1 

### MEMORANDUM | 23 January 2009

TO 

### Cho

- Yi Kwan and Timothy Roberts, EPA

FROM 

### Cynthia Manson

, Todd Chamoy

, and Mark Ewen, Industrial Economics , Inc.

SUBJECT 

### Detailed Assessment of UST Universe by Tank Use and Industry Sector

( WA 1

- 25, Task 6 )

U nder the requirements of the Regulatory Flexibility Act (RFA) of 1980, as amended by the Small Business Regulatory Enforcement Fairness Act of 1996 (SBREFA) and
Executive Order (EO) 13272, entitled “ Proper Consideration of Small Entities in Agency

Rulemaki ng, ” agencies must consider the potential impact of regulations on small businesses, small governmental jurisdictions, and small organizations during the development of their rules. EPA’s Office of Underground Storage Tanks (OUST) is currently exploring th e possibility of revising existing regulations associated with certain types of underground storage tank (UST) systems and equipment. This memo randum presents estimates of the number of facilities and tanks

, and the purposes of those tanks

, for informing f

uture small business regulatory analyses

.

This memo classif

ies the universe of USTs into the following categories:

Service station tanks;

Airport hydrant systems;

Emergency generator tanks;

Field

- constructed tanks;

Non

- retail refueling tanks; and

Tanks storing substances other than fuel.

We will also include a discussion of USTs found on Tribal lands, including privately

owned USTs as well as those owned by Tribal governments.

This section describes the regulated universe of USTs

. W e first distribute the known USTs by type or purpose of tank using two possible methodologies that provide a range

of values

. Next, we examine whether data on the contents of the tanks will help further refine these estimates. Finally, we conclude with a d iscussion of the industries using tanks

on Tribal lands.

TYPES AND PURPOSES O F UST S


### Potential OUST regulatory revisions may affect s ix general categories of USTs: INTRODUCTION AND

BACKGROUND

THE UST UNIVERSE2 

### Tanks storing fuel at retail service (i.e., gas) stations;

Tanks (both storage tanks and hydr ants) that are part of stationary airport hydrant refueling systems;

Field

- constructed tanks;

Tanks storing fuel to provide emergency generator support, including emergenc y tanks at nuclear power plants;

Non

- retail t anks storin g fuel for fleet owners; and

Tanks storing substances other than fuel (e.g., used oil or hazardous substances ).

According to EPA data, a pproximately 630,000 tanks were in active use or temporarily

closed at the end of fiscal year 2007, the latest year for which we have data

. 1 

### To distr ibute this total across the six categories we rely primarily on two previous research efforts. In the first analysis, IEc, in conjunction with PCCI, estimated the state

- level distribution of USTs based on data from the Energy Information Administration (EIA), the EPA, and

other sources

. 2 

### Separately, E 2 

### , Incorporated

, analyzed state databases to determine the

national

- level distribution of tanks by industry. 3 

### We fur ther refine these analyses to include more specific state

- level data where available and to distribute non

- service station tanks among their various uses.

Exhibit 1 list s our best estimates of tanks distributed by use derived from the original

PCCI and E 2 

### methodologies. Both of these analyses indicate that motor fuel retailers account for the majority of tanks in the United States, although a considerable discrepancy exists between the two estimates. We have reliable estimates of t he number of airport hydr ant refueling systems and field constructed tanks from the Federal Aviation Administration (FAA) and the Defense Energy Support Center (DESC). However, it appears that most

, if not all

, airport hydrant refueli ng tanks are above ground storage
tanks; theref

ore, we do not consider these tanks further in this memo. 4 

### We rely on state databases to estimate the number of emergency generator tanks and non

- fuel tanks, and we assume the remaining tanks are non

- retail tanks used to provide fuel for fleet vehicles
(e. g., government

- owned vehicles, car dealerships, school bus operators).

1 EPA, “FY2007 End

- of

- Year Activity Report,” December 5, 2007, as viewed at http://www.epa.gov/oust/cat/ca_07_34.pdf

on December 18, 2008.

2 See Industrial Economics, “Preliminary Assessment and Scoping of Data Related to Potential Revisions to the UST

Regu lations; Tasks 2

- 4, Work Assignment 1

- 25,” November 20 , 2008, and appendices.

