Semiannual Report OfUST Performance Measures Mid Fiscal Year 2015 (October 1, 2014 - March 31, 2015) Where does EPA get the performance data? Twice each year, EPA collects data from states and territories regarding underground storage tank (UST) performance measures and makes the data publicly available. EPA directly provides data on work in Indian country, since the Agency implements the program for those sites. This data includes information such as the number of active and closed tanks, releases confirmed, cleanups initiated and completed, facilities in compliance with UST requirements, and inspections. EPA compiles the data and presents it in table format for all states, territories, and Indian country. What are the UST performance measures? The most current definitions for the UST performance measures are available on EPA's website www.epa.gov/oust/cat/camarchv.htm under Definitions. What is in the mid fiscal year (FY) 2015 report? Page UST Corrective Action Measures For Mid FY 2015 Alphabetical By State Within Region 1 National Totals 5 UST National Backlog Graph 6 UST Compliance Measures For Mid FY 2015 7 States With More Stringent SOC Requirements 9 Inspection/Delivery Prohibition Actions For Mid FY 2015 11 How does the UST program's performance at mid FY 2015 compare with its FY 2015 goals and mid FY 2014 performance? Mid FY 2015 UST Program Performance Compare With FY 2015 UST Program Goal Compare With Mid FY 2014 UST Program Performance Completed 5,017 cleanups (including 13 in Indian country) Complete 8,600 or more cleanups, including 30 in Indian country At mid FY 2014, completed 5,084 cleanups (including 13 in Indian country) 71.8 percent significant operational compliance rate Achieve a significant operational compliance rate of 70.5 percent or higher At mid FY 2014, the significant operational compliance rate was 72.1 percent Confirmed 3,378 releases, which is below the midpoint of EPA's goal to decrease confirmed releases Decrease newly-confirmed releases to fewer than 6,965 At mid FY 2014, confirmed 3,007 releases 13.8 percent of confirmed releases at UST facilities remaining to be cleaned up Reduce to 14 percent or less the percent of confirmed releases at UST facilities remaining to be cleaned up At mid FY 2014, reduced to 14.6 percent the percent of confirmed releases at UST facilities remaining to be cleaned up AEPA Office of Underground Storage Tanks, Washington, D.C. 20460 www.epa.gov/oust May 2015 ------- What other highlights are included in the mid FY 2015 report? There are 569,340 active USTs (at approximately 205,000 sites) which are regulated by EPA's UST program Since the 1984 inception of the UST program, 1,827,148 USTs have been properly closed Of the 525,095 releases reported since the beginning of the UST program, 452,847 (or 86.2 percent) have been cleaned up, leaving 72,248 remaining to be cleaned up - From FY 2010 through FY 2013, the UST program saw increased performance in cleaning up and closing releases due in part to a one-time infusion of LUST Recovery Act money 42,073 on-site inspections at federally-regulated UST facilities were conducted between October 2014 and March 2015; of those: - 42,021 were conducted by states, territories, and third-party inspectors - 52 were conducted by EPA and credentialed tribal inspectors in Indian country How are EPA and its partners doing at reducing the backlog of UST releases? Reducing the number of releases remaining to be cleaned up (also known as the backlog) remains a priority for the national UST program. The graphic on page 6 of this report shows that the national UST backlog of releases remaining to be cleaned up has been declining for more than a decade. The rate of releases confirmed has held steady since 2010 at approximately 6,000 to 7,000 releases reported each year; the