New England Interstate
   Water Pollution Control
   Commission
                            Boott Mills South
                            1OO Foot of John Street
                            Lowell, Massachusetts
                            01853-1124
Bulletin 36
November
2OOO
   LUST.
   A Report On Federal & State Programs To Control Leaking Underground Storage Tanks
   THi FUTURE IS iO/fl//Jff
   ran MB BITE mR m
   by Ann Banner Carpenter
 a
ff:"
     1 egulators, can you provide prompt answers
    1 to public information questions and at the
   1 same time be off doing a site inspection? Can
  9you easily and quickly access site-specific data
from all across the regulatory landscape from one
source? Can you enter site data onto your database
from the field? If you can't, why not? The technol-
ogy is here, it's getting more user-friendly and
affordable every day, and it can make your workload
a whole heck-of-a-lot more manageable.
   One-stop database shopping is already up and
running in some states and gearing up in others.
Geographic Information Systems (GISs) are being
used by regulators in many states as an important
tool in the day-to-day business of environmental
management and decision making. Mapping soft-
ware can help them analyze data, while the Internet
allows them to speed it to those who need the infor-
mation and who would otherwise be calling on the phone. Don't
have good location data? Well, all is not lost—there are several
ways to get it, including highly accurate Global Positioning
Systems (GPSs).
   For regulators, the marriage of CIS, GPS, and Internet
access can be a dream come true. For users, it's as easy as shop-
ping on-line—and you don't even need a credit card.

Why Do It?
Ignorance is not bliss. GIS brings to light spatial relation-
ships that may otherwise be unknown because informa-
tion is  scattered throughout various  regulatory
programs. Regulatory entities often lack the wherewithal
to efficiently and effectively share information on gaso-
line releases and water supply contamination. This lack
of communication can jeopardize water quality.
                          • continued, on page 2
                                                             atea imMnf Am-'' ''Vyfif public
                                                    But the Truth" Book Review
                                                  •tical Issues for MTBE and Related Oxygenates
                                              ^Getting Results, PFP Style
                                               Tank-nically Speaking: Quest for the Perfectly Reliable LLD_
                                                 's RP100 for UST System Installation Revised      1
                                              -Oa^eisj>f.F^e^T^EJ|eleas^s-r^antaJ|!arg,^
                                               Neyif OUST Director/Initiatives      _
                                               Alaska Tank Explosion Linked to Polyester Coveralls
                                               HQ Update

-------
LUSTLine Bulletin 36
• The Future Is Coming...
continued from page 1	

    Easy  access to  environmental
information is important for stake-
holders, such as water  suppliers,
responsible parties, consultants, and
the general public. When regulatory
personnel and stakeholders can eas-
ily access the same data, the result
should be less duplication of effort,
better communication,  and more
informed decision making. And the
environment is a winner, too.
    When a release has been identi-
fied,  UST regulators can use CIS
mapping information to  identify
such  decision-making  criteria  as
proximity to wellhead protection
areas, drinking water  wells and
aquifers, and other receptors. Water
suppliers, land-use  planners, and
developers can use  GIS  to locate
potential sources of  contamination
(e.g., UST facilities,  dry cleaners,
landfills)  near  drinking  water
sources. Realtors, developers, and
bankers can use GIS to identify,
           LUSTLine
           Ellen "Frye, Editor
 	;	Rldd Pappo, Layout
 f	  Majxfil Mpreau, Technical Advisor
 * i	Patricia Ellis, Ph.D., Technical Advisor
 Bpnald Poltak, NEIWPCC Executive Director
 	';	' i Lyim'DePont, EPA Project Officer
    i   i Lela Bijou, OUST Liaison
 ''LUSTLine is a product of the New England
 Interstate Water Pollution Control Commis-
     Ejivirpnrnental Protection Agency.
        11": j	," '    	;i:	' • ii1 :   .I	   '' •"' f
   LUSTLyie is issued as a communication  ;'
      service for the Subtitle IRCRA
   Hazardous & Solid Waste Amendments  ''
        rule promulgation process.       !
  1"  LUSTLine is produced to promote    j
  information exchange on UST/LUST issues.,
  Jhe opinions and information stated herein j
  fare those of the authors and do not neces-  4
  i sarily reflect the opinions of NEIWPCC.  *,
      This publication maybe copied.
     ! Please give credit to NEIWPCC
 !!!: NEIWPCC was established by an Act of
 I Congress in 1947 and remains the oldest
 ,{[ agency in the Northeast United States
 i'ConCCrnCd with coordination of the multi-
 *'	 ' - -' m&l ia environmental activities
    of the states of Connecticut, Maine,
     Massachusetts, New Hampshire,
 • New York, Rhode Island, ana Vermont.
 '  ' '•	•	NEIWPCC
   Boott Mills South, 100 Foot of lohn Street
         Lowell, MA 01852-1124
        Telephone: (978)323-7929
           Fax:(978)323-7919
        	lustline@neLwp_c&_Qrg	
    i<2» LUSTLIna Is printed on Recycled Paper
among other things, potential envi-
ronmental risks.
    California's GIS was developed
in response to a legislative mandate.
With the closure of several  Santa
Monica drinking water wells contam-
inated with MTBE in 1997, the state
legislature passed  two bills that
charged  the State Water Resources
Control Board (SWRCB) with the task
of assessing the feasibility and appro-
priateness of establishing a statewide
environmental  database  and GIS
mapping system, beginning by con-
ducting  pilot projects in the Santa
Monica and Santa Clara Valley areas.
 i	GIS brings to light spatial
 | relationships that may otherwise be
 ~i  unknown because information is
     scattered throughout various
     ill It " ml,  '-'    i r  . .     - c- '-  I
         regulatory programs.
    In   response,   SWRCB  and
Lawrence Livermore National Labo-
ratory (LLNL) staff members worked
together to develop GeoTracker, a
GIS that provides on-line access to
environmental data. GeoTracker is
the interface to the state data ware-
house, the Geographic Environmen-
tal Information  and  Management
System (GEIMS).
    GeoTracker was developed to
provide timely information to coor-
dinate and support state agencies in
protecting public  drinking  water
sources from motor fuels contamina-
tion. The SWRCB has already real-
ized those benefits and more from
having the system up and running
and  on-line  (http: / / www.geot-
racker.ecointeractive.com /).  The
entire state is now included, and the
agency is planning to add active fuel
sites and other data layers, such as
recharge areas.
    At  the  regional  level,  EPA
Region 3 is working with its states to
develop a pilot system to obtain loca-
tion data and map wells and regu-
lated facilities, with the goal of GIS
analysis and Internet access. Like
California, Region 3 will begin with
two counties. The region is also con-
sidering developing a risk-indexing
tool to aid in planning.
    If your UST/LUST  program
hasn't already done so, there are sev-
eral good reasons to start planning
for GIS mapping and linking up with
the Internet:

• Better Manage Site
Cleanup Objectives
When you must  respond quickly,
there is no time for an archaeological
dig in the file room. With GIS, you
can  view the area  where  an UST
release  has occurred  and  identify
potential  receptors.  The more data
available to you, the  better informed
your decision and the more timely
your response.
    GIS can help you prioritize sites
based on  risk. "To help us with our
risk  evaluation,"  explains  Art
Shrader,  with  the South  Carolina
UST program,  "we put all our GPS
data into a common  database, shook
it up twice, and asked the system to
tell us which of our LUST facilities
were within 1,000 feet of a public
water supply. We used that informa-
tion to prioritize sites that had the
highest potential risk so that we
could begin assessments  on those
sites first."
    Beginning in 1997, the South Car-
olina UST program identified 300
sites that  met the high-risk criterion.
Since then, about every six months,
when the analysis is run again, an
additional 10 to 20 sites are added to
the assessment priority list.

• Streamline Permitting,
Enforcement, and Reporting
The Internet can streamline the per-
mit renewal and compliance process
by making it easy to enter, transmit,
and retrieve data. For example, on-
line UST permit forms and reporting
forms are available through Geo-
Tracker. These well-designed forms
help improve the accuracy of infor-
mation collected. Pull-down lists,
check boxes, and select boxes give the
user specific choices so that data are
standardized.  Error-checking soft-
ware further quality-controls the val-
ues of information when it is entered
on the Internet forms to assure data
quality. When entering an address,
for example, the system will prompt
the user if the ZIP code is not consis-
tent with the city. Now, one person
can conveniently enter information
and transmit it for storage and use by
others. After the permit is approved,
the data moves into  the GEIMS data-
base. Handwriting and in-box delays
are no longer  an issue. Costs are
reduced and accuracy is increased.

-------
                                                                                                  LUSTLine Bulletin 36
    OeoTracker can generate reports for LUFT sites and nearby drinking water wells (e.g., within 1/2 mifei.

                            JBJ^Ii«!tt3LypJ.gl!g-?
                                                                         ^^ffiTjlEl: ''' 'I'l g'l'^ '',: Vj^t V^^^
  EfBLJIFT Sites

  njlActive Fuel Sites
                                                     leaking Underground Fuel Tank Report for;
                                                     Unocal *4918^S4aiiifebraCoiurty)
        r Roads

        r Roads

        l Major Rtls

  IBiSurfacB Water
  -^•Watersheds

  jfeGWlBasins
  ~i*ConfIning Layers

  Leaking Underground Euel Tank Report for;
  Unocal #4918 (Santa Clara County)
  895 N Sail Antonio Rd
  Los Altos, CA 94022
                                                          siimated tn he Wigmi 1Q Me:|iteiailea\vdl itjigl
                                                     eating Underground Inel Tank Report for!
                                                    Unocal J-I91S 
-------
LUSTLine Bulletin 36
m The Future Is Coming...
continued from page 3	

    Vermont's Agency for Natural
Resources distributes public data via
its CIS data warehouse, the Vermont
Center for Geographic Information
(VCGI). Users can select an area on a
state map, zoom in or out, turn avail-
able data layers on or off, and click on
a well or facility symbol to find its
name, address,  and more specific
information. The site has links  to
important regulatory  information
and notices from the water supply
and waste management  divisions.
There's a link for water supply opera-
tors and links to contact staff.
    The Vermont UST program Web
site provides a listing of upgraded
USTs for purveyors of fuel (required
for delivery of product), a report on
the Petroleum Cleanup Fund, and a
grant  application package   for
removal  of farm and  residential
USTs. The screens are appealing and
easy to use. Visit the site at http://
www.anr.state.vt.us / gismaps /.
    Another site to visit that is ori-
ented  toward   public  use  is
Delaware's Environmental Naviga-
tor. Contaminated site information
includes general site discovery infor-
mation, a site history summary, cont-
aminants, proposed or final plans,
site status, and deed restrictions. This
site is located at http://sirb.awm.
 dnrec.state.de.us /.
    These Web sites give new mean-
 ing to the word "accessibility," and
 they suggest an openness and will-
 ingness to serve the constituency.
 • Facilitate Land Use
 Planning, Source Water
 Protection, and More
 With a wealth of environmental, land
 use, and historic information at your
 fingertips, there is no excuse for mak-
 ing uninformed land use decisions.
 CIS  information can  be a tool  for
 evaluating risk to public health and
 safety and risk to ground and surface
 water resources. Accurate knowledge
 of existing and potential source loca-
 tions can help determine appropriate
 setback distances for a multitude of
 competing uses, such as buildings,
 wells, water supplies, and parking
 lots.
 • Visualize and Publicize
 A picture, or a map, is worth a thou-
 sand words. GIS provides you with
an incomparable visual tool, in addi-
tion to  its spatial analytic ability.
USGS topographic maps (at various
scales) are used as background to
help you become oriented. Digital air
photos will become available on Geo-
Tracker to enhance site location and
analysis. Want to add the dimension
of time? An additional feature of
GeoTracker is its ability to generate
water quality graphs on-line titiat plot
contaminant values across time, so
users can visualize trends.
    All of the Internet mapping sites
we visited promise expansion of ser-
vices in the future, and the mapping
industry is busily developing new
applications to expand GIS capabili-
ties.
    The Internet can streamline the
 ;   permit renewal and compliance

   process by making it easy to enter,
  I •!    i r     '    i -        • .
      transmit, and retrieve data.
                                J
 Test Drive a Site Today
 Now that you are aware of the bene-
 fits, find out  how  easy it is to use
 interactive mapping. Take, for exam-
 ple, GeoTracker. (See a demo of all
 site features  at http: / /www.geot-
 racker.ecointeractive.com / gdemo /.)
 There are various  ways to locate  a
 site. You can use a business name, an
 exact or partial address, or a case ID.
 All sites in an area can be found by
 entering a particular street, city, or
 county. When information is really
 sketchy, use a wildcard (*) to let the
 computer do the work. Enter North*,
 if you don't know whether North is a
 street or an avenue. The computer
 will display all possibilities.
     Once on the map screen, you can
 select   various   data  layers   or
 "themes," and use "tools" to zoom in
 or out, or identify a feature, such as a
 leaking  underground   fuel  tank
 (LUFT) site or a well, selected on the
 map. You can also select a well and
 search for LUFT sites within 1,000 feet
 or 2,640 feet (one-half mile), or vice
 versa. This area is called a  "buffer"
 and is used for proximity analyses.
     To get more information about a
 particular well at a desired location,
 first use the identify function and
 then click on the well name. You will
 discover links to other screens that
contain several layers of informa-
tion-—well description, public water
system information, number of LUFT
sites estimated to be within one-half
mile. You can delve deeper for loca-
tional  information, including lati-
tude/longitude, the way in which the
data were obtained, estimated level
of error, nearest physical address,
elevation of a well, or public water
supply information, including sys-
tem name, class of system, number of
connections, and population served.
    For specific LUFT sites, you can
access regulatory history, locational
information, more detailed site and
leak information,  and number of
public wells estimated to be within a
specified distance of the site.

Events That Have Enhanced
This Information Revolution
Aside from the obvious advances in
technology and software, a few key
events have contributed to the avail-
ability, accuracy, and usability of GIS
in the environmental field:
   • The development of interactive
     mapping, an extension of com-
      monly used GIS  software to
      display GIS products over the
      Internet. Quality GIS software
      is expensive, and this system
      provides  low-cost  access to
      valuable geographic informa-
      tion. The only requirement is
      Internet access and a compati-
      ble browser. The user can view
      and  query  GIS data  using a
      map interface.
    • Recognizing  that  GPS  has
      become "a global utility" for
      navigation,   communication,
      and emergency response, the
      U.S.  government  abandoned
      the intentional degradation of
      signals (for security purposes)
      in May 2000.  GPS users can
      now pinpoint locations  with
      much greater accuracy. This
      ability narrows an area  down
      from the size of a football field
      to that of a tennis court.
    • The Internet is growing in leaps
      and bounds. According to the
      Internet  Society,  use of the
      Internet  has  been  doubling
      annually since 1988.  With an
      estimated 150 million users in
       1999 worldwide, Internet usage
       is expected to reach 300 million
      by the end of the year 2000.

-------
                                                                                              LUSTLine Bulletin 36
 (Setting Started
 There are several ways to gather sup-
 port to develop GIS and interactive
 mapping. In Idaho, initial work was
 under way when a new manager
 came on board and wanted the appli-
 cation to  be up and running in a
 month.  The  focus on this effort
 speeded the delivery of new equip-
 ment, which made it happen soon
 after.
     In California, the application was
 developed by  popular  demand.
 Stakeholders were brought together
 and given a sense of ownership in the
 development and advancement of an
 Internet mapping application. They
 found that while it may help to have
 a visionary at the top, not to mention
 the interest of the governor and a leg-
 islative mandate, the process worked
 from the bottom up, rather than from
 the top down. Members of various
 regulatory agencies, water districts,
 and  the petroleum industry came
 together and  were able to visualize
 the benefits to their respective orga-
 nizations. Ideally, user groups should
 remain involved and as broad as pos-
 sible. Conference calls are still held
 twice each month  to address Geo-
 Tracker issues.
    It helps to form partnerships
 with other state and federal agencies
 to  identify the  benefits of sharing
 information.   Establish  common
 "themes" and data  elements. Every-
 one should be reading from the same
 script and speaking the same lan-
 guage.

 How Far Out in Left Field
 Are You?
 If you plan to get started on GIS,
 there is no time like the present to
 begin the process of improving loca-
 tion data. The first step is often to
 "clean" your data. For example,
 before you verify  the  location  of
 wells, give each well a unique identi-
 fication name  or  number.  Older
 water systems may have a confusing
 array of names, or a single name
 applied to multiple wells. In Califor-
 nia, a delay in issuance of state well
 names left many  wells officially
 "unnamed."
    The biggest barrier to performing
 spatial analysis is obtaining accurate
locations.  Starting  with what you
 already have, plot your data and find
out where each location is. If the site
 appears to be out in the ocean or in a
 different state, you know if s wrong.
 You can also run a sample analysis.
 LLNL evaluated  the  location  of
 drinking water wells in California. To
 do this, the lab acquired highly accu-
 rate locations for over 1,000 wells and
 compared them with locations in the
 state database—26 percent of the sites
 were within 1,000 feet of the actual
 location and 40 percent were within a
 half a mile.
    Improving  locations for LUST
 and UST facilities can be relatively
 easy.  Permitted   facilities   have
 addresses, but water wells generally
 do not. Thus different approaches are
 needed. Geocoding software is avail-
 able   that  can  match  up  street
 addresses with latitudes and longi-
 tudes.
  |E// helps to form partnerships with
  j^1—"" *" n        r  "
  Bother state and federal agencies to

   I identify the benefits of sharing
   'T*^ ^   JJ.*»r    _    \
    information. Everyone should he

           rom the same script and

  '$.-, speaking the same language.
                                 1
                                 I
    In California, LLNL found that
 84 percent of commercial facility
 addresses produced reasonably accu-
 rate latitudes and longitudes with an
 estimated median error of 396 feet.
 According to Dr. Anne Happel of
 LLNL,  the  batch  approach  and
 address matching are most cost- and
 time-efficient for regulated facilities.
 First, the addresses are standardized
 and verified using U.S. Postal Service
 software, then they are matched up
 to  locations  using  commercially
 available geocoding services. "If it is
 a facility owned by a corporate entity,
 make sure you have the address of
 the facility with the tanks, and not the
 corporate office," cautions Happel.
    When LLNL compared verified
 well location data for over 1,200 wells
 with locations in the state database,
 the median error was estimated to be
 2,251 feet. Obviously, when a buffer
 or radius of 1,000  feet is used  to
 assess vulnerability, a high level of
 accuracy is needed for well locations.
Accurate well locations are more dif-
ficult to obtain, but with GPS technol-
ogy improving, and becoming less
 expensive and more available, help is
 on the way. When data are directly
 downloaded from a GPS unit into the
 system, it allows for "single entry,
 multiple use." It saves time and
 reduces errors. Old-fashioned map-
 ping onto assessor parcel maps and
 digitizing is also a possibility. Cali-
 fornia's DHS is committed to getting
 location information to within a 25-
 meter accuracy by 2003.