3 See E 2 , Incorporated, “Delivery Prohibition

- Draft Preliminary Analyses,” December 18, 2006.

4 See Industrial Economics, “Preliminary Assessment and Scoping of Data Related to Potential Revisions to the UST

Regulations; Tasks 2

- 4, Work Assignment 1

- 25,” November 20 , 2008, Appendix A, p.9.3 EXHIBIT 1 DISTRIBUTION OF TANK S BY USE

USE CATEGORY NUMBER OF TANKS (MODIFIED PCCI METHODOLOGY) NUMBER OF TANKS (MODIFIED E 2 METHODOLOGY)

Service Station Tanks 430,144 1 482,318 8

Field

- Constructed Tanks (FCTs) 2 239 239

Nuclear Emergency Generator Tanks (EGTs) 3 104 104

Other Emergency Generator Tanks (EGTs) 18,925 4 18,538 9

Other (Non

- fuel) Tanks 25,040 5 23,736 10

Non

- R etail F leet Refueling Tanks 6 155,414 104,931

Total Active USTs 7 629,866 629,866

Notes:

1. Equal to 2.65 times the number of service stations reported by the EIA and other sources, adjusted downwards in states where that value would exceed the total number of tanks. Also adjusted for more precise state data available in state and Tribal land UST
databases.

2. Industrial Economics, “Preliminary Assessment and Scoping of Data Related to Potential Revisions to the UST Regulations; Tasks 2

- 4, Work Assignment 1

- 25,” November
20 , 2008, Appendix A.

3. Industrial Eco nomics, “Preliminary Assessment and Scoping of Data Related to Potential Revisions to the UST Regulations; Tasks 2

- 4, Work Assignment 1

- 25,” November
20 , 2008, Appendix A.

4. Equal to 3 percent of total tanks, based on weighted average in databases from Florida, Massachusetts, Missouri, and Wisconsin, except in several states where there are not enough tanks to fill the remaining categories.

5. Equal to 4 percent of total tanks, except in Iowa , where there are not enough remaining tanks to fill this category, and Alaska, where the state database identified 59 tanks containing used oil.

6. Equal to all unaccounted

- for tanks after calculating other values.

7. EPA, “FY2007 End

- of

- Year Activity Report”.

8. Equal to 3.13 times the number of service stations reported by the EIA and other sources, adjusted downwards in states where that value would exceed the total number of tanks. Also adjusted for more precise state data available in state and Tri bal land UST
databases.

9. Equal to 3 percent of total tanks, based on weighted average in databases from Florida, Massachusetts, Missouri, and Wisconsin, except in several states where there are not enough tanks to fill the remaining categories.

10. Equal to 4 percent of total tanks, except in several states where there are not enough tanks to fill the remaining categories, and Alaska, where the state database identified 59 tanks containing used oil.



### T he major difference between the modified PCCI an d modified E 2 

### methodologies shown

in Exhibit 1 is the assumed number of tanks per service station. The estimated number of service station tanks under the PCCI methodology assumes the default number of tanks per service station is 2.65, whereas the modifi ed E 2 

### methodology assumes the default number of tanks per service station is 3.13. Note that this results in approximately 52,000 additional tanks assigned to service stations under the modified E 2 

### methodology , most of which were assigned to fleet refueling tanks under the modified PCCI methodology

. For

a breakdown of the distribution of tanks by state under each methodology , see Appendi x
A

. 5

5 N ote that under the modified E 2 methodology, two states (A labama and Nevada) result in no tanks being assigned to either

the fleet refueling or non

- fuel categories . Furthermore, for two additional states (South Carolina and Washington) , no tanks

are assigned t o the fleet refueling category

.4 

### As the results show, a number o f differences exist between the fig ures, and certain estimates have considerable uncertainty. We discuss these issues below, including: (1) the number of tanks at motor fuel retailers; (2) the number of non

- retail fleet

- refueling tanks; (3) the number of emergency generator tanks; and (4) o ther non

- fuel tanks.

