New England Interstate
Water Pollution Control
                         Boott Mills South
                         1OO Foot of John Street
                         Lowell, Massachusetts
Bulletin 38
A Report On Federal & State Programs To Control Leaking Underground Storage Tanks
With Federal UST Regulations More Than 15 Years Old, It's
High Time to Heed What We've Learned in the Meantime'
by Marcel Moreau, Patricia Ellis, Ellen Frye
 m r
    he 1998 deadline for removing, replacing, or upgrad-
    ing substandard USTs was such an all-consuming push for
    regulators that some of the other particulars of the
tank program (e.g., leak detection and operation and
maintenance) enjoyed considerable freedom
from attention.
   But oh oh oh, when the tank
regulation folks finally came up for
air after the 1998 deadline passed, a
troubling UST reality set in—
those puppies were still leak-
ing! And finding methyl tertiary-butyl
ether  (MTBE) cruising through the
groundwater nether regions did nothing
to help matters, except to focus our
attention on the fact that USTs are still a
problem—one that many, including state
and federal legislators, were getting ready to
consider over and done with.
   While the fact that UST systems leak has
not come as a major surprise to UST regula-
tors, a certain amount of dismay and frustra-
tion tugs at their hearts and minds just the
same. "How much more can we do," they
ask, "when our resources have already been
stretched beyond the beyond? How can we be
effective at addressing changes in technology
when the federal rule seems to have drifted
into a state of stifling stagnation? How will
we ever get this complicated set of rules
across to a regulated community that relies
on a continuously revolving  and disinter-
ested workforce to carry out day-to-day oper-
ations and maintenance?"
                • continued on page 2
                                    ASTM's Standard Guide to Microbial Contamination in Fuels
                                     ispensing Wisdom         	

                                    The Sense of Secondary Containment
                                    Prescription for Identifying a Facility's Release Detection Method
                                    The Human Side of UST Enforcement	
                                    Maine's New UST Siting and Inspection Laws
                                    California Research on 1998 UST Upgrade Effectiveness
                                    Indoor Air Pathway Risks
                                    An Innovative Approach for Meeting Training Needs
                                    PFP in Florida
                                    PFP in Vermont
                                    New Report on Ethanol in Gasoline

WSTLine Bulletin 38
• Live and Learn
continued from page 1
    Don't get us wrong, the 1998
deadline accomplished some very
important milestones with regard to
USTs. Besides bringing substandard
UST systems up to improved opera-
tional speed, it helped permanently
close approximately 1.5 million of
them,  leaving us with that many
fewer tank systems to  worry about.
Now we can focus on the remaining
estimated 693,107 tank systems sub-
ject to federal regulation and  the
innumerable  heating oil  tanks,
aboveground storage  tanks,  and
"what not" tanks that are not subject
to federal regulations. Keeping in
mind that no tank  is  too small to
cause a big headache, the headaches
are bound to persist.

in Light  of the GAO Report
The May  2001 General Accounting
Office (GAO) report, Improved Inspec-
tions and  Enforcement  Would Better
           Ellen Frye, Editor
          Ricki Pappo, Layout
     Marcel Moreau, Technical Advisor
    Patricia Ellis, Ph.D., Technical Advisor
 Ronald Poltak, NEIWPCC Executive Director .
     Lynn DePont, EPA Project Officer

 LUSTLine is a product of the New England
 Interstate Water Pollution Control Commis-
 sion (NEIWPCC). It is produced through a
  cooperative agreement (SCT825782-01-0)
     between NEIWPCC and the U.S.
     Environmental Protection Agency.
   LUSTLine is issued as a communication
      service for the Subtitle IRCRA
   Hazardous & Solid Waste Amendments
       rule promulgation process.
     LUSTLine is produced to promote
 information exchange on LIST/LUST issues.
 - The opinions and information stated herein
  are tfiose of the authors and do not neces- .
   sarily reflect the opinions of NEIWPCC.
     This publication may be copied.
     Please give credit to NEIWPCC.
   NEIWPCC was established by an Act of
   Congress in 1947 and remains the oldest
    agency in the Northeast United States
  concerned with coordination of die multi-
      media environmental activities
     of the states of Connecticut, Maine,
     Massachusetts, New Hampshire,
   New York, Rhode Island, and Vermont.
  Boott Mills South, 100 Foot of John Street
         Lowell, MA 01852-1124
        Telephone: (978) 323-7929
    (g» LUSTLine Is printed on Recycled Paper
Ensure the Safety of Underground Stor-
age Tanks, (
getrpt?gas-01-464 or www.gao. gov/
new.items/d01464.pdf) does a nice
job  of  characterizing  the  UST
dilemma. The report was under-
taken  in  response  to  concerns
expressed by members of Congress
that the UST program is not effec-
tively  preventing  leaks and that
USTs continue to pose risks. The
report is surprisingly  discerning,
due in large  part to the fact that
those who conducted the survey on
which the report  is based asked
good questions and, more impor-
tantly,  actually  listened   to  the
answers provided by state  and fed-
eral UST program managers.
    Based  on  state  and  EPA
responses to the survey, the report
estimates that about 89 percent of
the total number of federally regu-
lated tanks were upgraded by Sep-
tember 2000.  It also estimates that
about  29 percent of  the regulated
tanks were,  as of  the survey, not
being operated or maintained prop-
erly, increasing the risk of soil and
groundwater contamination.
    Clearly, our problems with USTs
have not gone away, and as  the GAO
report points out unequivocally,
inspection and enforcement effec-
tiveness   is  in  serious  need  of
improvement. According  to  the
report, "22 states do not inspect all of
their tanks on a regular basis, and
therefore, some tanks may  never be
inspected." These  states typically
target tanks for inspection based on
factors such as a tank's potential risk
to the environment, proximity to
groundwater, or the number of com-
plaints lodged against it.
    Clearly, any such improvement
in  inspection  and enforcement
requires  increased resources—the
eternal stumbling block. Those who
hold the purse strings seem to have a
preference   for  spending more
money to clean up contamination
than for  spending less money up
front to prevent it from occurring in
the first place.
    Then  again,   we  must also
acknowledge that the technical and
operational   compliance  require-
ments   for   this   program  are
humdingers to enforce. EPA esti-
mates  that a qualified inspector can
visit 200 facilities in one year. (Report
to Congress on a Compliance Plan for
the Underground  Storage Tank Pro-
gram, June 2000, EPA 510-R-00-001.)
However, based on the time it takes
to perform a complete  inspection
and the follow-up  involved, many
program  managers feel that  this
number is optimistic.
    Another enforcement frustration
that the report noted more than once
is that most states and EPA lack
authority to use the most effective
enforcement tools, such as prohibit-
ing fuel  delivery to noncompliant
tanks,  and  many  state  officials
acknowledged   that    simplified
enforcement tools and resources are
needed to ensure tank compliance.
    Another serious drawback with
the tank program that was identified
in the report is the  lack of informa-
tion on the extent and causes of the
leaking tank problem, the effective-
ness of current equipment and tech-
nology,  and  the effectiveness  of
existing standards.
    Amazingly, in the 13  years since
the  federal regulations  went  into
effect, precious little has been done to
collect appropriate data and to evalu-
ate and modify the rules. As one of its
four UST program initiatives,  the
U.S. EPA Office of Underground
Storage  Tanks has undertaken  a
nationwide effort to assess the ade-
quacy of existing equipment require-
ments to prevent releases.

Anecdotal Pearls
Heaven knows, those of us who have
lived and breathed USTs over the
years that the tank program has been
chugging along have amassed tank
pits full  of opinions. And we  can
only hope that the pearls  of  wis-
dom—the down  and   dirty tank
experiences that have accrued dur-
ing these years—finally  have some
value. When the rules were devel-
oped in the mid-1980s,  regulators
had no tank  history of their own
from which to draw;  they relied
almost entirely on industry input.
    We'd like to  take this opportu-
nity to add some of our history  and
our opinions to the story. (Altogether,
the three of us who are authoring
this article have over 45 years of UST
history.) We'll tell it as we see it and
then open up the podium to  a
broader group of distinguished  and
sagacious UST regulators, who  will
dispense their thoughts on what they

 LUSTLine Bulletin 38
 • Live and Learn
 continued from page 3
 understanding of the technologies
 they were buying.'
     To compound the problem, most
 UST owners who went the upgrad-
 ing route were primarily motivated
 by the need to beat the deadline '98
 while spending as little money as
 possible. As a result, there is wide-
 spread regulatory concern that much
 of the upgrading work may have
 been  substandard  to  downright
 shoddy. Though the data are sparse,
 there are indications that the upgrad-
 ing technologies may not fare as well
 as the designers of the federal rule
 had hoped.

 Spill Containment (D)
 Spill containment has no doubt had
 some effect in containing small spills
 associated with fuel deliveries, but it
 has also posed a major maintenance
 headache for owners and operators.
 Because of inadequate design, poor
 installation practices, and abuse dur-
 ing use, keeping spill containment
 manholes functional has proven to
 be a distasteful chore that is most
 often ignored.
    The engineering challenge of cre-
 ating a spill container lid that is liq-
 uid tight,  easy to  remove  and
 replace,  and capable of operating at
 or near the ground surface has not
 yet been met. It is clear, as well, that
 spill containment manholes  do not
 age gracefully, particularly  in the
 rust belt where the corrosive action
 of road salt and the destructive activ-
 ity of snowplows  contribute to a
 short life expectancy. Unfortunately,
 the regulatory program has no provi-
 sion to evaluate these systems over
 time so that they can be replaced in a
 timely fashion.

 Overfill Prevention (F)
 Prevention of spills from tank over-
 fill events is an important element in
 reducing petroleum contamination.
 But regulatory efforts to address the
 problem have been compromised by
 a failure  to consider the entire deliv-
 ery system. Attempting to solve the
 overfill problem by installing equip-
 ment in the tank without considera-
 tion for the effects on the  delivery
 operator  or  the  workings of the
 delivery truck has lead to solutions
 that are perhaps worse than the
problem. (See LUSTLme #21  article
 on overfill prevention.) The equip-
 ment industry also bears some blame
 here for failing to  design overfill
 devices that work.
    It seems that a complete revamp-
 ing of the approach to overfill pre-
 vention is necessary for this source of
 spills to be effectively controlled.
 (See LUSTLine bulletin #31, "If Only
 Overfill Prevention Worked.")

 Leaks are an embarrassment  that
 nobody in the UST-owning commu-
 nity wants to talk about. The major
 flaw in the leak detection strategy of
 the federal rule is that it assumes that
 tank  owners will voluntarily come
 forward and confess their leaks to
 the regulators.
    This assumption fails to take into
 account that humans hate to confess
 their mistakes.  To regulators who
 have a hard time understanding this
    We are in a position now to step *i
  hack and look at all we have learhefl
   and honestly assess what has been
    accomplished and what remains ~
            to he done.
attitude, next time you are driving
and notice that you have exceeded
the speed limit, stop in at the next
police station and turn yourself in at
the desk. The abysmal failure of leak
detection (at least as far as regulators
can tell) is due in some  significant
measure to the lack of compliance
with regulatory reporting require-
    But lack of reporting is only part
of  the  problem.  Too  many  tank
owner/operators have little to  no
understanding of the leak detection
equipment  they  own  or the leak
detection  procedures  required  of
them. Too many of them believe that
with the  investments they have
made for new equipment and/or
upgrading,   they  are  protected
against any and all leaks for the fore-
seeable future. To some extent, this
attitude has been fostered by equip-
ment salespeople who are anxious to
make  a  sale  and  unwilling  to
acknowledge the limitations of their
    We need look no further than the
widespread occurrence of MTBE in
 the environment to demonstrate that
 the goal of contamination-free UST
 systems is still far from being real-
 ized. One of the most daunting tasks
 facing regulators today is disabusing
 the regulated community, of the fan-
 tasy that their storage system wor-
 ries are behind them.
    And to top it all off, there is
 uncertainty (within the regulatory
 community,  at  least) of the real-
 world  effectiveness of  many  of
 today's leak detection technologies.
 While anecdotal evidence of the fail-
 ure  of leak detection abounds,  to
 date, little hard data have been gath-
 ered  to  document how well leak
 detection hardware is actually per-
 forming. Without substantial efforts
 to gather such data, it will be virtu-
 ally impossible to  change the status
 quo for the simple reason that the
 regulated  community  wants   to
 believe that everything is working.

 Because the remediation prong of the
 federal rule  had  fewer technical
 specifications, leaving it up to the
 states to set cleanup standards and
 strategies, cleanup  technologies have
 had the chance to evolve based on
 trial and error. As  a result, we have
 learned an awful lot and have at our
 disposal a toolbox  of technologies to
 help us do a much better job than we
 could have 10 years ago.
    "It was summer of '86  when I
 climbed into my first excavation pit
 in Vermont,"  recalls Alaska DEC's
 Ben Thomas.  "Back then my stan-
 dard issue of equipment was a hard
 hat, buck knife, and H-NU meter. I
 would be lowered into the pit in a
 backhoe bucket, stab at the side walls
 with my pocket knife, sniff for soil
 vapors, and tell the backhoe operator
 where to dig.  Those were the days
 when we closed out hundreds  of
 sites based on  vapor readings alone.
 Later,  I  was  given  an explosion
 meter, just in case."
    Early remediation emphasis was
 mostly on source  removal  or free
 product removal. We typically didn't
 look for dissolved  BTEX plumes or
 determine the direction of groundwa-
 ter flow. Site characterization was lim-
 ited  to the few  wells  that  were
 installed, and pump and treat was the
 only game in town. (Actually, it works
better for our current MTBE problem
 than it did for BTEX constituents.)

                                                                                          LUSTLine Bulletin 38
have learned about USTs. Let's begin
at the beginning.

Once Upon a Time, There
Was a Problem...
It was that time around 1984 to 1988,
a heady time at EPA. A new, impor-
tant, and challenging program was
being born. It was being crafted vir-
tually from scratch. It was attempt-
ing to regulate a problem on a scale
never before attempted. It's dynamic
leadership was focussed on a single
goal: Let's build a program  that
    Anything was possible, so  long
as it was grounded in the reality that
there were more  than two million
underground storage systems in use,
and more than a quarter of them may
have been leaking toxic and flamma-
ble  substances into the ground.
    The architects of the UST  pro-
gram were young, committed, ideal-
istic, and human. They sought and
considered the advice and counsel of
industry,  other  regulators,  and
equipment  manufacturers.  They
spent lavishly on research to create
defensible data on which to  base
decisions. They  gradually became
invested and enamored with the pro-
gram that they'd crafted, a program
that many of them felt could not fail.

Prevention,  Detection,
The  program had  three major
prongs: prevention, detection and
    The prevention prong dealt with
those areas that had been identified
as the primary villains in the  tank
world:  corrosion  and  delivery
spillage. The antidote would include
the  installation of corrosion-pro-
tected new systems and the elimina-
tion   of    systems   that  were
unprotected  against  corrosion by
1998. Spill containment and overfill
prevention were to be implemented
on newly installed systems immedi-
ately and added to all pre-1988 sys-
tems by the end of 1998.
    The detection prong was a back-
up  to the prevention prong. It was
intended to stand vigil on the storage
system and  detect problems that
might occur  on  existing  systems
before they were upgraded and that
might still  (though  infrequently)
occur on new systems.
   The strategy was to reliably
detect leaks soon after they occurred.
The size of leak to be detected was
set at the limits of  the volumetric
detection technology of the time. The
established frequency of detection
was one that was thought to be suffi-
cient to catch leaks before they cre-
ated large problems without creating
an undue burden on storage system
   The remediation prong  was
intended as the measure that would
deal with all preexisting problems
and would also be the final barrier
between future leaks and the protec-
tion of human health and the envi-
   When the rules were developed in >
   the mid-1980s, regulators had no  \
  tank history of their own from which
   •,••...«•..,.,-;.. v.^	,,     , ,      i
  to draw; they relied almost entirely
         on industry input.         !
    Remediation standards were left
vague, with the intention that states
would fill in the blanks, but the door
was explicitly left open so that site-
specific standards could be set for
cleanup. When  fully opened, this
doorway would eventually lead to
risk-based decision making.
    The unveiling of the final UST
system regulations, though widely
anticipated, caused remarkably little
stir in the regulated  community.
Most people with knowledge of the
status  of the tank population recog-
nized that the need to take measures
to address the problem was overdue
and noted that the rules relied heav-
ily on existing industry practices.
The timetable for implementation
was ambitious, but 1998 seemed a
long way off in 1988. There were a
few murmurs of discontent, but, by
and large, the industry set out to do
what needed to be done.

