"New England Interstate
Water Pollution Control
Commission
Boott Mills South
1OO Foot of John Street
Lowell, Massachusetts
01852-1124
Bulletin 37
March
2001
LUST.
A Report On Federal & State Programs To Control Leaking: Underground Storage Tanks
Setting Our Sights on Operational Compliance
by Ben Thomas
any regulators still define the universe of underground storage tanks (USTs)
according to the erstwhile two-part model that focuses on those tanks that are
upgraded and those that are not. Under that model, new or upgraded tanks
are, more or less, resistant to failure. Conversely, nonupgraded tanks are an inherent
risk to human health and the environment. Prior to December 22,1998, this either/or
model helped drive 1.5 million tanks into compliance or closure. However, two full
years after .the deadline, if s just not that simple any more. ^ . ^
Like it or not, UST programs are in transition from a simplistic model-of theJtank
universe (upgrade) to a more complex and real-world model (operatip'n'al cojrfplSance).
The sooner states start doing the groundwork to move in this new^directiorirthe better off
both regulators and tank operators will be—not to mention theenAdronrrtent.
The "1998 deadline" had a fearsome and somewhat tantafizing^atu^Mtd a nice, neat do-or-die endp'oint, but it is his-
tory. Now regulators are tasked with energizing the USEprogram witfeafnew long-term target that is fraught with behav-
ioral implications for the UST operator—"Significant;©perational^g.ompliance."
I'd like to offer a recipe for how states can ii
lowing key ingredients:
•, achievg^Snd maintain this new target. The recipe contains the fol-
Epcget the'98 deadline.
Admit that operational compliance is a national problem.
Define new goals, change old endpoints.
Explore new incentives. B continued on page 2
Inside
ska's Third-Party Inspection Program
Tank-nically Speaking: Plugging the Holes in Our UST Systems
•Taking the Pulse of Maine's CP Tanks
Getting a Hand on Facility Compliance Inspections
Mew California Document Highlights the UST-LUST Connection
A Circle Vicious: What Do We Know About the Other Oxygenates?
Is MNA Appropriate for Remediating MTBE?
Gasoline Oxygenates and Private Wells
E-Commerce at the Dispenser
MTBE Survey Sheds Light on Where States Are and Aren't
Iowa Makes Transition from State Fund to Marketer-Owned Insurance
An Expedited Site Assessment CD
-------
LUSTLine Bulletin 37
m Operational Compliance...
continued from page 1
Forget the '98 Deadline
It may seem heretical to ask someone
to disregard a historical marker like
the 1998 deadline, but let's face it,
some of us are still thinking of the
UST program with a pre-1998 mind-
set. This is dangerously short-sighted.
From the big-picture standpoint, we
can assume that basic equipment-
based compliance is pretty much
achieved. We must now set our
sights on ensuring that those envi-
ronmental safeguards function. For-
ever.
Not only is the '98 deadline irrel-
evant to our goal of preventing
future fuel releases to the environ-
ment, it is actually getting in the way
of how we look at the future of the
UST program. I've seen this time-
warp mentality manifested in a num-
ber of ways:
• A state regulator says his program
is not ready to embrace operation
LUSTLine
Ellen Frye, Editor
Ricki Pappo, Layout
I Marcel Moreau, Technical Advisor ;
S PatriciaEllis.Ph.D., Technical Advisor "'
tRorudd PolM, NEIWPCC Executive Director ~
i Lynn DePont, EPA Project Officer .
Lela Bijou, OUST Liaison *
^ LUSTLine is a product of the New England
^Interstate Water Pollution Control Commis- *
sion (NEIVyPCC). It is produced through a ;
T cooperative agreement (SCT825782-01-0) \
WPCCandtheU.S.
cooper
i ' oetween!
; Enx'lronmental Protection Agency.
* '"" "!"-" ' «" ' ' ' ' ' I
; issued as a communication
~ Hazardous _& Solid Waste Amendments s
ff ...ml **tilrt r\f/^rYinlnfnfTr*Ti nr/~»rlocc
_ r is produced to promote
^Information exchange on UST/LUST issues.;
|".Tjhe opinions and information stated herein
I are those of the authors and do not neces- :
i sarily reflect the opinions of NEIWPCC.
« This publication may be copied.
E:;V::ll:::,?teasegivecreditJoNEIWjPCC. ~m
I NEIWPCC was established by an Act of '
" Congress in 1947 and remains the oldest
s agency in the Northeast United States
I concerned with coordination of the multi- ^
; media environmental activities
i of the states of Connecticut, Maine,
- Massachusetts, New Hampshire, ,
| New York, Rhode Island, ana Vermont.
- "' ' NElwfcC '"""'*"' "v"":',
Boon Mills South, 100 Foot of John Street
Lowell MA 01852-1124
; Telephone: (978) 323-7929
^ Fax:(978)323-7919
• lustline@neiwpcc.org
1 4J& LUSTLine Is printed on Recycled Paper
and maintenance outreach efforts
yet because of the number of non-
upgraded tanks still in existence.
• A federal inspector speaking at a
national conference belabors his
concerns about pre-1998 leak
detection methods that are no
longer valid for most tank own-
ers.
• A number of states have Web
page headlines with outdated
1998 logos, deadline descriptions,
and warnings.
Not that all regulators are living
in the past. How many of you, in the
early winter months of 1999, were
wondering where the program
would go after the deadline? Some of
you must have wondered: What hap-
pens after all the tanks are upgraded,
after closures trickle down to the
occasional, and when risk-based
decision making brings the lion's
share of the LUST sites under con-
trol?
Fear not, fellow visionists. For
better or worse, the national spot-
light on MTBE has raised some
pretty pointed concerns about the
fundamental effectiveness of the UST
program as a whole. Sure we got rid
of 60% of the nation's USTs. Sure
there are 300,000 LUST sites with
cleanup underway. And sure the
nation's tanks are mostly upgraded.
So why is MTBE showing up in
water supplies?
Echoing the prophetic incanta-
tions of a number of astute UST afi-
cionado are a number of excellent
MTBE studies that ask some hard
and fundamental questions.
• Does leak detection actually
detect leaks?
• Do a majority of operators under-
stand leak detection requirements
at a basic level?
• Do operators know what to do if
they suspect a release?
• Are the upgraded tanks being
adequately maintained?
• What can we do to minimize
future releases from "upgraded"
tanks?
• How often must an UST system be
inspected? And how thoroughly?
• What parts of the UST system are
most susceptible to releases in the
post-deadline world?
The biggest problem with the
1998 deadline is that we put so much
effort into showcasing this important
date that we failed to see that we
were creating a perception that the
program would be over after Decem-
ber 23,1998. The deadline turned into
an artificial endpoint, when, in fact,
1998 was only the beginning of the
program.
An ATG in alarm mode during inspection,
Haines, Alaska, June 2000.
We need to focus our efforts on a
new level of detail. Instead of settling
for the presence of an automatic tank
gauge (ATG) on the compliance
checklist, regulators need to be ask-
ing the salient questions concerning
that gauge—Is the ATG currently
third-party approved? Is the monthly
test run for the proper time duration
and with enough product for a valid
test? Are there 12 months worth of
records available to prove a history of
leak detection? How does the ATG
console indicate when a release
occurs, and will the owner know
what to do?
Operational Compliance
A November 2000 report prepared by
the Alaska Department of Environ-
mental Conservation (ADEC) shows
that operational compliance is a
major problem in the state. Expanded
to a national level, we may have sev-
eral hundred thousand malfunction-
ing or mismanaged USTs that are
accidents waiting to happen. Indus-
try representatives will tell you this
scenario is not possible, but they can't
prove operational compliance on a
wide scale any more than most states
can.
Enter the new mindset—signifi-
cant operational compliance. U.S.
EPA, working with states, developed
a concept meant to be a yardstick by
which states can measure problems
and successes in the post-deadline
-------
LUSTLine Bulletin 37
Before
After
P/pe sump before and after rusty water was removed, Juneau, Alaska, August 2000.
world. Behind the concept is the need
for states to prioritize prospective
violations because, in reality, a state
inspector can go to virtually any UST
facility in America and find at least
one violation.
EPA claims that 85% of UST sys-
tems in the United States are achiev-
ing operational compliance. This
percentage is based on numbers that
are handed over to the agency by
each of the states. These numbers are
based on projections, not systematic
studies. I contend that most states
have not taken enough of a represen-
tative sample' to extrapolate to a
meaningful percent. Also, we may
never know the real national picture
because EPA developed only a con-
cept and not guidance. Essentially,
EPA is allowing states to come up
with their own definition of signifi-
cant operation compliance.
Are all UST regulations of equal
weight or significance? Is it realistic
to try to enforce all regulations for all
USTs equally? If not, what is the pri-
ority scheme? How do we determine
which requirements are "mission
critical" and which we, well, over-
look for the time being? Having a
consistent, national guidance on
significant operational compliance
would help us answer these ques-
tions.
Alaska, with its meager 1,100-
tank population, completed its
first- ever sweep of operational com-
pliance in 2000 by having third-party
inspectors inspect one-third of all the
tanks. And, big surprise—most tanks
failed significant operational compli-
ance. Our finding is exactly opposite
the delusional compliance rate that
states are theorizing. And Alaska has
achieved almost 100% with regard to
equipment-based compliance, which
means that a mostly new population
of USTs is highly susceptible to oper-
ational compliance failure.
Invalid (INVL) test results fromATG at small
service station in Juneau, Alaska, August 2000.
So how bad off is operational
compliance in your state? Until you
have done some systematic inspec-
tions, or until you mandate routine
operational inspections, you may
never know.
Define New Goals, Change
Old Endpoints
While the federal UST regulations
have been effective at helping tank
operators achieve compliance, they
are not necessarily effective at help-
ing tank operators maintain compli-
ance. What seem to be entirely
absent from any tank program are
protocols for addressing repairs,
fixes, alterations, additions, or
enhancements of UST systems. If
you've ever tried to guide an opera-
tor through the requirements on
repairing an UST system, you will
know what I mean.
Getting unstuck from the 1998
deadline also means that regulators
are forced to burrow into a deeper
layer of unanswered questions that
have persisted over the years but that
have been relegated to the back
burner. Until now. Will somebody
please tell me:
• How often an UST system should
be inspected for operational com-
pliance?
• How do you assess compliance on
UST systems with multiple or
redundant leak detection types in
place? Does the owner have to
meet the requirements for one,
some, or all?
• Does a double-walled, pressur-
ized pipe need to have an auto-
matic line-leak detector as well as
a sump alarm?
• How does an owner document
compliance with leak detection
methods that produce no paper?
For example, what do you tell the
owner of an UST with continu-
ously monitored double-walled
piping who has no monthly print
out of leak detection status? Does
he have to upgrade to a printer? Is
an "idiot light" enough?
• Why must automatic line leak
detectors be tested annually for
functionality and not flow rate? I
have unnamed sources that say
many ALLDs don't meet the
3 gph leak rate out of the box and
may not be working.
• Does the "power on" light on an
ATG console need to be working
in order to be in compliance?
• continued on page 4
-------
LUSTLine Bulletin 37
m Operational Compliance...
continued from page 3
• What is an acceptable national
standard for performing a
cathodic protection test?
• What standard do we use for
adding sacrificial anodes to an
existing STI-P3 tank that has low
CP readings?
• Does an UST with double-walled
piping that has a continuous
sump-sensor alarm need monthly
recordkeeping? Is monthly check-
ing required if it is continuous?
• Is a piping sump alarm okay if ihe
UST is an unstaffed, 24-hour sta-
tion?
• What method do you use to test a
spill bucket for tightness? Hydro-
static? Visual?
• How do you confirm that a ball
float valve is both present and set
to trip when the tank is 90% full?
• How do you test the functionality
of a drop-tube overfill device once
it is installed?
These questions must be an-
swered as more and more states
focus on the operational end of UST
compliance. And if they cannot be
answered easily in the OUST techni-
cal compendium, it may be time to
open the hood of the UST regulations
and make some changes. Many peo-
ple are concerned that revisiting the
national UST regulations is the envi-
ronmental equivalent of Pandora's
box, but I think the program will be
forced to move in this direction even-
tually. We can approach it clearly
and with intention, or we can be
dragged to it kicking and screaming.
Explore New Incentives
In the big picture, we shouldn't fool
ourselves into thinking that our prob-
lems are over—far from it. I believe
that the real work of leak detection
has not even begun. So what are the
best incentives we can use to pro-
mote a continuous vigilance that will
result in better release prevention?
How do you promote a "release pre-
vention attitude"?
Like UST specialist Marcel
Moreau said at the EPA UST/LUST
conference last year, tank operators
are generally more interested in how
potato chips are displayed than how
to do monthly leak detection. This is
because they know they make money
on potato chips, but they don't see
the economic return of release detec-
tion.
It helps to remember that we,
regulators and regulated alike, all
share a common goal of preventing
releases to the environment from
USTs. Some of you more weathered
field inspectors may smirk at this
lofty assessment but it's true: With a
common goal we can continue to
make common ground. So again,
what can we all do better?
Here are some specific recommenda-
tions for states to consider.
• Voluntary operator certification
Currently there is no method that
states are using to test the compe-
tency of UST operators, although
Florida and California are headed
in this direction.. I would like to
see a method to promote educa-
tion and testing of UST operators.
I am not convinced that another
regulation mandating operator
certification is the most effective
way, so we need to consider
incentives to encourage operators
to the plate.
• Compliance tags
A number of states, Alaska now
included, rely on compliance tags
to document compliance at UST
sites. The tags help motivate oper-
ators to think about compliance,
especially in states that have fuel
bans for noncompliant tanks. UST
operators as well as the fuel-con-
suming public need a simple way
to identify operational compli-
ance. Compliance tags should not
be an indication that a tank has
met the 1998 deadline—they must
indicate operational compliance
and be renewed periodically.
UNDERGROUND STORAGE TANK
Hi
DEC %* I** V*. 1 Ug
"MM Gas 10000991 -
• Frequent mandatory inspections
These are not a bad thing if they
motivate tank operators to contin-
uously assess and maintain their
USTs. Alaska has used this
method with great success over
the past year.
• Continuous training
Don't put away your training
brochures yet. High operator
turnover (400% at convenience
stores) should be enough to tell us
we need to plan on training opera-
tors as long as tanks lie beneath
the ground. States need to de-
velop a whole new repertoire of
material to address operation and
maintenance of UST systems. The
more available the training, the
more operators have an incentive
to attend.
• Rewards
Good prevention practices trigger
behavior modification through
rewards. Remember Pavlov's
dog? Regulators need to think cre-
atively on how to offer reward-
like incentives to motivate
employees to do a good job look-
ing for problems.
• Enforcement/Outreach blend
The big stick approach works
sometimes, but it must be accom-
panied by a solid education and
outreach effort by states.
New Programs Mean
New Frontiers
In the future, a clean sump and a
well-maintained sensor, such as the
one shown on page 5, will be much
more exciting to a regulator than an
STI-P3 versus a fiberglass tank. As
regulators we need to shift our focus
to the more subtle and complex
details of the UST program.
States are shifting or eventually
will have to shift to compulsory
programs that focus on operational
compliance. Routine, mandatory in-
spections offer a great framework for
tying lots of loose programmatic
ends together.
The longer we wait to implement
this new directive, the harder it will
be for our UST operators to make the
shift. In Alaska, we believe that our
move to third-party inspections went
smoothly because UST operators
barely got through the rigors of the
'98 deadline requirements before
-------
LUSTLine Bulletin 37
Well maintained interstitial sensor sump, Juneau,
Alaska, June 2000.
launching into the next campaign.
UST operators will perceive any
lag time between what the state
expects before and after 1998 with
suspicion and reluctance. "I spent
all this money to upgrade my tank
and now you want what?"
Let's avoid this trap and get
busy working on a long-term plan
to prevent another generation of
leaking USTs. •
Ben Thomas, Environmental Specialist
for the Alaska Department of Environ-
mental Conservation, developed and
now administers the third-party UST
inspection program in Alaska.
He can be reached at
ben thomas@envircon.state.ak.us.
Privatizing UST Compliance Inspections
Alaska's Third-Party Inspection
Program
by Ben Thomas
How do you protect ground-
water, promote environmen-
tal responsibility, increase
compliance to nearly 100%, and not
hire any new staff? Simple, you pri-
vatize the inspection of UST systems.
