Issue L.U.S.Tneiwpcc.org/lustlineold/lustline_pdf/lustline_50.pdf · 2018-02-15 · Patricia Ellis, Ph.D., Technical Adviser Ronald Poltak, NEIWPCC Executive Director Lynn DePont,

by Ellen Frye

Leakin’ out, mixin’ up, leakin’ out—oopy oop.Mixin’ up, leakin’ out, mixin’ up—uppy up.Gasoline, groundwaterDrinking water, gas.Mixin’ up, leakin’ out. Buried tank. Alas!

Whoa, man! No man! Dis is profound!Gotta get that BTEX outta the ground!Whoa man! Hey man, what’s goin’ down?Gotta KEEP that gasoline outta the ground!Subtitle I is passed.Gotta stop the leakin’ fast.

Chug Chug Chug ChugChuggie Chuggie Chuggie. NotificationInterim prohibitionTechnical standardsFinancial responsibilityInspection and enforcementCorrective action. Ruba dub dubby!

Marchin’ words, big job—sis boom bah.Everybody tool up.Rah, rah, rah. Strategize, franchise, harmonize, analyze!Build a better leaky trappy.Clean up all the petro crappy.Make the rules. Spread the word.We’re gonna try.LUSTLine LUSTLineKeepin’ LUST bustin’ alive!

L.U.S.T.LINENew England Interstate 116 John StreetWater Pollution Control Lowell, MassachusettsCommission 01852-1124

Bulletin 50August2005

A Report On Federal & State Programs To Control Leaking Underground Storage Tanks

■ continued on page 2

www.neiwpcc.org/lustline.htm

“We Hope LUSTLine Will Be Useful . . .”LUSTLine Bulletin #1,

August 1985

California’s Designated UST Operator Program

Tanks on Tribal Lands

A Message from Cliff Rothenstein: Got Water?

EDB at South Carolina LUST Sites

Leaded Gasoline—What’s in Those USTs?

10,000 Facilities to Inspect—GIS Shines a Light

GER Analysis Methodology

County Websites to the Rescue

I’ve Looked at Tanks from Both Sides Now

Making Sense of UL 971

Maryland’s New Helium Test Protocol

Lightning Strikes Florida Tanks

Inside6

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25

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20th

Anniversary

Issue

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LUSTLine Bulletin 50 • August 2005

mulgate regulations to prevent,detect, and correct the problem ofleaking underground storage tanks.We decided to call our new bulletinLUSTLine.

Staying on top, if not a few stepsahead, of tank-related issues is whatwe’ve tried to do for the past 20years. We started out with baby stepsand Pablum, because the magicalworld of UST and LUST regulationwas as new to us as it was to manyregulators. Early LUSTLine issueswere only about 12 pages long. Nowthat we’re nearly legal age for finewine and oysters on the half shell, it’shard to imagine producing a LUST-Line as short as 12 pages. We’ve triedto meet the technical level of themajority of our readers. In essence,we’ve all smartened up together—we hope.

“I can supply nothing but kudos to

LUSTLine and what the editorialstaff has accomplished over thelast 20 years. I have been an

avid reader of each bulletin forjust over half of that time span.

Thanks to my predecessor, I have a nearly complete set,

which I still reference from time to time. Thank you.”

Walter Nagel,PA DEP, UST Program

Tripping the Leak Tank-TastickIn our first issue, we described U.S.EPA’s initial game plan, explainedrequirements for owners/operatorsto notify states of their tank owner-ship, and shared examples of stateUST efforts already underway. BySeptember 1985, EPA had created theOffice of Underground StorageTanks (OUST). Ron Brand wasnamed Director. We were truly offand running. OUST quickly promul-gated rules for UST Notification, butthey really had to put the pedal to themetal to tackle corrective action, newtank standards, leak detection, tankclosure, and financial responsibility.

State and federal regulatorsembarked on fact-finding missions.How did UST systems work? How

did available leak-detection and cor-rosion-protection technologies work...to begin with? Is secondary contain-ment an option? How will states fundtheir UST programs...permit fees?registration fees? How does petro-leum behave when it leaks into theenvironment? What cleanup tech-nologies work best? Oh, and who’s incharge? Oy!

“As a young federal employee,

I cut my teeth on EPA’s NPDESWastewater program, andeventually I migrated to theRCRA Subtitle C Hazardous

Waste program. In November1984, I was asked to help startup this new program in EPA –New England to try to controlLUST in America. How could I

resist a job like that?! But I learned very early that thisnew program would be different

from the others. Our founder[first OUST Director], Ron Brand,had a vision that states shouldrun this program and the EPAregion’s job was to help makethe state programs successful.Franchising and TQM were ourmantras. The rest is history...and, gosh darnit, it worked!

At a meeting I attended whenthe Superfund program wasstarting up, one of my seniorEPA regional managers was

discussing CERCLA priorities withour states. He said the agencywanted to work in partnership

with the states but that they hadto realize that EPA would be thesenior partner! If the UST/LUSTprogram had tried to establish

itself with that level ofarrogance, it would have beenimpossible to achieve the true

working partnership we’ve hadover the past 20 years.

In partnering with the states, I also got to work with a

venerable organization calledNEIWPCC. They’d been bringing

the New England states and

L.U.S.T.LineEllen Frye, Editor

Ricki Pappo, LayoutMarcel Moreau, Technical Adviser

Patricia Ellis, Ph.D., Technical AdviserRonald Poltak, NEIWPCC Executive Director

Lynn DePont, EPA Project Officer

LUSTLine is a product of the New EnglandInterstate Water Pollution Control Commis-sion (NEIWPCC). It is produced through a

cooperative agreement (#T-830380-01)between NEIWPCC and the U.S.

Environmental Protection Agency.LUSTLine is issued as a communication

service for the Subtitle I RCRA Hazardous & Solid Waste Amendments

rule promulgation process. LUSTLine is produced to promote

information exchange on UST/LUST issues.The opinions and information stated hereinare those of the authors and do not neces-sarily reflect the opinions of NEIWPCC.

This publication may be copied. Please give credit to NEIWPCC.

NEIWPCC was established by an Act ofCongress in 1947 and remains the oldest

agency in the Northeast United Statesconcerned with coordination of the multi-

media environmental activities of the states of Connecticut, Maine,Massachusetts, New Hampshire,

New York, Rhode Island, and Vermont.

NEIWPCC116 John Street

Lowell, MA 01852-1124Telephone: (978) 323-7929

Fax: (978) [email protected]

LUSTLine is printed on Recycled Paper

■ LUSTLine’s 20th AnniversaryIssue from page 1

Humor me. I haven’t written any“poems” since, oh, LUSTLine #12 in1990. But, recognizing that some-times art must trump enlighteneddiscourse to “soothe the savagebeast,” I thought, okay, LUSTLine #50would be as good a time as any toinsert a poem...for old time’s sake.Humor me, also, as I trip the leaktank-tastick and reminisce, touchingon the timeline of tank issues, andcommenting on (with a little helpfrom my friends) where we are nowand where we might be going. Why?Because August 2005 marks the 20thanniversary of LUSTLine!

In 1985, U.S. EPA awarded theNew England Interstate WaterPollution Control Commission(NEIWPCC) a grant to publish anddistribute five issues of a bulletin thatwould inform and update state andfederal regulatory agencies across thecountry on topics related to the newRCRA Subtitle I requirements. Thislegislation called for U.S. EPA to pro-

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August 2005 • LUSTLine Bulletin 50


In the early days of the UST program, when tanks were being yanked at unprecedented rates, the dangers associated with tank removal and disposal were a big concern. While health and safety will always be a concern, improved monitoring, inerting, cleaning, and dismantling of tanks has minimized accidents. The days of finding tanks lying on the side of the road are mostly in the past. However, you might finda bear or three calling a tank “home,” as some of us did at an animal farm on the Olympic Peninsula in Washington State.

New York together for manyyears to protect water quality,including groundwater. Throughthis NEIWPCC connection I was

drafted to write an article with aregional perspective for the first

issue of this new publicationcalled LUSTLine. That was 20

years ago. It’s been covering allthe bases since then. Happy

20th, LUSTLine.”William Torrey, UST/LUST Regional Program

Manager, U.S. EPA – New England

To Thine Own Tank Be TrueAt the risk of subjecting readers to ahuge “Duh” moment, the only waywe can prevent a petroleum releasefrom an UST system is by ensuringthat all aspects of that system, includ-ing product-delivery and -dispensingoperations, are designed, installed,operated, and maintained such that arelease cannot occur. LUSTLine hascovered the gamut of technical issuesassociated with petroleum storage,including installer certification, prod-uct delivery, facility inspection andenforcement, and the 1998 deadlinefor upgrading, replacing, or remov-ing tank systems.

We’ve also covered related issuessuch as abandoned tanks, health andsafety, heating-oil and other tanksnot regulated under the federal pro-gram, the future of “mom and pop”

facilities, UST facility siting, productcompatibility with system compo-nents, owner/operator training andcertification, and most recently,vapor releases from UST systems.

The people who know those top-ics best have written most of the arti-cles on the many subjects we havecovered. LUSTLine would not bewhat it is were it not for its contribu-tors! And I thank you one and all. Iam particularly grateful to a coregroup of contributors on whom I relynot just for articles but also foradvice and content review. At thetop of this list is Marcel Moreau,author of our “Tank-nically Speak-ing” column.

I met Marcel in 1984, when hewas a geologist at the Maine Depart-ment of Environmental Protection.The New England states and NewYork had been meeting at NEIWPCCtwo or three times a year to discussconcerns about impacts on ground-water from UST-system releases.Marcel, who attended these meet-ings, clearly had a leg up on the sub-ject. During his tenure at Maine DEPand in his current role as an UST-system consultant, he has served thecause of release prevention withdedication and integrity and hasbeen an invaluable friend, advisor,and LUSTLine contributor—author-ing or co-authoring about 40 articleson all aspects of USTs, including thehuman element. His articles add upto a solid body of work that shouldbe required reading for anyoneinvolved with USTs.

In 1989, Bob Renkes, ExecutiveVice President of the PetroleumEquipment Institute (PEI), initiatedhis column “Field Notes,” givingLUSTLine readers an industry per-spective on UST-related issues.Through the years, Bob has providedconcise and timely information onthe issues that most closely intersectthe interests of LUSTLine readers andPEI members. He has also been avery sensitive sounding board attimes when I have been flummoxedby a particular topic.

Since 1992, David McCaskill ofMaine DEP (originally from Missis-sippi) has provided us with his inim-itable insight into tank issues in hiscolumn “Tanks Downeast.” LikeMarcel, David has a knack for choos-ing topics that resonate nationwide.He has covered a range of themesincluding aboveground storagetanks, heating-oil tanks, secondarycontainment, waste-oil tanks, andUST facility siting. For years, he’sbeen working (unsuccessfully) to getme out in a sea kayak.

Thanks also to Marshall Mott-Smith (Florida Department ofEnvironmental Protection), ErnestRoggelin (Florida’s Pinellas CountyHealth Department), Kevin Hender-son (Mississippi Department of Envi-ronmental Quality), Ben Thomas (BenThomas Associates, Inc.), and ShahlaFaranak and Erin Ragazzi (formerlywith the California tank program) fortheir bounteous input over the years.

Taking Aim at Site CleanupOne driving theme from OUST in theearly stages of the UST/LUST pro-gram was the need to work towardcontinuous improvement. Lookingback at early LUSTLine articles, onequickly realizes that our comfortzone with cleaning up LUST siteswas quite narrow, but there was, andstill is, continuous improvement.

One of my early articles referredto contaminated soil as the “new kidon the block of national environmen-tal concerns.” But we’ve come a longway. We learned that without ade-quate site characterization, cleanupstrategies are essentially hit or miss.Seems obvious to many of us now,but maybe not so much once upon atime. Over the years, cleanup tech-nologies went from classic muck-and-truck and pump-and-treat to insitu approaches, such as air sparging,air stripping, soil vapor extraction,and even monitored natural attenua-tion.

And, by the way, how clean isclean? In January 1994, I wrote acover article called “Stop theWorld...It’s Time to Step Off andRegroup,” which was our first seri-ous look at the subject of risk-basedcorrective action (RBCA, now knownas risk-based decision making(RBDM)). Despite our growingunderstanding of the nature of thecorrective-action beast, there was agrowing backlog of LUST sites and alack of a commensurate number ofLUST site closures. Conditions wereripe for RBCA. From what I cangather from NEIWPCC’s 2003 surveyon “State Experiences with MtBE andOther Oxygenate Contamination atLUST Sites,” about 44 states now usesome form of RBDM in their correc-tive-action protocols.

Then, just when it seemed likewe were getting the hang of cleaningup the BTEXs, the TPHs, the PAHs,the tra las, along came the gasolineoxygenate methyl tertiary butyl ether(MtBE), and new challengesemerged. MtBE behaved differentlyfrom the other contaminants of con-cern—it’s more soluble and mobile,seemingly less degradable and treat-able, and has no MCL. As it turns

out, we are recognizing that since wedon’t want to be finding fuel-contam-inant surprises in our drinking water,we should probably be looking a bitmore closely at a wider selection ofgasoline components, such as TBA,ethanol, TAME, DIPE, and EDB.

As OUST Director Cliff Rothen-stein reminded us in LUSTLine #49,“Our bottom-line job, day after day,is to protect the environment andhuman health from undergroundstorage tank releases and keep Amer-ica’s land and water clean and safefor all citizens and future genera-tions.”

Once again, I want to thank themany contributors who helped spreadthe word as we grew in our collectiveunderstanding of such corrective-action enigmas as site characteriza-tion, soil and water cleanuptechnologies, RBCA, and MtBE andother oxygenates. I’ve known Pat Ellis(Delaware Department of NaturalResources and Environmental Con-trol, Tank Management Branch) formany years. As I got to know her, Ifound myself calling her more andmore with questions about correctiveissues, until she finally agreed to bemy official LUST technical adviser.Once she finished serving on EPA’sBlue Ribbon Panel on MtBE, she knewmore than she ever hoped to know

about that subject. She wrote her firstLUSTLine article in March 2001.

Which brings me to my learnedfriend Hal White at EPA OUST, withwhom I have had many thoughtfuldiscussions on anything and every-thing related to LUST remediation.Hal waded into the LUSTLine watersin March 2002 with the article “DoMonitoring Wells Monitor Well?” Heeventually wrote his own thought-provoking column called “Wander-LUST.” When he bowed out, Pat Ellisgraciously picked up the column andcontinued to run with it.

Two other people who have beenthere for LUSTLine over the years,writing and reviewing articles andanswering questions, are Bruce Bau-man, Soil and Groundwater ResearchProgram Coordinator at the Ameri-can Petroleum Institute, and BlayneHartman, a soil vapor methods andanalysis specialist.

The USTfields RenaissanceIt seemed perfectly obvious to mewaaay back in graduate school, whenI was writing papers on reusingabandoned mill buildings, thatreusing an existing property made aheap more sense than taking a back-hoe to a verdant copse. Likewise,ignoring abandoned or idle petro-leum-contaminated sites ‘cause it’stoo much trouble to deal with theissues and easier to move on to apretty little “greenfield,” smacks ofhubris—the telltale mark of a throw-away society.

Many state LUST programs andcommunities are seeing the benefitsof reusing these properties by unitingeconomic development with sitecleanup efforts. LUSTLine first cov-ered the subject of LUST sites inbrownfields in 1997, a time when thefederal Brownfields program did notinclude petroleum contamination,and state LUST programs were moreconcerned with having to deal withadditional hurdles to clean up thesesites. But times, they are a changin’.Now we hope to demonstrate thatour efforts to protect human healthand the environment from petroleumreleases also have a socioeconomicbenefit.

Special thanks to Gary Lynn,New Hampshire Department ofEnvironmental Services, who, among

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“Congratulations to LUSTLine on its

20th anniversary and on thismilestone 50th issue! EPA

appreciates the integral roleLUSTLine has played in reaching

out to underground storagetank partners over the history of

the national tank program.LUSTLine has provided timely,

accurate, and useful informationabout tank systems to manystakeholders. EPA is proud to

have been a supporter ofLUSTLine over these many

years, and we look forward toour continued partnership inproviding a forum to share

information about tank issues.” Cliff Rothenstein, Director – Office of

Underground Storage Tanks, U.S. EPA

other things, has helped keep me upto speed on USTfields, and SteveMcNeely, EPA OUST’s USTfields/Brownfields marriage broker.