A Report Card
So now that we have lived this bold
plan for 13 years, what  have we
learned?  Did  the  plan  work  as
intended? Did it work in unintended
ways? Did it fail in ways unforeseen
and/or unforeseeable? Does hind-
sight reveal some serious flaws in the
vision? There are, no doubt, many
views on this. Here are ours—grades
and all.


Reducing the UST Population (A+)
As stated earlier, there is little ques-
tion that the most wildly successful
aspect of the national tank program
has been the enormous reduction in
storage system numbers. The better
than 60 percent reduction in storage
systems points to the vast number of
nonessential storage systems  that
were in place in the 1980s (recogniz-
ing that many USTs have become
ASTs with their own set of problems,
but that is another story...). The only
UST that is guaranteed not  to leak or
spill is the UST that doesn't exist.

Corrosion Protection for New UST
Systems (A)
The regulatory  program accom-
plished virtually overnight via the
"interim prohibition," which went
into effect on May 7,1985, what man-
ufacturers  of corrosion-protected
UST systems had struggled in vain to
achieve for 15 years—the routine
installation  of corrosion-protected
systems. By and large, these tech-
nologies have performed very well,
though  it remains to be seen  how
gracefully they perform in the long

Upgrading of Existing UST Systems (C-)
The upgrading  requirements for
protecting existing systems from cor-
rosion have been somewhat problem-
atic. The rules do not require the
outright replacement of noncorro-
sion-protected UST systems, instead
they allow existing systems  to  be
"upgraded" via cathodic protection
or internal lining technologies. While
perhaps realistic in terms of making
the program more affordable, the
program erred in establishing a sin-
gle date by which all systems needed
to be upgraded rather than phasing
in the requirement over several years.
    The single-date deadline  cou-
pled with a lack of effective incen-
tives to accomplish the upgrading
work early, led to a massive demand
for upgrading services in a short
time frame. This was an invitation to
entrepreneurs to prey on a popula-
tion of tank owners that  had  little
                 • continued on page 4

                                                                                           LUSTLine Bulletin 38
    State funds had a lot to do with
 changing the remediation dynamic.
 In the early 1990s, a considerable
 number of state assurance funds
 were  created as means to cleanup
 sites and provide financial assurance
 to UST owners and operators. Within
 a relatively short window of time,
 state  funds became  the  primary
 financial responsibility mechanism
 used by tank owners and operators.
    The funds effectively dealt with a
 huge  number of cleanups. To pre-
 serve  fund resources and deal with
 the overwhelming backlog of conta-
 minated sites, EPA and the states
 began to  focus on  the  need  for
 cleaner, faster, cheaper remediation
 alternatives, encouraging the explo-
 ration of  innovative technologies.
 LUST  cleanups had initially been the
 consultant's dream come true—pro-
 tracted and lucrative.
    The problem was that many sites
 that went beyond standard dig-and-
 dump procedures had become vic-
 tims of years of ineffective pump and
 treat cleanup efforts or endless moni-
 toring without  any closure on  the
    At the behest of EPA, many regu-
 lators adopted the industry view that
 contamination in the ground is okay
 as long as  it doesn't hurt anybody.
 This cleanup  approach, originally
 called  risk-based  corrective action
 (RBCA) and more recently risk-based
 decision making  (RBDM),  helped
 direct  resources to the higher risk
    States viewed this approach as a
 way to move sites to active remedia-
 tion or close them out due to the lack
 of environmental risk—eliminating
 the endless monitoring. The new phi-
 losophy was directed less toward
 how much you could cleanup and
 more toward how much you could
 safely  leave behind. Monitored nat-
 ural attenuation became  the  new
    But now that remediation tech-
 nologies have improved  tremen-
 dously, we have the capability of
 doing a better job of cleaning up sites
 and still keeping the costs down—so
 let's do it.
    We need to stress source reduc-
 tion and rapid response in cleanups.
We've  got new tools for site charac-
 terization that allow us to perform
on-the-fly plume delineation  with
 direct-push technology and  field
labs. No more multiple rounds of
monitoring well  installation and
weeks or months between each drill
rig mobilization.
    At a minimum, we should attack
residual contamination in the source
area. Using our technology toolbox,
we can perform source area and
plume remediation where  needed,
then let natural attenuation do the rest.
    We don't need to leave impaired
properties behind. None of us have a
crystal ball to tell us what a site will
be used for five years  from now.
Must we emphasize human health
and safety and forget about the envi-
    Finally, let's remember the root
cause of the UST problem—it was
cheaper to leak than not to leak. If
state funds pick up the cleanup tab
and leave the tank owner/operator
free of compliance responsibility or
financial repercussions, leaks will
continue. The UST problem will not
be solved  until it becomes  more
expensive to leak than not to leak.
Stepping Back and
Going Forward
The UST program is an enormous
balancing act in which many factors
and outcomes must be considered.
The program has had notable suc-
cesses, and the overall storage sys-
tem population  is much healthier
today than 20 years ago. But we are
in a position now to step back and
look at all we have learned and hon-
estly assess what has been accom-
plished and what  remains to be
done. The goal of this article is not to
provide answers but to spark discus-
sion and perhaps movement so that
the dreams  of the founders of the
UST program may ultimately come
to fruition. •

 If you have any comments or responses
 to this article, please let us know. In an
  effort to encourage dialogue on where
 we are going with the UST/LUST pro-
gram, we will publish your thoughts in
     the next issue of LUSTLine.
   ASTM's Standard Guide to  Microbial
   Contamination in Fuels and  Fuel
   Systems Available

   Uncontrolled microbial contamination in fuels and fuel systems remains a
   largely unrecognized but costly problem at all stages of the petroleum indus-
   try from crude oil production through fleet operations and consumer use.
   Microbes growing in fuel systems can cause system component damage,
   degrade fuel quality, or both. We plan to cover this subject in more detail in
   the next issue of LUSTLine. Meanwhile, check out a new American Society of
   Testing Materials (ASTM) document, "D 6469 Standard Guide to Microbial
   Contamination in Fuels and Fuel Systems," available from ASTM's Web site:
       This guide provides those who have a limited microbiological back-
   ground with basic information on the symptoms, occurrence, and conse-
   quences of chronic microbial contamination. Most importantly, it provides
   personnel responsible for fuel and fuel system stewardship with the back-
   ground necessary to make informed decisions regarding the  possible eco-
   nomic and/or safety impact of microbial contamination in their products or
   systems. It also addresses the conditions that lead to fuel microbial contami-
   nation and biodegradation and the general characteristics of and strategies
   for detecting and controlling microbial contamination.
       The information in the guide applies primarily to gasoline, diesel, avia-
   tion turbine, marine, industrial gas turbine, kerosene, gasoline, and aviation
   gasoline fuels  (specifications D396, D910, D975, D1655, D2069, D2880,
   D3699, D4814 and D6227) and fuel systems. However, the principals dis-
   cussed also apply generally to crude oil and all liquid petroleum fuels. The
   guide complements and amplifies information provided in ASTM Practice D
   4418 on handling gas-turbine fuels. •

LUSTLine Bulletin 38
Dispensing Wisdom
We checked in with some state folks around the country who have been with the UST/LUST pro-
gram far ten years or more to ask them what they've learned about USTs. In -particular, we asked
them to think about what we know now that we didn't necessarily know when the program
began. Of course, we also asked them to condense their wisdom to as few words as possible. Here's
what we they came up ioith—an interesting selection of opinions. The dates in parentheses indicate
when they started working ivith the UST program.
        Marshall Mott-Smith (1983)
- Florida DEP  There is no substitute
for secondary containment and an
active field inspection presence. The
number one incentive for compliance
with our rules  is fear of getting
caught. Also, we can't ignore above-
ground storage systems.
         Jeff   Kuhn  (1987)  -
Montana DEQ
It's Time to Change, or Wither
We've come a  long way since the
infancy of the  UST/UST program,
and we still have a ways to go. At
most conferences I've attended in the
last several  years, we enshrine the
early days of the federal UST/LUST
program as if they were sacred. Most
of us agree that EPA's first Office of
Underground Storage Tanks (OUST)
Director, Ron Brand, did a marvelous
job of getting the program  off the
ground and that he established the
course for all that was to come. How-
ever, we, the federal and state regula-
tors, have been left with the job of
making  it work. If we fail to act
responsibly,  our programs  will
wither and fade to ineffectuality.
Operational Compliance Is the Key
Of the current initiatives being dri-
ven by OUST, the most important is
operational  compliance. We must
communicate the real need here—
that facilities are not remaining in
compliance  and  that we  are hard
pressed to really address the problem
of preventing releases. We must shift
the focus of our programs to leak pre-
vention. Since that was the original
focus of the UST/LUST program, if s
fair to say we've come full circle in
the last 14 years.
State Funds: Is Money the Root of
All Evil?
From the perspective of many state
funds, money really is the root of all
evil. Many of the problems discussed
by state fund administrators seem to
be almost universal and are caused
by the insatiable human desire for
more money. Some state funds have
learned how to cope with greed by
establishing strict guidelines, using
pay-for-performance   approaches,
and eliminating coverage for third-
party costs. States and territories
need to establish these types of cost-
control approaches and stick to them.

No-Fault Consulting
With the help of regulators some con-
sultants quickly learned how to max-
imize profit. Having worked as an
environmental consultant, I have the
utmost respect for those hard work-
ing  souls  who are committed to
excellence,  no matter what the situa-
tion. But lef s face it, we're all human,
and if s easier to do "C" work most of
the time.
    In consulting  it frequently pays
more to do a bad job than to do a
good job. Many states fail to recog-
nize this and end up paying substan-
tially more in time and money when
consultants submit a work plan,
receive approval,  and then immedi-
ately start a series of change orders in
the field—the hope is to get the regu-
lators  frustrated  enough that they
just tell the consultant exactly what
they should do. The result? "No-fault
consulting,"  where the consultant
bears no responsibility for greatly
inflated project costs.
    State regulatory agencies face an
uphill battle with consultants  that
target LUST sites for profit purposes
only. Even consultant certification is
limited in controlling work product
quality problems.  The type of certifi-
cation that seems to help the most is
one specific to the LUST Program,
rather  than an  all encompassing
"professional geologist" or "environ-
mental scientist"  certification pro-
    The "C" work philosophy does
have its downside—eventually con-
sultants employing this approach
alienate most of  their regulatory
counterparts, and  find the trust level
has severely diminished. In the long
run, good  consulting begets more
work and more profit. Consultants
and regulators have a lot to learn
from each other. Their goals do not
have to be mutually exclusive.

Environmental Cleanup Is
My mother in law, who grew up dur-
ing the depression, always reminds
me of how "patriotic" it is to recycle. I
was surprised when she said this to
me one day. So I had to stop  and
think about why she said it. During
the depression and especially WWII,
metals and other raw materials were
in short supply. There were signifi-
cant scrap drives to gather and recy-
cle metals "for the war effort."

                                                                                            LUSTLine Bulletin 38
    Having grown up in the 1960s
 and  '70s I never had a sense that
 cleaning up pollution was  "patri-
 otic." But it was instilled in me that
 environmental cleanup was the right
 thing to do, was an expression of our
 stewardship of the earth, and helped
 preserve something for future gener-
 ations. And when  it comes right
 down to it, it is "patriotic" to take
 care  of the environment we live in.
 This  is my home, my town, my coun-
 try, and I care deeply about preserv-
 ing it  for  my  children  and their

 A Few More Words
 • Good decisions beget good results
   and respect from the public.
 • How you do things really mat-
   ters—quick, poorly thought out
   solutions usually lead to poor
   results that set precedents that are
   hard  to  overcome  on   other
   cleanup sites in the future.
 • Bad legal precedents are like rip-
   ples on a pond, the effects  can go
   on for a long, long, time.
         Chuck Schwer (1985) -
 Vermont DEC  I have learned that
 to meet the challenges of cleaning
 up over 2,000 leaking underground
 storage tank sites in Vermont, the
 program has had to be adaptable to
 respond to changes in technology,
 gasoline composition, and political
 forces. To be stagnant is to fail!
    Also, I have learned to never for-
 get your stakeholders.
         Shahla Farahnak (1990)
- California SWRCB  As regulators
we can succeed in achieving our
goal of protecting the environment
by constructive and critical thinking.
By that I mean we must constantly
evaluate our program and its ele-
ments to determine what direction
to take and where to focus our lim-
ited resources—while remembering
our past successes. This approach
allows us to maintain a positive per-
spective  while striving to make
things better. The MTBE problem
has taught us the value of being
proactive and not reactive, and I
hope that we can carry that lesson
into the era of widespread use of
ethanol blends.
    We need to focus on communi-
cation,  training, and  inspections
before focusing on enforcement. It is
our job to make sure that the regu-
lated community knows what we are
asking them to do  and why. We
should also seek out ways to help
them stay in compliance.
    I also strongly believe it is essen-
tial that we work cooperatively with
the members of industry, owners
and operators, and inspectors to gain
a better understanding of the effec-
tiveness of equipment at operating
stations. We can then use that infor-
mation to guide ourselves through
the  development of  any  future
         Ben Thomas  (1986) -
Alaska Department of Environmental
Conservation  Everything I know
about tanks systems I learned work-
ing with "mom and pop" operators.
Some of the key lessons include:
•  Can we detect a  problem? Leak
   detection doesn't detect leaks, it
   simply frustrates  operators. Tank
   pulls are still the most reliable
   method of leak detection.
•  The rules are  too complicated.
   Today's leak detection options use
   high-tech systems for  low-tech
   operators,  meaning most opera-
   tors cannot do leak detection cor-
   rectly  because  the requirements
   are simply too difficult to main-
•  Diligence  detects  leaks,  not
   equipment. Leak detection is only
   as good as the diligence of those
   who are watching for leaks.
•  Streamline the program. The reg-
   ulations are simply too compli-
   cated for operators to manage. I
   vote to simplify the program in the
   following ways:  1)  Mandatory
   double-walled tanks with continu-
   ous, not  monthly, monitoring;
   2) Mandatory suction piping, and
  3) All deliveries monitored by
  both operator and driver. Phase
   out single-walled  tanks and pres-
  surized piping over  a 10-year
   Field inspections forever. Assum-
   ing the streamline approach sug-
   gested in the previous bullet is not
   realistic to implement, then the
   best thing we can do now is man-
   date  periodic  inspections  to
   increase the national  field pres-
   ence of inspectors and use effec-
   tive incentives, such  as tags, to
   discourage complacency. A state's
   ability to do both will best define
   whether  or not they have safe
         Lynn  Woodard (1988) -
New Hampshire DES  What have I
learned about UST systems? They
leak! In 1985 we were fortunate to
be able to require double-walled
containment for all new UST sys-
tems. That probably was the best
thing we could have done, along
with establishing a cleanup fund.
But you  have to have  a strong
enforcement program to make  a
cleanup   fund work,  otherwise
you'll be wasting money because
owners and operators will tend not
to comply. All of the money spent
on improving the UST infrastruc-
ture for the 1998 deadline will be
for naught if we don't have compli-
    With regard to tank installation,
the contractors were killing us— cut-
ting corners and changing specified
products. We had to train them. We
started to review plans and to be  on
site prior to backfilling of the system
to make sure that construction was
in  accordance  with the approved
design. We had to make believers of
the contractors. They had to know
we were serious. We'would halt pro-
jects until necessary changes were
made. Because of this, I think we got
a better product.
         Herb Meade (1978) -
Maryland Department of the Environ-
ment  What immediately comes to
mind is that containment sumps
should be mandatory for under the
dispenser and on the tank top. The
key is to come up with a design that
keeps the water out! Also, we need
                • continued on page 8