All USTs in Alaska must now be
inspected every 3 years for opera-
tional compliance by a licensed
third-party inspector and tagged in
order to receive fuel. Between May 1
and November 1, 2000, one-third of
the active USTs in the state were
inspected in this manner.
Alaska is the third state to adopt
third-party inspection regulations—
the other states are Pennsylvania and
Montana. Inspection includes exam-
ining, assessing, testing, and docu-
menting leak detection, spill and
overfill prevention, and corrosion
protection systems. Our program is
unique in that inspectors can also
repair UST systems to bring them
into compliance to pass inspection.
Results of the First Year
One-third (423), of Alaska tanks
required inspection in 2000. By early
November, 2000, 99%, or 419 tanks,
were inspected. Alaska tank owners
rose to the challenge of paying for
and setting up third-party inspec-
tions. ADEC received no formal com-
plaints from tank owners. The cost of
inspections ran from around $300 to
$1,200 per site. Any required repair
work was an additional cost. Here's
what we learned:
• Eight out of every 10 tanks had
problems. Eighty-two percent of
the USTs that passed inspection
did so only after one or more
problems were identified and cor-
rected. Six hundred fifty-six prob-
lems were discovered and
corrected at 317 tanks.
• While inspectors found a few
cracked spill buckets, there were
no "real" petroleum releases
found in the summer of 2000. Or
put another way, one-third of
Alaska UST systems were not
leaking this summer. Realistically
speaking, this could mean: (a)
inspectors are not documenting
releases properly, (b) leak detec-
tion may not be working and
some tanks are leaking, or (c)
Alaska's UST population is in
good shape at the moment.
• Over 60% of all problems found
and corrected were associated
with leak detection. One-third of
all inspected UST systems did not
have adequately documented
Bill Tatsuda (left) receives Alaska's first UST
Compliance Tag from Bob Fultz of the Alaska
DEC, Ketchikan, Alaska, May 2000.
proof of leak detection for the last
12 months.
• Most problems were not caused
by the absence or failure of proper
equipment. Eighty-seven percent
of the problems identified were
related to operations or record-
keeping. Thirteen percent were
equipment-related problems.
• There were 397 individual leak
detection problems noted, versus
92 spill/overfill problems and 167
corrosion protection problems.
The types of leak detection prob-
lems vary widely. The high num-
ber of leak detection problems
indicate that operators still don't
understand leak detection very
well. Or it is simply not working
in the way it was intended.
• continued on page 6
-------
LUSTLine Bulletin 37
m Third-Party Inspection
Program... continued from page 5
• While some spill and overfill
devices were missing, the biggest
problem was keeping spill buck-
ets clean and free of debris and
water. Inspectors also discovered
a few UST systems that were
reported to have spill/overfill
devices but did not.
• The major deficiency for steel
tanks was the lack of any history
of CP testing. Roughly 85% of
Alaska's USTs are steel. Many
tanks received their first-ever CP
test as a mandatory part of the
third-party inspection.
Inspectors Performed Well
ADEC, with help from U.S. EPA,
found no violations when auditing
inspectors in the fall of 2000. Rigor-
ous qualification requirements, train-
ing, and communication probably
attributed to this achievement. We
made our requirements difficult
intentionally to avoid the hassle of
attracting "fly by night" inspectors.
ADEC trained over 90 people in
1999 and 2000, 26 of whom became
• continued on page 9
Elements of Alaska's Third-Party Inspection Program
Inspections are required every 3 years starting in 2000.
One-third of all tanks are inspected each year.
Licensed third-party inspectors perform the work.
The inspection is a total UST system check for presence and functionality of
leak detection, spill and overfill, and corrosion protection.
The inspector can make repairs.
Owners have 150 days to complete inspection, make corrections, and file
paperwork.
The Alaska Department of Environmental Conservation (ADEC) issues a per-
manent tag for all tanks that pass inspection.
An UST may not receive fuel unless it is tagged.
JMUl TYPES OF PROBLEMS
Deficiencies
No ATG documents
Water In tank interstitial space
ATG not rated for 20K tank, only 15
Interstitial sensor alarm on or not working
Doing IC+TTT but not allowed
Check valve in wrong location on suction piping
Not enough product in tank to run valid test
ATG broken
. ATG in alarm mode
ATG turned off each night
No leak detection records
Dispenser meter not calibrated
Inventory Control and/or reconciliation not being done
No Annual ALLD functionality test
No annual line tightness test
Fuel "dampness" in interstitial space
No maintenance of interstitial sensors
No documentation of interstitial sensors
No ALLD present
ALLD installed wrong
ALLD Leak rate unknown
ALLD not set to run 0.2/0.1 ggh leak rate monthly
Water in containment sump
Product in containment sump, pipe loose
FOUND IN ALASKA'S SUMMER 2000 INSPECTIONS
Leak Detection Spill/Overfill Cathodic Protection
28 ....
1
4 -
9 ' ......... ,
10 .
2
3 ' '-.•-.'"•
3
1 • • • ' i
1 .'.•••' .
137 ;
1 '. " • . i
4 . - ;
23 . .
25
2 '-•-.' . • '
62
62 ']
4 . i
1
2 "• ' • '
2
3 : ' - ' i
2 ' .:
Sump sensor positioned too high to detect a release. Product in sump. 3
Sump sensor networking
Overfill alarm not audible to driver or not working
Overfill alarm disabled
No Overfill device
Spill bucket damaged, cannot hold liquid
No spill bucket
Spill bucket full of product or water or dirt
CP failed
CP current low. Rectifier needed adjustment
Impressed current rectifier turned off
Records of last 6 moTSj/ear tests not present
60-day log not present
Total
2 ' - i
.. . 3 . , ' .• • • ';
1
10. : . .
.13
4 • -|
61
11
3 i
• ' 6
.126
21.
397 92 167
-------
LUSTLine Bulletin 37
Leak Prevention
pT£:- Marcel Moreau is a nationally „'
^recognized petroleum storage specialist
, Tank-nically Speaking,
-)n/ca//y Speaking
by Marcel Moreau
p.vfs a regular feature o/LUSTLine. As ;
yalw.ays, we welcome your comments and J
jj. questions. If there are technical issues ^
i" that you would like to have Marcel .
p discuss, let him know at ]
f, - marcel.moreau@juno.com. 1
PLUGGING THE HOLES IN OUR UST SYSTEMS
J'vejust returned from an exhausting week spent representing the interests of a city whose water wells are threatened by a
release ofMTBEfrom a service station. The situation is similar to one I described a few years ago. (See "The Holes in Our UST
Systems," LUSTLine #30.) A "state-of-the-art" storage system was the source of significant MTBE contamination. The storage
system owner claimed that there could not have been a release from the double-walled system, that some wayward customer must
have caused the problem by spilling a few gallons of gasoline.
My analysis of the situation included the possibility of customer spillage as a
contributing factor but also pointed out the likelihood of vapor releases, overfills,
and failure of the secondary containment to capture every drop of product.
One of the questions addressed to me by the city was, "What could be done to
prevent any future contamination from this facility?" While it is clear to me that
the only guaranteed way to prevent future discharges is to remove the facility,
this seems to be an unacceptable alternative. Given that the facility is to con-
tinue operations, what requirements could the city impose to provide maximum
protection to its water supply?
As I pondered the answer to this question, it occurred to me that over the
next few years quite a number of communities may be seeking answers to this
same question. What follows is a preliminary list of measures that I believe could
be effective in minimizing contamination from UST facilities. These measures are
intended to supplement double-walled systems. The first and most important measure to take
if you have a single-walled system is to upgrade to secondary containment.
Clearly, not all measures would need to be implemented at all sites. A site-specific evaluation would be needed to determine which
measures would be most effective for a given location. I present this list here to stimulate thought and promote discussion.
Some Leak Minimizing
Measures
[NOTE: This list assumes that the UST
facility is in full compliance with all exist-
ing regulatory requirements concerning
corrosion protection, leak detection, spill
containment, and overfill protection. The
issue I am addressing is that regulatory
compliance does not provide assurance
that releases of gasoline will not occur
from operating UST systems.]
• Ensure that secondary containment
is tight.
We learned long ago that primary
containment systems do not remain
tight forever, yet we blithely assume
that this will be true for secondary
containment systems. The integrity of
secondary containment systems must
be verified periodically. This includes
the outer wall of tanks and piping as
well as piping sumps and dispenser
sumps. Florida and California have
headed down this road and it is
something that is well worth doing.
• Ensure that secondary containment
catches everything.
A facility I inspected recently showed
evidence of a liquid release (staining)
from vapor recovery piping in the
dispenser cabinet. Following the trail
of the stain, it became apparent that
the liquid release flowed down into a
crack between the dispenser contain-
ment and the concrete of the pump
island into the soil. Secondary con-
tainment systems must be designed
so that they reliably capture releases
from both liquid and vapor handling
components of the storage system.
• Replace pressurized pumps with
suction.
Though my evidence is admittedly
anecdotal, I believe that pressurized
pumping systems are responsible for
better than 90 percent of the liquid
releases that occur from newly
installed, corrosion-protected storage
systems. A simple change of technol-
ogy could virtually eliminate this
source of product releases. Argu-
ments that suction pumps will not
work in America are specious. Suc-
tion pumping systems are still domi-
nant in Europe. If they can work in
Europe they can be made to work
here.
• Replace permeable pipe with
impermeable pipe.
An industry estimate of the likely
releases due to permeation from flex-
ible piping systems states that 8
grams per day (about a gallon per
year) of liquid can escape from these
• continued on page 8
-------
LUSTLine Bulletin 37
m Tank-nically Speaking...
continued from page 7
double-walled systems ("Compatibil-
ity and Permeability of Oxygenated
Fuels to Materials in Underground
Storage and Dispensing Equipment,"
Paul A. Westbrook, Ph.D., Shell Oil
Company, January 1999). While this
is a small quantity, it is sufficient to
cause contamination when MTBE is
present in the gasoline. Piping sys-
tems susceptible to permeation
should not be allowed in sensitive
areas.
• Provide secondary containment for
vapor piping.
While Stage II vapor return piping
handles vapors primarily, there is no
question that it also carries small
quantities of liquid product. Pressure
decay tests that are conducted to
meet air quality requirements are not
sufficient to detect small defects in
vapor piping. Secondary contain-
ment of this piping seems like the
best way to assure that liquid and
vapor releases do not occur.
• Do not allow pressurization of the
tank vapor space.
Vapor releases into the environment
are exacerbated by vacuum-assist
vapor recovery systems that pressur-
ize the tank ullage and force product
vapors out of the storage system. The
California Air Resources Board
(CARB) has recognized this weak-
ness and will require that future
vapor recovery systems maintain the
pressure inside the storage tank at or
slightly below atmospheric pressure.
Until such technology is commer-
cially available in this country, vac-
uum-assist Stage II vapor recovery
systems should be replaced with the
traditional balance Stage II systems.
• Isolate tank backfill from ATG and
Stage I vapor recovery risers.
Vapor releases and possible liquid
releases resulting from overfill inci-
dents that occur at automatic tank
gauge (ATG) risers and Stage I vapor
recovery risers typically pass directly
into the tank backfill. The installation
of spill containment 'manholes
around these openings would pro-
vide a barrier to vapor and liquid
penetration into the soil.
• Video tape deliveries.
We desperately need to rethink our
overfill prevention strategy (see
LUSTLine #31, "Hmmm...If Only
Overfill Prevention Worked!"), but
this is not on the horizon as far as I
can tell. As a stopgap measure,
install video surveillance cameras to
monitor the delivery process. Deliv-
ery drivers would need to be notified
that their activities are being
Potential Sources
of Leaks from Tanks
That Are
in Compliance
1 Delivery spills
2 Leaking spill containment manholes
3 Liquid and/or vapor releases from tank risers
(ATG, vent, spares, etc.")
4 Leaking submersible pump manifolds and/or product piping
5 Leaking piping sumps
6 Liquid and/or vapor releases from Stage II vapor recovery piping
7 Leaking dispenser sumps
8 Customer spillage
8
-------
LUSTLine Bulletin 37
watched and that their jobs depend
on spill-free deliveries.
• Do not allow any exposed backfill
around fill pipes.
The backfill around the perimeter of
some below-grade spill-containment
manways is exposed, providing an
all-too-convenient avenue for drips of
fuel from the hose (or even an entire
hose full of fuel) to enter the environ-
ment. Though these types of spill con-
tainment manways are effective in
keeping precipitation out of spill
buckets, as a contamination pathway
they pose too much of a risk.
• Require 15- to 25-gallon capacity
spill containment manways.
Until such time as effective overfill
prevention hardware is in place,
install spill containment equipment
that can hold the entire contents of
the delivery hose in case of a tank
overfill.
• Seal the pavement around the
dispensers.
To deal with customer spillage, seal
the surface around the dispensers
with petroleum-proof sealant, and
grade the pavement so that all liquid
runoff runs to an oil-water separator
that discharges to a holding tank.
The holding tank contents would
need to be periodically and properly
disposed of. The sealant would need
to be maintained to ensure its effec-
tiveness.
• Seal tank-top manway covers.
If tank-top manways are in an area
where surface spillage could occur,
they should be slightly above grade
or have liquid-tight covers to prevent
surface runoff from infiltrating the
tank backfill.
• Do not allow self-serve gasoline
dispensing.
Though messages on most dispens-
ing nozzles warn against it, topping
off when refueling automobiles is
still a common occurrence that leads
to spillage. By allowing only trained
attendants to dispense gasoline, this
problem could be reduced.
• Install automatic subsurface
monitoring.
Though it never proved popular for
UST leak detection, a device was
developed in the mid-80s that had
the ability to sample soil vapors at
numerous points on a daily basis and
monitor for the presence of gasoline
vapors. With today's communication
technology, such a system could eas-
ily be monitored remotely. Such a
system could provide early warning
of releases from any portion of the
storage system or even surface
spillage and overfills. In conjunction
with a preinstalled remediation sys-
tem (see next item), subsurface moni-
toring could be very effective in
detecting and intercepting contami-
nation before it can migrate off site.
• Preinstall a soil-vapor extraction
system.
A preinstalled network of slotted
pipe in a permeable backfill under-
laying the dispensing area and over-
laying the tank pit would make it
possible for remediation efforts to
begin within a very short time of the
discovery of a release (via the auto-
matic subsurface monitoring). Truck-
mounted, self-contained vapor
extraction and treatment units could
simply drive up, plug in to the prein-
stalled piping, and deal with small
releases in a few days or weeks time
if releases are promptly identified
and addressed.
• Implement periodic groundwater
monitoring.
Conduct monthly or quarterly
groundwater monitoring in areas
adjacent to storage system compo-
nents to provide early warning of
contamination. Monitoring well loca-
tion and construction would have to
be carefully considered so that the
wells would provide effective early
detection without posing the undue
risk of becoming a conduit for conta-
mination into the subsurface.
So...
Are all these measures necessary?
Would any of these measures really be
effective? Could a regulatory agency or
municipality ever realistically impose
any of these measures as requirements,
either across the board or at specific
facilities? Do you have better ideas? If
you could implement any three of
these measures, which would you
pick? Why? Send your two cents to
marcel.moreau@juno.com. •
• Third-Party Inspection
Program... continued from page 6
certified UST inspectors. There was a
ratio of about 17 tanks for every
licensed inspector, which seemed to
be sufficient. ADEC met with most
inspectors after the 2000 season and
discussed ways to improve reporting
requirements.
Veteran regulators who pooh-
pooh the mere concept of privatizing
inspections are apt to worry that
inspectors will fabricate problems in
order to perpetuate business. Indeed,
when I was a gas station attendant in
1982,1 was told by my supervisor to
get under the hood and sell as many
engine fluid products as humanly
possible.
What makes Alaska inspectors
different from my situation is the fact
that they are petroleum contractors,
by trade and can easily lose their
license (i.ev professional livelihood) if
they are caught cheating. Second,
inspectors must review the inspec-
tion form with the operator, and both
parties sign every page. This forces
the inspector to explain everything
he did, reducing the opportunity for
hiding anything. Third, UST opera-
tors can and do contact the state if
they want a second opinion.
