New England Interstate
Water Pollution Control
Commission
255 Ballardvale Street
Wilmington
Massachusetts
O1887
Bulletin 25
December
1996
IDS
A Report on Federal & State Programs To Control Leaking Underground Storage Tanks
A  MATTER OF SURVIVAL

As the '98 UST Upgrade Deadline Looms Ever Closer, "Mom and Pop" Gasoline
Retailers Face Tough Financial Decisions And—In Many Instances—A Hefty
Dose Of Confusing Information


      Beaudry Store sits in rural splendor, framed by the
      backdrop of Camel's Hump Mountain, the fourth
      highest mountain in Vermont. Ten years ago,
Terry and Linda Pecor made the decision that selling gaso-
line was essential to the viability of their small country
store. "We knew we needed to be able to offer one-stop
shopping," explains Terry. "We took a hard look at what
we had and figured we stood to lose 40 percent of our busi-
ness if we closed out our tanks."
    "You really have to think about the amount of busi-
ness you do and whether its  worth keeping those tanks,"
adds Linda. "We are rural,  and we do a lot of business
with loggers, school buses, and the fire department. We're
just far enough out that we don't have the competition. If
we'd been someplace else, we might have decided differ-
ently. Like every business, you take long looks before you
do something."
    Terry and Linda mapped out a long-term plan. Their
bare steel tanks were more than 20 years old. The first
thing they did was to remove the tanks and replace them with fiberglass tanks and spill and overfill protection. In 1993,
they had automatic tank gauges installed in both of their gasoline tanks and their kerosene tank. At the same time, they
had vapor recovery piping installed in anticipation of any future Stage II requirements.
    "We didn't want to have to tear up the parking area again if we
could help it," says Linda. "I really like the automatic monitoring," she
adds enthusiastically. "Every morning we push the monitoring button,
and we know exactly the status of that tank. That's really important to
me. I want to know that my tanks aren't leaking.
    "Ten years ago," she recalls, "none of us knew anything about all of
this. It used to be that we only needed to be concerned with weights and
measures for our gasoline and the health department for our deli business.
Now we have storage tank requirements, hazardous waste requirements,
air pollution requirements, and health and safety requirements. The aver-
age person realizes why we're doing these things. No one wants to
pollute. But for mom and pops it's harder."
                                  • continued on page 2
                                     I
                             Drinking Water SRFs
                             The Last Lonely Gas Station
                             Contractor Availability
                             Testing Cathodic Protection
                             ALICE: An Evolving Concept
                             Status of ASTM ES 40-94
                             PA: 3rd-Party UST Inspection Program
                             Increasing Enforcement Presence
                             Contamination in Silts and Clays
                                  1 Printed on Recycled Paper

-------
LUSTLim Bulletin 25
• A Matter of Survival from page 1
With the leak detection and financial
responsibility compliance deadlines
behind them/ tank owners and oper-
ators with unprotected steel tanks
now face a deadline that will essen-
tially define the course of their petro-
leum storage operations. They have
until December 22,1998 to comply
with corrosion protection and spill
and overfill  prevention require-
ments. If they don't plan to close
their tanks by then, they must decide
whether to install new tanks  and
piping, or satisfy minimum federal
requirements by retrofitting their
existing systems.
     While larger companies, such as
major oil companies and convenience
stores, and a sizable portion of inde-
pendents  have had upgrade pro-
grams underway for a number of
years, nonretailers  (e.g., trucking
fleets), utilities, government entities
(especially smaller municipalities),
and small "mom and pop" businesses
lag behind. The mom and pops, in
particular, tend to be out of die retail
marketing information loop.
     "Many of these people either
don't know what their upgrade and
monitoring options are," says David
Rubin, Principal Geologist with the
New Jersey Department of Environ-
mental    Protection's   (NJDEP's)
            the NEIWPCC \v ilh a grant
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       atsaehusetts New Ham
           Rhode Island and  ermont
            Balurdvalc 'Street
           mington MADlSS?
        Telephone  508)658-0500
              (508J65-5!W -
                               While larger companies, such as
                                  major oil companies and
                              convenience stores, and a sizable
                              portion of independents have had
                              upgrade programs underway fora
                                number of years, nonretaiiers
                               (e.g., trucking fleets), utilities*
                               government entities (especially
                              smaller municipalities), and small
                              ^f'mom and pop" businesses lag
                              ^behind.  The mom and pops, in
                            t!!!	
                            I:
   particular, tend to be out of the
  .retail marketing Information loop.
Bureau of USTs, "or if they do know
them, I'm not sure they fully under-
stand all the advantages and disad-
vantages of each of the options. As a
result, they rely on the vendors, who
are selling a product that may satisfy
the rules, but may not be the most
cost-effective  solution  for  that
owner."

Getting the Story  Straight
In deciding how to go about meeting
'98 deadline  requirements,  tank
owners need to know, first and fore-
most, exactly what those require-
ments are. Large corporations often
have whole departments whose sole
responsibility is  to figure out the
rules and regulations, provide facts
and figures on options, and move
the environmental compliance show
along. Mom and pops,  on the other
hand, are the chief cooks and bottle
washers of their  own  small enter-
prises. They are  not likely to sink
their teeth into the federal register or
state statutes to find out every little
thing the rules and regulations say
they are supposed to be doing. Some
of these small business owners are
incapable of reading outreach mater-
ial; others don't take the time.
     Richard Ostrom, Supervisor of
the Idaho Petroleum Storage Tank
Fund (PSTF), has worked hard to
provide state fund insurance policy-
holders  (about 87 percent  of the
state's service stations) with  clear
and concisely written material, pri-
marily through the fund's newslet-
ter, PIPELINE. PSTF even published
a  special  in-depth  edition  of
PIPELINE dedicated solely to the '98
deadline. Even so,  says Ostrom,
PSTF field reps, who make annual
visits to all policyholders to verify
compliance, make it a point to "talk
up" the '98 deadline.
     "If you look at it from an insur-
ance  perspective,"  says Ostrom,
"how  many  people know what's
actually in their policy? That goes for
the regs too. Unless there's an infrac-
tion they  need to address, people
rarely read the regs; many  don't
even  read  user-friendly  written
material."
     Then again, questions come, up
that   wouldn't   necessarily  be
addressed  in  anybody's  written
material. Questions like, "Can I do
my internal lining and cathodic pro-
tection at different times?"
     Many mom and pop businesses
find themselves unwittingly caught
up in a survival catch-22—running
marginally viable businesses  and
facing upgrade costs that could drive
them out of business. As Linda Pecor
points out, most tank owners know
the rules came about for good  rea-
son, but for mom and pops, coping
with these rules is particularly hard.
Their survival margin is slim. If they
don't get  the story  straight about
their options, they won't be in a posi-
tion to make intelligent, informed
business decisions.
     At the outset of a  recent out-
reach  workshop mounted by  the
NJDEP, a couple who owned a gaso-
line retail facility took the opportu-
nity to launch into a tirade on the
theme that they were overregulated
and that the  cost of compliance to
station owners is enough to drive
them out of business. At the end of
their discourse, they received an
enthusiastic round of applause from
the others in attendance.
     As the day went on and state
staff and invited experts explained
the technical requirements and how
to get a loan,  some of the anger  and
frustration that had filled the room
earlier subsided. "Many of these
tank  owners were  either  misin-
formed or misunderstood the rules,"
says David Rubin. "By the end of the
day, they had a better understanding
about the options and  were more
comfortable about what they had to
do to comply.
     "Their concern is  survival,"
observes Rubin. "They all want to do
the right thing, but feel it could be
done cheaper. After spending time

-------
                                                                                            LUSTLine Bulletin 25
talking to the couple who spoke out,
we realized one big reason why they
were so very angry. They were lead
to believe, through an assortment of
vendors and contractors, that they'
had to use literally every leak detec-
tion and corrosion protection option
to be in compliance. They were get-
ting astronomical prices to do their
upgrades."
     "Some people are scared, so they
don't want to ask," says Dale Marx,
UST Section Manager at the Utah
Department of Environmental Qual-
ity. "A lot of tank owners think the
rules are worse than they really are."
    -In  Utah,  every  facility is
inspected. When the inspection is
completed, the inspectors let the tank
owners know what they have to do
to comply and have  them sign an
inspection sheet that says they know
what they have to do. The depart-
ment also provides training for own-
ers and operators.
     "In talking to owners and oper-
ators, we've had people who were
planning to go out  of  business
rethink their options because they
realized  they'd  gotten the wrong
story," says Marx.

Business Viability
In deciding whether to close, replace,
or upgrade their tanks, owners and
operators need to be able to evaluate
all their options, the pros and cons of
each  alternative,  and  the  costs.
Examining the viability of the busi-
ness—with  or  without  gasoline
sales—is an essential element in this
process.  An income/expense,  or
profitability, analysis should be con-
ducted. Income should be calculated
for each element of the business (e.g.,
gasoline  sales,   groceries,  video
rentals).  All expenses  should  be
included in the calculations (e.g.,
utilities, insurance, wages and bene-
fits, taxes, debt service).
     The resulting net profit calcula-
tion should be further analyzed in
terms  of the  decision to  close,
replace, or upgrade. Gasoline sales,
which  may constitute just one ele-
ment of the total profit picture of a
rural convenience store, may well
constitute the most important ele-
ment of the profit picture. If the busi-
ness  does not sell gasoline, will it
continue to attract the same levels of
grocery sales or video rentals?
     Once they've pulled together
all their facts and figures, many tank
owners will have to take a hard look
at whether its worth staying in the
gasoline  retail  business—closure
may be the best business decision.
     If a decision is made to replace
or upgrade, most tank owners will
need to be able to get a loan. At this
point,  a realistic evaluation must be
made of the ability of the business to
sustain additional debt. For example,
a $80,000 loan for a period of 10 years
at 9 percent interest,  results in a
monthly debt service  of $1013.14.
While  the cost of replacing  or
upgrading an UST system may be
less than $80,000, an accurate esti-
mate of debt service is  essential to
future  planning.
 gfB/nosf tank owners know the rules
  Wabout for good reason, but for
        Snfl pops, coping with these
      ^fparticuTarlyliard. Their
     'ival margin is slim. If they don't
     ^sy-a^i^^  ^ ^^M *•«*    * -"-    •
   'get the story straight about their
  options, Ihey won't be in a position
       make intelligent, informed
         business decisions.
Close, Replace, or
Upgrade?
In general, the cost of upgrading a
tank system is considerably less than
replacing the entire system—tanks,
piping, pads, dispensers. For tank
owners or operators in states  like
Florida and Maine, the business deci-
sion is limited to two options: close
or replace.  In  Maine, all bare (or
asphalt-coated) steel tanks must be
removed as of October 1,1997 and all
new tank systems must be double-
walled. In Florida, cathodic protec-
tion and interior lining are no longer
allowed, as of December 31, 1991.
     If a tank owner or operator
decides that he or she can afford to
replace, then the decision becomes
one of choosing an affordable system
that, at the least, meets minimum reg-
ulatory requirements or, at the most,
saves time and effort and "guaran-
tees" that not one drop of product
will ever find its way into the envi-
ronment. Tank replacement   also
involves the uncertainty of not know-
ing what level of contamination will
be found in the soil and groundwater
when the old tanks are pulled, and
thus, what cleanup costs might be
incurred. On the bright side, how-
ever, tank replacement suggests the
satisfaction of starting anew with a
"clean slate" and reduced risk. Many
tank owners are wiping their slates
clean by removing their USTs and
replacing them with  ASTs  (above-
ground storage tanks).
     If you're the only tank owner in
town, you don't have price competi-
tion.  If you decide to replace your
tanks, you can pass some of this cost
on to your customers. If you are com-
peting with two or three other busi-
nesses and you are the only one who
replaces, it will be more difficult to
pass the cost on to customers.
     In states that allow  a  third
option to closure or replacement, if a
tank owner wants to stay in business
and can't afford to replace, he or she
will need to upgrade. This means
retrofitting the existing system with
spill prevention and overfill protec-
tion.  This means retrofitting the
existing system, including the pip-
ing, with corrosion protection. This
also means leaving any contamina-
tion that may be lurking in the soil or
groundwater unattended until such
time that it is inadvertently  discov-
ered...or not. Upgrading can  add
years to the life of an underground
storage operation as long as all the
upgrading has been done properly,
and as long as the system is moni-
tored properly and leak detection is
in working order.
     In deciding how to meet the '98
deadline, tank owners and operators
who run  retail operations tend to
weigh-in one other significant factor:
the cost of lost business. Many tank
owners and  operators make  deci-
sions based on how much, if any,
down time is involved. Some choose
to upgrade rather than replace their
tanks, partly  out of fear  that cus-
tomers will take their business else-
where and never come back.

Financing
Tank owners and operators need cap-
ital to make improvements to their
facilities. Lenders want to be able to
extend secured loans where there is
sufficient collateral to cover the loan
should the business  fail. In some
instances, the assessed value of a

               • continued on page 4

                               3

-------
llISTLinc Bulletin 25
• A Matter of Survival from page 3

property with an UST is insufficient
to cover a sizable loan, particularly if
the property has contamination.
     In recent years, lending institu-
tions have been  reluctant to extend
loans to businesses where tanks are
involved and where the real estate is
the primary collateral because of
uncertainty  about  their  liability
should the business fail and the
lender take possession of the prop-
erty through foreclosure.
     EPA's   recent  UST-specific
lender liability rule has helped ease
these uncertainties by specifying the
conditions under which secured cred-
itors may be exempt from compliance
with federal UST rules and thus avoid
incurring cleanup liability. In doing
this, EPA hopes it has removed a sig-
nificant barrier  to the financing of
UST facility  improvements. But in
many states, environmental agencies
still need to educate lending institu-
tions on matters of USTs.
     "We realized a while back that
we  needed  to  do  something to
address  the hysteria in the lending
institutions over UST facilities," says
Herb Meade, Chief of Compliance at
the  Maryland Department of the
Environment Oil Control Program.
"The banks need to be comfortable
about the tanks and the pollution lia-
bility.  [The state had its own lender
liability rule in place.] So we held a
series  of meetings across the state
with loan  officers  and  property
assessors to put  things into perspec-
tive and point out the questions that
they need to be asking. They were
envisioning a monster, and the meet-
ings seem to help make tank proper-
ties a little less frightening. Things
started rolling again."
     Once the myths and miscon-
ceptions are stripped away, lenders
should be able to  look at UST sites
strictly from a lender's standpoint.
Many  small  businesses are able  to
obtain tank upgrade or replacement
loans with relative ease. Some have
to look around a bit before they find
the right bank—it's  important that
the  tank owner go  to the  "right"
bank. Some banks are actually look-
ing to lend  money  to small busi-
nesses or  local  businesses;  others
have some other criteria. The small
business owner who has done his
homework, has his financial house in
I* Once the myths and misconceptions
I are stripped away, lenders should  "
I be able to look at UST sites strictly
i: tank upgrade or replacement loans
e laokarounia bjibejfojejhey find the
   right hank—it's important that the
   tank owner go to the "right" bank.
  Some banks are actually looking to
:  lend money to small businesses or
           other criteria.
order, runs a prudent gasoline retail
operation, and has the wherewithal
to secure the loan stands a good
chance of finding a willing lender.
The more secure the loan, the better.
     Unquestionably, however, some
businesses will fail to qualify for a
tank upgrade or replacement loan.
"I've seen mom and pops whose
profit margin is $4,000 a year," says
Meade. "Thaf s not a viable business.
As regulators, we can give an owner
or operator a little more time to see
what they can do to come into com-
pliance, but in most of these cases
another month or two won't make
any difference."

Financial Assistance and
Public Policy
Should  we care whether the mom
and pops survive? If small business
is, indeed, the backbone of America
as many politicians proclaim, should
government assist in ensuring its sur-
vival? in many rural areas, the loss of
a small marketer would mean the
loss of the only petroleum retailer for
miles. (See the following article, "The
Last Lonely Gas Station.") In many of
these states, the programs were initi-
ated because of concerns that small
petroleum  marketers  would  be
forced out of business because of dif-
ficulties in obtaining financing  for
regulatory compliance outlays.
     Some assistance is available to
small businesses through Small Busi-
ness Administration loan guarantees.
Many mom and pops, however, are
in such tenuous financial circum-
stances that a loan guarantee is of lit-
tle value because they are not able to
deal with additional  debt service.
     "If s a public policy issue," says
Mike Brush, Claims Supervisor for
the Idaho PSTF. "States may want to
make sure there  are  way stations
where people can pull off the high-
way to get gas, make an emergency
phone call, get help if their car brakes
down...to meet public need. This ser-
vice is important for tourism as well
as for local well-being. Mom and pop
convenience stores are  part of the
economic fabric of many rural states.
There are many issues besides prof-
itability that fall into the area of pub-
lic need."
     Many rural convenience stores
are the source of gasoline, not just for
motorists, farmers,  or loggers, but
also for such public entities as fire
departments,  police  departments,
school buses, and ambulances. The
public safety support provided by
mom and pops prompted the Wash-
ington  legislature   to   maneuver
through some rather serious constitu-
tional constraints to conduct a grant
program that reached 99 mom and
pops throughout the  state.  During
the devastating forest fires of 1995 in
north central Washington, three gas
stations that  had been upgraded
through the grant program were the
sole source of fuel for the fire-fighting
crews for more than 3 weeks.
     Some state legislators and UST
program managers have grappled
with how to resolve a few basic ques-
tions: Who do we need to help just
because of  environmental  issues?
Can we make sure that environmen-
tal compliance concerns are not the
single  factor that puts a mom and
pop out of business? If a mom-and-
pop station is teetering on the brink
of failure simply because it  can't
afford the upgrade, should the state
step in and offer some assistance? If
we offer assistance, what criteria do
we use?
     Fifteen states have instituted
financial  assistance  programs for
UST owners and operators. Most of
these are  loan programs;  a few are
grant programs. Kentucky is gearing
up for a  reimbursement  program.
Some programs, such as those in Cal-
ifornia and Oregon,  address tank
removal, installation, upgrade, leak
detection, and cleanup. Most of the
programs have a cap on what they
will loan per site.