As Steve once mused, “Hope-fully, LUSTLine will be able to enticethose champions of change to sharetheir challenges, lessons learned, andaccomplishments so we’re betterequipped to highlight our role in thegrand scheme of things.” Yes, Steve,LUSTLine will be there to help pointthe way to good sense.

Taking Aim at Paying forSite Cleanup in Order toExpedite Site Cleanup!It’s so good to know that so many sharppeople are out there making sure you getthings right...like the author of the nextsection, Chuck Schwer, VermontDepartment of Environmental Conser-vation. I’ve known Chuck since the weehours of the program, and I knew that allI had to do was ask and he would help meout with the state fund part of this arti-cle. Each year, Chuck and his staff con-duct and summarize a state fund survey,the results of which Chuck presents atthe Annual State Fund AdministratorsConference. Take it away, Chuck.

It’s hard to believe that the USTprogram and LUSTLine have beenaround for 20 years. There have beenso many challenges over those years:more than a million unprotectedtanks, contamination everywhere,programs understaffed and under-funded, and my favorite, the conceptof financial responsibility (FR). It wasthis FR requirement that set the stagefor the birth of state funds, as tankowners were unable to secure privateinsurance or find other means offinancial surety. By the end of 1990,38 states had established statecleanup funds, and by 1997, therewere 48. Only Hawaii and Oregonchose not to create state funds.

For the 48 state-fund managers,funds presented unprecedented chal-lenges. But with the help ofLUSTLine, states worked together todevelop tools and strategies to takeon those challenges. One of the firstgrim facts we all faced was the realitythat the cost of cleaning up all thecontamination caused by leakingUSTs was far greater than the fundsavailable. To respond to this reality,

states developed strong, enforceablecost-control measures. These in-cluded allowable costs, preapproval,and limits on markups and overhead.Site cleanups also needed to be prior-itized, and RBCA was born.

And then there were thosenearly-impossible-to-prevent legisla-tive raids on the funds. Despite ourbest efforts to put strong languageinto our rules to prevent such action,legislative raids still present an ongo-ing challenge.

Claims, claims, and moreclaims—would they ever stop? Stateshad to develop streamlined claims-processing systems to survive. Butwhat about all that fraud and abuse?This became a real threat to manystate funds. Even with high-profilecases being won against perpetratorsin Florida and North Carolina, state-fund managers continue to battlefraud and abuse on a daily basis.Then came pay-for-performance(PFP). Could this be a way to stopfraud and abuse, speed up sitecleanup, and reduce paperwork? Fif-teen states have implemented PFPprograms.

And what about the reemergenceof private insurance? For some statesthis has become a reality. Elevenstates have transitioned to FR mecha-nisms other than state funds. Some“sunsetted” funds are still paying forthe cleanup at older sites, while oth-ers are entirely done. One fund,Michigan, declared dead when it wasdeemed insolvent in 1995, has beenreborn to help with the challenges ofcleaning up contamination at oldersites.

As we look to the next 20 years,we know that many of the issues wedeal with today will no longer exist.However, we also know that to getthere, we will have to continue towork to complete the many tasks setout by state funds. There are stillmore than 125,000 backlogged USTsites yet to be cleaned up. We are alsodiscovering new sites every day—more than 1,500 nationally in the lastsix-month reporting period.

Vapor releases and flexible pip-ing issues are new challenges tokeeping upgraded UST systems fromleaking petroleum into the environ-ment. We all know prevention is thekey. But what’s the best way to get atthis prevention? Third-party inspec-tion programs? Environmental

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results programs? Making compli-ance a condition of fund coverage?As we take on our upcoming chal-lenges, it is comforting to know thatLUSTLine will be there with tools andideas to help state-fund managerswork through these many difficultissues.

“Congratulations on your 20th anniversary. Thoughtyou might like the contributionof a photo of a gas station in

Cyprus from about the time yourpublication first started. It wassituated close to a place calledLara Beach where the turtles goto lay their eggs. You can seethat I was impressed by the

storage and dispensingarrangements...and used it torefuel my rental car. Much hashappened to this station in 20years—it is now very smart.

Cyprus is in the European Unionand the storage tanks are now

underground and double-walled steel with leak

detection, thus protecting theturtles on the nearby beach!”Jamie Thompson, Chair of the European

Standards Committee for Gas Station Equip-ment, former regulator for London, and

LUSTLine friend and contributor


pages of weightyand lengthywritten material.She is a skilledprofessionalwith a greatsense of humor.Needless to say,Ricki and I wel-comed our car-toonist, HankAho, on boardwith open arms.Hank is Maine’sUncontrolledHazardous Sub-stance Sites UnitSupervisor andan artist. It was truly a miracle tomeet up with a cartoonist who actu-ally understands the quirky world ofregulators and petroleum storagesystems. There’s nothing like a Hank

The LUSTLine TeamThe LUSTLine team is all of you whowork with us to get appropriate andtimely information into each issue.We really and truly value all feed-back, and we depend heavily on yourinput in the way of suggested stories,topics to explore, and article andphoto contributions. And, we alwayswelcome new contributors.

Our core team consists of RickiPappo, Hank Aho, our NEIWPCCreviewer, Kara Sergeant, and ourEPA OUST project manager, LynnDePont.

Ricki, who designs and lays outeach issue, always, always goes theextra mile. She tries to keep the bul-letin looking light, often in the face of

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As of January 1, 2005, each ofthe 15,000+ UST facilities inCalifornia was required to

have a Designated UST Operator(D.O.) who is responsible for con-ducting monthly UST-system inspec-tions and providing basic on-the-jobtraining for facility employees. Thisrequirement is in addition to theannual facility compliance inspectionconducted by the local UST regula-tory agency. To serve as a D.O., anindividual must pass a standardizedcertification exam demonstratingthat he or she has knowledge of USTlaws, regulations, and managementpractices that minimize the risk ofrelease to the environment. The D.O.certification must be renewed everytwo years.

Our UST System Operator Examis based on the International CodeCouncil’s (ICC’s) National UST Sys-tem Operator Exam, with minorchanges incorporated to address

California-specific regulations. ICCdeveloped the exam with theassistance of the California WaterResources Control Board (CWRCB).ICC offers the exam at approximately40 test centers throughout the state.Information on ICC’s various UST-related exams can be found on itswebsite at http://www.iccsafe.org/certification/.

Although exact figures are cur-rently unavailable, regulatory inspec-tors throughout California arereporting that most UST facilitieshave assigned D.O.s and are comply-ing with the monthly inspectionrequirements. Many UST ownershave become certified and are serv-ing as their own D.O.s, while othershave chosen to contract with quali-fied third parties to provide this ser-vice. Nearly 3,500 individuals havepassed the California ICC D.O. certi-fication exam since it was first offeredin August 2003, and the number ofcertified D.O.s continues to grow.

Our D.O. program is still rela-tively new, but it already appears to

be improving UST compliance in thestate. D.O.s are identifying deficien-cies during their monthly inspec-tions, and working with owner/operators to make the necessary cor-rections. D.O.s are also implementingfacility employee-training programsand helping to ensure properresponses to spills, overfills, andalarms from monitoring systems. Inthe coming months, CWRCB andlocal regulatory agencies will con-tinue education and enforcementactivities in an effort to achieve 100percent compliance with D.O.requirements. ■

For more information onCalifornia’s Designated USTOperator Program, visit the

California Water Board’s websiteat http://www.waterboards.

ca.gov/ust or contact Scott Bacon at (916) 341-5870 or

[email protected].

California’s Designated UST OperatorProgram’s Lookin’ Goodby Scott BaconCALIFORNIA

cartoon to get us in the right frame ofmind to crank out a new issue.

LUSTLine is a wonderful partner-ship among many people. We thankyou all. See you next time. ■


LUSTLine Production Team: Ellen Frye, Hank Aho, and Ricki Pappo

Ya’a’t’eeh means “greetings” inthe Navajo language. I want tointroduce the Navajo people,

briefly describe their traditionalbeliefs on the environment, and thenend with a report on the UST andLUST programs in the NavajoNation.

The Navajo Nation encompassesportions of Arizona, New Mexico,and Utah, covering more than 25,000square miles of land—nearly the sizeof West Virginia. In my view, theNavajo Nation is the eighth wonderof the world. I assert this because,among other things, it is home toMonument Valley and Shiprock.Monument Valley is a scenic area inUtah with dramatic landscapes,where you’ll find red mesas and tow-ering, ancient red sandstone forma-tions that seem to defy gravity. In thenorthern part, near Shiprock, NewMexico, is an igneous intrusion thattowers hundreds of feet above thesurrounding landscape. In Arizona,grays and purples represent ancientdeposits of volcanic ash and petrifiedwood, well preserved in the ChinleFormation. Recent flows of black lavaand red cinder cones cover the land-scape in the southern parts nearFlagstaff.

Navajo Traditional BeliefsAccording to our traditional beliefs,the Holy People laid down the lawsfor the Navajo people, endowingthem with sophisticated healing cere-monies for their well-being. TheNavajo creation story informs us of a

series of emergence and progressionthrough different worlds. The firstworld was “dark world” and wasinhabited by insects. The secondworld was “white as light” and wasbestowed to people. Then there was“yellow world.” Each world under-went destructions and renewals.“The ‘fifth world,’” as an old Navajosaid, “would not come for thousandsof years. Man does not know of itscoming. As long as the plants andanimals continue to live and grow,we are in the ‘fourth world.’ Whenthey are gone, we will be somewhereelse.”

We were given sacred cere-monies with songs, prayers, andpoems to maintain our health andharmony with Mother Earth, as weare all a part of her. This means livingin balance with all living things,elements of the universe, and ourenvironmental surroundings. Ourlanguage perpetuates the Navajohealing ceremonies that protect thehealth of Mother Earth, Father Sky,and the Navajo people.

Navajo EnvironmentalViewpointIn April 1995, the Navajo NationTribal Council passed a resolution, apart of which said, “In the Navajo way,the Earth is our Mother, the mountainsare part of her sacred body, the watercourses are veins and arteries. When theEarth is injured, the resultant instability,imbalance, and disharmony bring illnessto life on Earth including humankind.”These Navajo beliefs hold as strong as

when the Holy People first bestowedhealing ceremonies on the Navajopeople to maintain and protect theenvironment.

Water, or “to’” in the Navajo lan-guage, is one of the three mostimportant elements for growth, nour-ishment, and perpetuation of all liv-ing things. Rivers, streams, springs,and all other natural sources of waterare sacred. Water plays an integralrole in all healing ceremonies. Air, or“nilchi,” like water, is another sacredelement. Air sustains all livingthings. The third element, sunlight,or “adinidiin,” is required for thegrowth of plants, animals, andpeople.

Our UST ProgramThe Navajo Nation Tribal Councilpassed the Underground StorageTank Act in October 29, 1998, whenthey saw the need to protect preciousgroundwater resources and to regu-late the USTs located on the NavajoNation.

In 1999, I began work withNavajo EPA to further focus the workplans for the Navajo LUST and USTprogram and to start the enforcementof the Navajo Nation UST Act of1998. In the last couple of years, usinggrants from U.S. EPA, our programhired additional staff to become USTinspectors. Currently, there are fourcertified UST inspectors. Previously,the program averaged 1.6 persons toconduct UST inspections and LUSTsite assessments.

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Tanks on Tribal Lands

With this issue of LUSTLine we are delighted to introduce a new column, “Tanks on Tribal Lands.” The column will providetribal members and all of our readers with insight into the unique logistical and geographic issues, activities, solutions, and suc-cesses associated with USTs and LUSTs on tribal lands. We are honored to have Henry Haven, Jr. launch this column. Henry hasserved the Navajo Nation’s UST/LUST program with great purpose and dedication. Following Henry’s article, “T’o IinaAt’eeh,” Mimi Newton, U.S. EPA Region 9, discusses U.S. EPA’s new memorandum clarifying its position regarding the use offederal LUST Trust Fund money at abandoned UST facilities in Indian Country.

T’o iIna At’eeh – Water is Lifeby Henry Haven, Jr.


I undertook my first UST-inspec-tion training program with U.S. EPAin 1999 and realized for the first timehow huge the UST universe was onthe Navajo Nation. (See Figure 1.) Myinitial training period consisted ofobserving the U.S. EPA inspectorduring joint U.S. EPA and NavajoNation EPA (NNEPA) inspections.Later, I obtained an UST inspectorcredential from the Inter-TribalCouncil of Arizona. I became the firstUST inspector for the Navajo USTprogram office in November 2002.

I started by building an USTdatabase to identify operating, leak-ing, abandoned, and questionableNavajo UST sites in Arizona, NewMexico, and Utah. With the help ofsummer students, we prepared filesfor all sites and ordered new filingcabinets to start a filing system. Weordered equipment such as a globalpositioning system (GPS), explosime-ter, compass, and topographic mapsfor our program. We obtained GPSdata and plotted operating UST siteson maps. We conducted field siteassessments to determine how manytanks were operating and how manywere abandoned in place. We com-piled data on inspected UST sites foreach year and recorded violations toaid the program in targeting sites forfollow-up inspections.

There are approximately 1,200USTs on the Navajo Nation; thisincludes operating, permanentlyclosed, temporarily closed, aban-doned, and questionable sites. Thereare approximately 142 operating siteson the Navajo Nation, with approxi-mately 550 tanks in place. This num-ber does not include Bureau of IndianAffairs facilities. Our operating USTsites include privately owned or oper-ated service stations, Navajo Nationgovernment refueling stations, stateschool bus barns, and state Depart-ment of Transportation and NavajoHousing Authority facilities.

In 2001, 45 joint U.S. EPA andNNEPA inspections were conducted.After 2001, the agencies averagedapproximately 53 UST inspectionsper year on government-owned andprivately owned service stations. In2001, U.S. EPA and NNEPA jointUST inspections showed a compli-ance rate of only 2 percent. By 2004,the compliance rate had risen to 53

percent as a result of the partnership,outreach, and increased inspectionrates.

Our LUST ProgramSince 2001, approximately 40 USTshave been closed and removed eachyear. In 2004, 60 USTs were removedand assessed for contamination at 24sites. Six sites had USTs that leakedand had shallow groundwater contam-ination. Also in 2004, the Navajo LUSTprogram removed 46 abandoned USTsfrom 16 sites and provided furtherassessment of several leaking USTsites. Approximately 86 abandonedUST sites remain with about 200 USTsstill in place.

Section 703 of the Navajo NationUST Act of 1998 established a Leak-ing Underground Storage Tank Fundfor corrective actions, removal ofabandoned tanks, and cleanup ofcontaminated sites. The programreceives the proceeds of 1 cent fromevery gallon of gasoline sold onNavajo Nation lands.

In 2004, the NNEPA LUST pro-gram set out for the first time to usethe $1.3 million of tariff fees collectedon gasoline sold on the NavajoNation. Navajo environmental con-tractors were hired to go to 19 sitesthat had been abandoned since the1960s to remove USTs and remediatewhere necessary. Navajo contractorsdrilled monitoring wells to assess thelateral and vertical extent of ground-water contamination and remove

petroleum-contaminated soil. Of the19 sites addressed by NNEPA in 2004with remedial action, 17 will beclosed with no-further-action status.

The majority of our LUST sitesare located in Arizona and New Mex-ico. Tuba City, Window Rock, andShiprock are the communities withthe most LUST sites. There areapproximately 43 leaking sites on theNavajo Nation that have not beenaddressed with aggressive cleanupmeasures. Over 50 percent of the USTsites on the Navajo Nation pose athreat to shallow groundwaterresources at approximately 20 feet.

Recently, the Navajo LUST pro-gram drafted preliminary groundwa-ter and soil cleanup standards, whichare stricter than those of U.S. EPAand the State of Arizona, to startaddressing contaminated ground-water resources.

Looking to the FutureIn recognition of the Navajo Nation’sUST/LUST program’s phenomenalsuccess during the past five years,U.S. EPA Region 9 awarded and rec-ognized the Navajo program with anational environmental award. Thefuture holds great promise, as U.S.EPA and the Navajo Nation joinefforts this year to begin the cleanupof contaminated groundwater sites.This year the Navajo LUST programwill address seven sites to removeabandoned underground storagetanks.

8


■ Water Is Life from page 7 FIGURE 1. UST Universe on the Navajo Nation.

