'Ne-vH Bta.glaxul Iia.tersta.te Water Pollution Control Commission Boott Mills South 1OO Foot of John Street Lowell, Massachusetts 01852-1124 Bulletin 4O March 20O2 LUST A Report On Federal & State Programs To Control Leaking Underground Storage Tanks Tanks at Ground Zero Toy Karen Gomez On September U, like many o.thers, I watched with disbelief as the World Trade Center buildings collapsed. In dealing with the sheer horror of this attack and the human tragedy, I recognized that there was still a need to address the environmental aspects of this event. Within 'the first few hours following the tragic collapse of the World Trade Center buildings, I, like World Trade Center Response Petroleum Bulk Storage Tank Inspections 1 for WTC Area Legend Inspection Zones A/ Zom>1 '/y/ Zon.2 yfy Zones . Inspected Petroleum Bulk * Storage Facility m Spill Associated With Tanks Identified at Inspected Facility m Spill NOT Associated W^anks v Identified at Inspected Facility _ Area In which tanks cannot K^'l be Inspected due to debris and/or damage Facility locations are approximate N.Y.S. Department of Environmental Conservation Map created by DIS CIS Unit 12/05/01 many other New York State Department ' of Environmental Conservation (DEC) staff, was summoned to the DEC command post to assist in the agency's response efforts. As an engineer responsible for DEC's spill response and petroleum and chemical bulk storage programs on Long Island, I was asked to focus on these same issues as a preliminary assessment of the damage was conducted. I continued on page 2 Inside When MTBE Struck Pascoag, Rl ', UST Owner/Operator Education in FL, CA, and OR -Natural Attenuation: Is Dilution the Solution? Do Monitoring Wells Monitor Well? Part I Is MTBE off the Hook in Europe? New UST Leak Detection Web Site Now Available Maryland Completes Study on Environmental Effects of MTBE ' ... • - * J. What If Tank Operators Knew How to Operate Tanks? Qs and As: Microbes and Fuel Systems .Mississippi Seeks Input on Cathodic Protection Document Will Congress Lay Down the Law on USTs? * - Industry Gives the Nod to S. 1850 ------- LUSTLme Bulletin 40 • Tanks at Ground Zero continued from page 1 An Assessment Strategy The seven buildings in the World Trade Center complex were either destroyed or partially collapsed. In addition, several other buildings adjacent to the World Trade Center suffered major structural damage. Based on the earthquake-like force of the catastrophic collapses of the buildings, we believed this destruc- tion had die potential to cause struc- tural damage to chemical and petroleum bulk storage tanks and systems in the vicinity of the site. We concluded that a high prior- ity in DEC's response effort would be to use the department's resources to identify and assess bulk storage sys- tems to prevent further collateral damage from releases from those tanks, and in so doing, protect the health and safety of the recovery workers and the environment. In the weeks that followed, I was given responsibility for coordinating LUSTLine Ellen Frye, Editor " Ricki Pappo, Layout • ; Marcel Moreau, Teclinical Advisor : ;: Patricia Ellis, Ph.D., Teclmical Advisor \ :" Ronald Poltak, NEIWPCC Executive Director ] '% Lynn DePont, EPA Project Officer i LUSTLine is a product of the New England j Interstate Water Pollution Control Commis-:! •i ston (NEIWPCC). It is produced through a ,, cooperative agreement (SCT825782-01-0) J il between NEIWPCC and the U.S. < i Environmental Protection Agency. 5 \ LUSTLine is issued as a communication j service for the Subtitle IRCRA i • Hazardous & Solid Waste Amendments rule promulgation process. ; LUSTLine is produced to promote - information exchange on UST/LUST issues. \ : The opinions and information stated herein - are those of the authors and do not neces- i >; sarily reflect the opinions of NEIWPCC. ', r Tliis publication may be copied. ; i: Pleasa give credit to NEIWPCC :, « NEIWPCC was established by an Act of '„ ,; Congress in 1947 and remains the oldest , •- agency in the Northeast United States j: concerned with coordination of the multi- ; I media environmental activities ]' t of the states of Connecticut, Maine, j in Massachusetts, New Hampshire, ..; I New York, Rhode Island, and Vermont, j NEIWPCG i Boott Mills South, 1QO Foot of John Street ! Lowell, MA 01852-1124 i Telephone: (978) 323-7929 'I :: Fax:(978)323-7919 f. lustllne@neiwgcc.org il > LUSTLine Is printed on Recycled Paper the development and implementa- tion of a plan to assess the structural integrity of the bulk storage tanks and associated systems in proximity to the World Trade Center. DEC's response was intended to prevent and alleviate immediate and future releases of hazardous substances or petroleum that could threaten the health and safety of recovery work- ers and the public or further impair the environment. "ji The World Trade Jl«|l* i* H uiliiiHIIf US" f IIf US" f4t , had a storage capacity of more than 0,000 gallons of petroleum, ana i the adjacent buildings had a storage V i i * t t] -H *r V capacity ofmofe^than 170,000 ! Working with my colleagues, I developed a phased approach that prioritized inspections in areas that had received the most structural damage. The inspection areas were divided into three zones (see map on cover) within an area encompassing approximately one third of a square mile around the World Trade Center. To assess the extent of damage within a short period of time, we established percentage goals for tank inspections in each zone to coincide with the extent of building damage in each area. The goals were as fol- lows: • Zone 1 The area in which build- ings collapsed or suffered major structural damage—100 percent inspection. • Zone 2 The area in which most buildings were damaged but sta- ble—50 percent inspection. • Zone 3 The area in which a few buildings were damaged and sta- ble—25 percent inspection. This phased approach provided us with the opportunity to continu- ously evaluate the inspection results within each zone and adjust percent- age goals for tank inspections accord- ingly. Utilizing the state's tank registra- tion database and the New York City Fire Department's database, we developed a list of storage tanks within each zone to allow DEC to efficiently and accurately assess the condition of the storage tanks and associated piping. These databases i were critical for developing the plan; however, we could not rely on them , alone as they did not always include small unregulated tanks. ' Implementation Implementation of the plan required deploying personnel within the con- straints of security and health and safety at Ground Zero. With a team of trained DEC spill responders, we commenced the tank inspections in accordance with the plan during the first week of October. The inspections focused on structural damage assess-; ment, which included the following: • Inspection of fill pipes, product piping, and vent pipes for damage and functionality • Inspection of tanks for leaks, dam- : age, or stability problems • Inspection of electronic monitor- ing systems designed to register leaks and failures When the inspector identified any damage to the tank or system, DEC advised the tank owner to make the necessary repairs and take any necessary precautions. If there was a release from the tank or system, DEC advised the tank owner to initiate a cleanup or made arrangements with the U.S. EPA to utilize one of their emergency contractors to empty the tank and initiate cleanup. Findings Initially, DEC inspectors made slow progress in completing the inspec-' tions, due to security, accessibility, health and safety issues, and the recovery activities at Ground Zero. By early November, however, DEC: had completed inspections of 84 • tanks ranging in size from 275 gal- lons to 20,000 gallons at 42 buildings.' All of the tanks contained either fuel oil, diesel, or kerosene, which was used for heating purposes or as fuel for backup generators. There were no regulated gasoline tanks since there were no fueling facilities in this area of Manhattan. Except for 18 underground tanks, all of the tanks were aboveground within the buildings. In Zone 1, ------- LUSTLine Bulletin 40 DEC inspector on top of a 20,000 gallon tank that was crushed by the partial collapse of a building. except for 6 of 12 tanks in Buildings 1 and 2 of the World Trade Center, DEC inspected all of the buildings and associated tanks. DEC inspectors identified three tanks in two buildings that were damaged as a direct result of build- ing collapses; two buildings with three tanks with piping damage; and two buildings with eight tanks with the fill and/or vent pipes that could not be inspected because they were buried by debris—these will be tested before being put back into ser- vice. In addition, one of two chiller plants containing Freon was damaged in Building 1 of the World Trade Center—the EPA made arrangements to recover the remain- ing Freon from these plants. In Zone 2, DEC completed inspec- tions of 63 percent of the tanks. DEC inspectors identified two buildings that had two tanks with piping dam- age. For Zone 3, based on an evalua- tion of Zone 2 findings (only two tanks out of a total of 34 tanks with piping damage), we concluded that further comprehensive inspections were not necessary. Instead, as DEC routinely follows up on minor spill incidents in buildings in Zone 3 (and buildings in Zone 2 that were not inspected), spill responders will be inspecting all tanks and appurtenances. Follow Up Except for one building that suffered minor piping damage, all of the tank and piping damage were in buildings that collapsed or suffered major structural damage. Building owners have already initiated or completed repairs of any tank or piping damage. The inspection results indicated that there were very few tanks that were damaged in Zone 2; however, as a precautionary measure, DEC con- tacted owners of storage tanks that it did not inspect in Zones 2 and 3 to advise them to independently inspect their tanks and piping. Tank owners were instructed to notify DEC for a follow-up inspection if they discov- ered piping or tank damage. While conducting the tank inspections, DEC inspectors also checked buildings and the surround- ing areas for other spills that were not associated with tanks. The inspectors discovered and followed up on hydraulic spills from elevator shafts, minor spills associated with recovery operations at Ground Zero, and a significant spill from the elec- tric substation beneath Building 7 of the World Trade Center, which con- tained more than 100,000 gallons of transformer oil and dielectric fluid. Upon Reflection Standing at Ground Zero and looking at the immense destruction sur- rounding the World Trade Center complex, it seems incredible that the damage to the tanks and piping was not greater. The World Trade Center complex had a storage capacity of more than 80,000 gallons of petro- leum, and the adjacent buildings had a storage capacity of more than 170,000 gallons of petroleum. How- ever, the World Trade Center destruction damaged only three tanks with a combined storage capac- ity of 32,000 gallons and caused small to moderate spills from five addi- tional tanks with piping damage. Overall, the storage tanks and their piping suffered very little damage. I completed my assignment in November; however, spill respon- ders from the New York City office continue to deal with spill-related matters at the recovery site. • Karen Gomez is the Regional Spill Engineer with the Region 1 (Long Island) office of the New York State Department of Environmental Conser- vation. She can be reached at kjgomez@gw.dec.state.ny.us ------- LUSTLine Bulletin 40 When MTBE Struck Pascoag;... An Abridged Chronicle of the Impact of an MTBE Release in a Rhode Island Village by Paula-Jean Therrien Prior to the summer of 2001 the state of Rhode Island had the good fortune of having had no public water supplies shut down due to MTBE contamina- tion. We had been monitoring for MTBE in public water systems since the 1980s, and the results were so far, so good. Our clean slate gave us the luxury of listen- ing sympathetically to the stories of public water supply disasters, relieved that such hardships were not ours. But that situation changed dramatically this past Labor Day, when the village of Pascoag was found to have a public water supply emergency due to contamination by MTBE. TJie ensuing events have been dizzying, and I can not possibly present all the facts of this complex event from the perspectives of all involved. The experiences of those inti- mately involved, including numerous officials and agencies from the village, the town, the state, and, most importantly, the residents and businesses of Pascoag, would fill a book. In the interest of space, therefore, I will discuss the events of most impact to the work of the Underground Storage Tank Management Program of the Rhode Island Department of Environmental Management (DEM). Discovery Pascoag is one of many villages in Burrillville, a town in the rural northwest corner of the state. The village's public water was drawn from a wellfield that the Pascoag Utility District used to service over 4,000 people. Around 400,000 gal- lons of water per day were pumped from the wellfield. A new well (Well 3A) had been installed and put on line in the spring of 2001 to supple- ment an existing well (Well 3). Quarterly sampling required by the Rhode Island Department of Health (DOH) for all new public wells had been conducted, and no contamination had been found in the May sampling. MTBE was a tar- get compound in this quarterly monitoring. During the summer, however, a resident of Pascoag found that the water from his tap tasted bad. He had a water sample tested in late August, and elevated MTBE was reported. DOH sampling confirmed that finding and thus began a five-month nightmare for the residents and businesses of Pascoag. Tracking Down the Source The discovery of this drinking water emergency and the ensuing multi- agency response occurred through- out the Labor Day weekend. Emergency Response personnel from the Office of Compliance and Inspec- tion were OEM's first responders. On Labor Day, personnel from DEM's Underground Storage Tank Management Program were called to the office to pore through DEM files to identify and review information on all registered UST facilities storing gasoline and all known LUST sites in Pascoag. The DEM initiated an investiga- tion that week, sampling existing monitor wells and installing addi- tional wells with a Geoprobe in areas that the file reviews identified as potential source sites. This effort yielded enough information to nar- row the list of most likely sources to two—the Burrillville Department of Public Works (DPW) and Main Street Mobil. Both sites were approximately 1,700 feet from the impacted public wells, the DPW to the northeast and the Mobil station to the southwest. The Burrillville DPW had con- ducted a DEM-approved corrective action after discovery of a gasoline release in 1996. As that investigation had not included off-site bedrock wells, the DEM issued an Immediate Compliance Order (ICO) to the town of Burrillville on September 13 to install bedrock wells to determine if any contamination was migrating toward the public wellfield from the DPW. Burrillville installed the required wells and sampling results provided no indication that the DPW was the source of the contamination of the public water supply. Main Street Mobil, an operating gasoline station with three 6,000-gal- lon gasoline USTs, became the most likely source. Free-phase product and high dissolved concentrations of : gasoline constituents, including MTBE, had been found in a Geo- probe well that DEM installed in the sidewalk directly in front of the sta- tion. An ICO was issued on September 13 to the owners and operators of the Main Street Mobil station to test the UST systems for leaks and conduct an . investigation in both the overburden and bedrock. The USTs tested tight on September 19. The operators hired an environmental consultant who installed overburden wells and a recovery well on-site and recovered some product, but they did not install ; the required bedrock wells. Unsatisfied with the owners' and , operators' response to the ICO, on September 24, the DEM and the Rhode Island Attorney General's Office filed a complaint in the Provi- dence County Superior Court to com- pel compliance with the ICO. At a hearing on September 25, the court froze the assets of the owners and operators and required the parties to exchange documentation; however, it denied the state's demand for imme- diate off-site and bedrock investiga- tion activities. Instead, the court permitted the operators to perform a more limited on-site investigation , and directed the parties to return to court on October 3. Liquidation On September 26, Pascoag residents began picketing the station. In response, the operators removed the product from the USTs, effectively ------- LUSTLine Bulletin 40 Burrillville DPW WeU3**WeU3A N A •radford Manor PASCOAG PUBLIC WELLS AND SURROUNDING AREA closing down all operations. Back in court on October 3, the state won a court order directing the owners and operators to begin installing off-site bedrock wells. On October 12, DEM issued a Notice of Violation (NOV) with penalties against the owner and operator for prerelease violations. On October 23, DEM learned that the consultant had ceased work on the project and removed some reme- dial equipment because he was not being paid. The operators filed a motion in court asking to be relieved from the October 3 order due to an alleged financial inability to comply. The state countered with a motion to have the operators held in contempt. At a hearing on October 30 the court adjudged the operators in contempt and placed them into receivership. At the same time, the court provided DEM with full access to the property for the purpose of performing all nec- essary investigation and remediation from then on. On November 2, the two opera- tors, Potter Oil, Inc. and Medea LLC filed voluntary bankruptcy under Chapter 7 (liquidation) of the U.S. Bankruptcy Code. The principals of these corporations are members of a family that owns and operates other gasoline stations and businesses in Rhode Island under different corpo- rate names. The financial relationship between these various corporations and the corporations that operated the Main Street Mobil station is part of the bankruptcy investigation. One of the gasoline stations that these principals own and operate in Warwick, Rhode Island, was the site of a release discovered in 1997 that had an impact on an adjacent neigh- borhood and wetland area and that required the DEM to issue formal enforcement actions to compel reme- dial actions. A release at another sta- tion operated by the same principals affected a number of private residen- tial wells in Middletown, Rhode Island. Water for Pascoag When the contamination was discov- ered, the concentration of MTBE in the wellfield was around 350 to 400 parts per billion (ppb), an order of magnitude above the drinking water health advisory level of 40 ppb estab- lished by the DOH for MTBE. The DOH issued health advisories informing residents that the Pascoag water should not be used for drink- ing, cooking, or bathing small chil- dren. Bottled water was provided by various organizations. The DEM arranged for delivery of bottled water, first to the Pascoag Utility Dis- trict for customer pickup and then to homes. Sixty gallons per month were provided, assuming four people per household. Larger households could get another 15 gallons per month for each additional person. Frequent sampling of the public wells by the DOH had showed a con- tinuing rise in MTBE concentrations in the wellfield. Concentrations rose from over 600 ppb at the end of Sep- tember, to 1,100 ppb by the end of October, to a high of 1,700 ppb by the end of December. The DOH issued health advisories asking residents to limit showering time, ventilate to reduce exposure to MTBE vapors, and reduce overall water use in an effort to minimize the pumping of the wells, which was drawing MTBE to the wellfield. Beginning at the end of Septem- ber, public water from Harrisville, a village just east of Pascoag, was piped into the Pascoag distribution system at a rate of 100,000 gallons a day to dilute