Twice a year the US EPA publishes UST performance measures of all the states territories and tribes. How did your agency, state, or region do? Is UST compliance up? Are new leakers down? Do more operators have pollution liability insurance? Is operator training mostly a common thing? And how are we doing on those monthly walk-through inspections?
Get the full report here Semiannual Report Of UST Performance Measures
End Of Fiscal Year 2021 (October 1, 2020 – September 30, 2021)
National snapshot looks good
86.6% Class A and B operator training requirements
88.4% Financial responsibility requirements
77.6% Walk through requirements
And while these numbers may look impressive, here are a few things to consider:
- These are national averages, so some states rated very high and some states rated kind of low.
- A number of states had not begun reporting their rates and therefore you’ll see a number of not applicables or NAs.
- We did see 99-100% scores. Is that really possible?
- Theoretically each state should have inspected about a third of their tank population each year and therefore should be reasonably representative of each of the compliance targets. But if, for instance, the one-third was mostly small operators, you’d expect the numbers to be lower.
- You will notice that class C operator certification is not reported on. What’s up with that?
- Compliance rates are noticeably lower when it comes to states just starting to implement the “new” EPA regulations like more detailed testing of prevention equipment. That is to be expected.
- If training compliance is high (86.6%), shouldn’t walkthrough inspections be better than 77.6%? We would think training about doing inspections would make the inspection compliance rates higher. Asking conversationally.
- We’d like to know more about what compliance rates for UST operator training look like state to state: Do inspectors look at each certificate? Verify the trainer is approved? Check dates on certificates? Quiz operators based on what they should have learned?
What are your thoughts? Do these numbers make sense? Are there better compliance questions to ask or better ways to measure our national UST success?