 Security Issues
 Of course, with thousands of wells
 and facilities and their related data,
 you can never  guarantee 100 percent
 accuracy and availability. All Internet
 mapping sites include disclaimers
 concerning the accuracy of data. A
 disclaimer describes the purpose of
 the application—for example, to pro-
 vide a visual display of statewide or
 local data from various sources. The
 disclaimer directs the-user to the state
 agency staff to be sure of obtaining
 complete, accurate, and up-to-date
 information.
    The disclaimer also points out
 particular  requirements  such  as
 screen resolution that are necessary
 to properly view the features and
 indicates that the sites are dynamic
 and subject to change as more maps
 are created. Some maps or databases
 may  be  temporarily  unavailable
 because of updating. For the applica-
 tions that  allow the user to  input
 data, such as GeoTracker, passwords
 are issued to authorized users.

 Interim Steps—Your
 Warm-Up Act
 A number of states have plans  in the
 works to develop or improve their
 GIS and Internet access. Virginia
 plans Internet access to its geodata,
 and at present has put in place  an
 interim step. It is a "very friendly"
 GIS station located at each of the six
 regional offices and headquarters
 that is available to the public. The
 geodata contains all 15,000 petroleum
 release sites plus historical data.
    Users can select counties, "pan"
 around for a specific site, zoom in or
 out, or identify sites within a given
radius. They can also look for a spe-
 cific petroleum complaint or  a site
name and address, and determine
whether the complaint is "opened or
dosed." For more detailed information,
                • continued on page 10

-------
LUSTLinc Bulletin 36
   SiygeKafes;
The Subsurface Fate of Ethanol

A Look at the Emerging  Oxygenate

Alternative to  MTBE

Susan E. Powers and David Rice
    Jn response to the widespread contamination caused by MTBE-blended reformulated gasoline (RFC), legislative initiatives in
    several states and at the federal level have phased out, or are trying to phase out, the use of MTBE as a gasoline oxygenate.
    Ethanol is currently the most likely gasoline oxygenate alternative to MTBE. This potential for increased use ofethanol has
been most loidely acknowledged by California. The California Executive Order requiring the phase-out of MTBE also required that
an analysis of the fate, transport, and health risks associated with the use ofethanol as a gasoline oxygenate be conducted. It is clear
that California and many other states now recognize the need to understand the environmental fate of gasoline oxygenates before
any policy decisions are made regarding their widespread adoption.
    The material included in this article begins to summarize findings of the study completed for California. The full report is avail-
able at httir./fwwio-erd.llnl.vov/ethanol/. The primary physical and biological properties ofethanol that have implications for ground-
water contamination are identified in this article. Future articles will focus on the uncertainties in our understanding and research
required to make sound policy decisions. (For an overview on ethanol, see LUSTLine #32, June 1999, "With the Possible Phase-Out
of MTBE, Wliat Do We Knozu About Ethanol?" by Bruce Bauman.)	
 Ethanol Use in Gasoline
 Ethanol is currently used in  oxy-
 genated gasoline, albeit not as widely
 as MTBE. Meeting the federal oxygen
 requirement would call for 8 percent
 (by volume) ethanol for oxyfuel and
 6 percent for RFC. However, because
 of  a 54 cents per gallon of ethanol
 used federal subsidy, the blending of
 ethanol at 10 percent with gasoline is
 popular. Several states provide addi-
 tional subsidies for ethanol produced
 and used in their own states. (See
 sidebar on page 9.)
    In Nebraska, 21 percent of  all
 motor fuel sold contains 10 percent
 ethanol. At present, 60 percent of
 gasoline sold in Illinois, and 90 per-
 cent of gasoline sold in the Chicago
 area, contains 10 percent ethanol.
 Throughout the country,  U.S. con-
 sumers use  more than 56 million
 cubic meters  (15 billion gallons) of
 ethanol-blended gasoline each year.
     The ethanol used for fuel is made
 primarily from   grains  or  other
 renewable agricultural and forestry
 feedstocks. One advantage of ethanol
 is  that it can be made from liquid or
 solid waste, such as wood by-prod-
 ucts, or agricultural waste, such as
 rice straw. The ethanol used for fuel
 is  a high-octane, water-free alcohol
 produced from the fermentation of
 sugar or converted starch.
     Unlike most gasoline hydrocar-
 bons, ethanol loves water. These two
fluids are completely miscible. This
property has important implications,
both for the manner in which we use
ethanol-blended RFC and its envi-
ronmental impacts. For example, it is
difficult to   distribute  ethanol-
blended RFC because of the propen-
sity for water  to absorb into the
gasoline. Gasoline distribution termi-
nals receive gasoline and ethanol sep-
arately; the two are then mixed as
they are  pumped  into the tanker
truck for  delivery to a gasoline sta-
tion (Figure 1). With current ethanol
production capabilities, most of the
ethanol used would be produced in
                Ethanol Bulk
                  Storage
            Gasoline Bulk
               ^torage _  _^.
         The life cycle of ethanol-RFG has some components that are significantly
                    different than other gasoline formulations.       j;

-------
                                                                                             LUSTLine Bulletin 36
 the Midwest and shipped by rail or
 marine  cargo and then  by rail or
 truck delivery to a final destination
 terminal.
    Given the nature of the ethanol
 life cycle, the most likely spill scenar-
 ios associated with the use of ethanol
 as a primary fuel oxygenate would
 involve leaks of  ethanol-blended
 RFG from tanker accidents or USTs
 or spills of neat ethanol at distribu-
 tion terminals.
     CH3-O-C-CH3
                CH3

            Ethanol
         CH3-CH2-OH
            Hexane
        CH3-(CH2)4-CH3
      Molecular structure df gasoline
   oxygenates and hexane, a representative
    component of gasoline. The electrons
    (") on the oxygen atoms make the
   MTBE and ethanol molecules polar and,
    therefore, much more water-loving
     (hydrophilic) than hexane or other
         gasoline hydrocarbons.
Potential Impacts of Ethanol
on Groundwater Quality
Many of the chemical properties and,
therefore, the environmental trans-
port properties of ethanol are similar
to those  of MTBE.  The chemical
structures of these two molecules can
help  us understand their environ-
mental fate (Figure 2). The oxygen
atom in both MTBE and  ethanol
makes these molecules more polar
than other petroleum hydrocarbons.
This polarity is the reason that they
"love" water, a property described
by the term "hydrophilic." Thus both
MTBE and ethanol have a relatively
high  solubility in water and high
mobility in the subsurface relative to
more hydrophobic  (water-hating)
gasoline constituents such as hexane.
    The key difference in the envi-
ronmental fate of these  two oxy-
genates is caused by  the tert-butyl
group on the MTBE molecule. This
branched structure makes biodegra-
dation of MTBE very difficult. Thus,
while the ethanol molecule can be
degraded and naturally attenuated in
the subsurface, the MTBE molecule is
not effectively attenuated, allowing it
to travel significant distances from a
spill site. The net effect of these prop-
erties results in very different envi-
ronmental impacts associated with
these two gasoline oxygenates:
   •  MTBE  deleteriously   affects
      groundwater  quality  for  ex-
      tended periods.
   •  Ethanol is not expected to be a
      significant groundwater conta-
      minant for extended periods.

    Although we  do  not  expect
ethanol to contaminate groundwater
as much as MTBE, it is possible that
its presence in gasoline and ground-
water near a spill site  will affect
groundwater concentrations of other
constituents from the gasoline—for
example, benzene, a known carcino-
gen.
    When considering the ultimate
risk of any contaminant in the sub-
surface, we are most interested in
potential  groundwater  concentra-
tions at some receptor point down-
gradient of a spill site (Figure 3).
Numerous processes can affect these
concentrations following the spill of a
petroleum product. The presence of a
hydrophilic compound in the gaso-
line  adds additional processes  we
have not had to consider previously.
Research conducted so far has identi-
 fied the following important issues:
   • Sufficient amounts of ethanol
     can decrease the interracial ten-
     sion of the gasoline, potentially
     inducing greater lateral spread-
     ing of the gasoline within the
     capillary fringe.
   • The presence  of ethanol  in
     water  can create a cosolvent
     effect,  increasing  concentra-
     tions of other contaminants.
   • All of the  oxygen (and other
     electron acceptors,  such  as
     nitrate, iron, and sulfate) and
     nutrients   needed   for   the
     biodegradation of benzene can
     be  consumed  as  ethanol  is
     biodegraded.

    Insufficient work has been com-
pleted to date to allow us to under-
stand the net effect of the first issue.
Both of the other two processes may
result in an increase in the concentra-
tion of  hydrophobic  compounds,
such as benzene, and an increase in
the distance these compounds would
travel from a spill site before attenu-
ating processes reduce their concen-
trations.  Note  that there  are  no
known field studies of the behavior
of  ethanol  and  BTEX (benzene,
toluene,  ethyl benzene and xylene)
from an UST release. Efforts are
under  way  to identify sites.where
ethanol-blended gasolines have been
used and presumably been released
from an UST.

                • continued on page 8
              Flow through unsaturated zone

                        reading as a gasoline pool
                          ort and biodegradation
                      (affected by rapid ethanol biodegradation)
  Predicting groundwater quality and health risks at a downgradient receptor location requires
  that the net effects of several fate and transport processes be understood. Ethanol in gasoline
  can potentially increase concentrations of constituents dissolving from the gasoline source
                   and decrease rates of BTEX biodegradation.

-------
LUSTLine Bulletin 36
 I Ethanol/rom page 7
Cosolvency Issues
When mixed with water in the labo-
ratory,  ethanol quickly and com-
pletely   transfers  from  ethanol-
blended RFG into the aqueous phase.
Depending on the volume fraction of
ethanol in the gasoline and the rela-
tive volumes of gasoline and water
that are mixed, it is possible that the
resulting aqueous-phase concentra-
tions of ethanol will be high enough
to increase aqueous-phase concentra-
tions of other hydrophobic com-
pounds such as benzene.
    The addition of ethanol to gaso-
line affects these concentrations by
the "cosolvent effect." Cosolvency
describes the reduction of the polar-
ity of the aqueous phase when high
concentrations  of  organic  com-
pounds, such as alcohols, are present.
Essentially, the  ethanol molecules
add organic material to the aqueous
phase, making it more attractive to
other organic molecules.
    Figure 4 illustrates the approxi-
mate logarithmic increase in BTEX
concentrations  with   increasing
ethanol concentrations. It has been
predicted that the volume fraction of
the dissolved ethanol in groundwater
systems will be less than or equal to
             15 percent (i.e., 150,000 mg/L). At
             these relatively low ethanol volume
             fractions, BTEX concentrations in the
             aqueous phase near a gasoline spill
             are predicted to increase by approxi-
             mately 20 to 50 percent.
                The smallest percentage increase
             (smallest slope)  was observed for
             benzene, the least hydrophobic of the
             BTEX compounds. Therefore, it is
             unlikely   that   cosolvent-related
             increases in BTEX concentrations will
             be significant at the field scale follow-
             ing spills of ethanol-blended RFC.
             Spills of neat ethanol at-a bulk termi-
             nal, however, could result in very
             high ethanol  concentrations  in a
             localized area. This problem could
             cause a much more significant—pos-
             sibly  an  order  of  magnitude—
             increase in BTEX concentrations if the
             soil was previously  contaminated
             with a petroleum product. Field stud-
             ies are in progress that should help
             clarify our understanding of cosolu-
             bility issues.

             Biodegradation Issues
             Ethanol can be degraded either aero-
             bically (in the presence of oxygen) or
             anaerobically (in the absence of oxy-
             gen) at faster rates than can other
             gasoline constituents (e.g., benzene,
             MTBE). In laboratory studies with
       ~ 10,000
           1,000
        CD
        u
        d
        u
        
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                                                                                              LUSTLine Bulletin 36
     How Much Ethanol Is in That Gallon of RFG?
          Did you know that no real formal definition exists for how much
          ethanol you need in gasoline to call it gasohol? It's frequently
          assumed to be 10 percent, but there is no legal definition. How
   much of an oxygenate might we expect in a gallon of gasoline? To meet the
   2.0 and 2.7 weight percent oxygen requirements of reformulated gasoline
   (RFG) and oxygenated gasolines (oxyfuel), respectively, requires 10.8 and
   14.8 volume percent MTBE. Technically, the use of ethanol in RFG requires
   only 5.7 percent (7.8 percent for oxyfuel), inasmuch as ethanol has a higher
   oxygen content than MTBE. In the real world, ethanol is almost always
   blended into gasoline to 10 percent volume. The reason? MONEY!
      There is a federal tax break for the use of ethanol in gasoline—54 cents
   per gallon of ethanol used. The ethanol tax incentive has three tiers reflecting
   ethanol/gasoline blends  at volumes of  10 percent, 7.7 percent,  and
   5.7 percent.

   The Specifics
   The 18.4 cents per gallon federal excise tax on gasoline is used to fund the
   Federal Highway Trust Fund, the primary source of federal dollars used for
   road-building projects. The ethanol tax incentive is highest when ethanol is
   blended at a 10 percent level. When it is blended into gasoline at that level,
   each gallon of gasoline receives a 5.40 cents exemption from the federal
   excise tax. (Each gallon of gasoline contains 0.1 gallon of ethanol, so the tax
   exemption is 0.1 x 54 cents, or 5.4 cents.) For ethanol blended into gasoline
   at 7.7 percent, each gallon of gasoline receives a 4.16 cents exemption. (In
   this case, each gallon of gasoline contains 0.077 gallon of ethanol, so the
   exemption is 0.077 x 54 cents, or 4.16 cents.) For 5.7 percent ethanol/gaso-
   line blends, the exemption is 3.08 cents. (You do the math for this one.)
      The actual economic calculus that a gasoline blender would use is fairly
   complex. To grossly oversimplify things, it is usually most profitable to use
   the 10 percent blend. It basically means that you can sell your gasoline at
   the pump for the same price as the nongasohol station across the street but
   get a 5.4 cents per gallon "rebate" from the federal government. That usu-
   ally makes more "cents" than blending at 7.7 percent and getting only a 4.16
   cent rebate.
      A quick check of data from a recent national gasoline survey confirms
   this assumption. Nationally, the average ethanol concentration in alcohol-
   blended fuels during the summer of 1999 and the winter of 1999-2000 was
   about 10.1 percent, with a minimum value of 9.5 percent and a maximum of
   11.0 percent.
      Several states provide additional  subsidies for ethanol produced and
  used in their own states. The take-home message here is that in the majority
   of cases, if a gasoline contains ethanol, be it an RFG or oxyfuel, it is probably
  present at about 10 percent by volume.  •
revealed that they indeed know that
they have had spills of gasohol, but
they cannot be tracked because data-
bases archiving spill histories gener-
ally do  not identify the type  of
gasoline. The lack of any regulations
requiring groundwater to be tested
for ethanol content also contributes to
the scarcity of data. The paucity of
historical data confounds efforts to
understand and predict the effects of
ethanol on groundwater quality.
    We should learn from lessons
associated with MTBE—namely, that
the ubiquity of MTBE in the environ-
ment was not understood until we
started to look for it. Analytical tech-
niques for assessing ethanol concen-
trations are now available. It is time
to start adding this analyte to routine
monitoring  at  gasoline-impacted
sites, especially in the Midwest, Cali-
fornia, and other locations where
ethanol is already in use.
    At this point, no extensive mod-
eling studies are available to predict
the overall fate of ethanol and BTEX
in an aquifer following a spill of
                                      ethanol-blended   RFG.   Various
                                      researchers have conducted model-
                                      ing studies but always with limiting
                                      assumptions about the significance of
                                      cosolvency or biodegradation mecha-
                                      nisms. For example, many of the
                                      models assume that BTEX biodegra-
                                      dation does not occur in areas where
                                      ethanol is present at concentrations
                                      above some threshold value. Regard-
                                      less of the assumptions employed,
                                      the conclusions drawn from the vari-
                                      ety of modeling studies'suggest that
                                      benzene  is likely to travel  farther
                                      from ethanol-blended RFG  release
                                      sites. Predictions generally show that
                                      benzene   plumes  from  ethanol-
                                      blended gasoline could be from 20 to
                                      150 percent longer than those from
                                      nonoxygenated gasoline.
                                         As states and the federal govern-
                                      ment ponder the increase in use of
                                      ethanol as an oxygenate and a bio-
                                      mass fuel, the potential environmen-
                                      tal benefits and costs associated with
                                      this oxygenate must be weighed and
                                      compared with other economic and
                                      social implications. (Ideally, the poli-
                                      tics won't overshadow the science.)
                                      Conclusions drawn based on the lit-
                                      erature review completed for Califor-
                                      nia suggest  that  the  effects on
                                      groundwater resources associated
                                      with the use of ethanol will be less
                                      severe and more manageable than
                                      those  associated with the use  of
                                      MTBE.H
    Susan Powers is with the Depart-
   ment of Civil and Environmental
Engineering at Clarkson University in
  Potsdam, NY. She can be reached at
 sep@clarkson.edu. David Rice is with
the Lawrence Livermore National Lab-
  oratory, Environmental Protection
Department, in Livermore, CA. He can
    be reached at rice4@llnl.gov.