Tanks at Motor Fuel Retailers 

### The number of tanks at motor fuel retailers is an estimate with considerable uncertainty. According to EPA’s June 2000 “ Report to Congress on a Compliance Plan for the Underground Storage Tank Program, ” fa cilities with tanks have an average of 2.65 tanks

per facility

. 6 

### However, a more recent investigation of state databases by E 2 

### shows an average of 2.87 tanks per facility , with retail gas stations specifically having 3.13 tanks per facility

. 7 

### Finally, a co mparison of the state data in EPA’s “ FY2007 End

- of

- Year Activity Report ” and data on the number of service stations in each state from the Energy

Information Administration (EIA) shows that in many states there must be less than 2.65 tanks per service stat ion, as the total number of active USTs in all sectors is less than 2.65

times the number of service stations. 8



### T he estimated number of gas stations under the E 2 

### analysis accounted for 526,000 tanks

in 2006

, which we can adjust downward to approximately 514,000 tanks to account for service stations closing in 2007

. U sing the EPA average of 2.65 tanks per facility ( except in states where the number of tanks per facility is obviously lower, as discussed above ),
however, IEc and PCCI derive d an estimate of 427,500 tanks at service stations. (A

detailed derivation of this estimate is described in a prior memorandum. 9 

### ) The actual figure is likely somewhere in between. In Exhibit 1 , we further refine the estimates with more precise data from states that publish their UST databases. In addition, we apply the

E 2 

### estimated average of 3.13 tanks per service station on a state

- by

- state basis, adjusting

downward in states where the total number of tanks is less than 3.13 times the number of

service statio ns. As a result, we estimate that the number of tanks at motor fuel retailers range approximately between 430,100 and 482,300.

Non

- Retail Fleet Refueling Tanks



### Further evidence on the distribution of non

- service station tanks comes from t he Steel

Tank Ins titute , who, in 2000, estimated that fleets accounted for just four percent of new

UST installations. 10 

### However, they further estimate that “ institutions ” (e.g., universities and hospitals) account for six percent of installations

, and government account for another six percent. These sectors likely include a mix of refueling stations for vehicles and emergency generator tanks. In general, the Steel Tank Institute observes that, due to EPA regulations and clean

- up costs associated with UST leaks, non

- retai l service station

6 EPA, “Report to Con gress on a Compliance Plan for the Underground Storage Tank Program,” June 2000, as viewed at

http://www.epa.gov/OUST/pubs/rtc_0600.pdf on December 18, 2008, p.38.

7 E 2 , Incorporated, “Delivery Prohibition

- Draft Preliminary Analyses,” December 18, 2006.

8 Industrial Economics, “Preliminary Assessment and Scoping of Data Related to Potential Revisions to the UST Regulations;

Tasks 2

- 4, Work Assignment 1

- 25,” November 10, 2008, Appendix A.

9 Basically, the number of service stations is derived from EIA data and other sources for non

- state territories. This value is

multiplied by 2.65 and compared to the total number of tanks reported in EPA’s “FY2007 End

- of

- Year Activity Report.” If the

multiplication results in too many tanks, the rate is adjusted down to e ither 2.0 or 1.0 such that service stations no longer

account for more than the total. See Industrial Economics, “Preliminary Assessment and Scoping of Data Related to Potential

Revisions to the UST Regulations; Tasks 2

- 4, Work Assignment 1

- 25,” November 2 0, 2008, Appendix A.

10 Geyer, Wayne, “UST History,” 2000, as viewed at

https://www.steeltank.com/LinkClick.aspx?fileticket=GLBrj44tMj0%3D&tabid=108&mid=502 on November 23, 2008, p. 12.

Note the Steel Tank Institute does not define or otherwise specify what types of businesses are included in the category

“fleet” in their statistics.5 

### facilit ies that need tanks favor above ground storage tanks. 11 

### Because we do not have

reliable estimates of non

- retail fleet refueling tanks, and because we believe these tanks account for the vast majority of tanks not otherwise specified in this analysis, we assign all remaining tanks after calculating the other categories to fleet refueling in order for the

total to match the EPA’s “FY2007 End

- of

- Year Activity Report”.