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                                                                                             LUSTLine Bulletin 25
      EPA published  a  document
 titled, Financing Underground Storage
 Tank Work Federal And State Assis-
 tance Programs, to help all UST own-
 ers  and  operators—but especially
 those with tanks on tribal lands—
 obtain loans or grants for financing
 corrective action and upgrading UST
 systems to meet the 1998  require-
 ments,  (Copies   can  be  ordered
 through the RCRA/Superfund Hot-
 line  at  (800)424-9346,)
 Why Not Wait
 Until 1998?
 Terry and Linda Pecor
 upgraded their tanks on a phase-in
 basis, In terms of which tanks and
 what hardware they would install,
 they relied on their contractor. "You
 rely on others to make some of these
 decisions and hope you do the right
 thing," says Linda, "I  find myself
 trying to second-guess everybody,
 and I don't hesitate to call the state if
 I have questions,"
     Terry  and Linda  have made
 their tank management decisions;
 they've addressed their  corrosion
 protection, leak detection, and spill
 and overfill requirements; and now
 they are comfortably out of the fray
 should there be a last minute '98
 deadline stampede. Unfortunately,
 this isn't  the case for many others
 like them.
     It's a  matter of supply  and
 demand, Iowa is a good example of
 demand for  contractor  services ex-
 ceeding supply. Anyone  who was
 using the Iowa state fund for insur-
 ance  purposes, or who was self-
 insured and eligible for remedial
 benefits (about 3,000 facilities) had to
 be  upgraded by January 1, 1995.
 According to Pat Rounds, Adminis-
 trator of the Iowa Underground Stor-
 age Tank Financial Responsibility
 Program, a lot of people  waited until
 the last minute.
     Many of the owners and opera-
tors who would have replaced their
tanks had difficulty scheduling their
replacements to meet the  deadline
 (even when it was extended an addi-
tional 3 months), so they selected the
quickest   and   cheapest   upgrade
method they could find, which was
either lining or cathodic protection, By
not installing new systems, these tank
owners also lost out on the benefit of a
$10,000 grant the state fund was offer-
ing as an incentive for installing dou-
ble-walled systems. "It was definitely
a crunch," says Rounds,
     The law of supply and demand
was also operative in Florida in 1991,
In that state, cathodic protection and
internal lining were not allowed after
December 31,1991—this was the last
chance for a cheap upgrade, As the
deadline approached/the demand
for contractors soared, but the sup-
ply was short, Florida contractors
brotjght in  personnel  from other
states to help them with the backlog,
     Waiting until  the  last  minute
presents potential problems of back-
logs, materials shortages, and worst
of all, shortages of qualified,  compe-
tent contractors to install new sys-
tems   and  upgrade  or  remove
existing systems, While some tank
and equipment manufacturers may
not agree that  there will be short-
ages, most agree that the costs for
products and services are likely to go
up as the '98 deadline approaches.
      On the cleanup side  of  the
equation, tank removals more often
than not reveal some degree of petro-
leum contamination, If 1998 brings
an upsurge in tank  removals and
associated remediation activity, state
fund programs may experience
claims processing problems, not to
mention drawdown problems.
     Many mom and pop businesses
may have already made the decision
to hang in there until the '98 deadline
(or until they get caught) and then
close up shop. Without some form of
assistance, some of  the  marginal
facilities will have to make that hard
business decision to shut the doors
and pull down the shades. For those
small businesses who want to stay in
business but haven't gotten their
upgrade house in order, now is the
time to act. •
  New Drinking Water State Revolving Loan Funds
  Leave Door Open  For UST Projects
       The new Safe Drinking Water Act (SDWA) amendments signed into law this
       past August authorized a total of $9.6 billion in capitalization grants for the
       establishmeLKLnt of State Revolving Loan Funds (SRFs) to offer financial
  assistance to public water systems. Eligible uses of these funds include a variety of
  source water protection measures, such as delineations and assessments of drink-
  ing water source protection areas, land acquisition, and a variety of source protec-
  tion implementation activities,     -        "'_'    _   :
       The law states that  up to 15 percent of a state's appropriation can be used  to
  provide loans to community water systems for source protection measures, as long
  as no more than 10 percent of the appropriation is "set aside" for any single initia-
  tive. States are currently awaiting final guidance from EPA on how to administer the
  SRF program but have been advised to begin thinking about what types of activities
  they would like to fund using these "set-asides." Preliminary guidance, and the
  Interpretation  of this guidance by some states, acknowledges that eligible source
  protection measures could include UST projects, providing the tanks exist in a
  drinking water source protection area and the projects would prevent contamina-
  tion of drinking water,  ".-...;•.-.•
       States will need to  make careful decisions
  about how and to what extent they want to take
  advantage of the allowable set-asides. In Massa-
  chusetts, for example, should they choose to take
  advantage of all the allowable set-asides, 31 per-
  cent of their fund would be unavailable as loans
  to finance infrastructure projects., "-.'•
       States need to be thinking about how they
  will administer their SRF programs now, State
  UST/LUST programs that  might want to consider
  this financial assistance  option should contact
  their state SDWA primacy agency to discuss eli-
  gible projects and the possibility that UST pro-
  jects could be considered for funding under the
  source protection set-aside. •
               •  FREE
         The League of Women Voters
          Education Fund presents
        Tools for
        Drinking
        Water
        Protect!
        For information and a license form,
             call 1-800-257-2578
             or visit our Web site!
           www.drinking water.org
                 »™,^,   «}
                 yS&SHSl tts
        Live via satellite • March 19,1997
               2:30-4pm ET

-------
LUSTUne Bulletin 25
                     Washington State Takes a Hard Look at
                     The Last Lonely  Gas Station
                     by James M. Sims
       An effective petroleum supply
       and distribution system in
       rural America is essential to
the flow of commerce and emer-
gency services. This fuel distribution
network, which can be found any-
where in rural America, was not cre-
ated by design; it evolved as a simple
and practical, market-driven notion
that where there are people and fuel-
driven vehicles, somebody will open
a gas station. Ironically, however, lit-
tle thought had been given to the
importance of  these far-flung fuel
oases until their survival became
uncertain. Many of these marginally
profitable businesses face a host of
costs associated with technological
improvements  and financial assur-
ance to protect the environment and
image  requirements  to  remain
branded dealers.
     In 1991, the Washington State
Legislature took steps to ensure the
survival of the rural motor vehicle
fueling network in our state. The leg-
islature recognized that many of these
rural gas stations were not generating
the profit necessary to upgrade or
replace their underground storage
tank systems as required by federal
and state law. In response to this
problem, the Washington State Pollu-
tion  Liability   Insurance  Agency
(PLIA) was directed to establish the
UST Community Assistance  Pro-
gram. PLIA began processing appli-
cations for grants to upgrade  or
replace USTs at remote and rural gas
stations in January 1992.
      The grant eligibility criteria
 established by the legislature speci-
 fied  that the station be rural and
 remote, that the owner demonstrate
 serious financial hardship, and that
 the local government entity certify
 that the continued operation of the
 station was vital to the community
 for public safety, education, or health
 reasons. Rural and remote was even-
tually defined as a facil-
ity where no more than
one other retail source of
petroleum is located within
5 miles. Financial hardship    ™.
was evaluated through a thor-
ough review of the financial
records of the business by an inde-
pendent  small business  financial
analyst. Each grant was limited to
$150,000, of which no more than
$75,000 could be spent on remediat-
ing contamination.
     PLIA  awarded a total  of 112
grants throughout the state; 99 were
to small  businesses  and 13 to local
government entities. In the process
of evaluating the grant applications,
PLIA staff traveled to more than 350
communities in the state to look at
the sites,  take pictures, and verify the
locations and the fact that there were
no other facilities within 5 miles.
PLIA carefully reviewed the finan-
cial status of each grant applicant in
terms of revenue, taxes, debt service,
and past and projected sales.
     PLIA determined not just the
financial hardship but also the viabil-
ity of the business to remain in oper-
ation for a period of 15 years. After
investing a large sum of money to
improve the business, assurance was
needed that the business would sur-
vive. Because of the likelihood that
low volume service stations would
fail,  grants were not awarded to
businesses selling less than 120,000
gallons per year, roughly 10,000 gal-
lons per month.
      The Small Business Administra-
tion  experiences a failure  rate of
almost 30 percent within the first  5
years for businesses comparable to
those receiving PLIA grants. To date,
only three grant recipient businesses
have closed because of financial prob-
lems. Those of us at PLIA are confi-
dent that this low failure rate is the
direct result of our financial scrutiny.
The Cost of Doing
Business
UST owners and operators face a
number   of   potential   finance
demands: upgrading  or replacing
their UST systems to satisfy 1998
technical standards; installing Stage
II vapor recovery, if required; clean-
ing up contamination associated
with a petroleum leak or spill; carry-
ing pollution liability insurance or
having access to some other method
for satisfying financial responsibility;
and satisfying image requirements in
order to remain a "branded" dealer.
     The replacement or upgrade of
USTs to satisfy 1998 technical stan-
dards will typically cost (for a three-
to five-tank system) between $60,000
and $100,000, not including the
removal of old tanks and remedia-
tion of any existing contamination.
Installation of Stage II vapor recov-
ery, if required, will cost between
$15,000 and $45,000 per site.
     To illustrate the financial bur-
den associated  with UST system
upgrading or replacement, consider
the debt service on a 10-year, $80,000
loan—at 8-percent interest, the debt
service is $970 per month; at 9 per-
cent, the debt service is $1,013.14 per
month. Expressed in terms of vol-
ume of business needed just to sat-
isfy the debt service on such loans:
$970 requires a throughput of 8,083
gallons per month at a 12-cent profit
margin;   $1,013.14   requires    a
throughput of  8,442 gallons per
month at a 12-cent profit margin.
(The next section discusses the issue
of expressing debt service in terms of

-------
                                                                                            LUSTLine Bulletin 25
the number of gallons sold, a dra-
matic means of expressing the plight
of the small retailer.)
     In terms  of cleaning up any
contamination, the experience here
in Washington is that over 70 percent
of sites with USTs older than 16
years have some level of contamina-
tion that  will cost over $2,500  for
removal and/or remediation. Very
few sites actually involve a threat to
human health and the environment,
but most lenders and many regula-
tors  require removal and/or treat-
ment of contamination.
     Our  experience shows that for
over  80  contaminated  UST sites
included under the grant program,
the average cost of cleanup was only
about $20,000 per site. This low cost
is the direct result of firm cost control
measures, including preapproval of
all work  and close supervision of
field work. Without such controls,
we estimate that the average cost per
project would have been some 20 to
30 percent higher.
     Pollution liability insurance, or
another method of satisfying finan-
cial responsibility, is probably one of
the least of the financial concerns of
the UST owner or operator. There
was, of course, a time when pollu-
tion  liability insurance was neither
readily available nor affordable. In a
number of states, state cleanup funds
have filled this gap. Otherwise, pol-
lution liability insurance remains
expensive for UST systems that con-
stitute a  very  high risk—over  20
years old, no cathodic protection,
manual  inventory  system,  high
water table—while coverage on UST
systems that have been upgraded is,
for the most part, readily available
and affordable.
     Under our Washington pro-
gram,  premiums range from $500
per year for a  state-of-the-art UST
system with automated leak detec-
tion to $5,500 per year for a site with
up to five older USTs that have not
been upgraded and that rely on man-
ual inventory as the method of leak
detection.
     Environmental  requirements
aside, the  major oil companies have
prescribed image requirements that
dealers must satisfy to continue to fly
the  company  flag and have the
advantages of  being a branded
dealer. These requirements are nei-
ther  trivial nor optional.   Image
requirements can  entail painting,
new signs, a canopy, new dispensers,
card readers, and pumps for three or
perhaps four products. The cost of
satisfying these requirements can
range from $20,000 to $50,000. The
cost of  additional tanks, lines, and
dispensers will be even higher.
     The consequences of a  dealer
losing a brand are significant. We've
seen cases where sales have dropped
by at least 50 percent within 6 or 8
weeks of loosing a brand and becom-
ing independent. The inability to use
major oil credit cards contributes sig-
nificantly to the decline. Then,  of
course,  there is the motorist's uncer-
tainty  about the   product:  "How
much pinging will I hear, or how
much water will I have in my tank if
this is lousy gas"?
^ When considering the profitability of
     retail petroleum outlet, a clear
Sneasure of profit is volume (gallons
fir sold) per month. While most rural
» petroleum retailers have other profit
   sources, such as repair services,
   f/re anil battery sales, groceries,
   aiM/ video rentals, the volume of
jfe»jraso//Se and diesel sales is a
     definitive measure of profit.
                                I
Profitability/Viability
When considering the profitability of
a retail petroleum outlet, a clear mea-
sure of profit is volume (gallons
sold) per month. While most rural
petroleum retailers have other profit
sources, such as repair services, tire
and battery sales, groceries,  and
video rentals, the volume of gasoline
and diesel sales is a definitive mea-
sure of profit.
     Most retail petroleum dealers
calculate profit on the  basis of a
"pool margin," wherein, for  exam-
ple, the dealer makes only 3 cents
profit  on each gallon of regular
unleaded gasoline, but 11 cents on
super  unleaded, and  7  cents  on
diesel. The dealer  calculates the
number of gallons sold in each cate-
gory to determine the  margin of
profit for the entire pool of products
sold.
     In the metropolitan  areas  of
Seattle, Tacoma, Everett, Spokane,
and Tri Cities, the pool margin is usu-
ally 4- to 8-cents profit per gallon. In
rural areas of Washington, the pool
margin is more like 10- to 16-cents
profit per gallon.
     Reporting  in  the  April 1994
issue of National Petroleum News,
petroleum industry analyst Daniel
Johnston states that gasoline retailers
typically make between 3- and 6-cents
net profit per gallon. After looking
into the matter carefully, PLIA deter-
mined some regional trends, based on
throughput:

•  125,000 gallons per month - Cur-
   rently in the Northwest, major oil
   companies are attempting to cap-
   ture a larger portion of the retail
   market and are prepared to make
   considerable funds available for
   replacement of canopies, signs,
   dispensers, and  card readers  to
   large volume dealers if they will
   change brands. A major oil com-
   pany will usually make such an
   investment only if the dealer sells
   at least 125,000 gallons per month.

•  70,000 gallons per month - Some
   jobbers (distributors) make funds
   available to  their  dealers for
   upgrades, particularly if a major
   oil company establishes require-
   ments to satisfy  "image"  stan-
   dards. Most jobbers will not make
   these funds available unless the
   retail dealer sells 60,000 to 70,000
   gallons per month.

•  55,000 gallons per month - Daniel
   Johnston reports that "small ser-
   vice  stations"  pump  between
   55,000  and  75,000 gallons per
   month.

•  30,000  gallons per month -  A
   commonly   accepted  industry
   standard is  that a convenience
   store should sell at least 30,000
   gallons of gas per month to  be
   profitable. Daniel Johnston states
   that gasoline accounts for about
   one-third of  convenience  store
   sales, with the typical store pump-
   ing between 30,000 and 40,000 gal-
   lons per month.  Johnston notes
   that inside the store, the profit
   margin on products  other than
   petroleum is usually 30 percent of
   gross  sales.  Delis can  carry  a

               • continued on page 8

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LUSTUttf Bulletin 25
• Last Gas Station/rom page 7
  50 percent profit  margin, while
  soft drinks can yield a profit mar-
  gin of up to 70 percent.
• 12,000 gallons per month - PLIA
  examined the gasoline sales of 57
  rural gas stations and convenience
  stores that received grants under
  the  program. Ten of the busi-
  nesses had monthly throughputs
  of 30,000 gallons or more. The
  average monthly gas sales of the
  other 47 businesses was  11,800
  gallons. For this reason, PLIA con-
  cluded that a monthly throughput
  of 12,000 is the minimum level of
  sales required for  a rural gas sta-
  tion to be barely profitable.
• 9,000 gallons per month  - This
  monthly throughput is not really a
  measure of profit so much as a
  level of survival. Based on PLIA's
  experience and observations, a gas
  station or convenience store with
  no (or at least very little) debt ser-
  vice can barely survive wititi sales
  of 9,000 gallons per month...and
  this figure depends on whether or
  not the gas station has significant
  sales  of beer  or soda,  video
  rentals, mechanical worlv or other
  revenue.
     The sale of 9,000 gallons per
month results  in a  monthly gross
profit  from gas sales  of $720 to
$1,080, based on a profit of 8 to 12
cents per gallon. Based on Johnston's
estimated profit of 6 cents per gallon,
the monthly gross profit from gas
sales would be only  about $540. On
an  annual basis,  this throughput
level would result in  an annual gross
profit  of $8,640 to $12,960 at a profit
of 8 to 12 cents per gallon, or $6,480
at 6 cents per gallon.

The LiF  General Store in
LaCenter
In May 1994, Brian Chang, owner of
the Lil' General Store in the town of
LaCenter,  was awarded a grant to
replace his UST system under our
UST  Community Assistance Pro-
gram. The new system included
three  new stiPS® tanks, new dis-
pensers, and automatic tank gauging
system, and Stage n  vapor recovery.
The replacement and construction
portion of the grant amounted to
$87,600. Corrective action for conta-
minated soil discovered when the
old UST was removed would cost an
additional $57,000. Chang borrowed
money to install a canopy.
     From the time that Chang and
his family took over the business in
1989 to the time that the new grant
• A gas station or convenience store

r that pumps less than 12,000 gallons '
!?»<_ £,__   ,   ^.rrr__f__T_r_ _ „,.  _„  _ ,  J
L- per month is marginally profitable
s                               fe
i" and is probably in a very precarious
M   * „  *~  * ~ ~l ™ fr"l~ ~'r   "'J j ~* j
jb   financial state. It is not entirely
rrtiusTriess is already closed. The
f	'	I	I	>	If"	IP!!	I	"i	11	»	mil	IB
•jt'Towhersjust haven't reached that
            maslatignjs hot the ''[',
                     ™_,
was awarded, annual sales of gaso-
line increased from 220,00 to 350,000
gallons per year. After the new con-
struction, sales increased dramati-
cally: 820,000 gallons sold in 1995
and, during the  first 9  months of
1996, more  than 680,000 gallons.
     The business sells gasoline to
the local police and fire departments
as well as school buses. It also sells
groceries and rents videos.  The
Changs are active in the community,
and the store acts as an informal
information center for the commu-
nity and the surrounding area.
     Without the grant, the Lil' Gen-
eral Store might well have failed to
secure the financing needed to meet
environment standards and remain
viable as a branded dealer. The com-
munity would have lost an impor-
tant resource. The grant helped keep
the rural petroleum distribution net-
work in tact.