the MTBE contamina- tion. While this reduced the concen- tration of MTBE, it still remained elevated—on the order of several hundred ppb. A carbon filter system was installed in the wellfield in mid- November, reducing MTBE concen- trations from 1,200 to 1,700 ppb to under 100 ppb and in some cases to under 40 ppb. However, the health advisories issued by DOH remained in effect. Carbon filtering of the cont- aminated Pascoag well water was expensive, requiring frequent carbon replacement, and was only meant to be a short-term action. The neighboring village of Har- risville provided the long-term solu- tion. The Harrisville Fire District had been planning a new wellfield for some time. In response to the Pas- coag emergency, they accelerated the permit application process, installed three wells in Eccleston field, and were ready to provide water to Pas- coag by the beginning of 2002. How- ever, a disagreement arose between Harrisville and Pascoag as to the administration of the water districts. Harrisville required that the two water districts merge before Har- risville would provide water to Pas- coag. Pascoag was concerned about the degree of representation they were afforded in the merger that was proposed. • continued on page 6 ------- LUSTLinc Bulletin 40 • MTBE at Pascoagfrom page 5 On January 11, 2002, the court ordered that Pascoag shut down its wells and that Harrisville supply water to Pascoag. The details of the merger could be worked out later. Harrisville residents had voted to approve the proposed merger, but on January 14, the residents of Pascoag voted it down. The good news was that water was flowing from Har- risville to Pascoag. Coliform bacteria was detected during system flushing, but it quickly cleared and on January 19, the residents and businesses of Pascoag at long last had dean drink- ing water flowing through their taps. Investigation and Remediation The investigation of the area im- pacted by this release began immediately after discovery of the contamination in the public wells. While a consultant working for the Pascoag Utility District installed monitor wells in the wellfield, the operators' consultant and then OEM's technical contractor installed monitor wells in the area of Main Street Mobil. It became clear that due to the presence of free-phase product on- site and off-site around the Mobil sta- tion, the DEM had to prioritize the removal of the source. OEM's investi- gation and remediation efforts to date have focused on the source area. Multiple monitoring wells for both overburden and bedrock have been installed. A soil vapor extraction sys- tem was successfully pilot tested and a full system has been installed on- site and is in operation. A total of over 1,200 gallons of product had been recovered from the site as of mid-January. A trench for the recovery of free product and contami- nated groundwater was installed and in operation by the end of January. An abandoned 2,000-gallon gasoline tank containing about 500 gallons of prod- uct was discovered during installation of the recovery trench. Analysis of that product has identified it as leaded gasoline, not a source of the MTBE that contaminated the Pascoag wells. The DEM is conducting weekly gaug- ing and sampling of monitoring wells, with analytical services provided by the EPA laboratory. It is not yet known what caused the release or when it occurred. The single-walled tanks, which had been lined and cathodically protected prior to the 1998 deadline, tested tight in September. While we suspect it is a more recent release, it is possible that the release occurred years ago. Piping was replaced in 1994 without the required notification to and approval from the DEM. The required monitor wells were not installed. The DEM has focused resources on investiga- tion and remediation of the released product. The tanks will be removed when funds for that work are avail- able; however, all product has been removed from the tanks. Indoor air issues arose in November. DEM responded to odor complaints from Bradford Manor (an elderly housing facility), from a small school administration building, and from a private residence—all down- gradient of the station. Venting and sealing cracks abated the problems at the school building and the manor. An air filtration unit was necessary for the basement of the residence to reduce benzene concentrations; a consultant hired by the homeowner later added an air exchange unit. As usual, bedrock has made the investigation challenging. Pascoag's new public well (Well 3A) was installed 9 feet into the bedrock, intersecting two large fractures. Solid casing was sealed into the bedrock, isolating the well from the overbur- den. The older well (Well 3), which is located 8 to 10 feet away, had been installed only to the bedrock surface. Each well was pumped at rates of up to 500 gpm. It is not clear if the timing of the finding of MTBE contamination in the wellfield was due to a recent release or if Well 3A was pumping water from deeper in the bedrock and inter- cepted an older MTBE plume that Well 3 had not. Bedrock exists at and near surface in the area of the Main Street Mobil, and it has complicated the mapping of the product plume and the interpretation of dissolved contamination results. It will also cer- tainly pose an added degree of diffi- culty for remedial efforts. Additional bedrock monitoring wells will be needed to fully delineate the contami- nation; only then can DEM determine the best remedial approach for the dissolved contaminant plume. The Pascoag wellfield, which has been pumped at a high rate and con- tinuously for years, has just been shut down. The effect this shutdown will have on the groundwater and the plume of contamination in this area remains to be seen. Will the water table rise to surface and flood peo- ple's yards? Will indoor air contami- nation in buildings over the plume become a larger problem as the water table rises? If it becomes necessary or '. advantageous to resume pumping of the wellfield, treatment and disposal of the water will be a significant issue. Funding Sources Funding for the huge costs incurred by response to an emergency of this magnitude is challenging. It became apparent early on that significant funds would not be available from the owners or the operators of Main Street Mobil. Circumstances are as ; follows: • The DEM had about $400,000 available from EPA LUST Trust funds. This money has been used to fund OEM's actions, including the investigation and remedial work conducted by DEM and its technical assistance contractors ; and the bottled water delivery to , the residents of Pascoag. • The application by the operators of Main Street Mobil to the UST , Financial Responsibility Fund was denied because of noncompliance identified in the unresolved NOV. After the DEM became the per- forming party, up to $350,000 was , offered by the Fund Board to install and operate the carbon fil- , tration system on the Pascoag I wells. The Fund is also available to reimburse third-party claims by Pascoag residents and businesses , that incurred expenses related to the water emergency. Additional monies will be sought from the Fund for OEM's continuing inves- tigation and remedial action. • DEM has submitted an USTfields grant application for up to $100,000 to be used for work at Main Street Mobil. This includes , removal of the USTs and contami- nated soils and installation of additional overburden and bedrock wells, both on-site and, off-site. ------- LUSTLine Bulletin 40 Epilogue The contamination of the Pascoag wellfield has been a very public issue that seriously impacts all the people who live and work in Pascoag. It has drawn constant local and statewide media attention. With such attention comes criticism. A frequent and expected criticism of agencies in- volved in a complex response such as this is that the time it takes to accom- plish the various tasks associated with the emergency is longer than the public thinks it should take. And cer- tainly a review of events could result in lessons for the future. This event has heightened statewide awareness of the conse- quences of contamination in our pub- lic water supplies. State and local agencies are reviewing what can be done to prevent problems in the future. DEM regulations prohibit the installation of new USTs in wellhead protection areas, although this event involved a facility that existed before the regulations took effect. DEM has prioritized compliance inspections at gasoline stations in GA groundwater areas, where the groundwater must be suitable for public or private drinking water use without treat- ment. Communities can optimize protection of their public water sup- plies by controlling land develop- ment and creating buffer zones. The incident is hardly over for many, including the DEM. The inves- tigation and remediation of ground- water contamination in bedrock to drinking water standards is a diffi- cult assignment and one that the DEM will be working on for some time to come. • Paula-Jean Therrien is a Principal Environmental Scientist in the Under- ground Storage Tank Management Program of the Office of Waste Man- agement of the Rhode Island Depart- ment of Environmental Management. Paula-Jean acknowledges contributions from Patrick Hogan, Senior Engineer and DEM Project Manager for the Main Street Mobil LUST site, and from Brian Wagner, Esq., of the DEM Office of Legal Services. Paula can be reached at (401) 222-2797 ext. 7125 or pjtherri@dem.state.ri.us Getting Started with UST Owner/Operator Education in Florida, California, and Oregon Florida's Tank School Tank School is an online training course developed for and approved by the Florida Department of Environmental Protection (DEP). It provides informa- tion designed to help owners/operators (0/Os) avoid costly UST system prob- lems and comply with all the requirements of the Florida Storage Tank Rule. All DEP storage tank rule requirements are covered in separate AST and UST tracks. Forms, manuals, rule definitions and other helpful materials can be downloaded and printed to assist in regulatory compliance and provide valu- able reference material. Tank School may also be used to reduce the cost of tank insurance premiums since insurance companies consider the positive benefits of training programs in evaluating the risk of loss to be insured. The course can be purchased with a major credit card for $200 and accessed any time, anywhere, for a 90-day period via the Internet. Multiple choice and true-false tests are included in the course materials. Persons suc- cessfully completing the course can print a course completion certificate. To find out more about Tank School, log onto www.fltank.learnsomething.com, or contact Bill Reeves at (850) 385-9443 or by e-mail at Br1009@aol.com. California O/Os Will Need to Meet New Standards California's Legislature recently adopted Senate Bill 989 (Stats. 1999, Ch. 812), requiring various parties, including UST owners and operators, to "meet minimum industry-established training standards." The legislation required the State Water Resources Control Board (SWRCB), which oversees the UST program in California, to adopt regulations implementing this requirement UST program staff established a workgroup of industry representatives, con- sultants, and local regulatory agencies to develop industry-based owner/oper- ator training standards. SWRCB staff expect to propose regulations requiring individual(s) responsible for the day-to-day operation of UST facilities to be trained in accordance with the standards developed by the workgroup. To sat- isfy this requirement, individuals could either pass an exam provided by an independent third-party testing organization or complete an approved training course. SWRCB staff are also working with the International Conference of Building Officials (ICBO) on their UST owner/operator certification program. California's UST owner/operator training program is still under develop- ment. For more information, call Shahla Farahnak at (916) 341-5668 or Scott Bacon at (916) 341-5873. Oregon Legislature Mandates Operator Training Oregon's 2001 Legislative Assembly directed the Department of Environmen- tal Quality (DEQ) to develop rules for a mandatory operator training program. A subcommittee comprised of DEQ UST staff and industry representatives has been working on a draft proposal since October 2001. DEQ's full Advisory Committee met on February 19,2002, to discuss the draft proposal. The agency expects to have a public comment period in July, with the presentation of draft rules to the Environmental Quality Commission in September 2002. For additional information, contact Laurie McCulloch, Senior UST Policy Coor- dinator at 503-229-5769 or e-mail at mcculloch.Iaurie@deq.state.or.us. Information on this effort will be posted on the DEQ Web page at: http://www.deq.state.or.us/wmc/tank/USTAdvisoryCommittee.htm. ------- LUSTLine Bulletin 40 JSy^HTslitrl Natural Attenuation: Is Dilution the Solution? by Joseph E. Odencrantz, Mark D. Varljen, and Richard A. Vogl i ust as it was beginning to look like we were winning the remediation bat- j tie at groundwater contamination sites, the impact of MTBE releases J reared, its ugly head. In the midst of our remediation battle and our MTBE discoveries, we have seen the blossoming of a management strategy for conta- minated groundwater known as monitored natural attenuation, or MNA. MNA refers to the reliance on natural attenuation (see definition below) processes within the context of a controlled and monitored site cleanup approach to achieve remedial objectives. A close examination of the application of MNA, however, reveals some potential problem areas involving the misidentifica- tion of processes that govern contaminant plume behavior. These problems are often the result of the misapplication of simulation modeling techniques and/or consideration of unrepresentative data due to outdated or inappropriate monitoring well construc- tion and sampling approaches. Dispersion on a grander scale has been advocated at municipal production wells as one approach to diluting the problem plume. Such problems have become especially apparent at MTBE release sites, where the use of MNA could present the danger of a potential false sense of security. We may be encouraging "walk away" site closures when active remediation should really be implemented. In this article we'll discuss potential pitfalls associated with MNA and explore the limitations of monitoring networks. Ground- water sampling techniques can promote misidentification of plume biogeochemical parameters and in some instances excessive dilu- tion. We'll examine the location and construction of monitoring wells, seldom spelled out in state standards or guidelines. We'll conclude by highlighting the potentially false sense of security we may have when we mistake concentration dilution for concentra- tion destruction at a LUST site or in a municipal production well. Hmm. Wonder what became of yesterday's smoke. Destructive Processes? The term "Natural Attenuation" (NA) has been defined as "naturally occurring processes in soil and groundwater environments that act without human intervention to reduce the mass, toxicity, mobility, volume, or concentration of contami- nants in those media" (Wiedemeier et al., 1999). This popular definition goes on to mention that the "in-situ" processes of NA include biodegrada- tion, dispersion, dilution, adsorption, volatilization, and chemical or bio- logical stabilization or destruction of contaminants, meaning that natural attenuation is composed of numer- ous contributing factors of which biodegradation is only one. In practice, unfortunately, the term "natural attenuation" is often used synonymously with such terms as intrinsic bioremediation, self reme- diation, natural restoration, passive 8 bioremediation, or intrinsic remedia- tion. The negative result of this is that it is increasingly common to inter- change "natural attenuation" with "remediation," when in fact they are not synonymous. Natural attenuation occurs to some degree at every site; however, depending on site conditions, there can be definite limits to its effective- ness as an interim or long-term solu- tion because natural attenuation does not necessarily imply that contami- nants are removed. Furthermore, the site-specific conditions that often limit the effectiveness of natural attenua- tion as a contaminant removal/ destruction process are rarely prop- erly evaluated. It is vital that we distinguish between destructive pro- cesses and dilution. To do this it is first necessary to establish the types of biological processes that may be induced or monitored at a site. Intrinsic or Engineered? Consider a "Biologically Active Zone," or BAZ, which occurs in close proximity to the contaminant source in the presence of electron donors in the mix of available electron accep- tors. Contamination that escapes the BAZ escapes biological reaction and continues to move downgradient. Perhaps this is the reason why many of our chlorinated solvents plumes are so long (miles and kilometers long). For chlorinated solvents dis- solved in water, biodegradation typi- cally occurs within a BAZ, and the limiting factor is the availability of electron donors (primary substrates) for which a zone of increased biologi- cal activity can be established. In other words, there must be some growth of bacteria in order for biodegradation to occur, and growth requires the overlap of bacteria, elec- tron donors, and acceptors. ------- LUSTLine Bulletin 40 Biodegradation can be either intrinsic or engineered. Intrinsic biodegradation processes refer to those which occur under indigenous aquifer conditions within the conta- minant plume. Contaminant plumes vary in size and shape in accordance with each constituent, as does the intrinsic biodegradation rate of each of these compounds. Oxygen is often consumed near the source of a gaso- line leak by the indigenous bacteria, using benzene as an electron-donor and oxygen as an electron-acceptor. In the far-field region of the plume, indigenous oligotrophic bacteria (those which survive on trace levels of substrates) may be stimulated by some gasoline constituents, causing biodegradation to occur at slow rates. Engineered biodegradation re- fers to the adding of nutrients, bacte- ria, electron-acceptors (e.g., oxygen, nitrate, sulfate) and perhaps other electron-donors (e.g., molasses, lac- tate) primarily in the near source area to develop a healthy BAZ. Flow con- trol or a circulation system to aid in the efficiency of the BAZ sometimes accompanies this in situ biodegrada- tion. In examining the potential bio- degradation of a compound in the field, you should rely on other lines of evidence such as tracers, microcosm studies, lack of degraders, published biodegradation pathways, compari- son of movement to the other con- stituents in the source, and changes of mass of the compound (National Academy of Sciences, 2000). Regardless of the type of biodegradation process that may be occurring at a site, establishing lines of evidence on a compound-by-com- pound basis is necessary. An exami- nation of the spatial variability of oxidation-reduction potential and dissolved hydrogen may provide us with some idea of the potential zones of dominant biodegradation regions; however, it does not necessarily tell us if there has been biodegradation of a particular compound. For intrinsic biodegradation processes, how do we determine if decay rates are sufficiently large to cause a change in mass or if biodegradation is occurring at all? Unfortunately, these biodegradation processes are commonly misidenti- fied, and decay rates are, therefore, incorrectly determined. Puff of Smoke A recent study conducted at the Bor- den Aquifer, Borden Airfield, Ontario, Canada, focused on a 16- month university research project which was extended to 8 years after the initiation of the original project (Schirmer and Barker, 1998). Eight years after MTBE was instanta- neously (for all practical purposes) injected into an aquifer, the researchers decided to "go find it." ?