'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
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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
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1
D DISPERSION AND DECAY COMPARED TO BASE CASE
— .— Base Case
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• Base Case - 0.2 year decay
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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
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pe,.. complex and sophisticated (for
sons that are economic as well
as environmental), as are the
jjigulatidns^govefhing them. Yet we
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pjffjhj^ street
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'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
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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
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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
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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
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BooU Mills Smth. 100 Foot of John Street.
LowtlL MA 01852-1124
T«b (978) 32J-7929 • fix (978) 323-7919
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