Will The Rural Network
Survive?
In  evaluating Washington's  rural
network, we learned that the notion
of the last lonely gas station with no
other service for 50 miles is exagger-
ated and, perhaps, mostly myth. In
the entire State of Washington, with
significant mountainous, rural, and
remote  areas, only 8 gas stations
were identified where there is no
other service within 15 miles.
    Likewise, when the Iowa UST
Financial Responsibility  Program
attempted to quantify the nature of
the potential impact of UST regula-
tions on rural petroleum marketers
by  reviewing the  proximity  of
smaller communities to retail outlets
throughottt the state, they discov-
ered only three communities with
populations of less than 1,000 that
might have been affected using the
criterion of driving up to 15 miles
one-way to obtain gasoline. As  it
turned out, two of those communi-
ties had access to facilities in Mis-
souri and the other has access within
a 20-mile radius.
     Barring state assistance to pre-
serve the rural petroleum distribu-
tion network, many businesses will
fail. A gas station or convenience
store  that  pumps less than 12,000
gallons per  month is  marginally
profitable and is probably in a very
precarious financial state. It is not
entirely facetious to conclude that
such a business is already  closed.
The owners just haven't reached that
conclusion. Chances are, however,
that station is not the last lonely gas
station.
     America's rural fuel network
will probably, for the  most part,
remain viable. As with any business,
however, the survival of the rural
gasoline retailer depends upon good
business and tank management prac-
tices. In states where the survival of
this rural network is crucial to the
state's economic fabric, providing
some kind public support in the
form of a low interest loan or grant
program that helps out the marginal
but responsible gasoline retailer can
make good political and fiscal sense.
     At the very least, state UST pro-
grams need to work with small busi-
ness administrations and lending
institutions to find ways to create
opportunities and remove barriers.
Finally, many of these small retailers
might well need some help in under-
standing the ways in which they can
comply with environmental laws in a
cost-effective manner. •

     James Sims is Director of the
  Washington State Pollution Liability
         Insurance Agency.
 8

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                                                                                        LUSTLine Bulletin 25
from Robert N. Renkes, Executive Vice President, Petroleum Equipment Institute (PEI)          '

It was originally my intent to write an article on the subject ofUST contractor availability. Prior to writing the article, I
attended a national convention where Becky Newberry of the Petroleum Services Division of Omega Environmental, Inc.,
Atlanta, Georgia, spoke on the same subject. Her presentation was so well received that I believe the reader will be better
served by reading a summary of her presentation.

              He or  She  Who  Hesitates  May Lose  Out When
                               That Deadline  Bell Tolls
A       number of people in the petroleum industry
       have started to wonder exactly how compli-
       ance with EPA requirements for underground
 storage tanks is going  to be accomplished by the
 December 1998 deadline. The rate of compliance work
 has certainly not been steady since the federal rule
 was published in 1988, and the backlog is increasing
 sharply as the deadline nears.
     Many industries are  lagging  behind in their
 efforts to meet the compliance deadline. Some gov-
 ernment agencies feel that they will be excluded from
 the mandates or that the  regulations will not be
 enforced in their case.  For nonretail tank owners,
 compliance work represents an unwanted mainte-
 nance cost that is not directly related to revenue.  It is
 also anticipated that many of the tank owners who
 plan to remove their tanks will wait until just before
 the deadline to do so, to keep revenue coming in as
 long as possible. Many had hoped for, and perhaps
 counted on an extension, but it is now clear that the
 1998 deadline is definite.
     It is generally assumed that as the  deadline
 draws closer, contractors and manufacturers will sim-
 ply "gear up" to accommodate the increased demand.
 After all, who can turn down work? There are several
 reasons why this may  not be a good assumption.
     The petroleum equipment manufacturers are
 limited as to the  quantity of tanks, automatic gauges,
 cathodic protection, and spill and overfill equipment
 they can produce, although it is likely that they can
 increase production somewhat. It is unrealistic, how-
 ever,  to expect that  they will add  the facilities,
 machinery, and personnel needed to meet the sharply
 increased demand that will occur if compliance work
 continues to be  postponed. It is also unrealistic to
 expect that they will manufacture the equipment and
 stockpile it in advance, tying up their operating dol-
 lars.
     The number of contractors and installers avail-
 able to perform this work is also restricted to those
 able to meet certain qualifications.  Contractors are
 expected to meet not only experience and quality
 requirements, but also special insurance or bonding
 capabilities, such as pollution liability insurance. Fur-
 thermore, a number of states now require contractor
 licensing or installer certification (or both) for tank
removal, installation, or upgrade work. There is also a
federal requirement for OSHA's 40-hour safety train-
ing for all employees performing work on existing
systems. Contractors and installers must also be
authorized by the equipment manufacturers to install
tanks or most types of equipment. None of these
requirements can be met quickly, cheaply, or easily
enough to allow new contractors and personnel to
enter the industry fast enough to meet the expected
sharp increase in work to be done.
     Even if all compliance work were scheduled
now and spread out evenly over the remaining time
before the deadline, there may not be enough quali-
fied manpower available to complete the work on
time.
     An estimated 1.1 million or more tanks are in
service at this time—roughly 30 percent independent
oil, 20 percent convenience store, 10 percent major oil,
12 percent government, 5 percent utilities, 3 percent
trucking, and 20 percent private other. It is estimated
that only 26 percent of these are in compliance with
1998 regulations, leaving approximately 850,000 tanks
to be upgraded, removed, or replaced. Of that
850,000, an estimated 25 percent, or 212,000, will be
removals, while 75 percent,  or  638,000, will be
upgrades or replacements.
  	• continued on page 10
       1,100,000 TANKS IN SERVICE
                                  • 20% OTHER
                              •5% UTILITIES
                             •3% TRUCKING
                          •12% GOVERNMENT
                      •10% MAJOR OIL
                  •20% CONVENIENCE STORE
        •30% INDEPENDENT OIL


-------
LUSTLiiie Bulletin 25
                 850,000
               TANKS TO BE
                UPGRADED,
               REMOVED OR
                REPLACED
3.1 AVG. TANKS
 PER LOCATION
                                      275,000
                                     PROJECTS
                                              CONTRACTOR
                                                BRANCHES
                      TWO WEEKS PER PROJECT
                                                           AVERAGE
                                                          4.5 CREWS
                                                            EACH
                 100 WEEKS
                   LEFT
                (90% productivity)
        550,000
       WEEKS OF
      (WORK TO DO
 | 4,500
 CREWS
AVAILABLE
                           CONTRACTOR AVAILABILITY
        Assuming an average of 3.1 tanks per location,
   approximately 275,000 projects will need to be com-
   pleted within the next 114 weeks. If the productivity
   rate is 85 percent (due to weather and other delays),
   and the average length of time per project is two
   •weeks, then 5,500 crews will be needed to perform the
   work.
        On the supply side, there are approximately
   1,000 PEI-member contractor branches who do com-
   pliance work.  (Author's note: PEI membership is
   widely considered by many in the industry to be the
   main body of  contractors who meet the necessary
   qualifications for compliance work.) If these contrac-
   tors employ between four and five crews each, which
   is a reasonable number, we end up with about 4,500
   crews available to perform the work. Not enough to
   meet the demand. None of these figures take into
   account the other UST and AST work, such as image
   upgrades and  new facilities, that will be  called for
   over the next 2 years.
        It should now be obvious that waiting any
   longer to comply with the rapidly approaching dead-
   line is not advisable. If the amount of work to be done
   exceeds the ability of qualified contractors and manu-
   facturers to perform it, the owners left out will suffer.
   Not meeting the deadline may result in fines or facil-
   ity closures. Equipment lead times will become longer
   and longer. As the deadline nears, prices will proba-
   bly go up, and the quality of contractors available will
   go down. The  top-quality contractors will have the
   luxury of selecting customers with long-term relation-

                       ships, large or multiple projects, good potential for
                       new  construction after the deadline, and enough
                       money to pay the higher prices.
                            If they are not already doing so, tank owners
                       should start planning now to avoid the crunch. Even
                       if the money can't be spent now, an owner can enter
                       into a lump sum, multiple site or unit price contract
                       now  to have the work done later or over a period of
                       time. Equipment can be ordered now, to be delivered
                       later, maybe with just a down payment. Financing
                       and lease packages are available to help owners buy
                       now  and pay later.
                            The planning process begins with having site
                       surveys performed and with having lists of equip-
                       ment, scopes of work, and budgets for each location.
                       Priorities need  to be set and decisions made  to
                       upgrade, remove, or replace equipment. The down-
                       time for upgrade work is also be a good time for
                       image upgrading, standardizing, centralizing,  or
                       automating equipment and tasks.
                            It is true that a job well planned is a job well
                       done. If they haven't already, tank  owners should
                       begin planning their compliance projects now. •
                        From the seminar, "Compliance ^98: UST Deadline, Con-
                         tractor Availability", NACS 96, by Becky Newberry,
                        Omega Environmental, Inc. For more information, con-
                         tact Becky 'Newberry at Omega Environmental, Inc.,
                                      1-800-39-OMEGA.
10

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                                                                                     LUSTLine Bulletin 25
 Anna Virbick is New
 OUST Acting Director

 Lisa Lund, Former Acting Direc-
 tor of the EPA Office of Under-
 ground Storage Tanks  (OUST)
 has moved to EPA's Office of
 Policy, Planning, and Evaluation
 as Deputy Assistant Adminis-
 trator for Project XL (Excellence
 in Leadership), an EPA initiative
 that seeks  to work with regu-
 lated entities to develop innova-
 tive approaches for addressing
 environmental issues. Lisa had
 been with the UST program for
 9 years, first with the Arizona
 program and then at EPA head-
 quarters. Good-bye and good
 luck Lisa.
     Joshua Baylson, Director of
 OUST's Policy and Standards
 Division,  served  as  Acting
 Director of OUST for 5 months
 following   Lisa's   departure.
 Now, as of January 6, Anna
 Virbick, will assume the post of
 OUST Acting Director.  Virbick
 served as EPA's Deputy Inspec-
 tor General for over 6 years and
 prior  to that served as EPA's
 Assistant Inspector General for
 Management. Josh Baylson will
 now return to his former posi-
 tion.
                                  New Guide on Free
                                  Product Recovery

                                  OUST has developed a guide to
                                  help UST regulators understand the
                                  portion of an UST corrective action
                                  plan that proposes free product
                                  recovery  technologies.  How  To
                                  Effectively Recover Free Product At
                                  Leaking Underground Storage  Tank
                                  Sites: A Guide For State Regulators
                                  (510-R-96-001) focuses on appropri-
                                  ate technology use, taking into con-
                                  sideration site-specific conditions.
                                      The  guide is designed  to
                                  answer three basic questions:
                                  • Is free product recovery neces-
                                   sary?
                                  • Has an appropriate method been
                                   proposed for free product recov-
                                   ery?
                                  • Does the free product recovery
                                   plan provide a technically sound
                                   approach to remediating the site?
                                      OUST has distributed copies
                                  of the guide to its regional offices
                                  and to states and their regional
                                  offices in order to reach every state
                                  regulator who reviews corrective
                                  action plans. Consultants, engi-
                                  neers, lenders, public health profes-
                                  sionals, environmental education
                                  centers, and others involved in the
                                  cleanup or remediation of a leaking
                                  UST site may also be interested in
                                  this guide.
                                      The  guide is  available  for
                                  $17.00 from the U.S. Government
Printing Office, Superintendent of
Documents, P.O. Box 371953, Pitts-
burgh, PA 15250-7954. Order stock
#055-000-00553-2.
                      New
                      Leaflet
                      on Tank
                      Closure

                      OUST
                      has pre-
pared a leaflet, Closing Underground
Storage Tanks: Brief Facts (EPA-510-
B-96-004), which highlights closure
as a compliance option for meeting
the 1998 deadline  and provides
basic  information on closing  an
UST properly. OUST encourages
states  or others who wish to get the
word  out on proper tank closure to
adapt this leaflet to meet their spe-
cific needs.
    You can use the Internet to
download a copy  of the leaflet
(WordPerfect 6.1). To reach OUST's
World Wide Web Home Page, go to
http://www.epa.gov/OUST. The
leaflet is also available on EPA's
electronic bulletin board, CLU-IN,
in Directory 4 (EPA/OUST Publica-
tions)  as the file called "CLO.EXE."
The leaflet is also available on a
computer  disk,  as reproducible
originals, and as printed  copies.
Contact Jay Evans at (703) 603-7149
for assistance.
    Enforcement
                        EPA Issues First-In-The-Natioii UST Program
Complaints Against The Navy For Violations At Two B.C. Facilities
       On September 30, EPA Region 3 issued first-in-the-nation UST program complaints against the U.S. Navy for
       violations of federal underground storage tank regulations under RCRA Section 9006 at two sites: the Wash-
       ington Navy Yard and the Anacostia Naval Station in Washington, D.C. The Navy is the owner of many
USTs at these facilities, which are used to store regulated substances, such as petroleum.
    "Environmental laws apply to government facilities, as well as private companies," said EPA Regional Admin-
istrator W. Michael McCabe. "EPA will bring appropriate enforcement actions to ensure that both public: and private
parties obey the law."       '
    According to the EPA's complaints, the Navy failed to comply with UST release detection, notification, and
recordkeeping requirements for several underground tanks at the two sites. In accompanying compliance orders,
EPA directs the Navy to correct the violations and submit a report to EPA which certifies whether or not the require-
ments have been met. The Navy is entitled to a hearing to contest the alleged violations. Region 3 coordinated this
action with the District of Columbia Environmental Regulation Administration. •

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LUSTLine Bulletin 25
                           nicaity Speaking
                              by Marcel Moreau
  In this edition of "Tanknically Speak-
  ing," David McCaskill, who writes
  our "Tanks Down East" column,
  and Marcd Moreau, who regularly
  writes this column, have collaborated
  to discuss some of the problems asso-
  ciated with cathodic protection test-
  ing. It behooves anyone who has not
  read "Rust Though Art And To Rust
  Thou Shalt Return" in LUSTLine
  Bulletin #23 to do so before reading
  this article. Some background on
  cathodic protection will make this
  reading mare meaningful. Marcel
  Moreau is a nationally recognized
  petroleum storage specialist. David
  McCaskill is a petroleum storage spe-
  cialist with the Maine Department of
  Environmental Protection.
Is This Tank

Cathodically Protected?

by David McCaskill

 W Melbert has had cathodically protected (CP) tanks at his station for 8 years and has
 If yet to have them tested to see if they are, indeed, cathodically protected. Federal
 Jr  tew requires that galvanic corrosion-protected systems like Delbert's be monitored
within 6 months of installation and every 3 years thereafter. Nozv that the environmen-
tal regulatory agency has sent him a letter stating this fact and reminding him that he is
in violation of the environmental regulations if his CP tanks haven't been tested, Delbert
looks up the name of the guy his installer gave him 8 years ago. Delbert has had enough
experience with the flatlanders from the capital to know that this letter is a harbinger of
inspectors  to come. He also knows that when his tanks were installed, his contractor
gave him the low down on how his tanks were protected from corrosion holes. Delbert
can see the loisdom of getting a CP tester over to see if everything really checks out.
     Ctiarlie, the CP tester, arrives with all the proper paperwork needed to document this
blessed event. He brings out his  magical meter and hooks one wire to what Delbert knows
is his CP test station (a wire connected to the tank) and another wire from the meter to
some sort of a probe. He pours water on the soil over the tank ends. He mashes the probe
into the ground and peers deep  into his meter as if to summon the CP spirit of the tank.
     But Charlie's characteristic cherubic smile is soon replaced with a look of bedev-
iled puzzlement. He mashes the probe into other parts of the soil above the tank, as if
doiosingfor water. He borroios Delbert's dipstick, fastens a bolt with a wire attached to
the bottom end, and lowers the apparatus down thefillpipe. He connects the wire from
the dipstick to the voltmeter and peers at the meter again. Still not satisfied with the
readings he's getting on his meter, he unhooks the lead to the test station and starts
touching the vent pipe and some exposed electrical conduit as if to summon their opin-
ion on ttie situation. But Charlie has performed CP tests often enough to know that he
will have to tell Delbert what he surely doesn't want to hear, that his tank is not pro-
tected against corrosion.
                                                                           Since  1986,  Maine's  rules  have
                                                                           required that CP tests be made every
                                                                           year, rather than every three years,
                                                                           as  required in the  federal rules,
                                                                           either by a certified installer who has
                                                                           been trained by the Maine Depart-
                                                                           ment of Environmental Protection or
                                                                           by a cathodic protection tester. Two
                                                                           years ago our office sent out notices
                                                                           to  owners of CP tanks to  remind
                                                                           them about our annual CP testing
                                                                           requirements. We included sample
                                                                           CP recordkeeping logs in the mail-
                                                                           ing. We also sent these notices to our
                                                                           certified tank installers who would
                                                                           be getting the calls to do the work.
                                                                           Once these letters went out, many of
                                                                           the CP installation sins of the past
                                                                           came to light.
                                                                                The  galvanic CP steel  tank
                                                                           design relies heavily on isolating the
                                                                           tank from other metallic structures,
                                                                           such as steel piping or electrical con-
                                                                           duit which may overwork the  CP
                                                                           system. Remember, the CP system
                                                                           was designed to protect only the
                                                                           defects in the tank coating. Isolation
                                                                           is accomplished by providing dielec-
12

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                                                                                          LUSTLine Bulletin 25
trie  bushings  (usually  made  of
nylon) at the tank openings. Failure
to achieve isolation is the first issue
that must be investigated when the
CP readings don't meet the specs.
     The CP tester in the illustration
on page 12 is coming up with a read-
ing of -0.75 volt, which is below the
acceptable  -0.85-volt level but still
well above the naturally occurring
reading of a bare steel tank (-0.4 to
-0.6 volt). A voltage reading in this
range  is a  positive  sign that  the
cathodic protection system is operat-
ing but trying unsuccessfully to pro-
tect more than just the tank.
     In the past,  when  a tank
installer would call me with ques-
tions about a low CP reading, his (or
her) first assumption was that  the
factory anodes had given out and
that it was time to slap on a couple of
17 pound magnesium anodes and be
done with it. I'd have to tell him that
the answer was not necessarily that
simple. He'd need to troubleshoot
the system to be sure that the tank
was, in fact, isolated from all other
buried metals. (See Marcel's "How
To..." section to find out how this is
done.) If the tank is not isolated, then
adding anodes will only defer  the
problem to another not-too-distant
time.