_Natural attenuation occurs to some &•'degree at evefysite; however, p-**. ^KurS-uc V *" **"™-i"F^T i t «= 3*fTTgpTv*T ^epe/j^/^o^s^co/7iW/OT^|ere ^n *e definite limits toils '^flecljyejiess as an interim or ygtig-term solution because natural ^attenuation does not necessarily ^ imply that contaminants The researchers only found 3 per- cent of the injected mass and con- cluded that 97 percent had biodegraded—simply because they didn't find the mass. This is analo- gous to trying to find all the smoke from a puff of smoke released to the outdoor air 7 hours after its release (assume dispersion in air is 10,000 times that in water; 8 years is 70,080 hours). Finding all of this smoke is clearly something that we would not expect to be possible, yet when reviewing this work, few seem to consider that perhaps the researchers simply didn't find (or couldn't quan- tify) the dispersed contaminant. The work was excellent with respect to quantifying the natural attenuation of a small instantaneous amount of MTBE; however, it did not document biodegradation. There was no definitive proof (such as the presence of metabolic byproducts) presented that suggests that biodegradation of MTBE occurred in groundwater. Unfortunately we are now seeing this assumption of intrin- sic decay being carried forth in prac- tice by both the consulting and regulatory communities. What was missed in the research was recogni- tion that natural attenuation ofMTBE can occur, under the right set of cir- cumstances, in the absence of biodegradation processes. So where do you draw the line between dispersion/dilution and biodegradation? You must first deter- mine whether changes in concentra- tion are changes in mass of the plume or if the plume has moved to places unknown in the aquifer. Decay, Dispersion, and Misnomers Monitored natural attenuation proto- cols (OSWER Directive 9200.4-17P, 1999) generally involve the collection of biogeochemical data from ground- water monitoring wells at sites. The data are correlated in time and space with the various chemicals of concern (COCs) to establish predominant biodegradation mechanisms. In evaluating the size, behavior, and mass of groundwater plumes, monitoring wells are sampled by a variety of techniques at fixed loca- tions. This protocol assumes that the monitoring wells fully delineate the plume and that there is an adequate number of wells to calculate a plume mass every time the wells are sam- pled (unfortunately this is not often the case in practice). Under this assumption, though, can we really give some kind of explanation of what the plume is doing (i.e., expanding, remaining sta- ble, or shrinking) by examining the time history of concentration of a gasoline compound at a well? Of course this depends largely on where the well is located (i.e., source prox- imity), how it was constructed (e.g., type, screen length), and how it was sampled (i.e., low-flow, traditional purge, or no purge). If the concentra- tion rises and drops over a 2-year period, does this mean that the plume is shrinking, that is has moved past the well, or that there is a change in flow direction? This question cannot be an- swered unless we look at the concep- tual model of the site, changes in concentration at other wells, and, perhaps, changes in other biogeo- chemical parameters—parameters that are often overlooked. So the biodegradation is being inferred, rather than directly confirmed. • continued on page 10 ------- LUSTLitte Bulletin 40 m Natural Attenuation from page 9 These considerations are intu- itive, and most practicing profession- als routinely use standard methods and state guidelines to work through these types of evaluations. When evaluating the dominant attenuation processes, obtaining representative data from monitoring wells is a criti- cal first step in moving onto isolating NA processes. The importance of col- lecting representative sampling data (as influenced by well location, con- struction, and sampling protocols) cannot be underestimated. This will be discussed further in later sections of this article. Assume for the moment, how- ever, that we have not only an ade- quate number of wells to fully delineate our plume but that there are only nondestructive NA processes at work (i.e., advection, dispersion, sorption, and volatiliza- tion) and we can predict them per- fectly using models (another assumption that is never really achieved in practice). Now if sorption and volatiliza- tion were minimal, the mass of the plume would remain virtually con- stant if we calculated it each time from the concentration in the wells. We could go back and adjust any small changes in mass by our models of sorption and volatilization. This approach has been used at a variety of research sites where several tran- sects of multilevel monitoring wells were placed perpendicular to the groundwater flow direction. If we had the typical monitoring wells at a service station site, however, and ihe same exercise was performed, it would be nearly impossible to make a reasonable estimate of the plume mass with time. Continuing with our example, consider a situation where we are faced with applying a common model, BIOSCREEN, to estimate the NA at a site. We have a well at 30 feet downgradient (near-field) and one at 300 feet downgradient (far-field). We prepare to run the model by method- ically estimating all the independent variables (i.e., source concentration, hydraulic conductivity / gradient, and longitudinal dispersivity). We run the model with no first-order decay and find both wells are off sig- nificantly. _ In this particular case we do not have lines of evidence of biological degradation, so we will try to use a first-order "decay" coefficient to match the results found in the field. The near-field well matches with a first-order decay rate of 0.2 years and the far-field well matches with a rate of 1.5 years. Without getting into the details of transport modeling, it might seem reasonable that there is more decay near the source than away from the source. Using the decay coefficient in this manner assumes decay is a lumped parameter in that it is not specific to a mechanism such as biodegradation. In this case it is used to account for loss of mass in a gen- eral sense. Perhaps the loss mecha- nism is not necessarily decay and there is more dispersion in the sys- tem than initially estimated. We ran the model with ten times the disper- sion without first-order decay and found the model output matched the data from the wells as shown in Fig- ure 1. This suggests that perhaps first-order decay in some sites is not occurring. So the next time you see a degra- dation rate or half-life presented, (a) be sure you clarify what processes it encompasses, (b) establish exactly how it was determined, (c) make cer- tain other processes, such as disper- sion, were estimated correctly, and (d) if it is a first-order biodegradation rate, examine the available lines of evidence to substantiate it. Unfortunately, the BIOSCREEN "Help" section encourages the mix- ing of processes, as seen from the fol- lowing passage: "Modelers using the first-order decay model typically use the first-order decay coefficient as a calibration parameter and adjust the decay coefficient until the model results match field data. With this approach, uncertainties in a number of parameters (e.g., dispersion, sorp- tion, biodegradation) are lumped together in a single calibration para- meter." Now that we have highlighted the potential ramifications of confus- ing dispersion and nondestructive decay with biodegradation processes, what about mixing at a larger scale? What if we assume that all the conta- minant mass leaves from a site and enters a municipal groundwater pro- duction well? What happens then? First things first: How do you esti- mate the mass of a contaminant leav- ing a site? Mass Flux and Dilution A recent paper by Einarson and Mackay (2001) presents a framework by which dissolved-phase mass of groundwater constituents mixes with water extracted from production wells. The mass-flux mixing approach takes the mass from a o IN _4 O) E o s 09 U a o CREASE 16.000 14.000 12.000 10.000 8.000 - 6.000 - 4nnn - 2.000 - 0.000 1 D DISPERSION AND DECAY COMPARED TO BASE CASE — .— Base Case . lnv • Base Case - 0.2 year decay \ \ ! \v J w \Near Field ^ — ^-__ $ ^^~*^~*^*^— Fnr Fiplri 0 100 200 300 Distance from Source, feet i 400 ------- LUSTLine Bulletin 40 groundwater plume and mixes it with the water from typically larger, deeper flows and formations. The authors state: "They [the capture zones] are useful for illustrat- ing contaminant dilution in continu- ously pumped supply wells." The capture zones are the regions of groundwater that are pumped into a production well as a function of time. According to the authors, when mul- tiple plumes are heading toward a municipal well, "the larger pumping rates of many municipal supply wells may be sufficient to cause enough blending so that contaminant concen- trations in extracted water remain relatively low." Einarson and Mackay's paper seeks to establish the mass flux of contaminants leaving a site by using multilevel well fences on the down- gradient side of a plume in order to provide an accurate determination of flux leaving the site. In the example in the paper, seven locations spaced 11 feet apart each contained seven vertical probes spaced 2 feet apart; the first probe was located 1.5 feet below the water table (all distances approximate for they were scaled from diagrams in the original paper). Each of the 49 probes sampled represented 22 square feet of aquifer perpendicular to the flow direction and the entire fence a 1,078-square feet section of the contaminant plume. Although this is an extensive monitoring array, the data seem to indicate that even this elaborate mon- itoring approach was not adequate. The sides and bottom of the transect contained contaminant in significant concentrations, implying that only a portion of the plume was sampled. The example yielded a mass flux of 31 grams of a compound per day after multiplying by the calculated specific discharge (Darcy Velocity of 0.64 inch/day) and adding up each mass flux from the individual probe areas. If this mass flux were to enter a municipal supply well pumping 1,000,000 gallons per day (694.4 gal- lons per minute), the resulting con- centration after mixing would be 8.2 ug/L. The average concentration at the fence was approximately 20,000 ug/L. The net effect is lowering the concentration by approximately 2,500 times once the water is pumped from the aquifer from the municipal sup- ply well. What does this imply? Have we now come to rely on end-user dilu- tion to manage contaminant plumes? Furthermore, what does this say about our sampling results if moni- toring wells are sampled with high- volume, high-flow purging and sampling techniques, or if the moni- toring wells are located in areas that may underestimate the dimensions of the plume? The Sway of Sound Well Location, Construction, and Sampling Most state standards or guidelines for implementing MNA do not address well construction and sam- pling procedures. Consider a LUST at a service station above a water table aquifer in a groundwater recharge area. Typical groundwater monitor- ing is conducted using wells with screens completed across the water table (presumably to measure LNAPL, even though they are far downgradient of the LUST, and no residual hydrocarbon was noted dur- ing drilling). Common sampling shortcomings may include the use of high-flow purging, including explo- sive vacuum truck purging (complete evacuation), bailing, failure to mea- sure parameters with a closed flow- through cell, and passive or no-purge sampling. These shortcomings can lead to an underestimation of the lateral extent of the dissolved contaminant plume (MTBE and BTEX) and misrep- resentation of biogeochemical condi- tions (e.g., REDOX and other lines of evidence) in the following ways: • Wells completed across the water table. Water that is being sampled from a well completed across the water table will always have some direct contact with the atmosphere (increasing the likelihood of volatilization) through the well bore. Also, zones of artifi- cially enhanced biodegradation (not representative of the aquifer) often occur in the immediate vicinity of I the well due to increased atmos- pheric contact allowed by the well. Enhanced volatilization and bio- degradation can occur right at the water table (due to atmospheric con- tact) but not at deeper levels in the aquifer, so the sample collected from the water table may not be represen- tative of the dissolved plume; and in recharge areas a dissolved plume will likely move vertically downward and a well at the water table may completely miss the plume. In this situation, fresh water from precipita- tion recharge may also reduce con- centrations of dissolved constituents right at the water table. • High-flow purging. This may cause dilution as described in the previous section. Also, volatilization losses may occur if excessive drawdown is caused, and water "cascades" into the well screen. Increased oxygena- tion may occur, eliminating the abil- ity to accurately characterize REDOX conditions. If an electric pump is used, dissolved hydrogen determina- tions may be overestimated due to electrolysis. • Sampling with a bailer. Volatilization losses may occur due to agitation. Mixing of altered (due to atmos- pheric contact) water with .water being sampled is inevitable. Accurate field parameter determination and proper sampling for dissolved gases (oxygen, hydrogen, methane) is impossible. • Failure to measure parameters with a closed flow-through cell. Both bias (high) and variability is introduced into dis- solved oxygen determinations that have been collected by either pump- ing or decanting (from a bailer) into a cup and inserting a hand-held probe. Measurements of pH can be affected by off-gassing of CO2. • Passive sampling or "no-purge." These methods sample water in the well, not in the aquifer. While ambient flow may occur, and water in the well may be representative of the aquifer without purging, this must be veri- fied by purging, because ambient flow (and hence "flushing") may occur to different degrees at different locations and may also vary season- ally at a given location. Furthermore, when passive sampling with diffu- sion-type samplers, the sampler itself may block any ambient flow. In summary, we must keep in mind that many standard practices in groundwater monitoring are not giving us representative data that is • continued on page 12 11 ------- LUSTLine Bulletin 40 • Natural Attenuation from page 11 useful for truly evaluating MNA. Solutions to this problem, are to develop and enforce standards for well location, construction, and sam- pling protocols such that the data will be useful for the intended pur- pose. When "standard" groundwater monitoring practices were first implemented years ago, no one was thinking that we would be "taking the pulse" of a site in the manner required for MNA evaluations. Our new information needs to exceed the abilities of the old practices to deliver the required information. New stan- dards should encourage short- screened wells in three dimensions (only screened across the water table where NAPL monitoring is required) and low-flow purging and sampling with nonelectric positive displace- ment pumps. So, Do We Care? It is all about liability and short-term versus long-term thinking. You might get approval for a "walk away" today based on some notion of NA; however, if it is not technically correct, it may be a long-term liability (for both regulators and the regulated community) regardless of current accepted technical practice. Both reg- ulators and LUST owners are under pressure to get sites "off the list." Both also stand to suffer some nega- tive consequences if we have to revisit these sites and implement active remediation in the future because we find out that contaminant reduction processes were not what we'd thought they were. One might initially think that in practice it doesn't matter what is going on at a site—destruction versus dilution—as long as concentrations are reduced below a risk threshold. Maybe so, provided direct monitor- ing can prove this is happening. In practice, however, we are frequently dosing sites and electing not to con- duct active remediation, not because concentrations are already below a threshold, but rather because of some prediction that contaminant concen- trations in groundwater will not exceed some risk-based threshold at some location downgradient some time in the future. 12 Seems to make sense. But what if for some reason (like the ones men- tioned in this article) our predictions are not correct? What if we underesti- mate the plume mass in the first place, and we mistake concentration dilution (due to mixing or improper sampling) for concentration destruc- tion (i.e., biodegradation)? What if we calculate a degradation rate and extrapolate that out? The model will paint a rosy picture, and we walk away from the site. In reality, those contaminants are still out there, spreading further while we sleep soundly with a false sense of security that they are being degraded. This brings to mind a few more questions. What happens in an urban area were several of these diluted plumes commingle? What happens to the aquatic ecosystem that receives this contaminant mass discharge? We're back to a question posed by the surface water pollution commu- nity 30 years ago. Is dilution the solu- tion to pollution? In short, we think it can be, but only in certain circum- | Is dilution the solution to pollution? [ In short, we think it can be, but only I* J IIk T I < . I in certain circumstances and f, '',".' , ,. I certainly not without more confidence in our data and more careful evaluation and comprehensive understanding of 1 what is really going on. j... • i :- stances and certainly not without more confidence in our data and more careful evaluation and compre- hensive understanding of what is really going on. If we are to comfortably embrace MNA as an alternative to active remediation, we'd better be certain that (a) if concentrations are low, there will be no cumulative affects and (b) if we are relying on degrada- tion to remove contaminants to achieve a risk-based concentration goal, we are very confident in our assessment of biodegradatioh. The only way to do this is through better groundwater monitoring and biogeo- chemical evaluation practices that will result in the proper recognition of the natural attenuation processes : that are actually occurring at a given site, their relationship to the concen- tration trends observed, and the use of these findings to accurately predict concentrations into the future. II Joseph E. Odencmntz, Ph.D., P.E.,is Principal Civil and Environmental Engineer at Tri-S Environmental Con- sultants and is involved as an expert consultant on MTBE projects in sev- eral states. Publications related to nat- ural attenuation and MTBE can be found at www.tri-s.com. Joseph can be reached at jodencrantz@tri-s.com. Mark D. Varljen is a Hydrogeologist/ Project Director at SCS Engineers. He can be reached at mvarlj en@scsengineers.com. Richard A. Vogl, R.G., CHG, is Prin- cipal Hydrogeologist at HydroGeo Consultants in Costa Mesa, California. He can be reached at ravhydrogeo@aol.com. References Einarson, M.D., and D.M. Mackay, 2001. "Pre- dicting Impacts of Groundwater Contamina- tion." Environmental Science and Technology, Vol. 35, No. 3. 