Troubling Theme
One goal for our third-party inspec-
tion program was to simultaneously
reduce enforcement while increasing
compliance. Given the percentage of
inspections completed and the high
number of corrections made, this
goal has been achieved for at least
one-third of the state's USTs. How-
ever, the variety and number of prob-
lems found in 2000 all point to a
troubling theme—that Alaska UST
systems are not being adequately
maintained, and without periodic,
mandatory inspections, UST opera-
tors have no incentive to prevent fur-
ther releases. •
g~[ For more information about
^Alaska's third-party inspection
yrogram, contact Ben Thomas at
3en_thomas@envircon.state.akais.
I
-------
LUSTLinc Bulletin 37
by W. David McCaskill
David McCaskill is an Environmental Engineer with the Maine Department of Envi-
ronmental Protection. Tanks Down East is a regular feature o/LUSTLine. David
can be reached at David.Mccaskill@state.me.us. As always, we welcome our readers'
comments.
Taking the Pulse of Maine's
CP Tanks
There was a time when cathodic
protection (CP) was relegated to
preventing major engineering
projects such as bridge pilings or inter-
state pipelines from rusting to pieces. On
the consumer side, cathodic protection
zvas used to prevent outboard motors or
hot water heaters from rusting to pieces.
The former CP systems were project-spe-
cific designs for high-risk projects, while
the latter were pre-engineered systems
for consumer uses. Major structures
were usually monitored carefully by pro-
fessionals over the life of the structure,
while the consumer goods—let's face
it—were sold, and that was that. In the
case of cathodically protected USTs, we
have some sort ofCP hybrid—high-risk
structures with pre-engineered systems
that generally get little attention.
The Life and Times of CP
in Maine
In Maine, we have 1,812 cathodically
protected steel USTs—roughly one-
third (31%) of our total population of
5,900 active USTs. Most of these
tanks were installed with pre-engi-
neered galvanic CP systems, where
the number and size of the sacrificial
anodes (zinc or magnesium bars that
provide the flow of electrical currents
around the tank and protect the tank
from corrosion) have been selected
and connected directly to the tank
rather than installed in the field.
Galvanic CP systems are rela-
tively simple in construction and
operation, but it is widely acknowl-
edged that their effectiveness must be
monitored over time. This monitor-
ing is relatively easy to accomplish
by measuring the electrical potential
10
(voltage) of the tank relative to a
standard reference cell (usually a
copper/copper sulfate reference elec-
trode).
Since 1985, Maine has required
that cathodically protected steel
tanks be tested annually by certified
tank installers (CTIs), who are
required to demonstrate a minimal
competency in CP by passing a certi-
fication exam that includes some
questions concerning CP. (Corrosion
professionals who are not CTIs but
want to test tanks can obtain separate
cathodic protection tester certifica-
tion.) CTIs must periodically attend
With ourCP data suspect, our CP
testing requirements suspect, and
, ourCP compliance rate unknown,
we decided it was time to stop the
madness and take the pulse of our
] CP tanks and the way in which we
assured compliance.
I
industry-sponsored refresher semi-
nars on CP testing and troubleshoot-
ing as a part of maintaining their
certification.
For the past six years, the Maine
Department of Environmental Pro-
tection (DEP) has mailed annual CP
test reminders to tank owners. This
mailing includes a log sheet to help
remind tank owners that records of
their CP test results must be kept on
file for a minimum of three years.
Because tank owners are not required
to submit the results of this monitor-
ing to DEP, little data has been avail-
able to the agency on how the CP
systems or the storage tanks were far-
ing. However, as the tank owners got
around to contacting the CTIs and
having their CP systems tested, the
DEP began to see some problematic
trends.
Stop the Madness
For years we have grappled with a
number of issues associated with
cathodically protected tanks—conti-
nuity problems with leak detection
devices and electrical conduits; CTIs
looking all over the site for that elu-
sive passing reading; and even plain
old falsification of CP readings.
Finding a qualified and inter-
ested contractor has become a rarity.
Many times the CTIs just aren't inter-
ested in getting involved with in-
depth troubleshooting for a CP
problem (or the owners aren't willing
to pay for the work), or they don't
feel that they have the expertise to
properly troubleshoot failing sys-
tems. Added to this is our suspicion
that a large number of tank owners,
especially "consumptive use" tank
owners, have never had their tanks
tested.
With our CP data suspect, our CP
testing requirements suspect, and our
CP compliance rate unknown, we
decided it was time to stop the mad-
ness and take the pulse of our CP
tanks and the way in which we
assured compliance. We hired an
engineering consulting firm to test a
sample population of CP tanks in the
state.
-------
LUSTLine Bulletin 37
We set out to answer the follow-
ing questions:
• What is the compliance rate for
the annual CP testing require-
ment?
• Are our current test procedures
adequate to determine the CP sta-
tus of these tanks?
• Are any categories of tanks (e.g.,
size, age, manufacturer) more
prone to CP failure than others?
• Should the state's annual CP mon-
itoring procedure be modified to
improve its effectiveness?
The Methodology
From a practical point of view—
travel, logistics, cost—we decided
that testing 75 randomly selected
sites would be "doable" in a single
field season. As it turns out, the study
involved a total of 134 tank tests at 73
facilities. In terms of tank types, we
had 68% motor fuel, 30% fuel oil, and
2% new/used oil. Because most of
these facilities did not have cathodi-
cally protected steel piping, the study
was limited to CP tanks.
Our current regulations allow for
a single-point CP reading. For the
purpose of the study, however, we
decided to evaluate the tanks using a
multiple measurement protocol—
taking a reading along the top of the
tank at the middle and both ends.
This method would provide a better
measurement of the protective cur-
rent around the whole tank and
thereby address dead spots in the CP
current.
Past industry practice has been to
take a single measurement in the
middle of the tank over the center-
line. This location is considered the
most conservative because it is
equidistant from the anodes on the
end of the tank and thus the farthest
from their protective current. How-
ever, recent information from trade
journals and the National Association
of Corrosion Engineers (NACE) sug-
gests that multiple readings are a
more prudent way of determining
the adequacy of CP readings.
Multiple readings meant that our
consultant had to find additional
access to the soil over the tank. At
times, small holes (V6-inch diameter)
would have to be drilled in pavement
and concrete to access the soil (using
a thin "pencil" reference electrode).
We've heard stories about con-
tractors in other states, who when
faced with the soil access problem,
simply take a reading through con-
crete over the tank. Readings through
the concrete pad, rather than the soil,
almost always gives a false reading in
favor of passing the tank.
The Results
• Of the 134 tanks tested, 78 tanks
(58%) met the study criterion of
three readings; 17 additional tanks
(13%) met the less stringent DEP
criterion of one passing reading.
Thirty-nine tanks (29%) did not
meet any criterion for cathodic
protection.
• Using DEP's single-reading crite-
rion, CTIs passed 91% of the tanks
they tested. Using the same crite-
rion, the pass rate for the study
was only 71%.
• Many of the manufacturers of the
tanks tested during the study
were unknown, so no relationship
could be drawn between CP per-
formance and manufacturer.
• There was no significant relation-
ship between the age of the tank
and cathodic protection status.
• Only 44% of the tanks that passed
the study criterion were 6,000 gal-
lons or greater; 73% of tanks less
than 6,000 gallons passed the
study criterion.
• Limited electrical continuity test-
ing was performed on 42 failing
tanks. Thirteen (31%) of these
tanks had continuity problems.
• As far as compliance is concerned,
20 (27%) tanks had no CP testing
records, 14 (19%) had one year of
records, 24 (33%) had two years of
records, and only 15 (21%) had
the required three years of CP
records.
What to Do?
Our study made it clear that more
effort is needed to ensure compliance
with the annual CP test requirement.
One way we could do this would
be to make successful CP testing
(as well as the annual leak
detection spill and overfill pre-
vention testing) a condition for
receiving fuel. We currently
have a bill in the legislature
to address this. We'll see
how far that goes.
Regarding testing
requirements, we agree
with the study recom-
mendations that the three
tests over the top of the
tank (one reading on each end
and one in the middle) be
incorporated into our regula-
tions. The next step would be
to also include specific
requirements that spell out
the corrective actions and
timetable for repair of tanks
that have failed the CP test.
Regarding CP testers, the report
recommends that those still inter-
ested in dealing with CP tanks go
through a separate certification
process with more rigorous training
on testing, troubleshooting, and
repairing CP systems. Training
should be hands on.
One of our greatest concerns is
what to do about the 29% CP systems
lurking out there that are likely to fail
the test. Some CP systems may be
fixed easily by adding additional
anodes (see STI publication #R972-
98), but others may require the instal-
lation of an impressed current system
to protect the tanks.
• continued on page 12
-_
-------
LUSTLine Bulletin 37
• Maine's CP Tanks...
continued from page 11
Because the price tag for an
impressed current system, could run
up to $7,000, a financial package
should be developed to assist mom
and pop businesses faced with the
sticker shock. We have already pro-
posed a change to our statute that
would allow the Finance Authority of
Maine to make such loans for CP as
well as leak detection, spill, and over-
fill repairs and retrofits.
Finally, the study recommends
that we undertake a long-term study
of CP tanks that are removed to per-
form, in essence, a tank autopsy.
With more and more CP tanks being
removed this could prove to be an
interesting study. The implementa-
tion of this recommendation is still
uncertain because of the logistical
concerns.
What Did We Learn?
Our CP study provided us with the
basis for making some key improve-
ments in how we regulate and
enforce our CP tanks. In a nutshell,
this is what we learned:
• We need to tighten up compliance
so that all CP tanks are tested rou-
tinely.
• We need to tighten up our testing
protocol so that we can rely on the
testing data.
• We need to teach CTIs more
about CP testing, especially trou-
bleshooting techniques, so that
they can be more helpful to tank
owners with failing tanks.
• Galvanic CP systems are rela-
tively simple. If tank owners and
CP testers are having trouble with
these systems, we can only wince
at the thought of them having to
deal with impressed current sys-
tems, which may become more
common as the galvanic systems
are repaired. •
I Tlte complete report can be found
1 on our homepage at
•- http://janus.state.me.us/dep/
, rwm/publications/cpreporthtm.
Getting a Hand on Facility
Compliance Inspections
by Russ Erauksieck and David Bernstein
Without leaving his or her
desk, the typical inspector
is surrounded by informa-
tion—tank registration applications,
closure reports, site assessments,
information request responses, spill
reports, and (sometimes) self-audits.
However, even with all this informa-
tion available, the best single mea-
sure of the compliance status of a
facility is a comprehensive, on-site
inspection by a trained inspector. An
on-site inspection is the best way to
determine if the correct equipment is
installed, operational, and used
properly by the operator.
Yet, there are problems with site
inspections:
• They are resource intensive and
time-consuming.
• The inspector must travel to the
site, document site information,
and determine whether the tanks
and associated equipment are in
compliance with the require-
ments.
• The information gained from the
inspection must be taken back to
the office where an inspection
report is generated from the raw
data.
• After the inspection is completed
and the report written, the inspec-
tor files the report with all of the
other reports and tank-related
documents—where it typically
remains underutilized and some-
times forgotten or lost.
• Any effort to use inspection data
beyond writing up the. report
relies on the tedious entry of the
information into a database sys-
tem—a task that wastes valuable
inspector or support staff time
and is subject to transcription
errors. Meanwhile, the ability to
analyze the data gathered from all
those inspections might have pro-
vided the program as a whole
with meaningful insight. It might
have helped program managers
track the progress of the program,
identify trends and areas of con-
cern, and determine where addi-
tional resources are needed in
terms of additional inspections or
outreach efforts.
An Easier Way
While little can be done to improve
the resource-intensive and time-con-
suming nature of visiting a site to
perform an inspection, overall
improvements in efficiency are possi-
ble. With this goal in mind, the New
York State Department of Environ-
mental Conservation (NYSDEC) in
conjunction with EPA Region 2 has
initiated a project that will enable
inspectors to collect inspection infor-
mation on-site using a hand-held
computer and transfer this informa-
tion into a statewide database. This
technology will provide managers
and staff with up-to-date compliance
statistics with a minimum of effort
after the initial inspection.
The concept of using a computer
for inspections is not new. UST
inspectors in a number of states use
computers in the field, most often
laptops. There are, however, two
major problems with this approach:
(a) cost—a quality system can cost
thousands of dollars for the equip-
ment, software, and programming,
and (b) true portability—it is easy to
carry a laptop computer around in a
carrying case; it is close to impossible
to walk around and enter data into
the laptop during an inspection.
The early hand-held computers
were no better. Early handwriting
recognition software did not work
well, and the operating systems and
software were not sophisticated
enough to handle the detail required
of a compliance inspection.
The introduction of the Palm
Computing Platform changed all
that. Finally, a system was developed
that combined low cost, system sta-
bility, a usable handwriting recogni-
tion system, and development
software capable of handling the
12
-------
LUSTLine Bulletin 37
demands of a compliance inspection.
With the NYSDEC project, we set
out to streamline the inspection
process in the following ways:
• Program a standard inspection
form into the hand-held com-
puter.
• Prior to going into the field,
enable the inspector to download
the basic facility information from
the state database and use the
hand-held computer to collect and
enter the on-site inspection infor-
mation.
• Once back in the office, upload the
inspection information to the
database, where it is analyzed for
violations by the computer.
• Produce a computer-generated
draft inspection report (notice of
violation) that opens on the inspec-
tor's desktop computer, where it
can be edited and finalized.
The Long- and Short-Term
Benefits
NYSDEC's inspection streamlining
project has been under development
over the past several years. Although
the hand-held computers have not
yet been used in the field, we have
already realized or will soon realize
many benefits associated with this
project:
• Standardization
We developed and implemented a
standard inspection checklist. As a
prelude to implementing the
hand-held computer systems, all
inspectors were instructed to use
the same form and ask the same
questions at each inspection. Pre-
viously, inspectors used different
inspection forms and asked differ-
ent questions.
• Trend Analysis
All of NYSDEC's inspection infor-
mation is collected into a single
database. This allows the state to
analyze the data for trends, such
as outdated or inappropriate
release detection methods or
types of equipment used. Once a
particular trend is noted, we can
then devise a plan to address that
particular issue.
• Compliance Analysis
Consistent information allows us
to look at our database and assess
overall compliance with our
requirements. This is especially
important in light of recent
changes to EPA Performance
Measures, requiring states to
report operational compliance
with the upgrading and leak
detection requirements. The level
of detail in our improved database
allows us to show compliance
rates for upgraded versus new
tanks, or ATG versus interstitial
monitoring systems.
• Data Correction
When inspectors visit sites, they
often discover that the owner reg-
istered the tank system using
incorrect information or has modi-
fied the facility and failed to
update the registration informa-
tion. Using a hand-held computer,
inspectors can make changes to
the registration information in the
field. This information is uploaded
to the desktop computer, the facil-
ity is flagged as having incorrect
registration information, and a let-
ter is generated and sent to the
owner requesting that an updated
registration form with corrected
information be submitted.
• Task Automation
Our new system allows us to gen-
erate and automatically track
inspection reports, notices of vio-
lation, other letters, and pre-
designed database queries. This
automation allows the inspector
to spend less time at the desk and
more time in the field conducting
inspections.
On the Horizon
There are additional enhancements
to our system that are still being con-
sidered for the future. These include:
• Ask more detailed questions dur-
ing an inspection to gather model-
specific data. This can be done
through linked drop-down lists
designed so that data is gathered
with little impact on inspection
time. Information can also be
added to prompt the inspector on
what to look for during the
inspection (e.g., reference infor-
mation for all release detection
systems).
• Use hand-held computers to
download data off the Internet.
With registration
and inspection databases avail-
able on the Internet, an inspector
can download information while
in the field. This gives the inspec-
tor flexibility to identify a facility
for inspection in the field, down-
load current registration informa-
tion and previous inspection
information for the facility, and
perform the inspection. Informa-
tion from other databases can also
be downloaded (if available) and
uploaded from the field so that
the inspection report is waiting in
the office upon the inspector's
return.
• Use this application as a spill
response and remediation staff
tool. Staff can be in the field, be
notified of a spill, and download
the information on the site where
the spill has occurred. Information
on the facility, such as registration
and inspection information, can all
be useful during a spill event. •
The Palm Pilot program has been
developed in New York by the DEC
and U.S. EPA Region 2. The program
will be field tested this spring. Once it
is operational in New York, a federal
work group has been established to
develop the program for use in enforc-
ing federal UST regulations. For more
information on this project, contact
Russ Brauksieck, NYSDEC, at
rxbrauks@gw.dec.state.ny.us or
David Bernstein, EPA Region 2, at
bernstein.david@epamail.epa.gov.
