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LUST Task Force Review of National LUST Cleanup Trends (September 2003)
Issue: EPA-OUST is now more interested and open to States' input on achievable UST-cleanups-completed targets. EPA-OUST would like to discuss lower targets that decline over the next five years which provide a more realistic forecast of cleanups-completed-per-year as nationally we strive to complete the last 30% of UST cleanups.
Background: A few years ago, EPA-OUST proposed annual cleanups-completed targets of 18-23K based on the average of recent data reported by the States to EPA. The States (individually and through ASTSWMO) responded that the targets were unrealistically high since difficult cleanups were an increasing percentage of the remaining cleanups to be done. The data submitted semi-annually to EPA has generally been below the EPA-OUST targets and is expected to continue to decline, although there has historically been considerable "noise" in the semi-annual data, probably caused by under-reporting followed by periodic catchup corrections by some of the States. For example, the last several semi-annual cleanups-completed were reported as:
| Report: |
Oct-01 |
Oct-02 |
Oct-03 |
| Semi-annual: |
10195 |
7429 |
6142 |
| Annual: |
19074 |
15769 |
18518 |
EPA has historically reported the cleanups completed as a cumulative total and as a cumulative percentage, which had the effect of smoothing out the noise in the semi-annual and annual data.
The ASTSWMO LUST Task Force and Tanks Subcommittee have provided feedback to EPA-OUST over the last two years that the 18-23K annual targets were too high on average for the next five years. The historical time-to-closure data indicates that the number of annual cleanups completed will be significantly less than the 18-23K over the next five years and generally decrease over time. Specific numerical replacement targets were not provided by ASTSWMO, but the graphical projections suggest more realistic estimates in the 12-15K range of annual average cleanups completed over the five-year period.
Followup: We agreed to work with EPA to better explain how the model can be used to forecast more realistic targets for future years so that EPA can develop more reasonable targets for GPRA purposes. EPA would like ASTSWMO support for the new targets, when developed, and ideally would like to have a regional breakdown of the new targets.
»Attachment 1: Delaware LUST Data Analysis (91 KB)
»Attachment 2: Cleanups Completed on Contaminated Tank Sites in Oregon (36 KB)
»Review of National Cleanup Trends - Marilyn Hough (374 KB)
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