UST Locations

Ramah

Alamo

Farmington

Tuba City

Flagstaff

BigBoquillas

Canoncito

9


U.S. EPA Clarifies Circumstances Where LUST Trust Funds May Be Used in Indian Country

by Mimi Newton

I am honored to have been giventhe privilege to write an introductoryarticle for LUSTLine’s new column,“Tanks on Tribal Lands.” I thank Lil-lie Lane, Public Information Officerwith the Navajo Nation EPA, for herassistance and U.S. EPA Region 9 for

their continued assistance in devel-oping the LUST program for theNavajo Nation. ■

Henry Haven, Jr. is a Geologist withthe Navajo Nation EPA and can be

reached at [email protected].

of coverage required for the facility;and (4) where the owner or operatorhas failed to comply with a correc-tive-action order.

The primary focus of the Febru-ary 24 memo is USTs abandoned ontribal lands with known, suspected,or possible contamination, where theoriginal UST owners/ operators areunidentified, have not been located,or are not financially viable. Thememo clarifies that federal LUSTTrust Fund dollars may be used atsuch sites if they meet each of the fol-lowing conditions:

• The United States is the trustowner of the property for thebenefit of an Indian tribe or indi-vidual.

• The Indian tribe or individualdid not operate or manage theUST.

• If lease documentation can belocated,– there is evidence that the

Bureau of Indian Affairs nego-tiated the lease on behalf ofthe Indian tribe or individualand

– there is no evidence that theIndian tribe or individualactively participated in thelease-negotiation process orthat any such participationwent beyond minimalinvolvement (such as leaseapproval or concurrence).

The memo provides guidance tothe Regions on the use of LUST TrustFund dollars to address potential orconfirmed releases from USTs ontribal lands “if the Region determinesthat the situation requires promptaction” to protect human health and

On February 24, 2005, the U.S.EPA Offices of UndergroundStorage Tanks and Site Reme-

diation Enforcement issued a memo-randum clarifying the agency’sposition regarding the use of federalLUST Trust Fund money at aban-doned UST facilities in Indian Coun-try. As a result of the clarification,U.S. EPA Regions with jurisdictionover USTs on tribal lands may find iteasier to investigate and remediateabandoned USTs with LUST TrustFund money.

Prior to the February 24 memo,U.S. EPA guidance regarding the useof federal LUST Trust Fund dollarsfocused principally on LUST sitesoutside of Indian Country, wherestates are usually the implementingagencies and typically take the leadat LUST sites. At those sites, the useof LUST Trust Fund money shouldbe limited to emergency situations,because U.S. EPA is not the imple-menting agency. However, theInterim Final National CorrectiveAction Policy for USTs in IndianCountry (EPA OSWER Directive9610.9A, Oct. 26, 1995) establishedthat all sites in Indian Country—where U.S. EPA is the implementingagency—are eligible for LUST TrustFund money so long as they meet thestatutory criteria.

The federal Resource Conserva-tion and Recovery Act (RCRA Sec-tion 9003(h)(2)(A)–(D)) allows the useof federal LUST Trust Fund money infour situations: (1) where no owneror operator can be found who iscapable of carrying out correctiveaction properly; (2) where a situationexists that requires prompt action toprotect human health and the envi-ronment; (3) where corrective-actioncosts at the facility exceed the amount

the environment. The memo also pro-vides some factors the Regions mayconsider in determining whether asituation requires prompt action.These factors include determiningwhether contamination has been dis-covered or is suspected and theextent of the negative impact onhuman health or the environmentfrom an abandoned UST that hasremained unremediated for anextended period of time.

The memo also makes it clear thatthe Regions may take into account anumber of considerations relevant totrust-land ownership in determiningwhether or not to pursue cost recov-ery against a tribe or individual trustbeneficiary after LUST Trust Fundmoney has been expended. Thememo sets forth three examples ofsuch considerations: (1) the inabilityof the tribe or individual to divestitself of land ownership; (2) the natureof the leasing documentation; and (3)the participation or lack of participa-tion of the tribe or individual in thenegotiation of the lease (if any).

Shortly after the issuance of thememo, U.S. EPA’s Pacific SouthwestRegion (Region 9) obtained approvalfrom EPA headquarters for the use ofLUST Trust Fund money at nineabandoned UST facilities. These ninefacilities are located on trust lands ofthe San Carlos Apache and the Hopi.■

Mimi Newton works as a RCRA attor-ney with EPA Region 9. She began her

legal career as a RCRA enforcementattorney at EPA Headquarters in

Washington, D.C. The views expressedin this article do not necessarily repre-

sent the views of U.S. EPA. Mimi can be reached at

[email protected].

10


A MESSAGE FROM CLIFF ROTHENSTEINDirector, U.S. EPA Office ofUnderground Storage Tanks

Got Water?

With the lazy days ofsummer upon us,water becomes a big-

ger part of our lives as wemove our activities outside.We drink more than a half gal-lon of water a day, especiallyon a hot summer afternoon;and we each use about 50 gallons a day for cooking,bathing, and keeping our lawns green and our cars clean..On average, the typical family uses more than 100,000 gal-lons of water during a year. Our businesses, factories, andfarms also depend on water. It takes almost 40,000 gallonsof water to manufacture a car; 60,000 gallons to produce aton of steel; and 1,500 gallons to process a barrel of beer.

Most of the time, we take our water for granted, and forgood reason—it’s readily available and doesn’t cost much.The fact is water’s a bargain, costing on average only about$2 for every 1,000 gallons of water supplied to a home. Andmost of the time we assume that our water will always beavailable, plentiful, and clean.

But we all know that when gasoline leaks from an under-ground tank it can easily contaminate the surroundinggroundwater. In fact, some states have identified USTs as theleading threat to groundwater, the source of drinking waterfor half of all Americans. And when a water source is contam-inated, a lot of time, effort, and money go into cleaning it up,treating the groundwater, rehabilitating the aquifer, or findingan alternative water supply.

Prevention Is Essential We know that preventing a release by making sure petroleumdoes not contaminate soil and groundwater in the first placecosts much less than cleaning up a leak after it has polluted theenvironment. I’m pleased that we’ve seen confirmed releasesdrop significantly—approximately 35 percent over the lastyear. So, we need to continue that trend and heed BenFranklin’s byword—“An ounce of prevention is worth a poundof cure”—and do everything possible to prevent releases anddetect them early.

In the United States, we have a universe of about660,000 federally regulated tanks. It is important to inspectthese tanks on a routine basis to ensure that they are oper-ated and maintained correctly and that the tank systems arein compliance with release-prevention and leak-detectionrequirements. Inspections are an important tool in determin-ing whether owners and operators are operating and main-taining their systems correctly.

Yet inspection rates vary greatly across the UnitedStates—from once every year in some states to no more thanonce every ten years in others. I know it takes moreresources—people and money—to increase inspections, butthat investment will pay off manyfold.

I urge you to make prevention a priority and use some ofthe creative prevention approaches we’ve developed together.Consider taking the following actions:

• Adapt the environmental results program (ERP) to helpimprove owner and operator compliance with tank regu-lations.

• Target UST facility inspections in source-water protec-tion areas.

• Use our recently released UST-LUST Virtual Classroomto more efficiently train inspectors (http://www.epa.gov/oust/virtual.htm).

• Implement a third-party inspection program.

Cleanup Is Our Responsibility Together we’ve accomplished much—over the past 20 years,more than 323,000 cleanups have been completed. And justthis past year, more than 14,000 contaminated sites werecleaned up. Nonetheless, we’re seeing a decrease in the paceof cleanups. Over the past year, the cleanup pace has fallenby 22 percent from 18,518 in 2003 to 14,285 in 2004.

Although the cleanup backlog—currently at 125,000—isat its lowest level since 1992, we still need to aggressivelytackle the backlog and each year do our best to achieve ourcleanup goals. I understand that some of the remainingcleanups are those that are more complex and may requirelengthier cleanup processes because of complications, includ-ing contamination from MtBE.

But we know it is important for our country’s environ-ment and America’s citizens that we work diligently to cleanup sites. I urge you to apply some of the creative approacheswe’ve jointly developed. Consider taking the following steps:

• Target source-water areas to make the best use ofresources to reduce the risks UST releases pose to drink-ing-water sources.

• Streamline cleanups to complete them faster andcheaper by:– Developing multi-site agreements– Using the Triad approach where stakeholders evaluate

sites and make cleanup decisions collaboratively – Applying lessons learned from optimizing cleanups at

difficult sites in pilot states – Using pay-for-performance contracting.

• Apply some of the lessons learned from existing MtBEsites.

And through petroleum Brownfields grants, we need tofacilitate cleanups in order to foster productive reuse—asparks or recreation centers or municipal buildings—of sitesthat previously blighted the surrounding communities.

We’re Partners in This WorkTogether states, tribes, local governments, and industry—along with EPA—have done a great job of protecting Amer-ica’s precious water resources. I thank each of you for yourdetermination and tenacity and willingness to tackle thishuge job. And I remind you that we still have so much moreto do to ensure that future generations of Americans cancontinue to drink, use, and play in clean water. ■

11


What South Carolina Is LearningAbout Ethylene Dibromide (EDB) at LUST Sitesby Read Miner


Sout

h Car

olina

On a daily basis, each state rou-tinely reviews numerousreports documenting assess-

ment and corrective-action activitiesat UST sites. Commonly, projectmanagers review the projects andmake decisions based on the needs ofeach individual project. Staff rarelyhave the time or resources to compilethe data from numerous sites inorder to look for common trendsamong sites, or to understand thebehavior of a particular chemicalsuch as ethylene dibromide (EDB or1,2-dibromoethane). Because ofEDB’s toxicity and prevalence, theSouth Carolina Department ofHealth and Environmental Control(DHEC) UST program determinedthat an in-depth inquiry was neces-sary to evaluate policies regardingthe chemical.

EDB and 1,2-dichloroethane (1,2-DCA) were both part of an antiknockadditive package used in leadedgasoline from the 1920s through the1980s. (See “Leaded Gasoline?” onpage 15 to learn how leaded gasolineand these additives are used today.)Although approximately 90 percentof the EDB in the United States wasused in leaded gasoline during thattime period, it was also used as a pes-ticide until approximately 1984.

The DHEC UST program firststarted testing for EDB at LUST sitesin the early 1990s. Initially, werequested that U.S. EPA analyticalmethods 8260 and 8260B be used.However, because of the toxicity ofEDB and its corresponding maxi-mum contaminant level (MCL) of0.05 µg/L, these methods were foundto be insufficient since their reportinglimit was 5 µg/L. EPA analyticalmethod 8011, with a lower reportinglimit of 0.02 µg/L, is now our stan-dard. Last year, 1,2-DCA was addedto the list of analytes using EPAmethod 8260B.

Our database allows us to elec-tronically track the concentrations ofchemicals of concern at specific USTsites. During 2003, Nimeesha Bul-

sara, a Clemson University graduatestudent, queried the database todetermine the occurrence of EDB atUST facilities in South Carolina aspart of her thesis. The results werelater published (Falta and Bulsara2004 and Bulsara 2004).

Additional database queries byClemson University students JamesHenderson and Richard Mayer wereconducted in December 2004 to buildon Bulsara’s research. They foundthat approximately half of the USTsites assessed to date in South Car-olina contain EDB in the groundwa-ter (R. Falta et al. 2005). Thesefindings prompted UST programstaff to conduct a random survey of104 of the confirmed EDB sites to bet-ter quantify the magnitude of theEDB problem.

Distribution of EDB in South CarolinaThe 104 facilities included in the ran-dom survey are located in 14 coun-

ties. Nine of the counties are in thecoastal plain (primarily sedimentarysurface lithologies), and five countiesare in the piedmont province (com-posed primarily of metamorphic rockand saprolite). Sediments at the facili-ties range from relatively clean sandsto silty sands, sandy silts, and clayswith a full range of seepage velocities.

We reviewed the technical filesfor each facility and recorded the fol-lowing information: permit number,county, UST installation date, numberof wells in the monitoring network,number of monitoring wells contain-ing EDB, highest benzene and EDBconcentrations, length of the BTEXand EDB plumes, and seepage veloc-ity.

The data were evaluated andseveral summary figures were pre-pared. Figure 1 depicts the percent-age of sites where EDB was detectedwithin a given range of concentra-tions, reflecting the highest concen-trations detected at each facility. Thehighest concentration of EDBdetected to date in groundwater at aSouth Carolina UST site was 6,550µg/L. Approximately 1 percent offacilities with EDB had concentra-tions exceeding 1,000 µg/L. Almosthalf of the sites had EDB concentra-tions of less than 5 µg/L. This is animportant finding, as concentrations

are routinely found at levels belowthe reporting threshold of some ana-lytical methods.

If an analytical method such asEPA method 8011 or an equivalentmethod that can achieve a reportinglimit of <0.02 µg/L were not used,approximately half of the EDB

Concentration (ppb)0.05-4.99 5.24 25-99 100-499 500-1,000 >1,000

60.0

50.0

40.0

30.0

20.0

10.0

0.0

% o

f Fac

ilitie

s

FIGURE 1. EDB concentrations at UST facilities.

plumes in excess of the federal MCLwould go undetected.

Figure 2 plots benzene versusEDB concentrations. The benzeneconcentration was assumed to be40,000 µg/L for each site containinglight non-aqueous-phase liquids(LNAPL). Benzene and EDB concen-trations do not appear to be corre-lated. This lack of correlation couldreflect many possible factors, includ-ing, but not limited to, unknownrelease dates, multiple super-imposed releases at each facility, anddifferential degradation rates foreach chemical.

Figure 3 depicts the percentageof sites in the survey with EDB plumelengths falling within a given range.Although EDB plumes as long as2,800 feet have been confirmed atUST facilities in South Carolina,approximately 87 percent of the EDBplumes appear to be limited to within250 feet of the USTs, lines, and dis-pensers. At about half of the EDBsites, the length of the EDB plumeapproximates the dimensions of theBTEX plume. Approximately 44 per-cent of the sites have longer BTEXthan EDB plumes and approximately6 percent of EDB plumes exceed thelength of the BTEX plumes.

Unfortunately, EDB’s fate andtransport mechanisms are not verywell understood. Based on EDB’s lowHenry’s constant, low retardation,and recalcitrance to biodegradation,one would expect most EDB plumesto exceed the length of the BTEXplumes. That the opposite was foundmay be a direct result of the limita-tions of typical assessment tech-niques.

In South Carolina, petroleumplumes are typically defined usingdirect-push equipment and the semi-quantitative analysis of organic con-centrations using field-screeningmethods capable of producing real-time field data. The results of the fieldscreening are then used to determinethe optimum number and location ofmonitoring wells and appropriatescreened intervals to define the BTEXand MtBE plumes in three dimen-sions. Unfortunately, typical field-screening methods, such as PID, FID,Immunoassay, and HACH Test Kits,do not achieve the required reportinglimit for EDB of .02 µg/L. Further-

more, PIDs and FIDs only look atvolatiles.

Based on a review of numerousmaps, the longer EDB plumes arecommonly very narrow, cigar-shaped features. In addition, EDBcommonly dives with increasing dis-tance from the source. Many caseswere also noted where EDB was pre-sent in the deep monitoring wells butwas no longer present in the shal-lower water table bracketing wells.Because of these behaviors, it is likelythat an EDB plume may be missed by

a monitoring well network designedfor BTEX or MtBE. Field-screeningmethods and monitoring networksmay need to be modified to betteraddress EDB.

Figure 4 plots the length of eachEDB plume against its correspondingseepage velocity. Facilities with highseepage velocities but very short EDBplumes cannot be explained with theavailable data. A short plume may becaused by factors other than the seep-age velocity, such as biodegradation,or could indicate that the main EDB

12


EDB Concentration (ppb)1,0008006004002000

45,00040,00035,00030,00025,00020,00015,00010,0005,000

0Benz

ene

Conc

entra

tion

(ppb

)

FIGURE 2. Benzene concentrations in relation to EDB concentrations.

Length of Plume (feet)

<100 100-250 251-500 501-800 >800

70

60

50

40

30

20

10

0

% o

f Fac

ilitie

sFIGURE 3. Lengths of EDB plumes at UST facilities.

Seepage Velocity (feet/year)

250200 300 350150100500

900800700600500400300200100

0

Leng

h of

Plu

me

(feet

)

FIGURE 4. Lengths of EDB plumes in relation to seepage velocities.