  This article was prepared from the
  review completed for the California
  Environmental Policy Council by
Lawrence Livermore National Labora-
 . tory under the auspices of the U.S.
 Department of Energy (Contract W-
7405-Eng-48). Much of the work cited
in this report was conducted with addi-
tional financial support from the U.S.
   EPA Science to Achieve Results
(STAR) program in the National Cen-
 ter for Environmental Research and
   Quality Assurance (NCERQA)
     (grant number R821114).

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LUSTLinc Bulletin 36
  DTHER OXYGENATES
  In NEIWPCC's MTBE survey, states were asked if they analyze for any of the following oxy-
  genates: ethanol, TBA, TAME, ETBE, DIPE, or any others. The overwhelming majority of states
  Indicated that they do not analyze for any of these substances. Of the states that do:
    • Two states analyze for ethanol "most of the time" and eight states "occasionally."
       South Carolina and Nevada indicated that they have sites where it has been detected.
    • Six states analyze for TBA most of the time, and 15 do occasionally. Six of these states
       have multiple sites where TBA has been detected.
    • Five states analyze for TAME most of the time, and 12 do occasionally.  Four indicated
       that they have a few to several sites where TAME has been detected.
    • Four states analyze for ETBE most of the time, and 10 do occasionally.  Three states
       have sites where ETBE has been detected; Iowa had 33.
    • Six states analyze for DIPE most of the time, and 9 do occasionally. Four have multiple
       sites where it has been detected.
    • Missouri monitors for EDB occasionally and South Carolina monitors for ETBA, TAA,
       and TBF occasionally.
      Only five states monitor for ethanol; two others say they do sometimes. Seven states
  indicated that they have ethanol-contaminated LUST sites. Mot surprisingly, 36 states indi-
  cated that they did not know whether they have ethanol-contaminated LUST sites. Kansas has
  identified 70 sites that have sold a 10 percent ethanol/gasoline mix. The state  is in the process
  of analyzing these sites. •
     For Moiie  Information About Ethanol...
  Blue Ribbon Panel on Oxygenates in Gasoline. Achieving clean air and dean water:
     the report of the Blue Ribbon Panel on Oxygenates in Gasoline; EPA 420-R-99-
     021; U.S. Government Printing Office: Washington DQ 1999
     (http: / / www.epa.gov / otaq/ consumer / fuels / oxypanel / r99021 .pdf ).

  Corseuil, H. X., Hunt, C, dos Santos Ferreira, R., and Alvarez, P. J. J. 1998. The influ-
     ence of the gasoline oxygenate ethanol on aerobic and anaerobic BTX biodegra-
     dation. Wat. Res. 32 (7), 2065.
  Corseuil, H. X., and Alvarez, P. J. J. 1996. Natural bioremediation perspective for
     BTX contaminated groundwater in Brazil. Water Sci. & Technol. 35, 9-16.

  Heermann, S. E., and Powers, S. E. 1998. Modeling the partitioning of BTEX in
     water-reformulated gasoline systems containing ethanol. J. Contain. Hydrol.
     34(4), 315.
  Hunt, C. S., Alvarez, P. J. J., dos Santos Ferreira, R., and Corseuil, H. X. 1997. Effect
     of athanol on aerobic BTEX degradation. In: B. C. Alleman and A. L. Leeson
     (eds.), In situ and onsite bioremediation, 4 (1). Batelle Press, Columbus, OH, pp.
     49-54.
  Rice, D. W. (and others). Health and environmental assessment of the use of ethanol
     as a fuel oxygenate. Volume IV — potential ground and surface water impacts.
     Published by the state of California, UCRL-AR-135949, 1999 (http://www-
  http:/ / www.afdc.doe.gov/. Alternative fuels data center (USDOE). Biodiesel /
     ethanol general information. U.S. government fleet information. Alternative fuel
     vehicles.
  hjtp:/ / www.cleanfuels.net/. Oxygenated Fuels Association.

  http://www.ethanolrfa.org/. Renewable Fuels Association.

  http: / /_w_ww.greenfuels.org / index.htm. Canadian Green Fuels Association.

  hjtp:/ / www.ethanol-gec.org/. Governor's Ethanol Coalition.
  http://5jayw.ethanol.org/main.html. American coalition for ethanol. Information
     on ethanol, MTBE, publications, press releases, and more. Also links to other
     organizations.
                                                                               • The Future Is Coming...
                                                                               continued from page 5
such as the extent of contamination
or health risks, they are encouraged
to check the  site  characterization
reports, which are available to the
public at specified regional offices. To
protect the privacy of responsible
parties, financial information related
to the ability to pay for cleanup is
kept separately.
    New Hampshire uses a similar
approach. The Site Remediation Pro-
grams for the Waste  Management
Division sponsor  a GIS terminal at
their headquarters office for the pub-
lic, consultants, and other parties to
identify potential and existing conta-
mination sources and water sources.
They charge small fees to print maps
and reports. Reports can be saved to
a disk, and a feature to save maps
will be incorporated later.  In  the
meantime, source and receptor data-
bases with addresses are available
over the Internet on a system called
"Onestop" (http: / / www.des.state.
nh.us/onestop/). That's the warm-
up act until a New Hampshire Inter-
net GIS site  is on a Web site near
you—soon.

It Just Makes Sense
The reason for getting your GIS pro-
gram up and running on the Internet
is not because everyone else doing it,
but because  spatial  analysis  can
improve your agency's ability to pro-
tect the environment through better
information and sharing of that infor-
mation. The  public  can get better
(graphical) answers to questions than
they can over the phone, and you can
spend your time doing site inspec-
tions and catching the leak before it
reaches the well.
     In the next issue of LUSTLine,
we'll  continue our technology theme
with a story about a new integrated
UST inspection system, developed by
EPA Region 2 and New York, that
uses GPS to enter information into
the database in the field...and much
 more. Stay tuned. •
     Ann Carpenter is a former EPA
   employee who now teaches geography
   at a community college in Massachu-
   setts and writes on a free-lance basis.
 10

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                                                                                         LUSTLine Bulletin 36
  "Nothing  But the Trutfi" Uses
 MTBE as Its Weapon of  Choice
 by Patricia Ellis

     &
      list came the Woburn case,
     followed by the book A Civil
      Action, followed by the movie
 starring John Travolta. Next came
 Erin  Brockovich,  starring  Julia
 Roberts, based on a case involving
 Pacific Gas and Electric in Hinkley,
 California,    where  hexavalent
 chromium had been used as an
 antif ouling agent in cooling towers
 at a  compressor  station.  With
 MTBE playing such a major role in
 my life these days, I'd been trying
 to decide which  of  the major
 MTBE impacts  or  which of the
 many MTBE legal  cases in the
 works would make a good book or
 movie. Now mystery writer John
 Lescroart   has  presented   us
 with	
    Oh, wait—that book is fiction.
 Nobody really dumped MTBE in a
 reservoir as an act of eco-terrorism.
 So far,  the  impacts  to water
 resources in real life have all been
 "accidental"—accidental    tank
 leaks, accidental pipeline leaks,
 accidental car accidents, and other
 assorted  accidental spills.  The
 gasoline leaks that cost Santa Mon-
 ica more than half of its water sup-
 ply, the problems that caused the
 shut down 13  of 35 wells in South
 Lake Tahoe, or the spill from the
 Explorer pipeline that took out one
 of Dallas's water supply reservoirs
 for  months?  These  incidents
 weren't  fiction  like Lescroart's
 book.
    Nothing But the  Truth is mys-
 tery   writer   John  Lescroart's
 eleventh novel, including two that
 have  made the New York Times
 best-seller list. The plot involves
 petroleum, MTBE, evil efhanol lob-
byists,  gubernatorial   politics,
 romantic tangles (sorry, no steamy
 sex scenes),  grand  juries,  and
lawyers,  including an ambitious
prosecutor out to make a name for
himself. What more could  you
want?
     The book involves the death of
 Bree Beaumont, a scientist who had
 believed that MTBE was wonderful
 for improving air quality and had
 been a consultant for the Western
 States Petroleum Association and
 later for Calco Oil. Shortly before her
 death, she had changed sides in the
 volatile wars over the gasoline addi-
 tive, after coming to believe that
 MTBE was a cancer-causing additive
 that was seeping into California's
 groundwater in alarming amounts.
     In the story, MTBE was big busi-
 ness for the  oil  companies—they
 were making $3 billion per year on it.
 On the other hand, the ethanol indus-
 try profits were a mere $45 million in
 the United States just before Califor-
 nia announced its MTBE ban.  Now
 the ethanol market was expected to
 multiply exponentially. Stakes were
 high.
    During pre-election speeches,
 gubernatorial candidate Kerry calls
 for an immediate moratorium on
 MTBE use. "There is no reason to tol-
 erate even for one more moment this
 dangerous and insoluble toxin in our
 gasoline where there is an environ-
 mentally safe and effective substitute
 so  readily  available, and by this I
 mean ethanol."
    We need to point out at this junc-
 ture that MTBE is not "insoluble." If
 it were, MTBE would hardly  be a
 groundwater issue.  While it  isn't
 completely miscible (as is ethanol), it
 does have  a rather high solubility
 (45,000 ppb) compared with benzene
 (1,707 ppb).
    Back to the  story—candidate
 Kerry's opponent, speaking about the
 act  of eco-terrorism, says "If s not the
 MTBE that has caused this terrible
 crisis any more than it is guns that
 kill people. People kill people, and
 people—criminals—have  poisoned
 the  San  Francisco water supply.
 Gasoline without additives would
have produced the same effect, and
 "Nothing But the Truth" by John Lescroart,
 Delacorte Press, January 2000.
 no one is talking about making
 gasoline illegal."
    Well I can't think how many
 times I heard during the Blue Rib-
 bon Panel hearings, "It's not the
 MTBE, if s the tanks. If 'you people'
 would keep the tanks from leaking,
 the MTBE wouldn't be a problem!"
    A visit to Bree's office sounded
 like a visit to my office—"propa-
 ganda by the  armload on...every
 imaginable  side of the additive
 issue.  Legislative  reports,  news
 clippings,  executive  summaries
 from various  thinktanks,  media
 alerts.  MTBE, ethanol,  reformu-
 lated gasoline." Did this get Bree
 killed?
    As I read the book— with the
 idea of writing a review of it—I was
 "sticky-noting" the pages  where
MTBE  was mentioned. Lescroart
had a pretty good handle on the
issues and facts involving MTBE,
putting the proper words into the
mouths of each of his characters.
Now, who can we cast as... •
  Pat Ellis is a hydrologist with the
 Delaware DNREC LIST Branch and
    was a member ofEPA's Blue
         Ribbon Panel.
                                                                                                   11

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LUSTUne Bulletin 36
Diving Plumes  and  Vertical
Migration at  Petroleum
Hydrocarbon  Release Sites
by James W. Weaver and John T. Wilson

     Petroleum hydrocarbons  are
     mostly less dense than water.
     So they should float or at least
hang around the water table, right?
Not so fast. There are some fairly
common situations where we would
expect a plume of petroleum hydro-
carbons to move vertically into the
aquifer—as a result  of water  table
drawdown associated with pumping
from water supply wells, smearing
of contaminants due to water table
fluctuation and  site investigation
activities, and movement of water
through preferential flow paths in
heterogeneous environments. But
even in the absence of any of these
circumstances, a plume may still
move downward, or "dive," into an
aquifer.
    This  diving situation occurs
when groundwater recharge enters
the top of a shallow water  table
aquifer. Once in the  aquifer, this
water begins to move in the direction
of  groundwater  flow. Because the
recharge water is entering the aquifer
from above, it can push contaminant
plumes downward. The amount that
a plume "dives" depends on the
amount of recharge water entering
 the system and the relative contribu-
 tion this additional water makes to
flow in the aquifer.
     We expect  that  such diving
plume scenarios may occur in the
 wetter parts of the country, but even
 in dry climates, recharge-driven div-
 ing can occur because of irrigation,
 leaking water or sewer pipes, or
 recharge  from ephemeral surface
 water features. In either case, plume
 diving depends on the localized pat-
 tern of recharge, the flow rate in the
 aquifer, and the distribution of conta-
 minants—as shown in the following
 East Patchogue, New York, example.

 East Patchogue, New York
 A  gasoline  release  at an  East
 Patchogue, New York, UST facility
 _
created  large  BTEX and
MTBE plumes. The plumes
were detected  because  a
private water supply well,
located 4,000 feet down-
gradient from the source,
was  in their path. The
well screen was about 50
feet  below  the water
table, where much of the
MTBE mass was  located.
The site investigation started at this
point and went upgradient to iden-
tify the source.
   Because of the importance of the
aquifer for drinking water supply,
New York undertook an extensive
investigation of the  site, including
vertical   characterization of  the
plumes. Multilevel samplers with 6-
inch screens at 5-foot intervals were
used. A resulting vertical  section
through  the  plume showed that
BTEX and MTBE tended to dive into
the aquifer with distance from the
source. (See Figure 1.) It was further
noted that a significant amount of
diving occurred as the BTEX plumes
passed under a gravel pit.
                   By studying the well
              logs and performing a
             detailed hydraulic charac-
            terization of the aquifer with
           a borehole flowmeter, investi-
      gators ruled out vertical migration
      controlled by stratigraphy, because
      the hydraulic conductivities varied
      by less than a factor of 2 over the
      aquifer. This left recharge as the most
      likely explanation for the plume div-
      ing. The model described in the side-
      bar on page 14 was used to simulate
      the site and provided additional evi-
      dence that recharge was the cause of
      the diving.
         This Patchogue example sheds
      light  not  only  on how recharge
      pushes the plume downward, but
      also  on what happens when water
      discharges  from  aquifers. Where
      water comes up at discharge points,
      so  will the contaminants—along
      streams, rivers, lakes, or the ocean.
       40 -


        0 -
   S  -40 H
   CO
   UJ
      -80 -
     -120
                                           Gravel Pit
                                                    Total Xylenes
             6,000
-I	1	1
 4,000           2,000
    Distance (ft)
   A vertical cross section through the MTBE, benzene, and total xylene plumes at East
   Patchogue, New York. The gasoline source is located at the right-hand edge of the sections, \
   and flow is to the left. Each of the plumes dives into the aquifer with transport in the aquifer.

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                                                                                             LUSTLine Bulletin 36
  The ocean is the expected destination
  of  the  MTBE   plume  at  East
  Patchogue, where the groundwater
  flow system discharges into Great
  South Bay, adjacent to the southern
  shore of Long Island. The groundwa-
  ter and contaminants move upward
  as they approach the discharge point
  at the bottom of the bay.

  Consequences of Missing
  the Dive
  What about the consequences of a
  diving plume, or more to the point,
  the consequences of missing a diving
  plume?  We  averaged  the   East
  Patchogue data set to show how the
  plume would appear if sampled only
  from long-screened wells. The  data
  were averaged over the top 10 feet of
  the aquifer to simulate 20-foot  well
  screens—10 feet in and 10 feet out of
  the aquifer.
     The graphs in Figure 2 show two
  sets of concentrations plotted along
  the length of the plumes. The  first
  data set (circles) shows the maximum
  concentrations  from the multilevel
 samplers. This set represents the
 maximum concentration measured in
 each sampler, regardless of depth, at
 each location along the plume.  It  is
 intended to be  a reference to show
 the extent of contamination on the x-
 y plot.
    The second  concentrations (dia-
 monds) are the values for the simu-
 lated 10-foot screens. For these, the
 MTBE concentrations all fall below
 New York State's  threshold  of 10
 /ig/L. With only  these  data  we
 would have concluded that there was
 no MTBE plume at this site.  The max-
 imum concentrations, however, indi-
 cate a significant MTBE plume in the
 downgradient portion of the aquifer.
    The  simulated  long-screened
 data show that  the benzene plume
 appears to be shortened to about one-
 third its actual  length. This effect
 occurs because plume diving pushes
 the benzene plume out of the bottom
 of the sampling network. Along the
 way,  the concentrations appear to
 decrease, because clean and  contami-
 nated water mix in the  well. This
mixing results in diluted samples and
lower concentrations.
    Interestingly, the long-screened
data also show that the total xylenes
and benzene plumes appear to be the
same length. Here, because of sorp-
                                    Maximum
                                    Average of Top 10 Feel
                - 6,000
                - 4,000
                -2,000
                 0
                - 8,000

                - 2,000

                -1,000
                                                    p 20,000
                                                    -16,000
                                                    - 12,000
                                                      8,000
                                                    -4.000
                5,000  4,000  3,000  2,000 1,000
                     Distance from Source (ft)
  I Consequences of sampling only the top 10-feet of the aquifer at East Patchogue. The MTBE \
   plume disappears (top), the benzene plume is shortened by two-thirds, and the total xylenes
   plume appears at the same length, because it does not reach the gravel pit where diving dom-
  | inates the contaminant distribution.
 tion, the total xylenes did not travel
 far enough in the aquifer to drop out
 of the monitoring network, and there
 was no apparent shortening  of the
 plume. Nevertheless, these two cont-
 aminant distributions hint at a sam-
 pling problem. Our expectation is
 that there should be separation of
 benzene and total xylenes caused by
 sorption. In this case, the expected
 chromatographic separation has been
 negated by the monitoring network.