cumulative number of confirmed releases is now over 525,000. Viewed together, these data points show the progress EPA, states, territories, tribes, and other UST partners are making in reducing the percent of confirmed releases at UST facilities pending cleanup completion. Over the last few years, the percent of confirmed releases pending cleanup completion has declined from 20.5 percent in 2009 to 13.8 percent at mid FY 2015. Looking back several more years, the percent of confirmed releases pending cleanup completion was 29 percent in 2004. Fiscal Year Confirmed Releases Cleanups Remaining Percent Of Confirmed Releases Pending Cleanup Completion* Each Year Cumulative Mid 2015 3,378 525,095 72,248 13.8% 2014 6,847 521,270 73,947 14.2% 2013 6,128 514,123 77,717 15.1% 2012 5,674 507,540 82,903 16.3% 2011 5,998 501,723 87,983 17.5% 2010 6,328 494,997 93,123 18.8% 2009 7,168 488,496 100,165 20.5% 1 1 1 1 1 2004 7,850 447,233 129,827 29% *Divide cleanups remaining by cumulative confirmed releases Where can I find performance data from previous years? EPA's website www.epa.gov/oust/cat/camarchv.htm provides the most current report, as well as historical reports beginning with FY 1988, the first year reports were developed. Reports are listed beginning with the most recent first. For more information, contact Steven McNeely, EPA's Office of Underground Storage Tanks, at mcneelv.steven@epa.qov or 703-603-7164. AEPA Office of Underground Storage Tanks, Washington, D.C. 20460 www.epa.gov/oust May 2015 ------- UST Corrective Action Measures for Mid-Year FY 2015 (Data through March 31, 2015) Region / State Active Tanks Closed Tanks Confirmed Releases Cleanups Initiated Cleanups Completed Cleanups Remaining Actions This Year Cumulative Actions This Year Cumulative ONE CT 6,301 26,574 55 3,087 3,064 22 2,219 868 MA 9,674 25,468 15 6,413 6,344 32 6,202 211 ME 2,709 13,406 17 2,743 2,737 29 2,703 40 NH 2,962 11,995 18 2,622 2,622 21 2,017 605 Rl 1,546 8,560 4 1,379 1,379 7 1,226 153 VT 2,010 6,068 2 2,149 2,149 7 1,475 674 Subtotal 25,202 92,071 111 18,393 18,295 118 15,842 2,551 TWO NJ 13,567 63,962 1,017 14,253 13,506 617 10,392 3,861 NY 23,630 103,416 67 29,476 29,427 148 28,208 1,268 PR 4,491 5,789 2 1,070 837 3 502 568 VI 143 279 0 29 28 0 22 7 Subtotal 41,831 173,446 1,086 44,828 43,798 768 39,124 5,704 THREE DC 633 3,377 14 927 912 2 821 106 DE 1,194 7,397 19 2,765 2,710 29 2,668 97 MD 7,709 35,895 68 12,151 11,977 72 11,897 254 PA 22,801 65,941 79 16,421 16,355 201 14,453 1,968 VA 18,244 62,209 83 12,430 12,333 103 12,103 327 WV 4,514 20,914 17 3,558 3,478 35 2,860 698 Subtotal 55,095 195,733 280 48,252 47,765 442 44,802 3,450 Definition of confirmed releases, cleanups initiated, and cleanups completed are on EPA's website at www.epa.gov/oust/cat/PMDefinitions.pdf 1 ------- UST Corrective Action Measures for Mid-Year FY 2015 (Data through March 31, 2015) Region / State Active Tanks Closed Tanks Confirmed Releases Cleanups Initiated Cleanups Completed Cleanups Remaining Actions This Year Cumulative Actions This Year Cumulative FOUR AL 17,954 30,689 40 11,881 11,724 56 10,672 1,209 FL 22,333 111,618 78 26,916 18,242 291 15,431 11,485 GA 29,277 49,953 114 13,535 13,337 181 12,374 1,161 KY 9,986 40,136 92 16,437 16,416 141 15,569 868 MS 8,213 23,720 58 7,651 7,500 46 7,270 381 NC 25,632 69,791 83 25,862 23,394 172 21,457 4,405 SC 11,677 33,522 47 9,840 9,480 88 7,537 2,303 TN 16,495 40,157 60 14,897 14,861 99 14,617 280 Subtotal 141,567 399,586 572 127,019 114,954 1,074 104,927 22,092 FIVE IL 19,906 68,617 172 26,265 24,552 375 22,459 3,806 IN 13,448 42,488 69 9,738 9,669 179 7,975 1,763 Ml 18,174 70,649 89 22,637 22,230 198 14,208 8,429 MN 11,789 33,865 60 11,357 11,267 97 11,014 343 OH 21,844 46,811 279 30,937 30,798 279 28,781 2,156 Wl 14,283 68,467 58 19,392 19,111 