13
-------
LUSTLine Bulletin 37
Leak Prevention
The Missing Link Can Be Found in Appendix D
New California Document Highlights
the UST-LUST Connection
by Shahla Farahnak
\ I Ihe missing link is finally
I noticed!" That thought
JL crossed my mind when I
was asked to prepare Appendix D of
California's "Guidelines for Investi-
gation and Cleanup of MTBE and
Other Ether-Based Oxygenates." The
principal author of this document,
Kevin Graves, Senior Engineer with
the State Water Resources Control
Board, explained to me that the pur-
pose of the guidelines was to assist
managers and staff at state and local
regulatory agencies with the task of
overseeing the investigation and
cleanup of sites where there have
been releases of MTBE-blended fuel.
We talked about how an appendix
with the title of "Finding Leaks in
Tank Systems" would be an appro-
priate element of this
document — and the
work began. Many
thanks to those, espe-
cially Marcel Moreau,
who reviewed it and
provided helpful com-
ments.
What do I mean by
"missing link"? I mean the communi-
cation and team effort between those
who work on the leak prevention
side of the UST programs and those
responsible for the corrective action
oversight. Traditionally, these two
groups, whether working for the reg-
ulatory agencies or the consulting
world, rarely get together and evalu-
ate contaminated UST sites. In Cali-
fornia, with the discovery of MTBE at
new and upgraded UST sites, we
have been forced to attempt to bridge
that gap. Although the thought of
doing so may elicit groans from both
camps, the time for using teamwork
in site investigation is long past due.
A Game of Clue
After all, isn't one of the key elements
of site investigation finding the
"guilty"? Yes, if s a game of "Clue"!
There are many clues at an operating
UST site that could lead to the source
of a release. While these clues may
not be apparent to the corrective
action experts, they would be easily
recognized by those intimately
involved with UST system design
and leak detectionjaquipment opera-
tional details.
The purpose of "Finding Leaks in
Tank Systems" is to identify potential
activities that can be performed at
suspected release sites to confirm and
determine the source of a suspected
release from an UST system. The
appropriate level of effort for this
task is interrelated with the results of
groundwater monitoring, extent and
type of the release, and other site-spe-
cific characteristics.
This investigation may be an iter-
ative process, and it is important that
all data and findings be maintained
and properly documented. A team of
cleanup and leak prevention staff
must make a unified effort to oversee
activities and analyze the findings.
The subsurface contaminant distribu-
tion may point to a leak source (e.g.,
relatively clean tank pit but high con-
taminant levels around a specific dis-
penser or near specific piping joints).
Keep in mind, this document is
not a flow chart, there is no start and
end button. It is all inter-linked with
the site investigation information you
have gathered, the extent of the prob-
lem at the site, and the time factor. At
some sites it may make sense to move
quickly and perform an external full-
system evaluation -for
vapor and liquid releases;
at other sites you may
want to start with the
basics and work your
way toward a full-system
evaluation, if needed.
The theme here is
to be proactive. Don't just
continue to track quarterly ground-
water monitoring data and wonder
where the elusive "MTBE" will
appear next, or hope that its concen-
trations will start going down at some
point in time. Get in there and work
with the UST experts to either rule-in
or rule-out the existing UST system at
the site of the source.
Finding Leaks in Tank Systems (Appendix D)
I. Preliminary Site Evaluation -
The local inspector may perform
these activities. All activities and
findings should be documented item
by item.
A. Conduct a visual evaluation and
interviews.
• Check surfaces around UST sys-
14
tems for any visible signs of spills.
Evaluate and document the condi-
tion of the concrete and asphalt—
look for cracks, stains, etc. Pay
particular attention to the area
around fill pipes and dispenser
islands.
• Interview the operators with
respect to unusual operating con-
ditions, known spills and leaks,
inventory reconciliation, etc.
• Check monitoring equipment
(e.g., all sensors, line leak detec-
tors, ATGs) control panel for pres-
ence of alarm lights, trouble lights,
and power lights. Power lights
should be on; trouble and alarm
lights should be off.
-------
LUSTLine Bulletin 37
B. Review records.
• Review records of any water
pumped out from the tanks.
• Review records of product or
water removed from the sumps,
spill containment boxes, and dis-
penser containment boxes.
• Review records of product spills
by customers filling their gas tanks
or gasoline delivery trucks and the
action taken to clean up the spill.
• Review inventory records and the
results of any Statistical Inventory
Reconciliation (SIR) test reports. In
the SIR reports, pay attention to
the product-gain and inconclusive
test results. A quick method of
checking inventory records is to
count the number of positive and
negative daily variances in a
month. The number of positives
and the number of negatives
should be almost equal (e.g., in 30
days of recording there should be
15 positives and 15 negatives; 18 of
one and 12 of the other is suspi-
cious; 10 of one and 20 of the other
indicates a problem of some kind).
• Review any past tank and piping
tests performed at the site. Verify
that tests were conducted prop-
erly. Review the test results closely
to determine if the tester did any
system "fixes" (loose valves and
connections and loose fill pipes) to
make the test pass. Determine
what follow-up action was taken
at the site for reported fail results.
• Check the spill containment box
for the presence or indication of
product spills from product deliv-
eries.
• Check all sumps for the presence
of product, corrosion, or indication
of product releases.
• Check under-dispensing piping
for any visible signs of product
releases (e.g., drips, tarnished pip-
ing). This check should be done
both while the dispenser is idle
and during dispensing.
• Dipstick the tank to check for
water and product, allowing for at
least a 24- to 48-hour time period.
Use the tank chart and tank instal-
lation information to determine
the rate of any losses or gains from
the tank (same concept as manual
tank gauging). The tank should be
locked up and not used during
this time. Note tKat the tempera-
ture should be stable and deliver-
ies should not be allowed for a few
days prior to the start of the test.
The longer the test the better. A
test should run for 48 hours unless
the tank size is small. This test may
not be appropriate if it signifi-
cantly interferes with the daily
operation of the facility.
What do I mean by "missing link"?
I mean the communication and team
"--:- effort between those who work on
leak prevention side of the UST
^programs and those responsible for
IF7- the corrective action oversight.
-. . • -..* J
• To the extent possible, document
the type, model, and brand of all
major UST system components.
This information should be
reviewed and compared with any
data on manufacturer recalls or
any other frequently reported
manufacturer defects.
II. Detailed Site Evaluation and
Data Collection - A qualified and
authorized contractor should per-
form these activities with oversight of
the local inspector. All hands-on
work on equipment must be per-
formed in accordance with the manu-
facturer's instructions and test
procedures, findings should be docu-
mented in detail, and all system
reports printed.
A. Check for potential overfill events.
• Check the overfill prevention
device and report whether it is
functional.
• If the tank is equipped with an
automatic tank gauging (ATG)
system, have the contractor check
the system for overfill alarms,
review product delivery records,
and cross check deliveries with
ATG system inventory records for
consistency to verify proper deliv-
eries.
• If possible, contact the company
that delivers product to the facility
to find out if there were any over-
fills (this may be just a nice try!).
The ATG may also have a record
of overfills. If delivery invoices are
available, check to see if they con-
tain before and after stick read-
ings. Look for after delivery
readings that are above the tank 95
percent level. Document results
and file.
B. Check functional equipment.
Verify that leak detection equipment
is functional before reviewing past
test reports and using the equipment
to test the UST system components.
All work must be performed in
accordance with the manufacturer's
instructions provided in the equip-
ment maintenance manuals.
• Print and check system set up for
any programming errors.
• Verify that all monitoring equip-
ment and sensors are functional by
testing all sensors.
• Review the system diagnostic
information to identify any system
problems.
• Perform a quantitative test on line
leak detectors (mechanical and
electronic) to determine that they
can detect a leak of at least 3 gal-
lons per hour. This is a test where
the contractor simulates an artifi-
cial leak and the system response
to that leak rate is evaluated
and compared with the system
requirements and the setup infor-
mation.
C. Check alarm history, system failure
history, and leak test history reports.
• Review the history of system
alarms including system func-
tional alarms.
• If the tank is equipped with an
ATG, review the records of in-tank
water and the history of high
water alarms.
• Review the history of leak tests
performed by continuous in-tank
leak detection systems (CITLDS),
ATG systems, and electronic line
leak detectors. Analyze the test
results closely by comparing the
test information with the test
method specifications listed in the
National Work Group on Leak
Detection Evaluation's "List of
Leak Detection Evaluations for
UST Systems" (NWGLDE's List).
• continued on page 16
—
-------
LUSTLine Bulletin 37
m UST-LUST Connection...
continued from page 15
D. Test all secondary containment.
• Perform a hydrostatic test of the
spill containment box. (This is a
very crude test method that is cur-
rently only performed at the time
of installation.) The containment
box is filled with water, then the
water level is marked or measured
and checked again in 24 hours to
verify that the box is liquid-tight.
Document the results.
• Perform a hydrostatic test of all
sumps (see above) and document
the results. Also verify that all sen-
sors are functional.
• Check all piping penetrations and
fittings for proper seal, verify sec-
ondary containment piping termi-
nates in the sump, and verify that
any potential releases from the pri-
mary piping into the secondary
piping will drain into the sump
(i.e., see that the reducer that was
used to isolate the secondary pip-
ing during the installation tight-
ness test has been removed or if a
drain port was installed, that the
outlet is not plugged).
• Conduct a tightness test on the
secondary piping and the intersti-
tial space of the tank using an
approved test method.
• If there is dispenser containment
present, perform a hydrostatic test
(see above) and verify that the
leak-sensing mechanism is func-
tional.
E. Activate leak detection tests using
on-site equipment.
• Put the ATG system in a leak test
mode (preferably 0.1 gph mode if
available) and review the test
result. Note that there should be
no product dispensing from the
tank until the test is completed.
Evaluate the test results, not just
for pass/fail. Review the mea-
sured leak rates and, if needed,
extrapolate the number to a full-
tank leak rate to determine if there
may be a release from the tank.
Also, make sure that in-tank water
is recorded before and after the
test and look for water ingress
during the test.
• Activate the mechanical line leak
detector test mode (3gph) and
16
electronic line leak detector test
modes (3.0 gph, 0.1 gph, and
0.2 gph), review the test results,
and make note of any alarms or
slow-flow or product pump shut-
downs. Note that there should be
no product dispensed from the
piping system until the test is com-
pleted.
III. Tank and Line Tests - These
tests must be performed by a licensed
tester.
A. Have the product lines tightness
tested by a licensed tank tester, using
an approved test method.
Be present during the test if possible.
Compare the test information with
the test method specifications in the
NWGLDE List. Make sure the tester
performs the test before doing any
repairs or system fixes. If the test
fails, any fixes should be done before
a second test is conducted. All activi-
ties, including any repairs need to be
documented and reviewed.
B. Have the ullage space of the tank
tightness tested by a licensed tank
tester, using an approved test method.
C. Have the product-filled portion of the
tank tested, using an approved test
method.
Do not require the addition of any
product to the tank for this test. In the
event that the tank is leaking, the con-
tamination may get worse if more
product is added to the tank. Evaluate
the test results, not just for pass/fail.
Review the measured leak rates and if
needed, extrapolate the number to a
full-tank leak rate to determine if
there may be a release from the tank.
Also make sure that in-tank water is
recorded before and after the test and
look for water ingress.
IV. External Full-System Evalu-
ation for Vapor and Liquid
Releases - Perform an external eval-
uation. •
Shahla Farahnak, P.E., is a Senior
Engineer with the California SWRCB.
She can be contacted at
farahnas@cwp.swrcb.ca.gov. The
read the entire "Guidelines for Investi-
gation and Cleanup ofMTBE and
Other Ether-Based Oxygenates,"go to
www.swrcb.ca.gov and click on the
MTBE link.
A note from Dennis Rounds,
Executive Director of the South Dakota
Petroleum Release Compensation Fund.
Thank you for the many terrific
articles in the November 2000
issue of LUSTLine. In particu-
lar, I appreciated the timely GIS arti-
cle "The Future is Coming." It
contains good, basic information on
GIS and many examples of its appli-
cations. The author, Ann Carpenter,
also addressed many of the up-front
issues that managers should be
aware of when considering the use of
GIS in environmental applications.
Those readers of LUSTLine who
are interested in GIS may want to
know that ASTM subcommittee
E50.01 has initiated action on the
development of a new guide for the
use of GIS in environmental applica-
tions. The purpose of this guide will
be to address the crucial factors that
should be considered when develop-
ing, constructing, and maintaining a
GIS for environmental applications.
It may also provide guidance for
determining the applicability of GIS
for an environmental project.
ASTM is the world's largest
voluntary consensus standards orga-
nization. Anyone interested in work-
ing on the development of this new
GIS guide or other ASTM standards
can contact me for information. •
Dennis can be reached at (605) 773-
3769, or dennis.rounds@state.sd.us.
Washington UST Owners
Urged to Check Tanks
After Earthquake
The Washington Department of
Ecology wasted no time getting
information out to tank owners after
the recent earthquake in the Seattle
area. Ecology prepared a one-page
inspection checklist for owners of
underground tanks. It is available
over the Internet at
http://www.ecy. wa.gov/programs/
top/cleanup.html,
Check it out, because...
ya never know.
•
-------
LUSTLine'Bulletin 37
Oxygenates
A Circle Vicious
What Do We Know About the
Other Oxygenates?
by Patricia Ellis
On January 18, 2000, then-Act-
ing Director of EPA's Office
of Underground Storage
Tanks (OUST) Sammy Ng wrote to
regional and state UST/LUST pro-
gram managers urging them to
"begin monitoring and reporting of
MTBE and other oxygenates in
groundwater at all UST release sites
nationwide." He also recommended
that if MTBE or other oxygenates are
detected during monitoring activi-
ties, that states take "immediate and
aggressive remeoiaT"'"• a£tiffrCi to!
address the contamin^Mn."yL^^ I
Ng went on to state-that, .while;
MTBE has received most of the pub-
licity recently, it is by no means the
only chemical of concern for which
states should be monitoring and
reporting. Tert-butyl alcohol (TEA)
can be both a degradation product
and a fuel additive in its own right. It
is also potentially more toxic than
MTBE. States were urged to consider
assessing for other oxygenates, such
as tert-amyl methyl ether (TAME),
diisopropyl ether (DIPE), ethyl-tert-
butyl ether (ETBE), ethanol, and
methanol.
According to results of the
NEIWPCC survey conducted in
August 2000, most states were not
assessing for the presence of fuel oxy-
genates, other than'MTB"~~
require sampling and
MTBE in groundwater
and 29 require such sampling in soil).
Maybe in the time since the NEIW-
PCC survey was completed, this pic-
ture has changed. Maybe the
majority of states are now looking for
all of the oxygenates, as OUST
strongly urged. Riiiight, and if you
believe that, I've got a nice bridge to
sell you. Kudos to the 4 or 5 states
that are looking for most of the oxy-
genates most of the time.
I'd like to propose that we all
start paying a bit more attention to
the other oxygenates, because as you
will read, they may already be pre-
sent at your friendly neighborhood
LUST site. And, because I get this
uncomfortable feeling that history is
threatening to repeat itself.
A recent abstract by Andrew
Gray and Anthony Brown for the
National Ground Water Association
Petroleum Conference in Anaheim,
California neatly sums it up: "Many
within the petroleum industry have
suggested that it was overemphasis
on benzene in the 1980s and early
y|t paused them to neglect
''^appears that we may not
tiedjfrom this oversight, and
the pattern may be repeating itself.
Where there is now an emphasis on
MTBE, in many places they are not
looking for or evaluating the poten-
tial impact from the other fuel oxy-
genates." -g-~a ffr&l
Sfe^% Jifeil w
So lef s take a glance atWhafv^e*
know or don't know abouft tbi'o|her
oxygenates within the cotitexts~of
health effects, risk-based corrective
action (RBCA), natural attenuation,
remediation and treatment, and ana-
lytical techniques. Since we do know
a bit more about ethanol than TBA,
ETBE, and TAME, 111 provide a brief
synopsis on what we know about
that substance.
a 1996 study by the
gtsSnstitute, little or no
information is available for ETBE,
TAME, and DIPE; not enough infor-
mation is available on the toxicity of
ETBE and TAME to evaluate their
potential health effects, but more
research is being planned; no infor-
mation is available on the toxicity of
DIPE. The report recommended that
a comprehensive set of studies be
undertaken to determine levels of
personal exposure to oxygenates
using standardized protocols.