■ EDB at LUST Sites from page 11

plume may be detached from thesource area. The facilities with verylow seepage velocities but long EDBplumes could represent releases thatoccurred more than 50 years ago.This is an important finding becauseit implies that EDB at these sites isvery recalcitrant to biodegradation.

Natural AttenuationFurther evidence of EDB’s possiblerecalcitrance to biodegradationemerged when a large number ofadditional UST releases were evalu-ated for evidence of natural attenua-tion. For each site, the data collectedduring the assessment and subse-quent monitoring phases were com-piled and plotted against time. Eachfacility showed evidence of benzenedegradation (some much more thanothers).

Although the dimensions of theEDB plumes appeared to be stable,clear evidence of any EDB biodegra-dation was not observed in monitor-ing programs lasting as long as threeto four years, where groundwatersamples were analyzed using EPAmethod 8011. Thus, we can reason-ably conclude that if EDB biodegra-dation is taking place, verificationmay require much longer monitoringprograms.

Treatment of SitesContaining EDBThe DHEC UST program establishessite-specific target levels or cleanupgoals for each facility using a risk-based corrective action (RBCA)approach. Because of its toxicity,mobility, and persistence, EDB wasidentified as a chemical of concernmany years ago. Approximately 3percent of the releases of EDB haveimpacted water supply wells. Inorder to restore or protect water sup-ply wells, approximately 6 percent ofthe corrective actions currently inprogress at UST facilities in the staterequire treatment of EDB.

To further our understanding ofEDB, we reviewed the progress ofEDB remediation. The correctiveactions that were reviewed for thispurpose may or may not have beengeared to EDB remediation. Our gen-eral observations, which are summa-rized below, are related to EDB andshould in no way be misconstrued tobe a detailed analysis of site-specific

cleanups or the effectiveness ofcleanup technologies.

For each corrective action, moni-toring wells are sampled every threemonths (quarterly) to track the effec-tiveness of the corrective-action sys-tem. Since the treatment technologiesexamined utilize injection and recov-ery wells, the monitoring wells areused solely to measure groundwaterquality. For each monitoring wellcontaining EDB, we plotted the con-centrations of benzene and EDBagainst time.

■ Air SpargingAir sparging has shown mixedresults for treatment of EDB. In onecase, where the EDB plume was con-fined to the permeable UST basin,

and the air-sparge wells wereinstalled with overlapping radii ofinfluence, the EDB rapidly attenu-ated to below laboratory detectionlimits. In all other cases, the mea-sured concentrations of EDBincreased in the vicinity of the USTssubsequent to the initiation of airsparging. Figure 5 depicts thechanges in EDB concentration afterair sparging began at a site located inJasper County, South Carolina. Inthis example, EDB concentrationsincreased in the UST basin two quar-ters after air sparging commenced.Because EDB has a fairly high vaporpressure and a very low Henry’s con-stant, it is possible that the air sparging

13



FIGURE 5. Temporal change in EDB concentrations near the UST basin.

1 2 3 4 5 6 7 8 9 10 11 120

50

100

150

200

EDB

Conc

entra

tion

(ppb

)

Time (quarters)

FIGURE 6. Temporal change in EDB concentrations 80 feet downgradient from theUST basin.

1 2 3 4 5 6 7 8 9 10 11 120

50100150200250300350

EDB

Conc

entra

tion

(ppb

)

Time (quarters)

FIGURE 7. Temporal change in EDB concentrations 140 feet downgradient from theUST basin.

1 2 3 4 5 6 7 8 9 10 11 120

0.51.01.52.02.53.0

EDB

Conc

entra

tion

(ppb

)

Time (quarters)

may evaporate EDB from the LNAPL,but the vapors may then partition intothe pore water, resulting in elevatedEDB concentrations in the groundwater(R. Falta, personal communication,2005).

Figure 6 depicts the concentra-tions of EDB through time at a pointlocated 80 feet hydraulically down-gradient from the UST basin. A largeincrease in EDB concentration wasseen five quarters after air spargingbegan. Figure 7 shows a largeincrease in EDB 140 feet hydrauli-cally downgradient from the USTbasin during the seventh and tenthquarters after air sparging started.Although it is clear that air spargingis remobilizing some of the EDB, it isunknown to what extent the EDBmay be volatilized or bioremediated.

■ Chemical Oxidation At some EDB sites treated withhydrogen-peroxide injection, EDBconcentrations have increased (twoyears into cleanup) above precleanuplevels with subsequent erratic con-centration fluctuations. At other sites,EDB degradation is suggested. In allcases, remobilization of EDB is indi-cated.

■ Enhanced In Situ BioremediationIn the enhanced in situ bioremedia-tion cases that were observed, EDBconcentrations in the source areaincreased by one to two orders ofmagnitude subsequent to injection ofthe mixtures, and either continued toincrease or fluctuated significantlyduring the first two to three years ofcorrective action. No verifiable atten-uation of EDB was observed at any ofthe enhanced in situ bioremediationsites. Note: Although it has not yet beenproven, research suggests that EDB maydegrade better in highly anaerobic set-tings. If this is true, the addition of oxy-gen to enhance BTEX degradation mayhinder the EDB breakdown process (R.Falta, personal communication, 2005).

■ Phoster II™Phoster II, a patented technologywhereby air, nitrogen, and phospho-rous are injected into the ground as avapor to make the nutrients morereadily available to the microorgan-isms, has shown positive results atone site where EDB was present. Atthis site, the EDB concentration

increased from 31 to 49 µg/L oneyear after treatment began. However,during the subsequent two years oftreatment, EDB has shown an overallreduction to 1 µg/L. Additional mon-itoring of the ongoing correctiveaction will be necessary to determinewhether this technology can reduceEDB to less than 1 µg/L.

■ Pump-and-Treat/ Bioremediation CombinationEDB reduction has been favorable attwo sites where a combination ofpump-and-treat and bioremediationis being used. The cleanup strategy ateach of the facilities is to pump thegroundwater from the ground, treatthe water aboveground using an airstripper, treat the water in a bioreac-tor, and subsequently polish thewater using granular activated car-bon. Nutrients are then added to thetreated water prior to subsurfacereinjection into the plume.

This treatment successfullyreduces EDB concentrations from ashigh as 1,100 µg/L to less than 0.02µg/L a majority of the time. How-ever, sporadic breakthrough of EDBat concentrations less than 1 µg/Lhas been noted. While concentrationsof benzene and EDB have decreasedfavorably in monitoring wells locatedin the near-source portion of theplume (within the capture zone of thepumping wells), monitoring wellslocated on the perimeter of the plume(outside the capture zone of thepumping wells) that were historicallyclean are now showing low concen-trations of EDB. Although pump-and-treat/bioremediation appears tobe an effective combination for treat-ment of EDB, complete containmentof the plume is still critical givenEDB’s high mobility.

Can We Afford to Ignore EDB?Although a lot of work is still neededto understand EDB at UST sites, it isimperative that we expend time andeffort to quantify its presence at eachrelease where it is likely to have beenpresent and make appropriate risk-based responses to protect humanhealth and environmental receptors.EDB is found at approximately halfthe releases that have been assessedin South Carolina. It is toxic, mobile,and persistent. Natural attenuation ofEDB is very slow and cannot berelied on in time-sensitive cases withthreatened receptors.

The cleanup of EDB is necessaryat some sites. The available data fromSouth Carolina sites currently in cor-rective action suggest that the com-monly employed technologies forbenzene treatment may not work aseffectively for EDB.

Research NeedsEDB presents many research needs.A better understanding of the distrib-ution of residual EDB in the sourceareas is critical to developing a goodcorrective-action strategy. We needto better understand EDB’s fate andtransport properties as well as itsdegradation pathways and processes.Once these factors are better under-stood, treatment techniques need tobe adapted accordingly to maximizethe removal efficiency for BTEX,MtBE, and EDB. ■

Read Miner is a Hydrogeologist withthe South Carolina Department ofHealth and Environmental Control

Underground Storage Tank Program.He can be reached at

[email protected]. For moreinformation on EDB in the environ-

ment, see LUSTLine #47, “Lead Scav-engers: A Leaded Gasoline Legacy?” by

Ron Falta and Nimeesha Bulsara.

ReferencesBulsara, N., “The Occurrence of the Lead Scavengers

Ethylene Dibromide and 1,2-Dichloroethane inGroundwater from Leaking Gasoline UndergroundStorage Tanks with a Case Study in South Car-olina,” MS Thesis, Clemson University, December2004.

Falta, R. W. and Bulsara, N., “Lead Scavengers: ALeaded Gasoline Legacy?” LUSTLine, New EnglandInterstate Water Pollution Control CommissionBulletin 47, pp. 6–10, 2004, http://www.neiwpcc.org/lustline.htm

Falta, R. W., Bulsara, N., Mayer, R. A., and Hender-son, J. K., “EDB Contamination from Leaded Gaso-line,” Underground Tank Technology Update, Vol. 19,No. 2, pp. 2–5, March/April 2005.

14


■ EDB at LUST Sites from page 13

Because of these behaviors, it is

likely that an EDB plume may be

missed by a monitoring-well

network designed for BTEX or MtBE.

Field-screening methods and

monitoring networks may need to be

modified to better address EDB.

Lead Lives!...Off RoadLeaded gasoline was widely pro-duced and used throughout theUnited States from the early 1920suntil the phase-out of leaded gasolinebegan in 1973 and was finalized in1996, when the Clean Air Act bannedthe sale of leaded gasoline for “on-road” vehicles. Generally, for thepurpose of the ban, all cars, trucks,and buses that are driven on streetsand highways are considered on-road vehicles.

Most people today assume thatleaded gasoline no longer existsbecause it’s not usually available forsale at most gasoline refueling sta-tions. However, pilots of small-pis-ton-engine-powered aircraft anddrivers of off-road vehicles, such asracecars and racing boats, are wellaware of the existence of leaded fuel.The types of piston-driven enginesfound on small, general-aviation air-craft, racecars, and the like havehigher performance requirementsdue to their high compression ratios.

Leaded fuels found today usu-ally contain much higher amounts ofoctane-enhancing antiknock addi-tives than normal unleaded fuelsand, as a result, leaded fuels are thefuels of choice for use in high-perfor-mance, piston-powered engines. TheClean Air Act did not ban the use ofleaded fuels in aviation and off-roadvehicles.

What’s in Leaded Aviationand Racing Fuels?In an attempt to determine what ispresent in various leaded-gasolineformulations, I conducted a limitedsearch on the Internet for publiclyavailable Material Safety Data Sheets(MSDS) from the websites of varioussuppliers and manufacturers ofleaded aviation and racing fuels. Ineeded this information to supportcomments I was preparing for a draft

document being compiled on thelead scavengers ethylene dibromide(EDB) and 1,2-dichloroethane (1,2-DCA).

I obtained four MSDS from thewebsites of four different suppliers ofleaded aviation fuels. The leaded avi-ation fuel most commonly used inreciprocating piston-engine aircraft isknown as Avgas, and it is usuallyfound in two main grades—Avgas100 and Avgas 100LL (low lead). Thenumber 100 represents the octane rat-ing of the fuel.

Avgas 100 has a high lead con-tent and is dyed green for identifica-tion purposes. Avgas 100LL is thelow-lead version of Avgas 100 and isdyed blue. Avgas is available in avariety of other octane ratings, butthe Avgas 100 octane rating appearsto be the most common. I also foundout that Avgas fuels should not beconfused with other aviation turbinefuels, such as jet fuels, as these fuelsare unleaded. Both Avgas 100 and100LL grades contain tetraethyl lead(TEL), chemical abstract service(CAS) number 78-00-2, which is usedas an anti-knock additive.

I also obtained a number ofMSDS from the websites of two rac-ing-fuel suppliers. All of these MSDSalso indicated that TEL was a con-stituent in the fuel formulations.

All of the MSDS had the stan-dard laundry list of CERCLA haz-ardous substances that are usuallyand customarily found in gasoline,such as benzene, toluene, ethyl ben-zene, and xylene (BTEX). But I dis-covered something was apparentlymissing in all of the MSDS except oneof the Avgas 100LL MSDS.

Where There Are LeadedFuels, There Must Be LeadScavengers!Recent articles by Dr. Ron Falta ofClemson University have covered a

considerable amount of informationon EDB and 1,2-DCA, and I will notduplicate all of that information here.(See LUSTLine #47, “Lead Scav-engers: A Leaded Gasoline Legacy?”)But as a quick refresher, both EDBand 1,2-DCA are synthetic organicchemicals used as lead scavengers inleaded gasoline to prohibit the for-mation of lead oxides on spark plugsand exhaust valves in piston enginesduring combustion.

Recently, I was involved in anenforcement action and subsequentcourt case involving USTs at an air-port that stored Avgas. The enforce-ment action required that thecontents of the tanks at the airport besampled and analyzed. One of thetanks stored viable Avgas 100LL fuel.The volatiles scan of the Avgas 100LLsample indicated that EDB was pre-sent in the fuel at 460 milligrams perkilogram (mg/kg). The amount ofbenzene detected in the sample was120 mg/kg. My experience on thisenforcement case alerted me to thefact that EDB was a constituent inAvgas. I wondered why only one ofthe Avgas 100LL MSDS listed EDB asa constituent of the leaded gasoline’sformulation and the other AvgasMSDS did not.

The Quest for MoreKnowledgeI contacted one of the Avgas suppli-ers whose 100LL MSDS did not listany lead scavengers and inquiredabout the apparent omission of EDB.At the outset, a number of represen-tatives denied that EDB was an ingre-dient in the company’s Avgasformulations in accordance with itsMSDS. Not satisfied with theseanswers, I inquired further until Imade contact with an engineer whowas knowledgeable about the com-pany’s aviation fuels and their for-mulations.

15


Leaded Gasoline?Hmm, What’s in Those Underground Storage Tanks?by Steven Burton

A common misperception today is that leaded gasoline no longer exists. To most people, leaded gasoline is a relic of the past—gone with the wind. In reality however, leaded fuels are still produced today and used primarily in small-aircraft aviation and certain off-road vehicles. These leaded fuels are sometimes stored in USTs. As I have learned, determining the specific constituents of leaded gasoline presents a challenge.

32PETROIL

V I S T

V A L V O I L


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At first, he also denied that EDBwas contained in the company’sAvgas 100LL fuel. I then asked, ifEDB was not a constituent in theAvgas 100LL, then what substancewas being used to prevent the forma-tion of lead oxides on the spark plugsand exhaust valves during combus-tion? He replied that he did not knowbut would find the answer. Later, hecontacted me and revealed that EDBwas, in fact, a constituent in theAvgas 100LL. He further explainedthat EDB was apparently an additivein the TEL package the company pur-chased from a foreign supplier. Thecontents of the TEL package areblended in during the production ofthe Avgas 100LL fuel.

Later, I contacted a supplier ofleaded racing fuels whose MSDS Iobtained from the Internet did not listany lead scavengers and inquiredabout what substances were beingused as lead scavengers in the com-pany’s racing fuels. Again, I wastransferred a number of times withinthe company in an attempt to findsomeone who could answer my ques-tions. Finally, I made contact with aknowledgeable company representa-tive who informed me that the com-pany’s leaded racing fuels did indeedcontain both of the lead scavengersEDB and 1,2-DCA.

The TEL TellsIn subsequent discussions with theseleaded-fuel suppliers, I was informedthat two suppliers provide TEL anti-knock-compound packages that areused in the production of Avgas andleaded racing fuels in the UnitedStates. I also discovered that bothTEL suppliers obtain their productfrom the only remaining site in theworld that actually manufacturesTEL. This manufacturing site islocated in Europe.

I contacted both TEL suppliersand obtained copies of the MSDS fortheir respective TEL packages. All ofthe MSDS listed either 1,2-DCAand/or EDB as an ingredient in theTEL package formulations. Repre-sentatives from the TEL suppliersinformed me that generally two TELpackages are produced, one forAvgas and another for racing fuels.

Only EDB is used as a leadscavenger in Avgas. Both EDB and

1,2-DCA are usually included as leadscavengers in racing fuels, but someracing fuels may contain only EDB.After further examination of the TELMSDS, I found it interesting that theconcentration of EDB in the TELpackage for Avgas is 35.73 percent byweight as compared to 17.86 percentin the TEL package for racing fuels.1,2-DCA is also found in leaded rac-ing fuels at 18.81 percent by weight.