Isolating the Problem
We had a rash of reports of low read-
ings soon after our compliance let-
ters went out. It seems that several of
our CP testers were running across
double-walled CP steel tanks with
readings in the -0.6 to -0.7-volt range.
The case  was  cracked  when one
installer figured out that the leak
detection system used to  test  the
interstitial space (the area between
the two tank walls) was actually the
source of the problem.
     Most double-walled steel tanks
have an attached 1.5-inch steel moni-
toring pipe  that runs from  the bot-
tom of the interstitial space to  the
surface of the ground. Leak detection
probes are placed in the bottom of
the pipe where they can detect any
leaks. A type of leak detection sys-
tem popular in Maine uses a probe
that senses changes in pressure
resulting from changes in the level of
the liquid in the bottom of the tube.
These pressure changes are commu-
nicated to the  alarm box by copper
tubing that runs from the bottom of
the monitoring pipe, up through the
top of .the monitoring  pipe,  then
underground to the building where
the alarm box is located. The copper
tubing exits out of the monitoring
pipe through an isolating fitting, but
if it touches the inside of the moni-
toring pipe, the copper tubing and
everything  the  tubing   touches
becomes, inadvertently, part of the
tank's cathodic protection system.
    When everything is electrically
connected in this way, the anodes on
the tank are trying valiantly to pro-
tect not only the  tank but also the
buried copper tubing and any other
buried metal structures—plumbing,
rebar  in the concrete foundation,
buried electrical conduit (you get the
picture)—caught up in this vast elec-
trical  web. This problem is easily
fixed by sleeving the copper tubing
in small diameter PVC pipe  so it
doesn't touch the sidewalls of the
monitoring pipe.  Once this  was
done,  our CP testers found that their
readings quickly  came up to spec.
Needless to say, after that discovery I
was a hero many times over. I simply
disseminated my acquired wisdom
when the subject of low readings on
double-walled  steel  tanks   was
brought up, saving the contractor the
agony of further troubleshooting.
    Of course, lack of isolation is
not the only possible cause of low
readings, but it is the most common
one. Very dry soils and spent anodes
are also possible causes.

More is Not Better
Several years ago, a large heating oil
jobber in our state tested the CP
tanks  of an industrial client. At this
site, the jobber was getting readings
that were  too  high.  Now, where
cathodic protection  is  concerned,
more  is not always better; the read-
ings this tester was getting on these
tanks were in the -2.0+ range and
fluctuating. But such readings are no
mystery to a corrosion expert when
he knows that the industrial client is
in the business of welding together
steel beams.
    When a piece of metal is electri-
cally welded,  a current must  pass
from a grounded welding machine,
through the welding rod, to the
metal, which is also grounded so the
current can flow back through the
earth, thus completing the circuit.
But some of the current sometimes
goes  astray  through the  ground,
striking other objects, like buried
tanks. So the high readings that our
CP tester encountered here were not
from the tank's anodes but from the
welding machine.
     According to a corrosion engi-
neer,  the fix to this particular prob-
lem is to install a plastic vertical liner
between the welding machine sys-
tem and the tank to block the stray
currents from affecting the tank. Of
course,  a better solution is to not
install a CP tank in this kind of envi-
ronment in the first place—a fiber-
glass, composite, or jacketed-steel
tank is more appropriate. According
to the installer, the client was given
the fiberglass tank option; however,
the low price of the CP tank and the
client's affinity for things made of
steel won the day. So, before buying
a CP tank, check for possible sources
of stray currents. If it's too late, then
call a corrosion expert. (Contact
NACE at (281) 492-0535 ext. 214 for a
list of qualified corrosion profession-
als in your area.)
    Other sources of stray currents
include electric bus or subway sys-
tems,  communication towers,  or
even  adjacent  impressed  current
cathodic protection systems protect-
ing buried gas mains or other USTs.

Disappearing Anodes
During  the  first season  of   our
cathodic protection compliance cam-
paign, a coastal sewer district had the
CP tested on an emergency generator
tank at one of its coastal lift stations
in close proximity to a salt marsh.
The reading came  in around -1.1
volts  that year,  but  the  next year,
when the sewer district attempted to
start the generator  up for  its  own
annual testing, it got a good dose of
salty  groundwater  rather  than its
normal diet of diesel fuel. The  tank
was removed, and a couple of good-
sized  holes were  found near the bot-
tom. There was no sign of the anodes.
    Several things could have gone
awry  here. First, the CP tank had
been installed,in a very aggressive,
environment. The groundwater in
this area was affected by the ocean; it
had a high salt content and would
fluctuate with the tide. This made the
electrolyte of our corrosion cell very
conductive, meaning that the CP sys-
tem would work very effectively but
             • continued on page 14
                                                                                                      13

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LUSTUne Bulletin 25
• TANK-nlcally from page 13	
also that the anodes would be used
up  faster. Again, a corrosion-pro-
tected fiberglass, composite, or jack-
eted-steel tank would have been a
more corrosion-resistant solution in
this location. Second, it is possible
that the anode used in  this early
design was magnesium, which is not
suited for saltwater environments.
For this  reason, zinc anodes are used
on ship bottoms to fight the effects of
saltwater corrosion.
    There is still  the disturbing
question of why the  tank had a pass-
ing reading one year and holes the
next. There was no  evidence of the
anodes  during the  excavation, but
then again, we're not talking about
an archeological dig here either, so
who knows if anything was left of
them  or not. I say  "disturbing"
because this  means that a)  the
anodes  were not  protecting  the
whole tank, b) the anodes  quit work-
Ing and  the holes were formed in less
than a year, or c) the CP readings
from the prior year were incorrect.
Based on the contractor's prior expe-
rience  in  CP  troubleshooting,  I
believe  the initial  readings were
• Most cathodically protected USTs are
-   sold as pre-engineered packages,
 based on the assumption that one size
t   fits all. These systems have been
I around since 1969, but until ahpujtjip ~;
" years ago, they were not installed in
• very large numbers. As this population
;•	of tanl^ajie^jt^ become^	[	^_
I increasingly important to monitor the
    effectiveness of their corrosion
-*  protection to avoid repeating the
-    corrosion problems of the past.

indeed correct. I might also add that
the tank in this story was not a sti-
P3® tank, which is the industry stan-
dard for pre-engineered cathodically
protected tanks.

Time And Testing Will Tell
As you can see from my smattering
of stories, there  are  a lot things to
consider when installing and testing
cathodically protected UST systems.
There are some sites in this state
where installers have completed all
Testing  Cathodic Protection  Systems


by Marcel Moreau

       As David pointed out in the first part of
       this articlet testing of cathodically pro-
       tected structures is not always straight-
forward and does not always have  the desired
outcome. I had similar experiences this fall while
teaching corrosion/cathodic protection courses across the
country. It is clear to me that testing cathodically protected structures is rarely a
"cookbook" type of procedure. A clear understanding ofcathodic protection principles
is a prerequisite for the correct execution of the monitoring procedure and reasonable
interpretation of the monitoring results.
                         Having said that, I hereby offer my recipe for monitor-
                      ing the status of a cathodically protected UST system. Jdy
                        goal is not to turn any casual reader into a cathodic pro-
                          tection tester but to provide some guidance for those
                          TW/IO need a refresher. An understanding of how the
                          monitoring procedure should be carried out may also
                           help regulators and storage system owners under-
                          stand what's what when they are reviewing cathodic
                          protection monitoring reports.
                             As always, comments on how this recipe can be
                         improved are welcome.
troubleshooting and still can't get
good readings on tanks less than 10-
years old in relatively noncorrosive
backfill. Jacketed tanks with a steel
inner shells and polyeythelene  or
fiberglass outer shells that provide
corrosion protection  for the inner
steel tank have become popular in
Maine at  the expense of CP steel.
     Cathodic protection has had a
long and successful track record in
the protection of such steel structures
as  ship  bottoms,  cross-country
buried pipelines, buried and sub-
merged bridge supports, and oil ter-
minal tank bottoms. Most of these
CP systems have site-specific designs
and are for the most part tested and
maintained by corrosion technicians.
     Most cathodically  protected
USTs are sold  as  pre-engineered
packages, based on the assumption
that one size fits all. These systems
have been around since 1969, but
until about 10 years ago, they were
not installed in very large numbers.
As this population of tanks ages, it
will become increasingly important to
monitor the effectiveness of their cor-
rosion protection to avoid repeating
the corrosion problems of the past. •

 Testing Galvanic
 Cathodic  Protection
 Systems

 Equipment Needed:
 • A voltmeter with at least  10
   megohm  (million ohms) input
   impedance. Most voltmeters with
   a digital display will meet this
   requirement. Although a model
   from a consumer electronics store
   will give accurate readings, a
   voltmeter specifically intended
   for cathodic protection monitor-
   ing will likely be more durable in
   the field environment.

 • A copper/copper  sulfate refer-
   ence electrode (also known as a
   "half-cell" or "reference  cell").
   Typical reference electrodes are
   about  1 inch in diameter and 6
   inches in length. They may have
   either  a flat or a  cone-shaped,
   porous ceramic tip at one end that
   is covered with a plastic cap. The
   cap  must be  removed  when
   cathodic  protection  measure-
   ments  are  conducted,  but  it
14

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                                                                                             LUSTLine Bulletin 25
   snould be kept in place on the ref-
   erence electrode whenever it is not
   in use to minimize evaporation of
   the copper sulfate solution inside
   the electrode.

   Maintain the reference electrode
   as follows:
   -  Keep the reference electrode
     about 3/4 full with distilled
     water.
   -  Be sure that undissolved cop-
     per sulfate crystals are always
     visible inside the reference elec-
     trode.
   -  Discard the solution inside the
     reference cell when it becomes
     cloudy. Refill the reference cell
     with  copper  sulfate  crystals
     and distilled water. Clean the
     copper rod with  nonmetallic
     sandpaper.
   -  Keep the  reference cell away
     from freezing temperatures so
     that the copper sulfate solution
     does not freeze, or use the cop-
     per sulfate anti-freeze solution
     provided by the half cell manu-
     facturer.

• Two  test  leads (plastic coated
   wires with fittings on the end) that
   plug into the voltmeter and can be
   clipped onto the reference cell and
   the structure  being monitored.
   Test leads can be any length; how-
   ever, 2- to 3-foot lengths are typi-
   cal. It is also a good idea  to have a
   20-  to  30-foot  length  of wire
   handy, in addition to the two test
   leads for field work.

• A standardized form that can be
   used to record pertinent informa-
   tion concerning the facility, sketch
   the facility, note voltage readings,
   and indicate the locations where
   voltage measurements were made.

Testing Procedure:

1 Determine how you will obtain an
   electrical  connection with  the
   structure that is to be monitored.
   If you are monitoring an sti-P3®
   tank, there may be a monitoring
   wire (usually green in color) com-
   ing up  out  of the  ground and
   attached to the submersible pump
   riser, the automatic  tank gauge
   riser, or the fill pipe riser ("riser"
   is a generic term for a vertical pipe
   attached to the top of an under-
I-   The purpose of monitoring is to
IL,   ensure that the entire tank is
fcp. :•. protected. This means that the
|" portion of the tank farthest away   ]
I; from the anodes must still meet the
fs-                                3
!__  criteria for protection. It is good   ;
jt_ practice to take voltage readings
P* with the reference electrode in as
t-   many locations as practicable.
—                  *     •"         *

  ground tank), or located in a spe-
  cial cathodic protection test sta-
  tion. If no wire can be found, see
  the "What If...?" section that fol-
  lows.

^Determine where you will place
  the reference cell. The reference
  cell must be in contact with clean,
  moist  soil, not with  concrete  or
  asphalt. See the "What If...?" sec-
  tion that follows if no clean soil is
  accessible. The ideal location is
  along the top middle of the tank.
  On many  tanks installed  after
  1990 or so, this is where the auto-
  matic tank gauge riser is located
  and where soil is usually accessi-
  ble. Other possible locations are
  around the submersible pump or,
  if a spill containment manhole has
  not yet been installed, around the
  fill pipe.

  The purpose of monitoring is  to
  ensure that the entire tank is  pro-
  tected. This means that the portion
  of the tank farthest away  from the
  anodes must still meet the criteria
  for protection. Sti-P3® tanks  of
  10,000  gallons   and  less  have
  anodes located on the ends; this
  means that the reference electrode
  should be placed at the top middle
  of the tank. Readings taken with
  the reference electrode placed  near
  the ends of the tank will be higher.
  If there is no access to soil over the
  top of the tank, see the "What
  if...?" section that follows.

  It is good practice to take voltage
  readings with the reference elec-
  trode in as many locations as prac-
  ticable. I have seen tanks where
  one end of the tank registered 0.95
  volts, the middle registered  0.88
  volts, and the other end registered
  0.83 volts. This  situation  could
 result from an actual deficiency hi
 the cathodic protection caused by
 significant coating damage at one
 end  of  the tank  or  failure  to
 unwrap the anode at one end of
 the tank. This deficiency could not
 have been discovered if only a sin-
 gle reading had been made at the
 middle of the tank. Note,  how-
 ever, that this situation could also
 result from petroleum contamina-
 tion in the soil where the reference
 cell is placed (e.g., around the fill
 pipe) or from something that acts
 to shield the reference cell from
 the  tank (e.g., a metal culvert
 around the submersible pump).

 Unless the soil where you intend
 to place the reference electrode is
 quite wet, you will need to add
 moisture. Pour a quart to a gallon
 of water on the location where the
 electrode is to be placed and allow
 the water to be absorbed into the
 soil  before taking the  reading.

 Turn on the voltmeter  and watch
 the display to be sure that it is
 behaving normally. Consult the
 meter's instructions if you don't
 know what it is supposed to read
 when you first turn it on. If your
 instrument has  multiple func-
 tions, be sure that it is set to make
 low  voltage DC measurements
 and that the test leads are plugged
 into the correct sockets.  Connect
 the positive lead of the voltmeter
 to the wire from the structure to
 be monitored  and the negative
 lead from the voltmeter to the ter-
 minal at the top of the reference
 electrode. Do not touch any metal
 portions of the test leads when
 making a reading.

 The  display on the meter should
be steady. Fluctuations of 0.01 volt
 are okay, but fluctuations greater
 than this may indicate  a bad con-
 nection. There  should be a nega-
 tive  sign in front of the  reading,
 and  the reading should  be more
negative (greater) than -0.85 volts
 (which is the same as -850 milli-
 volts). Don't let the negative sign
 confuse you (-0.90 volts is greater
 than -0.85 volts [this is what you
want]; -0.80 volts is less than -0.85
volts [this  is  what you don't

            • continued on page 16
                                                                                                         15

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LUSTLine Bulletin 25

1 READING
Greater than -1 .65 volts for a
structure with magnesium
anodes
Greater than -1 .1 volts for a
structure with zinc anodes
Greater than -0.88 volt
-0.85 volt to -0.88 volt ;
Less than -0.85 volt
-0.4 volt to -0.6 volt
-0.3 volt to -0.4 volt '
-0.1 volt to 0.0 volt
Variable readings
Wildly fluctuating readings
(digital meter)

WHAT READING INDICATES
The maximum voltage output from a magnesium anode is -1.65 volts. If your reading is
greater than this, the system could have impressed current cathodic protection rather
than galvanic, or thqre could be stray currents in the vicinity. If it turns out this is NOT an
impressed current system, have a corrosion engineer investigate as soon as possible.
The maximum voltage output from a zinc anode is -1 .1 volts. If your reading is greater
than this, the system could have impressed current cathodic protection rather than gal-
vanic, or there could be stray currents in the vicinity. If it turns out this is NOT an
impressed current system, have a corrosion engineer investigate as soon as possible.
Structure is adequately protected.
Structure still meets the standard for corrosion protection, but there is not much of a
safety cushion. Monitor the system closely to determine the rate at which the voltage is
dropping and plan on adding anodes or performing other work on the system in the not
too distant future.
The structure does not meet the -0.85-voit standard for corrosion protection and is out of
compliance with regulatory requirements. This does not mean, however, that the tank is
leaking. (See "What if the tank or piping does not meet the -0.85 criterion?" in the follow-
ing section.)
Expect this voltage range from steel that has no cathodic protection. This could indicate
that the tank was not cathodically protected originally, or that the anodes are completely
shot. Call in a corrosion engineer to investigate.
Rusty steel will sometimes register down in this range. Call in a corrosion engineer to
investigate.
This type of reading is most likely to occur if you are measuring the potential of a piece of
copper. Most likely the copper wire you are connected to is broken off underground. Find
another way to get an electrical connection to the structure you want to monitor.
This could indicate stray currents, but check your meter to be sure that it is operating
properly and that all test lead connections are in solid contact with shiny metal.
This probably indicates that one of your test lead connections is not good or that your ref-
erence cell is dry. Make sure that all your connections are solid metal to metal. Might also
be indicative of extremely dry conditions in the backfill. Run water from a garden hose
into the tank backfill for a couple of hours and take another reading.
 • TANK-nically from page 15	

  want]).  The table on page  16
  "Interpreting What Your Volt-
  meter Is Telling You" should help
  you interpret your readings.

ONo job is done until the paper-
  work is completed.  While you
  should  document the cathodic
  protection monitoring with the
  usual site information (e.g., facil-
  ity name,, address), you should
  also make a quick sketch of the
  layout of the facility and indicate
  the reference electrode location(s)
  and the corresponding voltage
  readings. Duplicating the refer-
  ence cell locations over time is key
  to obtaining meaningful cathodic
  protection data.

What If...?

What if there is no monitoring
wire for the tank?
You need an electrical contact with
the tank.  If the tank is an sti-P3®
tank, all of the risers attached to the
top of the tank are electrically iso-
lated from the tank shell and cannot
be used to obtain readings of the
tank itself. To obtain a reading in this
situation, make contact with the bot-
tom of the tank through the fill pipe.
    A "quick and dirty" way to do
this is to fasten a length of wire (20-
feet long or so) to a brass bolt and
then fasten the bolt with a stainless
steel hose clamp to the end of a dip-
stick so that the head of the bolt
extends slightly beyond  the end of
16

-------
                                                                                           LUSTLine Bulletin 25
ike stick. Clip fKe end of the wire
that is not attached to the bolt to the
positive test lead from the voltmeter.
    Insert the bolt end of the stick
into the fill pipe and press firmly
against the bottom of the tank. There
may be sludge and scale on the tank
bottom which will require firm pres-
sure and a little twisting motion on
the stick to obtain good electrical
contact. Good contact is indicated by
a steady reading on  the digital dis-
play of the voltmeter.
    Be aware, some drop tubes are
equipped with tank bottom protec-
tors to  prevent  any damage  that
might occur when the  dipstick
repeatedly strikes the bottom of the
tank. The tank bottom protector con-
sists  of a metallic plate that  is
attached to the bottom of the drop
tube. A neoprene disc separates the
bottom protector and the bottom of
the tank,  electrically isolating the
tank bottom from the  tank bottom
protector.
    Because the tank bottom protec-
tor is connected to the drop tube and
the drop tube is connected to the fill
pipe,  the voltage reading obtained
through the fill pipe will reflect the
voltage of the fill pipe relative to the
reference electrode, rather  than the
tank  voltage.  So if the  dipstick
method results in a reading in the
unprotected range (0.4 to 0.6 volts)
take a reading on the fill pipe. If the
fill pipe reading and  the  dipstick
reading are identical and a drop tube
is present, remove the drop tube and
check for a tank bottom protector
before concluding that the tank is not
adequately protected.
    In  some cases, if the tank is
equipped with a manway at the bot-
tom of a containment sump, it may
be possible to contact the tank shell
directly. Look carefully around the
manway to determine how electrical
isolation is being accomplished and
whether any metal connected to the
tank shell, or the tank shell itself, is
accessible.