66A-73A. (Contains reference to supplementary material entitled "Estimating Future Impacts of Groundwater Contamina- tion on Water Supply Wells," dated Feb. 1, 2001.) . National Academy of Sciences, 2000. Natural Attenuation for Groundwater Remediation. Com- mittee on Intrinsic Remediation, Water Science : and Technology Board. National Academy Press, Washington, D.C. OSWER Directive 9200.4-17P, April 21,1999., Use of Monitored Natural Attenuation at Super- fund, RCRA Corrective Action, and Underground Storage Tank Sites—U.S. EPA, Office of Solid Waste and Emergency Response, Washington, D.C. .. , : Schirmer, M. and J. F. Barker. "A Study of Long-Term MTBE Attenuation in the Borden Aquifer, Ontario, Canada." Ground Water Mon- itoring and Remediation Spring 1998:113-122. Wiedemeier, T.H., J.T. Wilson, D.H. KampbeU, R. N. Miller, and J.E. Hanson, 1999. Technical Protocol for Implementing Intrinsic Remediation with Long-Term Monitoring for Natural Attenua- tion of fuel Contamination Dissolved in Ground- water, Volume I. Air Force Center for Environmental Excellence, San Antonio, TX. ------- LUSTLine Bulletin 40 Do Monitoring; Wells Monitor Well? Part I This article is the first of a series that will delve into the realm of site characterization. Successive decisions concerning any partic- ular site hinge on our understanding of what lies beneath the ground's surface. With so much at stake, is it not wise to seek to improve our site characterization when possible? Of course, the answer is "Yes." The very first thing we should seek to improve is the data that we collect. We must make it our business to continually ask our- selves and others: How well does this information support the decisions we make with respect to the site? Our formal education and experience give us insight into how geology, hydrology, and contaminant behavior interact to deter- mine where and at what level contaminants are likely to be found. As an aid to our understanding, we usually develop a conceptual site model. But our conceptual model must be validated by actual observations in the field, or it must be modified accordingly. Each bit of additional information allows us the opportunity to refine our model. And it's important to realize that all the pieces of information are interrelated. For example, the decisions we make about monitoring well placement or screen length directly affect how well the other pieces of the model will ultimately fit together. Well Begun Is Half Done... The primary function of groundwa- ter monitoring wells is to provide subsurface access for (a) the measure- ment of liquid levels and (b) the col- lection of liquid samples for analysis. In the UST program, the liquids that we are most concerned with are groundwater and petroleum prod- ucts, whether in the nonaqueous or dissolved phase. Monitoring wells may also be used to collect gas/vapor samples and measure ver- tical transport properties, and they are convenient (although rarely opti- mally located) places to install vari- ous components of remediation systems. Given that monitoring wells have such a wide variety of important uses, why is it that so little considera- tion is actually given to the question of whether the data we derive from them is of adequate quality? This question may come across as being contrary to conventional wisdom, but lef s think about it. Lefs begin by lay- ing out a scenario for a "conven- tional" site assessment that relies on typical monitoring wells, and then we'll dig a bit deeper to uncover some shortcomings: i,i.cr: We have a typi- cal neighborhood gas station that sits on a squarish quarter- acre lot at the intersection of two relatively busy streets. The station building is a one-story brick structure — an office/ storeroom occupies one-third of the building, and two garage bays occupy the other two thirds. One of the two pump islands (each with two dis- pensers) is in front of the station and parallel to the street; the other is parallel to the side street. There are three large 2,000- to 10,000-gallon USTs used for fuel storage and a small tank for used oil. The entire surface area of the lot is covered with con- crete or asphalt. Overhead power and telephone lines run above the property lines paral- lel to both streets. Underground utilities (i.e., water, sewer, nat- ural gas) also run parallel to the property line marking the front of the property. Representatives from an environmental company hired by the owner/operator to con- duct a site assessment arrive at the station. They visually sur- vey the station layout, noting the painted markings on the pavement where the utility company has delineated the water, sewer, and natural gas lines, and proceed to install a monitoring well as close as pos- sible to each of the four corners of the station property. However, due to the loca- tions of overhead and under- ground utilities, the tank field, the pump islands, the waste oil tank, and the station building, • continued, on page 14 ~ 13 ------- WSTLine Bulletin 40 • Wander LUST from page 13 the locations for the monitoring wells must be shifted somewhat from the originally intended locations at the property cor- ners. As a result, in plan, these four points outline a com- pressed and elongated quadri- lateral, not a square. At each location, the drill rig advances a 10- to 12-inch diameter bit in 5-foot incre- ments and then stops to allow for undisturbed soil samples to be collected. Each sample is 18 to 24 inches in length. A geolo- gist records the lithologic infor- mation for each sample and screens each interval with an organic vapor meter/analyzer for the presence of petroleum hydrocarbons. Beginning with the first detection of organic vapors, soil samples are placed in labeled jars and stored on ice in a cooler. Later, the jar with the sample containing the highest reading from each borehole will be sent to a laboratory for analysis. The on-site geologist also logs cuttings between the undisturbed samples. When the boring finally reaches the water table, it is advanced another 5 to 10 feet and then the casing and screen are installed. The casing and screen consist of a 4-inch inside diameter Schedule 40 PVC pipe with factory-threaded cou- plings and factory-cut slots (0.020 inch). Sufficient lengths of casing and screen are installed such that the screened portion extends 5 to 10 feet below and above the water table to allow for seasonal vari- ation. The screened portion is backfilled with coarse (#2) sand to a level that is a foot or two above the top of the screen. On top of the sand is a bentonite seal that is 2 to 5 feet in thick- ness. The remaining annular seal-to-land surface is sealed with a bentonite-grout slurry. The wellhead itself is protected either with a flush-mount cover or steel surface casing. The top 14 of the well is fitted with a lock- ing, watertight well cap. Later, the newly installed well is "developed" using either pumping or surging tech- .niques. Finally, after being allowed to recover for at least 24 hours past development, the well is ready for water level measurement and liquid sam- ple collection. Sounds familiar, doesn't it? With respect to the above scenario, con- ventional wisdom holds that the stratigraphy, water table, and groundwater flow direction are all well defined. Each boring has a con- tinuous log plus undisturbed sam- ples at 5-foot intervals. Analysis of soil samples from each boring indicates only minor amounts of residual contamination near the tank field. Analysis of groundwater samples from each of the four wells indicates (we'll assume) that they are essentially free of dissolved hydrocarbons. Quarterly gauging of the water levels indicates that water table fluctuations should remain within the screened interval so that none of the wells will go dry. Since the well casings are 4-inch inside diameter, if needed they can accommodate free-product recovery (and other remediation technology) equipment. For purposes of the following discussion, we'll assume that there is no problem with sampling or well installation techniques—this isn't a discussion of push technologies ver- sus conventional drilling rigs, or expedited assessment versus conven- tional techniques. Our focus is strictly on the design and location of the monitoring wells. So what can the problem(s) possibly be? Divining the Water Table In Euclidean geometry, three nonco- linear points in space are required to define a plane (if the points were col- inear, then an infinite number of planes—all equally plausible—could be drawn through the line). By assuming that the water table is pla- nar, the magnitude and direction of groundwater flow can be deter- mined. The "conventional" site assessment described above employs not just three but four monitoring wells, so the groundwater flow direc- tion can be well defined from these data, right? Wrong! While three points in empty space are adequate to define a mathemati- cal plane, the water table isn't in empty space, and it is hardly a plane. Its position relative to a lower confin- ing layer depends upon a number of variables that include amount and location of recharge sources, soil per- meability, soil heterogeneity, and location and strength of pumping wells and other sinks. How many wells are sufficient? That's not an easy question to answer, except to say that it's site- specific. In any case, the more wells , there are, the more accurately the water table can be defined. If we accept that we're limited to just four locations on any given site, we can learn a lot more if several wells with shorter screens at different elevations ; are nested at each of these four loca- ; tions. This is absolutely essential if \ we're to evaluate the presence and importance of vertical transport at a site. i Guessing Groundwater Flow Direction(s) It is typically assumed that by , default, three of the wells are downgradient and one well is upgra- ^ dient—but upgradient and down- gradient from what? Tank field; excavations (which are backfilled ; with pea gravel) have a conductivity that is relatively higher than that of the surrounding , soil. Rainwater . runoff that flows beneath the paved surface but on top of the soil often. collects in tank fields, creating a water table mound that dominates local groundwater. Radial flow from the tank field excavation (a primary source of potential groundwater con-; tamination) virtually assures that some portion of contamination will migrate in a direction where there are no monitoring wells. By confining the site investiga- tion to the UST property, a very small area is used to infer the magnitude and direction of groundwater flow. This practice can lead to some predic- tive problems, such as water table mounding in the tank pit, affects on flow based on how much of the sur-t rounding area is paved, and distribu- tion of recharge-inducing features/ ------- LUSTLine Bulletin 40 such as leaking storm drains or ditches. Such effects can perturb the regional groundwater flow system. While transport of contaminants near the site may depend on these effects, off the property the regional flow may dominate and direct contami- nants in a different direction. Because the array of four wells at our typical site is usually elongated in one direction and compressed in the other, there is a high degree of uncertainty associated with our inter- pretation of groundwater contours. Recognizing the fact that there is a subjective element to all contouring (even that which is based on linear interpolation), strictly speaking, only those contours that lie within the region bounded by our four data points are allowed to be solid lines— all other contours must be dashed to show the uncertainty associated with them. This area is nonexistent for colin- ear points and very small for elon- gated quadrilaterals. The area bounded by four points is maximized when the data points form a square. \\ i\ 3: B! 2 4 c p 1 c SENSITIVITY OF INFERRED GROUNDWATER FLOW DIRECTION ON MONITORING WELL LOCATIONS (a) m — V.—1^----.-1, A (c) __- (d) Figure 1 is an attempt to illustrate some of these points using linear interpolation and parallel contours for simplicity. In the simplest case (Figure la), the four points are colinear with dashed vertical contours and groundwater flow (solid arrow) from left to right. But, contours as illus- trated in Figure Ib or Ic (or anywhere in between), could be drawn with equal justification. The orientation of these contours differs by more than 300 degrees, and groundwater flow directions differ by nearly 180 degrees. Clearly data points away from the axis are necessary to deter- mine which interpretation is more correct. Finally, if the wells are oriented in a square (Figure Id), we can see that there is a relatively large area bounded by our data points where we may be reasonably comfortable in our interpretation (i.e., where the contours are solid lines) of both the water table contours and the direc- tion of groundwater flow. Note that simply maximizing the distance between the corners of the square at a given site isn't a solu- tion. This could lead to problems in detect- ing the location of the plume. Postulating Potentiometric Surfaces Our scenario assumes that the water directly beneath the site exists under unconfined conditions (which is often the case). But, in many geologic set- tings, layering of soil types of different per- meabilities can create localized perched water zones as well as confined zones. Espe- cially in coastal plain sediments, even thin clay layers (which may not be recog- nized to be continu- ous over the site due to the wide sample collection intervals) can create such zones. When well screens of 10 to 20 feet are open to these different zones, the water level measured in the well is an amalgam of all of the different poten- tiometric surfaces of these different zones. Consequently, the measured water level may not have any correla- tion whatsoever with the presumed direction of groundwater flow. In addition to providing erroneous information on flow directions, such wells facilitate cross-contamination of deeper water-bearing zones. Collecting Groundwater Samples With the understanding that moni- toring wells with relatively long screened intervals (10 to 20 feet) can- not be relied upon to provide accu- rate information about water table elevations, how can they be expected to provide accurate information on groundwater quality? They can't. Even if the stratigraphy at a given site were purely homogeneous and isotropic (such that there are no preferential flowpaths) and each of the downgradient wells actually intersected the plume, groundwater samples withdrawn from each well would be a composite of the concen- trations over the entire screened interval. The result is always that mea- sured concentrations are less than the true maximum. How much differ- ence can this make? It is possible that this effect can dilute concentrations to below detection limits. But, even in this ideal case where groundwater flow to the well could be assumed to be laminar, groundwater flow into the pump (or other collection device) would be influenced by vertical loca- tion of the pump intake. In the case where well screens are open to different water-bearing units, it is impossible to generalize what the effect might be. (To further explore the effects of in-well dilution on aver- age borehole concentrations, visit ORD's OnSite Calculator at http://www.epa.gov/athens/learn2m odel/part-two/onsite/abc.htm.) The most logical way to locate a contaminant plume would be to place sampling points along the length of the plume and to select some locations that are off the main axis of the plume. Unfortunately, the • continued on page 16 15 ------- LUSTLine Bulletin 40 • Wander LUST from page 15 reality of the situation is that the loca- tion of the plume in most cases is only known through samples col- lected from wells. If our conventional site assessment uses wells placed arbitrarily at the property corners, they should not be expected to pro- vide delineation of the centerline or extent of contamination. These can only be determined from a set of wells or other sampling points that transect the plume. Aquifer Testing Monitoring wells are essential for providing data on aquifer response to pumping stress. However, as with defining the water table or potentio- metric surface, or for collecting repre- sentative samples, wells with long screened intervals may also yield erroneous information during aquifer tests. It is critical that the pumping well and the monitoring wells tap the same hydrostrati- graphic unit. With a conventional four-well arrangement, as in our scenario, aquifer test results could provide only a gross estimate of average aquifer permeability and yield. While this may be the objective of water supply investigations, it is essentially useless for determining contaminant travel time. Because contaminants migrate along preferential flow paths that generally have higher than aver- age permeability, the "true" trans- port velocity of contaminants may be significantly underestimated. The result is that contaminants may arrive at potential receptors much earlier than predicted. Installing Remediation Systems One of the cost-savings objectives in a conventional site assessment as per our scenario is to allow for remedia- tion equipment (especially free prod- uct recovery devices) to be installed in any of the wells, as needed. Is this really how a remediation system should be designed? The answer is a resounding "No!" We've already established that the locations of the monitoring wells are essentially random relative to the distribution of contamination. So how is it that we can believe that 16 ~ their locations could possibly result in the installation of an effective (let alone optimal) remediation system? Further, given how ineffective many of these systems are, how long most of them are operated, and how much they cost to operate and main- tain over the years, how much cost- savings are actually realized by a decision to arbitrarily limit the num- ber of wells installed at a given site? Ne'er Do Well The preceding paragraphs are intended to illustrate some of the things that monitoring wells should not be relied on to do. So, what can we conclude about conventional monitoring wells with long screened intervals? • Four wells are generally insuffi- cient to provide necessary infor- mation about subsurface conditions at any given site. • Nested wells with short screened intervals should be installed in favor of wells with long screened intervals. • Measured water table elevations may not correlate to the same hydrostratigraphic unit from well to well. • Concentrations of contaminants in groundwater samples may be sig- nificantly lower than the true con- centration at that point. • Results of aquifer testing (i.e., per- meability, transport velocity) should be assumed to be best case (least conservative) because aver- aging gives a lower conductivity than the maximum. • The effectiveness of remediation systems should not rely on the random location of monitoring wells. All's Well That Ends Well... This article turned out to be more lengthy than I originally intended, and still it doesn't address all the monitoring well issues that I'd hoped it would. Perhaps it is naive to expect that long-entrenched behavior would be favorably altered based on a single article, no matter how convincing the argument. (That is, however, my hope, if not my expectation). Part II of this article will summarize moni- toring well design guidance pro- vided in 40 CFR 280. • Hal White is a hydrogeologist with the U.S. EPA Office of Underground Stor- age Tanks. He can be reached at white.hal@epa.gov. This article was written by the author in his private capacity and the conclu- sions and opinions drawn are solely those of the author. The article has not been subjected to U.S. EPA review and therefore does not necessarily reflect the views of the agency, and no official endorsement should be inferred. Tank Tester Sentenced for Falsified Tests Carolina Upgrading of South Carolina, Inc., an environmental contracting com- pany, and its former president and owner were sentenced for conspiracy to com- mit mail fraud and related crimes in connection with falsified tests of USTs. The former president/owner was ordered to serve 27 months in prison and Carolina Upgrading was placed on probation for 3 years. The president/owner directed employees of Carolina Upgrading to provide customers in South Carolina, North Carolina, Florida, Georgia, Virginia, and Ten- nessee with falsified test results and with invoices for those false results. Many of the over 1,500 falsified tests for which customers were billed were not performed at all. The loss from fraud suffered by these customers amounted to approxi- mately $750,000. The case was investigated by EPA Region 4's Criminal Investigation Division, the South Carolina Department of Health and Environmental Control's Office of Criminal Investigations, and the North Carolina State Bureau of Investigation. It was prosecuted by the U.S. Attorney's office in Columbia, SC, and the U.S. Department of Justice. • ------- LUSTLine Bulletin 40 Oxygenates Is MTBE off the Hook in Euro! A Perspective on Europe's MTBE Risk Assessment by Patricia Ellis In 1993, the European Union (EU) established a formal process for assessing the potential risks of chemicals to both human health and the environment. The