New Etvgland Interstate
Water Pollution Control
Commission
255 Ballardvale Street
Wilmington
Massachusetts
O18S7
Bulletin 29
June
1998
LUST.
A Report On Federal & State Programs To Control Leaking Underground Storage Tanks
Command and Control of Vapors
at UST Work Sites
by Deborah Roy
• Jl m itJtin one week, last December in California, explosions occurrei
MWmWWhen all was said and done, one worker had died and three had suffered s,
^f ^f pen. They shouldn't. They needn't. But they do. They happen when people
when site conditions change and the hazards are not recognized.
t two different locat
Tank accidents ap-
n ahurry and cut corners, or
Despite the obvious potential for death from explosion,
severe burns, petroleum or other chemical exposure,
physical injury from heavy equipment, and lacerations
and contusions from flying metal parts, many people who
work around tanks do not, or do not want to, recognize
the ever-present potential for danger. But tank-related
accidents and near misses do, in fact, occur, and
they occur all too often. Unfortunately, there is no
system for recording and maintaining records of the
number of tank-related accidents, deaths, or injuries
in the United States.
The 1998 deadline will certainly
add to the pressure on UST contractors
and inspectors. For this reason, it will be
even more critical for workers to be
properly trained, to have adequate
supervision, and to follow safe procedures. In my experi-
ence, most accidents occur because of poor control of
vapors combined with the introduction of, ignition
sources. In this article, I'll discuss the safe handling of
USTs and control of vapors during removal operations.
• continued on page 2
* ^ * 4*» SJ»*riw««feMJA ^ * -^*
F-rom Out gfjhe jPepths—ASTs
—
^Henry's Law
Enforcement Strategy Samplers
. Coast-to-Cpast ; ,
Enforcement Strategy Survey
HQ Update
EPA's SW-846 Protocols Spark
Uncertainty in the Reid
-------
WSTllne Bulletin 29
• Command and Control of
Vapors at UST Sites from page 1
OSHA Says...
The California explosions resulted in
Occupational Safety and Health
Administration (OSHA) citations
that illustrate the hazards that exist
on UST sites when safety procedures
are bypassed in order to save time.
In both accidents, the tanks had not
been purged of flammable vapors
prior to work, the atmosphere inside
the tanks had not been tested, and
ignition sources had been introduced
inside the tanks. In addition, both
accidents involved tank lining opera-
tions, and some of the workers were
actually in the tanks at the time of
the explosions. Jobs such as tank
cleaning, lining, and interior inspec-
tion involve a number of physical
hazards in addition to the health
effects from flammable liquids.
Since 1987, OSHA has required
that anyone working on a hazardous
waste site have health and safety
training. These requirements involve
40 hours of initial training and an
ne
Ellen Frye, Editor ,:
Jtodki Pappo, Layout ,
•Mured! l^oremt, Ytauiicat Atii>ror/£entributor,
'i Ronald poltak, ^W^CC ^«qA Project Officer
Kate Becker CtuSt Luitsan L
4 a product of the New England
. V
-------
LUSTLine Bulletin 29
Controlling Flammable
Vapors
Flammable substances have a range
of concentrations that will burn
when the other two elements of the
fire triangle (i.e., ignition source and
oxygen) are present. A sufficient con-
centration of vapor to cause a fire or
explosion will occur only if the tem-
perature of the substance is above its
flashpoint (i.e., the temperature at
which a liquid will produce suffi-
cient flammable vapors to support
combustion). For example, gasoline
generates enough vapors to support
combustion at any temperature
above minus 43 degrees Fahrenheit,
its flashpoint. Fuel oil, on the other
hand, has a flashpoint between 110
to 190 degrees Fahrenheit, depend-
ing on the grade of oil.
Flammable vapors may come
from a variety of sources on a tank
removal site. If the tank has leaked,
excavating the contaminated soil will
allow fresh vapor to evolve. Often
the soil will be contaminated from
overfills, even if the tank did not
leak. The tank itself is a source, as is
the piping, even after the product is
removed, because residual product
remains in the pores of the metal,
causing the tank and piping to
regenerate vapors over time. These
vapors can accumulate to potentially
explosive concentrations within the
confined space of a tank or piping.
If not properly positioned, the
vacuum truck used to remove resid-
ual product and vapor from the tank
can also add a significant amount of
vapor to the site. This potential
build-up of vapors is particularly
true if the flammable vapors are
vented at ground level or if they are
vented beneath an obstruction such
as the pump canopy.
In general, the industry stan-
dard is to vent the vapors at least 12
feet above grade and at least 3 feet
above adjacent structures. Some
states have mandated these stan-
dards. If vapors are not properly
vented and/or tall structures sur-
round the site, the amount of vapor
at ground level may accumulate
within the flammable range of the
chemical or petroleum product. Any
ignition source introduced to the site
may then cause an explosion.
Vapor hazards are often made
worse by poor work practices that
allow fresh product to be introduced
into the soil on the tank site. This
occurs when pipes are not properly
drained prior to removal or when a
tank with residual product is further
damaged by the backhoe. Time pres-
sure to finish the operation is often
the cause of these incidents.
Monitoring is often the place in The
«e-T**-# •*=• « v (a
jidpor control procedure where tank
^ workers take shortcuts. It can't lie
" '
emphasized enough, however, that
mper air monitoring is the only way
l£Lto determine it atmospheric I
ir * hazards exist.
Purging and Inerting Vapors
Control of vapor sources from the
tank itself is accomplished by purg-
ing or inerting the tank. This proce-
dure varies depending on state or
local codes or on local tradition. A
few states, including Maine, allow
tanks to be removed while they are
"overrich" (i.e., when vapor levels
exceed the upper explosive limit; see
LEL discussion below). This practice
is not recommended but is becoming
more common as the 1998 tank
removal deadline looms.
Purging involves ventilating
the tank and diluting the flammable
vapors with air. This procedure
reduces the fuel component of the
fire triangle. Even though the oxygen
and ignition components may still be
present, fire or explosion will not
occur. The two common methods of
purging involve the use of a dif-
fused-air blower or an eductor-type
air mover. Either method requires
bonding the pipe to prevent static
buildup. It is important to always
remember that purging is a temporary
method of reducing flammable
vapors. Sludge and product trapped
in the tank pores will eventually
evolve more vapors.
Vapor buildup is a particularly
important consideration when a tank
is removed and left on a trailer for a
period of time or moved a distance
to a tank yard. In fact, tanks should
be considered to be "time bombs"
during all phases of any tank
removal operation.
Inerting involves reducing the
concentration of oxygen by replacing
it with an inert gas such as carbon
dioxide or nitrogen. This method
eliminates the oxygen element of the
fire triangle, leaving the fuel and
ignition elements, which cannot, by
themselves, support combustion.
During the inerting procedure,
carbon dioxide gas is generated
through the use of dry ice, which
should be distributed evenly in the
bottom of the tank. The dry ice
releases carbon dioxide as it warms.
The amount needed is usually 15 to
20 pounds per 1,000 gallons of tank
capacity. For example, a 10,000-gal-
lon tank will require at least 150
pounds of dry ice to be properly
inerted. Carbon dioxide inerting
takes longer than some other meth-
ods because there is no additional air
movement in the tank. Tank workers
frequently underestimate the
amount of dry ice or try to speed up
the process. Monitoring the air in the
tank is the only way to tell if the tank
is safe to handle.
Nitrogen gas can also be used
to inert a tank. Using nitrogen
involves placing a hose in the tank
and pumping the nitrogen gas into
the bottom of the tank. Bonding and
grounding of the cylinder nozzle is
needed to prevent static buildup.
This method may be quicker than
using dry ice, but air monitoring is
still needed to determine if the oxy-
gen has been sufficiently removed.
As with purging, inerting is a
temporary method of making a tank
safe. If there are holes in the tank,
oxygen may be reintroduced and an
explosion could occur. The reintro-
duction of vapors is a particularly
important consideration when a tank
is removed and left on a trailer for a
period of time or if it must be trans-
ported long distances to a tank yard.
Monitoring the Atmosphere
To determine if the tank is safe to
handle and the site is safe for work-
ing, the air, both inside and outside
the tank, must be monitored. Moni-
toring is often the place in the vapor
control procedure where tank work-
ers take shortcuts. It can't be empha-
sized enough, however, that proper
air monitoring is the only way to
determine if atmospheric hazards
exist. The concentration of vapor
cannot be determined by odor.
• continued on page 4
-------
LUSTLi>te Bulletin 29
• Command and Control of
Vapors at UST Sites from page 3
There are two types of mea-
surements, depending on whether
the tank has been purged or inerted:
lower explosive limit (LED and oxy-
gen concentration. Both can be mea-
sured by using a combustible gas
indicator, or detector, which has sep-
arate sensors that read oxygen and
The key is to remember which ele-
ment of the fire triangle is affected.
For purging, the fuel concentration is
reduced. This means that the air
monitoring measurement should test
for flammable vapor levels in the
tank. The LEL sensor on the com-
bustible gas indicator will test for
vapor concentration. This level needs
to be below 20 percent. Some con-
tractors will continue purging until
FLMMABLE RANGE OF GASOLINE
LOWER EXPLOSIVE LIMIT (LEL) UPPER EXPLOSIVE LIMIT (UEL)
1.4% (% concentration by volume in air) 7.6%
I too few
10%
DANGER ZONE
100% of LEL
1,400 ppm 14,000 ppm
76,000 ppm
LEL (and sometimes other sub-
stances) independently. Oxygen is
measured based on the percent by
volume in air. Normal air has
approximately 21 percent oxygen.