What if tank is equipped with
a PP4 monitoring station?
If the tank is an sti-P3® tank installed
around 1993 or later, it may have a
test station consisting of a plastic
dome about 3 inches in diameter
with five metal terminals imbedded
in it that are flush with the surface of
the dome. The central terminal con-
nects to a permanently buried refer-
ence  cell (you don't  need your
copper/copper  sulfate reference
electrode to test this tank), and the
four terminals around the center
connect to one or more tanks. Simply
.connect the negative voltmeter lead
to the center terminal and the other
lead to each of the other terminals on
the  test station. You  should  get
appropriate readings on as many ter-
minals as there are tanks buried at
the facility.


What  if I need to monitor
piping?
Cathodically protected piping is
rarely equipped with  monitoring
wires to facilitate cathodic protection
monitoring, but this is not a serious
omission in most cases. Usually, the
piping will be accessible at both the
top of the tank and beneath the dis-
penser. There is typically also soil
exposed at these locations for placing
the reference electrode. If the anodes
have been installed as suggested in
the Petroleum Equipment Institute's
"Recommended Practices for Instal-
lation of Underground Liquid Stor-
age Systems" (PEI RP100), the ends
of the piping will be the points in the
system the furthest away from the
anodes and are good places to locate
the reference electrode. Be sure that
the point of contact between the pip-
ing and the voltmeter  test lead is
clean shiny  metal to ensure a good
reading.


What if there is no  soil along
the  tank top in which to place
the reference electrode?
It is possible to get voltage readings
by placing the reference electrode on
damp concrete or asphalt, but these
readings are generally  not consid-
ered to be accurate or reliable. In my
experience, readings taken with the
reference electrode on concrete will
always yield a reading in the range
of -1 volt, regardless of whether the
tank is cathodically protected. Read-
ings through asphalt are unreliable
because the voltage is determined by
the location of cracks in the asphalt
and not the  actual placement of the
reference cell.  The reference elec-
trode can be placed some distance
away at the nearest available soil, but
again, this is not the most accurate
measure of the corrosion protection
status of the tank. In my view, the
solution is to drill a hole through the
concrete or  asphalt to  allow direct
contact  between the reference cell
and the soil in close proximity to the
tank top.


What if the soil is "dry'"?
I often hear that storage systems fail
to meet cathodic protection criteria
because the tank environment is too
dry. While this may occasionally be
true in parts of the desert southwest,
it is not a likely occurrence in most
other parts of the  United States. If
excessively dry conditions are sus-
pected, run a garden hose to the tank
top and pour a large amount of
water into the tank backfill.


What if the soil where I need
to place my reference electrode
is contaminated with
petroleum?
Don't take a reading in soil that is sat-
urated with petroleum. Petroleum is
not an electrolyte; the reference elec-
trode must contact an electrolyte (e.g.,
water) for the peading to be accurate.
A slight petroleum odor is acceptable
for cathodic monitoring purposes, but
soil saturated with petroleum will
seriously affect readings.

What if the soil is frozen?
Traditional  wisdom indicates that
cathodic protection monitoring can-
not be  conducted  in  frozen soils
because ice  is not an electrolyte.
Experience in Maine indicates, how-
ever, that monitoring can be success-
fully  conducted in frozen  soils if
water is used to dampen the soil
where the  reference  electrode  is
placed.

What if the tank or piping
does not meet the -0.85
criterion?
The most common reason for failure
to meet the -0.85 criterion for gal-
vanic cathodic protection is failure to
electrically isolate the cathodically-
protected  structure   from   other
buried metallic or electrical compo-
nents. The best method for identify-
              • continued on page 18
                                                                                                        17

-------
 LUSTLine Bulletin 25
 • TANK-nically from page 17
 ing such components is to measure
 the voltage of all accessible metal
 (e.g., piping, electrical conduit, util-
 ity piping, leak detection probes).
 This is done by measuring the tank
 voltage  as described in steps 1
 through 5 above and then connecting
 the negative lead of the voltmeter to
 all accessible metallic structures with-
 out moving the reference cell. (This is
 where that 20- to 30-foot length of
 wire from the "equipment needed"
 section comes in handy.) A reading
 of within a few millivolts of the tank
 reading indicates that the two struc-
 tures are electrically connected. The
 exact place where the two structures
 are in contact must be located and
 the  connection  broken  for  the
 cathodic protection to work.
     Inadequately   isolated  tank-
 anchoring hardware, although a
 likely source of electrical isolation
 problems, usually cannot be evalu-
 ated using this technique, because
 the voltmeter connection cannot be
 made unless the top of the tank is
 excavated.
    Another possible reason for fail-
 ure to achieve -0.85 volt is exces-
 sively dry soil. Refer to the "What if
 the soil is dry?" section above.
    If the tank is  isolated and the
 backfill is damp, but -0.85-volt read-
 ing  still  cannot  be  measured,
 research the installation procedures
 to see if you can discover any clues.
 Then call the Steel Tank Institute, the
 tank manufacturer, or a corrosion
 engineer for help.
Testing Impressed
Current Cathodic
Protection Systems

Equipment Needed:
The equipment list for monitoring
impressed current cathodic protec-
tion systems is the same  as for gal-
vanic systems.

Testing Procedure:
 I Making an electrical connection to
   a structure with impressed cur-
   rent cathodic protection is  rela-
   tively  easy;   none   of   the
   components should be electrically
   isolated from one another. The fill
   pipe or any other accessible tank
   riser is usually a good place to
   make a connection to the tank.

   One case where this may not be
   true is when  impressed current
   cathodic  protection has  been
   added to a sti-P3® tank. In this
   case,  use  the  continuity test
   described under the  galvanic
   cathodic   protection   question
   "What if the tank or piping does
   not meet the -0.85-volt criterion?"
   to check to be sure that all metallic
   components of the system are con-
   tinuous. Use the dipstick method
   described under the  question
   "What if there is no monitoring
   wire for the tank?" to check the
   voltage of the tank shell.


2 The guidelines for placement of
   the reference cell are basically the
   same as for galvanic systems. The
   reference cell  should be close to
   the structure being monitored and
   as far away from the anode loca-
   tions as possible. Anode locations
   can often be inferred from saw
   cuts and small areas of patched
   asphalt or concrete. Anode loca-
   tions should also be indicated on
   the  cathodic  protection design
   documents.


3 The soil where the reference elec-
   trode is placed should be wet as
   for galvanic systems.


T"Test lead connections and volt-
   meter settings are also the same
   for impressed current systems as
   for galvanic systems.


OThe 0.85-volt criterion most com-
  monly  utilized   for   galvanic
   cathodic protection systems can be
   applied to impressed current sys-
  tems but is not  considered the
  most effective for these systems.
  There are many differing opinions
   among corrosion engineers as to
  the best technique for monitoring
  the effectiveness of impressed cur-
  rent systems. The 100 millivolt (0.1
  volt) polarization decay criterion
  that is described here is included
  in the National Association of Cor-
  rosion  Engineers'   RP-0285-95.
  The  set-up  of the monitoring
  equipment  (reference  electrode,
  voltmeter, and test leads) is the
  same as for galvanic monitoring.
  What is monitored, however, is
  the change in voltage of the struc-
  ture tihat occurs after the power to
  the rectifier is shut-off. This proce-
  dure requires two people to exe-
,  cute  it  properly: one  person to
  switch  off the rectifier, and the
  other to monitor  the  change in
  voltage of the underground stor-
  age system.

  When the power to the rectifier is
  interrupted, there will be an
  immediate  drop in the  voltage
  reading at the tank, followed by a
  continuing  slow decline in  the
  voltage. The person monitoring
  the voltmeter must note the volt-
  age reading immediately after the
  power  to the rectifier is inter-
  rupted.  (If the meter is digital, the
  numbers will change rapidly. The
  reading you want is the second
  number that  appears on   the
  meter's display.) The  voltage is
  then monitored for several min-
  utes  (possibly much  longer in
  stubborn cases) with the rectifier
  turned  off.  The  criterion  for
  cathodic protection is  a voltage
  shift of at least 0.10 volt from the
  initial reading after the power to
  the rectifier is cut off. For exam-
  ple, a system might have a voltage
  of -1.1 volts with the power to the
  rectifier turned on. Immediately
  after shutting off the power to the
  rectifier, the voltage might drop to
  -0.83 volt. The voltage must then
  drop below -0.73 volt (0.83 - 0.10 =
  0.73)  to meet  the  criterion  for
  effective cathodic protection.

  Another way to determine if this
  criterion for cathodic protection
  has been met depends on whether
  the original voltage of the tank
  (i.e., before  any cathodic protec-
  tion was applied) is known. If the
  voltage reading immediately after
  the rectifier is turned off is at least
  100 millivolts more negative than
  the original unprotected voltage,
  then the 100 millivolt criterion has
  been met. •

   Po not forget to restore
power to the rectifier before
      you leave the site!
18

-------
                                                                                      LUSTLine Bulletin 25
 Prevention/Enforcement
                                 ALICE: An Evolving Concept
For Documenting Good Tank  Management
      ALICE is not an acronym; it's a
      concept in progress. The con-
      cept seeks to address a sim-
ple question: Wouldn't it be helpful
if there were a recognized standard
certificate, signed by a licensed, certi-
fied inspector, that documents good
tank management? A certificate of
this sort could provide entities such
lenders, insurers, and real estate pro-
fessionals with a mechanism for
making better business decisions and
facilitating transactions where USTs
are involved.
     ALICE evolved out of discus-
sions between the EPA Office of
Underground Storage Tanks (OUST)
and  representatives from the real
estate, lending, and insurance indus-
tries as part of a Private Sector Initia-
tive developed by OUST to identify
and use market forces to ensure good
tank management. By incorporating
consideration of tank management
practices into their everyday busi-
ness decisions and asking the right
questions, those business  entities
that have some stake in UST-related
properties could help create market
incentives for proper tank manage-
ment and, at the same time, protect
their own interests and the environ-
ment. While federal and state UST
programs have  made tremendous
progress in educating tank owners
about good tank management, real-
izing EPA's goal of making good
tank management a common busi-
ness practice will require consider-
ably more time, effort, and a broader
range of players.
     After discussions with several
state program managers and after
learning what some states are already
doing in terms of using self-auditing
programs (e.g., Minnesota) and third-
party inspection  programs  (e.g.,
Pennsylvania), OUST recognized that
an ALICE-type certificate could also
be used by state UST programs to
augment or supplement their inspec-
tion and compliance programs.
     "People are always asking me
what the name "ALICE" means,"
says OUST's Sammy Ng, who has
been the ALICE helmsman. "We
needed a unifying concept to present
to  ASTM as a  possible standard.
                                  What we had was an array of diffuse
                                  ideas  from many interests that
                                  needed to evolve into a working con-
                                  cept. Many terms were being sug-
                                  gested, like "green certificate"  or
                                  "compliance certificate," but these
                                  terms all  had  connotations that
                                  meant different things to different
                                  people. In order not to  get side-
                                  tracked with having to define a con-
                                  cept that,   as  yet, had  no  final
                                  definition, I picked a name that had
                                  no particular meaning. Since worn-
                                  ens' names seem to be popular these
                                  days—Rebecca [risk-based corrective
                                  action - RBCA] and Renee [remedia-
                                  tion by natural attentuation - RNA], I
                                  picked ALICE, my mother's name."

                                  JK By incorporating consideration of
                                  ^ tank management practices into
                                  p their everyday business decisions
                                  |^  and asking the right questions,
                                  fe^ those business entities that have
                                  iz   some stake in UST-related
                                  ^properties could help create market
                                  I     incentives for proper tank
                                  ^management and, at the same time,
                                  I     protect their own interests
                                  F7 •'•    and the environment.
                                  An ASTM Standard?
                                  In April, Ng approached the Ameri-
                                  can Society  of  Testing Materials
                                  (ASTM) E50.01 Subcommittee (on
                                  USTs) for approval to develop an
                                  ALICE standard for a third-party
                                  inspection and certification program
                                  for USTs. As proposed, this standard
                                  would specify items that should be
                                  included in such an inspection pro-
                                  gram;  the  specifics  of  different
                                  inspection   tiers  (e.g., ALICE-1,
                                  ALICE-2), if needed; and the training
                                  and experience requirements for cer-
                                  tifying third-party inspectors.
                                      ASTM gave approval to have an
                                  informal Task Group begin scoping
                                  out the standard. That group, made
                                  up of tank owner trade associations,
                                  insurers, lenders, several state pro-
                                  grams,  and OUST has met twice.
                                  While there is some consensus among
                                  the group's members that the concept
has some merit and should be devel-
oped further, tank owners voiced
strong concerns about the potential
additional cost and burden of a third-
party inspection program, especially
if the benefits (e.g., lower insurance
premiums or loans) are not certain.
     Several states supported the
concept as a means of augmenting
their inspection programs. For some
states, a third-party inspection pro-
gram may represent an alternative to
no inspection program. A few states
indicated that they  had adequate
resources for annual inspections at
every UST location and had no need
for a third-party  program,  others
were concerned about how an ASTM
inspection framework would affect
their own inspection program.
     Through the ASTM meetings
and discussions, ALICE continues to
evolve. There seems to be consensus
that the most  useful inspection
would be one that is similar to a typi-
cal state inspection. One state pro-
posed that tank owners be allowed
to use the ALICE standard to  do
their own inspections. State inspec-
tors would spot check items on the
inspection checklist,  allowing them
to do more inspections as a result of
spending less time at  one facility.
Self-inspections could also spare
tank owners the cost of  having to
hire a third-party inspector.
     As a result of an October 1996
ASTM meeting  in New Orleans, a
formal go-ahead was given for the
Task Group to move ahead and draft
a standard. The Task Group writing
the standard is comprised of repre-
sentatives  from the four ASTM
stakeholder  categories:  industry
(tank owners), regulators, consul-
tants, and  general  interest (e.g.,
lenders, insurance). The Task Group
hopes to have a draft proposed stan-
dard ready for the next ASTM meet-
ing in April 1997 in Baltimore. •


* For more information, contact the
**    co-chairs: George Kitchen,
^International Lubrication and Fuel,
^Consultants, Inc., (505)892-1666, or
lammyK.Ng, OUST, (703)603-7166^
  0ig.sammy@epamail.epa.gov
                                                                                                 19

-------
LLlSTLine Bulletin 25
                         ASTM's Emergency  Standard for
Assessing Bare Steel  Tank Integrity  Goes
Back to  The Drawing  Boa
EPA Issues Interim Guidance
      On  November 15, ASTM's
      "Emergency Standard Prac-
      tice for Alternative  Proce-
dures for the Assessment of Buried
Steel Tanks Prior to the Addition of
Cathodic Protection"  (ES  40-94)
expired, and a proposed replacement
standard was not adopted. The pro-
posed  replacement  standard  re-
ceived  a number  of  negative
responses in the American Society
for Testing Materials (ASTM) ballot-
ing process, too many for ASTM's
Committee on Environmental Assess-
ment to tackle at its October meeting
in New Orleans.
     Shortly after the New Orleans
meeting, the ASTM G01 Committee
on Corrosion agreed to form a Joint
Task Force with the ASTM E50.01
Subcommittee for Storage Tanks to
continue the activity on the standard.
Prior to this agreement, the corrosion
standard work had been carried out
by the E50.01 Subcommittee through
its cathodic protection task group.
The new Joint Task Force will work
to develop a new technical standard
to evaluate corrosivity on tanks, but
not to address environmental com-
pliance. Dennis Rounds, Chair of the
ASTM  E50.01  Subcommittee, has
established a new task group under
E50.01 to draft a standard that will
focus on environmental issues and
serve to complement the corrosion
standard activity. Both task groups
are scheduled to begin meeting soon.
     ASTM published  the emer-
gency standard in fall  of 1994 to
address industry concerr, that the
internal inspection method u>r struc-
tural assessment of older steel tanks
cited in the 1988 federal rule (40 CFR
280.21) made tank upgrading pro-
hibitively expensive. Inasmuch as
the rule left the door open for the
approval of other methods, members
of the corrosion protection and lining
industries, EPA, and state regulators
took the opportunity to organize a
Task Group within ASTM to write a
standard  practice  for conducting
structural assessments for tanks over
10 years old.
    The  ES 40-94 standard pro-
vided minimum performance prac-
tices  for three   tank   integrity
assessment alternatives to physical
internal inspection:

• Noninvasive -  Data about the
  tank and its environment are gath-
  ered and  analyzed and then the
  remaining tank life is estimated
  statistically.
• Ultrasonic Robot - The tank's
  thickness is measured robotically
  over a  certain percentage of the
  tank interior and analyzed in com-
  bination with portions of the non-
  invasive method.
• Video  Camera  - A visual tank
  integrity assessment is performed
  using a video camera in  combina-
  tion with portions of the noninva-
  sive method.

    The standard also required that
the tank be assessed to ensure it was
not leaking prior to employing any
of these alternative techniques.