53 18,335 1,057 Subtotal 99,444 330,897 727 120,326 117,627 1,181 102,772 17,554 Definition of confirmed releases, cleanups initiated, and cleanups completed are on EPA's website at www.epa.gov/oust/cat/PMDefinitions.pdf 2 ------- UST Corrective Action Measures for Mid-Year FY 2015 (Data through March 31, 2015) Region / State Active Tanks Closed Tanks Confirmed Releases Cleanups Initiated Cleanups Completed Cleanups Remaining Actions This Year Cumulative Actions This Year Cumulative SIX AR 8,841 21,609 26 1,720 1,426 12 1,419 301 LA 10,980 35,461 41 4,967 4,967 79 4,287 680 NM 3,708 12,890 14 2,616 2,319 6 1,772 844 OK 10,040 27,875 24 5,114 5,113 46 4,757 357 TX 50,629 120,792 120 27,233 26,320 130 25,549 1,684 Subtotal 84,198 218,627 225 41,650 40,145 273 37,784 3,866 SEVEN IA 6,709 23,475 13 6,142 5,968 48 5,337 805 KS 6,549 21,028 20 5,182 5,061 43 3,840 1,342 MO 8,981 31,904 49 6,977 6,958 64 6,086 891 NE 6,532 15,081 34 6,436 5,395 50 5,112 1,324 Subtotal 28,771 91,488 116 24,737 23,382 205 20,375 4,362 EIGHT CO 7,347 23,075 54 8,122 7,811 79 7,499 623 MT 3,148 11,802 4 3,063 2,930 21 2,183 880 ND 2,240 7,518 0 875 858 0 835 40 SD 3,167 6,878 8 2,726 2,585 19 2,584 142 UT 3,677 13,813 25 4,855 4,820 46 4,512 343 WY 1,700 8,078 3 2,668 2,552 93 1,850 818 Subtotal 21,279 71,164 94 22,309 21,556 258 19,463 2,846 Definition of confirmed releases, cleanups initiated, and cleanups completed are on EPA's website at www.epa.gov/oust/cat/PMDefinitions.pdf 3 ------- UST Corrective Action Measures for Mid-Year FY 2015 (Data through March 31, 2015) Region / State Active Tanks Closed Tanks Confirmed Releases Cleanups Initiated Cleanups Completed Cleanups Remaining Actions This Year Cumulative Actions This Year Cumulative NINE AS 5 63 0 8 7 0 7 1 AZ 6,585 21,772 52 8,838 8,247 21 8,081 757 CA 37,112 131,334 40 44,438 42,533 545 39,295 5,143 GU 250 475 1 140 140 1 120 20 HI 1,549 5,543 16 2,090 2,042 7 1,947 143 MP 64 72 0 14 14 0 14 0 NV 3,763 7,536 5 2,529 2,529 9 2,383 146 Subtotal 49,328 166,795 114 58,057 55,512 583 51,847 6,210 TEN AK 1,003 6,727 11 2,411 2,378 23 2,082 329 ID 3,334 10,998 0 1,486 1,460 6 1,385 101 OR 5,573 26,464 21 7,446 7,285 38 6,588 858 WA 10,196 36,982 16 6,805 6,337 35 4,768 2,037 Subtotal 20,106 81,171 48 18,148 17,460 102 14,823 3,325 Definition of confirmed releases, cleanups initiated, and cleanups completed are on EPA's website at www.epa.gov/oust/cat/PMDefinitions.pdf 4 ------- UST Corrective Action Measures for Mid-Year FY 2015 (Data through March 31, 2015) Active Tanks Confirmed Releases Cleanups Initiated Cleanups Completed Cleanups Remaining Region / State Closed Tanks Actions This Year Cumulative Actions This Year Cumulative REGIONAL CORRECTIVE ACTIONS FOR INDIAN COUNTRY REGION 1 13 5 0 1 1 0 1 0 REGION 2 156 28 0 6 6 0 5 1 REGION 3 N/A1 N/A1 N/A1 N/A1 N/A1 N/A1 N/A1 0 REGION 4 68 77 0 15 15 0 10 5 REGION 5 460 1,042 1 240 223 0 176 64 REGION 6 347 309 0 67 67 1 65 2 REGION 7 80 96 0 21 21 0 13 8 REGION 8 544 2,129 1 538 531 2 404 134 REGION 9 461 1,363 2 299 223 8 236 63 REGION 10 390 1,121 1 189 189 2 178 11 SUBTOTAL 2,519 6,170 5 1,376 1,272 13 1,088 288 Active Tanks Closed Tanks Confirmed Releases Cleanups Initiated Cleanups Completed Cleanups Remaining Actions This Year Cumulative Actions This Year Cumulative | NATIONAL TOTAL 569,340 1,827,148 3,378 525,095 501,766 5,017 452,847 72,248 Definitions of confirmed releases, cleanups initiated, and cleanups completed are on EPA's website at www.epa.gov/oust/cat/PMDefinitions.pdf 1 N/A = Not Applicable. EPA Region 3 does not have any federally recognized tribes. 