LUSTLiiie Bulletin 3S
m Dispensing Wisdom
continued from page 7
double-walled  piping.  In Mary-
land, 60 percent or more of our fail-
ures are  piping. Double-walled
tanks are  also a good option, but
there is a very good single-walled,
fiberglass-clad steel tank that we
have  never  seen  fail,  and  the
technology has been around since
about  1981. I'd want to see that
option remain.
    In terms of tank upgrading, tank
lining certainly hasn't worked in this
state. Impressed current cathodic
protection was hastily installed, and
tank owners are now paying the
price for that with ongoing tank fail-
ure and releases into the environ-
    One really good thing we did in
Maryland  was  to require  tank
installer and remover certification. It
got a lot of the fly-by-nighters out of
the loop and notched up the profes-
sionalism of the companies that do
the work.
    55ES Clark Conklin (1986) -
Nebraska  Fire  Marshal's   Office
Looking back over the years, there
are several matters that I wish we
had handled differently:
•  Tank upgrading should  either
   have not been allowed  or  more
   oversight   should  have  been
   required.  It appears that  there
   have been a number of  upgrade
   contractors who may have been
   too hurried to get to the  next job,
   thus leaving the last one without
   the quality  control we had all
   hoped for.
•  The decision to not require  inter-
   nal inspections  of tank linings
   when cathodic protection (CP)
   was   added  (in  the   upgrade
   process) was, in my opinion, irre-
   sponsible. This released  all lining
   contractors from virtually any lia-
   bility for  failed linings. The CP
   contractors are going to take the
   fall (at least initially) for  tank fail-
•  Generally, the independent (mom
   and  pop) tank owner has been
   removed from most compliance
   issues as they do not have tike time
  or the technical expertise to fully
  understand the requirements (at
  least here in rural America). While
  most of the regulatory dialog is
  between the  regulator  and the
  contractor, all of the responsibility
  for compliance falls on the owner.
  It wouldn't surprise me if owners
  might  think  that  there is some
  kind of a conspiracy between the
  regulators  and the contractors,
  based on the fact that the regula-
  tor directs him to comply with
  something he doesn't understand
  and his contractor makes him pay
  for it.
• Then there are the state cleanup
  funds.  Because of the high cost of
  remediation,  the funds allow the
  cleanup of contaminated sites to
  actually occur. Many tank owners,
  such as those I've just been talking
  about, do not have the resources
  or the  insurance coverage to pay
  the bill for site cleanup. However,
  think about this for a minute. The
  tank owner has a leak. The regula-
  tors rush in and require hoards of
  outside contractors to repair, eval-
  uate, drill, calculate, and propose
  fixes that  are  based on MCLs,
  RBSLs, and  other unexplained
  acronyms.  The  regulator then
  arrives on the scene, checkbook in
  hand,  and  pays for the cleanup.
  Where is the incentive for tank
  owners when the government and
  the contractors are in control of
  the-entire process?
• Contractors  do  the  work, but
  when it's done incorrectly or not
  at all the tank owner is penalized.
  Some  regulatory responsibility
  needs to be shared by tike contrac-
  tors if they  are playing such a
  large part in this process.
• There  are  many problems with
  leak detection techniques. The UC
  Davis  study  (Field Verification of
  UST System Leak Detection Perfor-
  mance) bears  this  out. Many folks
  feel that secondary containment is
  the best solution to  cure  leak
  detection's many ills. I'm not nec-
  essarily convinced that this is
  always true. Tighter (^develop-
  ment of third-party protocols and
  stricter enforcement of leak detec-
  tion requirements would go  a
  long  way  in  helping  detect
    New regulations will not answer
all the questions and will certainly
cause new questions  to be asked.
What we really need is to diligently
enforce the requirements through
field actions and more of a hands-on
approach. Inspectors need more time
in the field with the tank owners, less
paper trail  loop  holes,  stricter
enforcement  strategies,  and better
training. Face  to  face  inspection,
enforcement, investigation, and train-
ing is what we need.
        David McCaskill (1986) -
Maine DEP  In my experience, to
have an effective UST program you
must have siting requirements, sec-
ondary containment, and a certified
installer program. In other words,
location matters, no tank has the
right to leak. And for Pete's sake,
doesn't it make sense that you need
a license to install a  system that
contains the most toxic and flam-
mable substance that the general
public will routinely be exposed to?
        Gary Blackburn (1979) -
Kansas DHE   One of my responsi-
bilities when I first started working
at the Kansas Department of Health
and Environment was to investigate
complaints regarding fuel contami-
nation of water wells, sewers, and
other structures. This  was before
UST regulations, and we performed
most of the work using  a small drill
rig the agency owned.  As a geolo-
gist it was a  great experience to
travel around the state drilling out
sites. I learned through this work
that  most  UST sites have had
releases to some extent. Often the
source of this contamination was
obvious, but other times it appeared
to be from an accumulation of spills
or a past release.

Release Prevention
In recent years, there has been much
discussion  on  whether  the new
release detection technologies  for
tanks are detecting leaks as intended.
This concern stems from the fact that
new releases  are still being discov-
ered. In reality, I believe most of the

                                                                                            LUSTLine Bulletin 38
 release detection systems probably
 meet their design specifications of
 either .1 or .2 gallons per hour when
 the systems are actually used. Based
 on those release detection standards,
 a  tank system can  theoretically
 release between 876 and 1,752 gal-
 lons per year and still comply with
 the regulations. Add to this the fact
 that a considerable number of UST
 facility employees who are responsi-
 ble for operating the systems are not
 well trained. So it is easy to see that
 we haven't worked ourselves out of
 a job yet.
    The  performance   standards
 established by EPA  are a huge step
 in  the  right direction, but I  don't
 think  those who developed  them
 ever   thought   these  regulations
 would eliminate tank releases com-
 pletely. They were only the first step
 in a program that will require us to
 continue to monitor systems and to
 respond to the releases that we dis-
    I don't believe that it is reason-
 able to ask tank owners to again
 invest in more advanced systems
 than what have been installed under
 the current laws.  I am not convinced
 that an affordable system exists or
 can be developed that could com-
 pletely eliminate releases. We should
 first employ methods to determine if
 all  of the active systems have been
 upgraded  to the current standards
 and that the required release detec-
 tion activities are being performed.
    I  am confident that the vast
 majority of active UST facilities in
 Kansas have been upgraded with the
 equipment required by the 1998 stan-
 dard. This confidence comes from
 our UST permitting program and
 licensing of installation contractors.
 To complement the permitting, we
 had a targeted inspection program to
 check all of the systems that were not
 upgraded to ensure  that they were
 taken out of service. During the 2000
 and 2001 permitting process, Kansas
 has required that tank owners who
 perform a  monthly  monitoring
 method of  release detection submit
 evidence that the system is actually
being operated properly. They must
 submit copies of their tank monitor-
ing or SIR reports with their annual

 Corrective Action
The other  element that has been
incorporated into the Kansas pro-
 gram is a realization that the active
 UST facilities will continue to create
 contamination, even when operating
 according to the program require-
 ments. With this in mind, Kansas has
 used a priority ranking system since
 1992 to determine the appropriate
 corrective action for each site.
     For example, it makes little sense
 to perform a $100,000 cleanup at an
 active fuel dispensing facility that
 poses no risk to the public. The site is
 most likely going to cause additional
 contamination after the cleanup is
 complete. A more practical approach
 is to install a monitoring system and
 perform monitoring with free prod-
 uct recovery to manage the facility as
 a contaminated site with the goal of
 preventing the plume from migrat-
 ing  to a receptor. This type of site
 management is  possible  because
 Kansas uses a  state-managed trust
 fund as a financial responsibility
 method. The sunset date  for  the
 Kansas fund has been extended to
    Where a site poses a risk to water
 supplies or other receptors, the site
 will obviously need a more compre-
 hensive remedial response.  The
 Kansas program has focused on per-
 forming source area remedial mea-
 sures to remove the largest mass of
 contamination with the least effort
 and cost. Rather than trying to cap-
 ture plumes by chasing them with
 pump-and-treat  or  elaborate  air
 sparging systems, we require exten-
 sive monitoring around threatened
 water supplies so that treatment sys-
 tems can be installed where neces-
 sary. If possible, the well owners are
 encouraged not to use the wells until
 the cleanup is complete. Where areas
 are  served by private wells,  the
 response is often to extend public
 water to the threatened parties.
    The move  many states have
 made to RBCA-based standards is a
 step in the right direction. However,
 closing sites where active tanks are
 in use may not be a sound decision if
 you believe, as I do, that the UST sys-
 tems are likely to release fuel again
 in the future. This  contamination
 may not be from the UST system per
 se but may result from surface spills.
   In many cases, we have been leav-
ing most of the monitoring wells and
remedial system piping in place at
facilities where a future release is
likely. The suggestion has also been
 made that UST owners should install
 soil vapor extraction  (SVE) piping
 with their new tanks and lines. Since
 the tank systems must be installed in
 granular material, the SVE systems
 should work very well if needed in
 the future. If  the  SVE pump  is
 installed, periodic operation would
 allow for testing of the effluent to
 determine if a release has  occurred
 and  can provide  ongoing vapor
 removal if operated on a regular basis.
    The number of releases discov-
 ered across the nation remains high
 for  several reasons. Many  of the
 releases reported to Kansas are dis-
 covered from the systems that were
 taken out of service prior to the new
 rules. Much of the concern about con-
 tamination being detected around
 new tank systems may actually be
 that the prior systems leaked and the
 environmental assessment did not
 detect the release when the old tanks
 were removed. In Kansas, the vast
 majority of assessments have been
 performed by agency staff, who have
 confirmed a very high percentage of
 releases. I am convinced that a large
 number of contaminated sites from
 historical USTs will continue to be
 discovered as real estate develop-
 ment takes place.

 Risk Management for Tanks
 All of the state and local agencies are
 limited by budgetary  concerns, so
 limited resources  must be used
 where the maximum benefit can be
 realized. The UST programs should
 be operated with a risk management
 focus. To accomplish this,  the first
 step is to determine where the most
 significant risks are within your state
 and then to work  with all of the
 stakeholders to manage those risks.
    A  real priority should  be  to
 determine where fuel is stored in
high risk locations, such as near pub-
lic water supply wells, and then to
 direct more resources toward reduc-
ing those potential risks.
    Each state should work within
its system to establish the safeguards
that work best with the local geology
and politics. I don't believe that new
national regulations are the answer
to  the  continuing releases from
tanks. I think it's time for the states
to fine-tune their programs to meet
the overall goal of public safety.

    What are your thoughts? •

WSTLine Bulletin 3S
The Sense of Secondary


by Wayne Geyer

 "\  TaS8^lS revelations ofMTBE in groundwater have undermined the tenets of
 I \ I gasoline behavior in the environment and set off a flurry of activity among
JL \ UST regulators and state and federal legislators. How could we get into this
position when so much time and effort went into upgrading underground storage tank
(UST) systems? And while a great deal of attention has been directed toward the effec-
tiveness and proper design of leak detection to meet federal requirements, there is still
concern that the leak detection equipment that is in place may not be operated or main-
tained properly. As a result, many UST systems may operate as if they had no leak
    One solution to this problem is to install equipment that will passively contain a
release before it can permeate into the environment. Clearly, secondary containment
tank and piping systems have performed this function effectively and continue to rep-
resent the state of the art for containing petroleum releases. Secondary containment
makes good sense from both an environmental and a business standpoint.
    Both fiberglass reinforced plastic (FRP) and steel double-walled tanks are now
well established in the market place, but single-walled systems are  still out there in
abundance. STI records indicate that over 60 percent of new tanks bearing the STI
label are of single-ivalled construction. I'd like to take this opportunity to stroll down
secondary containment lane. As a representative of the steel tank industry, I'll discuss
the sense of secondary containment using steel tank examples (of course).
Dual-Wall Tanks
Secondary containment tanks first
appeared in the United States in the
early 1980s, when certain local and
state jurisdictions were beginning to
investigate and promulgate rules for
hazardous wastes and chemical stor-
age. Secondary containment was one
of the solutions.
    In California, the first secondary
containment steel tanks were termed
Type II double-walled tanks. The two
walls of steel were physically sepa-
rated with angles or channels to cre-
ate an annular interstice of several
inches. The goal of this design was to
create an enclosure that would hold
110 percent containment of the pri-
mary tank capacity.
    But these systems were  costly
and bulky, and the industry needed
a more  cost-effective design. The
industry soon realized that there was
no need to contain 110 percent of the
tank's  capacity—100 percent was
sufficient. Later, with the introduc-
tion of fill-limiting devices designed
to stop incoming deliveries to 90 or
95 percent of the tank capacity, sec-
ondary containment tanks with 95

percent  containment  were  also
    In 1984, the Steel Tank Institute
(STI) introduced  the first national
construction standard for secondary
containment  tanks. It provided  a
design for  a Type I, intimate wrap
steel secondary containment tank,
with several alternative construction
methods for enabling the interstice to
be monitored for releases (i.e., liquid
or pressure sensors). The standard
even allowed for a simple gauge stick
to be lowered into a monitoring pipe.
    The STI standard was based on
German technology.  In Germany,
secondary containment had already
been in use for a number of years. As
a matter of fact, the Germans really
didn't regulate corrosion protection
at that time.  As long as secondary
containment was in place to prevent
a release, the time to replace a system
that failed due to corrosion was
merely an economic decision and not
an  environmental  concern.   STI
adapted the  German construction
methods to American tank produc-
tion methods in order to create the
Dual-Wall Tank Standard.
    A year later, changes were initi-
ated to incorporate secondary con-
tainment    into    Underwriters
Laboratories (UL) listing UL 58, the
primary steel UST construction stan-
dard. Several UL listings for dual-
wall tanks had already been issued
prior to 1985 for both the steel and
FRP tank industries.

The Jacketed Tank
Around 1987, nonmetallic secondary
containment on steel tanks emerged
as a popular concept. A thick poly-
ethylene material was wrapped over
the tank, and a polyethylene spacer
created the  interstice between  the
two materials. The idea of using plas-
tic over a steel tank was actually con-
ceived many years earlier for  the
purpose of corrosion protection, not
containment. Around  1970, many
steel tanks were wrapped with thin,
overlapping plastic  sheets sealed
together by duct tape in the field.
One such system was called Poly-
Wrap. By keeping soil and water
away from the  steel surface, corro-
sion could be successfully impeded.
    The  Poly-Wrap   system   did
inhibit corrosion in many cases, but
lost popularity because it required
installation under less than perfect
field conditions, making it particu-
larly dependent on installer care  and
expertise. It eventually faded from
the market, to be replaced by more
sophisticated corrosion control sys-
           tems. The newer poly-
            ethylene material used
            to  provide secondary
            containment was much
               thicker than Poly-
                Wrap. The sheets
                   of plastic were
                    fused together

                                                                                             LUSTLine Bulletin 38
 with, a plastic welding machine at the
 factory to make it testable and capa-
 ble of containing releases. By 1989, it
 became a viable product in the mar-
     In that same year, Underwriters
 Laboratories published their UL 1746
 standard. The third part of the stan-
 dard  provided a test protocol for
 nonmetallic containment of steel
 tanks and coined the term "jacketed
    STI tested several prototypes for
 secondary containment of steel USTs.
 We tried coated fabric material that
 had to be sewn together. When filled
 with air  it looked like a zeppelin.
 When emptied of air it turned into a
 wrinkled baggie. Strike one!
    We tested different coatings that
 were sprayed through various forms
 of geotechnical reinforcement materi-
 als. Great ideas, since they could be
 used in conjunction with existing
 coating equipment in the shop.  But
 we just couldn't permanently seal the
 system. Strike two!
    How about using FRP? Compos-
 ite tanks had already been accepted in
 the  market  by  buyers and  were
 allowed in the 40 CFR Part 280 envi-
 ronmental  regulations  (ACT-100).
 Historically, an FRP coating had been
 shown to be an effective method for
 corrosion control (originating  in the
 1968  STI  specification for  STI-LIFE
    Instead of bonding the FRP to
 the steel to form a coating, however,
 we decided to separate the two and
 create  an  interstice  to  contain
 releases.  The interstice  could be
 monitored for releases while also
 assuring  corrosion control. Home
 Run! By 1990, several companies had
 begun testing their products through
 UL to acquire a listing for an FRP-
 jacketed steel tank.