Be AwareI have learned a couple of valuablelessons thus far from this exercise.First, lead scavengers are not to befound just at older UST release sites;they are still key ingredients inAvgas and racing gasolines. Second,MSDS do not necessarily list all of theenvironmentally significant ingredi-ents found in leaded fuels. So, whenresponding to releases from tanksstoring these products, be aware thatthe MSDS may not identify all of thechemicals of concern, such as EDB or1,2-DCA. Because of the extremelylow MCL for EDB in drinking water,

this could be especially critical infor-mation at sites where direct exposureis a concern.

Stay TunedThe Occupational Safety and HealthAdministration (OSHA) within theDepartment of Labor is the federalagency responsible for setting thestandards for MSDS. Copies of thevarious MSDS I obtained from theInternet have been forwarded toOSHA’s Atlanta Regional Office forassessment regarding compliancewith OSHA’s rules and require-ments. The results of their reviewmay be discussed in a future LUST-Line article. ■

Steven Burton is an EnvironmentalScientist with U.S. EPA Region 4 and

manages the Region’s LUST TrustFund. He can be reached at

[email protected]. For moreinformation about lead scavengers, visit

EPA’s Lead Scavengers website athttp://www.epa.gov/oust/

pbscavms.pdf.

■ Leaded Gasoline from page 15

NEIWPCC Publishes Source- Water Protection Guideby Kara Sergeant, NEIWPCC

What steps can municipal officials take to protect public drinkingwater supplies? NEIWPCC provides the answers in Water Today…Water Tomorrow? Protecting Drinking Water Sources in Your Commu-nity: Tools for Municipal Officials, a new 52-page guide funded by U.S.EPA. The target audience of municipal officials includes town employeesand volunteers on planning boards, conservation commission members, and other related posi-tions. These are the people with the power to make decisions at the community level, such asenforcing a new protective zoning ordinance or starting a septic-tank registration database.

For the most part, states have already begun the protection process by developing usefulSource Water Assessment Program (SWAP) reports that assess potential threats to public watersupplies for each area in the state. NEIWPCC created the guide and a companion series of factsheets to help officials understand these reports and identify ways they can implement protec-tion at the municipal level. The guide even provides useful ideas for towns with mostly privatewells.

The guide focuses on five key areas of vulnerability as identified by state groundwater andsource-water protection managers—local regulations and ordinances, underground storagetanks, on-site sewage disposal systems, hazardous materials storage, and stormwater runoff.The guide features background materials for those who want to learn the basics of source-waterprotection, and specific strategies for action on each of the five topics. The guide is color-coded,so it is easy to find information on septic systems, for example, if that is the main concern in acommunity. Each of the five topic chapters contains several case studies showcasing ways othertowns and communities have addressed those problems.

Written and designed for NEIWPCC by Enosis–The Environmental Outreach Group, theguide and fact sheets have been widely distributed, and only a limited number of printed copiesremain. At this time, we must limit orders to one set of materials. The shipping charge for oneset of fact sheets and a guide is $2.50. To order a copy, send your name, address, and phonenumber to NEIWPCC at the address on the back of LUSTLine. The guide and fact sheets can alsobe downloaded for free at our website (www.neiwpcc.org/sourcewateroutreach).

For more information about the project, contact Kara Sergeant at [email protected].

The Risk FocusAs a response, the Region began uti-lizing a groundwater-endangerment-risk analysis approach in 2002.Charles Hillenbrand, of U.S. EPARegion 2, laid the groundwork bycreating a regional Groundwater-Endangerment-Risk Map for NewYork State in 2001. This map consid-ers the following key factors:

• Risk of introducing contaminantsat or near the surface of the earthas a function of land use

• Susceptibility of aquifer systemsto contamination, which is afunction of vertical linear veloc-ity of the unsaturated zone andthe depth to the water table

• Human use of groundwater as asource of drinking water.1

To utilize Hillenbrand’s hydro-geological analysis, the followingmap layers are imported:

• State/federal facility information

• Dunn and Bradstreet commerciallistings

• North American Industry Classi-fication System (NAICS) data

• Land-use information from theUSGS

• Census data on sewered/non-sewered communities.

These combined data layers indi-cate the geographic regions with thegreatest potential for rapid transportof contamination to drinking water—high-risk areas. With this informa-tion, the UST/UIC program thenutilizes ArcMap 9.0 to review inspec-

tion referrals, decide on focus areas,and interpret and address agency pri-orities (e.g., Environmental Justice,Children’s Health Initiative).

How Is the Risk Map Used?With the information input into GIS,EPA focuses on facilities that typi-cally use significant quantities of haz-ardous substances and that arelocated in areas with the followingcharacteristics:

• relatively fast surface-to-ground-water travel rate

• groundwater serves as the pri-mary source of drinking water(public and/or private)

• no public wastewater treatmentsystems (nonsewered).

UIC Inspection-TargetingResultsIn October 2002, the UST/UIC pro-gram began using the Risk Map forUIC Class V wells, targeting wellinspections in NYS. The law definesan injection well as any bored,drilled, or driven shaft or dug holeused to discharge fluids under-ground, where the depth is greater

than the largest surface dimension(length or width) of the disposal facil-ity. UIC Class V wells are shallowwells that inject nonhazardouswastes. They are typically on-site dis-posal systems, such as floor and sinkdrains, leach fields, and similar typesof drainage wells. This categoryincludes the motor-vehicle waste-dis-posal wells that are the subject of thisreport.

Table 1 displays the results ofUIC Class V well inspections per-formed during the first half of fiscalyear 2003 as compared to UIC facilityinspection results from the first halfof fiscal year 1997. The table consid-ers facilities that have been inspectedand located by a global positioningsystem (GPS).

As shown in Table 1, of the 185inspections performed in 1997, 29 UICClass V wells were discovered. Ofthese wells, only two were located inareas of significant groundwater-endangerment risk (GER). The 1997rate of UIC Class V well discovery perinspection was 16 percent, but only 1percent of the inspections yielded UICClass V wells in areas of significantgroundwater-endangerment risk.

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Total Percentage GPSed Class V Percentage Wells in of Wells UIC Wells of Wells High GER found in

Fiscal Year Inspections Discovered Discovered Areas GER Areas

1997 185 29 16% 2 1%

2003 235 78 33% 78 33%

SUMMARY OF UIC WELL IDENTIFICATION—1997 AND 2003.TABLE 1


10,000 Facilities to Inspect!GIS Shines a Light in the Long, Dark Tunnelby Rebecca Jamison

Problem #1: More than six million people depend on groundwater as a source of drinking water in New York State (NYS)(NYSDEC, 1986; NYSDEC, 1987). Many of these drinking-water source areas are underlain by highly permeable aquifer systemsthat are vulnerable to contamination.

Problem #2: U.S. EPA Region 2 Ground Water Compliance Section (GWCS) (http://www.epa.gov/docs/Region2)extensively supports the UST programs of New York, New Jersey, the Virgin Islands, and Puerto Rico and directly implements theUnderground Injection Control (UIC) programs in New York and the Virgin Islands. With a staff of 12 inspectors (five UST andseven UIC), GWCS faces a huge challenge in implementing the programs. With a potential 120,000+ UIC locations in NYS alone,and hundreds of UST referrals, our inspection staff faces a daunting task in determining where to go. Which areas are most vulnera-ble to contaminants and which communities should we focus on first?

Table 1 also shows that in 2003,235 UIC Class V well inspectionsyielded the discovery of 78 UIC ClassV wells in areas of significant ground-water-endangerment risk. In 2003,UIC Class V well inspections yielded aClass V well discovery rate of 33 per-cent; the rate of discovery of UIC ClassV wells in areas of significant ground-water-endangerment risk was also 33percent.

UST Inspection-TargetingMethodologyFor UST inspection targeting, NYSUST registration data is used to postUST facilities in areas of significantgroundwater-endangerment risk.The UST/UIC GIS liaison then identi-fies UST facilities for inspectionbased on (a) the risk rankings and (b)desired focus (e.g., location, sector).A map and a spreadsheet are createdto reference pertinent UST data andinformation. Both are provided to theinspectors in advance of their deploy-ment.

Another target that may be con-sidered when conducting USTinspections is a location where vaporintrusion may be an issue. Vaporintrusion is the migration of volatilechemicals from the subsurface intooverlying buildings. Volatile chemi-cals in buried wastes and/or in cont-aminated groundwater can emitvapors that may migrate through thesubsurface and into air spaces ofoverlying buildings.2

Adapting for ChangingPrioritiesIt is very easy to incorporate new andemerging policy areas into GIS for usein program planning and goal setting.Within the last year, we havesmoothly integrated emerging agencypriorities into our overall methodolo-gies. Below are three examples.

■ Source Water Assessment ProgramDuring the past few years, thenational UST program has put anemphasis on conducting more fre-quent inspections in Source WaterAssessment Program (SWAP) areas.A source-water assessment is a studyand report that provides basic infor-

mation about the source used to sup-ply drinking water to a particularwater system. The assessment identi-fies drinking-water sources and theareas of land that most directly con-tribute the raw water for thosesources. Assessments also identifythe major potential sources of conta-mination of drinking-water supplies.This information is used to determinehow susceptible a water system is tocontamination.3

Region 2 has the ability and datato include NYS surface water areas(reservoirs and their drainage basins)in targeting analyses. Surface water isalso used in heavily populated areasof New York, such as Syracuse (Hem-lock and Candace Lakes), New YorkCity (Croton Reservoir watershed),and Albany (Alcove Reservoir).

With our mapping work, EPARegion 2 is at the forefront of coordi-nating UST and SWAP information.Much of the GIS mapping done bythe GWCS from 1999 to 2004 incorpo-rated 500-meter buffers around pub-lic water supply wells. As the SWAPareas are officially defined by stateand local agencies, EPA reviews NewYork’s UST risk areas (ranked from 1to 3) and incorporates them into des-ignated SWAP areas. Currently, theNYS SWAP areas are in our highestrisk categories, levels 1 and 2.

■ Environmental JusticeIn 2004, Region 2 identified a poten-tial Environmental Justice (EJ) area inRochester, New York. All media pro-

grams were asked to participate inproviding compliance assistance andenforcement to the community.Using the targeting methodologydescribed earlier, we faced a chal-lenge. Given that Rochester (a) islargely sewered, (b) has its source ofdrinking water located at two reser-voirs south of the city, and (c) has nofederally regulated UST facilitieswithin the prescribed EJ area, howcould we support the Region’s RochesterEJ initiative?

Using our Risk Map, we focusedon facilities around the two reser-voirs south of Rochester as targets forUST/UIC inspections, and createdbuffer zones around the GeneseeRiver on the western boundary ofRochester. The Genesee River origi-nates in Pennsylvania and ends atLake Ontario in Rochester. The upperGenesee River (southern New York)is a well-known destination forbrown trout fishing, and in Rochesteritself surprising catches of salmonhave been noted. The east bank of theGenesee in Rochester proper has ahistory of heavy industrial usage.

Therefore, to support theRegion’s EJ initiative, we focused onthe Monroe County portion of thesource of water for the EJ neighbor-hood and on the urban GeneseeRiver, which is still heavily fished.Then, utilizing Dunn and Bradstreetand the New York State PetroleumBulk Storage databases, we targetednearly 100 facilities for the initiative.

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FIGURE 1. Woodstock, New York Area, with Focus on UST/UIC Targets in Risk Areas■ GIS from page 17

High Risk Level 1High Risk Level 2 High Risk Level 3Inspection Targets

■ Changing Priorities andAddressing Public ConcernsWhen public concerns arise via thepress, governmental leaders, or otheravenues, the Risk Map has proven tobe a very adaptable and flexible toolwhile still ensuring the program’sfocus on protecting groundwater.When a particular business sector isidentified, by using an existent data-base, such as state or federal registra-tion information (e.g., environmentalor Department of Motor Vehicles)and/or commercial listings (e.g.,Dunn and Bradstreet and NorthAmerican Industry ClassificationSystem (NAICS) identification), datapulls can be undertaken to identifypotential facilities for review, com-pliance assistance, and inspections.

The map can also focus in on par-ticular geographic features, such as ariver, lake, or pond, a watershed area,or a village, town, or county. A lot ofthis information is now readily avail-able from commercial (ESRI), state (GISprograms), and federal sources (e.g., U.S.Geoglogical Survey, U.S. EPA).

Cutting Down Hunting TimeThe enormous amount of timeinvested in creating and organizing agroundwater protection mappingsystem has paid off in how expedi-tiously we are now able to handlesuccessive projects. This approachhas reduced the targeting processfrom a multi-day analysis to one thatcan be accomplished in less than anhour, which includes generating acomplete list of facilities and a largemap for the inspector. Providing amap to an inspector is a valuabletime-saver, especially if the inspectoris conducting routine inspectionsalone rather than as part of a team.Maps can be prepared that show thelocations of targeted facilities, majortransportation routes, nearby waterbodies including rivers and lakes,public water supply wells, and anyother information an inspector feelsmay be helpful. (See Figure 1.)

Overall, the use of GIS helps usto refine our focus through objectiveand measurable processes, assists us

in our endeavors to safeguard drink-ing-water sources, and affords usconsiderable time savings in target-ing our compliance-assistance andinspection efforts. Using GIS hasimproved our ability to identify envi-ronmentally sensitive areas and spe-cific or potential threats to thoseareas. Overall, our planning and effi-ciency in protecting the environmenthave been dramatically improved. ■

Rebecca Jamison is a UST and UICInspector at EPA Region 2. She alsoconducts targeting for the two pro-

grams using the Hillenbrand hydro-geological model in GIS. She can be

contacted [email protected].

Notes1 Hillenbrand, City University of New York, 20022 Evaluating the Vapor Intrusion into Indoor Air.

United States Environmental Protection Agency.November 2002, EPA530-F-02-052 http://www.epa.gov/correctiveaction/eis/vapor/f02052.pdf

3 EPA Source Water Assessment Program website,http://www.epa.gov/safewater/protect/assessment.html

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Methodology: Groundwater-Endangerment-Risk Analysisby Charles Hillenbrand

The use of GIS technology hasallowed U.S. EPA Region 2 toprioritize areas for inspection

in New York State (NYS). A ground-water-endangerment-risk (GER) gridwas devised based on a modifiedHuman Health Risk Index (HRI) for-mula (Carney 1991). A GER value isthe result of dividing a land-use risk1

by aquifer susceptibility2 and multi-plying the result by the ratio of apopulation dependent upon ground-water as a source of drinking waterto a total population.3

The risk-ranking scheme used tocreate the GER grid is analogous to amodified HRI formula (Carney1991). The HRI is equal to the prod-uct of Hazard and Exposure.

HRI = Hazard x Exposure

Hazard = ( DI x DV )Exposure = (( PE / PC ) x Ef )

DI = Degree of Impact

DV = Degree of VulnerabilityPE = Population ExposedPC = Population in CommunityEf = Exposure Factor

The Hazard component of theHRI formula is a product of Degree ofImpact and Degree of Vulnerability.

The Degree of Impact is a chemi-cal-specific component in the HRIthat assesses the degrees of cancerand noncancer potency, mutagenic-ity, environmental fate, and pharma-cokinetics. The GER analysis uses aland-use-risk data layer4 to assign aDegree of Impact. The U. S. Geologi-cal Survey (USGS) Multi-ResolutionLand Characteristic data layer wasanalyzed to produce a relative-envi-ronmental-risk comparison of the 15different land-use classifications.This analysis assessed the risk ofintroducing contaminants near thesurface of the state.

The Degree of Vulnerability com-ponent in the HRI is a measure of the

vulnerability of the population toadverse reaction due to exposure.Factors such as age, lifestyle, andpre-existing disease are quantifiedwhen selecting a Degree of Vulnera-bility. In the GER analysis, theDegree of Vulnerability was assignedaccording to the hydrogeologic vul-nerability of the aquifer system toreceiving contaminants.

The GER analysis uses an inverseof the aquifer-susceptibility grid as aDegree of Vulnerability component.USGS and NYS Geological Surveyhydrogeologic and geologic data lay-ers were analyzed to produce anaquifer-susceptibility grid for NYS.