Emergency Generator Tanks



### A necdotal evidence from the Hill Company, a large installer of USTs in Texas, suggests that up to 80 percent of non

- retail service station tanks are part of emergency

generators. 12 

### However, an examination of state databases suggests a much lower estimate.

In Massachusetts, only two percent (243 of 11,876) of active USTs in the state database are designated as emergency generator tanks, although over 18 percent do not have a usage designated. 13 

### Wisconsin identifies a similar percentage of tanks as generators ( 2 34
of 12,354, or 1.9 percent), and while the state does not have any unidentified tanks, another 6.5 percent of tanks belong to the broad categories “ Industrial ” and

“ Mercantile/Commercial ”

. 14 

### Missouri identifies approximately 2.5 percent (215 of 8,419)

of active tanks as emergency generators. 15 

### Finally, while Florida ’s database does not explicitly identify tanks as emergency generator tanks, according to the tank contents

field

, 3.8 percent (1,130 of 29,028) of tanks have the value “ Emergency Generator

Diese l ” listed as the fuel

. 16 

### As a result, for the numbers shown in Exhibit 1, up to three percent of the total tanks in a state are categorized as emergency generator tanks based on the weighted average rate in the four states reporting this distinction. While four states are not enough to provide statistical significance in our national estimates, these states represent several regions of the United States, have differences in regulation for emergency generators, and present a tight range of estimates of emergency generator tanks, suggesting that it may be reasonable to assume that these numbers are representative of national patterns

.

Other Tanks



### Exhibit 1 reprint s the estimates of field

- constructed tanks and emergency generator tanks at nuclear power pla nts from our previous research. 17 

### We believe these estimates are derived from reliable sources, but they nonetheless represent a small fraction of tanks , so
these uses did not merit further investigation

. Finally, up to 4 percent of tanks are designated as tanks for storage of non

- fuel products. 18

TANK CONTENTS



### T o further improve the precision of our estimates above, we investigated the types of

fuels or other chemicals contained in the state databases. This proved to be less helpful than we anticipated due t o the dual

- use nature of diesel (i.e., diesel is a popular fuel for

both trucks and emergency generators). Alaska is the only state where tank content data compelled us to adjust our results , due to the relatively high number of tanks storing used

11 Geyer, Wayne, “UST History,” 2000, as viewed at

https://www.steeltank.com/LinkClick.aspx?fileticket=GLBrj44tMj0%3D&tabid=108&mid=502 on November 23, 2008, p. 10.

12 Personal communication with Tommy Dillard, Estimator/Project Coordinator, the Hill Company, on November 24, 2008.

13 Massachusetts’ UST database is available at http://www.mass.gov/Eeops/docs/dfs/osfm/ust/ust.exe

14 Wisconsin’s UST database is available at http://apps.commerce.state.wi.us/ers/ER

- EN

- TankArchive.zip

15 Missouri’s UST database is available at http://www.dnr.mo.gov/env/hwp/tanks/internet.zip

16 Florida’s UST database delivered by email from E 2 via EPA on December 16, 2008.

17 Industrial Economics, “Preliminary Assessment and Scoping of Data Related to Potential Revisions to the UST Regulations;

Tasks 2

- 4, Work Assignment 1

- 25,” November 20 , 2008, Appendix A.

18 E 2 , Incorporated, “Delivery Prohibition

- Draft Preliminary Analyses,” December 18, 2006.6 

### oil. Aft er excluding the 564 tanks positively

- identified as gas station tanks in Alaska, we distribute the remaining tanks by content, shown in Exhibit 2 . Exhibit 2 also presents, for comparison purposes, the values for tank use estimated above.

EXHIBIT 2 NON

- SERVICE STATION TANK S BY CONTENTS IN ALA SKA

TANK CONTENTS TANKS COMMENTS

Diesel 319 Subset of the 524 emergency generator tanks and fleet refueling tanks.

Gasoline 188 Subset of the 489 fleet refueling tanks.

Kerosene 8 Used for jet fuel; included in fleet refueling tanks.

Other 7 Unknown.

Used Oil 59 Exceeds 4% of total tanks; Exhibits 1 and 2 adjusted accordingly.

Source: Alaska state UST database provided by E 2 via EPA.



### Gasoline accounts for 188 tanks, well below the 489 fleet

- refueling tanks identified

earlier. D iesel tanks could be distributed as either fleet refueling tanks or emergency generator tanks such that this does not conflict with our earlier estimates. The used oil tanks, however, exceed four percent of tanks in Alaska; therefore, we adjusted our earlier estimates to account for this higher number. This is the only case where the tank contents reported in the 13 state databases informed our earlier estimates.