5 ------- "O OJ +Ļģ Q) Q. E o u nj -S2 u _o u m CO "ro c o nj 200,000 180,000 UST National Backlog: FY 1989 Through Mid-Year FY 2015 $ O ^ O r-,- Ŗ/ Ŗ S3? n? fs X ft ft Ŗ g o & , , ^ ^ "* S ģ - § p> I I I I I 1 o 01 fs IS) "I fV <0 i v ^ SP -* rj no oo Oi" rv '"v V _ rv O) Of O}' CO ' to 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 Years 6 ------- UST Compliance Measures for Mid-Year FY 2015 (April 1, 2014 - March 31, 2015) Region / State % in Significant Operational Compliance with Release Prevention Regulations % in Significant Operational Compliance with Release Detection Regulations % of UST Facilities in SOC w/UST Release Detection and Release Prevention ONE I o 77% 72% 64% MA 85% 27% 25% ME 81% 74% 62% NH 66% 69% 52% Rl1 74% 77% 64% VT1 88% 86% 79% SUBTOTAL 80% 56% 49% TWO NJ 93% 96% 90% NY 84% 73% 69% PR 75% 74% 67% VI 81% 100% 81% SUBTOTAL 86% 81% 76% THREE DC 90% 86% 79% DE 94% 97% 93% MD 81% 90% 75% PA 85% 84% 75% VA 86% 76% 70% WV 88% 86% 77% SUBTOTAL 85% 83% 74% % in % in % of UST Region / State Significant Operational Compliance with Release Significant Operational Compliance with Release Facilities in SOC w/UST Release Detection and Prevention Detection Release Regulations Regulations Prevention FOUR AL 90% 78% 72% FL 99% 75% 74% GA 81% 75% 70% KY 73% 75% 60% MS 72% 65% 54% NC 76% 70% 63% SC 83% 81% 72% TN 89% 88% 82% SUBTOTAL 84% 76% 69% FIVE IL' 74% 67% 60% IN 86% 94% 82% Ml1 86% 65% 60% MN 82% 83% 77% OH 89% 71% 67% Wl1 91% 86% 80% SUBTOTAL 84% 76% 69% SIX AR 74% 74% 61% LA 83% 82% 73% NM 76% 80% 65% OK 80% 89% 75% TX 95% 90% 88% SUBTOTAL 89% 87% 81% These compliance rates indicate the percent of recently-inspected facilities in significant operational compliance (SOC) with federal UST requirements from 4/1/14 through 3/31/15. According to EPA guidelines, states are allowed to report based on requirements more stringent than the federal SOC requirements. States identified with footnote1 indicated they had done so, as described on pages 9 and 10. Furthermore, states have different approaches to targeting inspections. For example, some states focus inspections on suspected non- compliant facilities, while other states conduct random inspections. 1 States reporting based on requirements more stringent than the federal SOC requirements. 7 ------- UST Compliance Measures for Mid-Year FY 2015 (April 1, 2014 - March 31, 2015) Region / State % in Significant Operational Compliance with Release Prevention Regulations % in Significant Operational Compliance with Release Detection Regulations % of UST Facilities in SOC w/UST Release Detection and Release Prevention SEVEN IA 88% 84% 78% KS 54% 90% 51% MO1 85% 96% 83% NE1 81% 69% 61% SUBTOTAL 78% 86% 69% EIGHT CO 85% 84% 83% MT 90% 88% 81% ND 93% 95% 90% SD 75% 82% 66% UT 92% 92% 86% WY 99% 94% 93% SUBTOTAL 87% 88% 82% NINE AS 100% 50% 50% AZ 90% 97% 89% CA 82% 75% 64% GU 100% 96% 96% HI 99% 98% 98% MP 100% 92% 92% NV 89% 85% 78% SUBTOTAL 84% 79% 70% % in % in % of UST Region / State Significant Operational Compliance with Release Significant Operational Compliance with Release Facilities in SOC w/UST Release Detection and Prevention Detection Release Regulations Regulations Prevention TEN AK 80% 81% 73% ID1 84% 77% 63% OR 91% 91% 85% WA 89% 84% 77% SUBTOTAL 88% 85% 77% INDIAN COUNTRY REGION 1 DNA^ DNA^ DNA^ REGION 2 DNA^ DNA^ DNA^ REGION 3 N/Aj N/Aj N/Aj REGION 4 88% 38% 38% REGION 5 70% 73% 52% REGION 6 100% 97% 97% REGION 7 DNA^ DNA^ DNA^ REGION 8 62% 59% 55% REGION 9 93% 91% 84% REGION 10 89% 94% 83% SUBTOTAL 81% 80% 71% NATIONAL TOTAL TOTAL 84.8% 79.1% 71.8% These compliance rates indicate the percentage of recently-inspected facilities in significant operational compliance (SOC) with federal UST requirements from 4/1/14 through 3/31/15. According to EPA guidelines, states are allowed to report based on requirements more stringent than the federal SOC requirements. States identified with footnote1 indicated they had done so, as described on pages 9 and 10. Furthermore, states have different approaches to targeting inspections. For example, some states focus inspections on suspected non- compliant facilities, while other states conduct random inspections. 