Aquifer susceptibility is a valuethat is derived by aerially comparingrelative vadose-zone residence timesunder maximum load. Vadose-zoneresidence time can be a predictor ofaquifer susceptibility—a short resi-dence time indicates that contami-nants may be introduced to the


There are days when you wantto throw your computer outthe window—the network is

slow, it locks up right when you’realmost finished with a time-consum-ing task and haven’t saved yourwork yet, e-mails come flying inevery few minutes, interrupting, cre-ating more stuff to do. But there arealso days when you want to hug itfor making life easier.

I’ve had several projects involv-ing a large number of properties inaddition to the property where tankshave leaked. One of the difficulties indealing with projects like this is that alarge number of property ownersmay need to be notified for one rea-son or another—to sample wells intheir area and send out sampleresults afterward, to notify peopleabout community information meet-ings, or to get permission and signa-tures on permits to install monitoringwells at off-site locations. In the past,we’ve had to sketch out an area in thehope that the county tax office wouldhelp with names and addresses. Thisprocess could take weeks. It was evenharder for many of the consultantsworking on these projects who werefrom out of state.

With the Web, this information isnow available with just a few key-strokes. Each of Delaware’s threecounties now has this informationavailable online. The design of eachof the sites varies, as does the amountof detail available, but the basics arethere. I can get great maps showingtax parcels, and then zoom in to getthe maps to be just about any scale Imight need. Once I’ve located the

parcel numbers, it’s quick to getproperty owners’ names andaddresses.

For one of my projects, located inthe Rehoboth Beach resort area,about half of the property owners arefull-time residents and the other halfare weekend or summer residents.The website gives me the addresseswhere the tax bills are mailed, so Ican reach homeowners in Virginia,New Jersey, or Pennsylvania—wher-ever they call home when they’re notat the beach. Also, I’d much ratheraddress a letter to a real person thanto “Resident,” or something equallyimpersonal.

Once I’ve gotten the names andaddresses that I need, it does takelonger to track down phone numbers.I use a combination of the Internetwhite pages, local phone books, anddirectory assistance.For some areas, we have the criss-cross index avail-able, where I canlook up streetaddresses and getphone numbers formany of the resi-dents. Using a vari-ety of sources, I canusually manage totrack down most ofthe phone numbersfor the residents ina neighborhood.The neighbors aresometimes willingto help out withphone numbers aswell.

Bird’s-Eye ViewsAll three of our county websiteshave been updated so that aerialphotographs are also availableonline. I’ve now got a bird’s-eyeview of any of my sites. I can see alarge area, or I can zoom in andlocate the tank field, the dispensers,and even where some of the utilitiesare that might dictate where moni-toring wells can’t be located. Some-times I can spot other potentialsources without even leaving theoffice! One of the county websiteseven tells me whether there is a base-ment in the building (potential path-way for vapor intrusion), andwhether the property is served bypublic water.

The three county websites varyin their searchability. I can search bystreet address, property owner, or

20


by Patricia EllisWander LUSTW

ander LUSTA roving column by reporter Patricia Ellis, a Hydrologist with theDelaware Department of Natural Resources and EnvironmentalControl, Tank Management Branch. Pat served as a member ofU.S. EPA’s Blue Ribbon Panel on MtBE. She welcomes yourcomments and suggestions and can be reached [email protected].

Screenshot of Kent County “Smart Map” Web page showing a tax-parcel map. Once the tax-parcel number is obtained, a different sec-tion of the county website will give owner information. Differentdata layers can be toggled on and off.

County Websites to the Rescue

parcel number, or I can just keepzooming in until I find my site. Thereare lots of other layers that can betoggled on and off to provide addi-tional information. Two of the threecounty sites tell me the year wheneach building on a property wasbuilt. I know that if most of thehomes in an area with no publicwater were built in the 1950s, I’mprobably not going to be able to getmuch information about well-con-struction details because most of thewells pre-date the permittingrequirements.

The DataMILThe Delaware DataMIL (DelawareMapping and Data Integration Labo-ratory) is a joint project of the UnitedStates Geologic Survey, DelawareGeologic Survey, University ofDelaware, and Delaware GeographicData Committee. It’s an online GIS-based pilot project for the NationalMap (http://datamil.delaware.gov/home.asp). From this website, I can pull upthe most recent topographic maps foran area. The DataMIL allows me tosave maps that I have created and toextract various layers for use in otherGIS projects. The ability to importinformation into other applicationsmakes the DataMIL a more flexibletool than the county websites.

I’ve got parcel maps that I’vedownloaded for most of the projectswhere I deal regularly with a largenumber of residents. It’s a good

graphic display of who’s who in anarea, so when I get calls from resi-dents, it’s easy to visualize wherethey are with respect to the sourceand the plume.

Zoom Zoom ZoomWe recently got a call from our publichealth people reporting a well withMtBE contamination. We were ableto quickly pull up a tax-parcel mapshowing the property and surround-ing area. The aerial photographshowed which properties had homesand farm outbuildings, so we coulddetermine how many propertieswould need to have wells sampled.We made arrangements with the labto have a fairly firm number of sam-ples analyzed. Addresses for allnearby property owners werequickly obtained so residents couldbe notified in advance that ourdepartment wanted to collect wellsamples and why. Having the abilityto pull this information off the Webin advance eliminated the need tomake a preliminary reconnaissancetrip.

So, kudos to each of our threecounties! Their websites may havedifferent designs for providing tax-parcel information, and the amountof detail may differ from site to site.But each of the three counties has cre-ated a tool that helps make at leastone part of managing my projects alittle easier. ■

The New England Interstate WaterPollution Control Commission(NEIWPCC) initiated meetings in

Illinois and Minnesota (Region 5) tofacilitate discussion between UST andsource-water protection (SWP) pro-grams on ways to reduce potentialdrinking-water contamination fromUSTs. Since these programs have lim-ited resources, it makes sense to part-ner together to protect water supplies.The goal of the meetings was todevelop a written agreement, perhapsin the form of a memorandum ofunderstanding (MOU). Both stateswere at different levels of integration,but their programs were split betweendifferent agencies.

The Illinois Source Water Protectionprogram offered to train state UST pro-gram personnel on how to use theGEOcode system—the electronic data-base on source-protection areas andthreats—in order to prioritize inspec-tions in those areas. The UST programagreed to share inspection results withthe drinking-water program. Partici-pants also identified other partners thatplay key roles in implementing thiseffort on the local level, includingboards of health and the Rural WaterAssociation.

The Minnesota Source Water Protec-tion program already has an MOU withits LUST program. An important goalestablished at the meeting was to findout whether the state’s source-waterinventory matches UST location data,since both maintain separate data sys-tems. SWP personnel agreed to iden-tify areas they felt were mostthreatened by USTs, using the datafrom source -water protection reports.

EPA Region 5 agreed to perform a per-centage of its federal inspections insource-water protection areas and tofollow up with both states as theymove forward with their collaborativeefforts. ■

21


Screenshot of New Castle County Web page showing the layer with recent (color) aerial photo-graph. The parcel in the center of the photograph shows a gas station, where the canopy; con-crete pad over the tank field; patches in the paving from removal of a diesel tank, dispensers andproduct lines; and patches from installation of the Stage II vapor-recovery lines are clearly visible.

UST-SWP: ProgramsWork Together toProtect Drinking Water

Some years ago, I was speakingabout UST inspections at an USTconference to a roomful of sev-

eral hundred tank owners and opera-tors (O/Os). To try to warm up theaudience, I was foolhardy enough toask for a show of hands of those whothought that regulatory inspectionswere a useful thing. I was soon gaz-ing at a roomful of the stoniest faces Ihave ever seen from a podium. Thechill in the air was palpable.

Sensing I had perhaps succeededin creating an instant iceberg where Ihad hoped to break some ice, I saidwith somewhat of a gulp, “Nobody,huh?” Fortunately, I was rescued byone brave soul who finally raised hishand and said, “I think inspectionsare great. They let me know what I’mdoing right or wrong, and I knowthat they help keep my competitionhonest too.” I thanked the man and,with not much enthusiasm, launchedinto my talk.

That day, I became painfullyaware of the depth of my misunder-standing of my O/O audience. Sincethen, I’ve recognized the importanceof trying to see things from both sidesof the table.

So when John Cochran (NewMexico Environment DepartmentUST Program) called to see if Iwanted to talk about inspections atthis year’s UST/LUST National Con-ference in Seattle, we began to brain-storm about creating an opportunityfor inspectors and O/Os to sharetheir views about inspections, and foreach side to try their hand at guess-ing what the other side would say.We figured this would be a good wayto get a reality check on how welleach side understands the other.

We invited some regulators andO/O representatives to join ourpanel. These people were not ran-domly selected and we made no

effort to determine how representa-tive they were of the inspector orO/O general populations. This wasnot intended to be a statistical study,but rather a vehicle for fostering dis-cussion.

We gave the panel some basicquestions to think about ahead oftime, but we didn’t really know whatthey were going to say. During thesession, we asked three questions:

• What is the purpose of an USTcompliance inspection?

• What are the benefits of an USTcompliance inspection?

• What are the problems with USTcompliance inspections?Panelists were asked to answer

each question, first wearing theirown “hats” and then making aswitch to what they thought the otherside would say. The audience wasalso invited to provide their input.Comments were summarized “live”

and presented to the group via acomputer projector. The answers wereceived are summarized in thetables that accompany this article. Mythoughts upon reviewing theanswers are as follows.

What Is the Purpose of anUST Compliance Inspection?Speaking from their respective pointsof view, inspectors and O/Os agreedon many of the purposes of aninspection. Noticeably lacking fromthe O/O perspective was protectionof human health and the environ-ment (although this thought didshow up as a compliance inspectionbenefit when O/Os were speaking asinspectors). A key concern of O/Osthat came out in these answers, eventhough it doesn’t directly address thequestion, was fairness in the inspec-tion process.

When guessing what theythought the other side would say in

22


Marcel Moreau is a nationally recognized petroleum storage specialist

whose column, Tank-nically Speaking, is a regular feature of LUSTLine. As

always, we welcome your comments andquestions. If there are technical issues

that you would like to have Marceldiscuss, let him know at

[email protected]– nically SpeakingTank – nically Speaking

by Marcel Moreau

That’s not what the lastinspector said.

Why can’t they get their story

straight?

He’s not listening to a word I say

I’ve Looked at Tanks from Both Sides Now

response to the question, the O/Osseemed to have a pretty good under-standing of the inspector’s point ofview. Inspectors’ answers didn’t cor-relate quite so well, but my suspicionis that the inspectors may have beenvoicing some typical “mom and pop”O/O concerns (e.g., Why pick me?What’s going to happen to me? Look-ing for free consulting) and mom-and-pop O/Os were not representedamong the O/O panelists.

What Are the Benefits of anUST Compliance Inspection?I find it interesting that when speakingfrom their respective points of view,the O/Os’ and inspectors’ responseswere quite consistent in so far as theywent, but the inspectors’ list of benefitswas substantially longer than theO/Os’. I was encouraged to see thatboth sides recognized that inspectionsare an opportunity to establish rapportbetween inspectors and O/Os.

Both sides were reasonably accu-rate in predicting what the other sidewould say. Again, the inspectorsspeaking as O/Os included somethoughts that are more likely to comefrom mom-and-pop operations thanfrom the O/O representatives on ourpanel.

What Are the Problems withUST ComplianceInspections?This question raised the most con-trasting viewpoints and providedsome food for thought on both sides.While inspectors felt that the O/Os’reluctance to ask for help and igno-rance about UST systems were signif-

icant problems, O/Os emphasizedinconsistencies in the interpretationof the rules and in inspections overtime.

What inspectors saw as a failureof O/Os to ask for help, O/Os saw asa failure of inspectors to clearlyexplain expectations. Inspectors sawa lack of knowledge (i.e., training)regarding storage systems on the partof O/Os, while O/Os pointed to alack of training of state inspectors(O/Os also acknowledged that O/Osare in need of training). Overall, itseems to me that communication,consistency, and training are areasthat both inspectors and O/Os couldimprove on.

When O/Os put their inspectorhats on, they came up with a list ofproblems that was quite consistentwith that of the inspectors. Inspectorswearing O/O hats, however, focusedon a perception on the part of theO/Os that inspections are inconve-nient, and completely missed theO/Os’ concerns for consistency andclear communication. Again, thismay be due to the inspectors’ focuson the mom-and-pop response toinspections rather than the largercompanies represented on the panel.

Parting ThoughtsThis session reaffirmed for me thatfrank dialogue is critical to “seeingourselves as others see us.” Assessingissues from different points of view isa very valuable tool in determining thekinds of changes that might promoteimproved performance. Creatingopportunities for dialogue might be animportant first step in making life eas-ier for both inspectors and O/Os.

23


Some years ago, I visited a Ger-man tank-fabrication plant on thesame day that the regulatory inspec-tor was due for a visit. I was struckat the time by the plant manager’sapparent eager anticipation of theinspector’s visit. The plant managerexplained that the inspection wouldconsist of the inspector picking a fewtanks off the production line at ran-dom and running some tests. Theplant manager was not at all con-cerned that the tanks might fail. Thetank-construction standards wereclear and his production techniqueswere careful.

The plant manager was, how-ever, planning to take the inspectorto lunch. He had some tricky steelfabricating to do on a project and hewas hoping the inspector wouldgive him some tips on how to do it.In Germany, being an inspector isnot an introductory position; it is aposition you achieve after muchstudy and many years of experiencein your field.

While I do not expect that theGerman model of inspections willbe adopted in this country, the ideaof inspectors and O/Os sittingdown to lunch together does holdsome appeal...even if it’s just abrown-bag affair. Imagine how dif-ferent life might be if on a monthlybasis a brown-bag luncheon wereheld at some VFW hall or other neu-tral, low-key venue with the statedpurpose of allowing inspectors andO/Os to sit down, get to know eachother, and discuss issues of commonconcern.

These are my thoughts. What areyours? ■

What Is the Purpose of an UST Compliance Inspection?

Inspector Speaking as Inspector O/O Speaking as O/O

O/O Speaking as Inspector Inspector Speaking as O/O

• Ensure compliance• Provide compliance assistance• Look for leaks• Allow level playing field• Keep O/Os on their toes• Protect health and environment• See if O/Os are operating responsibly

• Determine compliance• Provide education for O/O• Respond to threats• Allow level playing field• Ensure recordkeeping• Fairness expected

• Ensure compliance• Help O/O with compliance• Identify faulty components• Determine that equipment is operating properly

• How do I measure up to regs?• What do I need to do?• Why pick me?• What’s going to happen to me?• Looking for free consulting

continued on page 24

24


What Are the Benefits of an UST Compliance



• Allow face-to-face contact (personalize bureaucracy)• Provide two-way education • Get to know O/O (educate me)• Correct problems• Deter violations• Discover problems, releases• Encourage compliance through credibility of inspector

(we are doing our job) • Reduce risk to environment• Provide outreach to small O/O• Can save O/O cost of unnecessary testing• Protect investment in property• Can allow discussion on issues concerning contractors

(misinformation, poor workmanship)

• Establish rapport• Audit processes to be sure they’re working• Point out deficiencies• Offer quality assurance (another set of eyes to look at

operation)

• Provide face-to-face meeting• Establish a presence • Even the playing field• Ensure things are working • Make sure leak detection is in effect• Allow inspector to see who is a good O/O and who is not• Protect environment• Verify maintenance and operation of equipment• Let O/O know about the penalties (especially red tag)

• Establish rapport • Personalize bureaucracy• Maintain a level playing field (I know you are out here) • I’m glad you told me what to do• Unbiased opinion about leak detection and work that needs

to be done (misinformation from contractors)• Hear directly from regulator what needs to be done• Get management’s attention


• Frustration with repeat offenses• Scheduling• Cultural and language barriers• Availability of paperwork• Lack of knowledge of rules on part of O/O• Lack of training on part of O/O• Not having right people on-site (unannounced inspections)• Not having right equipment (e.g., dispenser keys, tools to

remove sump lids)• O/O attitude may be a problem

• I have to count twinkies (O/O has more important things to do)

• You’re interfering with my day• This is costing me money• Why do you inspect me so often? (Note: Because many

O/Os do not distinguish between state-agency and EPApersonnel, they feel unfairly targeted when both agencieshappen to inspect the same facility.)