 Getting Better All  the Time
 The jacketed tank and the dual-wall
 steel tank rely on the primary or inner
 steel tank for structural integrity to
 hold the product in an underground
 environment. The outer containment
 must be strong enough to be handled
 at the job site and in the soil without
 losing its integrity. With the jacketed
 tank,  the  material must withstand
 various chemical/soil environments.
All of the tanks must be testable and
 able to communicate  a release to a
monitoring device. Approximately
  The truth of the matter is that as
   long as the human element is
   involved, mistakes can still be
 made. Secondary containment adds
^ a reliable measure to protect the
     environment against such
 one of three STI-labeled secondary
 containment USTs  are  of jacketed
 construction and two of three are
 dual wall steel.
    Today, new materials continue to
 evolve and to be developed for use as
 secondary containment. Usually, the
 first step into the marketplace is to
 pass the UL 1746, Part III test proce-
    While fewer than 10  states man-
 date secondary containment for reg-
 ulated USTs, use of the  technology
 continues to grow—nearly 50 per-,
 cent of all steel  USTs made in the
 USA today are believed to be sec-
 ondary containment tanks. When the
 EPA regulations were first promul-
 gated in 1988, this number was closer
 to 15 percent.
    Even greater strides have been
 made  outside the United States. In
 many  countries,  tank buyers have
 leaped from buying unpro-
 tected steel tanks to buying
 corrosion-protected   sec-
 ondary containment tanks.
 Mexico is nearly complete
 with its secondary contain-
 ment tank system upgrade
 program. The most popular
 STI-labeled tank installed in
 Mexico is the dual wall sti-P3
    The European Commu-
 nity issued a series of laws
 that apply to  all member
 countries, similar to the man-
 ner in which the U.S. EPA
 UST program is applied to all
 states.  One of these laws is
 through  the  Construction
 Products Directive (CPD). One way to
 ensure compliance  with essential
 CPD requirements is to build prod-
 ucts to harmonized standards.
    The European Standards body,
CEN, recently published a harmo-
nized standard EN 12285-1 for the
construction details of underground
      steel storage tanks. An appendix lists
      all the "water-polluting liquids" nor-
      mally  stored  underground  and
      includes a determination of whether
      the liquid is considered dangerous
      enough to mandate a double-walled
      tank with leak detection. Gasoline is
      considered dangerous and therefore
      all European Community partici-
      pants' tanks that store gasoline must
      be of double-walled construction
      with leak detection.
         The  province  of  Ontario  in
      Canada  is about to adopt  a  sec-
      ondary containment mandate. Yet in
      the United States, nearly one of every
      two steel tanks  built and sold is of
      single-walled construction.

      Where the Sense Comes In
      I can think of four key reasons why
      the use of secondary containment for
      petroleum storage should be a patent
      no brainer. It provides the following:
      •  Containment to prevent a release
        into soil and  all the undesirable
        elements that go with a release—
        report writing, cleanup, lawsuits,
        business interruptions;
      •  An extra insurance policy, just in
        case the  tank was improperly
        installed or maintained;
      •  Peace of mind; and
      •  State-of-the-art technology.
Percentage of STI-labeled USTs since 1990, representing
 over one billion gallons of storage capacity installed.
        Representing one segment of the
     petroleum equipment manufacturing
     industry, our industry likes to think
     that our systems are infallible. But the
     truth of the matter is that as long as
     the human element is involved, mis-
     takes can still be made. Secondary
     containment adds a reliable measure
                    • continued on page 23

                              It Can  Do  That?
                              Florida's Prescription for Identifying a Facility's
                              Release Detection Method and Having Some
                              Confidence That It Actually Works
by Ernest Roggelin and Joseph Sowers
 "ft is another hot and humid morning in Pinellas County, Florida. The UST inspector strides to the counter of a convenience
 I store. He identifies himself and explains that he is there to conduct the routine annual compliance inspection. He then moves
JL outside to complete tasks that include visually inspecting dispenser interiors, subsurface piping areas, spill containment buck-
ets. He takes the customary peek into the drop tube to ensure that no gauging stick has been strategically stored there.
    Now that the "physical" portion of the inspection is done, the inspector turns his focus to recordkeeping requirements and the
automatic tank gauge (ATG) system, which the facility has reported as its primary method of release detection its USTs. The inspec-
tor inquires as to the location of the ATG controller.
    "You mean the box that prints out the little slips? " replied the clerk. "It's in the back here."
    As the inspector approaches the unit he notes that it must be Christmas in July. Not only is the green power indicator lit but the
yelloio warning and red alarm indicators are flashing. Hanging from the box is a slip of thermal paper with the word "FAIL" - the
result of the static test for Tl (read as Tank 1) completed the previous weekend. Back to the counter.
    "Did you realize that the unit in the back is in alarm?" asks the inspector.
    "You mean the flashing lights?" answers the clerk. "Been like that for weeks now. It also has an irritating buzzer that goes off
every morning, but that's pretty easy to turn off."
    "Do you understand that 'the box' is indicating that Tank 1 has a leak? " says the inspector.
    "Really?" says the clerk with amazement.  "I didn't know it could do that!"
The Reality of Rules
The above scenario is repeated more
than any regulator would like, and
definitely more often than owner/
operators are willing to admit. There
are many owner/operators out there
who don't know the capabilities of
their release detection equipment or
whose  "clerks" who  don't  know
what to do  when the lights and
buzzers go off—or both!  With the
inception of a revised rule in July of
1998, the State of Florida made an
attempt to limit this. But before we
get to that, a little background.
    Since the inception of the Florida
Department  of Environmental Pro-
tection's (DEP's) storage tank system
rules  in  1984, there  have been
requirements for owner/operators to
provide and monitor their varying
forms of  release detection. In the
early years  of the program, most
owner/operators chose groundwa-
ter-monitoring wells as their method
of leak detection. The options have
changed  with the  technological
advances in  both storage tank sys-
tems and monitoring methods.
    Currently, about half of the USTs
in Florida have secondary contain-
ment with interstitial monitoring, the
other half must have secondary con-
tainment by 2010. Facilities with sin-
gle-walled   petroleum    storage
systems in Florida can select from the
following leak detection options: sta-
tistical inventory reconciliation with
3-year tank precision tightness test-
ing, continuous automatic tank gaug-
ing   (ATG),  static   ATG   with
three-year tank precision  tightness
testing, vacuum/sensor/visual mon-
itoring,  annual system  tightness
testing with daily inventory reconcili-
ation, groundwater or vapor moni-
toring wells, manual tank gauging,
and either mechanical or electronic
line leak detectors.
    The basic tenet of Florida's tank
program has been to eliminate, or
more realistically to reduce, the pres-
ence and associated effects of petro-
leum in and on the  environment.
Florida classifies petroleum releases
into incidents (suspicion) and dis-
charges  (confirmation),  requiring
reporting procedures that generate a
timely "contain, remove, and abate"
response. The compliance inspector
in essence charts facility history and,
through  an  ongoing  educational
process, helps the owner/operator
understand  what is required  to
achieve and maintain  compliance.
Occasionally a stronger nudge via the
enforcement process is necessary to
encourage compliance.

No More Excuses
During the period spanning  1984
through  early  1998,  compliance
inspectors   observed   interesting
release detection field conditions and
listened to a variety of excuses dur-
ing the course of their inspections.
Findings and excuses included the
inability to find all the wells, locks
rusted shut, submerged sensors, no
keys to the dispenser, burnt out panel
lights, "it's been like that for weeks,"
units hidden behind the stacked soda
cases, no tapes, silenced alarms, "it
always flashes," or  no concept of
what  constitutes  a valid  release
detection method. But again, the
inspector is an  "after the  fact"

                                                                                            LUSTLine Bulletin 38
 examiner of release detection history.
    With the July 13,1998, update to
 Florida's storage tank system rule,
 facilities now have  to provide  a
 Release Detection  Response Level
 (RDRL) document. The rule requires
 that "A RDRL shall be described in
 writing for each method or combina-
 tion of methods of release detection
 used for a storage tank system."
    No  longer are the  excuses  "I
 didn't know what to do" or "What
 does  that mean?"  valid for the
 owner/operator. The  RDRL  can
 range from a simple checklist to  a
 more complex response action docu-
 ment. For each facility,  owners and
 operators must provide the following
 information about release detection:
 what method they have, what it does,
 and when they are supposed to do
    A generic checklist was initially
 developed  by  the  Hillsborough
 County Environmental  Protection
 Commission tank  staff and  later
 adopted by the DEP as a tool for the
 field inspector to give to a facility
 owner/operator. The checklist can be
 as simple as: method  - visual moni-
 toring of sumps; action - observation
 of water above the  piping penetra-
 tion level or the presence of  free
 product. Or,  it could be as sophisti-
 cated as the Amerada Hess Corpora-
 tion's  "Leak Detection  Monitoring
 Procedures." These laminated cards
 provide classifications for 34 differ-
 ent release detection combinations in
 Hess's Florida UST systems, describe
 tank and piping construction, list the
 pertinent leak detection method, and
 on  a daily/weekly/monthly basis,
 list the responsibilities of facility staff,
 along with required documentation
 and reporting obligations.

 On to Repair, Operation, and
 Once owners and operators suppos-
 edly knew how their release detec-
 tion systems worked and when they
 are supposed to initiate a response,
 Florida  began  to  focus  on  the
 mechanical/electronic portions of
 these   systems—do  they  actually
work as intended,  or not? In the
Repair, Operation, and Maintenance
 section of the rule, there is a require-
ment that:
 "All release detection devices shall
 be  tested  annually  to ensure
 proper operation. The test shall be
  Did you realize that the unit in the back is in alarm?
  conducted according to manufac-
  turer's specifications  and  shall
  include, at a minimum, a determi-
  nation of whether the device oper-
•  ates as designed."

    In Pinellas  County, we  have
interpreted this requirement to mean
that the owner/operator of the facil-
ity must demonstrate that the sensor
or detector actually functions versus
simply receiving a "pass" test report.
On a monthly basis, an owner/oper-
ator may be testing an alarm horn, a
panel light, or reading an ATG-con-
troller history report.
    For the annual test, we want to
see the owner/operator place the sys-
tem into alarm and have the compo-
nent detect the condition. It can be as
simple as observing facility personnel
invert a float sensor and noting that
the ATG-panel went into alarm on-
site or at a remote location. Recently,
Tanknology, Inc. has begun using a
detailed Monitoring System Certifica-
tion form, based  on a  California
reporting requirement. The multi-
page form provides for an equipment
inventory, as well as a step-by-step
results-of-testing checklist.
    There has been some controversy
regarding the phrase "according to
manufacturer's specifications." Spe-
cifically, an ATG-controller manufac-
turer indicated to  the  DEP that
annual testing is not required for its
equipment. They assured the agency
that nonauthorized personnel han-
dling of the equipment might void
the warranty. The Florida DEP's legal
section responded by stating that the
rule requires annual testing, regard-
less of the manufacturer's claims. If
no specified method exists, then a test
method must  be developed by the

Have Our Requirements
Hmm, sort of, maybe, yes? The RDRL
requirement has made it clearer to
the  inspector  what  the  primary
release detection method or methods
are for a facility. It has also caused
owner/operators to think through
their release detection options and
formulate a "check list" that shows
personnel what to look at and when
further action is required. Granted
               • continued on page 14

LUSTLiue Bulletin 38
m It Can Do That?
continued from page 13
this requirement is more effective for
the conscientious owner/operator.
Alas, there are still instances when
"alarms" have gone off, and store
personnel still have made no attempt
to take appropriate action.
    With regard to the annual testing
of release detection devices, we have
an increased level of comfort that the
systems are functioning. All of this
leads to additional recordkeeping
requirements, and we can state with
heartfelt certainty that record reviews
continue to be the bane of the UST
inspection. How much detail do you
want to see—per tank, per product,
daily, weekly, monthly, annual, back
to the last inspection, or for the past
two years? Records also continue to
be a significant part of the noncom-
pliance problem.
    For example, during the period of
July 1999 through March 2000, Pinel-
las County performed 567 annual
compliance inspections out of a total
of 727 inspections. This timeframe
began one year after the rule revision
took effect.  Total noncompliance
items written numbered 1,835. The
prominent noncompliance categories
were incomplete records availability
(22%), no demonstration of financial
responsibility (8%), no RDRL (5%),
lack of annual release detection test-
ing (5%), lack of monthly visual exam
(4%), liquids in sump/liners (4%),
incomplete monthly release detection
(4%), lack of line-leak detector testing
(3%), incomplete repairs (3%), inci-
dents not reported (2%), and failure to
upgrade (1%).
    Then there is Florida's shift away
from  the  state-funded reimburse-
ment   program   for   discharges
reported on/after  January 1, 1999.
Corrective action coverage is now
handled as part of the petroleum lia-
bility insurance package that  the
facility must possess. Has this change
in   funding  put  a  damper  the
owner/operator's incentive to report
a discharge?  Owners know that
reporting  a release leads to  site
assessment and remediation tasks.
The discovery of an incident simi-
larly leads to an investigation, all
with a financial burden on the facil-
ity. In contrast, failure to file an inci-
dent  report represents a  minor
violation, not a significant threat of

penalty to insure timely reporting by
the facility.
   During  the  period  of January
2000 through April 2001, Pinellas
County received 235 incident notifi-
cations. Of that number, 22 were con-
firmed to represent a discharge event
(2 AST overfills, 14 closures, 3 con-
tractor accidents, 1 line failure, 1 AST
siphon event, and 1 unknown). The
remaining incidents included 43 SIR
failure or consecutive inconclusive
results, 63 visual or sensor liquid-
presence  alarms in sumps or dis-
penser liners,.  12  tank  interstice
alarms, 3 overfills, 2 PLLD alarms, 4
failed tightness tests, 75 ATG-alarms
for failed leak rate, 18 closure-related,
and 13 other.
 '-,'•' It still boils down in the end to
   education. While we might like to
    think that it is easier to takejhe
 1  "traffic cop approach" — it is their
 n   business and they should have
 i     )          ;
   known better—the fact is, we are
 I not traffic cops, and enforcement is
   "much more complicated and time
        M I  I III   ' f J I11 |    n     m  liiin
       consuming than merely
         1  writing a ticket.
    What does all of this represent?
 A cynical view would be that nothing
 has changed and that the inspectors
 are still noting the same issues. The
 types of records have changed. We
 now. have electronics, the supposed
 cure-all for continuously monitoring
 the status of a system. There is just
 more to go wrong now.  There are
 more records to look at, and there is
 another level of quality assurance to
 be confirmed by the facility. On the
 plus side, there are a lot more secon-
 darily protected systems, and release
 detection is picking up events (e.g.,
 product/liquid in sump  and dis-
 penser liners, water/mud in tank
 interstice)—the 213 incidents that did
 not result in a discharge are signifi-
 cant in their own right.

 Still Boils Down to Education
 With all our requirements and the
 sophistication/diversity  of release
detection equipment, it still boils
down in the end to education. While
we might like to think that it is easier
to take the "traffic cop approach" —
it is their business and they should
have known better—the fact is, we
are not traffic cops, and enforcement
is much more complicated and time
consuming  than merely writing a
ticket. Let's remember that there are
some basic truths associated with the
UST world:
•  Many owners who have no prior
   business  experience, let alone
   petroleum  storage  experience,
   continue to purchase facilities.
•  Release detection systems can be
•  Reading and comprehending our
   rules can be daunting, to say the
•  Education reflects the true mis-
   sion of our jobs—protecting the
   ground and surface waters of our
•  The effort to  educate fosters the
   perception that we as regulators
   are there to help  and not just to
•  Educating owners, for the most
   part, brings the facility into com-
   pliance and  makes  next year's
   inspection "easier."
So given our UST requirements, the
myriad of release detection options,
and the relentless turnover in facility
personnel, it seems fairly certain that
the inspecting agency will continue
to be (depending on your point of
view)  charged or saddled with  the
job of either providing the training or
being the impetus for the facility to
improve its  level of training and per-
formance. •

 Ernest M. Roggelin is an Environmen-
   tal Manager over Pinellas County's
   Storage Tank Compliance and Petro-
   leum Cleanup programs. Joseph A.
  Sowers is an Environmental Specialist
    III performing CIS/Enforcement
   Tracking/Technical Support, along
  with inspector-training for the Florida
 DEP. The Environmental Engineering
 Division of the Pinellas County Health
  Department contracts with the Florida
    DEP to inspect 777 facilities with
    2,084 UST/ASTs. There are three
          field inspectors.