UST S ON TRIBAL LANDS 

### In general, OUST delegates UST activities to state

- level environmental agencies.
However, EPA is the agency responsible for implementing regulations on Tribal lands.
Therefore, EPA is interested in specifically characterizing USTs located on Tribal lands. In addition, Tribal governme nts are typically small entities, so Tribal government

- owned businesses must be considered under RFA/SBREFA. This section provides an estimate of

the number of tanks on Tribal lands and a discussion of the industries and sectors to which these tanks belong.

In 2007, OUST produced a report to Congress entitled, “ Report to Congress on Implementing and Enforcing the Underground Storage Tank Program in Indian Country. ” In the report, they established that 2,658 active tanks existed o n Tribal lands at that

time. 19 

### This estimate differs only slightly from the 2,665 tanks estimated in the “ FY2 007

End

- of

- Year Activity Report ”

. We assume the difference is due to the specific date of

estimation. Exhibit 3 lists the number of tanks in each in dustry sector as reported in the database. Note that, like the rest of the United States, the majority of USTs belong to gas

stations.

19 EPA Office of Underground Storage Tanks, “Report to Congress on Implementing and Enforcing the Underground Storage

Tank Program in Indian Country,” August 2007, p.28.7 EXHIBIT 3 DISTRIBUTION OF TANK S BY SECTOR ON TRIBA L LANDS

SECTOR NUMBER OF TANKS

Airlines & Aircraft Owners 7

Auto Dealership 6

Commercial 47

Contractor 2

Farm 18

Federal Military 18

Federal Non

- Military 54

Gas Station 1

, 653

Industrial 15

State/ Local Government 120

Other/Unknown 1 29

Petroleum Distributor 9

Private 9

Residential 2

School 14

Truck/Transporter 6

Utilities 3

Total 2

, 112

Source: Database of USTs on Tribal lands provided by EPA.



### Not surprisingly, the distribution of tanks by sector in Exhibit 3 is similar to the types of

industries that use USTs in the rest of the United States, although there appear to be higher levels of government

- owned tanks than elsewhere. Two more interesting pieces of data extracted from the database are that only 35 tanks are identified as emergency generator tanks, and 724 tanks are identified as tribal

- owned.

Of the 35 emergency generator tanks, only 9 are not owned by the Federal government.

Based on conversations with two EPA regional inspecto rs representing Regions 8 and 9,

we do not believe this figure is reliable. We spoke with EPA official s in Region 8 ( Lisa

Luebke ) and in Region 9 ( Mary Keil ) to hear their experiences inspecting tanks at

businesses on Tribal lands. Ms. Luebke confirmed that the vast majority of tanks on Tribal lands in her region were found at gas stations. Ms. Keil was ab le to provide additional detail on industries, as her region includes the Navajo Nation, the largest tribe

in the United States , which accordingly accounts for the largest number and variety of

tanks . She listed several applications that are also commonly found outside of Indian Country, including bus depots at schools, emergency generators at hospitals, and Tribal government fleet refueling sites. In addition, she identified casinos and minin g companies

as firms that she sus pects are over

- represented on Tribal lands. In her experience, casinos all have emergency generator facilities , and many also operate their own retail gas

stations. While the database identified numerous casino

- operated gas stations, it contains only three casino

- owned emergency genera tor tanks. Unless the remaining casinos use aboveground storage tanks, this is a low estimate.8 

### Thus, other than the existence of casinos and natural resource extraction industries, we are unable to identify any substantial differences between the types of businesses owning USTs on Tribal lands and businesses in the rest of the United States. In addition, a large number of tanks (approximately one

- third) are owned by Tribal governments, most of

which are small entities.

The number and uses of tanks described in this memo are based on various sources. While the total number of active, regulated USTs is relatively precise, we have encountered several conflicting estimates of how those USTs are distributed among

ind ustries and uses. Therefore, we present two estimates of these distributions, with 8.3 percent of the tanks redistributed between the estimates . However, the actual number of tanks of a particular type could be higher or lower than the figures presented in this

memo.