• Find compliance—not violations• O/O don’t ask for help • Failure of O/O to communicate needs to agency BEFORE

inspector gets on-site• Insufficient records or information• Lack of knowledge about UST system• Language barriers• Apathetic attitude on part of O/O

• Attitude of inspector (help? or enforce?)• Inconsistent interpretation of the rules • Inconsistent inspections over time• On-site personnel often do not communicate problems dis-

covered to upper management so that they can beaddressed

• Need for clarity in explaining the violation and basis in rules• No clear expectations (what do you want?)• High fines for innocent paperwork violations• Multiple inspections by multiple agencies (e.g., UST, food,

air, weights, and measures)• Surprise inspections• Lack of training of O/Os and inspectors

What Are the Problems with UST Compliance Inspections?


On January 2, 2004, Underwrit-ers Laboratories Inc. (UL)revised its standard for Non-

metallic Underground Piping for Flam-mable Liquids (UL 971). The revisedstandard became fully effective onJuly 1, 2005. In order for manufactur-ers to continue to apply the UL markto piping manufactured on or afterJuly 1, 2005, their piping mustundergo a review and be tested forcompliance with the revised stan-dard. Only piping that UL finds to bein compliance with the revised stan-dard will be authorized to continueto bear the UL mark. The followingquestions and answers are intendedto provide a brief overview of thenew UL 971.

Why was UL 971 revised? Nationwide reports of nonmetallicunderground storage tank pipe fail-ures and reports indicating that notall nonmetallic pipe is performing asintended prompted UL to take a criti-cal look at UL 971. UL reports thatthese nonmetallic pipe failures are aresult of improper pipe system instal-lation, inadequate pipe system main-tenance, failure to properly respondto leak-detection alarms, and otherunspecified causes.

What are some of the differ-ences between pre- and post-July 1, 2005, UL 971-listed pipe? The most critical difference betweenpre- and post-July 1, 2005, UL 971-listed pipe is the physical testing towhich the pipe is subjected. Therevised UL 971 standard requiresmore stringent physical testing,which is intended to better simulatelong-term use and real field condi-tions and therby improve the abilityof post-July 1, 2005, pipe to withstandthe conditions found at operatingUST facilities.

For example, prior to undergoingcompatibility and permeability test-ing, pipe samples will be precondi-tioned by being subjected to bend,drop, and impact tests. Conducting

compatibility and permeability testson pipe that has been preconditionedwith the usual abuse pipe experi-ences during transport, assembly,and installation better approximatestrue installation and field conditions.As another example, to address pipedegradation resulting from long-termexposure to fuel, pipe samples willnow be subject to more stringentcompatibility and permeability test-ing that incorporates new criteria fordimensional stability and increasedminimum-retention values.

Other major revisions to UL 971include evaluating piping as a system(rather than evaluating individualcomponents) and a requirement forinstallation of pipe by qualified per-sons.

In summary, the standard wasrevised to incorporate more stringenttesting and installation requirementsso that pipe systems manufactured tomeet this revised standard have lesschance of experiencing the failureswe have seen in the past. (See LUST-Line Bulletins 47, 45, 43, and 42 formore information on nonmetallicpiping failures.)

Does pre-July 1, 2005, UL 971pipe maintain its listing? July 1, 2005, is when newly manufac-tured pipe must meet the revised UL971 standard. It does not affect thelisting of existing pipe manufacturedprior to July 1, 2005. Therefore, UL971-listed pipe manufactured prior toJuly 1, 2005, can remain in theground. It should be noted that afterJuly 1, 2005, some states might notallow piping to be installed that doesnot meet the revised UL 971standard. Owners/operators andinstallers should check with theirstate UST programs before installingnonmetallic pipe after July 1, 2005.

Note: Inspectors and owners/opera-tors should know that purchasing UL-listed pipe after July 1, 2005, does notguarantee that the pipe was manufac-tured after July 1, 2005, and meets therevised UL 971 standard. In fact, it may

25


Making Sense of UL 971The Revised Nonmetallic Piping Standard

by Laura Chaddock


take months or even years before the pre-July 1, 2005, pipe stock is depleted.

How do I identify pipemanufactured on or after July 1, 2005? Pipe manufacturers are required byUL to mark the date of manufactureon the pipe at ten-foot intervals, andon fittings or fitting bulk packaging.Most pipe manufacturers use what iscalled a modified “Julian Date Code.”This code typically consists of a two-digit code for the year in which thepipe was made (for example, 2005reads as 05), and a three-digit codefor the day of the year (from 001 to365) or a four-digit calendar monthand day notation (for example, 0101for January 1).

Depending on the pipe manufac-turer, a modified Julian Date Code forpiping manufactured on May 12, 2005could read 05132 (two-digit yearidentified first, followed by the three-digit code for the day of the year), or13205 (three-digit day of year identi-fied first, followed by the two-digityear code), or 050512 (two-digit yearidentified first, followed by two-digitcalendar month, ending with the cal-endar day).

Because manufacturers use differ-ent Julian Date Codes, it will take timeand research to determine the date onwhich a given pipe was manufac-tured. If you are unable to locate ordecipher the date, you can contact thesupplier or manufacturer of the pipefor assistance. Also note that there aresome differences in labeling (e.g.,changes to product types and fueltypes), which might also serve as a wayto determine the difference betweenpre- and post-July 1, 2005, pipe.

Can pipe manufacturers use list-ings from an independent test-ing organization other than UL?There are several nationally recog-nized independent testing organiza-tions under which pipe may be listed,and several pipe manufacturers hold

listings under more than one inde-pendent testing organization. There-fore, it could be possible that pipemanufacturers that fail to meet therevised UL 971 standard will con-tinue to manufacture and sell theirpipe using one of their other inde-pendent testing organization listings.

How is California transitioningto the revised UL 971?In California, both the UL 971 stan-dard and California’s design andconstruction requirements must beconsidered when determining theappropriate use of pipe manufac-tured pre- or post-July 1, 2005. Cali-fornia Health and Safety CodeChapter 6.7 not only requires anindependent testing organization list-ing, but also requires that primarycontainment be compatible with thehazardous substance stored and thatsecondary containment be con-structed to prevent structural weak-

ening as a result of contact with anyhazardous substance released fromthe primary containment.

The Future of UL 971The January 2, 2004, revision of UL971 is just a stepping-stone towardaddressing the nonmetallic pipe fail-ures we’ve seen in the field. In fact,UL 971 is currently under revision toinclude even more stringent testingand to set higher performance criteriaso that nonmetallic piping manufac-tured in the future will not experi-ence the problems that we have seenin the past. So, be vigilant and con-tinue to report those piping failuresto UL at www.ul.com. ■

Laura Chaddock is Chief of the USTLeak Prevention Technical Unit at theCalifornia Water Resources Control

Board. For more information on Cali-fornia’s transition to the revised non-

metallic piping standard, contact Lauraat (916) 341-5870 or

[email protected].

26


■ UL 971 from page 25

from Robert N. Renkes, Executive Vice President, Petroleum Equipment Institute (PEI)

Results of PEI’s UL 971 Piping Survey Available

UL 971, Nonmetallic Underground Piping for Flam-mable Liquids, contains requirements that coverprimary carrier, secondary containment, inte-

gral primary/secondary containment, normal ventand vapor recovery, nonmetallic pipe, fittings, andproducts intended for use underground in the distrib-ution of petroleum-based flammable and combustibleliquids, alcohols, and alcohol-blended fuels.

From October 1995 through June 30, 2005, non-metallic underground piping was produced in accor-dance with the UL 971 standard dated October 30,1995. Revisions were made to the 1995 standard inresponse to improper piping-system installation, inad-equate piping-system maintenance practices, and fail-ure to properly respond to leak-detection alarms. Theperformance requirements of the “new” UL 971became effective on July 1, 2005. That means productsmanufactured on or after July 1, 2005, must complywith the new requirements to be considered UL-listed.

As far as UL is concerned, the UL mark on a prod-uct serves as the manufacturer’s declaration that theproduct complied with the UL requirements that werein effect at the time the product was produced. In otherwords, as long as the UL mark is on the pipe, UL con-siders the product listed. Piping produced to the 1995

standard is still UL-listed, even though it can no longerbe produced.

There is some confusion in the industry about howthe states will handle the “old” UL-listed pipe (manu-factured from October 1995 through June 30, 2005) and“new” UL-listed pipe. More specifically, will statesallow piping listed to the 1995 standard to be installednow that the new UL 971 requirements are effective?

To help tank owners, piping manufacturers, andtank-system installers understand what the states willallow to be installed after July 1, 2005, PEI recently sur-veyed the each state. While printing deadlines do notpermit us to summarize the results of the survey in thisarticle, the results (state by state) of the survey are avail-able at www.pei.org. You will note that the vast majorityof states have permitted piping manufactured to the oldstandard to be used after July 1, 2005.

A complete listing of all UL certifications is avail-able through UL’s website at www.ul.com. Select the“certifications” menu item from the UL home page.Click on “standard number,” on the next page, type in971, and then select the piping option. The website willprovide information on all currently certified products.Only those products that are certified to the newrequirements are identified. ■

The Energy Policy Actof 2005?

On August 8, President Bush signedthe Energy Policy Act of 2005 into law.The act contains a number of provi-sions that will impact state and federalUST/LUST programs. Over the nextfew months we will all be studying theact to find out just what it requires. Inthe next issue of LUSTLine, we’ll pro-vide an update on the act as well assome state perspectives.

Meanwhile, A PDF file of the EnergyBill can be found at following Senatewebsite: http://energy.senate.gov/pub-lic/. Once at this Senate Energy andCommerce Committee home page,look to the right margin and under“Featured Items” click on “Text of Con-ference Report of Energy Policy Act of2005.” The text of the UST ComplianceSubtitle B, Title XV, begins at page1564 through 1607. It runs from Sec-tions 1521 through 1541. ■

Field Notes ✍

27


aquifer more readily than if therewere a long residence time. Attenua-tion of contaminants is minimizedwith high linear velocity and shorttravel distance because the solute willhave a short period of vadose-zoneresidence time and therefore will nothave substantial time to react withthe geologic matrix and existing aircomponents of porosity.

Groundwater risk was calculatedby dividing the land-use-risk grid bythe aquifer-susceptibility grid. Agroundwater-risk calculation is anal-ogous to the HRI hazard component.Groundwater risk demonstrates therisks associated with introducingcontaminants both at the surface and to an unconfined aquifer at thewater table. Existing CERCLA NPLgroundwater-contamination sitesdisplay a strong correlation to areasof significant risk on the groundwa-ter-risk grid. This grid does not takeinto consideration population expo-sure.5

The HRI exposure component isequal to the ratio of the populationexposed to the total population mul-tiplied by the Exposure factor. TheExposure factor (Ef) assesses the per-centage of population exposure overtime. In the GER study, this valuewas defaulted to one. The GER analy-sis constructed a ratio of populationusing groundwater as a source ofdrinking water grid from census tractand public water supply wellheadprotection area data layers.3

The value for population usinggroundwater as a source of drinkingwater was assumed to conform to theSource Water Assessment Areas(SWAPs) around public water supplywells. SWAP areas were provided bystate and local agencies. The ratio ofpopulation using groundwater as asource of drinking water to total pop-ulation is analogous to the HRI expo-sure factor.

The GER, which assesses the riskof introducing contaminants at thesurface in NYS and the risk of thosescontaminants percolating throughthe vadose zone and being intro-duced to an aquifer at the water tablein areas where humans use ground-water as a source of drinking water,is analogous to the HRI value as out-lined below:

HRI = (( DI x DV ) x ( PE / PC ) x Ef )

Assuming Ef = 1, then

HRI = ( DI x DV x ( PE/PC ))

The GER formula follows, withLUR analogous to DI, the inverse ofAS analogous to DV, and PGW equalto (PE/PC):

GER = (LUR /AS) x PGW

GER = Groundwater-endangermentrisk

LUR = Land-use risk

AS = Aquifer susceptibility

PGW = Ratio of population usinggroundwater as a source of drinkingwater to total population

The GER grid can be used by theGIS to statistically compare the meanUIC GER values of counties, zipcodes, wellhead protection areas, orany other areas defined with bound-aries. Mean GER values of zip codes,as an example, can be used to priori-tize UST and UIC inspection targetareas. Higher numbers indicatehigher risk. In order to relate the gridto practical inspector deployment,counties and zip codes wereprocessed to display mean GER percounty and zip code. By targeting ahigh-risk county, then a high-riskzipcode, specific areas possessingsubstantial GER may be identified.These areas may be sited for UST orUIC inspections. Facilities located inthese areas may be targeted for USTor UIC inspections. ■

Charles Hillenbrand is with the U.S.EPA Region 2’s Water Compliance

Branch. He can be reached at [email protected].

References:Carney, G. R, Human Health Risk Index, Draft docu-

ment, Policy and Analysis Section, U.S. EPA Region6, 1991.

Notes1 Hillenbrand and Simpson, in press.2 Hillenbrand and Friedman, in press.3 Hillenbrand, Hansen, and Friedman, in press.4 Hillenbrand and Simpson, in press.5 Hillenbrand and Ferri, in press.

D esign, Construction, Modifica-tion, Maintenance and Decom-missioning of Filling Stations

is the title of a publication producedjointly by the Association for Petro-leum and Explosives Administration(APEA) and the Service Station Panelof the Energy Institute. The 242-pagebook contains information basedlargely on experience from the UnitedKingdom and makes frequent refer-ence to legislation applicable in theUK; however, the authors anticipatethat the general principles will beapplicable to most regions of theworld. Copies can be obtained fromPortland Customer Services, Com-merce Way, Whitehall IndustrialEstate, Colchester CO2 8HP, UnitedKingdom. Phone: (44) 1206 796 351.E-mail: [email protected].

■ Risk Analysis from page 19

In April, the Sierra Club released a22-page report that describes indepth the threats to public health

and the environment from LUSTs.The report details the detrimentalimpact that leaks of gasoline and toxicsubstances from USTs have on thenation’s groundwater, the source ofdrinking water for 50 percent of thepopulation. The report also looks atcurrent federal and state efforts toprevent and clean up leaks from USTsand concludes that they are inade-quate to protect public health. Thereport notes the current slowdown inthe number of LUST cleanups com-pleted each year and predicts a rever-sal of years of progress in cleaning upthe nation’s backlog of LUST sites ifcurrent trends continue. The fullreport can be seen at http://www.sier-raclub.org/toxics/Leaking_USTs/index.asp.

Sierra Club Calls LUSTsa Threat to the Nation’sDrinking Water

New Publication onDesign, Construction,Modification,Maintenance andDecommissioning USTSystems from the UK

The Maryland Department ofthe Environment (MDE) deter-mined that a cost-effective

evaluation tool was needed to assistLUST investigators in pinpointingthe locations of vapor releases fromgasoline UST systems. The tool,which needed to be both cost effec-tive and easy to implement, is theoutcome of our ongoing strugglewith increasing incidents of MtBE-impacted groundwater from fullycompliant UST systems across thestate. MtBE releases at a portion ofthese sites could be tracked to small-volume releases from catchbasin andsump failures, spills at the dis-pensers, and poor maintenance prac-tices. However, we also recognizedthat vapor releases were a main con-tributing source for MtBE levels ingroundwater at these sites.

MDE reviewed the many UST-testing methods currently availablefor system evaluation. We found thatnone of the commercially availabletests fulfilled our immediate needs.Ultimately, we drew from our owntesting knowledge to meet ourrequirements. We realized that folksin the UST industry, as well as otherrelease-investigation industries, havehad experience with helium as a test-ing compound for well over 25 years.Therefore, we decided to take a bravestep and write our own protocol forUST helium testing, knowing fullwell this would be a first in thenation.

We began by drafting an evalua-tion protocol based on the experienceof MDE staff who had backgroundsin testing UST systems for both tight-ness and vapor-recovery operation.We then conducted a forum with sev-eral active tank-testing firms in ourstate with helium-testing experience.With these firms we were able tofine-tune the protocol and performfield-test trials. The real-world field-test trials assisted a great deal in thedevelopment of the final protocol.

Currently, vapor evaluation isrequired on all gasoline UST systemsthat have Stage II vapor recovery andare located within the High Risk

Groundwater Use Area of our state.Most tank owners are having theevaluation performed in conjunctionwith the required annual Stage IIvapor-recovery testing when the air-to-liquid ratio and pressure-decaytests are performed. The vapor-eval-uation protocol has added $300 to$600 to the annual Stage II testing. Astank testers become more experi-enced with the protocol and previ-ously unidentified vapor problemsareas are repaired, we expect theprice to decrease.

