From the Wires
Evidence-Based Management For Leaky Underground Tanks Improves Compliance, Saves Money
By: PR Newswire
Jan. 16, 2013 11:00 AM
MCLEAN, Va., Jan. 16, 2013 /PRNewswire-USNewswire/ -- The first state to apply an innovative system for managing leaky underground petroleum storage tanks nationwide showed that better compliance with federal laws can be achieved at a lower cost, according to a team of risk researchers and state regulators. Leaking storage tanks can result in negative human health and environmental impacts, particularly to drinking water supplies. The study finds that the system could provide a more cost effective way to use dwindling state inspection resources to prevent leaks and their negative human health and environmental impacts.
Richard T. Enander and Ronald N. Gagnon of the Rhode Island Department of Environmental Management (DEM), R. Choudary Hanumara with the University of Rhode Island, and other colleagues conducted the study, "Reducing Drinking Water Supply Chemical Contamination: Risks from Underground Storage Tanks," with funding from the U.S. Environmental Protection Agency's (EPA) National Center for State Innovation. The article is included in the December issue of the journal Risk Analysis, published by the Society for Risk Analysis.
To prevent leaks and protect groundwater resources, the U.S. Energy Policy Act of 2005 mandates that state environmental agencies inspect all UST facilities once every three years.
Many states stretch existing inspection resources to meet the requirement, or they comply at significant expense. As of September 30, 2008, more than 470,000 UST releases were recorded in the United States. To help address the issue, Rhode Island received an EPA State Innovation Grant to conduct a three-year study to evaluate "an alternative UST inspection model and determine whether it could be a cost-effective alternative to facility-by-facility enforcement and inspection and enforcement programs." The approach used a model that had four components, consisting of regulatory assistance, compliance certification using standardized checklists, independent agency inspections, and statistically-based performance measurement. The model was adapted from an Environmental Results Program (ERP) effort developed in Massachusetts.
In applying the ERP approach in Rhode Island, the researchers relied on binary (yes/no) count and descriptive data collected in the form of self-certification checklists and Return-to-Compliance plans that UST facilities submitted to the Department of Environmental Management by June 30, 2005. To assess whether compliance improved throughout the sector, statistical analysis was applied to data collected from a statistically predetermined number of randomly selected facilities that underwent field inspections by DEM regulatory staff at baseline and after certification. Ninety-six facilities were inspected at baseline and 93 post-ERP intervention.
For the analysis, data about 118 environmental compliance indicators were grouped into tables according to their expected utility for measuring UST sector performance improvements in future years. The analyses showed that 41 of the original 118 UST compliance checklist questions could be used for future performance measurement within five compliance categories: tank corrosion protection, tank leak detection, piping leak detection, spill prevention and overfill protection, and groundwater monitoring and tank pad observation wells.
In addition, DEM regulatory staff reviewed historic field inspection checklist data for the 96 baseline and 93 post-intervention random ERP inspections and calculated aggregate values for the percentage of "significant operational compliance" for three standard EPA UST compliance categories. The analysis showed statistically significant improvements in performance over time with point estimates ranging from 19 percent to 22 percent.
"Before conducting the 96 randomized baseline facility inspections in 2004, DEM did not have a clear or reliable picture of historic compliance levels for the industry sector," according to the paper. Using the ERP method, 2004 baseline compliance levels for measurable indicators were found to range from 0 percent to 95 percent, with a median of 76 percent. In addition, "The change or observed improvement in compliance among the post-intervention facilities for 41 measurable indicators" ranged from 22 percent to 100 percent.
An economic analysis compared the costs of Rhode Island's traditional UST inspection program with the ERP approach and found the alternative to have lower costs than the labor-intensive approach mandated by the Energy Policy Act. Overall, the data from Rhode Island and other states that have used ERP for other industry sectors show it can "provide a sound alternative to traditional inspection programs," the authors conclude. The findings and conclusions are solely those of the authors.
Risk Analysis: An International Journal is published by the nonprofit Society for Risk Analysis (SRA). SRA is a multidisciplinary, interdisciplinary, scholarly, international society that provides an open forum for all those who are interested in risk analysis. Risk analysis is broadly defined to include risk assessment, risk characterization, risk communication, risk management, and policy relating to risk, in the context of risks of concern to individuals, to public and private sector organizations, and to society at a local, regional, national, or global level. www.sra.org
Contact: Steve Gibb, 202.422.5425 firstname.lastname@example.org to arrange an interview with the author(s). Note to editors: The complete study is available upon request from Steve Gibb or here: http://onlinelibrary.wiley.com/doi/10.1111/j.1539-6924.2012.01843.x/full
A Letter to the Editor supporting the use of ERP in addressing reductions in government funding by Sarah Weinstein, Deputy Assistant Commissioner, Massachusetts Department of Environmental Protection and Chair of the Northeast Waste Management Officials' Association, also appeared in Risk Analysis in 2012 (Vol. 32, No. 7). The full text of the letter is available here: http://onlinelibrary.wiley.com/doi/10.1111/j.1539-6924.2011.01688.x/full
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SOURCE Society for Risk Analysis
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