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


                                                                                         LUSTLine Bulletin 38
 Selling the Healthy  Choice
 The Human Side of UST Enforcement
 by Jackie Poston

 Editor's note: This article is based on a
 presentation Jackie gave at the 2001
 UST/LUST  National Conference  in
 Albuquerque, New Mexico. That presen-
 tation was an appetizer of sorts for the
 "Full Meal Deal" panel on Operations
 and Maintenance (O&M).

       One of the biggest challenges
       regulators face is getting the
       attention of tank owners. A
 typical UST owner/operator faces an
 ever-changing kaleidoscope of regu-
 lations from a multitude of agencies
 at local, state, and federal levels. In
 reality, we live in a busy and compli-
 cated society, one in which business
 owners, like it or not, have to adapt.
 As regulators, we need to be cog-
 nizant  of this  uniquely human
 dilemma, because,  like it or not,
 we're bobbing around in the same

 To illustrate my point about  our
 mutual humanness, I offer this quiz:
 •  Look at the time. Are you wearing
   a  watch?  Can you recite and/or
   produce the warranty and techni-
   cal information that came with it?
 •  Have you read a copy of your
   vehicle manual in the past couple
   of years, and have you had all the
   recommended periodic mainte-
   nance performed?
 •  How about the details of your car -
   insurance? Do your  know your
   deductibles and amounts of cov-
 •  Do you know the details of you
   homeowner's policy?

   If you didn't keep  paperwork
and warranty for the watch, you have
a lot in common with  many tank
owners. You probably figured it
would operate for a  long time, cer-
tainly for  the warranty period. Or
you may have felt that if it did give
out, the cost wouldn't outweigh the
risk of not sending in the warranty
 card—something like the thinking of
 many an UST owner.
    How about your insurance pre-
 mium? Do you know the terms and
 details of  your coverage? Do you
 trust the insurance expert to provide
 you  with  the  coverage   you
 requested? Most of us do. How many
 owners and operators have invested
 in  equipment  and  trusted  the
 installer to provide them with what-
 ever the regulations require?
    Now you may say, "Yes, but a
 tank system is a much bigger invest-
 ment than a watch or an insurance
 policy." I agree, but not reading the
 fine print is, well, all too human. But
 then again, I've found, and studies
 have  shown, that once people are
 informed  and "get it" and under-
 stand the consequences, they're more
 likely to comply. The percentage of
 people wearing seatbelts demon-
 strates this concept.

 The Full-Meal Deal
 So how does a regulator go about the
 business of enforcement today? With
 federal regulations in effect now for
 over  10   years,  owner/operator
 "hand-holding" may not be as crucial
 as it was in the  past. However, it is
 imperative that as we enforce the reg1
 ulations, we do so in a considerate
 yet effective manner. Inspectors in
 today's world need  to be able to
 "hold-hands" by shaking with their
 left hand and writing a citation with
 their right hand. It's a social art akin
 to that of delivering hot coffee on a
 high wire. So how do we do this?
    As regulators, we need to focus
 on how we go about selling, yes, sell-
 ing, our product—operational com-
pliance. To  do this we must begin to
think about how we do what we do
in our encounters with the regulated
community during inspections and
other interactions. Whether we "reg-
ulate" through education and assis-
tance  or by  taking  enforcement
actions, we are selling a product, and
 we can only succeed if the regulated
 community "buys!"
    To get our teeth around the busi-
 ness  of UST inspections, let's  try
 thinking in terms of food—the "full-
 meal deal." The basic elements of the
 full meal deal are:
 •  Regulations and associated guid-
 •  Communication, and
 •  Guiding principles.

    Knowledge of regulations and
 associated guidance is critical, and
 you must be fluent enough in this
 area to go on "auto-pilot." It's not
 imperative that we know every detail
 of all regulations, policies,  and so
 forth, but  we should be familiar
 enough with them to be able to navi-
 gate our way through appropriate
 reference materials. This represents
 the main menu—the burger and the
    Communication is the vehicle
 that brings the regulations and guid-
 ance to life. It's the grill on which the
 food is cooked! It's the tool used to
 convey the rules and regulations—
 the outreach publications and docu-
   But it's  the  presentation that
 really counts— serving up the food
 and bringing it to the table. The prin-
 ciples that guide our delivery are the
 elements necessary for making the
burger and fries so appealing that the
 customer can't wait to dive in. We all
know how "bad service" in a restau-
rant can result in a negative dining
experience—food is never quite  as
appetizing as it might have been and
guests are less inclined to return. As
regulators, we too need to serve up

               • continued on page 16


LUSTLine Bulletin 33
• The Healthy Choice
continued from page 15
our agenda in such a way that people
feel positive and want to comply.
   I  understand the  difficulties
inherent in  balancing compassion
with consequence and  compliance
assistance with enforcement. Deliver-
ing the right mix is unique to each sit-
uation—there  will   always   be
circumstances that require nothing
less than standard enforcement.

The Sales Pitch
So, how can we reach owners and
operators? How can we make them
care? And what  are  we  trying to
achieve  with operational compli-
ance? Is it about taking people out of
the equation or having them take
responsibility? For this program to
really work, I think the answer must
be the latter. As our technocracy
busily  tries to develop the most fool-
proof  UST  technology to operate
independently of people, I firmly
believe that we must work harder to
involve people.
    Operational compliance is all
about changing UST owner/operator
behavior to ensure that their facility's
environmental safeguards function.
Individuals  will  comply  either
because they want to or because they
have to. Does it matter which? I think
it does. Ideally, compliance should be
born from the clear understanding
that it is highly desirable to prevent
    It's up to us  to provide a com-
pelling argument, or "sales pitch" if
you   will,   so  that   when  an
owner/operator  approaches   the
"Full Meal  Buffet," he/she makes
"healthy choices!" What can we do to
effectively market  the operational
compliance of USTs? Lef s dissect the
steps mentioned earlier a bit more.
    Communication  and guiding
principles consist of the following
 * Listen and observe.
 • Speak so you are heard.
 • Deliver your message.
 • Perform your duties.
 • Speak to effect change.
    The successful combination of
communication and guiding princi-
ples begins passively through the art
of listening and observing. Who is
this person? How does he communi-
cate (e.g., is the vocabulary simple or
sophisticated?)?  Express  himself
emotionally (e.g., ho-hum,  anger
about some government regulation,
personal struggles)? What are her
personal values? Does she "get" the
environmental connection? Is profit
the bottom-line and the only line? Is
he an  all-business, straight-to-the-
point type or more light-hearted? As
far as  you are concerned, it's not
about who you are, but who they
need you to be.
    Next, take what you've learned
and speak so the tank owner/opera-
tor hears. Approach the conversation
in a "language" that he or she can
relate to. When people are  made to
feel comfortable, they are more likely
to listen to what you have to say.
 „. Individuals will comply either
if" * because they want to or because
r they have to. Does it matter which? "I
  " think it does. Ideally, compliance
  - should be born from the clear
 _    i
 *  understanding that it is highly
 *"1 h desirable to prevent releases!
      i   i    i'  i  i   s.   	«_.
    Once you have their attention,
then you can deliver your key-under-
lying message, a message designed to
foster  a  personal  desire  to  care,
assume  responsibility,  and  take
action. The essence of tills message is
that leak prevention is about protect-
ing human health and the  environ-
ment. It's about the air we breathe,
the water we drink, and the world we
leave for the generations to come. If
you think this will all sound too
hokey for the tank owner, then work
on your delivery, because  the mes-
sage is too important.

Promoting Change
In the process of performing your
duties, be they inspecting,  conduct-
ing  compliance assistance  visits,
speaking at workshops, or  negotiat-
ing settlement agreements, always
speak to effect change. Put yourself
in the position of the doctor examin-
ing the patient, diagnosing an illness,
and prescribing a cure—chronic leak
detection violations where a leak has
not yet occurred. How you commu-
nicate the potential seriousness of
this to the patient is critical. Empathy
helps. The punishment approach can
be counterproductive. Can you imag-
ine informing a patient who's over-
indulged  in  a  few too many  full
meals that they should have known
the  consequences  because,  for
heaven's sake, the studies have been
out and well-publicized for over 10
years now?
    Informing  tank  owners  that
they've missed the boat and taking
enforcement  action says a lot.  The
compliance orders we issue will  also
seek corrective measures. But let's
challenge ourselves to go beyond, to
hope that we've inspired a change in
attitude that will survive beyond the
life of the inspection, seminar, or
enforcement action.
    Emphasis on  the  manner in
which we deliver  our enforcement
actions has been notably absent in
state and federal regulatory staff
training. What is typically missing in
all this is the  "human factor." In
many cases it's intuitive, but training
can always enhance our awareness.
We need to start by talking about it.
We, as regulators, would be very well
served to break free from the bureau-
cratic  mold and would benefit by
availing ourselves of every opportu-
nity to do so.

Challenge Yourself!
Try out some new techniques during
future inspections and other encoun-
ters with the regulated community.
And don't be afraid to ask for feed-
back. Send out a survey to people
that you've inspected to find what
they have to  say about their experi-
ence. The only way to gain an honest
perspective on how well we're doing
is to ask our customers.
    The future success of our regula-
tory framework lies not in scientific or
technical advances nor in the Code of
Federal Regulations, it lies in our abil-
ity to acknowledge and accommodate
humanity. I'd ask that each of us think
hard about the meanings and the
responsibilities that we have as ambas-
sadors, not of a government entity, but
as protectors of the environment for
today and for the future. •

  Jacqueline Poston is U.S.EPA Region
  10 Enforcement Coordinator. She  can
            be reached at

                                                                                         LUSTLine Bulletin 38
  ueak Prevention
 by W. David McCaskill
 David McCaskill is an Environmental Engineer with the Maine Department of
 Environmental Protection. Tanks Down East is a regular feature o/LUSTLine.
 David can be reached at As always, we welcome
 your comments.

 There  Ought to be  a  Law!

 Maine's New UST Siting and Inspection Laws
     For the past couple of years I've
     been pontificating on the issue
     of siting and proper operation
of UST facilities. (See "Convenience
Is Nice,  But UST Systems Aren't
Potato Chips, " LUSTLine # 32 and
"The Tank That Never Leaked, Isn't
it High Time We Made  Sure  USTs
Don't  End Up  Where They Don't
Belong", LUSTLine #35.) There are
endless  examples nationwide of
releases  that have resulted  from
owner/operator inattention to their
UST systems coupled with an appar-
ent lack of knowledge on how to use
the release prevention  equipment
that   they've   purchased.   Many
assume  that compliance can  be
achieved conveniently through the
purchase of black box leak detection
systems.  Active management of the
thousands of gallons of toxic and
flammable liquids located at their
businesses is  not the   preferred
   It would be  nice to  think that
some day soon we'll see the success-
ful marriage of diligent tank owners
and trouble-free tank systems. In the
meantime, if we have to live with our
compliance conundrum, then at least
there ought to be a law to reduce the
risk of releases in and around sensi-
tive groundwater resource areas.
   I mean look at the picture on
page 18.  Is that  right? Should the
homeowners (assuming  they  were
there first) have to worry about a
high-risk groundwater contamina-
tion source located across the street
from their home and water source?
   Well,  I am happy to report that in
Maine we finally have an UST siting
 law, PL 2001-302, An Act to Protect
 Sensitive Geologic Areas from Oil
 Contamination, that addresses this
 issue. It took public outcry, political
 fortitude (a lot of staff time),  and,
 unfortunately, a  number of large
 releases to make it all happen, but it
 did. The law consists of two parts: a
 provision to protect existing water
 supplies  (i.e., public  and  private
 wells) and another that calls for the
 development of regulations to pro-
 tect future water supplies (i.e., sand
 and gravel aquifers).
    It has always been clear to staff at
 the Maine Department of Environ-
 mental Protection (DEP) that there
 are  places  where  there  should
 absolutely not be any gas stations or
 UST bulk plants.  This motherhood
 and apple pie concept became more
 apparent to our legislative committee
 this session (especially when they
 heard from a few mothers!).
    One other UST-related thing our
 legislature did during  this  session
 was to pass a law  requiring owners
 and operators of existing UST facili-
 ties to obtain certification of compli-
 ance with our current requirement
 for annual facility  inspections. More
 about that later.

 What Are We Protecting?
 Our new siting law protects  public
 and private water supplies and sand
 and gravel aquifers. Under the fed-
 eral  Safe  Drinking  Water  Act
 (SDWA), a public drinking  water
 supply is any well  or other source of
water that furnishes water  to the
public for human consumption for at
least 15 connections, regularly serves
 an average of at least 25 individuals
 daily at least 60 days out of the year,
 or supplies bottled water for sale.
    There are three types of public
 drinking water supplies: community
 (e.g.,  municipal  water districts,
 mobile home parks, nursing homes),
 non-community transit (e.g., motels,
 restaurants, campgrounds), and non-
 community non-transit (e.g., schools
 and business with 25 employees or
    One of the requirements of the
 1996 SDWA Amendments  is  for
 water suppliers to delineate (map)
 the area that contributes recharge
 water to their well. These areas are
 referred to as source water protection
 areas  (SWPAs). In this state,  the
 Department of Human Services has
 mapped these areas using a formula
 based either on usage or actual pump
 tests supplied by the water supplier.
    As for  the  sand  and gravel
 aquifers, the Maine Geological Sur-
 vey has mapped the significant sand
 and gravel aquifers in the state using
 a combination of aerial surveys, well
 pump test data,  and  field  work.
 These  aquifer maps delineate  areas
 with less than 50-gallons per minute
 (gpm) yields and areas with  more
 than 50-gpm yields. The determina-
 tion of the aquifers yielding greater
 than 50 gpm is  based  primarily on
 well pump test data of existing pri-
 vate or community drinking water

 The UST Siting Law
 The new law prohibits,  after Septem-
ber 30, 2001, the siting of new UST
               • continued on page 18

LUSTUttc Bulletin 38
m Tanks Down East
continued from page 17
facilities within the mapped source
water protection area or within 1,000
feet (which ever is greater) of a com-
munity water supply or school well,
or within 300 feet of a private well. A
variance to the prohibition will only
be granted if  the applicant proves
that there is no hydrogeological con-
nection between the UST system and
the well(s).
   Protection of community water
supply wells  is fairly straightfor-
ward; schools are included because
kids not only  spend a lot of time at
school but are also a more contami-
nant-sensitive population. The most
powerful of these prohibitions, how-
ever, is the setback provision for pri-
vate drinking water wells. Replacing
private wells that have been contam-
inated with petroleum has been the
bread and butter of the remediation
work in our UST program.
    A few exceptions are identified
in the law. These include replacing or
expanding an existing UST facility,
converting tanks at an existing facil-
ity from aboveground storage tanks
to USTs, tanks that are used solely for
on-site heating, and facilities where
the well is located on the same prop-
erty as the tanks and serves only the
users of the property (i.e., you can
mess your own nest, but  we won't
pay for a replacement water supply).
    As for the non-community non-
transit (excluding school wells) and
non-community transit wells,  any
proposed facilities sited within the
mapped SWPA or 1,000 feet of these
wells may receive a variance based
on extraordinary engineering and
monitoring measures proposed by
the applicant. Such measures must
exceed regulatory requirements and
effectively minimize a release.
    What kind of measures are these
you ask? Some that we will consider
can be found in Marcel Moreau's arti-
cle, "Plugging the Holes in Our UST
Systems," in  LUSTLine #37. Quite
frankly, some of these measures, such
as dispenser  sumps with monitors
and 15- to 25-gallon capacity spill
buckets, should be requirements for
all tanks regardless of location, and
we may be considering such require-
ments at a later date.
The Rulemaking Part
The second part of the law requires
that the DEP develop rules for the sit-
ing of USTs over mapped sand and
gravel aquifers. The rules  are  to
include variances for certain circum-
stances. DEP scheduled two stake-
holders meeting to solicit input prior
to the formal rulemaking process.
The  stakeholders include industry
and business representatives, as well
as town  officials, environmental
groups,  consultants,  other  state
agencies (i.e., the  Drinking Water
Program and Department of Trans-
portation), water utilities, and tank
   Input from the  first stakeholders
meeting reflected our thinking that
perhaps there should be a three-
tiered model for the siting of USTs
over   mapped sand  and  gravel
aquifers, based on their potential as a
future public drinking water sup-
plies. These tiers could be set up in
the following manner:
•  No  additional requirements for
   UST siting over  areas  of the
   aquifer that have existing contam-
   ination  or  are  already heavily
•  Additional engineering and moni-
   toring measures to prevent dis-
   charges for USTs sited in aquifers
   capable of  yielding less than 50
   gpm, and
•  An all out UST prohibition in
   areas of the aquifer that are capa-
   ble  of yielding more than  50
   gpm—aquifers   or  portions  of
   aquifers of high potential as a
   water supply.