Levels below 11 percent oxygen will
not support combustion.
Explosimeters should never be
used to measure oxygen when a tank
is being inerted. Keep in mind that
11 percent oxygen is needed for an
explosimeter to work. If oxygen is
reduced because carbon dioxide or
nitrogen have been added, the meter
will not work properly.
The LEL is based on the flam-
mable range of the substance. For
example, gasoline has a flammable
range of 1.4 to 7.6 percent by volume
in air. The LEL on the combustible
gas indicator is based on 0 to 100 per-
cent of the bottom of the flammable
range, so for gasoline 10 percent of
the LEL would be 0.14 percent by
volume in air. This would translate
to 1,400 parts of gasoline per 1 mil-
lion parts of air. According to the
OSHA standard, the safe level for
tank work is below 20 percent of the
LEL. Many contractors do not con-
sider a tank safe to work with until
readings are are 10 percent of the
LEL. The API recommended practice
1604 (1996 edition), Closure of Under-
ground Petroleum Storage Tanks,
requires readings of 10 percent of the
LEL for tank work.
Tank workers are often con-
fused about which meter to use for
purging or inerting, oxygen or LEL.
the LEL is below 10 percent. If work-
ers must enter the tank, the LEL
must be below 10 percent according
to the OSHA confined-space entry
standard.
Inerting, on the other hand,
deals with removing the oxygen ele-
ment of the fire triangle. Therefore,
to determine if the tank is safe, you
must measure for oxygen. Most con-
tractors will inert a tank until the
oxygen level is 0 to 8 percent by vol-
ume in air.
The combustible gas indicator
needs to be calibrated every day
prior to its use. Between readings on
the site, move it away from the vapor
hazard area to fresh air in order to
clear the instrument. Do not use the
combustible gas indicator to test a
tank that is full of gasoline because
doing so will poison the LEL sensor
and damage the instrument.
Although it is not recom-
mended, moving a tank to a remote
site in an overrich condition for clean-
ing is sometimes done. If so, a differ-
ent meter is needed to determine if
the concentration in the tank is above
the upper explosive limit (UEL). This
meter is a type of combustible gas
indicator called a Gascope. It reads
the flammable vapor levels in percent
by volume. For gasoline, the UEL is
7.6 percent. The safe level for trans-
porting a tank in'an overrich condi-
tion has not been documented. If
done, however, be sure that the tank
is at least 15 percent by volume in air
prior to transport.
Looking Ahead
Working with underground storage
tanks can be dangerous, but there are
procedures that can make the
process safer. Control of ignition
sources, control of flammable
vapors, and use of proper air moni-
toring equipment are important tools
for achieving a successful tank
removal. Other hazards, such as
exposure to chemicals, confined-
space entry, and accidents associated
with careless use of heavy equip-
ment also need to be understood.
We'll touch on more of these topics
in future issues of LUSTLine. •
Deborah Roy, MPH, KN, COHN-S,
GET, ASP, is President ofSafeTech
Consultants, Inc., in South Portland,
Maine. For more information, contact
Deborah at (e-mail) info@stci.com.
For More Information
About Safety During
UST Removal...
OSHA Standards
• 29 CFR 1919.120 Hazardous Waste
Operations and Emergency Response.
• 29 CFR 1910.146 Permit-Required
Confined Spaces.
American Petroleum Institute
(API) Recommended Practices
• Safe Entry and Cleaning of Petroleum
Storage Tanks, API 2015 (May 1994).
Price: $70.
• Closure of Underground .Storage
Tanks, API 1604 (1996). Price: $40.
Order from: American Petroleum Insti-
tute, Order Desk, 1220 L Street, N.W.,
Washington, D.C. 20005, (202) 682-
8375.,,
Tank Closure Without Tears—
An Inspector's Safely Guide
(Video and Booklet)
Developed to train inspectors, this
video provides a general overview of
safety procedures and issues associ-
ated with tank closure, including what
causes fires and explosions, preparing
a safe workplace, preparing the tank,
getting rid of flammable vapors, clean-
ing out sludge, closing in place, and
tank disposal. The video is 30 minutes
long; the booklet is 20 pages. Price: $35
for video and booklet; $15 for loan; $30
for video; $5 for booklet.
Order from: New England Environmen-
tal Training Center, 2 Fort Road, South
Portland, ME 04106. (207) 767-2539.
-------
LUSTLine Bulletin 29
From Out of the Depths...
Aboveground Fuel Storage Systems Take Off Running
by Wayne Geyer
M
uch of LUSTLine has cen-
tered on the subject of leak-
,ing underground storage
tanks. Over the past six years or so,
however, we have noted an increas-
ing use of aboveground storage
tanks (ASTs) to store hazardous and
combustible liquids. AST systems
have been the choice at many gov-
ernment facilities, military bases,
schools, hospitals, and private fleet
fueling facilities, and for storing
chemical/industrial liquids.
The ASTs to which I refer are
not those clusters of vertical tanks
often seen at bulk storage facilities,
isolated far away from buildings and
human activity. Rather, today's most
common AST applications consist of
one or two horizontal tanks placed
within 25 feet of important build-
ings, property lines, or public ways.
While many of these horizontal
ASTs are cylindrical, some have
more rectangular configurations. The
flat tops of rectangular tanks provide
more flexibility in locating the
numerous fittings and components
required for safe and proper opera-
tion. Maintaining these components
is easier, as is accessing the fill open-
ing, because the awkwardness of
climbing ladders and balancing on
catwalks is alleviated.
Most of these tanks are small—
2000-gallon capacity or less. Steel
Tank Institute (STI) statistics over the
past several years indicate that the
average tank size is approximately
3,500 gallons. This is significantly
smaller than the 10,000- to 12,000-
gallon UST typically installed at
retail service stations.
Our statistics also show that
Class II combustible liquids (e.g.,
diesel fuel) account for nearly two-
thirds of the AST applications. The
least common AST application, retail
service stations, accounts for less
•than 3 percent of AST purchases
from STI Members.
The Fire Code Wake-Up Call
Using ASTs to store motor vehicle
fuel at private fueling facilities has,
without a doubt, been the most sig-
nificant new trend. Prior to 1992-—
prompted by several catastrophic
fires back in the 1960s and early
1970s—the fire codes either
restricted or prevented this type of
usage, except in the case of smaller
tanks in rural areas. Also, ASTs were
occasionally overfilled, increasing
the likelihood of a surrounding pool
fire. Furthermore, if the tanks were
not properly equipped with emer-
gency vents, the flammable liquid
would quickly vaporize inside the
tank during a fire, leading to oyer-
pressurization. Because these tanks
were designed for atmospheric pres-
sure only, excessive pressure could
cause the tank heads to eject out-
ward, like a missile.
As media attention focused on
USTs, release detection, tank
"testing™and expensive soil and
groundwater cleanup efforts,
aboveground storage provided an
• attractive alternative.
Nevertheless, in the early 90s,
tank owners seeking alternatives to
underground tank storage began
installing more aboveground
tanks—even with the code limita-
tions. As media attention focused on
LUSTs, release detection, tank
testing, and expensive soil and
groundwater cleanup efforts, above-
ground storage provided an attrac-
tive alternative. Tank owners could
visually examine their storage sys-
tem for releases, without the addi-
tional worry of UST financial
responsibility. Some states began to
consider legislation that would allow
ASTs at fueling facilities in an effort
to balance both tank owner and envi-
ronmental concerns.
This wave of interest in ASTs
was the wake-up call in the fire code
arena;
fire pre-
vention
associa- ^_^
tions sought
to follow the same track in writing
codes for aboveground storage tanks
as they did for underground installa-
tions.
Code Evolutions
The National Fire Protection Associ-
ation's (NFPA's) Automotive and
Marine Service Station Committee
modified NFPA 30A with a Tenta-
tive Interim Amendment (TIA) in
1992. The TIA provided code lan-
guage for the safe installation of
ASTs in a concrete vault or room.
Each vault, whether below or above
grade, enabled detection of liquids
and vapors, allowed personnel
access for physical inspection of the
tank walls, and provided means to
remove water and flammable liq-
uids. For more hazardous Class I liq-
uid (gasoline) storage, the code
required a ventilation system within
the vault.
By 1993, both the Uniform Fire
Code and NFPA 30A had expanded
or created means for aboveground
storage of motorized fuels, in capaci-
ties of up to 10,000 or 12,000 gallons.
The Building and Officials Code
Administration's National Fire Pre-
vention Code and the Southern
Building Code Congress Interna-
tional's Standard Fire Prevention
Code followed suit shortly there-
after. The Uniform Fire Code, which
strictly prohibited this type of usage
prior to 1993, added Appendix II-F
to provide local jurisdictions with
the option of allowing ASTs for fuel-
ing vehicles. The UFC required tanks
be secondarily contained and insu-
lated to meet a 2-hour fire rating. The
NFPA allowed single-walled tanks
in dikes, secondary contained tanks,
or fire-resistive tanks. The fire-resis-
tive tank could be installed closer to
a building than the traditional UL
• continued on page 6
-------
llKTUm Bulletin 29
I ASTs frontpage 5
142 tank. NFPA has also increased
the allowable AST storage capacities
to 20,000 gallons at nonretail diesel
dispensing facilities.