Interim Guidance
From  OUST
In the absence of a standard, EPA
and many of the state UST programs
find themselves in a kind of struc-
tural assessment policy limbo. The
EPA Office of Underground Storage
Tanks (OUST) issued interim guid-
ance in  an  October memo from
Acting Director Josh Baylson, recom-
mending that implementing agencies
continue to follow their current poli-
cies  regarding allowed  integrity
assessment  methods until  more
information is available, and OUST
issues further guidance.
    In his memo, Baylson was care-
ful to point out that it may be inad-
visable to use a tightness test as an
accepted  means   of  determining
whether a tank 10 years of Sge or
older is suitable for upgrading, an
approach  similar  to  one of the
options listed in the federal regula-
tions for upgrading tanks less than
10 years old. He cautioned states
against "changing to a policy that
relies  only on  leak detection for
assessing older bare steel tanks for
integrity."
    OUST is concerned about this
method for a few important reasons.
First, unprotected steel tanks often
corrode  through but do  not leak,
because the corrosion product, back-
fill, or interior sludge fill the hole. In
writing   the   regulations,  EPA
believed  that newer  tanks  were
much less likely to have corrosion
holes than older tanks.
    Also, there is uncertainty about
the prevalence  of tightly adhering
"rust plugs," which could begin to
leak after the addition of cathodic
protection. A tank that has a very
small leak or a hole that is not yet
leaking  because it is blocked by
something (e.g., clay, sludge) exter-
nal to the tank, may pass a tightness
test, but begin  to leak or leak at a
higher rate over  time. In short, a
tightness test could be used to inac-
curately conclude that a structurally
unsound tank is sound.
     "It is imperative that we assure
that only those tanks suitable for
upgrading are upgraded," says Bayl-
son, "so as to prevent another gener-
ation of leaking tanks." •
                           ......... "'i
\"-'For more information on ASTM
I  activity regarding developing a
E  corrosion standard for tanks,
t=i"   contact Dennis Rounds at

(gMiiii««jMi&!MilUMWMi	a«Sji,i.i
E	.itaigfivv	
       recommendations, contact
       '"•"' - • ' * 'iSiWH "n, i a, )i,"i ]««i,, LI, SiEHSifc jiMHBfcSliaHl* :>lr,
         fileu at (703) 603-7178.
               .     .          «
               °mat™n°n
20

-------
                                                                                    LUSTLim Bulletin 25
                    Prevention/Enforcement
                    Pennsylvania's Third-Party UST
                    Inspection  Program  Appears  To Be
                    Getting;  the  Job Done
    EJune  1994, the  Pennsylvania
    •apartment of Environmental
    rotection (PADEP) initiated a
third-party inspector program which
requires owners or operators of USTs
whose facilities are due for inspec-
tion to hire private,  certified UST
inspectors  to perform the required
inspections at their facilities. As of
November 1996, approximately 2,500
facilities have undergone facility
operations inspections.
    Inspector certification is a two-
step process. Prospective inspectors
submit an application describing
their education and  experience. If
their credentials are approved, they
must  take and pass a  two-part
(administrative -  80%  minimum
passing score, technical - 90% mini-
mum  passing score) certification
examination administered by a con-
tractor. Certifications are valid for 3
years. PADEP has the authority to
suspend or revoke a certification.
Circumstances under which these
actions can occur are listed in the PA
DEP regulations. Suspended certifi-
cations may be reinstated, but a
revocation is permanent.
    PADEP targets facilities  for
inspection by looking at tank system
age, type of product stored, number
of tanks, and history of environmen-
tal or regulatory problems. Facilities
identified  for inspection are sent a
packet which includes a certified let-
ter  notifying the owner that an
inspection is due (within 45 days
from receipt of the packet), a list of
certified   inspection companies,
information on what the inspection
will cover and how to prepare for it,
an  inspection report form, and a
postcard to be returned to PADEP to
confirm that the inspection is sched-
uled. It is the owner's responsibility
to set up and pay for the inspection.
    Inspectors use  a  standard
PADEP inspection form. Once an
inspection is conducted, the inspector
has 60 days to submit a report to
PADEP. During that period, inspec-
tors can work with UST owners or
operators to help them correct viola-
tions. If the help includes installation
of equipment, the inspectors must
have the appropriate PADEP installer
certification. To help prevent conflicts
of interest, inspectors may not inspect
their own employer's facilities.
    PADEP  does   not  initiate
enforcement action on the basis of a
third-party inspector's report. When
such a report indicates that an UST
facility is not in compliance, PADEP
sends the owner either a letter or
notice of violations. If an owner does
not respond with evidence that the
violations  have  been  corrected,
PADEP regional staff will conduct an
inspection to confirm that the viola-
tion still exists before formal enforce-
ment action is initiated. Third-party
sector inspectors are not authorized
to initiate enforcement actions.
    Program responsibilities are
shared by PADEP headquarters and
regional offices. Headquarters estab-
lished the program and developed
the regulations, and it has continu-
ing responsibility for communica-
tions,   coordinating    training,
developing  the   examinations,
reviewing applications, and issuing
guidance. Regional office responsi-
bilities include targeting facilities for
inspections, reviewing inspection
reports and other paperwork, taking
follow-up actions against facilities,
and conducting inspector oversight.
     PADEP managers  and staff
were initially skeptical  about  the
program, but many of them are now
convinced that it has been beneficial.
While the  inspectors' reports sub-
mitted thus far have indicated that
only 40 percent  of UST facilities
were in compliance when they were
inspected, PADEP's follow-up let-
ters and notices of violation have
raised the  rate to 90 percent. Com-
mon violations include failure to
perform inventory  reconciliation,
failure to  have tank testing per-
formed, and lack of documentation
of tank testing. •

      For more information about
   PADEP's third-party inspection
   program, contact Glenn Rider at
          (717) 772-5599.
           ANNUAL INSPECTIONS PERFORMED
                    (through November 20,1996)
           1600
                   1993     1994     1995
                              FISCAL YEAR
             1996
                                                                                                21

-------
 LUSTUnt Bulletin 25
                                       Where UST regulations are concerned, questions do pop up. No matter
                                      how obscure some of these questions may be, they merit exploration.
                                     No matter how obscure the question, someone out there needs an answer.
                                    Our answers derive from a carefully considered interpretation of the fed-
                                  eral rule, based on EPA guidance. Keep in mind, individual state require-
                                 ments may differ. 'Your questions and comments are welcome.
The last issue of LUSTLine contained the following
Q&A:
        » When is the last possible date that inventory
    control + tightness testing can be used as a legitimate
    method of leak detection for an existing tank? For a
    newly-installed tank?
             existing tanks (i.e., those installed on
    or before December 22, 1988), the last possible
    date that inventory control + tightness testing can
    be used is December 22, 1998. For newly-installed
    tanks (i.e., any tank installed after December 22,
    1988), there is no single date; all new tanks may
    use inventory control + tightness testing for the
    first 10 years after installation. For example, a
    tank installed in 2001 can use this method of leak
    detection until 2011.
Several astute readers called us to task for neglecting to
point out that if an existing tank is upgraded with three
things — corrosion protection (internal lining or cathodic
protection), spill buckets, and overfill devices — an exten-
sion is granted for the use of the combination of inventory
control and tightness testing as a leak detection method. If
the three items are done at the same time, this extension
ends 10 years afterwards. This means that a tank installed
in 1980 and structurally assessed by means of an internal
(human entry) inspection and then upgraded with corro-
sion protection and spill and overfill protection in 1997
could use the combination of inventory control plus tight-
ness testing every five years for leak detection until 2007.
     If you upgrade corrosion protection at a different
time than spill and overfill, what then? That is a question
pending EPA interpretation, and we have to defer it until
the next issue.
     Note, EPA guidance recommends that states have
owners give up the combination method of inventory
control plus tightness testing when any of the ASTM ES 40
methods for integrity assessment of existing tanks prior to
the addition of cathodic protection are used. This means,
in many states, that if a 1980 tank is assessed using an
ASTM  ES 40 technique and is upgraded with cathodic
protection in 1997, this tank would have to stop relying
on inventory control plus tightness testing for leak detec-
tion immediately after the upgrade is completed. And we
wonder  why owners and operators have trouble understanding
the rules!
     Don't forget piping! Even after upgrading, pressur-
ized piping must have an automatic line leak detector and
either monthly monitoring or an annual tightness test.
                               • continued on page 31
                          EPA Settles Multi-Million Dollar Action Against

  Worsley Companies, Inc. and Related Companies for Alleged

  Violations of UST Regulations
    In September, EPA Region 4 settled a consolidated administrative enforcement action against Worsley Compa-
    nies, Inc., Worsley Oil Company of Wallace, Inc., and Worsley Oil Company of Elizabethtown, Inc. for alleged
    violations of federal UST regulations. The Administrative Compliance and Complaint Orders alleged a range of
  violations including the failure to notify proper authorities of the existence of USTs, failure to comply with tank and
  piping release detection requirements, and failure to comply with the requirements to investigate and confirm
  releases.
      Under the terms of the Consent Agreement and Consent Order, the companies have agreed to pay a civil
  penalty of $199,325 to the United States Treasury, correct the violations, implement a comprehensive environmental
  compliance policy, and perform three Supplemental Environmental Projects (SEPs). The civil penalty is the largest
  penalty settlement for EPA's UST program nationwide.
   The total cost of the SEPs is estimated at $2,539,133. They include:
   • Enhanced Upgrades - the installation of double-walled tanks with pump sumps, double-walled product piping,
     and dispenser liners with continuous interstitial monitoring for tank and piping leak detection at a minimum of
     eighteen and a maximum of thirty facilities.
   • Accelerated Implementation of Minimum Upgrades - implementation of minimum upgrades at forty-five facili-
     ties in North Carolina, South Carolina, and Florida that include the installation of spill and overfill equipment
     and cathodic protection equipment.
   • Implementation of "Stage 1" Vapor Recovery on UST facilities in South Carolina - the installation of Stage 1
     Vapor Recovery equipment on all UST systems owned in South Carolina to secure significant environmental or
     public health protection and improvements. •
22

-------
                                                                                         LUSTLine Bulletin 25
    Enforcement
Those  Extra Pairs of Eyes
Maryland and Connecticut Increase Enforcement Presence
Without Increasing Budgets
     Through an agreement with two
     other state  agencies  whose
     inspectors regularly visit gaso-
line stations, Maryland's  UST pro-
gram has substantially increased its
field presence without any increase
in its budget. The Connecticut UST
program is set to embark on a similar
type of alliance.
     Under Maryland's agreement,
inspectors for the UST program, the
Bureau  of Weights  and Measures,
and  the Motor Fuel Tax Division
look for possible violations of all
three agencies' regulations. Thus, the
UST program,  which employs 24
inspectors, has help from 74 weights
and measures inspectors and 34 fuel
tax inspectors—a more than five-fold
increase in its field presence.
     When the three agencies began
discussing ways to  work together,
they first focused on the possibility
of combining their inspection activi-
ties, but they quickly concluded that
such an arrangement "was not feasi-
ble. They did agree, however,  that
they could assist each other if all
their inspectors were trained to look
for  certain indications of possible
violations of the other agencies' reg-
ulations.
     To keep the arrangement sim-
ple, inspectors have been trained to
check for just a few signs of possible
violations. As the three agencies gain
experience with the program, they
will  train the  inspectors to check
additional items.
     Inspectors for all three agencies
use a standard  form to record and
report   their  observations.   When
inspectors spot a possible violation
of one of the other agencies' regula-
tions, they use the standard form to
report that finding to the appropriate
agency; they also give the  facility
owner  or operator  a copy of the
form.
     The three agencies  have an
annual one-day cross-training pro-
gram, in which inspectors  and man-
agers educate each other on what
their regulations require and what to
look for when they are conducting
inspections. They also share informa-
tion about their experience in the
field. In addition, all inspectors have
opportunities to spend one day in
the field with colleagues from the
other agencies.
  Leveraging enforcement presence

  s   -
    with other programs that send
  flMspectors out to UST facilities is
        ' ~                     1
 .^as*^ ™   -^ *" *~ ~11? ^.s^i^       H
 igne practical way to let tank owners

  t- and operators Know your UST
  "•I, ^ *w. , *     . r   - If. „ ~rr _ ,      |
   t_	 f  -            .1
   ;"r program is alive and well.
     Herb Meade, Chief of Compli-
ance in the Oil Control Program of
the Maryland Department of the
Environment, says this arrangement
has benefitted the UST program in
several  ways. The  UST program
receives reports on  possible viola-
tions weeks before an UST inspector
would have visited  the facilities in
question. In the first 2 months, the
Department  of the Environment
received reports identifying 16 possi-
ble violations; most of them involved
improper or missing markings of fill
and monitoring pipes, but there also
were reports of leaks and spills of
petroleum  products, particularly
when   dispenser   sumps  were
inspected.
     Another benefit of the program
is that the three agencies are sharing
information.  They have compared
and adjusted their facility databases.
They are also coordinating enforce-
ment activities by sharing informa-
tion on facility owners and on the
'track records' of individual compa-
nies,
case^for^exar^ple, the Dgpar:tmenti,of
tfl.'e Environment  was ableyfo 'iisi
djata fromJthe Motor_JF;uel Tax Div|-
   i to demonstrate*tEatadefendant
                   "«*£•(*'••''* --">•-'•£•,
                 .compliance with
  «SKi . j  • •
ha<|Ta history c^noneojt:
Maf viand' lawv fhis'd
   -J-•:	 &"."•'• i   '  -  . ,W»i*"^¥^
evidence that, the^allgged violation of
UST regulationtfwas'willful and thus
added toxi^e penalig imjgosea on the
company.
     While Connecticut hasn't, as
yet, established a formal program,
the Connecticut  UST program has
begun to  expand  its  enforcement
coverage through an alliance with
the state air  compliance and con-
sumer protection (weights and mea-
sures)   programs.  "The   other
inspectors will help us check on '98
deadline and leak detection compli-
ance," says Scott Deshefy, Coordina-
tor  of   Enforcement   for   the
Connecticut Department of Environ-
mental Protection's UST program.
"Weights and Measures already lets
us know about leaks and spills, and
we have good communication with
Air Compliance."
     This  "good communication"
can help bring  about  compliance
results in more ways than one. For
example, Air Compliance has a loan
program for Stage II vapor recovery.
In reviewing  loan applications, air
personnel run compliance  checks
using information on the UST pro-
gram's database. They look for any
information   on  violations.  Any
apparent problems will be factored
into the loan decision. "This pro-
vides an incentive for compliance,"
says Deshefy.
     Leveraging enforcement pres-
ence by coordinating and communi-
cating with other programs that send
inspectors out to UST facilities is one
practical way to let tank owners and
operators know your UST program
is alive and well.  In the next issue of
LUSTLine, we'll take a look at states
that are "red tagging" delinquent
UST owners and operators. •
                                                                                                    23

-------
LUSTLinc Bulletin 25
When Bad  Things Happen to  Silts  and  Clays
API Focus Papers Shed a Collective Light On Processes, Human Exposures, and
Technologies Applicable to Low Permeability Soils
Thefolloioing article is adapted (with permission) from the API document: Summary
of Processes, Human Exposures and Technologies Applicable to Low Perme-
ability Soils, by Terry Walden, BP Oil Europe, a member of API's Soil and Ground-
ivnter Technical Task Force. Although the language in the article is uncharacteristically
"technical"for LUSTLine, we "threw caution to the wind," thrilled, as it were, that
somebody had assembled such information on these clayey and silty soil types.
     The American Petroleum Insti-
     tute  (API)  has published a
     series of ten focus papers on
the topic of light nonaqueous phase
liquids (LNAPLs) in low permeabil-
ity (e.g., clayey) soils. Collectively,
the papers address four key issues:
• Physical and chemical processes
  affecting  the  migration  and
  removal of LNAPLs;
• Available models for predicting
  this behavior;
• Exposure potential posed by clay
  soil  hydrocarbons  via a  soil,
  groundwater, or air pathway; and
• Available techniques for remov-
  ing or enhancing the removal of
  contaminants.
     The papers were prepared to
provide guidance and understand-
ing on the need and ability to reme-
diate low permeability soils in-situ.
Recognizing  the  limited  options
available   to  field  practitioners
charged with remediating sites with
silty or clayey soils, the API initiated
a 3-year program (beginning in 1992)
to consolidate information on the
topic and conduct research on tech-
nologies that show promise  for
removing, or enhancing the removal
of, contaminants from this media.
     A multi-discipline group was
assembled under the umbrella of the
API to address the four phases of the
problems listed above. These individ-
uals agreed to work as a team and
write focus papers on their areas of
expertise. Emphasis was placed, pri-
marily, on the vadose, or aerated,
zone of contaminated petroleum sites.
     The focus papers are compiled
in API Publication 4631, Petroleum
Contaminated Loiv Permeability Soil:
Hydrocarbon Distribution, Exposure
 Pathways, and In-Situ Remediation
 Technologies, August 1995.

 Process Issues
 Low permeability soil refers to silts
 or clays whose saturated hydraulic
 conductivity is generally below 10"°
 centimeters per second (cm/s). These
 soils can be encountered in three dis-
 tinct types of geologic settings:
Y////////////////////A
taining natural fractures in nonarid
regions, the fractures a short distance
above the water table are generally
air-filled, while the adjoining "solid"
matrix blocks between fractures are
water-saturated as a result of capil-
lary pressure forces. This means that
should a hydrocarbon spill occur, the
LNAPLs will fill the fractures in the
soil and bypass the matrix blocks,
traveling  downward  until  they
encounter the capillary fringe (the
area just above the water  table),  at
which point they will spread later-
ally into cross-cutting fractures. The
large  entry pressures  required  to
"push" the LNAPL into the matrix
will tend to hold  these separate-
                                        SANDLA^R]||£    ''"/::/';' ""
      MASSIVE FRACTURED CLAY
  •  Massive clay formations where
    the permeability is very limited
    and,  in fact, dominated by sec-
    ondary fractures  that typically
    result from desiccation or weath-
    ering processes;

  •  Layered or stratified formations
    where silt or clay layers are inter-
    spersed within sandy or higher
    permeability layers; and

  •  Silt or clay "lenses" that tend to be
    discontinuous and of a limited lat-
    eral and vertical extent  within a
    sandy matrix (a subset of layered
    or stratified formations).