We feel that we have providedtank owners and testers with an eval-uation tool that is meeting our goal ofdiscovering small vapor releases fromactive gasoline UST systems. Testersin Maryland are discovering numer-ous tank-top fitting failures. Thesefailures are now easily repaired anddoing so prevents continuous vaporleaks into the environment. Thehelium test section of the new Mary-land protocol appears below. For thefull protocol, visit MDE’s website at:www.mde. state.md.us/Programs/LandPrograms/Oil_Control/FactsheetsPublications. ■

Herb Meade is the Administrator of the OilControl Program, Maryland Department of

the Environment. He can be reached [email protected].

28


Maryland’s New Helium Test Protocolby Herb Meade

Performing the Helium-Test1. Initially perform California Air Resources Board (CARB) Test Procedure TP-201.3 using com-

mercial-grade nitrogen as required. Report test failure to the Oil Control Program and Air andRadiation Management Administration within two hours in accordance with Code of MarylandRegulation (COMAR 26.10.08.01A). Record any corrections made prior to and during the test-ing to achieve a passed test.

2. Once CARB test has been successfully completed, remove the pressure/vacuum (P/V) ventcap(s) on UST(s) to be tested and install 1-psi pressure relief valve.

3. Note: The UST systems should be in operating condition minus the vent cap. Install all fill andStage I dust caps for the duration of the helium test.

4. Begin introducing helium into the system following the specifications as stated in CARB proce-dure TP-201.3. Do not exceed 1.0 inch of water column. Monitor pressure in the tank con-stantly.

5. Confirm helium is present in all areas to be tested. Check test connections to verify they arenot leaking.

6. Lids to all sumps, tank-top components, and dispensers should remain in place until they aretested to allow for any helium release to build inside the contained area for detection.

7. Test for helium leaks at all tank-top components and areas in the dispensers at pump-islandgrade with the helium detector. Record the location of any positive detection of helium.

8. Repair or replace any defective components and record work performed.9. Repeat steps #7 and #8 until no helium is detected.

10. Once helium is not detected, increase pressure to 5.0 inches of water column and repeat steps#7 and #8 until no helium is detected.

11. Testing is complete once no helium is detected at 5.0 inches of water column in all sumps andmanways, at any of the tank-top components, or in the dispenser areas. Record the monome-ter pressure and time. Maintain the test for 10 additional minutes and record the pressureagain. If pressure decay is observed, record and bring pressure back to 5.0 inches of watercolumn and maintain for 10 minutes and record pressures. If pressure increase is observed,also record. A failure is any detection of helium or any decay of pressure after achieving 5.0inches of water column for 10 minutes.

12. Break down test equipment and replace P/V vent caps.13. If secondary piping exists, it must also be tested.14. Introduce helium through one test port on the line being tested. Place a second gauge farthest

from the area where the helium is being applied. Lines may have to be connected (jumped)inside dispensers to perform test. Loosen the secondary boot/hoses slightly on specific pipebeing tested and check with the helium detector to verify helium is present throughout theentire pipe. Once helium is detected, seal all boots/hoses tight. Charge line to 2.0 inches ofwater column and watch for decay. If line is decaying, check boots/hoses with helium detector.Tighten boots/hoses as needed. If no helium is detected at the boot ends and pressure contin-ues to decay, record decay rate if possible (inches of water column/minute or second). If pres-sure is not increasing or sustained, or is not confirmed at each boot end, record a failure.Point-source testing may be needed to identify area(s) of failure. If pressure maintains orincreases after holding for 10 minutes, increase pressure to 5.0 inches of water column andrepeat test. Pressure must be maintained for 10 minutes at 5.0 inches of water column. ■

29


This installment of the National Work Group on Leak Detec-tion Evaluations’ (NWGLDE’s) FAQs focuses on the differentprotocols used to certify continuous in-tank leak detection sys-tems (CITLDS) as well as which protocol the NWGLDEbelieves meets the federal requirements for manufacturer’s cer-tification of equipment performance. Please Note: the viewsexpressed in this column represent those of the work group andnot necessarily those of any implementing agency

Q. Has any CITLDS equipment that was evaluatedand third-party certified using the old manufac-turers’ protocols been accepted by the NWGLDE?

A. We can get to the answer by first looking at thehistory of CITLDS protocols. CITLDS had not yetbeen invented when U.S. EPA published proto-cols in 1990 for testing leak-detection methods.When CITLDS equipment came along later andthe manufacturers wanted to evaluate their equip-ment, they had to develop their own protocols.The manufacturers developed their own protocolsand had their equipment tested using these proto-cols. None of these protocols were alike, and mostdid not require very stringent tests of the opera-tion of the equipment. Since this was before thefirst NWGDLE list was issued, many statesreviewed and accepted CITLDS evaluations thathad been performed using the manufacturers’protocols.

When NWGLDE began to review availableCITLDS evaluations, it determined that most ofthe protocols were not sufficient. As a result,NWGLDE only listed one manufacturer’s CITLDSequipment in the 3rd Edition NWGLDE list onApril 18, 1997. The California State WaterResources Control Board volunteered to take thelead to try to encourage CITLDS manufacturers tocome together and write an improved protocolthat all manufacturers could use.

Dr. Jairus D. Flora, Jr. wrote a new protocol, andthe California State Water Resources ControlBoard and NWGLDE, both of which providedtechnical reviews of the protocol, accepted thenew protocol on January 7, 2000. The new proto-col covered three types of continuous systems:continuous automatic tank gauging systems(ATGS), continual reconciliation, and automaticmonthly inventory control. It required more strin-gent testing of CITLDS equipment as well as test-ing at both laboratories and operating fuelingfacilities. It also addressed the operation of theequipment in manifolded tanks, limited the oper-

ation of the equipment based on throughput, andprovided for the optional inclusion of dispenser-blending data.

Most CITLDS manufacturers reevaluated theirequipment using this new protocol. The CITLDSleak-detection equipment on the NWGLDE web-site and list were evaluated using this protocol.However, a representative of a CITLDS vendorthat had its equipment recertified under the newprotocol has stated that his company believes thatit is not subject to the throughput limitationrequirements of the January 7, 2000, protocol instates where a regulatory agency previouslyaccepted its evaluation under the old protocol.

NWGLDE believes that the January 7, 2000, proto-col provides a more thorough evaluation ofCITLDS equipment and levels the playing fieldfor CITLDS manufacturers. NWGLDE alsobelieves that restrictions and limitations in thenew protocol should apply to all equipment certi-fied using the new protocol. However, NWGLDEdoes not revoke or invalidate test protocols.Therefore, the final decision as to whether or notto accept a manufacturer’s certification of leak-detection equipment performance lies with thelocal regulatory agency.

About NWGLDENWGLDE is an independent work group comprising tenmembers, including eight state and two U.S. EPA mem-bers. This column provides answers to frequently askedquestions (FAQs) the NWGLDE receives from regulatorsand people in the industry on leak detection. If you havequestions for the group, please contact them at [email protected].

NWGLDE’s mission:

■ Review leak-detection system evaluations to deter-mine if each evaluation was performed in accor-dance with an acceptable leak-detection test methodprotocol and ensure that the leak-detection systemmeets U.S. EPA and/or other applicable regulatoryperformance standards

■ Review only draft and final leak-detection testmethod protocols submitted to the work group by apeer review committee to ensure they meet equiva-lency standards stated in the U.S. EPA standard testprocedures

■ Make the results of such reviews available to inter-ested parties ■

Old and New CITLDS Protocols—What’s That About?

FAQs from the NWGLDE …All you ever wanted to know about leak detection, but were afraid to ask.

On June 28, 2005, an intenseearly evening rain and light-ning storm delivered a light-

ning strike to the canopy andperhaps the pad of a Circle K conve-nience store in Pinellas Park, Florida.The station had three 10,000-gallon,single-walled fiberglass USTs con-taining diesel, regular unleadedgasoline, and premium unleadedgasoline. The vents for this stationwere located within the canopystructure. The facility did not havelightning rods.

Based on reports from observersat the station during the incident, thefollowing initial sequence of eventstook place as a result of the lightningbolt strike:

• The tank pad rose three to fivefeet. (The pad is 36 x 40 x 1 feet ofreinforced concrete, with anapproximate weight of 63 U.S.tons.) The pad partially slumpedinto the tank excavation. A sub-surface explosion would supportthis movement.

• There was a flash fire on the sur-face of the pad.

• A 36-inch circular sump trafficlid was blown 60 to 70 feet intothe air and then sliced downthrough the canopy.

• A customer dispensing fuel intoher vehicle immediately droveoff, disconnecting the nozzle atthe breakaway fitting.

• The concrete pad in the vicinityof the spill containment/vaporrecovery ports was displaced.

Post MortemIt has been theorized that the light-ning strike delivered a spark to thevapor near the dual atmosphericvents. (The diesel and premium aretogether, and the regular is separate.)The spark followed a vapor trail backto at least the premium unleadedtank. At the time of the event, thepremium tank contained approxi-mately 4,055 gallons of product; thediesel contained approximately 5,220

gallons. Both the diesel and premiumunleaded gasoline tanks suffered cat-astrophic failure. The regularunleaded tank, which did not rup-ture, contained 1,821 gallons.

On June 28, the Pinellas Park FireDepartment, Pinellas County Haz-mat, Bureau of Emergency Response,and representatives of Circle K werethe initial responders. Circle K’s con-struction manager, Daryl Gottilla,and its remediation manager, AlanCubberley, provided directionthroughout the initial and followingdays. Circle K was very proactive,fully meeting the Florida Departmentof Environmental Protection’s “con-tain, remove, abate” criteria follow-ing a discharge event.

Circle K arranged for the con-tents of the regular tank and for freeproduct on the groundwater inter-face (at five feet below land surface)to be transferred by vacuum truck(SWS & US Filter) to a 20,000-gallonFRAC-tank. The tanks had beeninstalled in a crushed-rock backfillmaterial. Circle K’s consultant, Envi-ronmental Compliance Services,began installing observation wellsaround the perimeter of the tank fieldthat same evening.

On June 29, additional free prod-uct was removed. The exact amountof free product recovered has notbeen determined—the failure of bothtanks was at or below the ground-water table elevation. Sections of theslab were removed, allowing work-ers to observe that the center portionsof the premium and diesel tanksbetween the turbine sumps and theopposite end-cap were “missing”above the groundwater level (about25 feet of tank). The Pinellas Park FireDepartment monitored vapor levelsduring the excavation process. Theweather was hot and humid with lit-tle wind to disperse the strong vaporpresence. Later in the day, theremainder of the concrete pad wasremoved.

On June 30, the regular unleadedtank was exposed and removedintact from the excavation. A well-drilling contractor was on-site toinstall permanent and temporarywells. The accessible portions of thedamaged USTs were removed. Prod-uct piping and vent lines were notremoved at this time.

On July 1, the contractor back-filled the excavation with clean fillmaterial and placed four 6-inch prod-

30


Take One Part Premium, One Part Diesel, and a Stroke of Lightning

by Ernest Roggelin

The lightning-impacted site showing subsidence of the tank pad over the UST area.

31


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uct-recovery wells. Dur-ing the cleanup of theconcrete and steel rebarscrap, sparks from aquick-cut saw ignitedcrushed-fiberglass tankparts in the constructiondumpster, necessitatinga visit by the fire depart-ment.

The retrofit schedulewas advanced to initiatetank replacement bymid-summer. The initial site-prepara-tion involved installing sheet-pilingwith well-points. The effluent fromthe points was air stripped and storedin a FRAC-tank. During this site-preparation process, the excavationwas thoroughly cleaned of failed-tank remnants, all piping compo-nents, and concrete debris. The ventpipes were moved out from thecanopy and toward the edge of theproperty. This closure-completion

and installation-initiation processbegan on July 13.

The World Weighs InA brief synopsis of the event, gleanedfrom media reports, was distributedworldwide via the Internet in amoderated newsgroup, “DangerousGoods & HazMat.” This led to aseries of e-mails from industry con-sultants opining on the cause of thetank failures. One position indicated

that the vapor-rich ullage would notsupport ignition, nor would it allowthe movement of a spark or ignitionpathway back down the tank ventpipe. Other positions suggested apossible ignition of product vapors inthe crushed-rock backfill beneath thepad, or the flash boiling of ground-water to create a steam explosion. ■

Ernest Roggelin is an EnvironmentalManager with Florida’s Pinellas

County Health Department StorageTank Program. He can be reached [email protected].

Photos are courtesy of Ernest Roggelin,Lisa Frazier, Jamie Barnett, and

Michael Flanery of the Pinellas CHDStorage Tank Program.

The LUSTLine Index—isONLY available online. To download the LUSTLine Index, go towww.neiwpcc.org/lust-line.htm, and then clickon LUSTLine Index.

L.U.S.T.LINE INDEXAugust 1985/Bulletin #1 – November 2004/Bulletin #48

Firefighter examining tankremains.

The excavation showing theremains of the diesel andpremium tanks along withproduct.

NEIWPCC is accepting abstracts forprofessional papers to be consid-ered for presentation at the 18thAnnual National Tanks Conference& Exposition to be held March20–22, 2006, at the Memphis CookConvention Center in Memphis,Tennessee. The deadline for sub-mitting abstracts is September 9,2005. Complete instructions andthe online submittal form can beaccessed through NEIWPCC’s web-site, www.neiwpcc.org/tanks06.Also, check this website for infor-mation on updates and exhibitingopportunities.

18th Annual NationalTanks Conference Call for Abstracts

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Permit No.200

EPA Denies RFG WaiversOn June 2, U.S. EPA announced thatit would deny separate requests fromCalifornia, New York, and Connecti-cut to waive the oxygenate require-ment for reformulated gasoline(RFG). Reformulated gasoline con-tains 2 percent oxygen by weight.Since California, New York, and Con-necticut ban the use of MtBE, RFG inthose states contains only ethanol.

EPA’s RCRA/SF/OUST/EPCRACall Center DiscontinuesSupport of UST Program As of April 1, EPA’s RCRA/SF/OUST/EPCRA Call Center is nolonger providing information aboutEPA’s UST/LUST program. Forinformation about the UST/LUSTprogram, see the EPA OUST websiteat www.epa.gov/oust. To order publi-cations developed by OUST, callEPA’s publications distribution cen-ter at (800) 490-9198.

New UST-LUST VirtualClassroom Unveiled OUST introduced a new online,Internet-accessible training tool on

the UST program at the UST/LUSTNational Conference in Seattle. TheUST-LUST Virtual Classroom, cur-rently has two training modules. Thefirst, “Introduction to the Under-ground Storage Tank (UST) Pro-gram,” explains tank regulations,describes the differences between theUST and LUST programs, discussesfinancial responsibility, and orientsnew users to the components of atank system. The second module,“Basic UST Inspector Training,”describes how inspectors can preparefor and conduct compliance inspec-tions at typical UST sites. A thirdmodule providing training for LUSTsite managers will be added this year.The UST-LUST Virtual Classroom isavailable 24 hours a day throughEPA’s website at http://www.epa.gov/oust/virtual.html.

OUST Publishes MaintenanceManual for UST Sumps andSpill Buckets UST Systems: Inspecting and Maintain-ing Sumps and Spill Buckets – PracticalHelp and Checklist (EPA 510-R-05-001)was published in May. The manual,which was reviewed by EPA, states,

and industry, is intended to help USTowners and operators improve theoperation and maintenance of theirUST-system sumps and spill bucketsby presenting recommended inspec-tion guidelines and best managementpractices.

The manual will help ownersidentify and inspect the sumps andspill buckets associated with theirUST systems; explain some simplesteps owners can take to maintaintheir sumps and spill buckets andidentify potential problems; and pro-vide owners with tips for fixing com-mon problems before they cause arelease of petroleum products to theenvironment. The manual includessafety considerations, a general intro-duction to the kinds of sumps, basicmaintenance procedures for sumpsand spill buckets, and a sump andspill bucket inspection checklist.

The manual can be viewed anddownloaded from the OUST websiteat http://www.epa.gov/oust/pubs/sumpmanl.htm, and free printed copies areavailable from NSCEP at (800) 490-9198.

HQ UPDATE

Documents

Issue L.U.S.Tneiwpcc.org/lustlineold/lustline_pdf/lustline_50.pdf · 2018-02-15 · Patricia Ellis, Ph.D., Technical Adviser Ronald Poltak, NEIWPCC Executive Director Lynn DePont,