 Rethinking Our Assumptions
 Are plumes longer than we  think
 they are? The short answer is yes!
 The reason we think that they are
 shorter is that most LUST site moni-
 toring well networks do not ade-
 quately   delineate   contaminant
 plumes in three dimensions.
      "Conventional"  monitoring
 wells are primarily designed to moni-
 tor for the presence of free product
 floating on the water table. To accom-
 plish this task, conventional wells are
 constructed  with  relatively  long
 screens that bisect the water table.
 This approach is meant to allow for
 seasonal fluctuations in water table
 elevation in the hope that the screen
will extend below the lowest low-
 water elevation and just above the
 highest high-water elevation.
     Also, many monitoring networks
 consist of relatively few wells, most
 of which are located on the LUST site
 property. We've seen that such net-
 works are not well suited for deter-
 mining the true extent of a plume,
 nor can they provide accurate infor-
 mation about the vertical distribution
 of either contaminants or hydraulic
 conductivity. The lack of such data is
 a critical limitation for performing a
 quantitative risk assessment.
    Groundwater   samples   drawn
 from these conventional wells repre-
 sent  composite samples.  Because
 they mix waters of varying true con-
 centrations, they are diluted and give
 a falsely low impression of the sever-
 ity of contamination.
    So how do we  interpret concen-
 trations  of  contaminants that are
 below state or federal action levels?
 Here, an old  dictum applies: The
 absence of evidence is not evidence
 of absence.
    It may be  that, sometimes, low
 concentrations are just that. But we
need assurance that the wells have
been located such that they actually
               • continued on page 14
                                                                                                       13

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LUSTLitie Bulletin 36
m Diving Plumes from page 13

sample the plume. When we sample
from  the  wrong  place, as  our
Patchogue example shows, we may
well think that concentrations  are
lower than they actually are. As a
consequence, we incorrectly believe
that plumes are shorter than they are
actually, even to the point of appar-
ent nonexistent.
    With the prevalence of biodegra-
dation of BTEX (and some emerging
news concerning MTBE biodegrada-
tion), we may be too quick  to
attribute  short plumes to natural
attenuation, rather than to the true
cause—a sampling error.

An Approach to Assessing
Plume Diving
Is there a universal prescription for a
practical assessment of plume diving
and vertical migration? We're afraid
not. The site  assessment process
involves putting together the pieces
of the puzzle to delineate the extent
of contamination. One part of that
puzzle is a determination of the verti-
cal contaminant distribution. Because
of the potentially detrimental conse-
quences of missing a diving plume,
 the site investigation should  be
designed to ensure that a diving
plume  doesn't extend out of  the
 range of the bottom of the monitoring
 network. Site-specific factors, such as
 geology, hydrology, land use, and
 site geochemistry, provide the evi-
 dence for plume diving. The follow-
 ing factors should be evaluated in
 planning a site investigation:
 • Geology and the Sampling
 Network
 What land form contains the plume?
 Is it a flood plain, delta, or coastal
 plain? Do drilling logs indicate that
 there are discrete zones that yield
 plentiful water and other zones that
 do not?
     Core logs  give  information
 needed to define  the stratigraphy,
 including the geologic units, their
 consistency, and their orientation.
 Has a cone penetrometer or borehole
 flowmeter  test been performed?
 Have  the monitoring wells been
 tested to determine hydraulic con-
 ductivity? Have they been tested to
 determine whether they are screened
 in intervals known to yield water?
 What are the properties of the aquifer

 14
        The OnSite Plume Diving Calculator
        Calibrated numerical groundwater flow models, such as MOD-
        FLOW, can be used to show how much recharge-driven diving
        might occur in an aquifer. Inasmuch as these models are not
  applied at most LUST sites, we'd like to suggest that you try some sim-
  pler alternatives.
     From our experience at the East Patchogue site, a simple simulation
  model was developed to estimate the prospects for recharge-driven
  plume diving. The model is a part of EPA's on-line tools for site assess-
  ment called OnSite. Use of the tools requires only a standard browser and
  Internet access. The tools are available at http://www.epa.gov/aihens/
  software / training / WebCourse / part-two / onsite.
     The plume diving model allows an aquifer to be split into segments,
  each with its own hydraulic conductivity, recharge rate, and length. The
  upgradient and downgradient heads are specified in the aquifer, as is a
  starting point that represents the source and a well location. Given these
  specified aquifer parameters, an estimate is given for how deep the top of
  the plume goes below the water table at the specified well location.
      The software has been used on several Long Island sites and found to
  match the observed plumes. The model, however, is based on a simple
  one-dimensional conceptualization, and it won't be appropriate for all
  sites. It does, however, give an idea of the prospects for recharge-driven
  plume diving.
      As the site investigation moves away from the source, the model can
  be used to predict plume diving. Sampling of the aquifer can then show if
  the predictions were correct. More to the point, sampling can show if the
  plume is diving, and the model results give a guide for determining the
  vertical extent of contamination. •
with regard to depth, thickness, and
hydraulic conductivity?  Does the
well network characterize the aquifer
in two or three dimensions?
    Clearly, vertical delineation of a
contaminant plume requires three-
dimensional characterization, which
may include the use of permanently
installed multilevel wells or tempo-
rary push points. Because of the
expense of installing and sampling
from multilevel wells, temporary
push points can be used to reduce the
cost of vertical delineation.
    Using this push technique, loca-
tions  can  be  sampled  without
installing permanent wells when the
vertical location of the plume is not
known. Permanent monitoring wells
can be installed after the plume has
been located. Determining the hori-
zontal extent of contamination may
not necessarily be a simple task. Push
technologies can be of great benefit
here as well.
    Answers to the questions posed
above help  define the stratigraphy,
which serves as the geologic control
on the  contaminant distribution. In
many flood plains, for example, the
surface material is primarily heavy
silts and clays  that  have  been
deposited during  historical flood
events. Beneath these surface  silts
and clays are  sand  and  gravel
deposits  associated with previous
meanders of the river. The water
table is frequently in the surface silt
and clay. So the materials with a
capacity to carry groundwater (sand
and gravel)  and transport a plume
occur at the bottom of the sequence
of deposited sediment.
    The Elizabeth City, North Car-
olina, "Old Fuel Farm Site" illustrates
the effects of recharge, stratigraphy,
and sampling. It is described in a
report, Natural Attenuation of MTBE
in the Subsurface Under Methanogenic
Conditions, available from EPA at
http: / / www.epa.gov / ada / pubs /
reports.html.
• Hydrology and Land Use
From a topographic map, what do
elevations of areas such streams and
lakes indicate about the groundwater
flow system? How much annual rain-
fall occurs? What recharge estimates
have been developed for the area or
are commonly used? What are the
land use patterns?

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                                                                                                LUSTLine Bulletin 36
     For example, tKe flow-system at
  East Patchogue is determined by the
  regional flow on Long Island, where
  water generally flows from the center
  of the island in the north to the Great
  South Bay in the south. An average of
  44 inches of rain falls each year, and
  the United States Geological Survey
  (USGS) estimates that the  average
  recharge is about half of the rainfall.
     The  UST  facility  property  is
  paved and adjacent to  a highway.
  Downgradient, the land uses include
  light commercial, playing  fields, a
  gravel pit, and medium-density resi-
  dential areas. Each of these land uses
  influences the pattern of recharge,
  from very low recharge where the
  surface is paved to very high  recharge
  in the gravel pit.
     From this information, we could
  have suspected that the contaminants
  were likely to travel  toward  the bay.
  If the plumes moved away from the
  service station property and out from
 under the paved area, there would be
  a good chance for diving behavior,
 particularly if the plumes reached the
 gravel pit—as indeed they did.
    At other sites, unlined drainage
 ditches, leaking  water mains and
 sewer pipes, irrigation, and the flow
 pattern in the aquifer can determine
 the vertical distribution of contami-
 nants.
    Thus, where recharge is likely to
 be the plume diving instigator, the
 amount of water  that infiltrates the
 area  above the  plume, and the
 amount that this recharge contributes
 to flow in the aquifer, determines
 where and how much  diving will
 take place.

 • Geochemistry
 Simple geochemical tests can  be used
 to spot a plume that is diving because
 of clean water recharge. In general,
 uncontaminated recharge water  at
 the top of an aquifer will have oxy-
 gen  concentrations   that  exceed
 1 mg/L, iron concentrations that are
 less than 0.5 mg/L, and methane con-
 centrations that are less than 0.1
 mg/L. Groundwater that has been
 contaminated with petroleum hydro-
 carbons will generally contain oxy-
 gen concentrations that are less than
 0.5 mg/L and may contain concentra-
 tions  of iron and  methane that are
greater than 1 mg/L.  If the ground-
water is sampled with a bailer, the
sample is usually contaminated with
  atmospheric oxygen during sam-
  pling, and the rule of thumb for oxy-
  gen should not be applied.
      In general, clean recharge water
  will have low dissolved organic car-
  bon (DOC), usually less than 1.0 to 2.0
  mg/L. The plume will usually have
  elevated DOC, often exceeding  10
  mg/L.

  Putting the Pieces Together
  The stratigraphy of an area provides
  the first indication that plume diving
  should be considered. Are the conta-
  minants contained in dipping strata?
  If so, off-site  migration is likely to be
  controlled by the stratigraphy. Dip-
  ping or not, the plume direction will
  be dictated by the flow that water
  takes through the geologic structure.
     The groundwater flow rate and
  an estimate of the petroleum release
  date provide clues about travel time
  to various downgradient locations. If
  the rate  is low enough, the plume
  may never reach that gravel pit or
  unlined ditch that is waiting to drag
  it to the depths of the aquifer.
     So, before taking the site investi-
 gation off-site, can  an estimate of
 plume diving be made?  In simple
 aquifers, the OnSite plume  diving
 calculator can be used to estimate
 diving at a  specific location. (See
 sidebar on page 14.) Subsequent sam-
 pling with a  direct push probe can
 provide confirmation (or not) of the
 location of the plume,  both vertical
 and horizontal, before a commitment
 to permanent monitoring wells is
 made.
    From our  work on sites with div-
 ing   plumes,   it's clear  that  the
 prospects for plume  diving need to
 be factored into site  investigations.
 This  information can be  used to
 determine whether diving is likely to
 occur in the downgradient plume. If
 diving is a possibility, then the sam-
 pling design  must  be such that
 plumes  are   fully  characterized
 through the design of the monitoring
 network.
    By the way, plume diving is not a
 new concept.  It was evident in data
 collected  from  the  first Borden
 Aquifer dispersion experiment con-
 ducted  in the  1980s (MacKay et al.,
 1986, A natural gradient experiment
 on solute transport in a sand aquifer,
Water Resources  Research, 22(13)
2017-2029). It was also observed in
 data from the extensive USGS Cape
 Cod field study (LeBlanc et al., 1991,
 Large-scale natural gradient tracer
 test in sand and gravel, Cape Cod,
 Massachusetts,  Water Resources
 Research 27(5), 895-910). •

 Acknowledgment
 The U.S. Environmental Protection Agency
 through its Office of Research and Develop-
 ment conducted the research described in this
 article. It has been subjected to Agency review
 and approved for publication. loseph Haas of
 the New York State Department of Environ-
 mental  Conservation provided the  East
 Patchogue, New York, data set.

   Jim Weaver is with the Ecosystems
  Research Division ofEPA's National
  Exposure Research Laboratory,  Office
  of Research and Development (ORD),
  in Athens, Georgia. He can be reached
       at weaver.iim@epa.yov.

  John Wilson is with the Subsurface
  Protection and Remediation Division
  ofEPA's National Risk Management
  Research Laboratory, ORD, in  Ada,
    Oklahoma. He can be reached at
       Wilson.iohnt@epa.vov.
 DIVING PLUMES
 in  NEIWPCC's MTBE survey, when
 asked if they investigate MTBE plumes
 differently from BTEX plumes because
 of the  potential for diving plumes, 4
 states   answered  "yes"  and   15
 answered "sometimes." When asked if
 they require three-dimensional char-
 acterization of MTBE plumes, 14 of the
 19  states that answered "yes" to the
 previous question answered that they
 do  "occasionally," 3 answered "most
 of the  time," and 1 said "always."
 Delaware indicated that the answer
 depended   on  the  project officer
 whether  it  was  "occasionally"  or
 "most  of the time." Montana com-
 mented that if a vertical  gradient is
 apparent, nested wells will be required
 to  verify whether  a  diving plume
 exists.
    When asked if they are taking any
 extra steps to make sure MTBE is not
 migrating beyond standard monitor-
 ing  parameters, 19 states answered
 "yes."  When asked  what kinds  of
 steps, most said that they are using
 multilevel wells, nested wells, deeper
wells, and/or more wells located far-
ther downgradient from the source. •
                                                                                                          15

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    iiie Bulletin 36
  Oxygenates
Analytical  Issues for MTBE and

Related Oxygenate  Compounds

by Deana M. Crumbling and Barry Lesnik

      Questions have been raised about which analytical methods for MTBE and
      related analytes are appropriate within the context of state and federal LUST
      programs. To help answer some of these questions, we've prepared the fol-
lowing overview of the current status of MTBE analysis from the perspective and
experience of EPA's Office of Solid Waste (OSW) Methods Team, the group responsi-
ble for developing and maintaining the SW-846 Methods manual, and EPA's Technol-
ogy Innovation Office (TIO).
    Because MTBE is not currently a RCRA-regulated analyte, it has not been validated
in any SW-846 method at this time. Neither Method 8021 nor Method 8260 has been validated
for MTBE. As it stands, analyses of a few of the oxygenated analytes that are of more
recent interest to LUST program personnel [e.g., tert-buryl alcohol (TEA) and ethanol]
have already been validated and published in SW-846 methods several years ago.

"Approved Methods"
Confusion often arises in the search
for an "approved method." A com-
mon misconception is that  when a
method is published in SW-846 it
becomes an "approved method" and
is,  therefore, required across the
board. This is not true. In fact, any reli-
able method may be used, whether it
is published in an EPA methods man-
ual or suggested as an alternative
method. (Note: Some state UST pro-
grams require  the  use  of "EPA-
approved methods.") Any method
used must be able to determine the
analytes  of concern in the matrix of
concern at the action level of concern.

SW-846 Methods
Requirements  for  using  specific
 "EPA-approved methods" in the con-
 text of waste programs are discour-
 aged.  The   use  of  prescriptive
 analytical methods is counterproduc-
 tive to the generation of reliable data,
 because  samples  encountered  in
 waste programs are too varied and
 complex for any single method to
 work for all samples all the time. For
 this reason, the SW-846 manual uses
 a performance-based approach to
 analytical methods.
     SW-846 is intended to provide
 general  guidance, not prescriptive
 requirements. There are no "refer-
 ence methods" in SW-846, in the con-
 text that the term is used in the Office
 of Water Programs. Part of the mis-
 understanding regarding analytical
 method requirements stems from the
fact that EPA water programs do
require "EPA-approved methods"
when implementing the Safe Drink-
ing Water Act (SDWA) and the Clean
Water Act (CWA). However, meeting
SDWA and CWA requirements is not
usually the driver for projects within
waste   programs,   and   "EPA-
approved methods" are not required.
    Thus there will never be a pre-
scriptive method for MTBE within
OSW programs, even when MTBE is
included as a target analyte in pub-
lished SW-846 methods. However,
the growing interest in oxygenates
indicates that an SW-846 method that
addresses MTBE would be highly
valuable to the UST/LUST commu-
nity.
    By the time they are published,
SW-846 methods have undergone
thorough evaluation and peer review
to (1) determine the level of method
performance that can be expected
under "typical" conditions, and (2)
identify what interferences might
compromise method performance
and what to do when it happens. We
believe that some of the existing SW-
846 methods are appropriate for the
sample preparation (Method 5031)
and determination (Methods 8015
and 8260) of MTBE and other related
target analytes in aqueous matrices.
However, it would take a "demon-
 stration of applicability" to prove it.

 In the Meantime
 Until MTBE analysis is validated in
 an SW-846 method, which methods
could be used for MTBE and related
analytes? The simple answer is that
"any method that can be demon-
strated to measure the constituent of
concern, in the matrix of concern, at
the level of concern, and at the degree
of accuracy as identified as necessary
to address the site decision" can be
used. (See http://  duin.org / down-
load /char/articled^, pdf. page 2.) Of
course, demonstrating that a method
is working as expected on a variety of
real-world sample types takes time
and technical  expertise,  and that
means that the answer may not be so
simple. With this caveat in mind, lef s
look at oxygenate analysis in relation
to existing SW-846 methods.