The data presented in this m emo on tanks on Tribal lands have several areas of uncertainty as well . Most significantly, three of the EPA regions representing 14 states and two territories are not included in this analysis

.

NEXT STEPS 

### This analysis provides a general estimate of the number and type of USTs currently in use, and the general distribution of UST use across industrial sectors. While the priorities for refining this analysis will be determined in part by the specific regula tory options under consideration, the following options may provide useful insights:

Additional data on Tribal ownership patterns: The data collected to date do not address all tanks on Tribal lands and rely on limited contacts with EPA regional staff. I f Tribal ownership or sector distribution of tanks on tribal lands is central to EPA’s rulemaking effort, collection of additional data on tank
ownership and use from remaining regions and Tribes, as well as supplemental data from the regions already conta cted, could be useful.

Detailed analysis of specific sectors or tank applications: This analysis provides general information on the industrial sectors and uses of USTs; if EPA determines that a specific sector (e.g., agriculture, health care, or local

go v ernment) requires consideration to address small business impacts or to determine more about how tanks are used and distributed among facilities of
different sizes, then additional sector

- specific research to augment the general state data may be useful.

Refinement of estimate of retail gasoline establishments and tank use: This analysis identifies discrepancies in the number of tanks and establishments

associated with the retail sale of motor fuel. If EPA determines that the uncertainty associated with retail motor fuel tank usage would have a significant impact on estimates of total regulatory cost, then refining this set of estimates may be useful. At a minimum, updating the estimate to reflect 2007 Economic Census data (when available) is potentially useful because it will reflect more recent gasoline sales figures and facility ownership patterns. KEY SOURCES OF

UNCERTAINTY AND NEX T

STEPS9 APPENDIX A

EXHIBIT A

- 1 DISTRIBUTION OF TANK S BY STATE AND USE (MODIF IED PCCI METHODOLOGY )