The codes have a number of
requirements designed to prevent
releases from ASTs—secondary con-
tainment is one consideration. How-
ever, because fire prevention is best
addressed by simply eliminating the
chance of a release, preventing over-
fills during deliveries was a high
code priority. Obviously this concept
is not much different from the phi-
losophy of preventing releases from
UST systems. The codes generally
require three controls: 1) a gauge on
the tank, 2) an audio and/or visual
high-level alarm, and 3) an auto-
matic shut-off device.
The codes also require anti-
syphon devices, openings only at the
top of the tank, thermal expansion
relief devices, and emergency vent-
ing of the primary tank and all sec-
ondary containment areas. As stated
earlier, the emergency vent is the
most important device should a fire
occur, regardless of whether the tank
is fire-protected. Tank owners must
make sure that both emergency and
normal vents are operable and main-
tained...always!
By the way, the goal in pointing
out these code changes is give you an
idea of how the industry has evolved
and continues to evolve in terms of
accommodating ASTs. If you really
need to know the specifics about a
particular code, you'll need to roll
your sleeves up and dig into the code
itself.
New Fabrication Standards
Along with the code changes, fabri-
cation standards also experienced
significant activity. Underwriters
Laboratories increased the length of
its UL 142 standard covering storage
of flammable liquids in aboveground
tanks by two- or threefold. New lan-
guage to cover secondary contain-
ment tanks, steel-diked tanks, and
rectangular tanks was added. UL
also introduced a new standard for
insulated tanks in December 1994.
The standard covered 2-hour fire
testing of both UFC-mandated "pro-
tected tanks" and NFPA-optioned
"fire-resistant tanks." On December
30,1997, UL released the second edi-
tion of UL 2085 for protected tanks
only and a UL 2080 outline for fire-
resistant tanks. In addition, UL has
issued an outline UL 2245 for below-
grade vaults.
Insulated tanks come in various
forms, but presently three designs are
the most common: one that places the
insulation between two walls of steel;
one that places a steel tank within a
concrete encasement; and a third that
places a plastic membrane over the
steel tank and encases the entire
assembly in concrete.
The most recent standard
development came in October 1997,
when UL provided its first two list-
ings to a new UL standard—UL
2244. This standard covers complete
factory-assembled AST systems. In
other words, all important core com-
ponents of a tank used for motor
vehicle fueling, aviation fueling, gen-
erator tanks, and so on are evaluated
"MOTOR;VEHICt£:FUELLDJSPENSING SYSTEM TOP FILL AND, WITH SIRE-iyiQUNIEB: PJIElMiiB:,:
FLAME ARRESTER
(OPTIONAL)
•LIQUID LEVEL GAUGE
iCHANICAL OR AUTOMATIC)
SPILL CONTAINMENT
FILt PIPE-LOCKING
£"£151810 XTAL& EMERGENCE VENT
OR SOLENOID VALVE SECONDARY TANI
BLOCS VALVE «•»««
TAW
StCONOASIU CONIAINEI
* SUWOfll—S /
,t CONTAINED TANK—'
^—LIQUID SENSI
5/D£ VIEW
NOT TO SCALE
SB
Steel
Tank
Institute
Today's AST Is no longer Just a simple steel cylinder. A properly engineered system includes a great many environmental and safety components.
-------
LUSTLine Bulletin 29
by UL at the factory prior to ship-
ment. The goal is to remove the con-
cerns that authorities having
jurisdiction (AHJs) might have about
missing emergency vents and other
accessories that prevent releases and
system failure during fires. After all,
what good is a 2-hour fire-rated tank
if important components are not
attached? The merits and drawbacks
of a systems concept are still being
debated.
The Steel Tank Institute has
also developed several important
new AST standards over the past
several years: the F911 steel dike
AST, the F921 double-walled AST,
and the F951 protected aboveground
secondary containment tank (called
"Fireguard"). STI statistics show a
tremendous growth rate in F921 and
Fireguard tank installations. In 1997
alone, the 64 shops eligible to build
Fireguard tanks increased their pro-
duction by approximately 40 percent
over 1996.
The inclusion of secondary con-
tainment for ASTs has justifiably
received a great deal of attention
lately. In 1991, EPA proposed an
amendment to the SPCC (Spill Pre-
vention Control Countermeasure
Plan) requirements for ASTs suggest-
ing that secondary containment be
impermeable for 72 hours. This pro-
posal, coupled with the fire code
activity, has created a tremendous
demand for aboveground tanks with
built-in secondary containment. These
tanks can take the form of integral
dikes, double-walled construction, or
insulated tanks with secondary con-
tainment. The NFPA Flammable and
Combustible Liquid Code, NFPA 30,
allows any tank 12,000 gallons and
under with overfill prevention devices
and emergency venting devices to be
secondarily contained, as an alterna-
tive to a traditional dike. Today,
nearly one-third to one-half of STI
member-labeled ASTs are being built
with secondary containment. Com-
pare this to 10 years ago, when that
statistic was closer to 0 to 5 percent.
Other Considerations
Finally, I should mention some basic
installation requirements. Tanks
must be installed on a firm founda-
tion. In areas prone to flooding or
earthquakes, tanks may require fur-
ther anchoring (or seismic considera-
tions) in accordance with local fire or
building codes. When tanks arrive at
a site, the NFPA 30 code requires that
both primary and secondary contain-
ment tanks be tested to ensure that
tank system integrity has remained
intact throughout shipment.
Piping considerations are
another big factor. Many AST motor
vehicle fueling facilities do not
require underground piping, as the
dispensers are mounted directly atop
or to the side of the protected tank.
While eliminating another cause of
release common to old UST systems,
aboveground piping must be pro-
tected against potential damage by
vehicular impact at fueling facilities.
Aboveground tanks do have
their pitfalls, however. More mainte-
nance is required to keep the tank
aesthetically acceptable, such as
painting steel or patching cracks in
the concrete. Evaporation and con-
densation are a bigger factor in
aboveground storage tanks. The
operator needs to check for water at
the bottom of the tank on a monthly
basis, and all water should be
removed. Also, Stage II vapor recov-
ery can sometimes be a problem.
Spill prevention plans are
required for aboveground storage
tank systems larger than 660 gallons
that are located such that a release
into a navigable waterway can
potentially occur. Also, the tanks
must be protected from vehicle
impact. Extra security measures (e.g.,
a fence enclosure) are necessary to
guard against vandalism.
In Summary...
Motor vehicle fuel storage systems
are no longer confined to the under-
ground. Existing model fire codes
have been changed to allow above-
ground fuel storage. A number of
third-party listed AST construction
options exist for dispensing motor
vehicle fuels. Secondary containment
and other important environmental
and safety appurtenances are now
incorporated into tank designs.
As with any growing market,
new technologies and new listings
are being introduced to expand
safe and environmentally-friendly
options available to buyers and users
at retail operations. The nonretail
sector of tank system operators who
store motor vehicle fuels has chosen
ASTs over USTs because of conve-
nience, cost, and the ability to see the
tank at all times. •
Wayne Geyer is Executive Vice Presi-
dent/or the Steel Tank Institute. For
more information about ASTs, contact
Wayne at (847) 438-8265 or at
wgeyer@interaccesses.com
An AST imparts a marine ambiance in coastal Maine.
ipsr"* *T^T^K\J "~~^*** ~~*°^~3^~~*~5S;|pfiS^^fe^^
tyou ttooe any UST/LUST-fela&l snapshots from the field that you would
shat^witit Qurjceffders, please send them to Ettenfrye c/o NEIWPCC.
'
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LUSTLmeBtttkiin29
itIcaffy Speaking
by Marcel Moreau
I'n Marcel Moreau is a nationally
recognized petroleum storage specialist
whose column, Tank-nically Speaking,
is a regular feature ofLUSTLine. As
always, we welcome your comments and
questions. If there are technical issues
that you would like to have Marcel
....: dzscwss,let us know.
Of Blabbermouths and
Tattletales
The Life and Times of Automatic Line
Leak Detectors
Automatic Line Leak Detectors = Devices that alert the operator to
the presence of a leak by restricting or shutting off the flow of a substance
through piping or by triggering an audible or visual alarm. According to the
federal rule [40CFR280.44(a)], a device used to meet this requirement must
detect leaks of 3 gallons per hour at 10 pounds per square inch line pressure
within 1 hour. An annual test of the operation of the leak detector must be
conducted in accordance with the manufacturer's requirements.
An Antidote to Pressurized
Piping Leaks
With a history going back to the late
1950s, the automatic line leak detec-
tor (ALLD) is probably the grand-
mother of all the "continuous" type
of leak detection devices on the mar-
kot today. ALLDs were developed
not too long after submersible
pumps began to be commonly
used—an indication, perhaps, that
the increasing use of pressure rather
than suction to move product from
underground tanks into motor vehi-
cles had intensified the severity of
piping leaks.
While line leaks in suction
pumping systems certainly existed,
they tended to be self-limiting; if the
leak got too bad, the pump would
cease to function. Even small leaks
would cause noticeable interference
with the fuel delivery operation and
thereby alert the operator.
Although pressurized pump-
ing systems had operational advan-
tages, such as simplified piping and
the absence of vapor lock (see LUST-
Line #10, "Pumping Product—The
Push Ups vs Pull Ups of Product
Delivery Systems—Implications for
Environmental Health"), they had a
definite downside in terms of leaks.
