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State of the Nation: UST Compliance and Training - UST Training

April 5, 2012

The US EPA periodically publishes a list of states and how well they are achieving significant operational compliance, or SOC. In other words, what percent of all the tanks in each state are in compliance with release detection, spill/overfill prevention and corrosion protection requirements.
How does your state compare to others?

Region / State % in Compliance with Spill/ Overfill/Corrosion % in Compliance with Release Detection % in Compliance with Both
ONE
*CT 86% 82% 76%
MA **DNA **DNA **DNA
ME 80% 68% 62%
NH 69% 71% 51%
*RI 81% 73% 62%
*VT 79% 81% 74%
SUBTOTAL 80% 77% 68%
TWO
NJ 94% 92% 87%
NY 87% 77% 72%
PR 45% 38% 36%
VI 83% 87% 85%
SUBTOTAL 85% 78% 74%
THREE
DC 81% 83% 70%
DE 84% 81% 74%
MD 97% 98% 94%
PA 92% 85% 79%
VA 79% 69% 61%
WV 77% 70% 63%
SUBTOTAL 87% 80% 73%
FOUR
AL 90% 78% 74%
FL 98% 79% 78%
GA 87% 73% 68%
KY 70% 72% 57%
MS 77% 76% 65%
NC 81% 78% 73%
SC 87% 87% 78%
TN 85% 81% 75%
SUBTOTAL 86% 78% 72%
FIVE
*IL 76% 71% 57%
IN 77% 85% 74%
MI 80% 57% 51%
MN 73% 78% 67%
OH 87% 66% 63%
*WI 86% 77% 69%
SUBTOTAL 80% 71% 62%
SIX
AR 66% 72% 56%
LA 72% 83% 65%
NM 72% 81% 64%
OK 83% 86% 76%
TX 91% 88% 84%
SUBTOTAL 84% 85% 77
SEVEN
IA 91% 87% 83%
KS 62% 93% 58%
MO 88% 93% 84%
NE 77% 64% 54%
SUBTOTAL 81% 85% 71%
EIGHT
CO 83% 77% 74%
MT 97% 90% 87%
ND 89% 91% 83%
SD 76% 79% 65%
UT 83% 81% 71%
WY 96% 98% 93%
SUBTOTAL 86% 83% 77%
NINE
AS **DNA **DNA **DNA
AZ 90% 89% 86%
CA 78% 85% 70%
CNMI 100% 100% 100%
GU 83% 80% 80%
HI 98% 92% 90%
NV 88% 87% 78%
SUBTOTAL 81% 86% 74%
TEN
AK 87% 82% 74%
*ID 77% 71% 58%
OR 93% 90% 87%
WA 84% 76% 67%
SUBTOTAL 85% 79% 72%
INDIAN COUNTRY
REGION 1 **DNA **DNA **DNA
REGION 2 74% 63% 52%
REGION 3 **NA **NA **NA
REGION 4 **DNA **DNA **DNA
REGION 5 56% 59% 41%
REGION 6 88% 78% 74%
REGION 7 73% 73% 66%
REGION 8 83% 94% 80%
REGION 9 89% 84% 74%
REGION 10 72% 74% 59%
SUBTOTAL 78% 78% 65%
NATIONAL TOTAL
TOTAL 83.7% 79.1% 71.3%

* States with stricter guidelines

 

* States with stricter guidelines     ** Data Not Available

A few disclaimers

  • Some states did not provide data.
  • Some states, indicated on the table with asterisks, have stricter compliance than other states, so lower numbers may indicate tougher measuring sticks.

A few observations

  • The national average for overall compliance for states, territories and tribes in 71%. Seven out of 10 UST systems are in significant compliance.
  • Highest compliance: Maryland (94%)
  • Lowest compliance: Puerto Rico (36%)

But the real questions are:

How will operator training affect these numbers?

Just for fun, we looked at four states that have had training rules in place for a number of years and compared the SOC numbers before training was required started to today.

How many years of operator training are required to show significant increase in compliance?

 

If you look at the four states, it appears that a few years may not be enough:

 

 

 

 

 

 

 

 

 

 

State Years Underway % Change in Compliance

  • Oregon 7 28%
  • Colorado 2.5 3%
  • Kansas 4 -8% (not sure what happened here)
  • California 6.5 18%

So either it takes a number of years for training to increase compliance significantly, or perhaps the compliance numbers have to be low to begin with in order for the maximum effect to be realized. Stay tuned for more guesses.

Is all training created equal?

 

Each of the four states above approach training in different ways. There is no one silver bullet method of training. How did each of the four states approach it?

State Methods

  • Oregon Private funded, all live classes, multiple trainers, but one principle trainer
    (us, of course!)
  • Colorado Private funded, live and online classes, multiple trainers
    (we trained about 25% of the state online)
  • California ICC certification exam only
    (private trainers not allowed)
  • Kansas State funded, live classes, one vendor
    (we did the first dozen live classes)

Is it possible that operator training will raise compliance to 100%?

I think we are being realistic without being pessimistic in saying that you probably can never achieve 100% 24 hours a day, 7 days a week, 365 days a year. There are a myriad of reasons for this: staff turnover, weather, system aging, missed violations, just to name a few. This doesn’t mean we shouldn’t be doing our best to raise compliance. But if we can help raise compliance say 15-25% in each state we are in, I’d say we are doing very good.

 

Will operator training make everyone’s life better?

Based on 7 years of experience and data in Oregon, we say yes. Other states may need to collect a few years worth of data to determine whether or not it works. Factors such as how training quality, diversity, and state enforcement will all likely have a bearing on whether it works. We at UST Training like to think good training pays for itself and bad training simple costs.

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