STATE OR
TERRITORY SERVICE

STATION
TANKS 1 FCT 2 NUCLEAR
EGT 3 OTHER

EGT 4 NON

- RETAIL

FLEET
REFUELING
TANKS 5 OTHER

(NON

- FUEL)
TANKS 6 TOTAL

ACTIVE
USTS 7

Alabama 16,430 0 5 567 1,127 756 18,885

Alaska 564 4 0 35 489 59 1,151

American Samoa 11 0 0 1 3 1 16

Arizona 5,300 0 3 211 1,208 281 7,003

Arkansas 7,298 0 2 284 1,492 379 9,455

California 26,421 87 4 1,125 8,362 1,500 37,498

Colorado 5,785 0 0 239 1,607 318 7,949

Connecticut 4,129 0 2 326 5,958 434 10,849

Delaware 1,131 0 0 45 232 59 1,467

District of Columbia 355 0 0 21 292 28 696

Florida 24,552 7 5 866 2,277 1,155 28,862

Georgia 23,120 0 4 902 4,821 1,202 30,049

Guam 111 33 0 9 103 11 267

Hawaii 912 24 0 51 637 68 1,692

Idaho 2,094 0 0 100 976 133 3,302

Illinois 13,250 0 11 678 7,732 903 22,574

Indiana 6,349 0 0 416 6,521 554 13,840

Iowa 7,046 0 1 222 0 103 7,372

Kansas 5,600 0 1 210 877 279 6,967

Kentucky 9,540 0 0 373 2,005 497 12,415

Louisiana 9,673 0 2 379 2,043 505 12,601

Maine 2,746 0 0 96 229 128 3,199

Maryland 5,883 0 2 278 2,710 370 9,243

Massachusetts 7,925 0 1 331 2,323 441 11,021

Michigan 13,208 0 4 605 5,531 807 20,155

Minnesota 9,990 0 3 436 3,521 582 14,532

Mississippi 7,100 0 1 264 1,065 352 8,782

Missouri 8,356 0 1 309 1,190 411 10,267

Montana 1,060 0 0 99 1,999 132 3,290

Nebraska 3,938 0 2 208 2,478 277 6,903

Nevada 3,098 0 0 111 313 147 3,669

New Hampshire 1,700 0 1 92 1,147 123 3,063

New Jersey 8,748 0 4 505 6,899 674 16,830

New Mexico 3,101 0 0 121 644 162 4,027

New York 17,755 0 6 867 9,113 1,156 28,897

North Carolina 18,306 0 5 862 8,383 1,149 28,705

North Dakota 1,844 0 0 65 167 87 2,16310 STATE OR
TERRITORY SERVICE

STATION
TANKS 1 FCT 2 NUCLEAR
EGT 3 OTHER

EGT 4 NON

- RETAIL

FLEET
REFUELING
TANKS 5 OTHER

(NON

- FUEL)
TANKS 6 TOTAL

ACTIVE
USTS 7

Northern Mariana
Islands 48 0 0 3 14 3 68

Ohio 13,078 0 2 690 8,308 920 22,998

Oklahoma 8,613 0 0 334 1,711 445 11,102

Oregon 4,494 0 0 184 1,189 245 6,112

Pennsylvania 12,463 0 9 741 10,476 988 24,677

Puerto Rico 3,146 0 0 137 1,094 183 4,560

Rhode Island 999 0 0 49 513 66 1,627

South Carolina 9,744 5 7 360 1,385 480 11,981

South Dakota 2,790 2 0 91 17 121 3,021

Tennessee 12,104 0 3 514 3,799 685 17,105

Texas 36,464 4 4 1,649 14,627 2,198 54,946

US Virgin Islands 98 0 0 5 35 6 144

Utah 2,981 0 0 121 761 161 4,024

Vermont 1,712 0 1 93 1,138 123 3,067

Virginia 15,189 23 4 618 3,942 824 20,600

Washington 8,098 50 1 304 1,254 405 10,112

West Virginia 3,445 0 0 171 1,852 228 5,696

Wisconsin 10,641 0 3 412 2,120 549 13,725

Wyoming 1,518 0 0 60 322 80 1,980

Tribal Lands 2,086 0 0 80 392 107 2,665

Totals 430,144 239 104 18,925 155,4 14 25,0 40 629,866

1. Equal to 2.65 times the number of service stations reported by the EIA and other sources, adjusted downwards in states where that value would exceed the total number of tanks. Also adjusted for more precise state data available in state and Tribal land UST databases.

2. Industrial Economics, “Preliminary Assessment and Scoping of Data Related to Potential Revisions to the UST Regulations; Tasks 2

- 4, Work Assignment 1

- 25,” November 20 , 2008, Appendix A.

3. Industrial Economics, “Preliminary Assessment and Scoping of Data Related to Potential Revisions to the UST Regulations; Tasks 2

- 4, Work Assignment 1

- 25,” No vember 20 , 2008, Appendix A.

4. Equal to 3 percent of total tanks, based on weighted average in databases from Florida, Massachusetts, Missouri, and Wisconsin.

5. Equal to all unaccounted

- for tanks after calculating other values.

6. Equal to 4 percent of total tanks, except in Iowa, where there are not enough remaining tanks to fill this category, and Alaska, where the state database identified 59 tanks containing used oil.

7. EPA, “FY2007 End

- of

- Year Activity Report”.11 EXHIBIT A

- 2 DI STRIBUTION OF TANKS BY STATE AND USE (MODIF IED E 2 METHODOLOGY)