risk assess- ment process for MTBE began in 1997 and was carried out in two stages. First, all known data on the health and environmental effects, along with the potential for expo- sure, were evaluated to determine the overall risk. The findings were then set out in a risk assessment report. Second, in areas where risks were identified, the authority recom- mended methods for minimizing those risks. The risk assessment for MTBE was prepared under the leadership of the Finnish authorities in the context of the European Community (EC) Council Regulation N. 793/93 on the evaluation and control of the risks of existing substances. The Finnish Environment Institute, the National Product Control Agency for Welfare and Health, and the Finnish Institute of Occupational Health led the evalu- ation for the 15 member states. In December 2001, the European Union published the overall conclu- sions of this risk assessment on MTBE ("COMMISSION RECOM- MENDATION of 7 November 2001 on the results of the risk evaluation and the risk reduction strategies for the substances: acrylaldehyde; dimethyl sulfate; nonylphenol phe- nol, 4-nonyl-, branched; tert-butyl methyl ether") in the Official Journal of the European Communities. The con- clusions are available at http:// europa.eu.int/eur-lex/pri/en/oj7dat/ 2001/l_319/l_31920011204en00300044 .pdf Drafts of the complete risk" assessment have been circulated through various sources. The com- plete risk assessment report will eventually be published on the Euro- pean Chemicals Bureau Web site: http://ecb.jrc.it/. Report Findings In Europe, MTBE is most commonly used as an octane booster. The maxi- mum allowable use of MTBE is lim- ited to 15 percent by volume in gasoline, under Directive 98/70/EC. On the average, however, the actual amount is closer to 2.5 percent by weight, but the amount varies by country and refinery. The EU risk assessment identi- fied a number of possible release sce- narios for MTBE and its perceived risks. A strategy was proposed for limiting those risks. In terms of impact to consumers, human health, atmospheric and terrestrial ecosys- tems, and microorganisms in sewage treatment plants, the report stated that there are not expected to be any risks from exposure to MTBE, and no further information or testing in these areas is needed. Risk reduction measures already being applied are deemed to be sufficient. The report found that with regard to the impact on human health, there is a need for workers to limit contact with MTBE during maintenance operations and automo- tive repairs because of the risk of skin irritation after repeated exposure to gasoline containing MTBE. It added, however, that there is no need for further information or testing to reduce risk to consumers, beyond the measures already being applied. In general, legislation exists for worker protection, but it was recommended that design changes might be made to fuel filters to make maintenance and repair work easier. The assessment concluded that there is a need to limit human expo- sure via the environment due to con- cerns for the potability of drinking water with respect to taste and odor. This risk exists as a conse- quence of exposure arising from leaking underground storage tanks and spillage from overfilling of tanks. To limit exposure of humans to MTBE via the environment, the fol- lowing recommendations were made, aimed at protecting ground- water and drinking water: • Existing legislation is designed to prevent releases of MTBE to the environment. Monitoring pro- grams were recommended to pro- vide for early detection of groundwater contamination by MTBE. • Best available technologies are recommended for the construc- tion and operation of under- ground storage and distribution systems at service stations. • Mandatory requirements for stor- age facilities in groundwater recharge areas should be consid- ered. • Construction and operation stan- dards for storage tanks should be standardized for all of the EU. • Potential past releases at storage facilities should be investigated, and remediated where necessary. The assessment concluded that there is a need for further informa- tion and/or testing with regard to potential risks to aquatic ecosystems. One concern had to do with potential releases of MTBE to surface waters from terminal storage tank-bottom waters. The report recommended that permits or rules should control MTBE-containing bottom waters of • continued on page 18 17 ------- LUSTLinc Bulletin 40 m MTBE in Europe from page 17 aboveground storage tanks. There are large numbers of terminal sites in the EU that store and handle gaso- line, and because some of these sites do not have on-site wastewater treat- ment plants for the tank water, it is believed that these terminal sites are the most pronounced source of MTBE releases to surface waters. The authors discounted the threat of direct releases of gasoline to surface water from motor vehicles and recre- ational watercraft due to predicted low levels of contamination. Given the large amounts of gaso- line stored at service stations and ter- minals and the nature of the transport system, it is inevitable that some release of MTBE to' the surface and subsurface environment will occur. However, because of the design of modern service stations, the commit- tee anticipated that the risk of serious releases to soil or groundwater dur- ing normal refueling operation should be low. The highest potential risk comes from leaking underground tanks or piping, where leaks may go unnoticed for some time. Based on my review of the January 2001 draft risk analysis report, the risk of groundwater contamination due to releases at refineries or bulk storage terminals with aboveground storage facilities does not seem to have been addressed by the study. MTBE—U.S. and EU So with this "no worries" conclusion about the risks of MTBE in Europe, I find myself asking whether or not I think Europeans should be worried about MTBE. Let's look at some of the similarities and differences between the tank situations in the U.S. and Europe. Other than at individual leaking tank sites, there is currently little rou- tine monitoring for MTBE in ground- water in Europe. The limited available monitoring data show the presence of MTBE at low levels in groundwater and well samples in urban areas. But you can't know whether there is a problem if you don't start looking for it. Few states in the U.S. were look- ing for MTBE until Santa Monica's wells were knocked out because of MTBE in 1996. There were problems 18 before then, but Santa Monica was the big wake-up call. I know of a few sites in Delaware where MTBE was first documented in the early to mid- 1980s. After Santa Monica, the ostriches—oops, states—started one by one to pull their heads out of the ground. Is Europe another ostrich, slow to pull its head from the ground? Arthur D. Little Report A study conducted by Arthur D. Lit- tle, Ltd. (ADL) for the European Commission (2001) assesses whether groundwater in the EU faces a similar potential for widespread contamina- tion by MTBE as has already occurred in the U.S. It also examines whether controls or obligations already present in EU member states that may or may not exist in the U.S. mitigate any such risk. Three factors were considered as part of this assessment: (a) UST construction, installation, and operation; (b) water quality regulation; and (c) MTBE monitoring programs. Information in this report shows that requirements for the construc- tion of UST systems in EU member states generally meet or exceed the equivalent federal or state legislation in the United States in the following four important areas: • Specifications for tank construc- tion. EU specs were typically either single-walled with addi- tional containment, or double- walled. • Specifications for corrosion-resis- tant material or cathodic protec- tion of materials prone to corrosion. • Specifications for leak detection systems, regular monitoring of this system, and regular monitor- ing of tank integrity. • Specifications for corrosion- and leak-resistant connecting pipes, and solid pavement that drains to an oil/water separator. The study stated that strong enforcement of the UST system requirements is essential for this source-control program to be effec- tive—ensuring that the potential for UST systems to cause groundwater contamination remains low in the future. Of the six member states for which some groundwater monitor- ing and survey information were available (Denmark, Finland, France, Germany, Sweden, and the U.K.), none of the findings indicated wide- spread or serious groundwater conta- mination by MTBE on the same scale as the U.S. The authors of the study believe that, given the recent adop- tion of new standards for UST sys- tems in the EU, this contamination appears to be largely either (a) his- toric contamination, or (b) isolated incidents where there was a recog- nized failure in either construction or operational standards. Because of the significantly lower concentration of MTBE in gasoline in Europe, it is not anticipated that groundwater contamination by MTBE will increase significantly in the near future. Finland is the only EU mem- ber state using high levels of MTBE in gasoline similar to that used in oxy- genated gasoline in the U.S. As requirements for the construction and operation of UST systems in Fin- land have only recently been intro- duced, data currently being collected on MTBE in groundwater will be an important indication of the effect of this usage. The Finnish Ministry of the Envi- ronment provided a statement for submission to the U.S. EPA's Blue Ribbon Panel. The ministry does not, for the time being, consider that the use of MTBE in gasoline should be restricted because of groundwater protection in Finland. "The release of gasoline to groundwater is prohib- ited even if it contains no additional substances. When the pollution of groundwater by gasoline is pre- vented, it is not relevant whether or not the gasoline contains MTBE." (May 17, 1999, letter from Peeka Jalkanen and Tapani Suomela of the Finnish Ministry of the Environment to Jarmo Honkamaa of Fortnum Oil and Gas, for transmission to EPA's Blue Ribbon Panel.) In other words, polluting groundwater is absolutely prohibited in Finland. The ADL report cited a study conducted between 1997 and 2000 by the Danish Oil Industry's Association for Remediation of Retail Sites. Tests were conducted at selected stations where gasoline contamination had been remediated. The stations had been in operation after 1985 (when ------- LUSTLim Bulletin 40 MTBE had first been used in gasoline blends in Denmark). Of the 479 sites, 21 percent tested positive for MTBE contamination. Of the contaminated sites, 7 percent exceeded the thresh- old level of 0.03 mg/L. Denmark's Concern The ADL report concluded that groundwater contamination by MTBE is unlikely to increase in Europe if existing standards governing the con- struction and operation of USTs are strongly enforced. Based on that, the Commission of the European Commu- nities has not proposed any changes in gasoline composition with respect to MTBE content, with the exception of Denmark, which continues to express concern over the use of MTBE. Individual member states have the right to request stricter environ- mental specifications in areas of par- ticular sensitivity. The European Auto/Oil program and its associated legislation were designed to improve air quality (much like the Clean Air Act). Denmark is trying to extend this opt-out provision to cover water quality as well. The Commission has pointed out that restrictions on the sale of gasoline that complies with EU specifications could impede the correct functioning of the internal market, in much the same way that ''boutique fuels" can cause supply problems in the U.S. In the summer of 2000, the Dan- ish media featured several stories linking the MTBE controversy with a potential threat to water supplies in Denmark, where drinking water is filtered rather than chemically treated before delivery to the con- sumer. Government authorities insti- tuted an enhanced monitoring program to discover the extent of MTBE contamination, instituted a reassessment of the existing drinking water standard for MTBE, and con- sidered a possible new tax on MTBE. In December 2001, Denmark introduced a tax incentive scheme, whereby lower taxes are charged on gasoline distributed by service sta- tions that meet more stringent stan- dards of equipment and operation. This reduction in the tax is available for stations that meet a standard that •will become compulsory in 2005. Denmark is in the process of phasing out MTBE in regular unleaded gasoline. MTBE is no longer being added to 92-octane gasoline, which is suitable for most cars. High-performance cars and some older cars require 98-octane gasoline, which still contains MTBE as an octane enhancer. This gasoline is available only at selected service stations, roughly 5 percent of the sta- tions in the country. Denmark's requests were approved by the Council of Ministers in September 2001, but the Council noted that "leakage into groundwa- ter does not represent a real health problem as this substance is harmful only when highly concentrated." However, it approved the measure on environmental grounds since "even minute quantities of MTBE in groundwater impart an unpleasant taste and smell... and water contain- ing negligible quantities of MTBE would be undrinkable." In commenting on the Danish actions, the director-general of EFOA (European Fuel Oxygenates Associa- tion), Bruno Hery, said "EFOA sup- ports the tax incentive scheme, which tackles the cause of possible ground- water pollution by MTBE—leaking storage tanks—rather than focusing on the product itself. We welcome Denmark's pragmatic approach to the issue, but since MTBE in ground- water is not perceived as a serious threat by other European countries, we have no plans to promote similar incentive schemes elsewhere." Although the overall usage of MTBE in Denmark is low (0.2 percent by volume), some unleaded gasoline is imported from Fortnum Oil in Fin- land, which supplies unleaded gaso- line with an MTBE content of 10 to 12 percent (Dottridge, 2000). Environment Agency Report on England and Wales Komex Europe completed a review of current MTBE usage and occur- rence in groundwater in England and Wales for the Environment Agency and the Institute of Petroleum (2000). Members of the Institute of Petro- leum own and operate approxi- mately 4,500 retail filling stations and 200 oil distribution terminals in the U.K. A total of 2,069 sites have been investigated for soil and groundwa- ter contamination, with analysis for ether oxygenates at 837 of these sites. Of 292 sites evaluated in more detail, 179 had MTBE in soil or groundwater (61 percent), 64 had detectable MTBE in soil (22 percent), 73 had detectable MTBE in groundwater (25 percent), and 40 additional sites had MTBE in perched water (13 percent). This report provided possible explanations as to why there were fewer problems in the U.K. than in the U.S.: • Lower concentrations of MTBE in U.K. fuels (1/lOth that of U.S. gasoline). • Greater distance between poten- tial fuel spill sites and drinking water wells in the U.K. A differ- ent geology and water supply infrastructure is likely to be more protective of public water sup- plies in the U.K. The U.K. has small numbers of deep, high- yielding public supply wells. In the U.S., there are larger numbers of shallow wells that supply small communities and that are at greater risk from MTBE contami- nation. In addition MTBE was introduced into fuel in the U.S. in the late 1970s, 5 to 10 years before it was used in the U.K. (late 1980s). • Greater incentive for good fuel storage due to higher fuel costs in the U.K. In the U.S., fuel is taxed as it is dispensed from the pump— leaked fuel incurs no tax. In the U.K., fuel is taxed as it leaves the refinery, ensuring that the costs incurred by retailers due to leak- ing fuel are much greater. This tax makes up about 75 percent of the cost of fuel and helps ensure that leaks are fixed promptly. MTBE Concentration Projections The primary reason for the addition of ether oxygenates to gasoline in Europe is to maintain the octane rat- ing of the gasoline in the absence of lead and with reduced aromatics. Such fuel usually contains less than 5 percent ether oxygenate by weight, often as low as 1 percent by weight. Recent European fuel quality and air emissions directives, mandatory in all member states, govern the compo- sition of gasoline in the European • continued on page 20 _ ------- LUSTLinc Bulletin 40 m MTBE in Europe from page 19 Union. Table 1 summarizes the maxi- mum allowable concentrations in 95- octane gasoline. Some major oil companies believe that the concentration of MTBE in fuel could increase with the implementation of the final part of 98/70/EC (EC 1998) in 2005. Reduc- tions in the allowable percentage of aromatics in gasoline are required, which will necessitate the use of octane from other sources. Based on information provided by EFOA, the ADL report predicts a temporary increase in the use of MTBE when the new specifications are required. It adds, however, that as new refining technologies are introduced to meet the tougher fuel specifications, the MTBE concentra- tion will again drop, eventually to concentrations similar to those in gasoline prior to introduction of the 2005 specifications. Given the high cost of adding oxygenate to gasoline blends, the extent to which MTBE is added to fuel is determined primarily by eco- nomics—where possible, petroleum refiners will use low concentrations of MTBE—unless this is overridden by policy or legislation that sets mini- mum oxygen or oxygenate concen- trations. Average MTBE composition in the EU countries varies from 0.2 per- cent by volume in Denmark to 8.5 percent by volume in Finland—1.9 percent by volume is the European Union average (Dottridge et al., 2000). The ADL report anticipates that MTBE octane requirements will settle out in the 1 to 4 percent by vol- ume range, depending on the avail- able octane, and will still be below the 10 to 15 percent volume by weight currently used in reformu- lated gasoline in the U.S. The effects of an increase in MTBE concentration in fuel from 1 to 5 percent to 10 to 15 percent were investigated in the Komex study using a model. The model predicts that increasing the concentration of MTBE in fuel will have little effect on the total number of wells with detectable MTBE, but it forecasts a significant rise in the number of pub- lic wells that will have tastable con- centrations of MTBE. 20 MAXIMUM ALLOWABLE CONCENTRATIONS IN EUROPEAN UNLEADED GASOLINE (95 octane). Component LejJ(g/I) Aromatics (% v/v) Benzene {% v/v) Oxygen (% m/m) Sulfur (mg/kg) 1985 0.013 Starting Date 1998 2000 0.013 500 0.005 42 2.7 150 2005 0.005 35 2.7 50 Dottridgeetal.,2000. An MTBE increase from 1 to 5 percent could lead to an order of magnitude increase in the number of public water supplies with tastable concentrations of MTBE. With higher concentrations of MTBE, the MTBE in wells will remain above the taste threshold longer and impact is likely from more distant sources. The longer travel time may create a delay before the source is identified and remediated. MTBE Not off the Hook A December 2001 press release by White Environmental Associates expressed the opinion that, due to the findings of the European Commis- sion risk study, the scheduled phase- out of MTBE in California gasoline now appears both unnecessary and economically risky. The press release states that MTBE has been cleared of allegations that it poses a significant risk to health or the environment. This release fails to account for the differences in the storage and han- dling of gasoline in Europe, differ- ences in geology and water supply infrastructure, and significant differ- ences in the percentage of MTBE used in gasoline in Europe compared with the U.S. Seems to me that we may be talking apples and oranges here! In Europe (as in the U.S.), leaking underground storage systems and spillage from overfilling tanks are the main cause of groundwater contami- nation (Finnish EPA, 2001). The severity of the consequences may vary greatly among countries, depending on, for example, the degree to which groundwater is used for drinking water