Because the piping operated under
25 to 30 pounds of pressure, leak
rates from even small holes
increased substantially over those in
suction pumping systems. To com-
pound the problem, there were no
indications of a problem at the dis-
penser, so the operator had no way
of knowing (except through inven-
tory control) that there might be a
piping leak.
Following the popular accep-
tance of the submersible pumping
system, the industry developed a
device that would automatically
detect leaks in pressurized pumping
systems. In one early ad, this new
device was dubbed the "blabber-
mouth" because it would quickly
"snitch" on a leaking pipe.
Over the years, a few refine-
ments to the leak detector were intro-
duced that shortened the time it took
to complete the test of the piping
from 5 seconds to 2 and added a
chamber to help compensate for
thermal contraction effects, but the
basic operation of the mechanical
device has remained unchanged to
this day.
Meanwhile, back at the fire sta-
tion, the fire codes recognized the
potential
hazards
posed
by pres-
surized
piping
systems
and began
mandating the use
of line leak detectors long before
they became an EPA requirement.
The codes included a requirement
that the devices be tested at least
annually to ensure that they were
functioning properly. Despite this
requirement, ALLDs were often
absent from pressurized pumps;
most owner/operators did not test
for proper operation on an annual
basis. The inclusion of these require-
ments in the federal rule, however,
resulted in significantly increased
use of ALLDs...and many are even
tested on an annual basis.
The Mechanics of a MALLD
The mechanical ALLD (MALLD) is
basically a pressure-operated valve.
The top of the MALLD contains a pis-
ton or diaphragm that is connected to
a rod that controls the flow of prod-
uct by operating a valve mechanism
at the bottom of the device. The valve
has three positions: wide open (full
flow), test (flow limited to 3 gallons
per hour), and restricted flow or
8
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LUSTLine Bulletin 29
"tripped" position (flow limited to 3
gallons per minute).
A spring inside the stem of the
MALLD pushes down on the control
rod, continually attempting to move
the valve into the restricted flow posi-
tion. Pressure produced by liquid in
the piping system pushes against the
piston or diaphragm inside the top of
the MALLD, compressing the spring
and keeping the valve open. Inside
the MALLD, there is a continual tug-
of-war going on between the spring
that wants to close the valve and the
liquid pressure that wants to keep the
valve open. Let's look at who wins
this tug-of-war under various operat-'
ing conditions.
What happens when all is well?
In a pressurized piping system, the
pump develops about 25-30 pounds
per square inch when it is operating
and delivering fuel. When the pump
motor is turned off, pressure in the
line is reduced to the "catch" pres-
sure of a pressure relief valve that is
incorporated in the submersible
pump. If the piping is tight, the catch
pressure is maintained in the pipe
until the pump is turned on again. In
this case, the liquid pressure wins
the tug-of-war, the spring stays com-
pressed, and the valve remains open.
What happens when there is a leak?
In a leaking pressurized piping sys-
tem, the pressure in the piping will
continue to drop below the pressure
relief valve "catch" pressure as prod-
uct leaks out of the piping. The rate
of pressure decline depends on the
size of the hole, but it is also a func-
tion of how rigid the piping system
is. A steel piping system is quite
rigid, so a small loss of liquid from
inside the pipe will produce a large
pressure drop.
Flexible piping systems are
generally much more "stretchy" than
steel. As the flexible piping is pres-
surized, it stretches, and as pressure
is reduced, the flexible piping tends
to contract—much the same way
(although to a lesser degree) as a bal-
loon expands when air is blown in
and contracts when air is removed.
When liquid leaks out of flexible pip-
ing, the piping contracts somewhat,
maintaining some of the pressure in
the pipe.
Thus, for a given leak rate, the
pressure will drop precipitously in
steel piping and more slowly in flexi-
ble piping. The point is, however, in
both cases the pressure will drop to
very low levels if the piping is not
liquid-tight. This sets the stage for
the spring to win the tug-of-war and
move the valve mechanism to the
restricted flow position.
How the MALLD responds...
When the pressure in the piping
drops below a threshold pressure,
the spring in the MALLD takes con-
trol and moves the valve past the test
position and into the restricted-flow
position. Different manufacturers of
MALLDs have different threshold
pressures, but they are all in the
range of a few pounds.
The MALLD stays in this
restricted-flow, or "tripped," posi-
tion, waiting for the next customer to
come along and turn on the pump.
When the pump is turned on, the
flow through the MALLD is
restricted to about 3 gallons per
minute. Unless there is a leak in the
piping that is greater than 3 gallons
per minute, this flow into the piping
system will increase the pressure in
the line. This increase in pressure
will press against the piston or
diaphragm of the leak detector and
begin to move the control rod that
activates the valve mechanism. At
about 10 pounds per square inch of
pressure in the line, the control rod
will have moved the valve mecha-
nism into the "test" position. In the
test position, the flow into the piping
system is reduced dramatically to 3
gallons per hour.
...To a false alarm.
If the leak detector has been tripped
because of a false alarm (see below)
and the piping is tight, this small
flow of liquid into the piping will
continue to increase the pressure in
the line. At a few additional pounds
of pressure, the valve mechanism
moves past the test position and into
the wide-open position, where the
dispensing of product can proceed
unimpeded. The time required to go
from the tripped position through
the test cycle and into the open posi-
tion is about 2 seconds.
...To a leak of 3 gallons per hour or
more.
If the piping has a leak of greater
than 3 gallons per hour, the 3 gallons
per hour of liquid flowing past the
leak detector into the piping will
flow out of the pipe as fast as it is
coming in. The pressure in the piping
will not increase, and so the valve
mechanism will not move out of the
3-gallon-per-hour test position.
Now, keeping in mind that the
reason the pump was turned on in
the first place was to dispense fuel,
we turn to the customer, who opens
the nozzle in anticipation of pump-
ing some product at a flow rate of 10
gallons per minute. If the leak detec-
tor is still in the test position, how-
ever, this will not happen. With the
nozzle open, whatever pressure was
in the piping is now lost, the leak
detector valve returns to its
restricted-flow position, and the cus-
tomer receives a flow of 3 gallons per
minute. It is this reduced flow rate
that is supposed to be noticed by the
customer and reported to the station
attendant (assuming a self-service
type of operation).
...To smaller leaks.
For leaks of less than 3 gallons per
hour or for flexible piping systems,
the time required for the leak detec-
tor to go through the test phase and
reach the wide-open flow position
will be longer than 2 seconds. But if
enough time is allowed, the piping
should be able to build enough pres-
sure to move the leak detector into
the wide-open flow position.
Whether a customer experiences
restricted flow will depend on the
length of time between when the
pump is turned on and when the
customer opens the nozzle.
A Few Rubs
A number of factors can cause MALLDs
to restrict flow when a leak is not present
(i.e., false alarm):
• Malfunctioning check valves
The valve mechanism in the sub-
mersible pump that retains prod-
uct in the line between the times
when customers pump product
can leak. This is not a leak into the
environment; rather, the product
merely returns to the under-
ground tank. The loss of product
in the line, however, will cause the
leak detector to trip, and it may
take many seconds to refill the
line, greatly increasing the likeli-
hood that the customer will have
opened the nozzle and, thereby,
set the MALLD in the restricted
flow position.
• continued on page 10
-------
UJSTUm Bulletin 29
• Tank-nlcalty Speaking from page 9
» Thermal contraction
In cold climates, the ground tem-
perature around the piping is
often significantly colder than the
ground temperature around the
tank. As a result, relatively warm
product flows into the piping.
When it is allowed to sit, espe-
cially overnight, it cools and
contracts. This reduction in tem-
perature can reduce the pressure
in the line and trip the ALLD.
* Air pockets
Air pockets in the piping intro-
duce "springiness" into the piping
system, because the air is very
compressible. As a result, it will
take more product (and therefore
longer time) for the MALLD to
move from the tripped to the open
position.
Tltere are also some factors that can
cause MALLDs to miss leaks:
• Excessive height of the piping
In order to move into the tripped
position, the pressure at the
MALLD must drop to a threshold
pressure that can be as low as
1 pound per square inch. A col-
umn of product about 3 feet high
is sufficient to produce a pressure
of about 1 pound per square inch
at the bottom of the column.
Let's say, for example, there is
a 4-foot height differential
between the MALLD and the dis-
penser shear valve. In order for
the MALLD to trip and conduct a
leak test, the height of the product
would have to drop about 1 foot
below grade. If the leak is at the
shear valve, however, the piping
below the shear valve will remain
full of product, the hydrostatic
pressure at the MALLD will never
go below the trip pressure, and
the leak will never be detected. In
the old days, deep burial of tanks
was quite uncommon, but now
that we are paying more attention
to piping slope, particularly with
Stage II piping, MALLD burial
depths can sometimes be well
below 3 feet.
* Mechanical wear
The tolerances in the valve mecha-
nism of the MALLD are quite fine,
but as the device wears, these tol-
erances tend to become less fine
(i.e., greater). The result is that as
the MALLD ages, the minimum-
size leak that it will detect tends to
increase.
Sticking
Because the MALLD is mechani-
cal, it relies on the physical move-
ment of parts to detect the leak. If
piping is tight and pressure is
always maintained in the line, the
mechanism of the MALLD may
move little or not at all for months
or even years on end. Deposits can
build up on moving parts, tending
to lock them in place. The result is
that when a leak does develop, the
MALLD fails to respond.