 The Inspection Law
 The other UST law that passed this
 legislative session requires that tank
 owner/operators obtain certification
 of compliance with our annual facil-
 ity inspection requirement. Since
 1991, all owners and operators of
 UST facilities have been required to
 have their leak detection, spill and
 overfill prevention, and corrosion
 protection checked for proper opera-
 tion on an annual basis by a certified
 tank installer or other qualified per-
 sons. For the past six years, DEP has
 offered training and issued annual
 reminders concerning this require-
    Last year, we undertook a study
 to  evaluate the compliance rates
with our annual equipment inspec-
tions. Using a randomly selected 10
percent sample (262) of active oil UST
facilities, the study found that more
than 25 percent of  the facilities had
not had the required annual equip-
ment inspections. Of those that had
the inspections, 29 percent had prob-
lems with equipment. The most com-
mon problems found were with spill
and overfill prevention equipment,
tank interstitial probes, and line leak
detectors for pressurized piping sys-
tems. The real kicker is that of those
facilities with problems, 35 percent of
the time the owners failed to have the
problems corrected!
    The  new  law  will  require
owner/operators to submit a certifi-
cate to DEP, signed by a certified
installer or inspector, stating that the
leak detection, spill and overfill pre-
vention systems, and stage I vapor
recovery   systems   have   been
inspected and that any deficiencies
discovered during the inspections
have been corrected. The first certifi-
cate is due by July 1,2003, and certifi-
cation is required annually thereafter.
    The law also gives DEP additional
enforcement powers to require the
owner/operator to cease deliveries of
oil  until the inspection is completed
and/or deficiencies are corrected.
    Finally, there is a prohibition on
delivery of oil  to nonconforming
(bare steel) tanks after May 1, 2002.
We hope that this will help provide
motivation for the removal of those
last 300 (more or less) remaining bare
 steel home heating oil USTs.

                                                                                       LUSTLine Bulletin 38
 fear and Loathing...
 They say never wish too hard for
 what you want because it may come
 true. DEP tank staff have dreamed of
 these tools, but now comes the heavy
 lifting to implement them. You fel-
 low regulators are probably reading
 this and conjuring up in your minds
 some of the devilish details that await
    With respect to the siting bill, we
 have a little less  than a  year  to
 develop regulations for the siting of
 UST facilities over mapped sand and
 gravel aquifers, but the prohibitions
 against siting close to public and pri-
 vate wells go into effect this October.
 We will need to develop guidance on
 what we mean by engineering and
 monitoring measures and what we
 will require for proof of no hydrogeo-
 logical connection between UST facil-
 ities and drinking water wells.
    My worst fear is about what will
 happen when that property owner
 who wants to build his American
 dream, small business, mom and pop
 variety store with "gas pumps" out
 front (to attract buyers of beer, ciga-
 rettes, ice, and picnic supplies) comes
 in for a variance. When told that he
 has to hire a hydrogeologist to deter-
 mine whether there is a hydrogeolog-
 ical connection between his site and
 the neighbor's drinking water well
 200 feet away, what's he is going to
 say? "You mean to tell me that you
 can't tell me that? You mean I have to
 gamble $10,000 for you to tell me
 whether or not I can sell gas on my
    Hopefully education and out-
 reach to industry, tank installers,
 municipal code enforcement officers,
 and banks will provide buffer against
 such a scenario. We have some pow-
 erful tools now in our quiver and a
 lot of work ahead, but in the end, this
 is bound to help prevent future
 nightmare cleanups.
    As for the inspection certification
 requirement, well, it builds on  an
 existing requirement. So for us, it is a
 matter of developing a database and
 an enforcement plan and then educat-
 ing tank owners that the require-
 ments become effective in two years.
 Another one of my fears on this one is
 that the 25+ percent of owner/opera-
 tors who have never  had their sys-
 tems checked will wait until the last
 minute to fix their problems. •
                           Are 1998 UST Upgrades  Effective?
                           California's  Field-Based
                           Research  Project
                           Looks  for  Answers
This article is reprinted, with permission,
from the autumn 2000 edition of the Cal-
ifornia State Water Resources Control
Board's newsletter Just UST News.

   In January 1999,  a State Water
   Resources    Control    Board
   (SWRCB) Advisory Panel deter-
mined that more research needs to
be conducted to evaluate the effec-
tiveness  of the 1998 UST system
upgrades. As a result of the panel's
recommendation, the California leg-
islature passed a bill mandating that
the SWRCB  conduct field-based
research to evaluate the effectiveness
of new and upgraded UST systems
in California.
    University of California at Davis
(UCD) is under  contract with the
SWRCB to conduct the project. Six
county test areas were selected, based
on their wide range of UST system
types, construction materials,  and
construction  techniques, and they
were able to provide UST permit data
in an electronic format.
    Under contract with UCD, Tracer
Research Corporation plans to test a
total of 180 facilities in the test areas
over a two-year period. To test the
UST systems, Tracer is installing 25 to
35 soil vapor probes in the tank pit
backfill and along the piping trench.
The tank is then inoculated with an
inert tracer  compound. Seven to 14
days later, Tracer returns to collect
vapor samples from the probes and
analyze them for the inoculant. If any
inoculant is detected,  the owner/
operator must make repairs to the
system. Then Tracer comes back and
adds a different inoculant to the tank
for  a second round of testing. This
second test is to  determine whether
the  repairs  were adequate to stop
leaks from the UST system.
    If  inoculant  is not detected in
either the first or second sampling
event, then Tracer presumes that the
tank system is tight.
If inoculant is detected in the
second round, then the system is
presumed not to be liquid and/or
vapor tight. Information from this
follow-up test will help the owner
make decisions about further repairs
or excavation efforts. Tracer will pro-
vide the UST owner with a report of
its findings.
    After completing this research,
the SWRCB will better understand
where  leaks  are  most  likely to
develop in an UST system and if
there is a difference between the
integrity of single-walled  compo-
nents and  double-walled  compo-
nents of UST systems. •

For more information, contact
Shahla Famhnak at (916)341-5668,
or Erin Ragazzi at (916) 341-5863.


LUSTLine Bulletin 38
         tjgatioi, ancj RemediatirQn
Indoor Air Pathway Risks1
What is the Impact on UST Cleanup Sites?
by Michael Anderson, Steve Bainbridge, Henning Larsen, Paula Lyon, Hun Seak Park, and Bruce Wicherski
     Prior to 1995, many state LUST
     programs based their cleanup
     requirements solely on the risk
of exposure to BTEX2 contamination
from ingestion of groundwater. With
the advent of the American Society
of Testing Material's (ASTM's) Stan-
dard Guide for  Risk-Based Corrective
Action Applied at Petroleum Release
Sites (RBCA) (ASTM, 1995) and the
subsequent encouragement of its use
in EPA's OSWER Directive 9610.17
(EPA, 1995), states began to incorpo-
rate  risk-based  decision-making
(RBDM) into their LUST programs.
To  accomplish  this,  we  had  to
expand site investigations to include:
analysis of samples for additional
constituents (e.g., polynuclear aro-
matic  hydrocarbons (PAHs)) and
evaluation of  exposures  by addi-
tional pathways (e.g.., volatilization
to indoor air).
    As a result, just when we thought
that RBCA might help us close some
sites that didn't  meet the low part-
per-billion  (ppb)   level   benzene
groundwater standard, we  found
that it now kept many sites open that
didn't  meet  the  low ppb  level
benzene volatilization-from-soil-to-
indoor air standard.3
    As states began to use the ASTM
RBCA guidance as the model for
revising their LUST cleanup pro-
grams and for setting new soil and
groundwater  cleanup  levels,   it
became  clear  that  training was
needed to help UST program staff
understand and implement some of
the new aspects of this approach.
Though we had experience with soil
and groundwater assessments, think-
ing in terms of a conceptual site risk
model and incorporating air path-
ways were new tools for many of us.
Some of the questions that arose in
this regard included:
• Is the indoor air pathway really a
   concern, or  is it just a false alarm
   resulting from the application of
   overly conservative generic mod-
• If indoor air exposure is a potential
  threat, how do we estimate poten-
  tial  impacts or  measure  real
• How well will indoor-air pathway
  models work •when applied to sites
  with good site-specific input val-
    As mentioned in the companion
article ("Region 10 Takes an Innova-
tive Approach to Meet Indoor Air
Training Needs"), UST program staff
from the Region 10 states and EPA
Region 10 worked  together to de-
velop a training course on this sub-
ject. This article describes the nature
and background of the problem and
discusses some of the lessons learned
in that course.

The Conceptual  Site Model
Prior to RBDM, the main questions
asked during a LUST site investiga-
tion and the development of a correc-
tive action plan were:
• Where   is  the   contamination
  located today?
• Can I dig out the contaminated
• Can I pump out the free product
  or contaminated groundwater?
    Risk was not totally ignored, but
it was primarily limited to concerns
about impacts on groundwater used
as drinking water. Vapors were usu-
ally only a concern in the early stages
of a release—are vapors in a building
reaching explosive levels, or are there
noticeable odors that might create
nuisance conditions or health con-
cerns? If vapor levels were well
below lower explosive limits and
there  were no complaints  about
odors, vapors were not thought to be
a problem.
    With the advent of a more rigor-
ous application of risk at LUST sites,
we had to perform a more thorough
examination of how human and eco-
logical receptors could be at risk due
to the release of petroleum products.
Because risk = toxicity x exposure,
one necessary element is to assess all
of the  reasonably likely exposure
pathways at a typical LUST site.
    In addition to some of the more
obvious pathways, such as coming
into contact with contaminated soil
or  drinking contaminated  water,
indirect pathways where contami-
nants are transported to the receptor
must also be considered. The concep-
tual site  model  (CSM),  which
describes all of the current and poten-
tial future ways that receptors may
become exposed to contaminants, is
the key component that bridges the
gap between the information gath-
ered during the site investigation and
the development of an effective and
protective risk-based remedy.
    Since petroleum products, espe-
cially gasoline, contain fairly volatile
constituents, we need to consider not
only where vapors might be located
today, but also where they  might
show up in the future as they con-
tinue to volatilize from contaminated
soil and groundwater. (See Figure 1.)
    Therefore, achieving a protective
remedy for the indoor-air pathway
depends on our ability to ensure that
the concentrations we leave behind
in soil and groundwater will elimi-
nate any current unacceptable con-
centrations of volatiles in indoor air
and prevent future unacceptable con-
centrations from  developing. One
way to estimate this is to use expo-
sure equations4 to calculate accept-
able  air  concentrations  for  the
contaminants  of  interest. Then  a
transport model can be  applied to
estimate the concentration of conta-
minants in air that might result from
given initial concentrations in soil or
groundwater.5 These results are then
combined to predict acceptable con-
centrations for the contaminants in
soil and groundwater.
    This approach is often used to
develop generic "screening levels" or
even site-specific "target levels" or
"cleanup goals." For screening levels,

                                                                                               LUSTLine Bulletin 38
                        Connective Transport
                                                     Mixing in
                                                   Breathing Zone

                                               Diffusive Transport
                                             Impacted Soil or Groundwater
                                               Partitioning to Soil Vapor
  (Adapted from a figure developed by Robbie Ettinger, Equilon Enterprises LLC. Used with permission.)
 a set of conservative conditions (e.g.,
 shallow groundwater and permeable
 soils) are used in the model so that
 the results can be safely applied to
 sites with a wide range of actual con-
 ditions. For site-specific work, appro-
 priate site data  are used in place of
 generic parameters to calculate the
 target levels.

 The Transport Model
 A number of models exist for simu-
 lating the flux of gases  and vapors
 from the  ground  into  structures
 (EPA, 1992). Early  interest in  this
 problem was directed at the infiltra-
 tion of radon into  buildings.  The
 model most commonly  used today
 for estimating the potential impact to
 indoor air from volatile organics in
 underlying soil or groundwater was
 developed by Paul Johnson and Rob-
 bie Ettinger  (Johnson and Ettinger,
 1991)6. Their model simulates all of
 the factors  illustrated  in Figure 1
 except for biodegradation. Volatile
 contaminants at the source (either
 contaminated soil or groundwater)
 volatilize into the available overlying
 air-filled pore space. The contami-
 nants then diffuse upward until they
 are close to the building.  At that
 point, reduced indoor air pressure
 generates a  convective  flow that
 sweeps the volatiles through cracks
in the building foundation where
they mix with the indoor air.
   In their 1991 paper, Johnson  and
Ettinger (J&E) not only develop the
 full equation for this system, they
 also present simplified equations for
 limiting conditions,  such as when
 transport is diffusion limited or con-
 vection limited. ASTM used the dif-
 fusion-limited version of the J&E
 model for the 1995 RBCA guidance.
 With ASTM's set of generic site para-
 meters, the diffusion-limited equa-
 tion predicts an acceptable soil-vapor
 to indoor-air screening level for ben-
 zene of 5 ppb (assuming an accept-
 able  excess carcinogenic risk level
 of 1  x 10~6). This  value generated
 considerable concern among state
 regulators. Is benzene really an unac-
 ceptable risk at such low concentra-
 tions, is the model incorrect,  or are
 ASTM's generic parameters too con-
    Field studies have been carried
 out  to  assess  the severity  of the
 indoor-air pathway risk. A study of
 168  sites by Massachusetts (45%
 BTEX sites and 55% chlorinated sites)
 found that  although  the model-
 derived screening levels were conser-
 vative for  BTEX,  they were  not
 conservative for chlorinated hydro-
 carbons (Fitzpatrick and Fitzgerald,
 1996). This could be due to the more
 rapid biodegradation rates of BTEX
versus chlorinated hydrocarbons.
    The results of a study at a refin-
ery site showed that  surface fluxes
were affected by source concentra-
tions, depth to the source, and source
depletion. It also showed that aerobic
degradation, could have a significant
 impact on the surface flux of volatile
 aromatic compounds. Soil moisture
 was also a significant factor because
 of its ability to retard diffusion.
     So, although the J&E model does
 appear to be somewhat conservative,
 especially when applied to  com-
 pounds that are likely to undergo
 significant biodegradation, it is still a
 useful generic screening tool and can
 also be a reasonable site-specific
 screening tool when realistic values
 are used for the input parameters.
 Model predictions can be improved
 by collecting data on soil moisture
 content, porosity, and bulk density.
 Results are sensitive to the stratigra-
 phy and can be influenced signifi-
 cantly by "dominant layers" (i.e.,
 layers that strongly influence trans-

 Field Tests
 Although screening and site-specific
 models are very useful, what should
 be done when a site exceeds the
 screening levels predicted by such
 models? Two answers that usually
 come to mind are (1) clean up the
 site, or (2) collect some indoor air
 samples to see if contaminants actu-
 ally exceed risk-based standards.
    Both of these approaches, how-
 ever, have inherent problems. First, a
 screening level is intended to screen
 out those sites that are obviously not
 an unacceptable risk. If a site meets
 screening levels, you should be able
 to close it without much concern.
 However, if a site exceeds screening
 levels, that does  not necessarily mean
 that it exceeds acceptable risk levels. It
 simply means that more investiga-
 tion may be needed  to determine if
 the risk is acceptable or not.
    Second, studies have shown that
 most indoor air contains measurable
 levels of many constituents, includ-
 ing benzene. If you collect an indoor
 air sample and detect benzene, how
 are you to determine what part, if"
 any, of that benzene is coming from
 the petroleum release?
    Unless conditions at the site are
 such that interim remedial measures
 or indoor air monitoring are neces-
 sary, the next step for sites  that
exceed screening levels would be to
measure soil  gas profiles close to or
under the building(s) in question.
Soil  gas  data may be useful  for a

                H continued on page 22


LUSTLine Bulletin 3S
m Indoor Air Pathway Risks
continued from page 21	

more realistic source concentration in
a site-specific model, or it may be
used with generic attenuation factors
derived from radon  gas studies to
estimate potential indoor air impacts.
In some cases it might be appropriate
to install dedicated sampling points
to monitor changes over time. Care
must be taken, however, to collect
representative samples. Short-circuit-
ing  may result from applying too
high a vacuum or from leaks in the
    If indoor air sampling is neces-
sary, there are a number of options to
consider. Active sampling can be
employed where gas flow is induced
into a syringe or canister. Passive
sampling, which  employs a  flux
chamber or sorbent materials, may
also be used.
    Active  sampling methods are
generally more expensive but often
preferred for risk assessments. Pas-
sive sampling is less  costly but may
be difficult to interpret. If there are
concerns about fluctuations in con-
centrations over the course  of a day,
it may be useful to collect samples
over a longer period of time (e.g., 8 or
24 hours) to get an integrated result.
Massachusetts and New Jersey have
developed guidance  documents for
indoor air sampling that  may be
helpful if you are considering this at
your site7.