Method 8015
The chemical and physical properties
of the target analytes and the poten-
tial for interferences in the samples
submitted  for oxygenate analyses
must be considered when selecting
potential sample  preparation and
determinative methods.  SW-846
Method 8015,  "Nonhalogenated
Organic    Compounds    Using
GC/FID,"  was developed for the
analysis  of  oxygenates and  is
expected to be applicable to MTBE
and other related compounds. (Note:
All SW-846 methods may be accessed
 on-line at http:// www.epa.eov/
 SW-846/main.htaO
    Method 8015 is a  determinative
 method [gas chromatography/flame
 ionization detector (GC/FID)] only.
 As such, it is merely part of the
 16

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                                                                                            LUSTLine Bulletin 36
"analytical  metKod"  picture.  A
"determinative method" applies to
the analytical instrumentation used
to generate the analytical result. A
sample preparation (or sample intro-
duction) method is needed to get the
target  analytes  from  the  sample
matrix into the analytical instrumen-
tation.
    An appropriate sample prepara-
tion method must be applied to the
original sample  (such  as water or
soil) so that the analytes can be trans-
ferred from the matrix onto the GC
column. If the sample preparative
method is not appropriate for the
analyte, transfer of the analytes from
the original sample into the instru-
ment may be  incomplete or unpre-
dictable, and the.final results may be
erroneous due to low recovery, no
matter how good the instrumental
determinative method is.
    Section 1.1 of Method 8015 cov-
ers some of the sample preparative
methods that have been shown to be
applicable for a variety  of oxy-
genated compounds. Note that Sec-
tion  1.1  shows  that  the  purge-
and-trap technique is rarely success-
ful for  highly water-soluble oxy-
genates. Purge-and-trap works best
for analytes that are both volatile and
relatively insoluble in water (e.g., BTEX
compounds).
    MTBE, however, is more soluble
in water than BTEX compounds, and
this characteristic decreases its purg-
ing efficiency relative to those com-
pounds, creating the possibility that
interferences  in  complex  sample
types could render purge-and-trap
analyses susceptible to  imprecision
and poor method sensitivity due to
unpredictable  sample-specific purg-
ing efficiencies. This generalization is
even more true for oxygenated ana-
lytes  that are  more  water-soluble
than MTBE is.
   As with any preparative or deter-
minative method, evaluation of sam-
ple-specific characteristics in relation
to expected method performance (to
meet project-specific needs) for spe-
cific analytes is required to determine
whether purge-and-trap  or some
other sample  preparation  method
can consistently provide the expected
data quality.
   Section 1.1 of Method 8015 rec-
ommends that samples to be ana-
lyzed  for  highly   water-soluble
oxygenated   organic  compounds
 [such as tert-butyl alcohol (TBA) and
 ethanol] be  prepared using direct
 injection  or  azeotropic  distillation
 (Method 5031). Direct injection alone
 (into a GC/FID) has been shown to
 achieve detection limits in the range
 of 400-500 ppb for TBA and ethanol.
    Azeotropic   distillation  tech-
 niques can be used to concentrate
 samples for  these alcohol  analytes.
 The azeotropic distillation sample
 preparation/concentration technique
 has been shown to produce detection
 limits in the vicinity of 10 ppb when
 the concentrated samples  are  ana-
 lyzed by GC/FID. Vacuum distilla-
 tion (SW-846  Method 5032) and static
 headspace (SW-846 Method 5021)
 could  also be considered as poten-
 tially  viable sample  preparative
 methods. Each of these preparative
 methods  will have its advantages
 and drawbacks. Additional develop-
 ment work for both preparative and
 determinative  methods  will  be
 required to validate routinely applic-
 able methods across the range of oxy-
 genate compounds, sample types,
 and detection limits that are now of
 interest.
g; The selection of any analytical
^method must always consider the
I™*—
-ultimate use of the data. TJie use of
^project-specific systematic planning
i£- can ensure that data collection
IN. -
^  methods are cost-effectively
      matched to the project's
      decision-making needs.
                                 i
                                 I
Method 8021
SW-846 Method 8021—Aromatic and
Halogenated Volatiles by GC Using
Photoionization (PID) and/or Elec-
troconductivity (E1CD) Detectors—or
a similar method that relies on a pho-
toionization detector, is not  recom-
mended as a determinative method for
MTBE and its associated oxygenates.
PID is most sensitive to compounds
that contain double bonds (which is
why this method is a good determi-
native technique  for BTEX  com-
pounds).
    MTBE and related compounds,
however, do  not contain double
bonds. Although the PID analysis
will respond to the oxygen atom in
these compounds, the  response is
weaker than the response for BTEX
compounds and, therefore, may be
subject to interference and false posi-
tives when real-world samples con-
tain significant amounts  of other
contaminants   such as  petroleum
hydrocarbons. (See pages 9 and 15 of
"An Evaluation of MTBE Impacts to
California Groundwater Resources,"
available at http:/ /www-erd.llnl.
gov / mtbe / pdf / mtbe.pdf.) The E1CD
detector of Method 8021 works only
for compounds containing halogen
atoms, and MTBE does not possess
this characteristic either.

Method 826O
GC with a mass spectrometer (MS)
detector is  also  appropriate  as a
determinative  method  for  oxy-
genates, as long as a sample prepara-
tive method  appropriate to   the
sample has been used. MS offers  the
advantage of unambiguous identifi-
cation of target compounds. It is a
good idea to keep a few things in
mind if a GC-MS  method for MTBE
and other oxygenates is discussed in
terms of SW-846 Method 8260:

  • Method 8260 has not been vali-
     dated by EPA for use  with
     MTBE.

  • Method 8260 is a GC-MS deter-
     minative   method   only—the
     sample preparation method is
     separate. Purge-and-trap is not
     specified by  Method 8260 and,
     in fact, is not recommended  for
     the few alcohol analytes that
     have been validated in Method
     8260 (e.g., ethanol and TBA).
     (See the Appropriate Prepara-
     tion Technique table in Section
     1.1 and Section 1.2.)

  • Improved   performance   of
     Method 8260 for MTBE and
     other   oxygenates   can   be
     expected if instrument operating
     conditions  are modified  to
     accommodate  that  particular
     analyte group (rather than try-
     ing to generalize operating con-
     ditions  to accommodate  the
     entire range of 100-plus vali-
     dated analytes in  the  Method
     8260 list).
                I continued on page 18

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LUSTLine Bulletin 36
• Analytical Issues for MTBE
from page 17	

Field Methods
In addition to their analysis by GC-
MS in the fixed laboratory, MTBE,
ethyl t-butyl ether (ETBE), and TEA
have  been successfully analyzed in
the field by using  a  field-portable
GC/MS and heated (at 60°C)  static
(i.e., equilibrium) headspace. Method
performance information (provided
by Field-Portable Analytical, Inc.)
shows detection limits in the range of
4-5 ppb when the MS is operated in
full-scan mode. When operated in
selective ion monitoring (SIM) mode,
detection limits down to 0.2 ppb are
possible with full positive identifica-
tion of the analytes. As samples are
analyzed in the field at the time of
collection, issues regarding sample
preservation are avoided.
    Depending on the nature of the
project, field analysis  can signifi-
cantly decrease costs by supporting
real-time decision making according
to  an Expedited Site  Assessment
approach. (See EPA 510-B-97-001,
"Expedited  Site  Assessment  for
Underground Storage Tank Sites: A
Guide for Regulators," available on
OUST's Web site at http: / /www.epa.
gov/swerustl /pubs/index.htm#sam.')

The Decision-Making Factor
Above all, the selection of any analyt-
 ical method must always consider die
ultimate use of the data. Data for risk
 assessment purposes typically need
 lower detection/quantitation limits
 than when data are used to delineate
 a plume or to place monitoring wells.
The use of project-specific systematic
planning can ensure that data collec-
 tion  methods  are  cost-effectively
 matched to the project's  decision-
 making needs.
    The flexibility inherent in SW-846
 methods permits "mixing and match-
 ing"  of  sample  preparation and
 determinative methods so that the
 needed method sensitivity and accu-
 racy  can be achieved. As long as data
 are of known quality, and that qual-
 ity has been matched to the decision-
 making needs of  the project, any
 reliable method can be used.
    Although we have discussed in
 general terms the various analytical
 method options for oxygenates that
 might be explored, a more specific

 18
answer to  the question,  "What
method should be used for MTBE
and/or oxygenates for this particular
project?", first requires that the pro-
ject  manager clearly  specify  the
intended use of the data. When this
use is known, the required detection
limits can be determined, the desired
turnaround time for the data results
can be estimated, and the most cost-
effective option for generating the
data (i.e., the sampling program and
the  analytical   methods)  can be
deduced.

For  More Information
Information about SW-846 and the
selection of analytical methods can be
found through  the Clean-Up Infor-
mation Web page of the Technology
Innovation  Office at http: / / cluin.
org/charl.htm  and the OSW Meth-
ods  Team home page at http: / /
www.epa.gov / SW-846 /. More infor-
mation about how site characteriza-
tion and cleanup can be made more
cost-effective  can   be  found  at
http://www.clu-in.org/products/
failsafe.htm. •
   Deana Crumbling is an analytical
  chemist with EPA's Technology Inno-
  vation Office, and works on improving
  the accessibility and application of site
   characterization tools to waste site
    cleanups. She can be reached at
  Crumbling.Deana@epamail.epa.gov.
  Barry Lesnik is the Organic Methods
  Manager with EPA's Office of Solid
  Waste Methods Team and is responsi-
  ble for the organic methods included in
  SW-846 and regulatory issues dealing
    with chemical analysis. He can be
    reached at lesnik.barn/@eva. mv.
Results of NEIWPCC
Survey of State
Experiences with MTBE
to Be Posted on Web
In August, the New England
Interstate Water Pollution Control
Commission (NEIWPCC) con-
ducted a survey of all 50 state
LUST programs to ascertain their
experiences with monitoring for
and cleaning up MTBE releases
from USTs. The survey, funded
by the EPA Office of Under-
ground Storage  Tanks, was
undertaken to provide the states
with  a better picture of how
each state  program is currently
dealing with MTBE  and other
oxygenates.  This very com-
prehensive survey consists of
34 questions and  numerous
subquestions. NEIWPCC received
responses from all 50 states.
    After sending the compiled
results to  all states for a final
review, NEIWPCC plans to post
the results with  an  executive
summary on its LUSTLine Web
site (lustline@neiwpcc.org^  on
December  15,  2000.  NEIWPCC
will encourage states to update
their information periodically and
will present the information in the
next issue of LUSTLine and at the
national UST/LUST conference in
Albuquerque,  New Mexico, in
March. You will also  find issue-
specific summaries in this issue of
LUSTLine with relevant articles.
Look for the "What Our Survey
Shows" boxes. •
             toEWTEeHNICAL	BULLETINS	EBQM	;APL
  The American Petroleum Institute (API) has recently completed several technical bul-
  letins that address aspects of LUST remediation. These bulletins can be downloaded
  from http://www.api.ehs/saresbul.
  • Dissolution of MTBE from a Residually Trapped Gasoline Source—September
    2000, Bulletin No. 13.
  • No-Purge Sampling: An Approach for Long-Jem Monitoring—October 2000,
    Bulletin No. 12.
  » Strategies for Characterizing Subsurface Releases of Gasoline Containing MTBE—
    August 2000, Bulletin No. 11.
  • Simulation of Transport of Methyl Tert-Butyl Ether (MTBE) to Groundwater from
    Small-Volume Releases of Gasoline in the Vadose Zone—June 2000,  Bulletin No.
    10.
  • Non-aqueous Phase Liquid (NAPL) Mobility Limits in Soil—June 2000, Bulletin No. 9.

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                                                                                          LUSTLine Bulletin 36
Getting Results,  PFP Style
      ray for performance (PFP) is"acommon-seme~appwach to LUST~sitej:leanup. Payments are made as con tmnmatwn levels go
      ' P^-—            ^^"       *x           a?**~         2      IB*.    ]         Sfr~"         8   ^—"~    * A,
       "n and. cleanup goals are achieved and maimamed. The price, interim payment milestones, contamination-level goals, and
        'mejimitfor reachingthe goals are all firmly fixed at the beginning ofthe cleanup ana
        -„•„      ,.~j	£,,7T., "£scflpg clauses" are tgrjjtten into the contract tha±.can release \
                                                                           not changed thereafter. Contaminant
reduciiornsjns-nsured fan
faulty sitelcharacterization
    WttWn the PFP frame
the lowest-price bid submit
                       yrk
                       •ed in i
                         new release).
                          there are significant vjjjyations on how stales pricjfyheir PFP c\
                         in open competition among qualified contractors or by negotf
South Carolina, and Florida^-all PFP pioneers—havejjgen pricing theif
       |P    -      J    J6fe—    & JT           iipBs,
negotiate^ price with the cleanup contractor. South Carolina conducts o
der. FlorMa has experimented-withboth negotiation and bidding and h,
one totaWprice. And predictions that lowest-bid contracjjfs would product
    Theijeadership of these states and the success ofth~&r_P_FP cleanups
                                                             cleanups using
                                                           'Pftitive bidding a
                                                           also awarded "bun
                                                            '.oddy work have n
                                                          §»p a wealth ofexp>
                                                                             contractor if thejiggd arises (eg, a
       ;r
>e set by award to
*•*   _,r ,*
ing their^unJPFP initiatives. These states arefindingmjat their PFP cleanups are typically lest
tive, conclude in the expected time, and spur innovationjn cleanup technology and managemei
   Thefollowing thr'ee articles shed some light on the Oklahoma, South Carolina, and Flo
progressjjsupportfor developing a state PFP program y
                                              bailable through OUST/EPA Regwnl
   ips. Prices m(
 "onjvith the contractor Oklahoma,
  rent methods. Oklahoma state staff
      the cleanup to the lowest bid-
  " of multiple,PFJLcleanup sites for
   wed true.
    that others can adapt in develop-
"Sxpensive and environmentally effec-
 iy contractors.
 fa PFP programs. PFP is a work in
 A         t
 I Office representatives.
               After Some PFP Growing Pains
               Oklahomans Realize PFP Benefits
                by Richard McKay

      iy state starting a performance approach to remedi-
ation will go through some growing pains.  For  the
smoothest transition possible, those involved must accept
that remediation programs  will undergo a paradigm
change. Leaders, technical groups, and accounting staff
must think outside their traditional time-and-materials
program models.
    The growing pains can be intensified if the regulatory
and fund groups work independently. In our experience,
the ideal arrangement is to have a technical staff with both
regulatory and fund authority. When one department is
managing the technical and financial aspects of a case, a
consistent message is projected to consultants and tank
owners, and the potential for having a case slip between
the cracks is reduced. If this setup is not available, a spirit
of cooperation between all parties is required.
    Regulators, fund  groups, and consultants are all
entrusted with the responsibility to protect human health,
safety, and the environment and to ensure that  cleanup
funds are spent effectively. These purposes will be under-
mined if the parties involved do not consciously work
together toward a common goal.

Statutory Roadblocks
Although statutes may not specifically provide or allow
the authority for a state agency to enter into performance-
based cleanup contracts, this omission may not necessarily
                                                      be an obstacle. Recognizing that the concept of perfor-
                                                      mance-based cleanup contracts made a lot of sense, the
                                                      Oklahoma Petroleum Storage Tank Division  (PSTD)
                                                      implemented a pay-for-performance (PFP) program in
                                                      1996 on a voluntary basis. The necessary forms were cre-
                                                      ated, several contracts were signed, and the remediation
                                                      systems were installed and implemented.
                                                         Despite challenges to our statutory authority, the per-
                                                      formance-based reimbursement program prevailed. There
                                                      were some parties, however, who felt specific authority
                                                      was needed. Thus, with the full support of the state's
                                                      petroleum marketers, statutes were passed in 1998, man-
                                                      dating that all work be preapproved and empowering the
                                                      authority to enter into preapproved purchase orders and
                                                      performance contracts. The rules were revised to make the
                                                      preapproval process mandatory. Now all site work must
                                                      be preapproved and most site remediation is performance
                                                      based.

                                                      Benefits of Pay for Performance
                                                      Oklahoma's PFP program provides benefits for the envi-
                                                      ronment, for fund protection and management,  and for
                                                      claim processing. These benefits include the following:
                                                        •  Consultants now install better-designed remedia-
                                                           tion systems. Thus our most difficult sites are being
                                                           cleaned up, and all site cleanups  are progressing
                                                           faster.
                                                                                       • continued on page 20

                                                                                                     19

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LUSTLinc Bulletin 36
m Results, PFP Style from page 19
   • Consultants must guarantee results, and no pay-
     ments are made until incremental goals are attained.
   • The flow of fund money is manageable, because
     remediation costs are fixed and controlled through
     negotiation and the use of TankRACER software.
     We are thus able to encumber preapproved site
     remediation monies in predictable amounts.
   • The time it takes to pay claims is shorter, and there
     are minimal disputes over reimbursements and dis-
     allowances.  Disputes over reasonable prices are
     eliminated.
   • Minimal claim support documentation is required,
     minimal erroneous or questionable documents are
     received, and  payment for work that is not per-
     formed is eliminated.
   • Collaboration between the tank owner, the consul-
     tant, and the state has improved so that tank owners
     are more likely to view the agency as an advocate
     than as a headache.

    Oklahoma's PFP program has shifted the consultants'
focus from keeping cases open on a time-and-materials
basis, with little incentive to close a case, to achieving
results to make money. As a consequence, the rate at
which groundwater benzene concentrations are reduced
has changed from a small, slow decrease over several
years to a large decrease within a few months.
    For example, in cases where contaminant reduction
milestones have been achieved, on average, the 25 percent
milestone has been achieved in 6 months, 50 percent in 8
months, 75 percent in 11 months, and 100 percent in 16
months from baseline concentrations measured prior to
system start-up. In each case, the consultant signed a per-
formance contract guaranteeing results in three to five
years from system start-up, and the existing remediation
system was replaced by an entirely new system. None of
the previous systems had been able to maintain contami-
nation levels below site-specific cleanup levels, and most
showed very little progress.
    Under PFP, the consultant guarantees that the soil and
groundwater readings in the remediation area will be
below cleanup levels for all chemicals of concern (COCs)
before the system can be turned off, and the readings must
remain  at or below site cleanup levels for six months
before the final contract payment is made. When we con-
vert a time-and-materials site to PFP, contamination levels
typically drop suddenly, rebound somewhat, and then
continue to decrease.