Satellite dispensers
In this era of self-serve gasoline
dispensing, there is a remotely
operated solenoid valve located in
the dispensers and controlled by
the cashier. This valve is often pro-
grammed to remain closed until
after the MALLD has completed
its test to prevent false alarm when
a customer opens the nozzle while
the MALLD is still looking for
leaks. As a result, leaks down-
stream of the solenoid valve are
invisible to the MALLD. In normal
dispensers, such "invisible" leaks
are not a big problem, because all
of this piping is above ground, and
leaks can be discovered visually.
However, many large truck
fueling facilities have what are
known as satellite dispensers that
allow the driver to fuel tanks on
both sides of the truck at the same
time. The satellite dispenser is
essentially another hose that is
routed from the master dispenser
to a nozzle about a dozen feet
away. The routing of this "hose"
is typically underground, and typ-
ical piping materials (e.g., FRP,
flexible pipe) are used.
In older model satellite dis-
pensing systems, the piping that
branches off to the satellite dis-
penser is typically downstream of
the solenoid valve. Because of
this, leaks in piping that goes to
the satellite dispenser are not
detected by the MALLD. A possi-
ble solution to this problem is to
add a dispenser-mounted elec-
tronic line leak detector to moni-
tor just the satellite piping.
Newer model master/satellite
dispensers incorporate two sole-
noids—one in the master and one
in the satellite. In this configura-
tion, the satellite piping branches
off from the master dispenser at a
point that is upstream of the sole-
noid in the master dispenser. This
dual solenoid system does allow
the satellite piping to be tested by
the line leak detector.
• Lack of pump cycling
In the vast majority of fueling
facilities, the pump motor is
turned off most of the time and
operates only while fuel is being
dispensed. This cycling of the
pump motor is essential to the
operation of the MALLD. How-
ever, there are a few facilities that
I've heard about where, for vari-
ous reasons, the pump motor is on
continuously for long stretches of
time. At this type of facility, the
MALLD fails to meet the regula-
tory criteria for detecting a leak
within 1 hour, because the pump
may be on continuously for days
or weeks; until the pump is turned
off and then restarted, any leak of
any magnitude will not be
detected by the MALLD.
• The human element
Historically, the restriction of flow
produced by the leak detector was
often dismissed as a problem with
the leak detector, because the prob-
lem went away when the leak detec-
tor was removed (and, all too often,
not replaced). Even today, knowl-
edge of the meaning of restricted-
flow rates is not universal.
For example, I was fueling up
in northern New Mexico not too
long ago and noted that it took a
very long time to complete my
purchase. When I mentioned this
to the attendant, his response was,
"Oh yeah, that pump always runs
slow." Admittedly, clogged fuel
filters in dispensers, malfunction-
ing pumps, and partially closed
shear valves can all produce
symptoms of restricted flow, so
this condition is not a conclusive
indication of a leak, but it is also
not a condition that should be
accepted as normal.
The Electronics of EALLDs
Over the past decade, the emphasis
on leak detection in piping created
by the federal rule has spurred the
10
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LUSTLme Bulletin 29
development of a new breed of line
leak detectors that are electronically,
rather than mechanically, based. This
new breed of electronic automatic
line leak detectors (EALLDs) usually
incorporates a microprocessor to
enable the EALLD to make more
informed decisions about the data
that it is receiving as well as to run
more sensitive tests on the piping.
Typically, but not always, EALLDs
control power to the pump. Very
often, the EALLD microprocessor is
incorporated into an automatic tank
gauge console.
Most EALLDs use a pressure
transducer (a device that converts
changes in pressure to variations in
voltage) to monitor pressure in the
piping. Except for the fact that both
MALLDs and EALLDs monitor pres-
sure in the piping, they have little
else in common. The EALLD usually
checks for a leak after the pump
motor has been turned off. As with
MALLDs, when the pump motor is
turned off, the pressure in the piping
is allowed to drop to some "catch"
pressure determined by the pump's
pressure relief mechanism. The
EALLD then monitors the pressure
in the system to see if there is a con-
tinuing precipitous drop in pressure.
If such a pressure drop is detected,
most devices will cut off the pump
power and not allow power to be
restored by the mere push of a but-
ton. A knowledgeable technician
must reset the unit to restore power
to the pump, presumably after he or
she has determined the cause of the
pressure drop.
This leak detection feature of the
EALLD is fairly straightforward and
works well as long we are looking for
a leak in the 3 gallons per hour range.
However, in addition to 3-gallon-per-
hour tests, many EALLDs also have
the ability to conduct 0.2-gallon-per-
hour and sometimes even 0.1-gallon-
per-hour tests. Leak detection at this
level is somewhat more challenging
because of thermal effects, piping
resiliency, air pockets, and the effec-
tiveness of system hardware such as
check valves—but that discussion
will have to wait until another issue
oiLUSTLine.
There are a few EALLDs that
work on a slightly different princi-
ple—by taking over control of the
pump motor and leaving the pump
motor running for a brief period
after the fuel dispensing operation is
completed. With the piping system
at operating pressure, an electrically
controlled valve near the pump
closes and a small alternate flow
path from the pump side of the valve
to the dispenser side of the valve
opens. As long as the pressure on
both sides of the closed valve is
equal, there will be no flow through
the alternate flow path. However, a
hole in the piping on the dispenser
side of the valve will cause the pres-
sure to drop, thus allowing product
to flow through the alternate flow
path. The flow rate is then measured,
and if it exceeds the threshold leak
rate for the device, a leak is declared.
Jhe new breed of electronic
automatic line leak detectors
,—jfJof^ sSr .SgSps™, ^ «Uf Jijw 3EHU < j|
usually incorporates a
'microprocessor to enable the EALLD
fto make more informed decisions
3T • ~ 1
'about the data that it is receiving as
I well as to run more sensitive tests
on the piping.
Several EALLDs incorporate
"wireless" technology to transmit
information from the pressure or
flow sensor located near the pump to
a control unit that is typically located
near the pump power supply. This
means that the sensor signal is sent
through the same wires used to
power the pump, thus avoiding the
cost of running new wires for the
EALLD. A number of EALLD
devices can also be installed in the
same opening as was used for a
MALLD. These features make retro-
fit of EALLD on existing installations
relatively straightforward.
Keep in mind that the UST
rules do not distinguish between
MALLD and EALLD with regard to
annual testing. Whatever device is
used to meet the 3-gallon-per-hour
leak detection requirement must be
tested annually for operation accord-
ing to manufacturer's instructions.
A Few Rubs
EALLDs have their own problems
when it comes to software. Most
EALLDs complete a 3-gallon-per-
hour leak test in a matter of seconds
after the pump is turned off. I am
aware of at least one model, how-
ever, that requires three consecutive
failed tests conducted at 5-minute
intervals before declaring that piping
is leaking. Thus, the detection of a
leak requires a minimum of 10 min-
utes, during which no fuel can be
dispensed. To meet the regulatory
standard of detecting a leak within 1
hour, this device would require 10
minutes with no fuel dispensing
every hour. There are a good many
facilities where 10 minutes of down-
time will happen only in the wee
hours of the night. It seems to me
that devices such as this one do not
meet the standard for ALLDs set by
the federal rule.
Note that EALLDs work when
a pump is cycled from on to off, as
opposed to MALLDs that test the
piping when the pump is cycled from
off to on. EALLDs still require that
the pump be cycled to conduct a test
and do not meet regulatory require-
ments on systems where the pump
motor is on all or most of the time.
EALLDs have the same issues
as MALLDs with regard to satellite
dispensers. Pressure-based EALLDs
may have false alarms from malfunc-
tioning check valves, and flow-based
EALLDs have moving parts that can
get clogged, but the other problems
mentioned above with MALLDs
have largely been overcome.
Future ALLDs
After several decades of stability,
ALLDs have experienced an explo-
sion of technical development since
the emergence of the federal rule.
These developments are continuing
with the introduction of more
sophisticated pumps that feature
automatic adjustment of pump
motor speed according to the num-
ber of nozzles that are open. This
allows the pump to operate more
efficiently and to rapidly fuel a
greater number of customers. At
least one manufacturer of these intel-
ligent pumps monitors the pressure
in the line to determine the pump
motor speed. This same pressure
monitor is then used after the pump
is shut off to look for pressure drops
in the piping that may indicate a
leak. Leak detection for pressurized
piping has at last become an integral
part of the pump design rather than
an afterthought. It's about time. •
11
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tUSTUne Bulletin 29
Investigation and Remediation
Communicating1 Environmental Risk
Jt's Tuesday evening, and you have to do a presentation to a group of tank owners and operators on your state's
revised underground storage tank cleanup regulations. The revised regulations incorporate risk-based decision
making into the corrective action process, particularly with respect to identifying necessary and appropriate
action. You are introduced. You stride to the podium and begin your presentation. Fifteen minutes later, a polite but
restive audience applauds your effort, but before the applause wanes, the first hand goes up.
"You say I don't have to clean up my site to what it was before the contamination, because you're going to put
some kind of deed restriction on it. But how am I supposed to sell this property if it has contamination on it or if the
deed is restricted? \MJiy are you doing this? It doesn't sound right to me."