Before the advent of RBDM there was
really only one remedy for a LUST
site—clean it up  to  the acceptable
cleanup levels. RBDM, however, pro-
vides owners of contaminated prop-
erty with the option of managing the
risk. Risk management usually falls
into the  categories  of  engineering
controls or institutional controls. For
risks associated with  vapor  intrusion
into buildings, the  most  common
engineering controls are using seals
and barriers to prevent the vapors
from  entering the building  or
installing improved  ventilation sys-
tems  to keep the  concentrations
below  acceptable levels.  In some
cases, a combination of the two may
be needed.
     At a dichloroethylene pCE) site
in  Colorado,  concentrations mea-
sured  in  indoor  air  correlated

strongly to the DCE concentrations in
the underlying groundwater plume.
Since DCE is not commonly found as
a background constituent in indoor
air, the indoor air impacts could be
tied directly  to the  groundwater
source. Of 170 homes tested, over 60
homes required some type of mitiga-
tion to reduce contaminant concen-
trations to acceptable levels.
    The use of membranes and sub-
slab ventilation systems were found
to be effective for these homes. In
most cases, concentrations dropped
to below action levels within days of
    In many cases, institutional con-
trols are  also  applied to  a site to
maintain the  engineering controls.
These legal controls may be used to
require the operation and mainte-
nance of the remedies, or they may be
used to prevent additional construc-
tion in areas where vapors are known
to be a problem. Risk management
may result in remedies that are less
costly and more  quickly imple-
mented  than traditional cleanups,
while still maintaining adequate pro-
tection from unacceptable risk. How-
ever, property owners may find it
more difficult to sell a piece of prop-
erty that has  additional regulatory
strings attached.

In Summary
• Volatile contaminants in soil and
   groundwater can generate indoor
   air  concentrations  that exceed
   acceptable risk levels.
• The Johnson and Ettinger model
   may be conservative for contami-
   nants that are readily biodegrad-
   able, but when applied properly,
   they can provide reasonable esti-
   mates of screening levels for the
   indoor-air pathway.
• Model   predictions   can   be
   improved by collecting site-spe-
   cific data on soil moisture content,
   porosity, and bulk density.
• Soil gas sampling should be con-
   sidered  for  sites  that exceed
   model-derived screening levels.
   The  results  can be  used  as
   improved  source estimates for
   additional  modeling   or  with
   radon-based attenuation factors to
   estimate  potential  indoor  air
 • Indoor air monitoring may be
   needed to further evaluate  sites
  but should be applied with cau-
  tion to try to relate it to specific
• Engineering  controls  such  as
  membranes and  ventilation are
  useful remedies for vapor impacts
  on indoor air. •
Note: This article does not necessarily reflect
specific policies of the Region 10 states. It sim-
ply summarizes the nature of the indoor air
pathway "problem" and the issues discussed
by attendees at EPA training on the topic.
 Michael Anderson is with the Oregon
 Department of Environmental Quality.
         He can be reached at
   Steve Bainbridge is with the Alaska
     Department of Environmental
 Conservation; Henning Larsen is with
      the Oregon Department of
 Environmental Quality; Paula Lyon is
     with the Idaho Department of
   Environmental Quality; Hun Seak
     Park is with the Washington
   Department of Ecology; and Bruce
      Wicherski is with the Idaho
 Department of Environmental Quality.
1 Information not specifically referenced in
  footnotes is taken from Nichols and Ettinger,
2 BTEX = benzene, toluene, ethylbenzene, and
  total xylenes.
3 The benzene-in-groundwater standard was
  based on the use of groundwater as drinking
  water and EPA's maximum contaminant
  level (MCL) for benzene. The benzene-in-soil
  standard was based on an acceptable excess
  cancer  risk of 1-in-a-million and default
  assumptions and equations used in the 1995
  ASTM RBCA standard for the soil-to-indoor-
  air pathway.
4 These are typically standard exposure equa-
  tions such as those found in Risk Assessment
  Guidance for Superfund (EPA, 1991).
5 The ratio of the air concentration to the soil
  or water concentration is often referred to as
  a "Volatilization Factor." See, for example,
  ASTM, 1995.
6 The Johnson and Ettinger Model, and other
  indoor air models, can be downloaded from
  EPA's  Web site at
7 Massachusetts has a draft document posted
  on the Internet at
  dep/ors/orspubs.htm . New Jersey's Indoor
  Air Sampling Guide for Volatile Organic Conta-
  minants can be ordered for $5.00 from the
  Maps and Publications Sales Office in Tren-
  ton, NJ, 609-777-1038.
 ASTM, 1995, Standard Guide far Risk-Based Cor-
  rective  Action Applied at Petroleum Release
  Sites, ASTM E1739-95, American Society for
  Testing and Materials, Philadelphia, PA.

                                                                                            LUSTLine Bulletin 38
 EPA, 1991, Ri'sfc Assessment Guidance for Super-
  fund: Volume I - Human Health Evaluation
  Manual (Part B, Development of Risk-Based Pre-
  liminary Remediation Goals), Office of Emer-
  gency and Remedial Response, Washington,
  DC, EPA/540/R-92/003.
 EPA, 1992, Air/Superfund National Technical
  Guidance Series: Assessing Potential Indoor Air
  Impacts for Superfund Sites, Office of Air Qual-
  ity Planning and Standards, Research Trian-
  gle Park, NC.
 EPA, 1995, Use of Risk-Based Decision-Making in
  UST Corrective Action Programs, Office of
  Solid Waste and Emergency Response, Office
  of Underground Storage Tanks, Directive
  Number 9610.17.
 Fitzpatrick, Nancy A., and John J. Fitzgerald,
  1996, "An Evaluation of Vapor Intrusion Into
  Buildings Through a Study of Field Data,"
  11* Annual Conference on Contaminated
  Soils, University  of  Massachusetts  at
 Johnson, Paul C, and Robert A. Ettinger, 1991,
  "Hueristic Model for Predicting the Intrusion
  Rate of Contaminant Vapors into Buildings,"
  Environmental Science and Technology, 25(8):
 Nichols, Eric, and Robbie Ettinger, 2001,
  Course notes for "Indoor Air Pathway & Risk
  Based Decision Making," February 28 -
  March 3, 2001, Portland, Oregon.

 • Secondary Containment...
 continued from page 11

 to protect the environment against
 such occurrences.
    Federal regulations do not man-
 date  tanks to  be  removed  and
 replaced after a certain life. Although I
 firmly believe that today's storage sys-
 tems can last 30 or more years, I
 wouldn't bet my life savings on a per-
 fect batting average  because of the
 human element.
    As with the roof job on my home
 and every major appliance I own, I
 know  that  someday it  will  need
 replacement. (My expensive 36" tele-
 vision set just bit the dust after only
 four years!) But I can also see these
 things every day, unlike a buried UST.
   Just 20 years ago tanks with sec-
 ondary containment did not  even
 exist. Today, the technology is there
 for the taking, yet the regulations
 have not caught up. One reason we
 suffered a tank crisis to begin with
 was  because tanks were routinely
buried and forgotten. I'd like to think
 that soon we'll get our tank house in
 order, once and for all, by requiring
 secondary containment for all petro-
leum storage tanks and piping. It just
makes sense. •

 Wayne Geyer is Executive Vice-Presi-
   dent of the Steel Tank Institute.
        He can be reached at
 Region  1O  Uses  Innovative
 Approach to Meet  Training  Needs

 Indoor Air Pathway Workshop a Success
 by Michael Anderson, Steve Bainbridge, Henning Larsen,
 Paula Lyon, Hun Seak Park, and "Bruce Wicherski
    If you want the job done, some-
    times you have to do it yourself.
    That was the approach taken by
 those of us  from various environ-
 mental offices in Alaska, Idaho, Ore-
 gon, and  Washington (Region 10
 states), with support from the U.S.
 EPA Office of Underground Storage
 Tanks (OUST), when we realized we
 needed training  on evaluating the
 potential impacts of volatile contami-
 nants on indoor  air exposures at
 leaking underground storage tank
 (LUST) sites. As there was no such
 training available, we also realized
 that we would need to make it hap-
 pen, and we did. As a result, approx-
 imately 35 project managers, policy
 writers, and technical staff recently
 had the opportunity  to  gather in
 Portland, Oregon, to learn  about and
 discuss the latest in:
 •  Modeling the transport  of volatile
   contaminants   from   soil  and
   ground water to indoor air;
 •  Methods for collecting and ana-
   lyzing air samples; and
 •  Strategies for managing risk from
   exposure  to  volatiles  entering

    Workshop participants received
 a high quality course conducted by
 two recognized experts in the field.
 (See the companion article, "Indoor
 Air Pathway Risks," on page 20 to
 find out what was covered in the
 course.) This course is an offshoot of
 an earlier course on MTBE Manage-
 ment and Assessment provided by
 the Georgia Institute of Technology
 through a cooperative agreement
 with EPA/OUST.
    Federal resource constraints hin-
 dered  delivery of the  Indoor Air
 Pathway Risk course to multiple state
 locations.  However,  at  the  2000
 UST/LUST   national   conference,
 interested states were informed as to
how they could obtain courses by
working directly with Georgia Tech
 (outside OUST's cooperative agree-
 ment). The ultimate objective of the
 Georgia Tech training is to provide
 cost-effective,  quality  training  to

 The Process
 After some initial discussions about
 our training needs with our EPA
 Region 10 point-of-contact,  Wally
 Moon, we learned that if this  course
 were to take place in the form we
 wanted, we, the states, would have to
 take the initiative to  create it.
    Wally organized a team of pro-
 ject managers and technical and pol-
 icy staff from the Region 10 states to
 brainstorm about what a course like
 this should cover. Through a series of
 conference calls and e-mails over sev-
 eral months, the team developed a
 two-day course agenda and course
    This information was forwarded
 to Georgia Tech, which then issued a
 nationwide request for proposals to
 search for qualified  people   to
 develop and deliver the course. We
 received a consolidated qualifications
 list of parties interested in providing
 this training.  After reviewing the
 qualifications,  the team got together
 on a final conference call to discuss
 the necessary  mix of skills that we
 thought would best meet our training
 needs and then forwarded this infor-
 mation to Georgia Tech.
    Georgia Tech selected the train-
 ers, who then  coordinated with the
 Region 10 states' project team to dis-
 cuss potential  enhancements  to the
 course and to provide a detailed
 agenda with their preferred order of
 presentation, list of subtopics, and
 allocated times for  each  topic. The
project team then reviewed the pro-
posed detailed  agenda and  made
 additional suggestions to help the
 trainers  better  understand  and
respond to the states' training needs.
Communications with the trainers
continued throughout the develop-
                • continued on page 24


LUSTLine Bulletin 38
m Region 10 Training Needs
continued from page 23	

ment of the course materials, and the
team was provided an opportunity to
evaluate the materials as they were
put together.
    Just prior to the course, a private
Intranet site was set up to facilitate
review of the nearly complete train-
ing materials. Draft versions were
posted on the site and were available
for downloading. By distributing
materials in this way, we were able to
view the most up-to-date material
available at that time.
    This innovative process gave us
the opportunity to design and assist
in the development of training that
was structured to meet our state-spe-
cific needs.

The Trainers
The trainers for this course were not
paid for the time and effort associ-
ated with course modifications or
time spent in discussion with the pro-
ject team. The opportunity to work
directly with a coalition of state regu-
lators to develop the course, com-
bined with the opportunity to deliver
the course, provided ample incentive
for  these  trainers.  Georgia Tech
retains  the rights to market this
course as part of its general  course
offerings. Georgia Tech also provides
continuing education units for select
courses offered through the institu-
    From a pool of very qualified
candidates, Georgia Tech selected
Robbie Ettinger, Equilon Enterprises
LLC, and Eric Nichols, LFR/Levine-
Fricke,  to develop and deliver the
course. Robbie Ettinger has degrees
in  Chemical  Engineering  and  is
Senior Research Engineer in the Soil
and Groundwater Department  at
Equilon. He has worked on many
remediation  projects    and  has
researched  fate  and  transport  of
chemicals in the subsurface environ-
ment since joining  Shell Develop-
ment   Company  in  1989.  The
Johnson-Ettinger model that ASTM
uses for the volatilization-to-indoor-
air pathway in  its RBCA standard
was developed by Robbie and Paul
    Eric Nichols, PE, is  a Principal
Engineer with LFR/Levine-Fricke.
He provides senior review for model-
ing and exposure assessment on a

variety of federal and private-sector
environmental restoration and water
resources projects. Eric also teaches
courses in modeling, risk assessment,
groundwater  hydrology,  and  site
assessment. As  LFR's Manager of
Quantitative Services, Eric leads the
subsurface modeling and risk assess-
ment practice for the company.

The Course
The course was held in Portland on
February 28 - March 1, 2001. Al-
though we experienced a rather inter-
esting interruption by an earthquake
on  February 28, we were able to
cover a significant amount of mater-
ial,  including:
• The risk-based process,
• Fate and transport mechanisms,
• Vapor migration modeling,
• Field methods for air sampling,
• Parameter estimation and mea-
• Indoor  air  risk  management
  options, and
• Case studies and field validation.

    Despite the  amount of material
covered,  ample time was allowed for
questions and discussion. Sharing
experiences with our cohorts from
the other states in Region 10 was an
equally valuable part of the training.
The information presented at this
workshop will assist policy staff in
the development of future guidance
and field staff in  the evaluation of
indoor air impacts at LUST sites.

The Aftermath
All  in  all, the participants  were
extremely  pleased with the course
content, the trainers, and the format
of the workshop. Those who partici-
pated in the planning and develop-
ment felt that it was well worth the
effort. The trainers, Talisman Part-
ners (Georgia Tech's contractor), and
EPA did an excellent job of develop-
ing materials and coordinating  their
efforts to stage the event. In addition
to the binder of printed course notes
and reference materials handed out
at  the  workshop,  each  attendee
received a CD containing electronic
copies of notes  and additional sup-
plementary materials. This should
prove to be a handy reference as we
use the information from the work-
shop to develop state-specific guid-
ance and training materials.
    Finally,  the application of this
innovative approach turned out to be
a very cost-effective use of state and
regional resources. The most surpris-
ing part of all is that it was only a lit-
tle  over  a  year  from  the  first
suggestion of developing the course
to the actual presentation.
    Since this was the first presenta-
tion of the course, the following are
examples of suggestions that have
been  made  that  we  think will
improve the course for future partici-
• Include a representative from a
  qualified laboratory to provide
  hands-on  access to   sampling
  equipment; and
• Use state-specific sites for the case
  studies to  better reinforce the
  lessons and encourage their appli-
  cation in the field.