Changes on the  Run
The PSTD has gone through several episodes of growing
pains since implementing its program in 1996. Our experi-
ence with writing performance contracts has helped us
dose a number of loopholes. For example, system design
was initially not specifically itemized as part of the final
cost. One consultant contested this policy, so we changed
our guidelines.
    We have received many ideas for program revisions
from consultants—in  the spirit  of  cooperation—to
improve the contract, rather than take advantage of an

20
omission. By keeping an open mind throughout this
process, our agency has had the opportunity to learn from
its mistakes, as well as from people outside the agency,
such as consultants and their attorneys.
    Through our experience, we've incorporated many
important defining points into our performance contract,
including the following:
   • Items that the contract price includes or excludes;
   • The remediation system warranty area;
   • Fair and reasonable payment terms;
   • Which  party  takes responsibility for  damages
    caused by the tank owner or his or her employee;
   • The situations that will allow  the contract to be
    renegotiated (i.e., secondary release, continuing
    release, or migration of a plume onto the site);
   • A provision that ensures continual system opera-
    tion;
   • Appropriate penalties if  a consultant abandons
    remediation activities prior to termination of the
    contract;
   • Points at which to take baseline samples;
   • Lab analyses that should be run, schedules for sam-
    pling wells, and conditions under which the consul-
    tant will be able to change labs during the course of
    the contract;
   • Ways that reduction payments are related to BTEX
    concentrations and the method of calculation;
   • The method for measuring free-product reduction;
    and
   • A sampling protocol to qualify for reduction pay-
    ments,  reserve the agency's right to verify all sam-
    pling data, identify key  monitoring wells  and
    compliance monitoring wells, and determine a rea-
    sonable period to monitor for rebound once all
    wells are below cleanup levels.

    The term of a PFP contract varies based on site-spe-
cific conditions, the chosen remediation technique, and
the operating history of similar techniques. For example,
after writing several contracts, we found that in clay-rich
soils,  the time it takes to achieve the final 25 percent
reduction can be longer than the time it takes to attain the
75 percent reduction milestone. To compensate for this
slowdown, many of these performance systems have been
enhanced by localized dig and haul operations, additional
remediation  wells to increase well density, the introduc-
tion of nutrients to increase bioremediation, or the intro-
duction of oxygen-releasing materials. The state  also
allows a  PFP system to be modified from the original
scope  of work, provided that modifications are performed
within the terms of the contract and at no additional cost.
    Without the ability to make these modifications, the
consultant risks leaving up to 40 percent of the perfor-
mance contract on the table. Keep in mind, there are also
sites where the 100 percent milestone has been achieved
six months after start-up, leaving the consultant with 2 to
21/2 years of operation and maintenance money as pure
profit. These cases create an established history from
which the agency can learn what a reasonable remedia-
tion time frame should be and apply that lesson to future

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                                                                                           LUSTLine Bulletin 36
 contracts. Although system performance varies, the con-
 sultant must ultimately achieve the final goal in a reason-
 able time frame and deliver a site that is ready to be
 monitored for closure.

 Negotiating a Fixed Cleanup Price
 One of the primary objectives of PFP cleanup is to achieve
 results at a reasonable price. Cleanup prices can be set
 through negotiations and/or bidding. Since the program's
 inception, Oklahoma has used a customized price build-
 up computer program, TankRACER, to determine a rea-
 sonable price. Detailed printouts from TankRACER are
 used as support documents for negotiating a final contract
 price with the consultant. Through this negotiated proce-
 dure, we have saved a total of $875,000 over the consul-
 tants'  original proposals,  which can then be used for
 characterization and restoration work on other sites. Typi-
 cally, the TankRACER price varies by only 4 percent, on
 average, from the final contract price, and assures all par-
 ties that the final negotiated price is reasonable.

 Reasonable Cleanup Goals and Price
 Cleanup goals have a direct effect  on the performance
 remediation price and are commonly based on a category
 system, a maximum contaminant level (MCL), or a tiered
 risk assessment. Oklahoma changed from a category sys-
 tem to a tiered approach in 1996, allowing more reason-
 able and achievable site-specific cleanup goals that are
 protective of human health and can be attained at a rea-
 sonable price. Based on this tiered approach, the consul-
 tant guarantees that soil and groundwater will be remedi-
 ated to site-specific cleanup goals at a negotiated price that
 includes all remediation costs. Today the average perfor-
 mance site remediation price using air sparge and soil
 vapor extraction techniques is $498,000 for a 26,500 yd3
 plume or $18.80 per yd3.
    Had we utilized a risk-based program to determine
 reasonable cleanup levels and instituted a performance
 program from the inception of our tank program, we esti-
 mate we could have saved as much as $6.48 million on just
 41 sites that were changed from time and materials to per-
 formance. This savings assumes that each site moved from
 site assessment directly into PFP remediation. These cases
 represent a small portion of the sites that require remedia-
 tion. The economic consequences of not instituting pro-
 grams to determine site-specific cleanup goals and a
 reasonable site remediation price could be substantial.
    Since these changes were instituted, we have been
 able to prioritize each site, use better budget controls, and
 move the worst sites more quickly toward implementing
 corrective  action. In addition, the consultants are now
 more inclined to develop and use remediation techniques
 that are faster, more efficient, and more cost-effective. •

  Richard McKay is Supervisor of Special Projects, Programs,
   and Operations at the Oklahoma Corporation Commission,
    Petroleum Storage Tank Division. He canbe reached at
                r.mckay@occ.state.ok.us.
                 South Carolina
                The Light at the End of the Invoices
                PFP Bids Well  in  South Carolina
 T
                by Arthur Shrader
  JL he South Carolina Bureau of UST Management imple-
mented a pay-for-performance (PFP) remediation pro-
gram for state-funded cleanups in 1997. Our program
goals were to encourage cleanup contractors to be more
efficient and effective, achieve cleanup goals at a reason-
able price, and simplify the invoicing process. In an effort
to streamline cumbersome time-and-materials procedures,
we implemented PFP, using the  competitive bidding
process. As a result of this move, we're seeing a nice,
bright light at the end of our invoices.
    Here's how PFP works in South Carolina. Our depart-
ment solicits bids for proposed projects in the state gov-
ernment biweekly publication, South Carolina Business
Opportunities. Prior to the advertisement, department staff
members prepare specification packages that contain an
assortment of information necessary to assist interested
contractors in preparing their bids—stated cleanup goals
(based on site assessment activities and current levels of
chemicals of concern in key monitoring wells), site maps,
summarized technical data, and other relevant informa-
tion. Contractors are also encouraged to review the entire
project file located at the agency's Freedom of Information
office. Inasmuch as South Carolina certifies UST rehabili-
tation contractors, a bid bond is not required. Any UST-
certified contractor is welcome to submit a cleanup
proposal.
    Contractors that wish to respond to the solicitation
submit a proposal that specifies a cleanup method or com-
bination of methods, an estimated time for completion,
and the total cost. UST program staff members evaluate
the proposal to determine whether the proposed technol-
ogy is feasible, the estimated time is protective of recep-
tors, and the total cost is reasonable, based on the costs of
similar cleanups. If more than one proposal meets all of
these parameters, the contractor offering the lowest bid is
selected.
    When the contract is awarded, the selected contractor
submits a detailed corrective action plan along with a per-
formance bond or irrevocable letter of credit equal to the
amount of the award to guarantee that the project will be
completed successfully . The department approves the
plan and notifies the public of the proposed corrective
action before work begins.
                                 • continued on page 22

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LUSTLine Bulletin 36
• PFP in South Carolina from page 21	

    As the project progresses, the contractor is paid a per-
centage of the total cost as agreed cleanup milestones are
achieved. Both program staff members and the cleanup
contractor take duplicate water samples for analysis by
separate laboratories to verify progress. When the contrac-
tor reports that cleanup goals have been reached, monitor-
ing wells are installed at random locations selected by staff
members to verify mat the total affected area has been suc-
cessfully rehabilitated.

Results Keep Getting Better
Since 1997, six cleanups using this process have been com-
pleted. All were completed within the schedule outlined
in the proposal. Of the ongoing 180 PFP cleanups, 57 per-
cent have reached 75 percent of the cleanup goals, 35 per-
cent are in post-startup and are achieving goals, and 8
percent are in the corrective action plan development
stage.
    At their own costs, contractors routinely install addi-
tional treatment points or excavate additional soils in the
main source area after implementation of the initial correc-
tive activities to accelerate the cleanup. The use of more
durable equipment (to eliminate downtime and to reuse
the equipment at the next job) is also quite common.
Table 1. Examples of decreased prices over time at South Carolina
PFP sites.

Free Product
& Dissolved
Free Product
Only
1997
$275,000
$180,000
1998
$180,000
$100,000
1999
$133,216
$30,000
2000
$117,000
$29,500
                                                              As contractors become more familiar with the PFP
                                                          process, bid amounts for cleaning up similar size ground-
                                                          water plumes have been further reduced. (See Table 1.)
                                                              Based on available data, our cleanup costs are more
                                                          directly attributable to plume size than to other factors,
                                                          such as geology or levels of mass reduction. The cleanup
                                                          of a larger plume requires more treatment points and a
                                                          greater overall effort than a smaller plume does. MTBE
                                                          plumes are more costly to clean up, because they are typi-
                                                          cally larger than BTEX plumes.

                                                          De-crazyfication
                                                          As we've eased into PFP, we've found that voluminous
                                                          invoices depicting time-and-materials charges are a thing
                                                          of the past. Invoices that are received from contractors
                                                          that have achieved a cleanup milestone consist of a single
                                                          page indicating the percentage of the bid price that is due.
                                                          The quarterly monitoring report documents the amount
                                                          of reduction, and the split-sample laboratory data verify
                                                          progress  for the selected monitoring points. The payment
                                                          approval process is typically completed within two days
                                                          (the invoice is approved for payment or returned until
                                                          progress  is documented).
                                                              PFP  focuses the contractor, the regulator, and the
                                                          fund administrator on environmental results. Although
                                                          our PFP  program is still in its infancy, we have already
                                                          been witness to more timely and efficient cleanups, lower
                                                          costs, and the opportunity for our staff members to spend
                                                          their time more appropriately overseeing cleanup activi-
                                                          ties, not reviewing invoices that resemble novels. •
                                                      Arthur Shrader is the Director of the Assessment and Correc-
                                                        tive Action Division of the South Carolina Department of
                                                      Health and Environmental Control, Bureau of Underground
                                                           Storage Tank Management. Art can be reached at
                                                               shradeaa@columb26.dhec.state.sc.us.
                        Florida
 *—U**K    !••
               \      \    For a Third of the Price, Who'd Be Without It!
j                 \-     \ Competitive Bidding; for Petroleum
                     xl Cleanup in Florida
 I
                        by Brian Dougherty
         t was one of those projects you don't really want. You
      don't think it will work, but you need to do your best to
      make it work. In 1996, the Florida legislature mandated
      that the Department of Environmental Protection (DEP)
      initiate a pilot program on bidding for petroleum site
      cleanup services. We went along because we had to, not
      because we thought it was a good idea. Now, four years
      later, it seems like maybe bidding is a good idea. Our
      experiment with competitive bidding for petroleum-cont-
      aminated site cleanup services has demonstrated not only

      22~                                            ~~
that it works, but that it gets the job done for one-third of
the price of preapproved cleanup work. (That's one-third
of the price, not one-third less).
   To date, the department has accepted six bids for
petroleum cleanup services: five for site assessment work
and one for PFP cleanups. The results are easy to see. (See
Table 2.) Florida has saved an estimated $815,671 (64%) by
bidding the work rather than doing it under our preap-
proval program.

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                                                                                            LUSTLine Bulletin 36
1 Table 2. Summary at petroleum cleanup program bids. \

Type of Work
Assessment
Assessment
Assessment
Assessment
Pay-for-Performance Cleanup
Assessment
Total

No. of
Sites
11
10
7
10
3
26

No. of
Responses
24
27
34
16
11
11

Cost for Requested Services
(Total for all sites)
Bid Award
$ 22,500
$ 32,751
$ 24,900
$ 34,075
$227,550
$ 123,768
$ 465,544
Preapproval
Estimate
$ 41,800
$ 95,000
$ 108,260
$ 95,509
$ 665,500
$ 275,146
$1,281,215
Cost Difference Between
Preapproval and Bid
Difference
Preapproval-Bid
$ 19,300
$ 62,249
$ 83,360
$ 61,434
$ 437,950
$151,378
$815,671
Percent
Reduction
46%
66%
77%
64%
66%
55%
64%
 What About Quality?
 An obvious question at this point is, What about the qual-
 ity of the work? Do you still get good work at such bargain
 prices? The answer is yes. The quality of the work per-
 formed under the bidding pilot has been as good as typi-
 cal work under preapproval. That is not to say that there
 have not been any problems with the work. We did have
 to provide a few reminders that the scope of work was a
 bid specification that had to be  performed exactly and
 completely. But all of the problems were resolved satisfac-
 torily.

 The Advantages of Bidding PFP
 Bidding a PFP cleanup has distinct advantages over nego-
 tiating the same cleanup. The one-time bid to establish the
 price for the cleanup rules out any need to negotiate the
 price. When you bid the cleanup, the burden for determin-
 ing the best, most efficient strategy for the cleanup is
 placed squarely on the consultant. The consultant must
 price the job as competitively as he or she can.
    Bidding the cleanup avoids the common negotiating
 pitfalls associated with estimating the cost of the treatment
 technology, estimating total cleanup time, and estimating
 the monitoring time. In a negotiated PFP, these estimates
 tend toward the high side to provide as much contingency
 as possible. This tendency  is not necessarily bad, and the
 need to cover contingencies is real, but it can be difficult
 and time-consuming to whittle the contingency down to a
 level that is acceptable to both parties.

 Getting the Specs Right
 Bidding the cleanup work  did initially require consider-
 ably more administrative  overhead than it would have
 under conventional preapproval. Much of this additional
 effort reflected our "learning curve" in developing a pre-
 cise specification and learning the administrative proce-
 dures. Most of this effort is now behind us.
    The single most time-consuming aspect of preparing
the invitation to bid is the  development of the exact bid
specification. As is common for bid work, the specification
must be exact and precise.  In this regard, we found that
the assessment bids were more difficult to spec than the
 PFP bids. The PFP bids were easier to prepare because it is
 fairly straightforward to write a bid specification for a
 completed cleanup.
    The assessment bids were more time-consuming to
 prepare because the exact locations and depths of wells
 had to be specified. Then, because it is nearly impossible
 to predict exactly how much work will be required to
 complete the assessment, the specification development
 effort had to be repeated for each  subsequent scope of
 work.
    After our first couple of bids, we found a way to elim-
 inate  the need for follow-up bid specifications. We did so
 by developing a fee schedule that sets forth  a precisely
 defined minimum scope of work that will be awarded. If
 the minimum amount of work is insufficient to complete
 the assessment, then we can award the additional work
 necessary to complete the assessment, using the fee sched-
 ule. This approach eliminates the additional overhead of
 having to prepare and offer a new bid. Bidding the
 cleanup work will always require a more formalized
 approach than preapproval, but the net overhead ends up
being about the same.

 Two  Thumbs Up
Bidding petroleum cleanup services has yielded tremen-
dous cost savings with no decrease in the quality of work.
The administrative overhead was a burden at first, but we
have already made many improvements to our internal
processes to reduce  that burden. The  fee schedule
approach will further reduce the administrative overhead
for assessment  sites. This reduction in administrative
overhead, coupled with the dramatically lower prices,
suggests strongly that bidding petroleum cleanup services
is an  unbeatable way to manage Florida's petroleum
cleanup program. •
  Brian Dougherty is an Environmental Administrator with
 the Florida Department of Environmental Protection. He can
      be reached at Brian.Doughertu@dep.state.fl.us.
                                                                                                      23

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LUSTLine Bulletin 36
                         nically  Speaking
                         by Marcel Moreau
                                      • Marcel Moreau is a nationally     -;
                                  SKagnized petroleum storage specialist _ |:
                                      e.folumn, Tank-nically Speaking, \
                                  |J is a regular feature o/LUSTLme. As  ;:,
                                 pi always, we welcome your comments and j
                                 |s- questions. If there are technical issues  \
                                 f  that you would like to have Marcel :\
                                  -  - --  discuss, let him know at      '.•;•
                                       'marcel.moreau@juno.com.  -•  ]
                                       —   --          ' --      --
The  Quest  for the Perfectly  Reliable  LLD, or

S/i0ttW Electronic Line Leak detectors Hatfe an Annual test

of Operation?
  M  & yfirst encounter with the electronic line leak detector (ELLD) "test of operation" issue came a few years ago during a
 J\/m compliance inspection. The recordkeeping at the facility was pretty good, but there was no record of an annual test ofoper-
X F P ation of the ELLD. The maintenance person said that he had checked with the manufacturer to obtain test procedures and
had been told that the device did not need to be tested.
    At the time, this statement seemed to me to be a bit presumptuous on the part of the manufacturer. Nevertheless, the rules did say
that test procedures were to be performed "in accordance with the'manufacturer's requirements," so the manufacturer did seem to
have some ground to stand on.
    I have since heard the question, "Do electronic line leak detectors need to be tested?", many times from inspectors and havefol-
Imved discussions concerning the issue with Internet interest groups. There are two main schools of thought on the issue:
   • The "proof is in the pudding" school. This view holds that, "The rule says a test should be done, and there is only one true test
     of operation and that is to see if the device can actually find a leak"—a view held primarily by regulators.
   • The "father knows best" school. This view holds that, "I build these things and I know how they work. These devices are pretty
     smart, can tell when they are not working right, and don't need any additional testing"—a view held primarily by some man-
     ufacturers. This vieio is also popular with UST owners who have invested in ELLDs, in part, to avoid the cost of annual test-
     ing of mechanical devices.