      Fluid (including contaminant)
  migration is distinct in each setting,
  and the remediation strategies differ
  accordingly for each media.
      In massive clay formations con-
       STRATIFIED SCENARIO
phase hydrocarbons in the fractures.
     Although separate-phase prod-
uct (i.e., LNAPL) will not invade the
water-saturated matrix to any great
extent, its constituents will eventu-
ally appear in the matrix as a result
of the process of diffusion  (i.e.,
movement resulting from the exis-
tence of  concentration gradients).
This is an aqueous phase—not a sep-
arate phase—process.
     In this situation, the soluble
constituents in the LNAPL will dis-
solve, and a concentration gradient
will be established between the dis-
solved hydrocarbon components in
the fracture and the uncontaminated
pore water  in the matrix. The more
soluble components will partition
out of the LNAPL phase first, and
over a period of weeks to months,
part or all of the LNAPL mass in the
24

-------
                                                                                            LUSTLine Bulletin 25
    Recognizing the limited options
    available to field practitioners    "
  charged with remediating sites with
 fsilty or clayey soils, the API initiated j
t   a 3-year program (beginning in
JJ1992) to consolidate information on
 ^ the topic and conduct research on
 | technologies that show promise for
 ^removing, or enhancing the removal
   of, contaminants from this media,  I
fractures will diffuse into the matrix.
Equilibrium is established when the
matrix storage capacity (including
both dissolved and adsorbed phases)
is reached.
     The process of diffusion has a
rather significant impact on remedia-
tion strategy. Diffusion is  a slow
process.  It has been said that if it
takes a substance x number of years
to diffuse into the soil, it will take x
number of years to get it out. In fact,
this is extremely optimistic.
     Simple  diffusion calculations
indicate  that the time it takes  to
achieve 85-percent mass recovery is
nearly 10 times longer than the  time
the contaminant was in the ground
before remediation began. So, if a
spill were to occur 2 years before
remediation (defined as an air or liq-
uid flushing system that sweeps the
fractures free of  contamination), it
may take 20 years to get 85 percent of
the  mass  out,  and 200 years  to
achieve 95 percent removal.
     These long remediation periods
are the result of disparate concentra-
tion gradients. High gradients drive
the contaminants out of the fractures;
only low gradients exist when the
fractures are cleared, establishing the
slow process of reverse diffusion out
of the matrix. It is apparent that tech-
nologies that rely strictly on diffu-
sion-controlled fluid movement will
take a long time to achieve success (if
ever) and could, therefore, have high
life-cycle costs.
     An important example of this
concept is in the application of soil
vapor extraction. The remediation
literature has numerous examples in
which high vacuum systems (some
approaching 25 inches of mercury, or
0.8 atm) are used for clay soils, pre-
sumably to  improve  the zone  of
influence of the induced air'  flow
around the extraction wells. Air is,
however, most likely to flow through
the fractures in a massive clay forma-
tion, or the sandy layers in a strati-
fied formation. Thus, the implication
that flow through the subsurface is
uniform is misleading.
     If the mass transfer of contami-
nants is diffusion-limited, the air
flow rate through the fractures or
high permeability layers should be
maintained at a level that will simply
keep  the  fractures  swept clear,
thereby minimizing operating costs.

Modeling llssues
To define the exposure potential, as
well as the  need for remediating
hydrocarbons in low permeability
media, it is necessary to have a good
understanding of the  chemical com-
position of the LNAPL (e.g., crude
oil or refined petroleum products),
the geology, as well as the subsur-
face processes affecting  LNAPL.
     Regarding chemical composi-
tion, the critical parameters for each
key compound are vapor pressure,
solubility, and mole fraction in the
LNAPL mixture. The geologic factors
that control exposure  are the perme-
ability of the subsurface, the degree
of stratification or fracturing of the
soil, the moisture content of the soil,
and distance of the source from the
water table (for a groundwater path-
way) or from the  receptor (for  a
vapor inhalation route of exposure).
     In order to assess exposure and
the need or ability to remediate the
site, the following parameters should
be measured in each geologic setting:

I'  Massive Clay'
   •  Permeability and  air-filled
-. -  porosity  of the  fractures  '.
*? •  Aveiage spacing  and con-
     nectivity  of the  fractures  ;
*            .'.'-'  -.--.: -•-•• ::<>.' • -..>"-W  "•-''.:  .-S
ipf Stratified Soil -   •   '  ,     -.  l,
fc^;;;,Pejrrneability over discrete  j
             '   •  -'"""'  "    '"•
     Air-filled'.-porosity in  low
     permeability layers    ;    :
|fi£*l Average  fracture  spacing
Hin..cancl connectivity (if any)

pyCiay Lenses'  ' \
    I jDlffusion coefficient of cont-
llro^^atrunants in clay
Ez?C' TMckness and length of clay
     Tracer data can be used to esti-
mate parameters such as, air-filled
porosity or average fracture spacing
(which could be calculated from the
tracer flow data after assuming or
measuring  an  average   aperture
dimension).
     To establish  the need for, or
efficacy of, remediation, the tracer
data can be modeled to determine
the fate and transport of the contami-
nants, both with and without reme-
diation. At this juncture, the third
element of the evaluation—the sub-
surface process data-—-comes  into
focus. Partitioning, biodegradation,
and  retardation effects need to be
considered. Biodegradation in low
permeability soils is particularly rele-
vant because of the generally long
residence  times   of  dissolved or
vapor-phase product in the subsur-
face as  it moves between  a source
and a receptor.-
     Given the varied subsurface
conditions and contaminant compo-
sitions one might encounter and the
data requirements  for modeling het-
erogeneity, the use of analytical
models for screening purposes rather
than numerical models for detailed
prediction is considered the  more
practical  approach at • the  present
time. This approach  answers the
questions: Will this particular reme-
dial action be effective?;  or What
gross exposure threats are posed by
leaving the soil untreated?   •

Exposure  Issues
Human exposure  to contaminated
media can be  the result of, either
direct or indirect contact with, soil,
groundwater, or their vapor emis-
sions. The factor that distinguishes
the potential for exposure to contam-
inated media in clay soils from other
more permeable media is the unique
soil structure of the clay.
     In clays, the  small pores com-
prising the soil matrix blocks increase
the capacity of the soil (relative to a
more permeable media) to store and
"sequester" contaminants over time
and to retain water in the matrix. The
secondary or "dual-porosity/dual-
permeability" nature of the material,
which is a consequence of the pres-
ence of natural fractures, results in the
nonuniform distribution and trans-
port of LNAPL, water,  and vapor

              • continued on page 26
                                                                                                        25

-------
LUSTJU'iie Bulletin 25
• Silts and Clays from page 25
phases throughout the  subsurface.
The low permeability of the bulk
media affects the migration of conta-
minants in the vadose and ground-
water zones.
• SOIL CONTACT
The direct soil contact  pathway is
strongly influenced  in  clays by
bioavailability of the contaminant
compounds. Bioavailability is a con-
cept that refers to the fact that conta-
minants which may be present in the
matrix (in  the  sense  they  are
extractable with a solvent) may no
longer pose a toxicity risk because of
the  way  they  are  retained  or
sequestered in the soil matrix. In the
simplest terms, the contaminants dif-
fuse into the interior pores  of the soil
or into the humic fraction, and are
increasingly slow in reappearing at
the surface of the soil (where their
toxicity can manifest itself) because
of mechanisms that limit the desorp-
tion rate.
     While the phenomenon of des-
orption rate limiting mechanisms
applies to all soils, it is particularly
relevant  to clay  because  of clay's
small pore structure. From an expo-
sure standpoint,  reduced bioavail-
ability lessens the absorbed dose
(and hence risk) of direct soil contact,
either by ingestion or dermal contact.
Recent research  led  by  the Gas
Research Institute and the  oil indus-
try has been directed at identifying
the suite of tests needed to demon-
strate and  quantify bioavailability.

• GROUNDWATER EXPOSURE
Exposure via the groundwater path-
way is very much a function of the
type of fine-grained geologic setting.
In thick, massive day soils, with no
underlying sandy aquifer, there is lit-
tle exposure threat in the source zone
because drinking water wells are
rarely placed in low-yielding clays.
Also, downgradient plume migra-
tion is less likely relative to sandy
soils. However,  when  a  contami-
nated clay stratum that contains frac-
tures lies above or below an aquifer,
mass transfer must be  considered
under each of the following two sce-
narios:
• If LNAPL is present  in the frac-
  tures,  rainfall or a  fluctuating
  water table flowing through the
  fractures will release dissolved-
   phase components at their effec-
   tive solubility limit (defined by
   Raoult's Law as the pure phase
   solubility multiplied by the mole
   fraction of the constituent in the
   mixture)  into  the aquifer.  Dis-
   solved-phase concentrations  of
   the BTEX compounds that are in
   excess  of  their drinking water
   standards (e.g., their MCLs) could
   occur in  the  aquifer  directly
   beneath the source.
• If the LNAPL has been depleted
   from the fractures (by some com-
   bination  of  the  processes  of
   volatilization, dissolution, biologi-
   cal degradation, or diffusion into
   the matrix blocks), reverse diffu-
   sion of the dissolved-phase conta-
   minants from the matrix back into
   the fractures will occur. Unless the
   distance between fractures is on
   the order of meters, the resulting
   concentration in the fractures will
   (essentially) be equal to that of the
   water held in the matrix. For high
   matrix concentrations and limited
   mixing of the fracture leachate in
   the aquifer, dissolved-phase con-
   centrations of BTEX could also
   exceed their MCLs in the aquifer.

     Both scenarios indicate that an
exposure risk in the aquifer beneath
the source area is possible. However,
if the receptor well is downgradient
of the source, exposure will be miti-
gated   by   natural   attenuation
processes affecting the BTEX plume.

• VAPOR EMISSIONS
Vapor emissions from low perme-
ability soils are generally unlikely to
pose an inhalation exposure threat.
This fact is  true even when  the
hydrocarbon source is directly adja-
cent to a basement, an excavated
trench,  or the  soil surface. Diffu-
sional transport is limited by the nor-
mally high moisture content of the
clay soils, which limits the number
and size of the air-filled  passages
through which the volatile organic
vapors  can  migrate.  The vapor
plume is further attenuated by the
processes of dissolved-phase parti-
tioning into the pore water in the
vadose  zone, adsorption  onto  the
organic fraction, and biodecay.

Technology  Issues
In developing  these focus papers,
seven technologies were judged to
have some potential for the remedia-
tion of low permeability soils in the
vadose zone. These technologies can
be broadly segregated by the type of
process that they induce:
   Contaminant Removal _
 ,  • Soil vapor extraction (SVE)
  Mobility Enhancement
  J • Thermal processes
  * Surfactant flushing
  L«'. Jn'-sitasmtrnMng'   .'...'''.	1'.

  Permeability Enhancement"
  y» Hydraulic fjracturing
  " * Pneumatic fracturing
To evaluate the technologies by com-
paring them to one another,  we
posed an identical set of questions to
each of the authors of a technology
paper. Generic questions addressed
the effects on contaminant removal
posed by high moisture content, the
ability to access under buildings, the
maximum depth to which the tech-
nology is appropriate, and the capa-
bility  to   remediate   petroleum
products other than gasoline.
     In addition, the two major geo-
logic settings of a naturally-fractured
massive clay formation and a strati-
fied formation were described; in
each case, the author was questioned
on the ability of the technology to
remove free  product,  dissolved
product, adsorbed  product,  and
residual product  trapped  within
pore throats. Each  paper concludes
with a breakdown of the costs to
close a hypothetical site; commercial
availability; case histories;  and a
summary  of  the strengths,  weak-
nesses,  and complementary tech-
nologies  which  could  enhance
remedial effectiveness.
     The most salient points for each
technology   follow;  they   are
described  in the  paragraphs and
summarized in the table below. A
common set of cost data (e.g., well
costs) has been used to derive com-
parable data for each technology as
applied to the hypothetical site.

• REMOVAL TECHNOLOGIES
In-situ technologies that actually
remove the contaminants, and  not
simply enhance their removal from
the ground, are  limited to two air
flushing  techniques—soil  vapor
26

-------
                                                                                            LUSTLine Bulletin zo
extraction and bioventing—which
are very closely related.

•  Soil Vapor Extraction/
   Bioventing
   Soil vapor extraction and biovent-
   ing refer to either the injection or
   extraction of air through a nonsat-
   urated medium. Both rely on the
   same technique for achieving suc-
   cess—the ability to sweep  air
   through regions of contamination
   within the formation. In soil vapor
   extraction,   the   air   induces
   volatilization of the contaminants;
   in bioventing, the oxygen encour-
   ages biodegradation. The distin-
   guishing  feature between the two
   processes is the rate of the air
   flow.  Bioventing  requires  less
   flow because the biodegradation
   rate   (and  thus  the   oxygen
   demand)  is relatively low.
In either case, the  air will flow
preferentially through the frac-
tures in a massive clay soil and the
higher permeability layers  in a
stratified soil. Remediation of the
matrix   blocks  or  the   clay
layers/lenses will then be limited
by diffusion.
For vapor extraction, the term
"diffusion" refers to the migration
of contaminants into the swept
fractures. For bioventing, "diffu-
sion" refers to the movement of
oxygen into the lower permeabil-
ity regions. The success of both
technologies depends on the dif-
fusion path length (i.e., the dis-
tance  between  fractures   or
thickness of the clay layer).
These  technologies are deemed
reasonably effective, both from a
technical and a cost perspective.
Stratified formations are some-
what problematic in soil vapor
extraction because it is difficult to
move the air anywhere other than
into the high permeability layers.
In bioventing demonstrations, this
difficulty is partially overcome by
injecting air over narrow-screened
intervals at close spacing in the
clay layers.
Both technologies have the poten-
tial  for enhancement  through
dewatering and induced (pneu-
matic or hydraulic) fracturing, as
long as the geometry and spacing
of the fractures is well controlled.
Soil warming could also enhance
performance, although tempera-
tures  that  would  significantly
improve    vapor    extraction
(through pore water evaporation)
would be at the expense of biolog-
ical activity. Optimum tempera-
            • continued on page 28
"••;." .;'lT'.. ":"' 	
4S*ffe^sa*:*Sr
- •. ' :-|"Jl •!'•••• 	 :"!|!"|',f. '••••p^r]l"?«^'Vr*-™Kr1r>~'Vp' |THf )?«iS3J»MJ?:;;
SOIL VAPOR
EXTRACTION BIOVENTING
Applicability
Strengths
Limitations
Costs ($/yd3)(a)
Time to Closure^3)
Availability
Complementary
Technologies
Volatile
fractions
Proven
technology
Low K layers in
strat. soils
$24(b)
9 months
Widespread
- Fracturing
- Dewatering
Middle
distillates
Lowcost(f)
-Slow(f)
- Low K layers
$23(b)
2yrs
Widespread
- Fracturing
- Warming
THERMAL
TECHNIQUES
Gasoline, diesel
and crude oil
Improved HC
recovery
-Non-
uniform
heating
- High cost(f)
$62(c)
50 days
Sparse
- Fracturing
-SVE
SURFACTANT
FLUSHING
Diesel and
crude oil
Residuals
reduction
- Emulsions
- High cost(f)
- Limited
experience
$65(d)
64 days
Very limited
Fracturing
SOIL MIXING
Volatiles &
semi-volatiles
- Fast(f)
- Enhanced
mass trans.
- Large
equipment
.f Boulders
- High cost(f)
$125
50 days
Sparse
Heating
i

HYDRAULIC
FRACTURING
Massive clay
formations
Reduce
diffusion path
length
- Overconsoli-
dated geology
only
- Surface heave
$6(e)
3 weeks
(fracturing only)
Very limited
All fluid flush
technologies
PNEUMATIC
FRACTURING
Massive clay
formations
Reduce
diffusion path
length
- Geology
- Surface heave
- Fractures
close w/time
$7(e)
3 weeks
(fracturing only)
Very limited
All fluid flush
technologies
NOTES
(a) Costs were calculated from information provided in the papers included in this report; closure refers to gasoline cleanup from 1000 to
200 ppm in stratified site, with 1 00 ft x 1 00 ft x 1 5 ft source dimension.
(b) Includes $1 5k for design, $20k for a pilot study, and $20k for pre and post-soil sampling.
(c) Assumes steam stripping.
(d) Assumes 80% recycling of the surfactant.
(e) Costs are for fracturing only, not subsequent remediation.
(f) Relative to other technologies described in this report.
                                                                                                        27

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LUSTLlnc Bulletin 25
 • Silts and Clays from page 27

   tures for bioventing are in the
   range of 20 to 30 degrees centi-
   grade.
• MOBILITY ENHANCEMENT
TECHNOLOGIES
Mobility enhancement is broadly
defined as a process which acceler-
ates the movement of contaminant
vapors or liquids to a subsurface col-
lection system. Surfactant flushing is
the typical example of this type of
technology, but this definition also
includes thermal techniques and soil
mixing.