"Although more information on
MTBE is needed," states the report,
"the need is particularly great for
assessing exposure to ethanol, TEA,
and TAME, because these com-
pounds are currently in use (or may
be soon) and the resulting exposures
have not been adequately assessed."
MTBE has been described as one
of the most studied chemicals on
earth, yet many studies have con-
cluded that there is "not sufficient
evidence" to declare it a human car-
cinogen even though animal studies
show it to be a probable carcinogen.
(Where will we be with some of the
less-studied chemicals that occur in
gasoline?)
Health effect studies are cur-
rently underway by industry and
EPA to understand more fully the
ted with
with and with-
lt oggep%.th*ough the major-
ity of~the researcn is focused on
inhalation-related health effects, the
results should help us better under-
stand the human health risks associ-
ated with exposure to fuels by any
route.
TEA is a major metabolite of
MTBE, regardless of the route of
exposure. From a toxicological point
of view, exposure to TBA elicits both
noncancer and systemic toxic
responses, as well as evidence of car-
cinogenicity. Animal testing of TBA
in drinking water produced carcino-
genic effects at high levels of expo-
sure. Additionally, formaldehyde,
also a metabolite of MTBE, is a respi-
ratory irritant at high levels of human
exposure and is currently considered
by EPA to be a probable carcinogen
(Class Bl) by the inhalation route
and, with less certainty, via ingestion
(Blue Ribbon Panel Report, 1999).
Studies of groundwater from the
City of Santa Monica's Charnock and
Arcadia well fields in California
• continued on page 18
17
-------
LUSTLine Bulletin 37
• Other Oxygenates...
continued from page 17
revealed the presence of four non-
MTBE fuel oxygenates—TEA, ETBE,
TAME, and DIPE (Gray and Brown,
2000). The California Department of
Health Services (CDHS) is particu-
larly interested in TBA because of its
increased mobility in groundwater
and the difficulties in treating the
chemical.
CDHS has established a Drinking
Water Action Level of 12 pgfT-. for
TBA. (Health-based advisory levels
are established by CDHS for chemi-
cals for which primary MCLs have
not been adopted.) In September
1997, New Jersey issued an Interim
Specific Groundwater Criterion of
100 /
-------
LUSTLine Bulletin 37
At tike sites, tine concentrations
and frequency of TEA occurrence in
groundwater were comparable to
those for MTBE. There was little dif-
ference in the relative concentrations
of TEA and MTBE in groundwater
between the sites where MTBE
sites
concentraMn's
alone may=nWtJ
of in-situ biodegradation potential.
TBA was detected in groundwa-
ter samples from all six states and
DC. The highest TBA concentration
was 223,000 ^g/L; 10 samples ex-
ceeded 50,000 pg/L; and 29 samples
were in the 10,000-50,000 pg/L range.
The MTBE:TBA ratio was nearly 1:1.
With numbers as high as these, it
seems fairly obvious to me that we
should always be looking for TBA in
our groundwater samples, even
when we aren't trying to determine
whether MTBE is degrading to TBA.
It is doubtful that many of these
sites have been investigated thor-
oughly in a three-dimensional man-
ner. The statistical method used
required that there be at least five
monitoring wells located along the
centerline of the plume. No mention
was made as to whether any of the
sites had been characterized using
any form of multilevel groundwater
sampling that would detect whether
any of the plumes were "diving."
A similar problem exists with
both the California, Texas, and
Florida MTBE plume studies £T
pel, Beckenbach, and Halden, l\
Mace, 1998; and Integrated Scij'
and Technology, 1999). Plume
lengths were determined (to a spe-
cific concentration of MTBE) based
on monitoring well data. Monitoring
wells for these sites were likely
screened in the traditional manner
for gasoline sites, at the top of the
water table. It is unlikely that moni-
toring included multilevel sampling
designed to detect a "diving" plume,
therefore plume lengths measured
may not represent the "true" plume
lengths for the sites. What effects
would this additional information
have on the findings of the natural
attenuation study?
A recent study by Kramer and
Douthit (2000) was performed to
determine whether the presence and
widespread occurrence of TBA in
groundwater could be explained as a
degradation product of MTBE, or
whether TBA was originally present
in significant quantities in gasoline as
an impurity or as an oxygenate. Liter-
ature reports (e.g., Salanitro, 2000)
indicate that natural MTBE biodegra-
dation is a relatively slow process.
^^^The study involved mixing
^experiments in the laboratory, where
gasoline samples from five New Jer-
-sey* gasoline stations were mixed
with water to determine the types
and concentrations of oxygenates
detectable. The solubility of each of
the oxygenates is related to the pure
compound solubility in water and
the mole fraction of the oxygenate in
the mixture.
All gasoline/water mixture sam-
ples showed TBA in the water phase
at approximately 83% of the dis-
solved MTBE cofg
average MTBE con^ptratiorTln tl
water samples wagI,63g!oQ
and the average TBA concentration
was 1,356,000 /ig/L. In addition, all
samples contained methanol in con-
centrations ranging from 26,000 to
51,000 jig/L. One sample contained
17,300 ^g/L ethanol, and the average
TAME concentration was 4,370 ?fg/L
(one sample contained 153,000 ^fg/L
TAME). DIPE, ETBE, and TBA were
not detected in any of the five sam-
ples. Total BTEX concentrations were
about 0.75% of the total oxygenate
concentration.
Kramer and Douthit caution that
the wide occurrence of TBA at similar
indicates
j l^aken in draw-
Ltipotential bio-
logical decay under field conditions
using TBA as an indicator. There are
significant differences in the solubil-
ity of MTBE and TBA. The solubility
of pure MTBE in water is approxi-
mately 48,000 pg/L; the solubility of
MTBE at 11% by volume in gasoline
is approximately 5,000 ppm, while
TBA is totally miscible in water. A
relatively small percentage of TBA in
MTBE could result in a significant
concentration in the water-soluble
phase.
Treatment/Remediation
Systems
Before you can remediate groundwa-
ter contamination, you need to fully
delineate the plume—area, analytes
present, concentrations, and varia-
tions with depth. Characterization of
a site includes both vertical and hori-
zontal delineation. Because of the
tendency of MTBE to move deeper
into the aquifer in some environmen-
tal settings, you must also focus on
vying its three-dimensional
tarjjjep'stics, searching vertically
" 'x&Pr&ence through direct-push
Ba'm'purcg,- clustered short-screen
monitoring wells, and the like.
When you think you are at the
end of your plume, you should look
deeper, to make sure that it isn't
sneaking below the bottom of your
well screen. Too often, I fear, we set
about characterizing our LUST sites
wearing blinders, hoping not to dis-
cover too much.
After all, ignorance is Bliss!
Harmful by-products created during
one of the oxidation processes? Not
to worry. Didn't even know about
the possibility! And let's face it, the
more we find, the greater the cleanup
cost.
Table 2 summarizes some
groundwater monitoring data from
one of my LUST sites in Delaware.
The three sampling locations are
along the centerline of the plume.
Several months prior to these analy-
• continued on page 20
|£liim GROUNDWATER MONITORING DATA FROM A LUST SITE IN DELAWARE
(Concentrations in ug/L)
Contaminant
Benzene
Toluene
Elhylbenzene
Xylenes
MTBE
TAME
TBA
Tank Field
330
472
1,870
2,720
46,100
10,900
29,500
30 Feet
Downgradient
1,150
6,070
1,950
14,600
3,120
51,500
782
100 Feet
Downgradient
<5
<5
<5
11
650
31
2,420 \
19
-------
LUSTLine Bulletin 37
• Other Oxygenates...
contitmedfrom page 19
ses, the MTBE concentration in the
tank field was 310,000 /
-------
LUSTLine Bulletin 37
Sorption characteristics influence
the movement of a compound in
groundwater and the effectiveness of
water treatment using carbon
adsorption. The low organic carbon
partition coefficient (Koc) for ethanol
indicates that it will sorb poorly to
organic carbon, therefore ethanol is
not expected to be significantly
retarded as groundwater moves
downgradient, and carbon is not
expected to perform well as a treat-
ment technology.
Ethanol appears to biodegrade
readily under most aerobic and
anaerobic conditions. However,
because it is preferentially consumed
by microbes, the biodegradation of
BTEX compcjundsjiiayjse-inhjbti
properties ^rf%\@ knEgyi, a
should be p'ossible-to predict i
and transport properties and
response to various treatment tech-
nologies, there is a general lack of
ethanol monitoring data in the litera-
ture.
Ethanol groundwater monitoring
is scarce, at least in part, because
most regulatory agencies do not
require ethanol analysis. Further-
more, it appears that no state agen-
cies have as yet set concentration
limits for ethanol in groundwater or
drinking water.
Creek and Davidson (2000) could
not locate any ethanol remediation
sites. The extent of any current possi-
ble problem and cost associated with
cleanup are unknown.
The Blue Ribbon Panel recom-
mended the lifting of the oxygenate
mandate that_forces the use of an
will probably—be--the— drAxSlrLas to^
whether ethanol will take the place of
MTBE, or whether refineries will be
permitted to blend oxygenate-free
gasoline.
Is There a Lesson Here
Somewhere?
A recent article by Franklin and oth-
ers (2000) reminds us of some of the
ways that got us where we are
today—faced with a national MTBE
problem. They point out that policy
makers only belatedly realized the
environmental ramifications of in-
creased levels of MTBE in gasoline.
The policy process that led to MTBE's
predominance was flawed, since no
systematic attempt was made up
front to evaluate all possible implica-
tions of MTBE's widespread use.
- The policy process that led to
• MTBE's predominance was flawed,
|. since no systematic attempt was
f made up front to evaluate all
^possible implications of MTBE's
p- , widespread use.
I
The history of MTBE in the
United States illustrates several typi-
it problematic, features of envi-
Eental policy making. It reveals
scale of chemical usage
lifectly impacts environmental
effects. It highlights how institutional
factors constrain policy makers
through statutory mandates, regula-
tory agency organizational struc-
tures, and the strong influence
exerted by politics and economics
even in supposedly "technical"
debates.
Finally, tit
barriers to efclVe
technical corm|Mtfcatnjs
policy makers, fegulateamdt
special-interest groups, and the pub-
lic. Will we just be substituting
another chemical name for MTBE?
An article by Erdal and Goldstein
(2000) discusses lessons for environ-
mental policy that we should have
learned as a result of choosing MTBE
as a gasoline oxygenate. They identi-
14 government initiatives during
fe 10-year period from 1989 to 1999
which the potential adverse conse-
efuences of MTBE were considered,
and a nearly identical research
agenda was proposed. More research
is needed, not further reviews of
research already completed.
What are some of the lessons that
should have been learned from
MTBE?
• Research should precede rather
than follow environmental health
policy decisions.
• The extent of potential human and
environmental exposure should
be an important criterion in deter-
mining the amount of information
needed before making an environ-
mental policy decision.
• The boundaries between various
EPA program offices should be as
fluid as the boundaries between
the environmental media. Air,
water, and waste programs
should all be working hand-in-
hand.
• It is more difficult to remove a
chemical once it is in commerce
than it is to prevent its use. (The
Bush administration requested
that EPA's proposal to ban MTBE
under TSCA be withdrawn, at
least at the present time.)
• Replacing MTBE with other, less
well-studied oxygenates, such as
TAME or ethanol, is poor environ-
mental policy.
Those who remember the MTBE
story on CBS "60 Minutes" in January
2000 may remember this exchange
between EPA's Bob Perciasepe and
CBS:
CBS: Have there been studies done on
the health effects of MTBE in the
drinking water?
Perciasepe: Not enough. Not enough.
CBS: But any? I mean, have any been
_
irciasepe: "I'm not aware of any
jecific studies that have been done
on that."
CBS: "What are you doing about the
problem? Right now. I mean, what
has been done since this first memo
in 1987? What's been done?"
Perciasepe: "Not enough."
Will some future EPA official be
answering questions about the other
oxygenates the same way in a few
years? EPA's Blue Ribbon Panel
Report summarized impacts of
MTBE to ground and surface water
resources in the U.S. It also stated
that the body of information avail-
able to evaluate impacts of other
gasoline oxygenates on water re-
sources is significantly more limited.
It's time to start looking at the extent
of the problem. •
[NOTE: References for this article can be
found on page 23.]
Pat Ellis is a hydrologist with the
Delaware DNREC UST Branch and
was a member of EPA's Blue Ribbon
Panel. She can be reached at
pellis@dnrec.state.de.us.
21
-------
LUSTUne Bulletin 37
Oxygenates
Is MNA Appropriate for Remediating MTBE?
Discussion and Dialogue from the Petroleum Hydrocarbon
Conference, 2000
by Matt Small
Monitored natural attenua-
tion (MNA) has been recog-
nized as a remedy that can
effectively achieve remedial goals for
groundwater, within a reasonable
time frame at some petroleum
release sites. MNA relies solely on
naturally occurring physical, chemi-
cal, and biological processes to
reduce contaminant concentrations.
It has proven most effective at gaso-
line release sites where there is a low
potential for receptor impact and
chemical contaminants have low
mobility and are readily biode-
graded (e.g., benzene, toluene, ethyl-
benzene, and xylene (BTEX)).
However, at an increasing
number of gasoline release sites
groundwater is contaminated with
significant concentrations of methyl
tertiary butyl ether (MTBE). Because
MTBE is more mobile and less likely
to biodegrade than the BTEX com-
pounds, there may be a higher poten-
tial for receptor impacts.
The Question
So the question arises, "is MNA
appropriate for remediating MTBE?"
The National Research Council has
said that natural attenuation is a
proven technology for BTEX com-
pounds but that it is not well estab-
lished as a treatment for other
common groundwater contaminants
(NRC, 2000). The ASTM Standard
Guide for Remediation by Natural Atten-
uation specifically cautions against
applying natural attenuation for the
remediation of recalcitrant com-
pounds such as MTBE (ASTM, 1998).
The EPA policy directive on MNA
also cautions against application of
MNA to recalcitrant compounds
(EPA, 1999).
With all of these cautionary state-
ments, are there any situations or sce-
narios where natural attenuation
could be appropriate as a remedial
alternative for MTBE? This question
_
was discussed at the 2000 Petroleum
Hydrocarbon Conference in Ana-
heim, California. The discussion
included brief presentations by a
panel of UST regulators, scientists,
and oil company representatives, fol-
lowed by input from attendees.
The Discussion
The following ideas regarding crite-
ria for appropriate application of
MNA at MTBE release sites were put
forth during this discussion. These
criteria are a mix of state policy, sci-
entific investigations, and personal
opinions and should not be taken as a
coordinated approach or guidance
document, but rather as an ongoing
dialogue and brainstorming session
on this contentious issue.
Panel Presenters' Criteria for Potential
Use of MNA for MTBE:
• MNA may be applicable in some
situations when the MTBE content
in the gasoline is low, the source
mass is small, and the impacted
groundwater is not currently used
or planned for use in the future.
Use restrictions must be main-
tained until remediation is com-
pleted or, if groundwater usage
changes, MNA must be re-evalu-
ated.
• Source size and distance to poten-
tial receptors are critical elements
for assessing potential risks and
the potential application of MNA
for MTBE.
• The applicability of MNA for
MTBE must be considered on a
site-by-site basis.
• The source must be located
greater than V4 mile from any
receptors. A one-mile "radius pro-
tection zone" should be imposed
for public wells in the vicinity of a
release that fits the state's profile
for migrating plumes. Also, the
use of the water supply, potential
for vertical migration, options for
blending MTBE-contaminated
water with clean water to lower
concentrations, and other site-spe-
cific criteria must be considered.
• The hydrogeologic context
(groundwater flow rate), available
electron acceptors (oxic or anoxic),
and the presence or absence of co-
contaminants (e.g., BTEX) must be
understood and considered.
• Sufficient site characterization is
required to support the decision
for MNA. Most sites evaluated for
active remediation are under-
characterized for such evaluation.
Attendee Comments on Potential Use of
MNA for MTBE:
• Geochemical footprints should be
examined in addition to plume
stability.
• Demonstration of stabilized and
shrinking plumes is sufficient,
assuming site characterization is
adequate.
• MNA secondary lines of evidence
should be required for MTBE
(20% of audience agrees).