and the condition of gasoline station USTs. As mentioned earlier, Europe has limited monitoring data on MTBE in groundwater. ADL's recent report to file European Commission states that "little public information is available across member states regarding mon- itoring of groundwater contamina- tion by MTBE." Citing unpublished information from six countries, the report concludes that "none of the findings indicated widespread or serious groundwater contamination by MTBE on the same scale as the U.S.A." The EU risk assessment report states, however, that the "docu- mented cases provide sufficient justi- fication for concern that MTBE poses a risk for the aesthetic quality of drinking water from groundwater supplies. It is justified to conclude that MTBE is causing a risk for the aesthetic quality of drinking water." (Finnish EPA, 2001) The EU risk assessment con- cluded that MTBE is a borderline case between non-classification as a carcinogen and Carcinogenicity Cate- gory 3. Von Krauss and Harremoes (2001) provide a good summary of the conflicting opinions as to the car- cinogeniciry of MTBE. The fact is that MTBE has been shown to cause cancer in two differ- ent animal species (rats and mice). What is uncertain is whether the same mechanism that causes cancer in these animals would also cause cancer in humans. The answer may be "No." But, in fact, we don't know. The Precautionary Principle So, if MTBE is a chemical that causes cancer in animals, do we really want to be unnecessarily exposing human ------- LUSTLine Bulletin 40 populations to it simply because -we don't know for sure that it won't cause cancer? And what if by itself a tiny bit of MTBE wouldn't hurt a fly? How will that tiny bit of MTBE plus a tiny bit of some other organic chemi- , cal affect the water we drink? There is so much that we don't know. Until the question of how mix- tures affect human health can be answered beyond a shadow of a doubt, it would be imprudent to blindly assume that any chemical is harmless. If nothing else, the precau- tionary principle counsels us to use caution when dealing with such unknowns. Potentially carcinogenic chemicals should be assumed to be carcinogenic until they are absolutely proven not to be. The Arthur D. Little report sug- gests that the new regulations and standards for USTs scheduled to take effect by 2005, along with strong enforcement, should prevent leakage. Studies in the U.S. demonstrate that even tanks in compliance with the U.S. EPA's 1998 standards can still leak. The U.S. EPA Blue Ribbon Panel considered whether reducing MTBE to "pre-RFG" levels would eliminate the MTBE problem. The consensus was that this would not be sufficient to solve the MTBE problem. Granted, the higher levels of MTBE were defi- nitely causing larger and more numerous problems, but problems existed even before the percentage of MTBE was increased. Unless all countries are as law-abiding as Fin- land, where polluting groundwater is absolutely prohibited, an increase in MTBE usage in Europe may signifi- cantly impact the groundwater! The European Environment Agency recently issued a publication titled Late Lessons from Early Warn- ings: the Precautionary Principle 1896-2000. The publication is about "the gathering of information on the hazards of human economic activi- ties and its use in taking action to bet- ter protect both the environment and the health of the species and ecosys- tems that are dependent on it, and then living with the consequences." The case studies question why both early warnings and the "loud and late" warnings tend to be ignored for so long. Former EPA Assistant Administrator Bob Perci- asepe said it best on the CBS 60 Min- utes episode on MTBE that aired in January 2000. He said "Those warn- ing bells, to the extent that they were ringing—-and they were ringing...in som^ parts of EPA, and they were ringing in other places—were not ringing widely enough. We are clearly admitting that they weren't ringing loudly enough. We didn't yell loudly enough." Bells seem to be ringing in parts of Europe and not in others. Let us hope that the U.S.'s his- tory of MTBE does not repeat in Europe. • Pat Ellis is a hydrologist with the Delaware DNREC UST Branch and served as member of EPA's Blue Rib- bon Panel on MTBE. She is a technical advisor and regular contributor to LUSTLine and can be reached at pellis@dnrec.state.de.us. References Arthur D. Little, 2001. MTBE and the Require- ments for Underground Storage Tank Construction and Operation in Member States — A Report to the European Commission. Reference Number ENV.D/ETU/2000/0089R, Reference 73488. "Commission Recommendation of 7 Novem- ber 2001 on the results of the risk evaluation and the risk reduction strategies for the sub- stances: acryaldehyde; dimethyl sulphate; nonylphenol phenol, 4-nonyl-, branched; tert- butyl methyl ether (2001/838/EC)." Official Journal of the European Communities. L319/30-44 Dec. 4,2001. http://www.europa.eu.int/eur-lex/en/dat/ 2001/l_319/l_31920011204en00300044.pdf Dottridge, J., P. Hardisty, A. Hart, and L. Zam- bellas, 2000. MTBE in Groundwater in the UK and Europe. Proceedings of the 2000 Petroleum Hydrocarbons and Organic Chemicals in Ground Water: Prevention, Detection, and Remediation Conference. November 15-17, 2000, Anaheim, CA, p. 321-331. Komex Europe, for the Environment Agency and the Institute of Petroleum, 2000. A Review of Current MTBE Usage and Occurrence in Groundwater in England and Wales. R and D Publication 97. Von Krauss, M. and P. Harremoes, 2001. "MTBE in Petrol as a Substitute for Lead," in Late Lessons from Early Warnings: The Precau- tionary Principle 1896-2000. European Environ- mental Agency. See report at http://reports. eea.eu.int/environjnental_issue_report_2001_ 22/en European Fuel Oxygenate Association, Newsletter No. 2001/1, December 2001. "Risk Assessment Based on Sound Science." http://www.efoa.org/newsletter/issue_l.html European Fuel Oxygenate Association, Dec. 7, 2001, press release. "EFOA Welcomes Publica- tion of EU Risk Assessment Report on MTBE." http://www.efoa.org/fr/efoa_news/det_press. asp?id=74&p_keybords= "MTBE •—The EU Risk Assessment." Hart's European Fuels News, Dec. 12,2001. http://quotes.freerealtime.com/dl/frt/N?art=C 2001121800352u6092&SA=Latest http://www.efoa.org/fr/efoa_news/det_press. asp?id=75&p_keybords= then click for pdf Me Lethbridge, G., 2000. "MTBE and Groundwa- ter Contamination in the UK," Petroleum Review, pp. 50-52. Ministry of the Environment, Finland, May 17, 1999 letter from Peeka Jalkanen and Tapani Suomela of the Finnish Ministry of the Envi- ronment to Jarmo Honkamaa of Fortnum Oil and Gas, for transmission to EPA's Blue Rib- bon Panel. White Environmental Associates, Press release December 13, 2001. "MTBE Poses Limited Threat to Health and the Environment, New Study Confirms." http://biz.yahoo.com/ prnews/ 011212/dcth038_l.html. New UST Leak Detection Web Site Now Available Anew non-EPA Web site pro- vides valuable information on UST leak detection systems. The National Work Group on Leak Detection Evaluations (NWGLDE) has worked on leak detection issues for several years and has now launched its own Web site at www.nwglde.org. Users can visit this new Web site for a variety of leak detection-related informa- tion, including the most recent list of leak detection methods that have been evaluated by third par- ties to see if they meet EPA's per- formance standards. Previously, much of this information could be found on the EPA OUST Web site, but now and in the future the NWGLDE Web site will be the place to go for the latest informa- tion on leak detection evaluations and other work by NWGLDE. There will be a link on the EPA OUST Web site to this new site. • ------- Oxygenates Maryland Completes Study on Environmental Effects of MTBE A Maryland Task Force on the Environmental Effects of MTBE, consisting of 16 mem- bers from various government agen- cies, the petroleum and ethanol industries, and health related profes- sionals, released its final report in December 2001. House Bill 823, signed by Governor Glendening on May 11,2000, created the Task Force, charging it with the following responsibilities: • Determine and assess the environ- mental and health risks associated with ground and surface water con- tamination from MTBE. • Examine national and regional efforts concerning ground and sur- face water contamination from MTBE. • Recommend a plan to minimize and counteract the environmental and health risks associated with ground and surface water contami- nation from MTBE. • Explore alternatives to MTBE, including ethanol and oxygenated fuel, that can be used for the purpose of reformulation of gasoline to reduce air toxic emissions and pollu- tants that form ground level ozone. Recommendations The report presents an overview of the MTBE situation in the state and provides recommendations for deal- ing with the problem from a health and environmental standpoint. Here are some highlights: • Continue testing and assessing wells and water supply systems for MTBE and other oxygenates. Posi- tive test results should result in a source investigation as appropriate. Specific steps include: • Continue to use the MTBE level of 10 parts per billion (ppb) in water samples at and above which a source investigation is conducted. 22 • Review U.S. EPA advisories and standards for MTBE and other oxygenates and modify state requirements as appropri- ate. • Finalize a method for testing and analyzing water samples for MTBE, TEA, ETBE, and TAME contamination. • Develop laboratory-testing methods for the determination of DIPE and Ethanol in water samples. • Work with local health depart- ments to expand testing of wells not currently tested in unconfined aquifers (shallow wells). • Encourage local governments to protect drinking water sources through locally adopted siting restrictions. • Enhance the level of inspection and enforcement of UST systems and spill prevention programs and control the escape of MTBE and other gasoline constituents through improving the technology and oper- ation of UST systems, including the piping and distribution system. Specific steps include: • Establish an inspection fre- quency for UST systems with a once per year goal. • Amend regulations as neces- sary to prohibit petroleum deliveries to UST systems that are not properly registered and do not meet federal or state UST upgrade requirements. • Work with stakeholders to develop a method for the on- site display of the registration status of the UST systems at all UST facilities. • Work with industry and U.S. EPA to establish comprehen- sive certification and training programs for owners, opera- tors, contractors, and employ- ees who work with petroleum storage tank systems to imple- ment procedures and processes that would minimize leaks and groundwater contamination. • Give careful consideration to even- tually reducing or phasing out the use of MTBE in gasoline sold in the state. Work with other states and stakeholders to address MTBE issues, consistent with current dis- cussions on energy supply. • Implement, through public-private partnerships, expanded public out- reach programs on the proper han- dling and disposal of gasoline. Programs should include warning the public that improper handling of petroleum products and filling of vehicle tanks and containers could lead to groundwater contamination. Require facilities dispensing gasoline to include signage informing users that the gasoline is oxygenated to reduce air pollution, and any spillage may result in contamination of water resources. Outreach efforts should also include a broad-based program targeting owners and users of private wells on measures to prevent, detect, and treat contaminated water. • Provide adequate support to address the impact of MTBE and other oxygenates in gasoline on Maryland's water resources. Specific steps include: • Provide funding to health department laboratories for testing of MTBE, TEA, ETBE, TAME, and Ethanol in water samples. • Provide resources1 for a proac- tive drinking water sampling program. • Dedicate appropriate resources to enforce all existing statutes and regulations with regard to UST system integrity, mainte- nance, recordkeeping, and remediation. full report can be found at &ttp://www.mde.state.md.us/was/ gpdf/mtbe_finalreport.pdf. • ------- LUSTLine Bulletin 40 nicatty Speaking by Marcel Moreau iT Marcel Moreau_ is a nationally < =mcognized petroleum storage specialist ? 'whose column, Tank-nically Speaking/ sJsiajegular feature o/LUSTLine. As ; Wsoays, we welcome your comments and j ^questions. If there are technical issues ; S-^Jhat you would like to have Marcel « ~^- discuss, let him know at s Of SQUARE PEGS and Round Tanks OR... ^S 3r What If Tank Operators Knew How to Operate Tanks? Author's Note This article focuses on the large majority of tank operators who have but a poor understanding of their storage tank systems. I know that there are some competent, professional tank operators out there, and I do not mean to offend them by lumping them together with tank operators who haven't a clue about what they are doing with respect to operating and maintaining their tank systems. The point of this article, however, is that there are far too few competent tank operators today, and the road we seem to be taking to address this problem is, I fear, unlikely to succeed. Who's in Charge? We all know the scenario: The UST inspector walks into the UST facility and asks the clerk about leak detec- tion, overfill prevention, corrosion protection. He/she gets a blank stare. "Where's the tank paperwork?" inquires the inspector. "I dunno, let me check the waste- basket..." replies the attendant. The alarm light is red. The alarm history indicates that the alarm has been active for months. The rectifier's off. There's water in the sumps, spill containers are full of crud, a broken- off gauge stick is jammed in the fill pipe, keeping the overfill device open. Sound familiar? In May 2001, the U.S. General Accounting Office published a study of the challenges still faced by EPA's underground storage system regula- tory program. One of the issues high- lighted in this report is operation and maintenance. "Tank operation and maintenance problems increase the risk of contamination," states the report on page 8. "EPA and states attribute operations and maintenance problems to insufficient training for all staff implementing tank require- ments, including owners, operators, installers, removers, and inspectors," states the report on page 10. (For the full report, go to www.gao.gov and look up report GAO-01-464.) The UST program in the U.S. depends heavily on proper operation and maintenance of leak detection, spill containment, overfill preven- tion, and corrosion protection sys- tems to keep releases in check. The technologies now used almost uni- versally to meet these varied require- ments were used only sporadically as recently as a dozen years ago. Despite the complexity of some of these systems, the fact is that none of these technologies are part of the core curriculum of any high school or uni- versity in the country. So where are people who are responsible for these systems supposed to learn about them? There are a few specialized schools and seminars available, but the vast majority of people who are directly responsible for USTs today learn "on the job." Having spoken with many of these people in semi- nars that I have given across the country, I can say that all too often this learning technique is woefully inadequate. Changes Afoot? This question of who's in charge reflects the disturbing situation more than 17 years after a national pro- gram was born and 13 years after detailed federal regulations were published. The rationale that this is a "new" program is untenable. The harsh reality is that if we keep doing things the way we've been doing them, we're going to keep getting the results we're getting. There are moves afoot to change things. There is a bill simmering in the Senate (#1850, Chafee) that would mandate that states develop and implement a strategy for training operators of underground storage tanks. Some states (e.g., PL, CA, OR) have begun programs designed to • continued on page 24 23 ------- LUSTLinc Bulletin 40 • Tank-nically Speaking from page 23 increase operator knowledge. (See sidebar on page 7.) But UST operator education programs seem to be based on the overly simplistic analysis that if ignorance is the problem, then training is the solution. This approach attempts to treat the symp- tom but does not address the root cause of the problem. This approach disregards two fundamental facts about today's tank operator popula- tion: • There is huge turnover in the per- sonnel that are generally regarded as tank operators. • For most tank operators today, keeping the storage systems up to snuff is an afterthought to the job description, if it appears on the job description at all. Let's look at how each of these fundamental facts points to the futil- ity of training existing tank operators as a solution to the problem. Personnel Turnover Personnel turnover in the conve- nience store industry, which repre- sents a large portion of the motor fuel facilities in this country, is a well- known phenomenon. The conve- nience store industry statistics for 2001 indicate that the average turnover rate is 102 percent per year. This means that, on average, a conve- nience store worker keeps his job for just under a year. This is not the place to discuss the reasons for this, but I think it is safe to say that this situa- tion is not likely to change in the fore- seeable future. So what does this tell us about the challenge of educating tank oper- ators? It tells us that the training effort required would be enormous because of the hundreds of thou- sands of people involved. It tells us that the effort will be neverending because a very large percentage of these people will be gone within a year. It tells us that employers are going to be unwilling to make any significant investment in training employees who will soon be out the door. It tells us that attempting to teach essentially temporary employ- 24 ~ ees title intricacies of storage tank sys- tems and storage tank regulations is a futile endeavor. Job Description And what if by some miracle tank operators did know what to do? How much time would they devote to doing it? Very few people today are hired as tank operators. The job titles typically read something like store manager, operations manager, main- tenance supervisor, environmental manager, health and safety supervi- sor, and so on. Some of these job descriptions include items like mak- ing sure there is an adequate supply of fuel available. Some may even include items like maintaining tank paperwork. But very few of these job descriptions have tank operation and management as a prominent compo- nent. These job descriptions do include a multitude of other responsibilities that are typically more urgent (e.g., the cash register person didn't show up today, so I have to fill in...), more apparent (e.g., light bulbs need replacing, floor needs cleaning, toilet is overflowing...), or more likely to affect the bottom line (e.g., the ciga- rette rack is almost empty, the beer cooler is on the fritz, and the beer is getting warm...). How many of today's tank operators have tank compliance status as a significant component of their job performance review? Storage systems are out of sight (buried, in fact!) and they are typi- cally a complete mystery to the hap- less operator. And we know from the generally low level of inspection and enforcement efforts (the GAO report cited above also states that 22 states do not inspect all of their tanks on a regular basis) that noncompliance with tank rules rarely has significant consequences. The end result of all this? Tank operation and manage- ment is a low priority. I firmly believe that the class of people that are generally considered tank operators today never asked to be tank operators, will never be ade- quately trained to competently oper- ate tank systems, and will never devote the time or energy to tank operation that is required. Attempt- ing to turn today's store managers and maintenance supervisors into professional tank managers is a hope- less task. Simply put, we are trying to jam square pegs into round holes. Who Should Be in