    Although I believed the points made by both sides had some validity, my own tendency has been to lean toward the regulatory
vitno of "the proof is in the pudding." Having done a little more research into the matter, however, I am beginning to lean toward the
 "father knows best" school.
 The Electronic LLD and the
 Testing Issue
 For the first 30 years after its intro-
 duction in the mid-1950s, the LLD
 remained  an entirely mechanical
 device (see "Of Blabbermouths and
 Tattletales," LUSTLine #29). Since the
 implementation of the federal rules,
 however, a number of manufacturers
 have developed LLDs that are con-
 siderably more sophisticated than the
 original mechanical models and rely
 on electronic components to do their
 job. Although the mechanical devices
 (MLLDs) are still the most common
 type in service, the ELLDs are mak-
 ing headway in the marketplace.
     Annual testing of MLLDs has
 been a requirement of the fire codes
 since long before the federal rule. The

 24
federal UST rule (and most state UST
rules) have adopted this requirement
as well. Typical language states that
"an annual test of the operation of the
leak detector must be conducted in
accordance with the manufacturer's
requirements" (40 CFR 280.44(a)).
   The testing of MLLDs  is fairly
straightforward. Because all of the
working parts are concealed and the
MLLD is self-contained, there is no
way to test it other than to generate a
leak and see if the MLLD responds.
The typical test procedure involves
connecting a testing device into the
piping system at the crash valve at
the base of the dispenser. The testing
device typically  includes pressure
gauges and a small valve  that can be
carefully adjusted to allow three gal-
lons per hour (gph) of product to leak
out of the piping and into a suitable
container.
   The "test of operation"  issue,
however, becomes more complex
with ELLDs. These devices are usu-
ally  capable  of conducting  more
accurate 0.2 or 0.1 gph tests, in addi-
tion to the 3 gph test. Because the fed-
eral definition of a line leak detector
is written as a performance standard
(detecting 3 gph leaks at 10 psi in one
hour), the annual test of operation of
LLDs applies only the 3 gph function
of ELLDs. There is no requirement in
the federal rules to evaluate the abil-
ity of the ELLD to detect leaks of 0.2
or 0.1 gph on an annual basis.

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                                                                                            LUSTLine Bulletin 36
 The Question Please...
 The  debate concerning ELLD  test
 procedures boils down to this point:
 many regulators want to continue the
 tradition of testing operation by gen-
 erating leaks and seeing if they are
 detected; some manufacturers insist
 that their ELLDs are completely self-
 testing and need no additional evalu-
 ation.
    Note that not all manufacturers
 claim that their ELLDs are self-test-
 ing. In fact, some state that the test of
 operation should consist of generat-
 ing a leak and verifying that it is
 detected.
    To understand the bases for the
 opposing opinions,  we   need  to
 understand a little more about  the
 operating principles of ELLDs and
 the types of "self-testing" they  are
 capable of conducting.

 Types of ELLDs and How
 They Work
 There are two basic types of ELLDs:
 flow-based and pressure-based. Both
 types  attempt  to  evaluate  the
 integrity of the piping immediately
 after each customer has finished dis-
pensing  product.  The  test  may
require from less than a minute to as
  long as 10 minutes to complete. If
  another customer arrives and turns
  on the pump, the test is aborted and
  restarted when this customer is fin-
  ished dispensing.
     In general, both types of ELLDs
  have the ability to turn the pump on
  and off and to communicate in the
  form of displays and/or printers.
  They also have some computational
  and/or logic circuitry that can deter-
  mine if a piping run is tight and eval-
  uate, to some degree, how well the
  ELLD itself is functioning.
     Are ELLD self-tests sufficient to
     meet the regulatory standard of
       "annual test of operation...
    Jojiducted in accordance with the
  ^manufacturer's requirements" or
        not? Well, it depends...
 Pressure-Based ELLDs
 Pressure-based ELLDs are the most
 common type of ELLD. These ELLDs
 monitor the pressure in the line after
 the pump has  been turned off. A
 check valve in the system is used to
         maintain some pressure in
            the piping. A leak in the
           piping  will reduce the
           amount of liquid in the
           pipe and produce a loss
           of pressure in the piping
           that can be measured.
                A pressure trans-
         ducer—a device that con-
        verts changes in pressure to
       changes    in   voltage—is
       installed  in  the  piping  to
      detect pressure changes. The
     bigger the leak in the pipe, the
   faster the pressure in the pipe will
 drop. If the pressure drops  more
than a certain amount in a set interval
of time, then a failed test results.
Brands of pressure-based ELLDs dif-
fer principally in how much pressure
is held in the pipe at the beginning of
the test, the  length of time during
which the pressure is monitored, and
the  number  of times the  test  is
repeated before a leak is declared.
    The common use of flexible pip-
ing in today's UST systems has pre-
sented  a bit of  a  challenge  to
pressure-based ELLDs. In a rigid pip-
ing system, very small losses of liq-
uid will produce fairly large pressure
  drops, because the volume of the pip-
  ing is relatively  constant over the
  operating range  of pressures that
  submersible pumps produce.
      In a flexible piping system, how-
  ever, the range of pressures normally
  encountered  (0 to 30 psi) produces
  relatively large changes in the vol-
  ume of the piping system. Like a bal-
  loon  (though  to a  much  lesser
  degree), the flexible piping expands
  as pressure increases and contracts as
  pressure is reduced. The contraction
  of the piping  has the effect of main-
  taining some  pressure in the piping
  as liquid leaks out, thereby prolong-
  ing the time required for the pressure
  in the pipe to drop a given amount.
     In  a  rigid piping  system,  the
  pressure drop in the piping due to a 3
  gph leak is quite rapid. In a flexible
  piping system, the pressure drops at
  a much more leisurely pace. Because
  pressure-based ELLDs monitor pres-
  sure change over time to determine
  whether a leak is present, the device
  must use a longer test interval to
  detect a 3 gph leak in flexible piping
  than in rigid piping.
     Pressure-based ELLDs must be
  programmed  at installation so that
  the length of the test interval  is
  adjusted for the flexibility and length
  of the  piping  system in which it is
  installed. In some models, this infor-
  mation must  be entered into the
  device manually. In other models, a 3
  gph leak is created in the piping at
  the time  of  installation, and the
  device is operated in a "learn" mode,
 whereby a series of tests are run to
 empirically determine the length of
 the test interval, based on the pres-
 sure decay curve that is actually pre-
 sent.

 How Pressure-Based ELLDs
 Test Themselves
 There is no question that pressure-
 based ELLDs can conduct a certain
 amount of self-testing. Because the
 device  controller can  operate the
 pump  on its  own, the controller
 knows that when the pump is off, the
 pressure should be at the approxi-
 mate holding pressure of the check
 valve; when the pump is on, the pres-
 sure should be  at the operating pres-
 sure of the pump.  If the measured
 pressure is outside of these ranges,
 then the controller knows that some-
                • continued on page 26

~                            25

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LUSTLine Bulletin 36
• Tank-nically Speaking
from page 25	

thing is not right and a warning can
be activated.
    The warnings will not only deter-
mine whether the transducer is mal-
functioning, but may also identify
other system problems [e.g., running
out of product (pump on, but line
pressure too low), or a  defective
pump control that keeps the pump
motor running all the time (pump
supposedly off, but line pressure too
high)].
    The comparison of expected ver-
sus actual pressure readings is typi-
cally  conducted  as  part  of the
protocol for the 0.2 or 0.1 gph tests.
The 0.2 gph tests are initiated when-
ever  the system has not  pumped
product for some period of time (typi-
cally about a half hour) and in all but
the most active 24-hour facilities are
usually conducted on a nightly basis.
Thus the operating condition of the
transducer is typically evaluated on a
nightly basis, and the successful com-
pletion of a 0.2 gph test is a reason-
ably reliable indicator that the ELLD
is functioning properly.
    Although I have not investigated
all available  brands of  ELLDs,  I
expect that there is significant varia-
tion in the sophistication of the self-
testing  that is conducted by the
different models. In addition, many of
these devices have evolved over time
so that earlier software versions may
not self-check to the same level  as
 later versions.
    To guard against improper pro-
 gramming,  some ELLD  models
 establish their default piping (the
 type of piping assumed to be present
 unless the installer reprograms the
 ELLD) as a fairly long run of the most
 flexible piping type. This assumption
 lengthens the test interval  signifi-
 cantly, which is likely to result in fre-
 quent "false alarms" if the piping is,
 in fact, a more rigid variety. Little can
 be done to thwart the person who
 might intentionally program the
 ELLD for operation in a rigid piping
 system (when the piping is actually a
 flexible variety) to reduce this "false
 alarm" rate.

 Flow-Based ELLDs
 Flow-based ELLDs typically work by
 keeping the pump motor operating
 after the customer has hung up the
 __
nozzle. This procedure maintains the
piping at operating pressure. The
ELLD controller then closes an isola-
tion valve at the pump end of the
line. The closing of this valve sepa-
rates the piping into what I will call
the "pump side," which is very short
and extends from the pump motor to
the isolation valve (in some cases the
valve is inserted in the pump mani-
fold in the traditional LLD port), and
the "dispenser side," which contains
the bulk of the piping and extends
from the isolation valve at the pump
to the dispenser.
    After the  isolation valve is
My gut instinct is that the number of
instances where a leak was missed
by a malfunctioning ELLD will run a
 distant third to the instances where
! a warning light resulted in a service
   call or was completely ignored.
                                 i
 closed, the pump side and the dis-
 penser side remain open  to  one
 another via a small passageway in
 which  a flow-sensing  device  is
 installed. The pump motor continues
 to run during the test period to main-
 tain a constant (operating) pressure
 on the pump side of the isolation
 valve. In a tight piping system, the
 dispenser side of the isolation valve
 will maintain the original (operating)
 pressure, and there will be no flow
 through  the  small  passageway,
 because the pressures on both the
 pump and dispenser sides of the pip-
 ing will remain equal.
     If the dispenser side of the piping
 has a leak, however, the pressure will
 drop on the dispenser side of the iso-
 lation valve. Liquid will now  flow
 through the flow-sensing pathway,
 because the pressure is greater on the
 pump side than the pressure on the
 dispensing side of the piping. This
 flow rate is measured. If it exceeds
 the threshold set for the device, a
 failed test is declared.
     In flow-based ELLDs, the pres-
 sure in the entire piping run during
 the test period is maintained at a con-
 stant level, because  any  product
 leaked from the dispenser side of the
 piping will be replaced with product
 from the pump side. Because the test
pressure is constant, there is no need
to take into consideration variations
in leak rate due to pressure changes
in the pipe. The ELLD test protocol is
the same whether the  device  is
installed in rigid or flexible piping.

How Flow-Based ELLDs Test
Themselves
Flow-based ELLDs are capable  of
some fairly rigorous self-tests.  In
some devices, after the completion of
a 3 gph test, a small bypass valve on
the dispenser side of the isolation
valve is opened. This valve generates
a calibrated 3 gph leak of product
from the dispenser side back into the
tank. The ELLD then checks whether
it can correctly measure this simu-
lated leak with the flow sensor. If it
can, then everything is fine; if it can't,
then  the  device communicates a
warning to the operator that the sys-
tem is not operating properly.
    Another flow-sensing brand sim-
ply keeps the flow-sensing pathway
open while the pump is dispensing
fuel and  checks  whether the  flow
sensor  registers  flow.  While this
approach is not as quantitative as  the
approach described previously, this
particular flowmeter has no moving
parts, so calibration is not a big issue.

And the Answer Is...
So, are ELLD self-tests sufficient to
meet  the  regulatory standard of
 "annual test of operation—conducted
in accordance with  the  manufac-
 turer's requirements" or not? Well, it
 depends...

 For Pressure-Based ELLDs
 For pressure-based ELLDs, I  think
 the answer is a little murky.  Some
 devices seem to  offer a reasonably
 comprehensive test of operation.  The
 main omission is that the ability to
 detect a 3 gph leak in a specific pip-
 ing run is not determined. But the
 EPA interpretation of the LLD  test
 requirement  is that a specific leak
 rate does not need to be detected
 (http: / / www.epa.gov / swerustl /
 compend/rd.htm, question 16). Thus
 this omission does not seem signifi-
 cant according to EPA's  reading of
 the rules.
     I suspect that some other brands
 and older models of pressure-based
 ELLDs probably fall short of a thor-
 ough self-test. I can think of  two

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                                                                                            LUSTLine Bulletin 36
 items that would serve as helpful
 compliance evaluation tools for both
 inspectors and storage system own-
 ers. One would be a list  of ELLD
 devices that includes the manufac-
 turer's official recommendations for
 the "annual test of operation" for that
 device. This information would be
 useful to compliance inspectors who
 need to know whether documenta-
 tion of a field test must be produced
 or whether the manufacturer believes
 that the ELLD's internal testing is
 sufficient  to  meet  the regulatory
 requirements.
    The second item would be an
 independent  review  of each ELLD
 model that a manufacturer claims is
 "self-testing" to evaluate  whether
 that claim seems reasonable or spe-
 cious. These items are beyond the
 scope of this article. If there is enough
 interest,  however,  perhaps  EPA
 could fund such a review, or the
 National Work Group on Leak Detec-
 tion  Evaluations might  consider
 undertaking such a review.

 For Flow-Based ELLDs
 Flow-based  ELLDs that  generate
 quantitative leaks  and determine
 whether they are correctly  detected
 should meet most everyone's defini-
 tion of a self-test. Flow-based ELLDs
 that use a nonquantitative flow test
 seem to provide a reasonable test of
 operation. All  of  the  flow-based
 ELLDs of which I am aware fall into
 one of these two categories.

 For Those Who Are Still
 Dissatisfied
 My reading of the regulations is that
 the privilege of deciding what a "test
 of operation" is rests with the manu-
 facturer of the device. The disagree-
 ment arises because of the  varying
 definitions of "operation." My dictio-
 nary says that "operation" means
 "the quality or state of being func-
 tional," and that "functional" means
 "performing or able to  perform its
 regular function." These definitions
 leave lots of room for manufacturers
 and regulators to have differing opin-
ions about what is meant by "test of
 operation."
    To tilt the definition in the regu-
latory direction would require a spe-
cific definition of "test of operation."
Such a definition might read, ""test of
operation' shall mean a procedure to
 confirm that a LLD will detect a leak
 of 3 gph by simulating a 3 gph leak
 and verifying that the LLD responds
 by shutting off the flow, restricting
 the flow, or sounding an alarm. Man-
 ufacturer's recommendations should
 be followed when conducting the test
 of operation." In the absence of a reg-
 ulatory definition for "test of opera-
 tion,"   however,    the   federal
 regulations and the dictionary give
 the manufacturer of the  LLD wide
 latitude in setting its own definition.

 My Two Cents
 My own thinking has evolved such
 that I would rather have a well-engi-
 neered, self-testing device that evalu-
 ates itself on a daily (or nearly daily)
 basis than a non-self-testing device
 that is evaluated by  a  person of
 uncertain competency on an annual
 basis.
    I've been somewhat reassured in
 researching this article that the most
 popular ELLDs do a fair  amount of
 self-checking that will realistically tell
 the facility operator (if he or she is in
 a mood to listen) whether the ELLD
 is functional. While the self-checking
 may not take into account all possible
 contingencies, there seem to be clear
benefits to automatic self-testing ver-
 sus an annual test of operation con-
ducted by a fallible human.
    Either way, there are no guaran-
    Either way, there are no guaran-
 tees that every leak will be detected in
 a timely fashion. As former OUST
 employee  David  Wiley  has been
 known to say, "We should not let the
 perfect become the enemy  of the
 good."
    It would be helpful to have some
 real-world data that would reveal the
 number/percentage of the following
 events:
   • The  number of piping  leaks
     that have occurred where the
     ELLD did not detect the leak;
   • The number of times service
     personnel have responded to
     customer  reports  of  ELLD
     warning lights or messages;
     and
   • The number of times service
     personnel responding to other
     problems    have   discovered
     ELLDs in warning mode.

    My gut instinct (whaf s yours?) is
that the number of instances where a
leak was missed by a malfunctioning
ELLD will run a distant third to the
instances  where  a warning  light
resulted in a service call or was com-
pletely ignored.
    Maybe what is really needed is
an annual test to verify that facility
operators  understand  their  leak
detection equipment. •
           ELLDs - Tips for Inspectors
     If an internal diagnostics system detects a problem, some ELLDs will
     not proceed with the more sensitive 0.2 gph test. If an ELLD has not
     completed a 0.2 gph test in the last week, it may indicate that die device
     is not working correctly (unless the facility is extraordinarily busy).

     Read alarm messages carefully (this task may require consulting an
     owner's manual or technical manual for the device) to understand
     what the ELLD is telling you (and the owner).

     For pressure-based ELLDs, consult the programming manual for the
     device to find out how to verify that the type and length of piping that
     have been programmed into the ELLD are consistent with the piping
     actually present at the facility.