1 States reporting based on requirements more stringent than the federal SOC requirements. 2 DNA = Data Not Available. 3 N/A = Not Applicable. EPA Region 3 does not have any federally recognized tribes. 8 ------- States With Requirements More Stringent Than The Federal Significant Operational Compliance Requirements CONNECTICUT Release Prevention: Operation and Maintenance of Cathodic Protection Lining not allowed. Release Detection: Testing Tanks and piping require weekly and monthly monitoring for releases and records must be available (for 2 of the most recent consecutive months and for 8 of the last 12 months). Statistical Inventory Reconciliation (SIR) not allowed as a stand-alone method. IDAHO Release Prevention: Operation and Maintenance of Cathodic Protection Three 60-day rectifier inspection checks are required. Two three-year system checks are required for impressed current and galvanic. Release Detection: Testing Records required for the past 12 months. Other Percent of UST facilities in compliance with both release detection and release prevention also factors in financial responsibility and EPAct requirements, such as operator training and secondary containment. ILLINOIS Release Detection: Testing Owner/operator must produce records within 30 minutes of arrival of inspector. MICHIGAN Release Detection: Required Methods Owners/operators must have inventory control plus another method of release detection. MISSOURI Release Prevention: Cathodic Protection All metal components in contact with any electrolyte must be cathodically protected. NEBRASKA Release Prevention: Spill Prevention Owners/operators cannot have debris or water in the spill bucket. Release Prevention: Reporting Owner/operator must submit monthly inventory monitoring reports to the state. Release Prevention: Temporarily Closed Tanks Owner/operator must permanently close USTs that have been in temporary closed status for more than one year. RHODE ISLAND Release Prevention: Operation and Maintenance All tanks and piping are required to be tightness tested after a repair. No exemptions. Release Prevention: Operation and Maintenance of Cathodic Protection Impressed current cathodic protection systems are required to be tested every 2 years. Sacrificial anode systems are required to be tested every 3 years. Release Detection: Testing Records required for the past 36 months. Inventory control is required for all tanks (single-walled and double-walled). The automatic tank gauge (ATG) has to be checked monthly and have an annual test conducted. Tightness testing schedule is different than the federal requirement; it depends on the type of tank. o Tank tightness must be performed on all single walled tanks. 9 ------- o Tightness tests must be performed every 5 years after the installation of the ATG until the tank has been installed for 20 years and every 2 years thereafter, o UST systems upgraded with interior lining and/or cathodic protections are not required to have an ATG for 10 years after the upgrade. Tank tightness testing must be conducted annually during these 10 years. After 10 years, an ATG is required and tank tightness testing must be performed every 5 years until the tank has been installed for 20 years and then every 2 years thereafter. The results of all tightness tests shall be maintained for 3 years beyond the life of the facility. Groundwater or vapor monitoring not accepted as a method of leak detection. SIR not accepted. VERMONT Release Prevention: Operation and Maintenance of Cathodic Protection Lining not allowed unless with impressed current. Release Detection: Method Presence and Performance Requirements Weekly monitoring