Charge? Why not create a new lot of round pegs that will actually fit into the round holes—a trained class of pro- fessionals who are interested in stor- age tank systems and are able to demonstrate that they have adequate knowledge—and put them in charge of storage systems? Let the store managers and operations managers focus on doing what they know how to do and let storage tank operators do what they know how to do. Are there any parallel situations? I think so. Not so very long ago, raw sewage was discharged into the nation's waterways. There was little or nothing in the way of sewage treatment. This was eventually found to be unacceptable, and we designed sophisticated plants to treat sewage. These plants needed people to oper- ate them, but this was not something that could be done by any Tom, Jane, or Harry off the street because it required specialized knowledge. So we created schools for sewage treat- ment plant operators and trained and certified a class of people to handle a vital and technically sophisticated operation. Not so very long ago, under- ground storage systems were little more than steel cylinders thrown in the ground with a few pipes and a basic pump connected to them. This led to unacceptable pollution, so today's storage systems are vastly more complex and sophisticated (for reasons that are economic as well as environmental), as are the regula- tions governing them. Yet we still expect that people off the street will be able to successfully operate these systems. Is it any wonder that they so often fail? I believe that what we need to create is a class of technically profi- cient professional tank operators who make a career out of properly manag- ing tank systems. Managing a few storage systems at a typical facility is not a full-time occupation. A single professional tank operator, depend- ing on the technology used at a UST ------- LUSTLine Bulletin 40 facility and the competency of the on- site personnel, should be able to man- age quite a few storage facilities. This would decrease the number of peo- ple who need to be trained by a factor of 10 to 100. These people will have invested significant time and perhaps money in obtaining their qualifica- tions, so they should, in theory at least, have significantly lower turn- over rates than typical convenience store personnel. These factors should in turn significantly decrease the overall training effort required. The Certified, Professional Tank Operator Professional tank operators could market their services in various ways. Some could become employees of companies with many tank sys- tems. They would have the official job description of keeping the com- pany's tank systems properly main- tained and in compliance. Some could become independent consul- tants hired by small tank owners to do the same job. Some could work within tank installation and mainte- nance firms to provide an additional service to the firm's traditional cus- tomers. Some could work with or within government agencies or the military to manage those tank popu- lations. A small mom-and-pop tank owner who wanted to manage her own tank could be free to do so, but only if she could prove through the certification process that she was a competent tank operator. The fundamental difference in this proposal from the usual under- standing of tank operator is that the certified operator is not the person who is on site every day. The certi- fied operator is the person who understands the characteristics of the storage systems at each facility for which he or she takes responsibility, knows what needs to be done to keep the facility in compliance, sees to it that these things get done, and main- tains all of the required paperwork. Duties of the professional opera- tor would also include providing basic training to on-site personnel on how to operate the UST (e.g., "You have a 10,000 gallon tank but don't ever try to put more than 8,500 gal- lons into it.") and how to respond to alarms or other malfunctions (e.g., "If this red light comes on, call me right away."). The presence of the profes- sional. operator can greatly reduce the level of training required for on- site personnel as well as provide a direct means of delivering very focused site-specific information to these people. This would be very effi- cient, effective, and economical for the employer. Today's storage systems ":':'-:'.'::V^;™!™'::T\-": - " -• -. pe,.. complex and sophisticated (for sons that are economic as well as environmental), as are the jjigulatidns^govefhing them. Yet we "" « 1 pjffjhj^ street , ~ T** *-"T."! 'jtrill be able to successfully operate bese systems. Is it any wonder that ~*-%- :±^X-^. 7^ ™=p*c—^-™i- *yu.:g -. ^ ^ J"i__ __S Bey so~oftenTail? - - To create this class, we need only tweak existing regulations slightly to require that each regulated storage system have a "certified" tank opera- tor and define the requirements for certification. Seed money might then be provided (and time allowed) to create the schools (perhaps within the existing vocational/technical school system, or an Internet course for those who are already well versed in tank management) to educate and certify a population of professional tank operators. The key here would be to create high enough standards and an evaluation tool (e.g., an exam- ination) that is effective enough to reasonably ensure that only truly knowledgeable people obtain certifi- cation. The certification process must be used to raise the bar of compe- tency, for if the certification process merely blesses the status quo, we will merely perpetuate the current situa- tion. Enforcement of the requirement that every tank system have a profes- sional tank operator could be simpli- fied by a system whereby certified tank operators would attach a tag (with their name and contact infor- mation on it) to storage systems for which they are responsible. After some fixed date, it would become illegal to deliver fuel to storage tanks that do not have a certified tank operator tag attached to the fill pipe. If a professional tank operator ceased to be responsible for a storage sys- tem, he or she would provide reason- able notice to the tank owner and then remove the tag. The tank owner would need to find a replacement professional operator to continue to receive fuel. Any such changes in professional tank operator would need to be tracked in the state UST database. As in the existing regulatory scheme, professional tank operators could be held liable for the regulatory shortcomings of the facilities for which they are responsible. Therefore, it would behoove a professional tank operator to drop from his client list an uncooperative owner who did not want to perform required mainte- nance or leak detection activities. Fre- quent changes in tank operator could be tracked in a state UST database and might be a signal that a facility is in need of a visit from a state inspector. To keep professional tank opera- tors honest, each state could organize a volunteer board consisting of industry-related people who oversee the conduct of certified tank opera- tors. Such a board has been operating in Maine for 15 years to oversee the certified tank installer population. Complaints brought by state UST inspectors or other sources are heard before the board and the board can impose disciplinary action, including fines, suspension, or even revocation of certification. This system can respond to problems in a much more timely and efficacious manner than traditional enforcement tools. Postscript Of course, this program must go hand in hand with vastly upgraded UST enforcement and inspection pro- grams. Professional tank operators will have a difficult time marketing their services to tank owners unless UST inspections are routine and defi- ciencies result in meaningful penal- ties. But think" how many more inspections an inspector could con- duct if someone who actually knew all the details of the storage system and could quickly produce all of the required paperwork greeted him or her at each facility. Imagine a world where violations became the excep- tion rather than the rule... • 25 ------- LUSTLine Bulletin 40 Overfill Spills Caused Too Often by Tampering Cliff Manis, a Storage Tank Safety Specialist with the Illinois State Fire Marshals' Office, wrote the following thoughts in response to Ben Thomas's article, " TheMissing Link in Overfill Prevention," LUSTLine Bulletin #39, November 2001: The article's reference to "prod- uct escaping out an opening no one suspected—the loose cap of the automatic tank gauge probe" brings to mind an emergency inci- dent I responded to several months ago. It also reminds me that it was most likely not an isolated incident nor was it an accident. I responded on an emergency basis to a report of a small spill at a gas station as reported by the local fire department. The tanker driver reported an approximately 20-gallon spill, but the fire department stated that the spill was much larger and wanted a representative from OSFM on site. Upon arrival, I observed that the fire department had the spill pretty much under control. They had spread absorbent material and applied absorbent socks to protect a storm sewer man way located approximately 200 feet from the overfill site. Product had run down tlie drive and along the street gutter for a distance of approximately 200 feet. Most of the spill area was at least 8 feet wide to the point of the street gutter, where the width nar- rowed. The amount spilled was approximated to be in excess of 300 gallons. The driver stated that he was at the truck when the overfill began and immediately shut down the valve. He stated that he had not measured the tank because the facility had ordered the fuel, and he assumed that the tank would hold the product. The major source of the overfill was at the point of the automatic tank gauge probe riser. Product also came out tlie vent pipes at a distance of approximately 25 feet from the fill pipe and elevated 12 feet. _ The investigation concluded that the overfill drop-tube valve had been tampered with by jamming a mea- suring stick into the mechanism and breaking it off. This action com- pletely voided the operational design of this safety.device. Also, the ATG probe riser cap had been loosened to facilitate increased venting. Further investigation resulted in the discov- ery that the overfill valves on the remaining tanks had also been tam- pered with, rendering them inopera- tive. The ATG probe riser caps had also been loosened. This is a situation that we encounter all too often during our inspections. Tanker delivery drivers use these methods to facilitate faster delivery drops, and I feel that every- one with the responsibility to oversee these facilities should be aware of this very dangerous procedure and take steps to prevent further occurrences. Keep up the excellent reporting in the newsletter. It keeps me on my toes. Ben Thomas's Response: I agree philosophically that the responsibility of overfills should be more broadly shared. But the truth remains that the UST regulations put the burden solely on the owners and operators. Period. I think the way out of this problem is to start by letting owners and operators know it is their responsibility. By and large owners and operators do not know this because no one reminds them, and no one enforces this regulation. Until those currently accountable know the rules, there is no motive to look for options for reform. In the meanwhile, keep looking for sticks in drop tubes and pray the Biloxi incident is not repeated. • pr L on Microbes and Fuel Systems On reading Fred Passman's article, "Microbes and Fuel Systems: The Overlooked Corrosion Problem," our UST system guru, Marcel Moreau, couldn't resist asking Fred some follow-up questions. So here are Marcel's questions and Fred's answers. Q. Are there any case histories or known incidents of fiberglass rein- forced plastic (FRP) tank failure from bacterial activity? * There is no published doc- umentation of FRP UST failure due to biodeterioration. There is, however a small but significant body of litera- ture addressing the biodegradability of composites. As I am sure you are well aware, failure analysis is a very delicate issue. Traditionally, failure analysis is fodder for litigation. My experience is that fear of litigation inhibits most impetus for all but what I call first-tier root cause analysis (RCA). My clients who do not moni- tor their tanks for microbial contami- nation have no history of microbial contamination. If a tank fails due to apparent mechanical damage, how extensively are contributory causes investigated? The point that I was trying to make in my article Was that there is sufficient evidence of FRP biodegrad- ability to justify a risk assessment based on assumptions and historical records. Assumptions about the inertness of various materials to biodegradation have repeatedly proven incorrect. Often microbes contribute to deterioration indirectly. Their role can be overlooked, particu- larly when an investigation team does not include microbiological expertise. In the U.S., several critical vari- ables have changed in the past half- decade. These changes limit the ------- LUSTLine Bulletin 40 usefulness of historic performance data. In particular, the increased use of oxygenates and other additives has changed the nutrient profile and fuel-water phase partitioning dynamics of both water and organics. Microbial communities recovered from fuel systems today appear to be more robust than those recovered in the past (before 1995). Industry con- solidation coupled with increased product demand has translated into dramatically increased throughput rates. Greater concentrations of con- taminated material get transported through the distribution system. Retail USTs typically become last- stage coalescers in which much of the contaminant material accumulates, further contributing to more robust microbial activity. I do not think that FRP failure is a common occurrence. According to statistics provided by the Steel Tank Institute, neither is steel UST failure. Their quoted annual failure rate is (to me) surprisingly low. I was not able to find any one willing to share FRP tank failure statistics with me, even in confidentiality. During a 1997 con- versation, one FRP tank manufac- turer allowed that they had previously experienced biodeteriora- tion problems, but (as of 1997) had modified their technology to prevent any future problems. Would it surprise you to hear that invariably reports of resistant microbes start cropping up within a few years after each new product's introduction? My point here is that since the scientific literature demon- strates that FRP is biodegradable, I encourage members of the FRP tank fabrication industry to determine the extent to which their products are vulnerable to biodeterioration rather than take a wait and see approach. d. I have always thought that bac- terial activity required the pres- ence of free-phase water in the bottom of the tank. While I gather from the article that this clearly exacerbates the problem, are you also saying that biofilms can exist in the total absence of free-phase water? . Exactly. First, most tanks don't lend themselves to accurate measurement of free water. Many (I estimate about 60 percent) USTs that are thought to be water-free, aren't. Electronic gauging can be inaccurate, tanks may slope away from the mea- surement point, measurements may be taken incorrectly, or water may be pooled at a location in the tank away from the point of measurement. A hundred milliliters of water in a 10,000-gallon UST is unlikely to be detected but can harbor 10E8 to 10E10 microbes. Also, since there is generally some free-water transported with fuel deliveries, and water can enter tanks as vapor in venting air, water can condense on tank walls and become embedded within slime accumulations on the walls. Conse- quently, a 10,000-gallon UST may have 10+ gallons of water entrained within slime accumulations on the shell surface. I used to illustrate this point by drawing a parallel between a 1/8- inch column of water next to a 1- micron long bacterium and a body of water as deep as the World Trade Center was tall next to a 6-feet tall person. Although I must obviously change the metaphor, the point remains that a tank thaf s dry from an industrial engineering perspective is not from a microbial ecology per- spective. d. My corrosion wisdom says that corrosion will not proceed in the absence of an electrolyte, and petro- leum products are not electrolytes. In other words, are biofilms a fuel qual- ity problem rather than a corrosion problem? . I've sampled and analyzed bottom water from close to 2,000 gasoline USTs since 1992. Typically bottom- water alkalinity is >1,000 ppm CaCOS; hardness is in the same range; and total dissolved solids are >1 g/L. Need I look further for elec- trolytes? G. What are the implications of all this for fuel quality/corrosion inside the automobile gas tank? Is an automobile that refuels once a month more at risk than an automobile that refuels once a week? . In the absence of hard data, it's heard to give an unequivocal answer. There is reason to believe that automobile fuel tanks are at risk. I feel that the risk depends more on where the fuel suction line draws from the tank than from frequency of fills. If the suction is offset from the tank's bottom to prevent water and sediment transport to the fuel filter, then water and sediment are likely to accumulate in the tank. This creates an environment that encourages bio- mass accumulation and consequent biodeterioration. If the suction line pulls from the tank's lowest point, then the fuel filter is likely to plug more often. Water and sediment do get into automobile tanks, but the relationship between water and sedi- ment transport and tank failure, or between fill frequency and tank fail- ure, has not been documented. O. Did you know that the 2000 edition of the Petroleum Equipment Institute's RP100, Recommended Prac- tices for Installation of Underground Liq- uid Storage Systems, recommends the installation of a water gauging port at the end of the tank opposite the fill pipe? I've been advocating this since I performed my first gas station survey in 1992. I've never understood why the second gauging port hasn't always been recommended. So far, I've sampled at only one gas station with a sampling port by the turbine. As a diagnostician, I'm a bit con- flicted. On one hand, it certainly makes it easy to get two bottom sam- ples, pull bottoms water, and moni- tor changes in tank trim. However, it makes it more difficult to convince clients that they need to pull the tur- bine (which means taking a UST out of service until the turbine is re- installed) so that I can look at corro- sion on the adapter, turbine riser, and distribution manifold. • Fred Passman is an industrial micro- bial ecologist and owner of Biodeterio- ration Control Associates, Inc., a consulting firm dedicated to helping industry recognize and control micro- bial contamination in process fluid sys- tems. He can be reached at bca-fjp@ix.netcom.com. 27 ------- Mississippi DEQ Seeks Input on Comprehensive TJST Cathodic Protection Guidance Document by Kevin Henderson The Mississippi Department of Environmental Quality (MDEQ) has recently issued a draft doc- ument titled "Guidelines for the Evaluation of Underground Storage Tank Cathodic Protection Systems." MDEQ has released the document for public comment. It is our intent that the final version of the docu- ment will serve as straightforward and easily understandable guidance for testing cathodic protection (CP). It is also hoped that the document will serve as a model that other regu- latory authorities can use in develop- ing their own guidance. We believe that it is necessary to develop this guidance because existing industry standards/codes are woefully inade- quate with regard to proper CP test- ing and documentation. While we recognize that the only thing certain about CP is uncertainty, we are attempting to work out some issues with regard to CP testing that we would like to bring to your atten- tion. We are also seeking any infor- mation you may have with regard to these issues so that we can be assured that the final version of the guidance document reflects a state-of-the-art viewpoint. Bimetallic Couples The