You have just entered the world of risk communication, which often takes place within the context of emotional stress,
fear, uncertainty, and a mishmash of competing facts and perceptions. It doesn't matter whether your stakeholders are
your colleagues, your management, tank owners and operators, legislators, bankers, environmentalists, or the general
public—your ability to effectively communicate risk-based programs and messages is crucial to the success of your
program.
You may already be applying the principles of risk communication routinely in your day-to-day work—maybe
without even knowing it. You may already be working hard at honing your risk communication skills...at times with
frustration. Aye, effective risk communication is a divine skill worthy to be wrought. That being said, we'll try to cover
risk communication in LUSTLine with a certain amount of persistence. For starters, we've asked Susan Brown, a risk
communication trainer with Brown Training Associates, to introduce the subject and explain some of the basic princi-
ples being taught today.
w-will "ir "iinn T'ii
Risk Communication = The exchange of information among interested parties about the
nature, magnitude, significance, or control of a risk. It is an interactive process that involves the
communication of multiple messages about the nature of risk and other messages that express the
concerns, opinions, or reactions of the stakeholders.
Three DOs
by Susan Brown
Ksk communication and its
>rinciples became popular in
he late 1980s in response to
the passage of a number of environ-
mental regulations that made public
participation a prominent feature.
Environmental regulators were sud-
denly faced with an emphatic man-
date stating that the public had a
right to be included in decisions
about risk and that regulators had
better get busy including them. Pub-
lic involvement was a novel
approach to environmental regula-
tion, and both government agencies
and private industry found them-
selves wondering: But how?
Some turned to the risk com-
munication pundits, who spoke of
risk messages, public perceptions,
and gaining trust and credibility. Dr.
Vincent Covello from the Center for
Risk Communication at Columbia
University asserted that perception is
equal to reality—"What is perceived
to be real is real in its consequences."
Dr. Peter Sandman from the Environ-
mental Communication Research
Program at Rutgers University spoke
of "hazard versus outrage," saying
that "the public pays too little atten-
tion to hazard; the experts pay
absolutely no attention to outrage."
Slowly, the principles of risk commu-
nication began to take their place in
today's environmental arena.
As the public has become more
involved in environmental issues
and the decisions that are made to
safeguard human health and the
environment, risk communication
has begun to play a critical role in the
effective exchange of information.
But where do you begin?
There are three fundamental steps
that you need to take as you begin to
apply risk communication princi-
ples to your public involvement
strategy:
1. Involve yourself in your public
involvement strategy.
Form and be part of an interdisci-
plinary team to implement your
public involvement strategy—an
action team, so to speak. Organize
the team in the very initial stages
of the public involvement process
and define the roles and responsi-
bilities for each member. Select
team members who include staff
from your legal department and
public affairs office, as well as
your environmental technicians,
engineers, and scientists. Ensure
that this group functions as a team
throughout the risk qDmmunica-
tion process.
As a team member, take your
role seriously. Engage in brain-
12
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LUSTLme Bulletin 29
storming sessions to determine
the best way to communicate your
efforts. Review fact sheets and
documents in a timely manner
and with due diligence. Volunteer
to meet with individuals or
groups to exchange information
with them. Be committed to meet
with the public at every opportu-
nity.
And speaking of the public,
define your public in the broadest
sense. Do you mean the neighbors
at the site of concern? Local
elected officials? State and federal
elected officials? Environmental
organizations? Business leaders?
ested? Is it because they think
meetings like this are a waste of
time, because no one ever listens
anyway? They'll do what ever
they want anyway. Why bother?
Chances are you have a pre-
ferred method for exchanging
information. Some of you have no
problem standing in front of the
microphone making comments in
front a group of 50 or 100 people.
Some of you would rather
exchange information in a more
informal, one-on-one environ-
ment. Some of you would rather
gather all the information you can,
review it, and then talk about it.
Just as you have your information
exchange preferences, so do the
many individuals who make up
your public.
to them. Focus your messages on
your public's concerns.
Also, structure your language
to ensure that the words you use
are understood by the receiver.
Remember that each person has
his/her own individual experi-
ences—some may be similar to
yours, and some may not. You
might be an engineer, but you are
talking with a banker. You might
be a biologist, but you are exchang-
ing information with a teacher. If
you use words that may be outside
that person's area of expertise,
explain your terminology with
easy to understand phrases.
Consistency of message is cru-
cial if you want your message to
be heard and remembered—espe-
cially in situations where anger,
Involve yourself in your public involve-
ment strategy.
Bankers? Real
estate agents?
Once you have
defined all of
your public,
identify each
group's inter-
ests. Neighbors
will more than
likely be inter-
ested in the
health and safety of their family
and pets. But what else? Property
values? Business leaders or
elected officials will have other
kinds of concerns that are specific
to their interests. Document these
interests for each group that
you've identified as your public.
2. Remember that public involve-
ment means more than public
meetings.
"But," you say, "the regulations
only require one (or two) public
meetings." This may be true. But
ask yourself: What, in fact, is the
right thing to do? How can you
reach the greatest number of peo-
ple? Have you had great success
at getting people to attend your
public meetings? If not, why? Is it
because your public isn't inter-
Remember that public involvement
means more than public meetings.
Develop messages that are focused,
understandable, and consistent.
So, you and your interdiscipli-
nary team members need to put
yourselves into the shoes of your
public and strategize. Brainstorm
all of the different methods of
exchanging information and com-
municating your message. Then,
implement the strategy!
3. Develop messages that are
focused, understandable, and
consistent.
Over the years, I have heard many
people say, "This is what I want to
tell them." ("Them," meaning
their public.) My question to these
people is, "Is that where their
interests lay?"
Develop your messages to
respond to your public's interests.
Keep in mind that what you want
to tell them may not be of concern
fear, and mistrust have clogged a
normally open mind. In those
cases, it is very important to be
consistent, clear, and concise. So,
repeat your message(s), using the
exact same words (12 or less, by
the way), between 2 to 4 times in a
dialogue.
If you plug these three risk
communication principles into'
your public involvement strategy,
you will be on the path to opening
the lines of communication, creat-
ing a level playing field, and giv-
ing yourself the opportunity to
partner with the public. A great
beginning for future exchanges! •
for more, information, contact Susan
Brown at brownta@aol.com.
-------
LU$nincBnUctto29
Investigation and Remediation
Aesthetic Criteria for Drinking Water
Contaminated with MTBE—The Angst Factor
byJc/Ktihn
In December 1997, the EPA issued
a drinking water advisory for
MTBE that recommend levels not
to exceed 20-40 micrograms per liter
(ug/L) in drinking water. The advi-
sory is based on aesthetic criteria—
taste and odor thresholds—for
MTBE. It states that although exten-
sive studies have not been under-
taken to determine the variability of
human response in tasting or
smelling the chemical, studies do
indicate that "keeping the concentra-
tions in the range of 20-40 ug/L will
likely avert unpleasant taste and
odor effects, recognizing that some
people may detect the chemical
below this." Unfortunately, how-
ever, many states may not be
equipped with the legal means to
enforce drinking water standards for
chemicals based on taste and odor
criteria alone.
There is a great deal of confu-
sion regarding whether aesthetic cri-
teria can be enforced by state
agencies. These standards are typi-
cally referenced as "secondary stan-
dards" by most state drinking water
programs. More and more fre-
quently, however, state UST/LUST
programs are called upon by the
public to enforce aesthetic criteria
that may be lower than current maxi-
mum contaminant levels (MCLs) or
other risk-based numbers used to
address contamination in groundwa-
ter used for drinking water pur-
poses.
The nationwide recognition of
the MTBE problem has brought this
issue more clearly into focus in many
states. The same issue is also univer-
sally recognized with TPH con-
stituents, but it has not raised the
same level of concern or garnered
the same level of attention as MTBE.
Over the years, regulatory
agencies have become more aware of
the real concerns of the public and
find themselves having to balance
how they respond to the conflicting
issues of supporting risk-based num-
bers for chemicals in drinking water
with the reality of public sentiment
when a water supply has a petro-
leum taste or odor that renders it
undrinkable. How can we come to
grips with these two issues and still
protect the health and welfare of the
public from unwanted chemicals in
their drinking water? How do we
explain that, although contaminants
may be present in private or public
drinking water supplies, they do not
exist at levels that require removal?
EPA/State Discussions
At the March 1998 EPA UST/LUST
Conference in Long Beach, Califor-
nia, participants in the MTBE session
noted the difficulty they face in
enforcing the drinking water advi-
sory limit and called for EPA to com-
plete the necessary toxicological
testing to determine the carcino-
genicity of MTBE. EPA representa-
tives indicated that the results of
such testing might not be completed
for 2 to 4 years.
This waiting period creates a
problem for most states: How can
they require cleanup of MTBE from
drinking water supplies if they have
no regulations regarding the cleanup
of other compounds that commonly
create taste and odor problems in
public and private water supplies
(e.g., iron, manganese, or sulfur)?
Preliminary results from a
recent University of Massachusetts
survey indicate that only 15 states
currently have a drinking water stan-
dard for MTBE. These standards
range from 20 to 240 ppb. Those
states adopted their drinking water
standards for MTBE by rule, statute,
or policy. California recently legis-
lated secondary and primary drink-
ing water standards for MTBE, a
reactive measure to prevent another
catastrophe such as the Santa Monica
well field contamination. Those stan-
dards will be implemented in
July 1998
and July
1999, respec-
tively. Maine
and Delaware
are contem-
plating leg-
islative
changes that
would establish
enforceable drink-
ing water standards
for MTBE and other
com-
pounds currently viewed as "noncar-
cinogens." New Jersey has an
enforceable interim specific criteria
standard (primary MCL) for MTBE of
70 ppb. Vermont requires provisions
for alternate drinking water for wells
that have any detectable concentra-
tion of MTBE.