STATE OR
TERRITORY SERVICE

STATION
TANKS 1 FCT 2 NUCLEAR
EGT 3 OTHER

EGT 4 NON

- RETAIL

FLEET
REFUELING
TANKS 5 OTHER

(NON

- FUEL)
TANKS 6 TOTAL

ACTIVE
USTS 7

Alabama 18,600 0 5 280 0 0 18,885

Alaska 564 4 0 35 489 59 1,151

American Samoa 13 0 0 1 1 1 16

Arizona 6,260 0 3 211 248 281 7,003

Arkansas 8,620 0 2 284 170 379 9,455

California 31,206 87 4 1,125 3,576 1,500 37,498

Colorado 6,833 0 0 239 559 318 7,949

Connecticut 4,877 0 2 326 5,210 434 10,849

Delaware 1,131 0 0 45 232 59 1,467

District of Columbia 419 0 0 21 228 28 696

Florida 24,552 7 5 866 2,277 1,155 28,862

Georgia 23,120 0 4 902 4,821 1,202 30,049

Guam 131 33 0 9 83 11 267

Hawaii 1,077 24 0 51 472 68 1,692

Idaho 2,473 0 0 100 596 133 3,302

Illinois 15,650 0 11 678 5,332 903 22,574

Indiana 7,499 0 0 416 5,371 554 13,840

Iowa 5,318 0 1 222 1,536 295 7,372

Kansas 5,600 0 1 210 877 279 6,967

Kentucky 11,268 0 0 373 277 497 12,415

Louisiana 11,425 0 2 379 291 505 12,601

Maine 2,746 0 0 96 229 128 3,199

Maryland 5,883 0 2 278 2,710 370 9,243

Massachusetts 7,925 0 1 331 2,323 441 11,021

Michigan 15,600 0 4 605 3,139 807 20,155

Minnesota 9,990 0 3 436 3,521 582 14,532

Mississippi 7,100 0 1 264 1,065 352 8,782

Missouri 8,356 0 1 309 1,190 411 10,267

Montana 1,252 0 0 99 1,807 132 3,290

Nebraska 4,651 0 2 208 1,765 277 6,903

Nevada 3,658 0 0 11 0 0 3,669

New Hampshire 1,700 0 1 92 1,147 123 3,063

New Jersey 10,332 0 4 505 5,315 674 16,830

New Mexico 3,662 0 0 121 82 162 4,027

New York 20,971 0 6 867 5,897 1,156 28,897

North Carolina 21,622 0 5 862 5,067 1,149 28,705

North Dakota 1,844 0 0 65 167 87 2,16312 STATE OR
TERRITORY SERVICE

STATION
TANKS 1 FCT 2 NUCLEAR
EGT 3 OTHER

EGT 4 NON

- RETAIL

FLEET
REFUELING
TANKS 5 OTHER

(NON

- FUEL)
TANKS 6 TOTAL

ACTIVE
USTS 7

Northern Mariana
Islands 56 0 0 3 6 3 68

Ohio 15,447 0 2 690 5,939 920 22,998

Oklahoma 10,173 0 0 334 151 445 11,102

Oregon 5,308 0 0 184 375 245 6,112

Pennsylvania 14,720 0 9 741 8,219 988 24,677

Puerto Rico 3,715 0 0 137 525 183 4,560

Rhode Island 1,180 0 0 49 332 66 1,627

South Carolina 11,509 5 7 360 0 100 11,981

South Dakota 2,106 2 0 91 701 121 3,021

Tennessee 12,104 0 3 514 3,799 685 17,105

Texas 43,069 4 4 1,649 8,022 2,198 54,946

US Virgin Islands 116 0 0 5 17 6 144

Utah 3,521 0 0 121 221 161 4,024

Vermont 2,022 0 1 93 828 123 3,067

Virginia 15,189 23 4 618 3,942 824 20,600

Washington 9,565 50 1 304 0 192 10,112

West Virginia 4,069 0 0 171 1,228 228 5,696

Wisconsin 10,641 0 3 412 2,120 549 13,725

Wyoming 1,793 0 0 60 47 80 1,980

Tribal Lands 2,086 0 0 80 392 107 2,665

Totals 482,318 239 104 18,538 104,931 23,736 629,866

1. Equal to 3.13 times the number of service stations reported by the EIA and other sources, adjusted downwards in states where that value would exceed the total number of tanks. Also adjusted for more precise state data available in state and Tribal land UST databases.

2. In dustrial Economics, “Preliminary Assessment and Scoping of Data Related to Potential Revisions to the UST Regulations; Tasks 2

- 4, Work Assignment 1

- 25,” November 20 , 2008, Appendix A.

3. Industrial Economics, “Preliminary Assessment and Scoping of Data Relate d to Potential Revisions to the UST Regulations; Tasks 2

- 4, Work Assignment 1

- 25,” November 20 , 2008, Appendix A.

4. Equal to 3 percent of total tanks, based on weighted average in databases from Florida, Massachusetts, Missouri, and Wisconsin, except in several states where there are not enough tanks to fill the remaining categories.

5. Equal to all unaccounted

- for tanks after calculating other values.

6. Equal to 4 percent of total tanks, except in several states where there are not enough tanks to fill the

re maining categories, and Alaska, where the state database identified 59 tanks containing used oil.

7. EPA, “FY2007 End

- of

- Year Activity Report”.