first and most troubling issue has to do with "bimetallic couples" and the applicability of the 100 mV crite- rion. The 100 mV criterion is met if it can be shown that the structure under cathodic protection depolar- izes 100 mV or more with the protec- tive current interrupted. We have heard arguments that this polariza- tion criterion cannot be applied to a UST system if there is a metal of a lower electropotential that is electri- cally continuous with the steel com- ponent of the tank system under protection. Without going into a lengthy explanation, the argument 28 goes something like this: If I have an older "bare steel" tank, more than likely it is electrically connected to copper through the wiring that supplies the electrical power to the pump. The electrical power system is grounded through the use of copper grounding rods and is normally also grounded to the water service lines at the facility. Since these lines are usually copper, a significant amount of copper could thus be electrically continuous with the steel components of the tank sys- tem. Stated in simple terms, the 100 mV criterion is not applicable when the metal you are trying to protect is electrically continuous with a metal of a lower electropotential (copper). Since nearly all such "bare steel" tanks will be bonded to copper of at least some significance, the net effect will be the elimination of the 100 mV criterion. As we believe there will be a sig- nificant number of impressed current systems that will be unable to meet the -850 mV instant off-criterion (the only other applicable criterion), this issue could have a potentially enor- mous impact on tank owners. Can you imagine their response when we tell them that they will have to "upgrade" their tank systems again in order to meet the regulatory requirements for corrosion protec- tion? Remote Earth Another issue that has come about recently has to do with the use of "remote earth" reference cell place- ment. The theory of this reference cell placement is that the observed struc- ture-to-soil potential is an average of the entire tank system under protec- tion. Remote earth is achieved when the observed potential does not change appreciably. The Steel Tank Institute is promoting this method of testing sti-P3 tanks for two reasons: • It ensures that the structure-to-soil potential observed does not con- tain an "IR drop" because the ref- erence electrode is within the potential gradient of an anode. An IR drop is defined as the voltage across a resistance and can be thought of as a component of a voltage measurement that causes an error. • It is said to overcome any "shield- ing" that may be affecting the structure-to-soil potential ob- served when the reference elec- trode is placed directly over the tank. Shielding occurs when a structure prevents or diverts an electric current from reaching the desired location. Shielding is com- monly cited when a substandard potential is observed because of the close proximity of the refer- ence electrode to the various tank riser pipes, pump heads, product piping, and other tank appurte- nances. How Many Test Points? A much broader CP issue has to do with the age-old question of how many test points are necessary for an evaluation of the CP system to be effective, and do they all have to "pass"? Some say that at least three test points are required over the tank (at each end and the middle). If thaf s the case, what if you allow the use of "remote earth" testing, which is now permitted as an alternative reference electrode placement in NACE TM0101-2001, "Measurement Tech- niques Related to Criteria for Cathodic Protection on Underground or Submerged Metallic Tank Sys- tems"? If the remote earth test point indicates adequate cathodic protec- tion, is it then acceptable for one or ------- LUSTLine Bulletin 40 more of tke local potentials to be less than-850 mV? More fundamental to some argu- ments that all reference cell place- ments must indicate a pass is the simple fact that measurement of structure-to-soil potentials with a ref- erence electrode is an inexact and crude technique that is fraught with difficulties. As it is entirely possible to substantially change the potential observed simply by moving the refer- ence electrode a few inches within a manway, it then follows that you could find at least one "dead spot" on practically any UST cathodic protec- tion system you are testing. In other words, a substandard potential can be observed on almost any UST sys- tem if you "hunt" long enough for it. Do You Have Some Answers? If so please download the draft ver- sion of the Mississippi CP guidance document from our Web site (www.deq.state.ms.us) and help us produce a useful document that will allow all of us to understand the proper techniques required for an effective evaluation of UST cathodic protection systems. From the home page, click on "Underground Storage Tanks" and then look under "UST Information" for the document titled "Guidelines for the Evaluation of Underground Storage Tank Cathodic Protection Systems." The draft document is available for comment until June 1, 2002; the final version will be published July 1, 2002. Your help in producing the final document is needed and greatly appreciated. Please direct any com- ments you may have to Kevin Hen- derson of the Mississippi DEQ. Telephone: (601) 961-5283; e-mail: Kevin_Henderson@deq.state.ms.us; mail: Mississippi DEQ, P.O. Box 10385, Jackson, MS 39289-0385. • Will Congress Lay Down the Law on USTs? A Glimpse at S. 1850, the Underground Storage Tank Compliance Act of 2001 by Ellen Frye With 18 years having passed since the first federal UST regulatory program was enacted and, alas, with our way-too- close encounters of the MTBE kind, we now have Senate Bill 1850—intro- duced on December 19, 2001, by Sen. Chafee (R-RI). The aim of the bill— The Underground Storage Tank Compliance Act of 2001—is to bring USTs into compliance with the requirements of Subtitle I of the Solid Waste Disposal Act and to provide sufficient resources for such compli- ance and cleanup. Cosponsors of the bill include Sen. Carper (D-DE), Sen. Smith (R-NH), Sen. Jeffords (I-VT), and Sen. Inhofe (R-OK). The pro- posed bill sets forth enhanced enforcement strategies and offers states funds and flexibility to get the job done. The bill, if enacted as written, will present states with some challenges that could have very positive results if thought through and implemented effectively—the ultimate challenge. Hopefully the bill will provide flexi- bility during the transition period so that states have the opportunity to look for new, innovative ways to meet the goals of the bill, without having to settle for counterproductive approaches designed to meet a pre- scribed timetable. Finally, while the bill would greatly increase the autho- rization levels for funds and expand the allowable use of funds, states still shudder to think of that vast and vex- ing gap between funds authorized and those actually appropriated. So lef s take a look at the bill's main fea- tures, section by section. • Leaking Underground Storage Tanks The bill gives states greater flexibility to implement the underground stor- age tank program. EPA would be required to distribute to the states at least 80 percent of the funds appropri- ated each year from the LUST Trust Fund (applies to Section 9013(2)a only). States could use these funds to pay for the reasonable costs of: • Actions to carry out and enforce corrective actions; • Necessary administrative costs of state assurance funds; • Enforcement of a state program; • State or local corrective actions; and • Corrective action or compensation programs under a state program if there is no financially viable owner or operator of an UST. States may also use funds to enforce state or local leak detection, prevention, and other requirements. States may not use these funds to provide financial assistance to own- ers and operators of tanks to comply with existing regulations governing USTs, including the requirements for upgrading existing tanks. • Inspection of Underground Storage Tanks All USTs regulated under Subtitle I are to be inspected every two years. This frequency would be an immense improvement over the inspection reality in most states. In fact, many states may find this timetable for get- ting such an inspection program up and running problematic. A June 2000 report released by EPA esti- mates that the cost of these biannual inspections will be $35 million for each of the first two years and $20 million for every year after that. This section authorizes that level of fund- ing to pay for this inspection require- ment. • Operator Training EPA must publish guidelines that specify methods for training opera- tors of underground storage tanks. The guidelines must take into account existing training programs put in place by states and operators, the high turnover rate of operators, the frequent improvements in tank technology, and the nature of the businesses in which operators are engaged. (See Marcel Moreau's thoughts on this in "Tank-nically Speaking" on page 23.) • • continued on page 30 29 ------- LUSTLine Bulletin 40 S. 1850 from page 29 From the date on which the guidelines are published, the states would have two years to develop and implement a strategy for the training of UST operators that is consistent with the guidelines, is developed in cooperation with owners and opera- tors, and takes into consideration existing operator training programs. This section allows EPA to provide an award of up to $50,000 if a state develops and implements a state operator training strategy. • Remediation of MTBE Contamination EPA and the states are authorized to carry out remediation of MTBE releases that present a threat to human health or welfare or to the environment. This section authorizes a one-time appropriation of $200 mil- lion for this purpose, which will remain available until expended. • Release Prevention and Compliance Funding ($200 million over six years) is authorized for EPA or states to con- duct inspections, issue orders, or bring actions under this subtitle. This section also requires states to submit to EPA a strategy to ensure compli- ance of tanks owned by state or local governments. EPA may award up to $50,000 if a state develops and imple- ments the strategy. EPA and states are required to consider compliance history and operator training programs when determining both whether, to issue a compliance order and the amount of the penalty. EPA or states with an approved program would have the authority to prohibit the delivery of regulated substances to USTs that are not in compliance with a UST requirement or standard. Prior to exercising this authority, EPA must promulgate reg- ulations that describe the circum- stances under which the authority may be used and the process by which the authority will be used con- sistently and fairly. EPA must require states and tribes to maintain and update data, at least annually, and make available to the public a record of USTs regulated under mis subtitle. EPA would make each public record available to the public electronically. • Federal Facilities EPA, in cooperation with federal agencies that own or operator USTs or that manage land on which USTs are located, would be required to review the status of compliance of those tanks within one year of enact- ment. Within two years of enactment, each federal agency that owns or operates USTs or that manages land on which USTs are located must develop strategies to bring its tanks into compliance with applicable law. from Robert N. Renkes, Executive Vice President, Petroleum Equipment Institute Industry Gives the Nod to S. 1850 When Congress debated the provisions of Subti- tle I of the Resource Conservation and Recov- ery Act Amendments of 1984, the petroleum marketing industry was quick to voice its concerns over what Congress hoped to accomplish and how they envi- sioned EPA regulating over 2.5 million underground tanks. The reaction of the petroleum marketers to the Underground Storage Tank Compliance Act of 2001 is different. This time they seem very supportive of the proposed legislation and anxious to get it passed. Here is a brief summary of each trade association's reaction to S. 1850. As you can see, the regulated community is not likely to stand in the way of the measure's passage. The Society of Independent Gasoline Marketers Association (SIGMA) is generally supportive of S. 1850 and will urge its passage. One provision that the group would like to change currently limits reimbursement of corrective action to owners and operators that do not have the financial resources "to pay the cost of a correc- tive action without significantly impairing the ability of the owner or operator to continue in business." SIGMA believes this form of economic relief should be available to all tank owners, without regard to their financial means to pay for the cleanup. Broadening the definition of who can be reimbursed will, in their opinion, clean up more leaks and not get the process bogged down by trying to figure out who qualifies for the reimbursement program. The Petroleum Marketers Association of America (PMAA) is strongly in favor of the bill as it is written. They believe the bill probably doesn't need any tweak- ing but were still in the process of canvassing their mem- bers to receive their input at press time. Although the National Association of Convenience Stores (NACS) agrees with the bill in concept, in their opinion there is some language that could be changed to improve S. 1850. One of the provisions they would like to amend provides using funds "to carry out corrective actions with respect to a release of methyl tertiary butyl ether (MTBE) that presents a threat to human health or welfare or the environment." NACS prefers to use the Trust Fund money to finance "high-priority cleanups" and not just those with releases containing MTBE. NACS also would like to have some provisions governing oper- ator training and prohibiting delivery of product clari- fied. The American Petroleum Institute (API) generally supports the bill but would also support some modifica- tions to the bill that would clarify the language and make it more effective. The message from the marketers we talked to is sim- ple: They are not going to stand in the way of S. 1850. In fact, we haven't heard from or read anything about any- one who is. • 30 ------- LUSTLine Bulletin 40 m Tanks Under the Jurisdiction of Indian Tribes EPA, in cooperation with Indian tribes, would be required to develop and implement a strategy within one year of enactment that prioritizes UST releases on Indian lands and take nec- essary corrective actions with respect to those prioritized releases. Within two years of enactment, and every two years thereafter, EPA would sub- mit to Congress a report that summa- rizes the status of implementation of the UST program on Indian lands. • Authorization of Appropriations This .section provides an authoriza- tion of $25,000,000 for each of FY2003-2007 to carry out Subtitle I (except the LUST program). It also provides an authorization for appro- priation of $100,000,000 from the LUST Trust Fund, for each of FY2003-2007 (to carry out the LUST program); $200,000,000 to remain available until expended for the remediation of MTBE contamination; $35,000,000 for each of FY2003-04 and $20,000,000 for each of FY2005-07 to carry out the biannual inspections;, and $50,000,000 for FY2003 and $30,000,000 for each of FY2004-2008 to carry out new section 9011. • •^...<*3v Tk£1*syXt-£ Photo by: Dave Meyers of Hardy Environmental Services in New Castle, Delaware Wow, what a patch job! Would you be surprised to learn that 19,000 ppm diesel-range organics were in the soil beneath this residential heating oil tank? If you have any UST/LUST-related snapshots from the field that you would like to share with our readers, please send them to Ellen Frye do NEIWPCC. LU.S.T.LINE Q One-year subscription. $18.00. Q Federal, state, or local government. Exempt from fee. (If you wish to have LUSTLine sent to your home, please submit your request on agency letterhead.) G Please take my name off your mailing list. Q Please send me back issues of LUSTLine. Fill out name and address — no P.O. boxes. Back issues cost $3.00 per issue or $50.00 for a complete set. If ordering back issues, please indicate LUSTLine issue #"s Q Please send me a LUSTLine Index. Name Company/Agency Address Please enclose a check or money order (drawn on a U.S. bank) made payable to NEIWPCC. Send to: New England Interstate Water Pollution Control Commission Boott Mills South, 100 Foot of John Street, Lowell, MA 01852-1124 Phone: (978) 323-7929 • Fax: (978) 323-7919 • lustline@neiwpcc.org • www.neiwpcc.org We welcome your comments and suggestions on any of our articles. 31 ------- New USTfields Initiative Grants to Be Announced in Late Spring The EPA Office of Underground Storage Tanks (OUST) has received proposals for its USTfields Initiative that will provide funding for up to 40 state-local pilot partnerships and at least one tribal grant to promote innovative approaches to foster cleanup and recycling of America's gas stations and federally regulated petroleum-contaminated sites. The grants will be awarded on a com- petitive basis, with at least one award for every EPA region. The money must be spent at a federally regulated UST site, and the site must be eligible for LUST Trust Fund expenditures. The grant awards will be announced in late spring. • Report on Recycling America's Gas Stations Now Available The Northeast Midwest Institute and the National Association of Local Government Environmental Professionals, in cooperation with EPA, have released a new report on EPA's USTfields Pilot Initiative, titled Recycling America's Gas Sta- tions: The Value and Promise of Revital- izing Petroleum-Contaminated Proper- ties. The report provides background on the challenges of UST contamina- tion across the nation. It profiles 20 examples of USTfield revitalization efforts in states and localities, puts forth key findings on USTfields issues, and promotes action items that could strengthen the national USTfields initiative. EPA will distrib- ute copies of the report to states and regions. To obtain a copy of the report, contact Matthew Ward at matt.ward@spiegelmcd.com. • Implementation Planning Underway for New Brownfields/Petroleum Sites Legislation Public Law 107-118, the Small Busi- ness Liability Relief and BrownfLelds Revitalization Act, has passed, fold- ing petroleum-contaminated sites into the brownfields arena and authorizing up to $50 million a year for the cleanup of petroleum sites of any type, not just federally regulated UST sites. This money can go directly to municipalities as well as states. PL107-118 implementation work- groups have been organized to examine how this bill will expand or complement work that is already underway in the revitaliza- tion arena and to develop guidance to streamline integration, n Inspector Training at Georgia Tech As part of OUST's ongoing efforts to achieve improved compliance it awarded the Georgia Institute of Technology in Atlanta, Georgia, a cooperative agreement to develop and deliver a training course for state and tribal UST inspectors. The course, "Compliance Inspections of Underground Storage Tanks," was held on February 12-14, 2002. Corey Fischer, research engineer with the Georgia Tech Research Institute, was the course director. The main instructors for the course included: Ben Thomas, Principle, Ben Thomas Associates; Shaheer Muhanna, Georgia Environmental Protection Division; and James G. Clemenson, U.S. EPA, Region VII. A total of 62 attendees were pre- sent, representing 38 state agencies, four territories, and six tribal enti- ties. Three EPA regional personnel audited the course. • LU.ST.UNE New England Interstate Water Pollution Control Commission Boott Mills South 100 Foot of John Street Lowell, MA 01852-1124 Forwarding and return postage guaranteed. Address correction requested. LUSTLine T-Shirts bekfifsfttt TWO BiW WACKY doslflns i and 6l«k TWO nnioss... long and short slfieva lotK)StS(V»S17.00 Strait sh«v« $13.00 SbMlM.L,X.XXL TO O«1C R 5md eh«k »r money (xdcr MIME* m US. twifa only) tK Niawrcc BooU Mills Smth. 100 Foot of John Street. LowtlL MA 01852-1124 T«b (978) 32J-7929 • fix (978) 323-7919 ------- |