* Thermal Processes
  Soil can be heated in one of two
  ways—hot fluid injection (i.e., hot
  water, air, or steam) or direct heat-
  ing (i.e., electrical resistance [ER]
  or radio frequency [RF] heating).
  In the former, the fluids are intro-
  duced through wells or trenches.
  In the latter, the heat is introduced
  through electrodes or antennae
  that are placed in the ground. In
  both cases, the key design goal is
  to spread the heat away from the
  source and maintain roughly uni-
  form temperatures throughout the
  remedial area. The increased soil
  temperature must be maintained
  near the extraction wells to avoid
  recondensation or immobilization
  of the contaminants.
  Thermal applications of water, air,
  and steam  differ according  to
  function. Hot water, for example,
  is used to improve mobile LNAPL
  recovery in water extraction wells
  by lowering the interfacial tension
  and contaminant viscosity. The
  hot air acts to dewater the forma-
  tion by vaporizing the pore water
  near the flow channels, thereby
  improving  the  performance  of
  vapor extraction. Steam is used to
  remove both residual and free-
  phase hydrocarbons  that are
  volatilized and recovered as a gas
  or as condensate.
  Like vapor  extraction, hot fluid
  injection is compromised by the
  tendency of the fluid to flow
  either through higher permeabil-
  ity layers in a stratified formation
  or through the fractures in a mas-
  sive day formation. These  prefer-
ential pathways make it difficult
to heat the formation uniformly,
limiting the remedial effectiveness
of hot fluid injection as a stand-
alone technology.
The ER and RF heating systems
attempt to raise the vapor pres-
sure  of  the   contaminants  to
improve hydrocarbon recovery
through vapor extraction wells.
ER can heat the soil to close to the
boiling point of water, while RF
can heat significantly above the
boiling  point,  providing   the
added benefit of drying the soil
(but at high cost). These technolo-
gies actually perform better in low
permeability media because they
depend on the water content of
the soil to conduct energy, and
capillary  forces retain  higher
moisture levels in silts and clays
than in sands and gravels. Still,
sufficient permeability must exist
to remove the vapors.
Undoubtedly, thermal technolo-
gies improve hydrocarbon recov-
ery    (especially   of   middle
distillates), but the costs are high
and field experience is limited, In
low permeability soils, a comple-
mentary technology, such as frac-
turing, may be needed to ensure
more uniform heat distribution
and a hydrocarbon removal path-
way,

Surfactant Hushing
Injection of surfactants through
wells  can aid  in  hydrocarbon
'recovery  in one of four ways:

-  Promote  dissolution  of  an
   LNAPL by increasing its solu-
   bility in the flushing solution;

-  Increase LNAPL mobility in the
   subsurface  by  lowering  the
   water-LNAPL interfacial ten-
   sion;

-  Reduce sorption onto soil parti-
   cles; or

-  Accelerate the release of soil
   colloids which may be carrying
   sorbed contaminants,

There are  two  principal  draw-
backs to the general use of surfac-
tants. The first is their cost, and
the second is their tendency to
form emulsions that are difficult
to break. Unfortunately,  in an
attempt  to  overcome  the first
problem through recycling, the
second  problem of emulsions
manifests itself, There are rela-
tively few examples of surfactant
usage in the literature. Those that
exist apply mostly to  DNAPLs
(dense nonaqueous phase liquids,
which are  typically  solvents)
rather than to petroleum hydro-
carbons,
Low permeability media further
complicate the effective use of
surfactants. As with other fluid
flushing  approaches (air or liq-
uid), the surfactant will bypass
the lower permeability regions,
relying on a diffusional process to
reach the contaminants in the clay
layers or matrix blocks. Induced
fracturing of the soil can alleviate
this problem to some extent, but
when combined with the cost and
emulsion issue, the feasibility of
cost-effectively treating a  silt or
clay media with surfactants is
doubtful. The technology appears
to have limited potential  at the
present time,

In-Situ Soil Mixing
In-situ soil mixing refers  to the
process of physically disturbing
the soil  with the  use of  large
diameter  (up to 14 ft) augers
mounted on a drill rig. Overlap-
ping columns of soil are augured
down to depths as great as 25 feet.
The technology requires that the
site be relatively level and free of
overhead obstructions; the sub-
surface must likewise be free of
boulders or other large buried
objects,
In the process of mixing the soil,
treatment of the contaminants can
take one of three forms:

-  Grout can be injected down the
   hollow auger stem to solidify
   the soil;

-  Air can be injected to volatilize
   the contaminants (which are
   then collected under a shroud
   placed on the surface); or

-  A chemical oxidant (e.g., per-
   oxide)  can be introduced to
   promote contaminant removal
 '  through chemical transforma-
   tion.
28

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                                                                                               LUSTLine Bulletin 25
   Ail three treatments Rave been
   demonstrated   in   the   field,
   although the long-term stability
   (leachability) of the grout has yet
   to be determined.
   Soil mixing is an aggressive tech-
   nology that causes significant site
   disturbance; the mixed soil has a
   volume at least 15 percent greater
   than the original volume. It is also
   very costly, relative to other tech-
   nologies, averaging  as much as
   $150 per cubic yard. The advan-
   tages of soil mixing are that it is
   not very sensitive to the geologic
   conditions and  that treatment is
   extremely fast (i.e., each soil col-
   umn takes hours). The size of the
   equipment,  however,  makes it
   impractical  for  service-station-
   type settings. In summary, soil
   mixing is a "niche" technology
   that may be uniquely suited to
   some  applications;  it  is  not
   expected to see widespread usage.

 • Permeability Enhancement
 Technologies
 Enhancing the permeability of low
 permeability media is possible using
 two techniques  that involve artifi-
 cially fracturing the soil—hydraulic
 fracturing and pneumatic fracturing.
      The permeability of silts and
 clays can be significantly increased
 by inducing the fracturing of the soil.
 It is  important, however, that the
 fracturing process be  controlled,
 because random fracturing can cre-
 ate unwanted short circuits, making
 it difficult for a remedial flushing
 solution to treat bypassed areas. The
 goal is to create a pattern of fractures
 that decrease treatment time by min-
 imizing the distance over which the
 diffusional process is required  to
 remediate the contaminated zone.
     Controlled fractures can be cre-
 ated either hydraulically or pneumat-
 ically. In hydraulic technology, a
 fracture  is  nucleated through the
 injection of a fluid, followed by a
 slurry of granular material and gel to
 "prop open" the fracture, thus main-
 taining a permanent channel in the
 matrix. In pneumatic fracturing, high
 pressure  air  creates  the  channel,
which is "self-propped" and will tend
to close over time. In stiff clays, the
 time to closure may be on the order of
 a year or more; it could however be
much less in soft  saturated clays.
     The key to successful fracturing
is the ability to propagate the frac-
tures in a horizontal plane. Horizon-
tal fracturing will occur where the
soil is "overconsolidated," meaning
that the horizontal  compressive
stresses exceed the vertical stresses.
Under these conditions, both tech-
niques are capable of initiating frac-
tures to a radius of 20 to 25 feet
before they begin to rise toward the
surface.  Fractures can  be created
with a vertical spacing of 1 to 2 feet,
providing a reasonably short diffu-
sion path length for  remediation.
Creating  fractures  near building
foundations must be carefully con-
sidered; surface displacements of up
to 2 inches have been recorded.
     Induced fracturing offers sig-
nificant potential for remediating
 low permeability media by incorpo-
 rating the technology with air flush-
 ing technologies or with thermal
 treatment. Air flushing may allow
 the amount of vacuum (and thus size
 of the equipment),to be reduced for
 moving comparable amounts of air
 through   the   subsurface.   Both
 hydraulic and pneumatic fracturing
 have similar costs and installation
 requirements, but hydraulic fractur-
 ing has one distinct advantage: sand-
 propped  fractures  are permanent
 and will not close over time, making
 the technology less sensitive to mois-
 ture levels and the degree of stiffness
 in the clay. •
[, More detailed information on silt and
&clay remediation can be found in the
r focus papers listed below.
  API's publication 4631^
  Petroleum Contaminated Low Permeability Soil Hydrocarbon
  Distribution, Exposure Pathways,, and In-Situ Remediation
  Technologies, August 1995, contains the following focus papers:

  Summary of Processes, Human Exposures arid Technologies Applicable.to Low       .
  Permeability Soils              ...         '•'"•        '....        •
  Terry Walden, BP Oil Europe

 . Relevant Processes Concerning Hydrocarbon Contamination in Low Permeability Soils
  David B, McWhorter, Colorado State University, Fort Collins, Colorado

  Assessment of Human Exposure Posed by LNAPLS in Law Permeability Soils
  Terry Walden, BP Oil Europe      ;
  David B. McWhorter, Colorado State University

  Soil Vapor Extraction in Low Permeability Soils            . •        -     :    '
  Frederick C Payne, ETC Environmental Inc.
  Bioventing in Low Permeability Soils   '    ...        :   .            . .
  Robert Hinchee,Parsons Engineering Science                ':.•'"

  Hydraulic and Impulse. Fracturing for Low_ Permeability Soils
  Larry Murdoch,. University of Cincinnati

  PneumaticFracturingfor Low Permeability. Soils \.                    .   '• .
  John R. Schuring, New Jersey Institute of Technology

  Thermal Technologies in Low Permeability Soils"'.             '''••..   -•   :
  Kent S. Udell, University of California at Berkeley

  Surfactant-Enhanced Soil Flushing in Low Permeability Media
  Thomas M. Ravens and Philip M. Gschwend, Massachusetts Instituteof
  Technology             .

  Mixed Region Vapor. Stripping and Chemical Oxidation for In-Situ Treatment Of
  NAPLS in Low Permeability Media        ..'.•-    .      ,   •   • ' '•.    ..•".•
  R. L. Siegrist, O. R. West, and D. D. Gates
  Oak Ridge National Laboratory

  Modeling Issues Associated with Fractured Media                     -'..''..
  Marian W.Kembiowski,HydroGaia Inc.

  To order this publication (Order No. 146310), call (202) 682-8375 or Fax
  (202) 962-4776. Price: $40.00. API members receive 20% discount on
  orders. '•''-..   ...••'--•'        .     ' •   "••  '"   : '
                                                                                                          29

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LUSTLine Bulletin 25
                                             Subcommittee
  Coast to Coast is provided as a regular feature of LUSTLine to update state and federal UST, LUST, and cleanup
  fund personnel about the activities of the Association of State and Territorial Solid Waste Management Officials'
  (ASTSWMO) Tanks Subcommittee. If you want to learn more about the Tanks Subcommittee, contact the Subcom-
  mittee Chair, Scott Winters (CO) at 303/620-4008, or Stephen Crimaudo (ASTSWMO)jit 202/624-5828.
  Tanks Subcommittee
  Chuck Schwer, Vermont Depart-
  ment of Environmental Conserva-
  tion,  received  a  Certificate  of
  Appreciation from ASTSWMO at its
  annual meeting in October in Wash-
  ington/ D.C. Chuck received the
  tribute in recognition of his continu-
  ing efforts to compile the informa-
  tion and data for the State Cleanup
  Funds Task Force's Annual  State
  Fund  Survey.  The latest  survey
  results (June 1996) contain five
  tables: Design  Characteristics of
  State  Financial  Assurance Funds,
  Funding for State Financial Assur-
  ance Funds, Level of Activity in
  State  Financial  Assurance Funds,
  Cost Control Measures and Man-
  agement Practices Used by  State
  Financial Assurance Funds, and a
  State Fund Legislative Update. Con-
  gratulations Chuck!
      The Subcommittee and  all of
  the Task Force groups completed
  work on a "report card" question-
  naire  on the Federal UST/LUST
  program. The group decided there
  was a need to demonstrate the
  scope and effectiveness of the fed-
  eral and state UST/LUST programs.
  Much of the  data that will be
  included in the report card will
  derive from USEPA STARS data
  and the State Financial Assurance
  Fund survey conducted by the Ver-
  mont DEC. To complete this effort,
  however, additional  information
  will be needed. Hence, report card
  questionnaires  were  sent out to
  state  and federal officials in early
  December. The recipients of these
  questionnaires  are encouraged to
  submit their responses by December
  17, so that the results and statistical
  information can be compiled for
  presentation at the 1997 UST/LUST
  National Conference, which will be
held in Charlotte, North Carolina in
March.
LUST Task Force
The task force is developing follow-
up reviews on the Lawrence Liver-
more National Laboratory Report on
LUST cleanups in California. The
group  also sent a letter  to  EPA
OUST expressing concerns about the
agency's initiative to change report-
ing requirements for "environmen-
tal indicators." The task force is in
the planning stages of developing an
innovative technology web site to be
housed  on both OUST's  and
ASTSWMO's home pages. Members
of the task force are participating on
an EPA MTBE work group.
     Jeffrey Kuhn, Montana Depart-
ment of Environmental Quality, is
the newest member of the LUST Task
Force.  For more information on
LUST Task Force activities, call co-
chairs Richard Spiese (VT) at (802)
241-3888 or Kevin Kratina (NJ) at
(609) 633-1415.
 UST Task Force
 Members of  the UST Task Force
 worked on completing the UST por-
 tion of the UST/LUST program
 report card.
     For more information on UST
 Task Force activities, call task force
 co-chairs Paul Sausville (NY) at
 (518) 457-4351 or Doyle Mills (KY)
 at (502) 564-6716.
 State Cleanup Funds
 Task Force
 Task force members have completed
 an agenda survey for the next State
 Fund  Administrators Conference
 which will be held in Sacramento,
 California on June 16 - 18. The group
will meet in January to develop an
agenda.
     The task force completed and
mailed out its "Success Stories Com-
pendium," a collection of the state
fund success stories submitted for
"Oscar" awards  by various state
fund programs at the June 1996 State
Fund Administrator's Conference in
Charleston, SC. The Success Stories
Oscar winners were: Iowa for Best
Cost Savings, Minnesota  for Best
Fund For Getting The Job Done,
Vermont for Best Future Planning
Effort, and Washington State for
Best Success With  Stakeholders.
     The task force welcomed three
new  members:  Arthur  Zontini,
Massachusetts Department of Public
Safety; George Matthis, North Car-
olina DEHNR; and Kelly Ward, Vir-
ginia Department of Environmental
Quality. If you have questions or
comments on State Cleanup Funds
Task Force activities, call task force
co-chairs Dan Neal (TX) at (512) 239-
2258 or George Matthis (NC) at (919)
733-1332.
TIE Task Force
The  Training  and  Information
Exchange (TIE) Task Force contin-
ues to  address the training  and
information  needs of  the  state
UST/LUST  programs.  The  task
force has assigned its members to
serve as liaisons to the UST, LUST,
and  State Cleanup  Funds Task
Forces. The  task force has been
assisting with preparations for the
ASTSWMO mid-year meeting in
New Orleans, April 7-9.
     If you have questions or com-
ments on TIE Task Force activities,
please call task force co-chairs Pat
Jordan (WY) at (307) 777-7684 or
Kathleen Galloway (DE) at (302)
323-4588.
 30

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                                                                                          LUSTLine Bulletin 25
 • Qs and As from page 22
    . We received a query from a reader
 who lias the following problem. He owns
 several  hundred tanks  with suction
 pumping systems that have their check
 valves located at the tank top. He has
 attempted to meet leak detection require-
 ments for his  piping by conducting
 tightness  testing every three  years.
 Unfortunately, in many cases, an accu-
 rate evaluation of the piping is not possi-
 ble using traditional test methods that
 pressurize the pipe to conduct the test,
 because many  of the tank  top  check
• valves are leaking product back into the
 tank. Is  there a  method that can be used
 that does not rely on the check valves to
 hold pressure in the piping?
         tracer-based method of pip-
 ing testing is the first solution that
 comes to mind. The tracer technique
 works by inoculating the storage sys-
 tem with a special compound and
 then operating the system normally.
About 2 weeks later, soil gas samples
are taken from around the storage
system to determine whether any of
the tracer compound has escaped
from any portion of the system,
including the piping. This technique
does not rely on the ability of check
valves to hold product in order to
conduct the test.
     Of  course,  alternative  leak
detection methods, such as ground-
water or soil vapor monitoring could
also be used if the environmental
conditions were  appropriate. SIR
would also be an option. Any other
ideas?
    » For tracer-type leak detection test
methods, does the detection of any tracer
outside the tank or piping constitute a
failed test?
     . Yes.
 NEIWPCC has been writing
  and producing LUSTLine
for 11 years, and we're proud
 to announce that NEIWPCC
      is celebrating its
   50th Anniversary as a
   Commission this year.
  1947
                      1997
                                          Fifty Years of Coordinating
                                    Interstate Water Quality Improvement
         EIWPCC
                                            New England Interstate
                                            Water Pollution Control
                                            Commission
                  LU.S.T.L1NE
   Qj  One-year subscription. $30.00.

   Q  Federal, state, or local government. Exempt from fee.
       (If you wish to have LUSTLine sent to your home, please submit your request on agency letterhead.)

   Ul  Please take my name off your mailing list.

   Q  Please send me back issues of LUSTLine. Fill out name and address below - no P.O. boxes.
       Back issues now cost $2.50 per issue or $25.00 for a complete set.
    Name
   Company/Agency,

   Address	
                                Street                        City/Town             State
    Please enclose a check or money order (drawn on a U.S. bank) and made payable to NEIWPCC.
    Send to:  New England Interstate Water Pollution Control Commission
             255 Ballardvale Street, 2nd floor                                 Phone: 508/658-0500
             Wilmington, MA 01887-1013                                    Fax: 508/658-5509
                                                                          lustiine @ neiwpcc.prg
                                                                          www.neiwpcc.org
    We welcome your comments and suggestions on any of our articles.
                                                         ZIP

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                    New and  Recently Revised UST-Related
                                    Publications From API
  4 Publ, 1628, A Guide to the Assessment and Remediation of Underground Petroleum Releases, 3rd Edition, July 1996
  This publication provides a basic overview on proven technologies for the assessment and remediation of petroleum
  releases that may contaminate soil and groundwater. This document is intended as a guide for those who must deal with
  accidental releases arising from the production, transportation, refining, and marketing of liquid petroleum products or
  refined crude oil. It may also be a useful manual for environmental professionals, regulatory agencies, consultants, attor-
  neys, fire marshals, and citizens. Order No.: A16283, Price: $50.00
  + Publ. 1628A, Natural Attenuation Processes, 1st Edition, July 1996
  This publication describes the physical, chemical, and biological processes that decrease the concentrations and, ulti-
  mately, limit the extent of the dissolved plume migrating from a hydrocarbon spill or leak. It focuses primarily on the
  more soluble hydrocarbon fraction that makes up the dissolved plume. Emphasis is given to the biological processes that
  can play a major role in the attenuation of a dissolved plume. Order No.: A1628A, Price $15.00
  *• Publ. 1628B, Risk-Based Decision Making, 1st Edition, July 1996
  This publication describes a risk-based decision-making approach that can be used both to focus remedial measures and
  funds on sites while being protective of human health and the environment (i.e., prioritize) and to facilitate timely closure
  of hydrocarbon-impacted sites. The approach combines the information gathered during a site investigation with data on
  the health effects of the size-related constituents to evaluate whether a particular site requires remedial action. Order No.:
  A1628B, Price $15.00
  4 Publ. 1628C, Optimization of Hydrocarbon Recovery, 1st Edition, July 1996
  This publication addresses the concept of recovery optimization—the achievement of an environmentally sound site clo-
  sure in the approximate time frame for the least cost. This document focuses on site-wide recovery system optimization;
  system designs and operation and maintenance are covered in separate documents. Order No.: A1628C, Price: $15.00
  •*• Publ. 1628D, In Situ Air Sparging, 1st Edition, July 1996
  This publication covers the in situ air sparging process, which can be defined as the injection of compressed air at con-
  trolled pressures and volumes into water-saturated soils. This process is applicable when volatile and/or easily aerobi-
  cally biodegradable organic contaminants are present in water-saturated zones, under relatively permeable conditions.
  Order No.: A1628D, Price: $15.00
  4 Publ. 1628E, Operation and Maintenance Considerations for Hydrocarbon Remediation Systems, 1st Edition, July 1996
  This publication addresses routine operation and maintenance (O&M) procedures, rehabilitation, troubleshooting, and
  comparisons that are useful as guidance in selecting appropriate remediation and. treatment systems for groundwater
  and soil. Order No.: A1628E, Price: $15.00
  Tliess publications can be ordered from: American Petroleum Institute, Order Desk, 1220 L Street, NW, Washington,DC 20005.
  Phone; (202) 682-8375. Fax: (202) 962-4776.
New England Interstate Water
Pollution Control Commission
255 Ballardvale Street
Wilmington, MA 01887
Forwarding and return postage guaranteed.
Address correction requested.
 L.U.S.T. Busier T-Shirts &
         Sweatshirts!
     Tee's: M,L, XL, XXL    $9.00pp
     Sweats: M, L, XL, XXL  $16.50 pp
SWfrf etteek or money order (drawn on U.S. banks only)
    lo: NEIWPCC 255 Ballardvale Street,
       Wilmington, MA 01887-1013

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