    If you would like  to have this
training  made available in  your
region, or  if you would  like to
develop training on another  topic
and want to ask questions about our
experiences, feel free to contact Wally
Moon, EPA Region 10, at (206) 553-
6903 or at •

Despite the opening sentence of this
article, we obviously did not do this
by  ourselves.  We would  like to
express our appreciation to all of the
LUST staff from the Region 10 states
who reviewed and commented on
the course outline and draft materi-
als. And, we want to specifically
acknowledge the efforts of:
Wally Moon, EPA Region 10, Seattle,
  WA (facilitator and logistics coordina-
Steven  "Striving  to  Improve  the
  Process" McNeely, EPA OUST, Wash-
  ington, DC;
Jacqueline  Rast,  Talisman Partners,
  Ltd. (Georgia Tech's contractor);
Robbie Ettinger, Equilon Enterprises
Steve Nichols, LFR/Levine-Fricke; and
Georgia Institute of Technology, Clif-
  ford H. Stern.
1 Johnson, Paul C, and Robert A. Ettinger,
  "Hueristic Model for Predicting the Intru-
  sion Rate of Contaminant Vapors into Build-
  ings," Environmental Science and Technology,
  25(8): 1445-1452,1991.

                                                                                      LUSTLine Bulletin 38
More  PFP  Stories
                          PFP's Emphasis on Success Helped Detect a
                          Leak When All  Else Failed
                         by Brian Dougherty
                               Jased  on an experi-
                               ence  at one of  our
 (PFP) cleanup sites, we've discovered that PFP cleanups
 can unintentionally result in detection of UST leaks that
 would otherwise have gone undetected. The key to this
 story is that under PFP, the  cleanup contractor gets paid
 as contamination levels decline and meet a series of
 "milestone" levels. If the contamination does not decline,
 the contractor does not get paid. So what happens if there
 is a leak from another UST at the site? Such a circum-
 stance could prevent the cleanup contractor from reach-
 ing these milestones and getting paid.
   That's what happened at one of our PFP cleanup sites.
 The cleanup system had worked great when first turned
 on, but then contamination levels stopped declining and
 even began to rise at some points. Meanwhile, none of the
 USTs at the site showed any evidence of a release, and
 they all tested tight. Furthermore, the responsible party
 was reluctant to double-check his leak-detection system
 results because a new release at his site at that time would
 require payment of a $10,000 deductible and a relatively
 low cap on state funding (the existing release had no
 deductible and no cap on state funding).
   This situation put the PFP cleanup contractor between
 a rock and a hard place. He would take an indefinite loss
 on the cleanup work unless he could show that the failure
 of contamination levels to go down was not the result of
 unsuccessful cleanup work on his part.
   The owner/operator remained reluctant to acknowl-
 edge the problem, and so the PFP contractor reported his
  suspicions to the state. The Florida Department of Environ-
  mental Protection authorized the contractor to look for
  leaks coming from the other parts of the system. This
  investigation was paid for by the state outside of the PFP
  agreement. Indeed, a fairly substantial leak with free prod-
  uct was discovered to be coining from one of the pipelines.
     Had it not been for the incentive that PFP gave the
  contractor to find and report the new leak at the site, the
  leak would have gone undetected, and product would
  have continued to be release into the environment. If the
  cleanup had been undertaken on customary time-and-
  materials terms,  it would have  gone on for a very long
  time and cost a lot, without reducing the contamination to
  environmentally acceptable levels.
     It's not fair to a PFP contractor to have to  continue
  futile work (e.g., when there's been a new leak) within the
  fixed price and time limits that were set before a new leak
  has been discovered. Standard practice in such circum-
  stances is to release the contractor from the PFP contract
  with no financial penalty. In this case, the contractor was
  released. Typically, the PFP will be renegotiated or rebid
  to take the new leak into account. In this case, a different
  contractor was hired to do the work and has not been will-
  ing to perform the work under PFP.
     The message here is that thanks to the PFP cleanup
  contract, the state found a leak that would otherwise have
  gone undiscovered, and the cleanup contractor was
  treated fairly too.  •

       Brian Dougherty is an Environmental Administrator
  with the Florida Department of Environmental Protection. He
     can be reached at
                         A  Funny Thing Happened on the Way to the
                         PFP Cleanup
                       by Chuck Schwer
                       and Richard Spiese
                            "ermont headed down
                             the PFP cleanup road
                             for leaking under-
ground storage tank sites in late 1999. We believed there
were some important advantages to changing from the
time-and-materials tradition to a PFP arrangement. We
liked the shift in risk from the state cleanup fund to the
consultant, and with this risk also comes the best incen-
tive—cash—to cleanup the site in a timely manner. We
liked the thought of getting away from the time-and-
materials mentality for which ever-changing site condi-
tions necessitate ever-changing scopes of work and
budgets. We also liked the idea that PFP offers a tremen-
dous reduction in the amount of paperwork needed for
submitting claims against the cleanup fund.
   No longer would we need detailed monthly invoices
that require of us such tasks as comparing the submitted
invoices with the preapproved workplan, checking for

                                • continued on page 26


LUSTLiiif Bulletin 38
 m PFP Stories continued from page 25
proper documentation of subcontractor work, and check-
ing for proof of payment. This would mean that our tech-
nical people could spend more time on science and less on
   Vermont currently has ten PFP agreements signed:
seven were negotiated and three were bid. So far, all the
projects seem to be progressing very well with one site
already having reached all but the last milestone. We
found that negotiating was more time consuming than we
originally planned, but with experience, the process has
been improving. We're feeling very positive about going
down the PFP road, especially since we discovered two
rewards that we weren't anticipating—clearer goals and
better remedial systems.

Clearer Goals
In our negotiation of the seven agreements reached so far,
considerable time was spent on establishing clear cleanup
goals. Although it can be argued that
we had clear goals under time-and-  Immfmm^^^g,,^
materials cleanups, there is no ques-  p| T]; ^     : :
tion that PFP has forced both our staff
and the consultant to be much more
specific about the goals, and for good
reason—payment is based on reaching
these goals. In a few instances we had
to rethink a goal when it became clear
that  the  cost to attain the goal out-
weighed the benefit. The result is  a
much more focused cleanup with  a
dearly defined endpoint.
  We're feeling very positive about
going down the PFP road, especially
  since we discovered two rewards
   that we weren't anticipating—
     \  remedial systems.
Better Remedial Systems
The second reward of PFP that we didn't expect has been
the quality of the remedial systems installed to date. The
remedial systems at the PFP sites have been some of the
most well thought out and designed systems we have ever
seen. We are seeing a new order of system flexibility and
remote monitoring capabilities. The consultants have
really put their minds to the task. If s their risk, and they
want to make sure they do the absolute most they can do
to minimize it.

How About This?
In the case of one site, the Moretown General Store, the
consultant built in many features to the remedial system (a
soil vapor extraction/air sparging system) to maximize
system flexibility. For example, he put in twice as many
remediation wells than the feasibility study indicated
were needed. In this way he could focus on a "hot spot" of
contamination with a maximum of remedial resources. He
used two 2-horse and one 4-horse power vapor extraction
blowers instead of one 5-horse power blower. He put the
eleven sparge well points on timers, using one small
blower to operate the system (instead of one large  15-
horse power blower operating all spargers at once, which
is more typical). He set up  a  300-standard cubic feet
minute catalytic oxidizer to allow replacement with car-
    The strategy is to allow flexibility of the system to
remove or replace system components with less expensive
components or to allow the system to use less power dur-
ing system remediation, thereby decreasing the overall
cost of system operation.
    Other improvements of this PFP system over other
systems include:
•  Putting all remedial components that need to be explo-
   sion proof (because of the possibility of coming into
   contact with petroleum vapors) on one side of the
   remedial shed (the XP side of the shed) and putting
   nonexplosion-proof equipment, such as switching and
   controls (much cheaper than the explosion proof ones),
   on the other side of the shed.
•  Clearly labeling each and every part of the remedial
   system so that whoever responds to the site to perform
   maintenance knows exactly which system component
   he or she is working on. (Under time and materials it
   really doesn't matter if consultant technicians respond-
   ing to the site can't fix a problem or take several extra
                   hours to complete system mainte-
^^^^=35=,    nance, they get  paid. Under PFP,
                   this is money out of the consultant's
                   Putting system operation lights on
                   the outside of the shed, so that if
                   one of these lights is on, the facility
                   operator knows to call the consul-
                   tant and report which lights are on.
                   In this way the consultant has some
                   idea before reaching the site what
                   the problem might be.
	- -••.*•  • •  '•••"I  •  Using a field GC to monitor the
                   progress of the remedial system.
                   For milestone success to be shown,
   the PFP agreement requires lab analysis. However, the
   consultant often took samples and had them analyzed
   by the field GC to see how to improve system perfor-
   mance and to determine when to take milestone sam-
   ples before the required quarterly sampling rounds.
 • Scheduling site monitoring to coincide with other jobs
   in the area. In this way, travel, man-hour, and equip-
   ment costs are shared reducing the overall cost of mon-
    All of these system construction  and operation
 improvements may not have happened were it not for
 PFP. The desire and motivation of  the consultants to
 improve system performance, thereby maximizing prof-
 its, seem to bring forward innovative ideas at every PFP
    Overkill you think? If you are satisfied with the price
 for the cleanup, do you care? Priority one is getting the
 site cleanup completed, and, so far, the remedial systems
 in Vermont under PFP are kicking butt! •

    Chuck Schwer and Richard Spiese are with the Vermont
  department of Environmental Conservation's Sites Manage-
           ment Section. Chuck can be reached at
, Richard at

                                                                                         LUSTLine Bulletin 38
 Driving Down  the Ethanol Road
 New England States Work  Together to
 Identify Potential Pitfalls
      The New  England  Interstate
      Water Pollution Control Com-
      mission (NEIWPCC) and the
 Northeast States for Coordinated Air
 Use Management (NESCAUM) have
 recently completed a three-volume
 report on Health, Environmental, and
 Economic Impacts of Adding Ethanol to
 Gasoline in the 'Northeast States. The
 two organizations were asked by the
 New England  Governor's Confer-
 ence  (NEGC),  Committee  on the
 Environment to assess the potential
 public health, environmental, regula-
 tory,  and  economic impacts of a
 gasoline oxygenate shift from methyl
 tertiary-butyl ether (MTBE) to eth-
 anol. NEIWPCC was specifically
 requested  to address alternatives
 with respect to water impacts.
    As detections of MTBE in soil
 and groundwater continue to occur
 with  increasing frequency,  many
 states are viewing this gasoline addi-
 tive with increasing alarm and have
 been considering or instituting leg-
 islative or regulatory actions to ban
 or reduce its use in gasoline. For its
 part, the NEGC wanted the North-
 east states to be in a position of hav-
 ing evaluated potential alternatives
 to MTBE prior to  the widespread
 introduction of a new substance into
 the region's gasoline supplies. In the
 near term, at least, ethanol is gener-
 ally acknowledged to be the most
 likely alternative to MTBE nation-
    NEIWPCC's document (Volume
 3, "Water Resources and Associated
 Health Impacts") was prepared by a
 committee  made up  of representa-
 tives from state water, health, under-
 ground storage tank (UST), and
 site  remediation  programs.  The
 NESCAUM document, Volume  2,
 addresses ethanol in  gasoline from
 the economic, air quality, and health
 perspective. Volume 1 is a summary
 of the two documents.

The NEIWPCC Report
The NEIWPCC committee focused its
evaluation  on the potential health
and environmental impacts of a
release of ethanol and ethanol-
blended (E-blend) gasoline. Alter-
native  oxygenates  other  than
ethanol were reviewed briefly with
an eye toward the possibility of a
more thorough evaluation at a future
    Focus groups worked on  key
areas  of concern associated  with

*£---.'" • .... ......,."..;  .       't
        The uncertainties and

   recommendations set forth in this  *

^report provide an essential jumping-

jgioff point tor future studies directed

|T toward better understanding the

  implications of the widespread use

       of ethanol in gasoline.

      The report can be found at
    -, .. .; , .::..  •   . •.  ..-"; ;.. .  .  I

ethanol:  Health Effects,  Aquatic
Impacts, Storage and Handling, Envi-
ronmental Impacts, and Other Alter-
natives.   The  goals  for the  focus
groups were to:
• Identify available information on
  ethanol with respect to health
  effects, aquatic effects, storage and
  handling issues, environmental
  impacts associated with ground
  and surface water resources, and,
  to a  lesser extent, alternatives
  other than ethanol;
• Ascertain what is known and not
  known regarding the issues of
  concern; and
• Prepare a  series  of summary
  reports that:
  - Clearly characterize the issues
    and  any  associated uncertain-
  — Present conclusions regarding
  — Make recommendations as to
    what information is needed to
    adequately  understand  and
    address concerns about ethanol,
   - Identify, where possible, steps
     that should be taken to mitigate
     potential problems if ethanol is
     widely introduced  into  the
     Northeast gasoline supply.

Covering the Bases
The health effects  section of the
report presents a summary analysis
of ethanol's neurologic and develop-
mental effects, while also considering
the  evidence for its  carcinogenic
effects and internal organ (particu-
larly liver) damage. In preparing this
analysis, key studies on toxicity of
ethanol  were identified. This infor-
mation is put into a risk context for
the drinking water pathway compar-
ative to health risks from MTBE.
    Ethanol storage and handling
were reviewed with regard to the life
cycle of pure (neat)  ethanol  and
ethanol-gasoline blend (E-blend)—
from feedstock production to  end
user (e.g., automobile, lawnmower).
Chemical  compatibility of storage
components and the environmental
impact of producing and transport-
ing ethanol to the Northeast were
    Ethanol, both as a pure product
and blended  with gasoline,  intro-
duces different problems for tank
and piping components than MTBE-
blended gasoline. However, much is
known about these  problems and
their solutions. The report placed
concerns associated  with storing
ethanol and E-blend fuels into four
• Compatibility with storage system
• Phase separation, causing ethanol
  to preferentially dissolve in water,
             • continued on back page


• Ethanol Report
continued from page 27
• Wear of various storage system
  components, due to the scouring
  internal surfaces with suspended
  particles, and
• Corrosion of various metal com-
  ponents due to the electrical con-
  ductivity of ethanol and E-blend.

Using the life cycle  of  E-blend to
identify potential sources of releases,
environmental impacts were evalu-
ated from the standpoint of:
• Neat ethanol and E-blend gaso-
  line releases,
* The potential pathways (i.e., sur-
  face runoff, infiltration into soil,
  groundwater   transport)    of
  ethanol/E-blend once released
  into the environment,
• The behavior (fate and transport)
  of  such  releases  in the  soil,
  groundwater, and surface water
  environments  and in contrast
  with MTBE,
• Drinking water impacts, and
• The remediation of neat ethanol
  and E-blend releases into  the
  environment and associated costs
  in comparison with MTBE.
A Call to Fill In the Blanks
A key reason why MTBE has grown
into the groundwater contamination
phenomenon that it has is because it
entered the gasoline scene as an air
quality   solution  without  going
through the necessary water quality
impact evaluation hoops. In an effort
not to duplicate this omission, the
NEIWPCC focus groups carried out
their work with due diligence, turn-
ing over as many stones as they
could find in conducting their inves-
tigation. It was the stones they could
not find, the uncertainties, however,
that left the participants hesitant to
welcome ethanol with open arms.
   For example, on the basis of rela-
tive toxicity and comparison across
possible drinking water guidelines,
replacement of MTBE with ethanol is
not expected to increase the public
health risks associated with gasoline
spills into groundwater. However,
this  toxicological assessment does
not take into consideration all of the
exposure factors that might affect
conclusions regarding relative risks.
The report lists several uncertainties
that affect the degree of confidence
we can have that ethanol will not cre-
ate significant health risks if spilled
into  groundwater and provides rec-
ommendations on areas where fur-
ther health effects research is needed.
    With regard to ethanol in the
environment,  while  the use of E-
blend gasoline instead of MTBE gaso-
line will result  in  a significant
decrease  in  well  contamination
caused by small spills, for significant
and continuous  E-blend gasoline
spills the focus group felt that it is
premature  to  predict the effect on
well  contamination.   The  report
strongly emphasizes  the need for
field experiments to understand the
true extent of the behavior of ethanol
in  the  environment  and  confirm
modeling studies. The kinds of stud-
ies needed are listed in the report.
    The  uncertainties and  recom-
mendations set forth  in this report
provide  an essential jumping-off
point  for  future studies directed
toward better understanding  the
implications of the widespread use of
ethanol in gasoline. All three vol-
effort can be found at www.neiw- •
New England Interstate Water
Pollution Control Commission
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100 Foot of John Street
Lowell, MA 01852-1124
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