Protecting the Public from
Potential Risk
Frequently, in public meetings, we
are asked "How many parts per bil-
lion of BTEX or TPH constituents (or
MTBE...) would you let your chil-
dren drink?" The response of most
regulatory folks I know is, "I don't
want it in my drinking water,
period." Be that as it may, it may be
very difficult for regulators to
require cleanup of water with conta-
minant levels that are below legally
enforceable standards, even though,
as far as the public is concerned, the
water is undrinkable.
Once groundwater that is used
for drinking water, bathing, or cook-
ing has been impacted by a petro-
leum product, most people will
14
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LUSTLine Bulletin 29
choose not to continue using the
water and will seek an alternative
source of clean water. Even though
concentrations of petroleum con-
stituents may be below state or fed-
eral drinking water standards, state
regulators may choose to require
provisions for an alternative water
supply. The reasoning in most cases
is that the affected party has lost the
use of the water supply simply
because it is "contaminated."
Until more in-depth studies of
the cancer and noncancer effects of
MTBE (i.e., kidney, neurological,
reproductive, and developmental)
are completed, states have three
choices: do nothing, follow the EPA
drinking water advisory recom-
mended levels (20-40 ppb), or
adhere to a different level (e.g., the
1991 California action level of 35
ppb). Regulators are often forced to
take a conservative approach that
acknowledges the loss of the use of
the water but that also protects the
public from unknown risks from
"potential carcinogens."
The Range of Sensitivity to
Taste and Odor
A presentation by Dr. Steven Book,
California Department of Health Ser-
vices, at the 10th Annual UST/LUST
Conference in Long Beach, summa-
rized much of the current taste and
odor research completed to date.
One study (Young et al., 1996) found
that four out of nine panelists tasted
MTBE at 40 ppb. In the same study,
three out of nine panelists sensed an
odor at 15 ppb. Another study com-
pleted by the Metropolitan Water
District (Dale et al., 1997) found that
four panelists sensed MTBE odor as
low as 21 ppb and taste as low as 2
ppb. Still another study completed
by the Orange County Water District
(Shen et al., 1997) indicated that
some panelists were able to sense an
odor as low 2.5 ppb in 7 out of 16 test
runs.
One obvious conclusion that
can be drawn be from these studies
is that some individuals are
extremely sensitive to the taste and
odor of MTBE. EPA's drinking water
advisory recognizes that some peo-
ple may detect the chemical below 20
to 40 micrograms per liter (ug/L).
Based on the lack of data on humans
from MTBE-impacted drinking
water and lack of exposure of labora-
tory animals to the contaminant in
drinking water, the advisory states
that "there are significant uncertain-
ties about the degree of risk associ-
ated with human exposure to low
concentrations (of MTBE) typically
found in drinking water."
Additional taste and odor stud-
ies are currently under way through
a unique partnership forged between
the Association of California Water
Agencies (ACWA*), the Oxygenated
Fuels Association (OFA), and West-
ern States Petroleum Association
(WSPA). Preliminary results of odor
testing, using a large consumer-
based group of panelists, are pend-
ing.
Given the uncertainties associated
• mththis chemical, states need to
* consider what level of MTBE in
\"drinkingwater represents ari
j^r— "unacceptable risk.
Decisions, Decisions
Given the uncertainties associated
with this chemical, states need to
consider what level of MTBE in
drinking water represents an unac-
ceptable risk. Some states may
choose not to wait for EPA to pro-
mulgate an MCL for MTBE and may
instead start by enforcing a sec-
ondary drinking water standard
based on taste and odor criteria.
Other states may want to consider
using the advisory level as an
interim standard within the allow-
able framework of their state drink-
ing water regulations.
The City of Santa Monica, Cali-
fornia, made an active decision to
shut down municipal wells that were
impacted by MTBE in the Charnock
and Arcadia well fields. As a result,
the city now imports 70 percent of its
drinking water from the Los Angeles
Metropolitan Water District at a cost
of about $1 million per year. The city
is currently evaluating treatment
options that will bring its wells back
on line.
* For information regarding the status of
the ACWA research, please contact
Krista Clark at (916) 441-4545.
Although this scenario is
extreme in terms of costs, recent visi-
tors to the site [participating in a
field trip sponsored by the Associa-
tion of State and Territorial Waste
Management Officials (ASTSWMO)]
were impressed by the magnitude of
the problem and the overwhelming
support of the public to address the
contamination.
Contamination of the Santa
Monica well fields resulted in the
recent enactment of several state leg-
islative bills to establish primary and
secondary drinking water standards
for MTBE in California and to com-
plete additional research to evaluate
MTBE remediation options.
The Sampling Conundrum
Another exasperating aspect of our
regulatory frustrations with MTBE is
the "now you see it, now you don't"
factor. Most project managers are
aware that groundwater conditions
can fluctuate radically at different
times of the year. Low concentra-
tions of some contaminants that may
be detected at low concentrations
and by odor in one sampling period
may not be detected with standard
laboratory analysis in a subsequent
round of sampling. At times we are
forced to ask ourselves whether the
problem really exists at all.
In my experience, the olfactory
senses of most impacted parties are
generally correct. With most gasoline
products, impacted parties are able
to smell constituents at very low con-
centrations that may not be detected
through standard lab analysis—and
this may be true for MTBE as well.
Volatilization is an ongoing problem
in sampling for low levels of volatile
constituents (e.g., benzene, MTBE).
Sampling procedure may be a signif-
icant factor as to whether we detect
the constituent at all. Therefore, sam-
pling procedures should be strictly
adhered to in order to minimize loss
of the contaminant.
Seasonal groundwater fluctua-
tion may also play a significant role.
We are frequently asked to consider
closure of sites that show an overall
trend of decreasing contaminant lev-
els (two to three consecutive sample
rounds). Most site workers typically
see an annual spike of BTEX concen-
trations as spring run-off raises the
• continued on page 16
15
-------
LUSTLfar Bulletin 29
• Drinking Water from page 15
water table and sends another load
of BTEX "down the pike."
The fact is that groundwater
samples collected at the wrong tune
of the year may underestimate
worst-case concentrations of con-
stituents in groundwater. Thus, pre-
mature closure of a site may occur if
a longer time period for groundwa-
ter monitoring is not allowed. An
even more discouraging aspect of
MTBE is the chance that the chemical
mass has moved off-site, potentially
impacting downgradient receptors
long after the source area is allegedly
cleaned up and closed.
Both state regulators and
sultants need to do a better jpb of
defining site conditions to under-
stand whether low concentrations of
contaminants really do indicate a
decreasing trend that may be\thj
result of active remediation efforts or
natural attenuation. Many states are
already considering reevamating
closed LUST sites where tne pres-
ence of MTBE was not prievicjnsly
questioned. Testing nearby
supply wells for MTBE
good place to start in the
tions.
Grappling with the Qiiestions
So, given the fact that it maj
years (if ever) before EPA puBKsfie
an MCL for MTBE, what-do_aytes\
do? State regulatory agencie^are,
the tenuous position orgolng outpja,
a limb to protect public health from
the possible carcinogenic and non-
carcinogenic effects of exposure from
drinking low concentrations of
MTBE-contaminated water. Until
further research is completed by the
EPA, state regulators may be forced
to take the most conservative
approach to protect human health in
communities with MTBE-impacted
water supplies. Although this may
lead to legal challenges from respon-
sible parties, failure to respond may
also result in legal challenges from
impacted communities.
Regulators are left to grapple
with a number of weighty questions:
• Should we expect the public to
continue drinking water that may
be "dean" by current federal stan-
dards but that contains petroleum
products that affect the taste and
odor of the water, have unknown
toxicity, and ultimately render the
water unfit for consumption?
Should states use the EPA drink-
ing water advisory range as an
interim standard or do nothing
until EPA publishes an MCL or an
additional health advisory?
What are the costs of protecting
the public from the unknown
risks of specific chemicals that
either appear in our drinking
water supplies at concentrations
below MCLs or, as in the case of
MTBE, do not have an MCL?
If treatment is required, should
treatment costs deemed necessary
to reach an aesthetic standard,
such as the EPA drinking water
a j advispry^bejjorne by the respon-
sible
r fmf.
Sse cpJ5stions> which have been
ebaten for many years by technical
regulatory staff in the TPH arena, are
oncefagain a primary topic of the
"how dean is dean?" debate.
States need to consider all of
theirjoptions regarding the cleanup
of MflTBE, acknowledging that once
3E has had an impact on a water
sup'ply, the beneficial use of the
rater may be temporarily lost.
Indeed, states may be forced to take
a more proactive approach toward
protecting water supplies to prevent
the taste and odor of MTBE from
rendering their water undrinkable.
The public may demand it in the
absence of an MCL.
In my opinion, in the absence of
detailed toxicological studies, states
need to consider limiting their liabil-
ity regarding possible carcinogenic
and noncarcinogenic health effects of
MTBE by requiring treatment for
impacted water supplies. State LUST
programs also need to more aggres-
sively manage MTBE plumes to pre-
vent off-site migration that may have
an impact on water supplies in the
future.