• Permeability of the vadose zone
should be considered along with
the concentration profile in the
saturated zone to examine site-
specific volatilization and the
potential presence of MTBE above
the water table.
• Funds should be reserved for
additional site cleanup if MNA is
unsuccessful.
• Long-term exposure management
and contingency plans with well-
defined criteria for triggering
additional action or remediation
must be combined with land-use
planning and public information.
• Source control should be com-
pleted prior to considering MNA
for MTBE.
-------
LUSTLine Bulletin 37
• The appropriateness of field con-
ditions for MTBE biodegradation
must be evaluated. The presence
of BTEX consumes the available
dissolved oxygen at many sites
creating an anaerobic environ-
ment that is not conducive to
degradation or attenuation of
MTBE.
• Natural attenuation is a compo-
nent of all remedies. If MNA is
treated the same as other reme-
dies, no additional investigation
or requirements are needed.
• MNA decisions should be based
on good science and a sound con-
ceptual model.
The Answer
In summary, the answer to the ques-
tion of whether MNA is appropriate
for remediating MTBE is "maybe and
in certain circumstances." The panel
presentations indicated that MNA
may be appropriate for remediating
MTBE in some cases. However, the
potential for plume migration and
the subsurface conditions that may
encourage biodegradation of MTBE
must be well understood. This means
that the site must be fully character-
ized to support MNA decisions. In
addition, MNA may be a more
appropriate option for MTBE remedi-
ation when source/release mass is
small and the potential for impact on
receptors is low.
Some attendees agreed generally
with the presenters, others felt that
MNA was appropriate for MTBE
with no extra requirements beyond
those typically imposed at BTEX
release sites, still others (about 20% of
attendees) felt that additional investi-
gation such as geochemical footprints
and secondary lines of evidence
should be required for evaluating the
application of MNA at MTBE release
sites.
One attendee pointed out that
the biodegradation of BTEX at gaso-
line release sites creates an anaerobic
environment that is not favorable for
biodegradation of MTBE and may
limit the application of MNA. Other
attendees expressed a desire to see
contingency planning and long-term
management incorporated into any
use of,MNA at MTBE release sites.
Overall this was a positive
exchange of ideas in the continuing
debate over appropriate application
of MNA to remediation of gasoline
releases containing MTBE.
Thanks to Ravi Arulanantham of
the California Regional Water Qual-
ity Control Board, Sanjay Garg of
Equilon, Greg Hattan and Bill Reetz
of the Kansas Department of Health
and Environment, Jeff Kuhn of the
Montana Department of Environ-
mental Quality, Jim Landmeyer of
the U.S. Geological Survey, and Jim
Weaver of the U.S. Environmental
Protection Agency for providing
panel presentations. Thanks to Bill
Reetz for compiling comments.
Thanks to all attendees of the 2000
Hydrocarbon Conference who partic-
ipated in the discussions. •
References
• Natural Attenuation for Groundwater Remediation
(2000), National Research Council, Commission
on Geosciences, Environment and Resources, Na-
tional Academic Press, http://stJHs.naj5.edu/booksy
0309069327/html/
• ASTM Standard Guide for Remediation of Ground-
water by Natural Attenuation at Petroleum Release
Sites (E-1943-98), (1998), ASTM, 100 Barr Harbor
Drive, West Conshohocken, PA 19428-2959.
http://www.astm.org/
• OSWER Directive 9200.4-17: Use of Monitored Nat-
ural Attenuation at Superfund, RCRA Corrective
Action, and Underground Storage Tank Sites, U.S.
EPA, April 21,1999, U.S. EPA, Office of Solid Waste
and Emergency Response, http://www.epa.gov/
swerustldirecttv/d9200417.pdf
Matt Small is a hydrogeologist with
U.S. EPA Region 9, UST Program
Office and a graduate student at U.C.
Berkeley. He can be reached at
small.matthew@epa.gov. Matt has
written this article in his private
capacity. No official support or
endorsement by the EPA, federal gov-
ernment, any state government or any
private company is intended or should
be inferred.
I Other Oxygenates... continued from page 21
References
•Blue Ribbon Panel on Oxygenates in Gasoline, 1999. Achieving Clean Air and Clean Water: The Report of (he Blue
Ribbon Panel on Oxygenates in Gasoline, Sept. 1999, EPA420-R-99-021; U.S. Government Printing Office. 126 pgs.
•Buscheck, T.E., and C.M. Alcantar. 1995, Regression Techniques and Analytical Solutions to Demonstrate Intrinsic
Bioremediation. In: Intrinsic Bioremediation, R.E. Hinchee, J.T. Wilson, and D.C. Downey, editors. In Proceedings of
the Third International In Situ and On-Site Bioremediation Symposium. San Diego, California, Volume 3(1): 109-
116.
•Erdal, Serap, and Bernard D. Goldstein, 2000. Methyl tert-Butyl Ether as a Gasoline Oxygenate: Lessons for Environ-
mental Policy. Annual Reviews: Energy and the Environment, V. 25:765-802.
•Franklin, Pamela M., Catherine P. Koshland, Donald Lucas, and Robert F. Sawyer, 2000, Clearing the Air: Using
Scientific Information to Regulate Reformulated Fuels. Environmental Science and Technology 34(18): 3857-3863.
•Gray, Andrew L, and Anthony Brown, 2000. The Fate, Transport and Remediation of Tertiary Butyl Alcohol (TBA) in
Groundwater. In Proceedings of the 2000 Petroleum Hydrocarbons and Organic Chemicals in Ground Water: Pre-
vention, Detection, and Remediation Conference and Exposition. Anaheim, California, p. 278.
•Halden, Rolf U., Anne M. Happel, and Sarah R. Schoen, 2001. Evaluation of Standard Methods for the Analysis of
Methyl tert-Butyl Ether and Related Oxygenates in Gasoline-Contaminated Groundwater. Environmental Science and
Technology. Web Release date: March 7,2001.
•Happel, Anne M., Edwin H. Beckenbach, and Rolf U. Halden, 1998. An Evaluation of MTBE Impacts to California
Groundwater Resources. Lawrence Livermore National Laboratory, UCRL-AR-130897,68 pgs.
•Health Effects Institute, 1996. The Potential Health Effects of Oxygenates Added to Gasoline. Cambridge, Massachu-
setts. 158 pgs.
•Integrated Science and Technology, 1999. Technical Report: Comparative MtBE Versus Benzene Plume Behavior BP
Oil Company Florida Facilities. Prepared for BP, Feb. 1999,58 pgs.
•Kolhatkar, Ravi, John Wilson, and Lloyd Dunlap, 2000. Evaluating Natural Biodegradation of MTBE at Multiple
UST Sites. In Proceedings of the 2000 Petroleum Hydrocarbons and Organic Chemicals in Ground Water: Preven-
tion, Detection, and Remediation Conference and Exposition. Anaheim, California, pp. 32-49.
•Kramer, William H., and Timothy L. Douthit, 2000. Water Soluble Phase Oxygenates in Gasoline From Five New Jer-
sey Service Stations. In Proceedings of the 2000 Petroleum Hydrocarbons and Organic Chemicals in Ground
Water: Prevention, Detection, and Remediation Conference and Exposition. Anaheim, California, pp. 283-290.
•Linder, Steven C, 2000. Tertiary Butyl Alcohol (TBA): MTBE May Not Be the Only Gasoline Oxygenate You Should
Be Worrying About. LUSTLine, Bulletin 34, New England Interstate Water Pollution Control Commission, Lowell,
Massachusetts, pp. 18-20.
•Mace, Robert, 1998. Spatial and Temporal Variability of MTBE Plumes in Texas. Prepared for API by the Bureau of
Economic Geology, University of Texas at Austin, 60 pgs.
•New England Interstate Water Pollution Control Commission, 200Q. A Survey of State Experiences with MTBE
Contamination at LUST Sites. Executive Summary at http://www.neiwpcc.org/mtbees.pdf. Results at
http://www.neiwpcc.org/results.pdf.
•Powers, Susan E., David Rice, Brendan Dooher, and Pedro J.J. Alvarez, 2001. Will Ethanol-Blended Gasoline Affect
Groundwater Quality? Engineering, Science and Technology, Volume 35, Issue 1, pp. 24A-30A.
http://pubs.acs.org/subscribe/journals/esthag-a/35/i01/html/01powers.html.
•Maryland DEQ, 2000. December 2000 Preliminary Report: Task Force on the Environmental Effects of MTBE
http://www.mde.state.md.us/was/mtbe_report.pdf.
•Salanitro, J., 2000. In-Situ Control of MTBE Plumes With Inoculated Biobarriers. In: Proceedings API/EPA
MTBE Biodegradation Workshop, February 1-3,2000. Cincinnati, Ohio.
•US EPA, 2000. Memorandum from Sammy Ng, Acting Director, Office of Underground Storage Tanks, to
Regional UST Program Managers, Regions 1-10, State UST/LUST Program Managers, January 18,2000. Subject:
Monitoring and Reporting of MTBE and Other Oxygenates at UST Release Sites.
23
-------
LUSTLinc Bulletin 37
Gasoline
Oxygenates and
Private Wells
Many observers would agree that
with the closure of Santa Mon-
ica's Charnock well field in 1996, that
city became the "poster child" for the
ban MTBE movement. Because of the
substantial political power wielded
by California water purveyors and
their trade group, activities aimed at
banning MTBE rapidly escalated.
Protecting municipal water sys-
tems and the thousands/millions of
customers they serve is an extremely
important consideration for UST reg-
ulators. However, it might be fair to
say that if we are concerned about
exposures to MTBE (or other com-
mon drinking water contaminants),
especially at levels above MCLs or
other health-based limits, then we
should be especially vigilant regard-
ing potential impacts to private
drinking water wells.
In some states, concerns about
private wells have been the catalyst
for legislative efforts to ban MTBE.
Incidents on Long Island and upstate
New York, for example, were fre-
quently cited during the MTBE leg-
islative debates in that state. In what
remains the best study on this topic,
the 1998 Maine Department of Envi-
ronmental Protection's study found
MTBE in 15.8% of the 950 private
wells they sampled.
The U.S. Census Bureau statistics
indicate that in 1990 over 15 million
households (around 42 million peo-
ple) received their water from private
domestic wells. Five states have
almost *A of these wells—Michigan
has over 1.1 million private wells;
Pennsylvania, North Carolina, New
York, and Florida all have over
800,000.
A recent article in Environment
Science and Technology (ES&T) noted
that 73 million Americans live in
areas where MTBE is used in RFC
and estimates that about 6.4% live
"near" a gasoline station. Most pri-
vate wells draw from shallow uncon-
fined aquifers that are susceptible to
24
contamination from a multitude of
sources, including USTs.
Little Is Known About
Private Wells
A 1997 EPA report on the nation's
drinking water infrastructure noted
that "very little is known about the
degree of contamination at private
wells." EPA has just released a fol-
low-up report that states "A lack of
monitoring data prevents a compre-
hensive assessment of the quality of
water supplied by private wells."
The 1997 report notes that such
wells at best are only tested immedi-
ately after they are installed and that
24 states do not even require that
level of testing. Few studies have
been conducted of private well water
quality. Those studies that have been
undertaken typically find dis-
turbingly high occurrences of conta-
minants.
Most private wells draw from shallow
,r « i , i ,
uncon fined aquifers that are
it V ,» i , - |
4 susceptible to contamination from a
t\2 Mi 'i'"t 1 • p'1, T ' liu'i
multitude of sources, including USTs.
' "
For example, a 1994 Center for
Disease Control study of over 5,000
randomly selected private wells in
nine Midwestern states showed that
over 13% of the wells had nitrate lev-
els above the U.S. EPA MCL.
Atrazine, a common herbicide used
in corn-growing areas, was found in
13.4% of the wells and above the
MCL (3 pg/L) in 0.2%. Similar results
were observed in a U.S. Geological
Survey (USGS) study of wellsjin the
Delmarva peninsula area of the mid-
Atlantic states of Delaware, Mary-
land, and Virginia (Environmental
Health Perspectives, 1997).
A 1997 Government Accounting
Office report on private wells and
community water supplies in Califor-
nia, Illinois, Nebraska, New Hamp-
shire, North Carolina, and Wisconsin
found that up to 42% of private wells
were contaminated with coliform
bacteria at levels in excess of the MCL
(as opposed to 3 to 6% of community
systems), and that up to 18%
exceeded the MCL for nitrate. Lim-
ited data were available for chemical
pollutants such as pesticides, metals,
and volatile organic compounds. The
report indicated that contamination
with those compounds is rare—only
1 to 2% of wells tested reported con-
centrations above federal MCLs.
Several recently published stud-
ies provide interesting details about
the private well side of the drinking
water impact issues. The February 1
issue of ES&T featured an article
(http://pubs.acs.org/subsmbe/journals/
esthag-a/35/i03/html/02mackay.html)
that describes an approach for pre-
dicting impacts to wells using the
concepts of contaminant-dissolved
mass flux.
The authors note that given the
limited amount of contaminant mass
in a dissolved plume (e.g., a "typical"
UST release site might leach about
10-100 grams of dissolved MTBE
daily from the residual gasoline
source area), coupled with the mas-
sive volume of water typically with-
drawn by large wells (e.g., 400-900
gallons per minute), that dilution will
frequently reduce MTBE concentra-
tions to levels below analytical detec-
tion limits and/or below levels of
concern. They caution that "...if an
impact is defined by the concentra-
tion of contaminants in the extracted
water, small, private water wells may
more often be at greater risk than
large municipal systems pumping
hundreds to thousands of liters a
minute."
In early February the state of
New Jersey released its report on the
environmental impacts of MTBE.
That report noted that they have been
monitoring for MTBE in municipal
systems for over 15 years and that
MTBE (at 0.5 - 20 pg/L) was present
in 15% of those systems; there were
no findings over 20 ^g/L.
The report summarizes USGS
studies of MTBE detections in
domestic wells in four separate sam-
pling areas (about 30 wells sampled
in each). MTBE was present in 43%,
28%, 7%, and 93% (yes 93%!) of those
wells. Almost all detections were rel-
atively low, however, as the median
concentration detected in each study
area was no greater than 1.16 ^ig/L.
Regarding the study area with
93% detections, it was around a lake
that received heavy watercraft use,
and where the lake water during
summer months contained as much
as 20 ^g/L or more MTBE due to the
discharges of two-stroke engines.
-------
LUSTLine Bulletin 37
Because the wells around, the lake
drew from the water table that was in
intimate hydrologic contact with the
lake, it is easy to see why so many
wells had some MTBE.
In the recent NEIWPCC survey
of state experiences with MTBE
issues, all but 10 states responding
indicated that they had less than 40
private wells impacted. Collectively,
the 10 states with more than 40
impacted wells estimated that about
2,300 private wells had been
impacted. Maine observed that
extrapolating its 1998 data to the
entire state population of private
wells would mean that between
37,000 and 50,000 wells would have
MTBE at more than 0.1 jfg/L.
This survey of UST personnel can
not be considered an accurate assess-
ment of private well impacts but per-
haps does give an indication that
most states do not routinely charac-
terize or track the impacts to private
wells from UST releases, even though
there may be many wells impacted.
In an article soon to be published
in ES&T (Lince et al., 2001), the
authors tried to determine if private
wells are more likely to be impacted
in areas where reformulated gaso-
lines are used. The New York Depart-
ment of Health conducted a survey of
71 private wells near 21 randomly
selected gas stations. Forty wells were
sampled in conventional gasoline
areas, and 34 wells were sampled in
RFC areas. Eight wells (20%) in the
conventional gas areas and 13 wells
(38%) in the RFC areas had MTBE at
more than 1 ^g/L. The authors note
that given the small sample size of
their study, "statistically definitive
conclusions are limited," but they also
note that their findings are generally
consistent with the Maine and USGS
studies that show lesser impacts to
drinking water in non-RFG areas.
The USGS's National Water
Quality Assessment program is
preparing a summary report on
about 1,700 private wells in 35 states
that have been sampled over the last
decade as part of its comprehensive
evaluation of shallow groundwater
quality. They will summarize data on
the occurrence of 55 VOCs in those
wells. The results should be available
by late fall (J. Zogorski, personal
communication, 2001).
Who's Looking Out for the
Private Wells?
Who speaks for the universe of
households using private wells? The
EPA Blue Ribbon Panel had a mem-
ber representing public water suppli-
ers, but no one really represented the
concerns of private well owners.