     Get a copy of the California State Water Resources Control Board's
     (SWRCB's)  new booklet, Understanding Line Leak Detector Systems. The
     booklet discusses the technological principles of LLDs and provides an
     overview of installation, inspection, maintenance, and special features
     of these devices. While you're at it, check out SWRCB's Understanding
     Automatic Tank Gauging Systems booklet. To obtain copies of either
     booklet, fax your request to the SWRCB UST Program at'(916) 341-
     5707, call (916) 341-5775, or visit its Web site at http:/ /www.swrcb.
     ca.eov / cwphome / ust. •
                                                                                                      27

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LUSTtitie Bulletin 36
   by Robert N. Renkes, Executive Vice President, Petroleum Equipment Institute

   PEI'S RECOMMENDED PRACTICE FOR UST SYSTEM INSTALLATION (RP100) REVISED
        The federal underground storage tank regula-
        tions (40 CFR 280.20) require that all USTs and
        piping  subject  to  these rules  be properly
   installed in accordance with a code of practice devel-
   oped by a nationally recognized association or inde-
   pendent testing laboratory and in accordance with the
   manufacturer's instructions.
       Of the three recommended practices mentioned in
   40 CFR 280, only one, PEI's Recommended Practices for
   Installation of Underground Liquid Storage Systems (FBI
   RP100-2000), has been updated  and revised about
   every three years since it was first issued in 1985.
       RP100 has been revised once again and is now
   available to individuals and firms interested in the lat-
   est guidance on proper techniques and methods for
   installing UST systems.
       The group responsible for writing the recom-
   mended practice, PEI's Tank Installation Committee,
   reviewed over 160 comments—with more than 40 per-
   cent  coming from regulators—and made many
   changes throughout the document. Here are a few
   examples of the revisions:
      • A more extensive list of post-installation testing
        recommendations is included in the reformatted
        chapter on testing.
      • The requirement that the bottom of the excava-
         tion be covered with leveled backfill material
        has been removed. Instead, the instructions read
         that tanks should be installed to facilitate water
    removal. In addition, a new section asks the
    installer to consider the installation of a water-
    gauging port at the end opposite the tank fill
    pipe. (See diagram below.)
  • New and stronger warnings on the use of vent
    restriction devices have been incorporated into
    the chapter on piping.
  • A new section on fill piping has been added.
  • About a dozen drawings and figures have been
    revised.
  • Substantial releases from secondarily contained
    pressure piping systems have occurred because
    of the failure of interstitial sensors or leakage of
    product out of  the  secondary  containment
    before the product could reach the sensor. The
    document now recommends that line leak detec-
    tors be installed on all pressurized piping sys-
    tems,   including  those   with   secondary
    containment.

   RP100-2000  supersedes  the previous  recom-
mended practice of the same name, published in 1997.
Copies are  available for $30 (includes postage and
handling) from PEI,  P.O. Box 2380, Tulsa, Oklahoma
74101-2380. Phone: (918) 494-9696. Fax: (918) 491-9895.
On-line orders  can  also be placed on PEI's  secure
server at wTvw.pei.org / catalog. •
                                             Piping Dimensions
                                                                         Water gauging     6min.—
                                                                         port
             Dimensions shown are generally accepted limits. Sloping all lines to the tank facilitates future testing. (Revised diagram.)
 28

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                                                                                       LUSTLine Bulletin 36
   MTBE
 Santa  Clara Study  Examines  Causes of
 Fuel/MTBE  Releases  at Active UST Sites
    In May, the Santa Clara Valley
    Water District released a report
    titled  An  Evaluation  of MTBE
 Occurrence at Fuel  Leak  Sites with
 Operating Gasoline USTs. The report
 presents the results of a study the
 District undertook because of con-
 cern over a disturbing rate of occur-
 rence and  magnitude of MTBE
 releases at facilities where gasoline
 USTs are still in use, compared with
 sites no longer storing or dispensing
 fuel. The study was designed to eval-
 uate potential causes  of significant
 MTBE contamination at  operating
 UST facilities, including evaluation
 of the  occurrence  of undetected
 releases and identification of actual
 and potential weaknesses in fuel
 storage, management, and delivery
 operations.
    To identify the most reasonable
 source and cause of the MTBE conta-
 mination, available  MTBE data for
 more than 150 LUST sites with oper-
 ating USTs were reviewed. A final
 study population of 16 LUST sites
 with operating UST systems and high
 concentrations of MTBE in ground-
 water was selected.  The sites were
 evaluated in detail to  determine
 whether new releases were occurring
 and not being detected by the moni-
 toring systems.
    The results of the 16 case studies
 reveal that 13 sites are suspected of
 having an undetected  release from
 the current UST system, and 2 sites
 are  suspected of having a  pre-
 upgrade release. Releases at two of
 the  sites  with significant  MTBE
 plumes   were  discovered  only
 because of significant nuisance con-
 ditions that warranted investigation.
 In one case, vapors in an off-site
 sewer prompted investigation of the
 USTs. In the other case, detection of
 MTBE in a nearby municipal well
 prompted  an investigation.  The
 release locations for these two sites
have been confirmed.
    In one case, a leak in the primary
piping drained to the  submersible
turbine pump but was not contained
 or detected. In the other case, the
 owner identified the release mecha-
 nism as a vapor release associated
 with the vapor recovery system, as
 well as potential breaches in various
 portions of the system.
     A specific  release mechanism
 could not be definitely identified for
 the other 14 sites. At two sites where
 detailed testing of the secondary con-
 tainment portions of the systems was
 conducted, components, such as dis-
 penser pans and turbine sumps, were
 not liquid-tight, but a release from
 these  components  was not con-
 firmed.
     An attempt was made to deter-
 mine the most likely source location
 and release scenario resulting in sig-
 nificant MTBE concentrations at each
 of the 14 sites. An evaluation of the
 available data indicated the follow-
 ing suspected source areas:

   • Twelve of the sites appeared to
     have source locations around
     the tank complex. Five of these
     are suspected of having releases
     associated with inadequate or
     absent sumps around the sub-
     mersible turbine pump.

   • Two sites  appeared to have
     problems associated with lined
     trenches.

   • Two sites  appeared to have
     source areas located around the
     tanks and piping.

   • Three sites appeared to have
     source   areas    near   the
     piping/ dispenser.

  • One site had inconclusive data.

    At least 7 of the 16 sites had
received notices of violation or had
problems  noted  by an inspector
related to monitoring system compo-
nents. Four other sites had under-
gone third-party inspections during
which components were found to be
either not liquid-tight or not vapor-
tight.
 Increased Vigilance Needed
 Inadequate, or  lack of, secondary
 containment and improper monitor-
 ing seemed to be the common theme
 associated  with suspected unde-
 tected releases. The study concluded
 that the results  of this and similar
 studies should be used to assess the
 threat to water resources posed by
 storage of fuels in USTs and the oper-
 ation of fueling facilities.
    Whereas most of the cases exam-
 ined in this study involved double-
 walled tanks and piping—14 of the
 16 sites had double-walled tanks, 10
 had double-walled piping, and 6 had
 lined piping trenches—the study rec-
 ommended that particular attention
 be paid to single-walled UST systems
 that have no protection against low-
 volume  leaks  that may not  be
 detected by monitoring or integrity
 testing. Conversely, the mere pres-
 ence of a double-walled UST system
 does not guarantee protection against
 undetected  and/or significant re-
 leases.
    The  study also recommended
 that although  operating UST facili-
 ties are not currently required to con-
 duct environmental monitoring at
 non-LUST  sites, such  monitoring
 should  be  considered the  only
 method to confirm the presence of
 MTBE in groundwater and evaluate
 the threat that past and continuing
 undetected releases pose to ground-
 water resources.
    The report is available  on the
 District's Web site at http://www.
 scvwd.dst.ca.us / wtrqual / factmtbe.
htm. A slide presentation based on
the report is also available from the
same Web site. •
  ;_ For more information, contact
      James S. Crowley, P.E.,
  g__ Engineering Unit Manager
  ^Leaking Underground Storage
^Tank Oversight Program, Santa
g* Clara Valley Water District, at
      (408)265-2607 (x2638).
                                                              .;„	J

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LUSTLine Bulletin 36
"There's  Still a Lot of Work to Do"
OUST Director  Announces New
UST Program  Initiatives
   It  seems clear that EPA's new
   Director of the Office of Under-
   ground Storage  Tanks (OUST),
Cliff Rothenstein, has a mission. He
is no stranger to the goings-on of
EPA's  storage  tank  program.
Rothenstein assumed his position at
OUST after serving three years as
Deputy Assistant Administrator for
the Office of Solid Waste and Emer-
gency Response (OSWER), where he
worked on EPA and the Administra-
tion's positions and strategies on
Superfund, solid and hazardous
waste, and UST legislation. He was
also the agency's chief negotiator on
Superfund and solid waste legisla-
tion, directing the Administration's
congressional negotiating teams.
    Since taking up up his new role at
OUST in June, Rothenstein has been
quick to get down  to business.  "I
think if s great," he says. "This pro-
gram presents a whole new and dif-
ferent type of challenge. There is a lot
of good work being done here. I just
want to help the program gain a little
more visibility, so people realize there
is still more work to be done. We've
done some creative things in the past,
and we'll continue to try to do that."
    As Director, Rothenstein is gear-
ing up to implement four new UST
program initiatives:
   •  Launching  numerous  UST-
      fields pilots to assess, clean up,
      and  foster redevelopment  of
      abandoned or closed UST sites;
   •  Taking steps  to improve and
      maintain UST system compli-
      ance with spill, overfill, corro-
      sion  protection,  and  leak
      detection requirements;
   • Taking  steps  to accelerate
      cleanups for the 160,000 petro-
      leum releases that have already
      occurred; and
   • Evaluating the performance of
      UST  systems  to determine
      what's working and what,  if
      any, regulatory changes should
      be made.
     On  October  23,  Tim Fields,
 EPA's Assistant Administrator for

 30
OSWER, sent a memorandum to all
10 of EPA's Regional Division Direc-
tors for Underground Tanks dis-
cussing the four initiatives. See EPA's
Web  site  at www.epa.gov / oust /
and click on the "What's New" but-
ton to view the complete memo.
    "Right now, we will continue to
work with the regions and states to
develop the details on these initia-
tives," says Rothenstein.
    OUST will step up its USTfield
efforts by conducting a series of pilot
programs where the states and the
local communities work together to
perform site assessments of the aban-
doned tank universe in  selected
cities, particularly in areas where
communities are trying to promote
redevelopment.
    As part of  this initiative, EPA
announced on November 2 that it
• has targeted  communities in 10
states to receive $100,000 each for
assessment  and cleanup  of  aban-
doned tanks. The 10 communities
include: Nashua, New Hampshire;
Trenton, New Jersey; Wilmington,
Delaware; Anderson, South  Car-
olina; Chicago, Illinois; Kansas City,
Missouri; Albuquerque, New Mex-
ico; Salt Lake City, Utah; Oakland,
California; and Portland,  Oregon.
EPA plans to select 40 more UST-
 fields pilot projects in 2001.
    "We will focus on filling in the
 gap at Brownfield sites, where tanks
 exist but  Superfund money cannot
be used,"  says Rothenstein. "Almost
 every Brownfield site has some aban-
 doned tanks. If they find them, they
 can't  do  anything  about  them,
 because they can't use that money.
 Our USTfields initiative will allow
 the state and the community to actu-
 ally do the assessment arid maybe
 even the cleanup at those tank loca-
 tions."
     "As for increasing compliance,
 we might look to establishing tar-
 gets, whereby we try to get more and
 more compliance each year,  "says
 Rothenstein. "We need to  come up
 with a good, common definition of
 'operational compliance/ so  that
     Oust Director Cliff Rothenstein.
everybody's working off of the same
page—to the extent that we can. We
might see if there is a way to pro-
mote the idea of multisite compli-
ance agreements with  owners—
maybe for cleanup, too^-so that you
basically negotiate one  agreement
that applies everywhere and save
time and resources."
    "I know a lot of cleanups have
been done, but there is still a bit of a
backlog," he explains. "We're look-
ing at  different  ideas—perhaps
establishing annual targets for clean-
ing up sites. We envision that the
regions  and the states will work
together to establish these targets.
We are also looking for ways to use
innovative approaches, such as pay
for performance,  to  speed   up
cleanups."
    He says the agency will go back
and evaluate the UST requirements.
"We won't get all the answers imme-
diately,  but we  want to focus on
some of the critical questions so we
can at least get  some preliminary
answers."
    Rothenstein has a mission for the
tank program. "I think there's been a
sense that this program's been work-
ing well and nothing needs to be
done," he says.  "But frankly, there
are 160,000 releases out there that
still need to be cleaned up—far more
than Superfund or RCRA combined.
There are still a lot of active tanks
that are not in compliance. There's a
whole universe of abandoned tanks
that people aren't really sure what to
do about—part of the reason for the
USTfields initiative. We've done a
great job, but there is still a lot of
work left to do." •

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                                                                                      LUSTLine Bulletin 36
  Health & Safety _
 Alaska  Tank Explosion Linked
 to Polyester Coveralls
 by Ben Thomas

      On May 16, 2000, a Soldotna,
      Alaska, UST owner was hos-
      pitalized with first- and sec-
ond-degree burns on his face after
one of three underground tanks he
was preparing for removal exploded.
The three tanks had been out of ser-
vice for some time and were mostly
empty. Anticipating the arrival of the
tank removal  contractors, the tank
owner was using an electric pump to
try and remove the last bit of gasoline
from the tank when the explosion
occurred. At the time, the tank owner
was wearing an insulated jumpsuit
that was a polyester / cotton blend.

The Ignition Source
The owner had unknowingly created
what is  known  in the fire-fighting
business as a "fire triangle." For a fire
to occur, three  critical ingredients
must be present: fuel, oxygen, and an
ignition source.
   The tank already contained a suf-
ficient fuel-oxygen mixture. Because
it was mostly empty, there was plenty
of space for the gasoline at the bottom
of the tank to vaporize. When the
owner tried to remove the product,
there was probably a high level of
explosive vapors in  the tank. This
environment set the stage for a dan-
gerous situation.
   The owner's coveralls were 35
percent cotton and 65 percent poly-
ester—enough polyester to
create some static while the
tank owner was working.
The static buildup from the
polyester suit, plus the dry
Soldotna air, created a spark.
All the spark needed was a
fuel  source  and  oxygen.
When the owner got near
enough to  the gasoline
vapors fuming out of the fill
pipe, the  static  from his

   ^ Picture of charred pump and
  baseball cap after tank explosions
      sends owner to hospital in
             Soldotna, Alaska
coveralls was  the  ignition  source
needed to trigger the explosion.

Think Twice Before...
Be careful when working around gaso-
line. It may be easier than you think to
create a "fire triangle." A tank that is
mostly empty can be a greater fire haz-
ard than one that is full of gasoline.
Hire trained professionals to properly
and safely remove a UST from the
ground. And seriously consider using
cotton-only  work garments  when
working around gasoline. •

 Ben Thomas is with the Alaska Depart-
 ment of Environmental Conservation
  UST program. He can be reached at
  Ben Thomas@envircon.state.ak.us.
          LU.S.T.LINE
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  Name Company/Agency

  Address _
           Street                           City/Town                     State             ZIP
  Please enclose a check or money order (drawn on a U.S. bank) made payable to NEIWPCC.
  Send to: New England Interstate Water Pollution Control Commission
         Boott Mills South, 100 Foot of John Street, Lowell, MA 01852-1 124
         Phone: (978) 323-7929 •     Fax: (978) 323-791 9 •  lustline@neiwpcc.org • www.neiwpcc.org

  We welcome your comments and suggestions on any of our articles.

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 Two New Compliance
 Assistance Tools Now
 Available
 The EPA Office of Underground
 Storage Tanks (OUST) is distribut-
 ing the following two new compli-
 ance assistance tools to Regional
 and state UST programs to help
 increase compliance levels:

 •  Operating and Maintaining
 Underground Storage Tank Sys-
 tems: Practical Help and Check-
 lists  (EPA 510-B-00-008)  is  a
 50-page  manual containing brief
 summaries  of the  federal UST
 requirements  for  operation  and
 maintenance (O&M), as well as
 practical help that goes beyond the
 requirements. Checklists prompt
 the user—the UST owner or opera-
 tor—to look closely at the kinds of
 equipment in use and explain how
 to keep that equipment working
 properly over the lifetime  of the
 UST system. The manual provides
 recordkeeping forms that also help
the UST owner and operator keep
equipment operating properly. If the
user has questions, the manual pro-
vides contact information for addi-
tional help.  The  O&M manual is
available in electronic form for free
viewing, printing, and downloading
at  wwTV.epa.gov / swerustl / pubs /
index. htm#ommanual. The manual
will be updated periodically, and the
most current edition will always be
available at this Web site.


• Automatic Tank Gauging Sys-
tems for Release Detection: Ref-
erence Manual for Underground
Storage Tank Inspectors (EPA 510-
B-00-009) is a 140-page manual that
can help state and EPA inspectors of
USTs evaluate how well UST owners
and operators are using their auto-
matic tank  gauging (ATG) systems to
comply  with  release  detection
requirements. The manual also pro-
vides handouts that UST inspectors
can distribute  to UST owners and
operators to help them understand
the proper operation and mainte-
nance of their ATG systems.
   The manual contains a sum-
mary of specifications, based on
third-party evaluations, for ATG
systems that detect leaks from USTs
and their piping. Each summary
provides information on certified
detectable leak rate/threshold, test
period  duration, product applica-
bility,  calibration requirements,
restrictions on  reports, sample
reports, and more. The ATGrnan-
ual is available in electronic form
for free viewing, printing,  and
downloading  at  www.epa.gov/
swerustl / pubs / index.htm#auto-
matic. The  manual will be updated
periodically, and the updated ver-
sion will always be available at this
Web site.

   Both manuals can be adapted and
tailored by states or industry to match
precisely their specific requirements
(for assistance, contact Jay Evans at
703-603-7149 or evans.iav@eva.sov).
LU.S.T.UNE
New England Interstate Water
Pollution Control Commission
Boott Mills South
100 Foot of John Street
Lowel^ MA 01852-1124
Forwarding and return postage guaranteed.
Address correction requested.
   LU.ST.UNE INDEX
    Auctut ItSiDuIIotln II -June SOOO/BaUgtln 135
    The updated LUSTLine
      Index—the long and
    action-packed story of
      USTs and LUSTs—
       is now available.
        Call NEIWPCC
       for your copy at
        (978) 323-7929

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