Unknown
5.5 % 7.6 % 8.0 % 9.2 % 0.5 % 6 .0 % 63.1 %

The source

- specific release cause percentages for all public records are presented in Table 4. Of known causes, most tank releases are caused b y corrosion (25.8 percent); most piping, dispenser, and STP releases are caused by physical/mechanical damage ( 18.0 , 13.6 , and 4 1.0 percent, respectively); and most delivery problem releases are caused b y spills ( 30.1 percent) or overfi lls ( 58.5 percent).

Table 4: Combined Total Source and Cause Results from Public Records Source Percentage

of Release s Cause

Spill Overfill Phys/Mech

Damage Corrosion Install

Problem Other Unknown
Tank 2 6.1 % 0 .0 % 0 .0 % 9.6 % 25.8 % 0.3 % 7.3 % 5 7.1 % Piping 1 2.0 % 3 .9 % 1 .4 % 18.0 % 9.1 % 1.9 % 4.9 % 60.9 % Dispenser 1 1.8 % 10 .7 % 6.2 % 13.6 % 2.6 % 0.9 % 4.8 % 61.2 % STP 0.9 % 0 .0 % 9.8 % 4 1.0 % 4.9 % 3.3 % 2 1.3 % 19.7 % Delivery Problem 9.1 % 30.1 % 58.5 % 1.7 % 1 .1 % 0 .1 % 2.2 % 6 .2 %
Other 19.1 % 3.5 % 3.8 % 4.4 % 1.4 % 0.2 % 1 0.1 % 76. 6 %