While the EPA Office of Ground
Water and Drinking Water
(OGWDW) has an extensive program
to address community water sys-
tems, there is no federal authority for
, private wells. The OGWDW Web site
has very little information on private
wells or any related activities
(http://www.epa.gov/safewater/pwe
llsl.html#more).
The National Ground Water
Association (http://www.ngwa.org)
represents the drillers who install
private wells and has established the
National Well Owners Association
(http://www.weUowner.org/mdexJitin).
There is also a National Rural Water
Association (http://www.nrwa.org/).
As noted earlier, MTBE is just
one of a long list of common contami-
nants in private wells. Perhaps the
increased attention paid to MTBE
will help raise awareness of all these
threats. Absent a strong political
voice, however, it may be awhile
longer before there is resolution to
this long simmering private well
issue.
As LUSTLine was going to press,
we learned that the New Jersey legis-
lature has sent a bill to the Governor
for signature that would require the
private wells at dwellings being sold
or leased to be tested for VOCs and
other contaminants. The bill also pro-
vides funding for a public education
program. This is clearly a step in the
right direction. •
References
• Lince, Daniel P., Lloyd R. Wilson, Gordon A. Carl-
son, and Anthony Bucciferro. Effects of Gasoline
Formulation on Methyl tert-Butyl Ether (MTBE) Contam-
ination in Private Wells near Gasoline Stations Envir. Sci.
and Technology. In Press.
• Drinking Water Infrastructure Needs Survey. Sec-
ond Report to Congress. February 2001. USEPA
Office of Water (4101) EPA 816-R-01-004.
• Drinking Water Infrastructure Needs Survey. First
Report to Congress. February 1997. USEPA Office of
Water (4101) EPA 812-R-97-001.
• Well, Well, Well Water. 1997. Environmental Health
Perspectives 105(12):1290-1292.
• Center for Disease Control and Prevention. Septem-
ber 1998. A Survey of the Presence of Contaminants in
Water in Private Wells in Nine Midwestern States.
NCEH 97-0265.
• continued on page 31
NEIWPCC Prepares
Report on Ethanol
as an Alternative
to MTBE
As state and federal moves to elim-
inate or reduce the use of MTBE
have gained momentum nation-
wide, ethanol has emerged as the most
likely oxygenate replacement for MTBE.
Recognizing that it is important that the
Northeast states be in a position of
having evaluated potential alternatives
to MTBE with regard to health effects
and potential environmental issues, the
New England Governor's Conference
(NEGC) Committee on the Environment
called for the states to work as a region
to evaluate alternatives to MTBE.
As an organization concerned pri-
marily with water quality issues in the
New England states and New York, the
New England Interstate Water Pollution
Control Commission (NEIWPCC) was
asked to address oxygenate alterna-
tives with respect to water impacts.
(The Northeast States for Coordinated
Air Use Management is preparing a
report from an air perspective.) In
response, NEIWPCC organized an
Alternative Fuels Subcommittee made
up of staff representatives from state
health, UST, and site remediation pro-
grams to address tank-related MTBE
and alternative oxygenate (ethanol)
concerns.
While there may be many possible
alternatives to the use of MTBE as an
additive in gasoline in the Northeast,
the subcommittee focused its evalua-
tion on the potential environmental
impacts of a release of ethanol and
ethanol-blended gasoline because, in
the near-term at least, it will likely be
more widely used in this region and
throughout the country. Alternative
oxygenates other than ethanol were
reviewed briefly with an eye toward the
possibility of a more thorough evalua-
tion at a future date.
The subcommittee divided into
focus groups to work on the key areas
of concern associated with ethanol—
Health Effects, Aquatic Impacts, Stor-
age and Handling, Environmental
Impacts, and Other Alternatives. A draft
report has been completed and
reviewed by state agency personnel
and outside experts. NEIWPCC expects
to complete the report in late spring. •
25
-------
LUSTLine Bulletin 37
E-Commerce at the Dispenser
Another Thing to Worry About?
by Sheldon Schall
E-commerce is a relatively new
term for a relatively new tech-
nology—electronic merchan-
dizing via the Internet. E-commerce
is appearing everywhere—television
screens, computer monitors, cell
phone screens, and now the gasoline
dispenser. But unlike television and
computer screens, the dispenser
island is a place that involves the
handling of gasoline, the comings
and goings of vehicles, and the activ-
ity of people getting in and out of
those vehicles. In short, e-commerce
at the pump adds an element of risk.
Wisconsin's preinstallation plan
review for UST systems includes spe-
cific information relating to the dis-
penser. Our concerns regarding
e-commerce at the dispenser were
sparked when a petroleum equip-
ment installer contacted our office
prior to submitting a plan for a dis-
penser island upgrade. The modifica-
tion to the island equipment included
the installation of dispensers that
would be performing an e-commerce
sales function.
The installer brought this to our
attention assuming that the new dis-
penser concept would have an
impact on the plan review process,
and he was hoping to prevent any-
thing from slowing down the
process. He was correct in that
assumption. After discussing the con-
cept and reviewing a manufacturer's
promotion manual our concern was
heightened even more.
At Issue
The strategy behind the concept is
obviously meant to capture more
business and generate more sales.
More sales either through purchases
initiated at the dispenser with the
transaction completed at the counter,
or Point-of-Sale (POS) credit card
transactions at the dispenser. The
dynamics of these limited e-commerce
sales transactions appear to have lit-
tle potential to increase the fire-safety
risk at the dispenser. However, some
of the expanded applications, such as
ATM and lottery functions, have the
potential to change the dynamics of
26
the dispenser environment signifi-
cantly, particularly with regard to
risks associated fire, human safety,
and accidental fuel spills.
Currently there is some debate
regarding the distractions caused by
a simple video display screen on a
dispenser. Indeed, it is possible that a
video display that is limited to a pro-
motional function may aid in keeping
some customers close to the dis-
penser. However, displaying sports
events or news broadcasts may
become a distraction by shifting a
patron's attention from operating a
dispenser nozzle to watching an
event or story being broadcast. Add
to that the expanded commerce func-
tion of the dispenser island.
Now you've got the potential
risk of accident and injury from the
changing dynamics of vehicle and
pedestrian traffic patterns as people
move about to access the pop dis-
penser or ATM machine adjacent to
the dispenser on the island—we've
heard several stories of minor acci-
dents involving the Speed Pass con-
cept. Furthermore, it is not too much
of a stretch to believe that a customer
approaching a dispenser island solely
to use the ATM will not have the
same consciousness about the ciga-
rette hanging from his/her lips as the
person approaching to dispense gas.
Clearly, owners or operators who
have made the decision to install dis-
pensers with e-commerce capabilities
are focused on the potential for gen-
erating more sales and are not realiz-
ing the potential risk. The attendant
or c-store operator is expected to
have a reasonable visual oversight of
the fuel dispensing areas. The e-com-
merce dispensers are wider than the
traditional dispenser and adding
goods dispensers (e.g., pop or snacks)
or ATM machines to the island
reduces the visual contact with activi-
ties in the dispensing area.
Are We Ready?
In the process of assessing our regu-
latory position on the application of
e-commerce dispensers, I distributed
a survey question to the states
through the Association of State and
Territorial Solid Waste Management
Officials e-mail distribution network.
Few respondents were aware of the
concept, but most respondents
agreed that there are fire and safety
concerns associated with the dis-
penser island application.
Several respondents indicated
that e-commerce dispensers were
appearing in various applications,
from placing a food counter order to
providing ATM access. Interestingly,
a number of respondents represent-
ing state UST regulatory programs
did not have regulatory authority
over the dispenser, so they could not
address the issue if they wanted to.
Missouri appeared to be the most
proactive in this regard, already hav-
ing a rule that states "Installation of
equipment and devices, such as
vending machines and ATMs, that
may produce safety hazards by dis-
tracting the customer from the dis-
pensing operation, limit ingress and
egress to the dispensing area or from
electrical components of the equip-
ment or .device, or limit visibility to
vehicle refueling on islands utilized
for the dispensing of petroleum
products regulated by Chapter 414,
RSMO is prohibited."
Because the regulatory commu-
nity tends to be more reactive than
proactive I expect the trend will be
well established before the regulatory
community has an opportunity to
effectively address it. It will be inter-
esting to see how the insurance
industry approaches this concept. As
one regulator responded, "I guess
nothing will happen until the mini-
van full of kids burns up."
How are we handling it in Wis-
consin? We are working on revising
the current regulation to develop a
restriction similar to Missouri's. In the
meantime, we are communicating to
the installation industry that we will
use our state regulatory authority to
protect the public welfare by conduct-
ing a site-specific assessment of any e-
commerce dispenser application
beyond the promotional or in-store
sale of goods function. •
Sheldon Schall is Chief of the
Wisconsin Department of Commerce
Bureau of Storage Tank Regulation.
He can be reached at
sschall@commerce.state.wi.us. •
-------
LUSTLine Bulletin 37
NEIWPCC's MTBE Survey Sheds Light on
Where States Are and Where They Aren't
by Ellen Frye
By now, many LUSTLine readers
may have perused the New
England Interstate Water Pol-
lution Control Commission's (NEI-
WPCC's) survey of state experiences
with MTBE on the Commission's
Web site (www.neiwpcc.org/mtbe
main.html). The 34-question survey,
to which all 50 states responded, was
designed to determine how MTBE
contamination is affecting state
LUST programs and the cleanup of
contaminated sites. It was I who con-
ducted the survey and then tallied
the results for NEIWPCC. As I
received each completed (or incom-
pleted) state response and entered
the results onto the master tally
sheet, I became more and more fasci-
nated by how much this survey was
telling us about what we don't know.
The survey provided a fairly
comprehensive snapshot of state
experiences with MTBE, as of Sep-
tember 2000, and also revealed siz-
able gaps in our collective knowledge
of the various issues associated with
MTBE in the environment. For many
questions, the "don't know" response
was quite common. But this was not
so surprising.
We knew, as we developed the
questions (and we had the help of
several state and consulting MTBE
aficionados) that we needed to ask
the questions that would provide a
complete MTBE/oxygenate picture.
Deep down inside, we knew a sizable
amount of white space would remain
on the canvas. We hoped, however,
that by conducting this survey, more
states would begin to seek answers to
questions such as these so that, in
time, we would all better understand
the nature of the MTBE beast as it
finds its way into the groundwaters
of America.
But alas, we have a long way to
go. The survey tells us what states are
or are not doing with respect to
MTBE. It tells us what states think
they know about MTBE's presence,
absence, or extent in the environ-
ment. But when we take the state
responses and attempt to compare
them, we end up with MTBE hodge-
podge—a mixture of dissimilar
ingredients.
Let's Begin with the
Standards
We divided the survey into six cate-
gories: MTBE Standards, Analysis,
Site Assessment, Remediation, Other
Oxygenates, and Other (CIS, infor-
mation needs). The answers to the
very first question in the survey—
Does your state have action levels,
cleanup levels, or drinking water
standards for MTBE? Yes or No?—set
the stage for what was to follow.
Thirty-eight states responded to the
question in the affirmative.
But wait, were these standards
for soil? for groundwater? action lev-
els? cleanup levels? primary drinking
water standards? secondary drinking
water standards? All? Some? One?
.Two?
f The survey tells us what stales are
or are not doing with respect to
j^MTBE. It tells us what states think
M
!ftheyl(now about MTBE's presence,
absence, or extent in the
environment. But when we take the
te responses and attempt to
compare them, we end up with
/ITBE hodgepodge—a mixture of
- dissimilar ingredients.
fer
J
Of the 38 states, 20 have soil
action levels, 28 have soil cleanup
levels, 26 have groundwater action
levels, 32 have groundwater cleanup
levels, 8 have primary (health-based)
drinking water standards, 6 have sec-
ondary (taste and odor) drinking
water standards, 8 use the EPA advi-
sory (20 /tg/L) drinking water stan-
dard, and 12 use a state or some other
advisory. Right off the bat, we've
established that states are looking for
MTBE in different ways and at differ-
ent detection limits.
Some of the standards and levels
are enforceable and some are not.
Eight states indicated that all of the
levels they use are enforceable while
six indicated that none are enforce-
able. The remaining states that
answered stipulated an assortment of
variations on the theme.
An MCL for MTBE might move
the states in the direction of a com-
mon denominator. Thirty-six states
indicated that a federal MCL for
MTBE would affect their state's
remediation process. Many of the
states, particularly those that do not
currently have a cleanup standard for
MTBE, felt that an MCL would lead
to the adoption of that standard and
hence more protracted and costly
cleanups, other states said that they
might have to adjust their existing
standards up or down, depending on
the established MCL. In many states,
a numerical federal MCL for MTBE
would effectively be adopted by the
state.
Keeping our vastly disparate
standards in mind, lef s take a peek at
MTBE analysis. Forty-three states
require sampling and analysis for
MTBE in groundwater at LUST sites.
Twenty-nine states require such sam-
pling and analysis in soil.
Of the states that require sam-
pling and analysis of MTBE in
groundwater, 14 do so for all sus-
pected releases and 30 do so for gaso-
line releases. Of the states that
require such sampling and analysis
in soil, 10 do so for all releases and 22
do so for gasoline releases.
States that require testing for
MTBE were asked when that require-
ment was initiated. That spectrum
ranges from Maine in 1986 right on
up to Washington in 2001. When
asked approximately how many sites
were closed before MTBE analysis
was required, many states indicated
that significant numbers of sites had
been closed before analysis require-
ments took effect.
A Matter of Dimension
Need I say more? I've gotten as far as
question 5e, and if s clear we have an
• continued on page 30
~~ 27
-------
LUSTUne Bulletin 37
instate Funds:
Life Beyond the Fund
After Exploring Its Options, Iowa Transitions from
State Fund to Marketer-Owned Insurance Company
by Pat Rounds
Since the early 1990s, state
cleanup funds have served as
the primary means for many
tank owners to comply with the fed-
eral financial responsibility (FR)
requirements—out of 47 states with
some kind of petroleum release
cleanup fund, 42 programs serve as
the FR mechanism for the owners.
Collectively, state assurance funds
raise almost $1.2 billion annually to
help pay for cleanups, some of
which, especially those of historical
releases, might not have occurred
had these funds not been created.
With technical regulations that
require that all USTs meet minimum
upgrade and operating requirements,
most historical releases should have
been discovered at operating loca-
tions by the 1998 technical upgrade
deadline. Thus, UST systems that are
in use today should be less prone to
releases than those of the past. Own-
ers and operators who have clean
sites (or are addressing past releases
with assistance from state assurance
funds) and upgraded tanks should
now be able to obtain coverage for
their sites for a reasonable price
through private insurance.
Many private insurers are offer-
ing FR coverage for less than $1,000
per site. Several states never pro-
vided FR coverage through a state-
funded program. Other states
including Texas, Florida, West Vir-
ginia, Iowa, and Maryland are exam-
ples of states that have successfully
transitioned their UST owners from
state fund FR coverage to private
insurance FR coverage.
The question today is not
whether private mechanisms can
address the FR requirements, but
whether there are states that are
ready to exit from the financial assur-
ance business. If that answer if "yes,"
then the question becomes one of
how to exit successfully.
28
Considering a Transition
When considering whether to end a
state FR program, many program
issues must be evaluated to deter-
mine if the program is achieving its
goals. If the program has achieved its
goal or if it is unable to achieve its
goal, then a transition may be worth
considering. An objective evaluation
of transition goals should be under-
taken to ensure that the transition
process itself does not have a nega-
tive impact on the decision to end the
program. The following issues
should be addressed:
• Determine what tasks the state
fund addresses today. The transi-
tion decision cannot be fully eval-
uated unless all state fund duties
and responsibilities are quanti-
fied. Is the fund responsible for
regulatory inspections? Managing
cleanup? Evaluating other FR
mechanisms? Does the fund pay
for releases from sources other
than active, regulated USTs? The
decision makers must understand
what the fund does before they
modify the program.
• Determine what role, if any, the
state fund will play in the future.
Will the fund be a cleanup solu-
tion for sites that do not comply
with FR requirements? Will the
fund be responsible for determin-
ing if owners are in compliance
with the FR requirements?
• Determine who pays for cleanup
today and who will pay tomor-
row. If the cost of FR is hidden in
per gallon fees collected on all
fuel, the UST owner may not want
to start paying for FR in the form
of site-specific premiums. Many
times it is easier to understand
reluctance to change when you
determine who will pay for the
change.