required for tank and piping. Records must be available for the two most recent consecutive months and for 8 of the last 12 months. Release Detection: Testing Inventory control /Tank Tightness Testing (TTT) not allowed as a release detection method after 6/30/98. Manual Tank Gauge (MTG) allowed alone up to 550 gallons; 551-1,000 gallons, MTG with annual TTT. WISCONSIN Release Prevention: Operation and Maintenance of Cathodic Protection Require annual cathodic protection test. Release Prevention: Spill Prevention Require USTs to be equipped with overfill prevention equipment that will operate as follows (NFPA 30-2.6.1.4 - 2000 and 2003 version): o Automatically shut off the flow of liquid into the tank when the tank is no more than 95% full; o Alert the transfer operator when the tank is no more than 90% full by restricting the flow of liquid into the tank or triggering the high-level alarm; and, o Other methods approved by the authority having jurisdiction. Release Detection: Testing Require NFPA 30A09.2.1 (2000 and 2003 versions). Accurate daily inventory records shall be maintained and reconciled for all liquid fuel storage tanks for indication of possible leakage from tanks or piping. The records shall be kept on the premises or shall be made available to the authority having jurisdiction for the inspection within 24 hours of a written or verbal request. The records shall include, as a minimum and by product, daily reconciliation between sales, use, receipts, and inventory on hand. If there is more than one storage system serving an individual pump or dispensing device for any product, the reconciliation shall be maintained separately for each system. Release Detection: Deferment No exclusion or deferment for "remote" emergency generator tanks. Other Require annual permit to operate that includes verification of financial responsibility. 10 ------- Inspection/Delivery Prohibition Actions for Mid-Year FY 2015 (October 1, 2014 - March 31, 2015) Number of On- Number of Region / State Site Inspections Delivery Prohibition Conducted Actions ONE CT 614 11 MA 286 0 ME 217 1 NH 123 0 Rl 118 1 VT 84 0 SUBTOTAL 1,442 13 TWO NJ 517 56 NY 1,427 0 PR 79 0 VI 12 0 SUBTOTAL 2,035 56 THREE DC 35 0 DE 47 2 MD 456 5 PA 1,491 44 VA 844 0 WV 291 3 SUBTOTAL 3,164 54 Number of On Number of Region / State Site Inspections Delivery Prohibition Conducted Actions FOUR AL 1,418 120 FL 2,974 0 GA 1,634 492 KY 918 81 MS 443 55 NC 1,702 111 SC 1,956 203 TN 1,350 172 SUBTOTAL 12,395 1,234 FIVE IL 1,334 337 IN 514 0 Ml 1,063 153 MN 478 23 OH 1,174 0 Wl 986 80 SUBTOTAL 5,549 593 SIX AR 552 21 LA 906 3 NM 274 5 OK 1,635 20 TX 2,046 5,285 SUBTOTAL 5,413 5,334 Not all states fully implement delivery prohibition at this time, and some states prohibit deliveries primarily for registration violations. 11 ------- Inspection/Delivery Prohibition Actions for Mid-Year FY 2015 (October 1, 2014 - March 31, 2015) Number of On- Number of Region / State Site Inspections Delivery Prohibition Conducted Actions SEVEN IA 828 30 KS 427 13 MO 1,065 0 NE 319 0 SUBTOTAL 2,639 43 EIGHT CO 591 9 MT 239 3 ND 16 0 SD 159 0 UT 364 0 WY 141 6 SUBTOTAL 1,510 18 NINE AS 4 0 AZ 155 9 CA 6,043 61 GU 16 0 HI 206 0 MP 4 0 NV 342 8 SUBTOTAL 6,770 78 Region / State Number of On Site Inspections Conducted Number of Delivery Prohibition Actions TEN AK 18 11 ID 158 0 OR 273 6 WA 655 2 SUBTOTAL 1,104 19 INDIAN COUNTRY REGION 1 0 0 REGION 2 0 0 REGION 3 N/A1 N/A1 REGION 4 8 0 REGION 5 9 0 REGION 6 4 0 REGION 7 0 0 REGION 8 3 0 REGION 9 22 0 REGION 10 6 0 SUBTOTAL 52 0 NATIONAL TOTAL TOTAL 42,073 7,442 Not all states fully implement delivery prohibition at this time, and some states prohibit deliveries primarily for registration violations. 1 N/A = Not Applicable. EPA Region 3 does not have any federally recognized tribes. 12 ------- |