• Identify the goal of the transition.
This may appear simple, but it is
probably more complex than it
seems. A goal may be to decrease
state expenses or reduce state
employees. It may be to reduce the
cost to the taxpayer or reallocate
the cost to the insured. Promoting
private enterprise may be a goal.
Other goals may involve creating
environmental incentives, expedit-
ing cleanup, promoting individual
responsibility, tapping the exper-
tise of the private sector (e.g.,
claims handling, underwriting,
inspections, policy issuance, limit-
ing appeals), or having the oppor-
tunity to reallocate state resources
to focus on another state concern.
The goal should dictate the transi-
tion plan.
• Determine what to do with
remaining money after the transi-
tion—a problem every state fund
administrator would like to face.
Leftover money may not appear
possible, but it may happen and
should be addressed up front.
Evaluating Alternatives
For most UST owners there are only
two methods for demonstrating FR:
(1) state funds and (2) private insur-
ance. However, when combined,
these alternatives create numerous
possibilities for creative mechanisms
to address each state's specific needs.
Just as funds vary from state to state,
financial assurance alternatives can
evolve as fund/insurance hybrids
that are tailored to fit individual state
temperaments. I'll discuss the smor-
gasbord of alternatives in a future
article. Right now, let's look at how
we might want to evaluate any alter-
native. .
First of all, facts and knowledge
should replace anecdotal stories and
fears. If fund managers are going to
-------
LUSTLine Bulletin 37
explore the alternatives they should
consider the following issues when
comparing any financial assurance
mechanism with the current opera-
tion of their fund. (For simplicity's
sake, I'll refer to the "mechanism" in
lieu of the "financial assurance mech-
anism.")
• Will the mechanism meet the fed-
eral and state requirements?
• How will we know that every site
has FR coverage?
• Will the mechanism cover an old
release?
• How will the mechanism deter-
mine if a release is old or new?
• What if the assurance mechanism
won't pay?
• What if there is a delay in pay-
ment?
• What if the assurance mechanism
can't pay?
• What if the policy conditions are
unreasonable?
• What happens if the owner does
not comply with the coverage
requirements?
• Is there an appeal process if a
claim is denied?
• What if the tank owner can't
afford coverage?
• What if the assurance rates
increase later?
• Are deductibles reasonable?
• How do we know the tank owner
can pay the deductible?
• Will environmental protection
concepts be promoted?
• Will there be incentives to pro-
mote proper tank management?
• Will there be incentives to dis-
cover and report leaks?
• Will cleanups be addressed in a
timely manner?
• Will cleanups be addressed effec-
tively?
• Will the coverage protect the pub-
lic?
• Will costs be allocated in the most
equitable manner?
• Will the overall cost associated
with UST FR and cleanup
decrease?
• Will the assuring mechanism have
the expertise to understand UST
operation and cleanup?
Just as we can't easily summarize
or generalize how every state fund
would respond to these questions,
we also cannot easily summarize
how every insurance carrier would
respond. Furthermore, with unique
program designs and varying pro-
gram expectations, all of the issues
raised should be answered objec-
tively and specific to the state pro-
gram being evaluated. All of the
questions call for an independent,
impartial analysis based on each
state's current status and program
goals. Iowa is an example of how one
state addressed transition concerns.
- The question today is not whether
"private mechanisms can address the
iFR requirements, but whether there
lare states that are ready to exit from
_the financial assurance business.
~lf that answer if "yes," then the
^question becomes one of how to
exit successfully.
The Iowa Transition
The Iowa UST cleanup fund was cre-
ated in 1989. By 2000 it was provid-
ing assistance to over 4,000 LUST
sites and providing FR for nearly
2,300 active UST sites. The cleanup
side of the program, funded at a rate
of $0.01 per gallon, was solvent and
able to pay all claims within 30 days.
The FR or insurance side, funded by
owner premiums, had over $30 mil-
lion accumulated and was collecting
premiums of approximately $2.5 mil-
lion annually from the nearly 2,300
participating sites. All active USTs
were upgraded.
Iowa provided assistance for past
cleanups under its remedial pro-
gram, guaranteed loans for upgrade
assistance, and provided FR for
releases that occurred after October
1990, if owners chose to pay premi-
ums for FR coverage. When Iowa cre-
ated its program it was designed to
be interim only. As soon as private
mechanisms were available, the
insurance portion of the program
was designed to end.
In 1995, the Iowa UST Fund
board decided to determine if it was
time to end the "interim insurance
program" and transition the liability
for future releases from active USTs
to the private insurance market.
Obviously the cleanup fund would
continue until historical releases were
all "closed," but the question was,
could FR come from somewhere
else?
In essence, the state program
took stock of itself by addressing the
following questions:
• Current state tasks? The state fund
provides cleanup benefits and FR
coverage. The state manages FR
claims similar to an insurance
company. The state licenses UST
installers and inspectors and
groundwater professionals.
• Continued functions? The state
would continue to oversee and
fund all cleanups of historical
releases until those LUST sites
were closed. In addition the state
would continue to license UST
installers and inspectors and the
groundwater professionals who
work at LUST sites. The state, of
course, would continue to handle
all regulatory issues.
• Who pays? Iowa collects $0.01 per
gallon to fund the cleanup pro-
gram for historical releases. Site-
specific premiums for FR coverage
are paid by UST owners. Owners
who self-insure or use other mech-
anisms (approximately 700 of
3,000 active sites) are not required
to pay into the insurance fund.
Transitioning the insurance pro-
gram to the private market will
not change the burden for paying
premiums.
• Transition goal? The Iowa pro-
gram was designed to be interim,
only until other mechanisms were
available for the UST owners. The
transition should end state liability
while allowing UST owners to
comply with FR and technical
operating requirements. The UST
owners must have a reliable
source of funding if new releases
occur. There should be no lapse of
coverage.
• Remaining money? The insurance
fund only contains money that
was paid by owners in the form of
annual premiums. The insurance
fund had accumulated approxi-
• continued on page 30
29
-------
LUSTLine Bulletin 37
m Life Beyond the Fund...
continued from page 29
mately $30 million. That money
could go into the historical
cleanup fund, or it could be
returned to the owners who paid
into the insurance fund.
Private Insurance Options
The Iowa UST Fund Board commis-
sioned a study of the private insur-
ance market in the state. The study
indicated that private insurance
could address the FR needs of the
UST owners in Iowa. It determined
that insurance was available, afford-
able, and that private insurance mar-
ket incentives would address
environmental concerns. A sunset of
the program was recommended.
After reviewing the privatization
study, petroleum marketers and some
legislators still had some concerns
about private insurance. Although
private insurance was readily avail-
able at affordable rates, many UST
owners remembered the dilemmas
they faced in the 1980s when insur-
ance coverage was not available or
not affordable. They also had con-
cerns about a lapse of coverage
between the state fund and private
insurance. UST owners wanted addi-
tional protections. Legislators did not
want the problem to resurface.
Iowa UST owners had a good
record of successful tank manage-
ment. The premiums they paid over
the years exceeded the costs of
cleanup associated with the insur-
ance program. They wanted their his-
tory of successful tank management
to count for something and sug-
gested using the remaining money in
the insurance fund to help alleviate
their insurance concerns.
The legislature determined that it
was time to transition out of the FR
business, and private insurance was
the answer. To protect the UST own-
ers' long-term interests with respect
to insurance premiums and payment
of claims, they would participate in
the ownership and management of
the insurance company. The legisla-
ture agreed to a plan that authorized
the transfer of the assets and liabili-
ties of the state insurance fund to a
private company made up of the
insureds, but only if the following
requirements were met:
30
• The company must be an indepen-
dent nonprofit entity;
• It must provide long-term insura-
bility based on competitive rates
for insureds who are in compli-
ance with technical regulatory
requirements;
• It must eliminate any lapse of cov-
erage between state coverage and
private coverage;
• It must provide ease in transition
from state requirements to private
insurance requirements;
• It must allow participation of
insureds in underwriting, applica-
tion, claims, and premium deter-
minations;
• It must continue to be an accept-
able FR mechanism; and
• "Poison pill" provisions were
established to recover all assets if
the company ceases to exist, ceases
to meet the listed requirements, or
is purchased by another entity.
In 1998, with support from the
Petroleum Marketers of Iowa, legisla-
tion directed the Iowa UST Fund
Board to transfer all assets and liabili-
ties of the insurance fund to the Petro-
leum Marketers Mutual Insurance
Company (PMMIC)—owned and
operated by the insureds. The transfer
was to be completed when specific
statutory requirements were met.
On November 8, 2000, pursuant
to a memorandum of understanding
with the UST Fund Board and in
accordance with previously adopted
administrative rules, all assets and
liabilities of the insurance fund were
transferred to PMMIC—an admitted
insurance company in the state of
Iowa. PMMIC now provides insur-
ance coverage to nearly 2,300 UST
locations. The company has approxi-
mately $35 million in assets with
under $5 million in reserves for open
claims. PMMIC picked up the
retroactive date of coverage for all
sites that transferred from the state
fund.
The Iowa solution is unique, but
the plan can be followed in other
states. The three keys to Iowa's suc-
cessful transition were: (1) an objective
evaluation of the fund before transi-
tion options were selected, (2) an
objective study of the goals to be
accomplished, and (3) an objective
consideration of the options available
to address the goals. In Iowa's case, the
state eliminated long-term liabilities
for future UST releases, while the UST
owners accepted their responsibility
for future liabilities and now control
their own insurance company. •
Pat Rounds is President of PMMIC.
He can be reached at
pjr@roundsassoc.com.
• MTBE Survey...
continued from page 27
amazing and colorful mixture of dis-
similar ingredients that could well
have a tantalizing affect on the out-
come of many of the subsequent state
responses regarding site assessment,
remediation, and other oxygenates.
In short, what we know about MTBE
or any other contaminant in the envi-
ronment is based on how diligently
we choose to look for it.
In site assessment, for example, if
state policy is to analyze for MTBE
only in situations where there have
been gasoline releases from USTs,
then MTBE occurrences from any
other sources remain undocumented.
If one state's MTBE detection limit is
10 ppb and MTBE plumes are charac-
terized three dimensionally, and
another state's detection limit is 70
ppb and plumes are characterized
two-dimensionally, the resulting
characterization for the same release
could be quite different. Of course, if
you're not looking for MTBE at all,
then you won't find it!
A Treasure-Trove
All that being said, the survey
yielded a trove of information of
where states were regarding MTBE,
as of last fall. Many states took the
time to explain their answers in care-
ful detail. Inasmuch as this survey
was designed to capture information
from the states for the states, we par-
ticularly hope that state UST/LUST
program personnel will use this
information to learn from each other.
We urge you to go to the NEIW-
PCC Web site and read over the sum-
mary and examine the state response
data compiled on the questionnaire.
You may find, as I did, that the more
intriguing story lies not in the statis-
tics but in the complexity of the life
and times of MTBE in 50 states.
• continued on page 31
-------
LUSTLine Bulletin 37
• WITBE. Survey...
continued from page 30
Changes will continue to take
place with regard to MTBE standards
and site assessment and cleanup poli-
cies. New discoveries of MTBE in
public and private wells may catapult
some states to greater vigilance. As
alternatives to MTBE, such as ethanol,
come into focus, there will be changes
in the way some states address these
potential environmental threats. And
who knows, come the next survey
(did I hear someone scream?), there
will be quite another story.
We thank all who took the time
to respond to this survey. •
• Gasoline Oxygenates and Pri-
vate Wells... continued from page 25
• Hamilton, Pixie and Robert J. Shedlock. 1993. Are
Fertilizers and Pesticides in the Ground Water? A Case
Study of the Delmarva Peninsula, Delaware, Maryland,
and Virginia. United States Geological Survey Circular
1080. U.S. Government Printing Office.
• Government Accounting Office. June 1997. Informa-
tion on the Quality of Water Found at Community
Water Systems and Private Wells. GAO-RCED-97-123.
• Swistock, B.R., W.E. Sharpe, and P.D. Robillard.
1993. A Survey of Lead, Nitrate and Radon Contamination
of Private Individual Water Systems in Pennsylvania.
Journal of Environmental Health 55(5):6-12.
Tuthill A., D.B. Meikle, M.C.R. Alavanja. 1998. Coli-
form Bacteria and Nitrate Contamination of Wells in
Major Soils of Frederick, Maryland. Journal of Environ-
mental Health 60(8):16-20.
At Last, An Expedited Site
Assessment CD
Expedited Site Assessment: the CD
is now available from the Con-
necticut Department of Envi-
ronmental Protection (CTDEP).
While in development, the CD was
shown at the all states UST/LUST
conference in Long Beach, California
and won best presentation at the
State Fair. The CD provides technical
guidance on investigating fuel
releases at underground storage
tanks sites in a multimedia format. It
is packed with slide presentations,
animations, simulations, and videos
(as well as some really great original
music) and includes spreadsheets for
data collection and analysis.
The CD emphasizes the. use of
direct-push sampling methods, mul-
tilevel groundwater and soil sam-
pling, and three-dimensional field
screening. It is a great training tool
and even has a real-world exercise
where you, as a project manager,
drive a direct- push drill rig around a
site to find the source and configura-
tion of contamination. For the experi-
enced environmental professional,
the CD is an excellent reference that
covers a wide range of topics, includ-
ing MTBE, biodegradation, purging,
installation, and hydraulic testing of
multilevel samplers.
The CD was developed for Peter
Zack, CTDEP LUST program, by Pro-
fessor Gary Robbins at the University
of Connecticut. Although elements of
the CD are Connecticut specific, most
of the technical guidance is generic. •
To order copies of Expedited Site
Assessment: the CD, contact the
DEP STOKE, Connecticut '•
Department of Environmental
f Protection, 79 Elm Street,
Hartford, CT 06106-5127. Phone:
(860) 424-3555 or (860) 424-3692. ]
For more information about the
CD go to www.esacd.uconn.edu.
LU.S.T.LINE
One-year subscription. $18.00.
Federal, state, or local government. Exempt from fee. (If you wish to have LUSTLine sent to your home, please submit
your request on agency letterhead.)
Please take my name off your mailing list.
Please send me back issues of LUSTLine. Fill out name and address — no P.O. boxes.
Back issues cost $3.00 per issue or $50.00 for a complete set.
If ordering back issues, please indicate LUSTLine issue ffs . .
Please send me a LUSTLine Index.
Name
Company/Agency.
Address.
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 01852-1124
Phone:(978)323-7929 • Fax:(978)323-7919 • lustline@neiwpcc.org • www.neiwpcc.org
We welcome your comments and suggestions on any of our articles.
31
-------
EPA to Propose Secondary
Drinking; Water Standard
for MTBE
&y Rachel Sakata
The U.S. EPA intends to propose a National
Secondary Drinking Water Regulation
(NSDWR) for MTBE, based on taste and odor
in 2001. NSDWRs were established to control con-
taminants in drinking water that primarily affect
the aesthetic qualities relating to public acceptance
of drinking water. These secondary levels repre-
sent reasonable goals for drinking water quality
but are not federally enforceable. Rather, they are
intended as guidelines for states, although states
can choose to adopt this standard.
This standard will pull from the existing infor-
mation presented in EPA's 1997 Drinking Water
Advisory and analyze additional information to
determine an acceptable taste and odor level for
MTBE. Because MTBE is a growing concern that the
Agency takes very seriously, EPA wants to provide
States and water systems with more direction con-
cerning this contaminant. •
Rachel Sakata is with the U.S. EPA Office of Ground
Water and Drinking Water.
LU.S.T.UNE
New England Interstate Water
Pollution Control Commission
Boott Mills South
100 Foot of John Street
Lowell, MA 01852-1124
Forwarding and return postage guaranteed.
Address correction requested.
LUSTLlN
HlRTS
Back of shirt
TWO new W4CKY designs
createdbyLUSTLine cartoonist, HankAho
TWO colors... red and black
TWO versions... long and short sleeve
Short
sleeve
shirt
Front of shirt
TO
Long sleeve $17.00
Short sleeve $13. 00
Sizes: M, L, X, XXL
: Send check or money order (drawn on U.S. banks only) to:
NEIWPCC
Boott Mills South, 100 Foot of John Street, Lowell, MA 01852-1124
Tel: (978) 323-7929 • Fax: (978) 323-7919
------- |