We must manage sites with the
goal of protecting the public's health
and not wait until the damage is
done. However, if drinking water
supplies are impacted, the issue
must be addressed. We owe it to the
public. More specifically, most of us
would choose not to let our children
drink water containing MTBE. •
JeffKuhn is with the Montana DEQ
Petroleum Release Section and is a
member of the ASTSWMO MTBE
Work Group.
References
Book, Steven, California Department of Health Services, "MTBE in Cali-
fornia Drinking Water," presented at the 10th Annual UST/LUST Con-
ference in Long Beach, California. March 1998.
Dale, Melissa S., Margeret S. Moylan, Bart Koch, and Marshall Davis,
Metropolitan Water District of Southern California, "MTBE: Taste and
Odor Threshold Determinations Using the Flavor Profile Method," pre-
sented at the Water Quality Technical Conference, American Water
Works Association, Denver, Colorado. November 9-13,1997.
Hitzig, Robert, USEPA, University of Massachusetts Survey results, pre-
sented at the 10th Annual UST/LUST Conference in Long Beach, Cali-
fornia. March 1998.
Shen, Yvonne P., Lee J. Yoo, Steve R. Fitzsimmons, and Mark K.
Yakamoto, Orange County Water District, "Threshold Odor Concentra-
tions of MTBE and Other Fuel Oxygenates." 1997.
"U.S. EPA Drinking Water Advisory: Consumer Acceptability Advice
and Health Effects Analysis on Methyl Tertiary-Butyl Ether (MTBE)."
December 1997.
Young, W. F., H. Horth, R. Crane, T. Ooden, and M. Arnott, "Taste and
Odor Threshold Concentrations of Potential Potable Water Contami-
nants," Water Research 30(2), pp. 331-340,1996.
16
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LUSTLine Bulletin 29
Oh Henry! (a constant)
by Blayne Hartman
[Editor's Note: This is the first in a series of articles that review some of the physical/chemical properties that are commonly used in
environmental assessment and remediation. ]
Okay, herein g^s^on that,
when I ask it,~We^5~percent of
the people answeiSiiicorrectly. See
how you do. ^=^_
Suppose I fill-ajzlosed container
with water until there are equal
amounts of air and water. Then
I spike 100 molecules of benzene
into the container, and shake it
until the benzene distributes
itself between the air and water.
Where will the benzene end up?
(a) Mostly in the water.
(b) Mostly in the air.
(c) Equal amounts in the air and
water.
(d) It sinks to the bottom as a
DNAPL.
Got the answer?
Well you know it's not (d), because
benzene is lighter than water and
would float as a free product.
(DNAPL refers to dense non-aque-
ous-phase liquid—a liquid heavier
than water.) If s not (c), because there
is a preferred phase for all com-
pounds, including benzene. So, do
you choose (a) or (b)?
Some hints:
• Benzene has a relatively high
vapor pressure and is considered
to be a volatile compound.
• Although benzene is considered
the most soluble of the aromatics,
the solubility of all of the aromat-
ics in water is relatively quite low.
• Very few regulatory agencies (in
fact, none that I know of) consider
benzene data from water samples
that contain air bubbles valid,
because of concerns about the loss
of the benzene to the bubbles.
Do these hints convince you that (b)
(mostly in the air) is correct? If so,
you're wrong. The correct answer is
(a). The benzene prefers to stay in the
water! Surprised? Well, welcome to
the 75 percent club.
The distribution, or partition-
ing, of a compound between air and
water is given by the Henry's law
constant and is defined as
"• ~ air ' ^"water
where Cair and Cwater are concentra-
tions of a compound in the air and
water phases, respectively. The units
for the air and water concentrations
are the same (i.e., ug/L).
Dimensional vs. Bimensionless
Henry's law constants are derived
empirically (i.e., by measurement in
the laboratory) and are commonly
tabulated in two forms: dimensional
and dimensionless. While both forms
are useful, the dimensionless form is
the easiest form to work with for the
inexperienced user.
The dimensionless form can be
thought of as the number of mole-
cules or mass of a compound that
exists in the air versus the number of
molecules or mass that dissolves into
the water. If the dimensionless
Henry's constant for a compound is
greater than one (Cair > Cwajer), then
the compound prefers to be in the air
phase. In contrast, if the Henry's con-
stant is less than one (Cair < Cwater),
then the compound prefers to be dis-
solved in the water. This partitioning
ratio will hold until a compound has
reached saturation in either the air or
water.
The dimensional form of the
Henry's constant is typically given in
units of atm-m3/mole and can be
computed from the dimensionless
constant using the ideal gas law by
multiplying by the universal gas
constant times temperature (0.082
times the temperature in degrees
Kelvin, which is equal to 22.4 at 0° C,
and 24 at 20° C).
Day-to-Day Applications
So, how do you apply Henry's con-
stant to day-to-day LUST situations?
Well, for one thing, you can use it to
predict the likelihood that a com-
pound exists in the soil vapor or
headspace. For example, consider
the alkane and aromatic hydrocar-
bons. For the lower alkanes
(methane through hexane), the
dimensionless Henry's constant
ranges from 30 to 70 (let's use 50 as
an average). For a system at equilib-
rium with equal volumes of soil
vapor and water, 50 molecules of
these alkanes will exist in the air for
every 1 that dissolves into the water.
In contrast, the Henry's con-
stant for the four common aromatics
(benzene, toluene, ethyl-benzene,
and xylene) is approximately 0.25. At
equilibrium/1 molecule will exist in
the air for every 4 that dissolve into
the water. Thus, the alkanes will par-
tition into the air approximately 200
times more than the aromatics
(50/0.25).
When measuring air samples
for fuel-related hydrocarbons (e.g.,
soil vapor surveys, screening soils
and waters using a head-space tech-
nique, exhaust from a vapor extract
system), sample analysis with a
flame ionization detector (FID)
instrument has a far greater chance
of detecting the contamination than
one with a photo ionization detector
(PID), because FIDs detect all alka-
nes whereas PIDs are relatively
insensitive to alkanes.
You can use Henry's constants
to compute the equilibrium concen-
tration of a compound in the air or
water from the other phase. Re-
arranging the expression for the
Henry's constant gives:
f~> TT >f /-I
^"air ~ n Cwater
For example, if the groundwater con-
centration was 10 ug/L for both
• continued on page 18
17
-------
LUSTLiiK Bulletin 29
• Oh Henry from page 17 _
methane and benzene, the equilib-
rium soil vapor concentration above
the water would be:
For methane (H = 30):
For benzene (H = 0.25):
C^ = 0.25 * lOug/L = 2.5 ug/L
It is very important to remember that
Henry's constants assume that equi-
librium exists between the air and
water phases and that the com-
pound's solubility in the air or water
has not been reached (i.e., below sat-
uration). These conditions are often
not met in the real environment, so
values computed from these con-
stants are approximations that can be
used for predictive purposes, but
should be used cautiously for quanti-
tative conclusions.
Now Back to the Original
Question...
Benzene has a Henry's constant of
approximately 0.25, meaning that for
every 1 molecule of benzene that par-
titions into the air, 4 molecules parti-
tion into the water. So, the correct
answer is (a). Remember, our exam-
ple assumed equal volumes of air
and water in the container. If the
air/water volumes are not equal,
then the actual distribution also
depends upon the ratio of air to
water. In other words, in a water
sample where air bubbles make up 10
percent of the total container volume,
the distribution of benzene would be
roughly 1 molecule in the air bubble
for every 40 molecules in the water
(only 2.5 percent of the total). The
startling conclusion here is that a few-
bubbles in a water sample don't sig-
nificantly change the water concen-
tration, depending upon the
compound's Henry's constant. Oh
Henry!
Got it? Now go ask the ques-
tion to your co-workers. (P.S., I get
10 percent of any winnings). •
Blayne Hartman is a regular contribu-
tor to LUSTLine. This article is taken
from a presentation on physical/chemi-
cal properties that he girxs as part of a
course on geochemical training. For
more information, contact Blayne at
bhSh'genv.com or check out his Web
page at jmvw.tegenv.com.
Prevention
enforcement Strategy Samplers
'98 Deadline
The December 22,1998 deadline for upgrading, removing, or replacing
USTs will call for a concerted enforcement effort on the part of EPA and
the states. Whaf s the game plan, so far?
Well, EPA's draft of its strategy for enforcement of the 1998 UST require-
ments, which was distributed to the states in February, was discussed in some
detail at the National Conference in March. Earlier, about half the states had
sent written comments to the agency. EPA is now in the process of revising the
document. EPA staff say the revised version will be responsive to the states'
concerns. The timetable for getting it out is uncertain. So, more from EPA
later.
As for the states and territories, some strategies are pretty much nailed
down, while others are still in the final throes of completion. To give you some
idea of what states are planning, we plan to run samplers to describe enforce-
ment strategies in selected states. In this issue, those states are South Carolina
and Michigan. Also, six trade associations plan to conduct a survey of the
states tcfglean what they can about enforcement policies anjrtprocedures. (See
n page 21.)
's!T:rvr\South Carolina
~~^ f~~
"Through April 1998, about 57 per-
cent of operating UST systems were
confirmed to be in compliance with
the upgrade requirements," says Bob
Hutchinson, Director of the Regula-
tory Compliance Branch at the South
Carolina Department of Health and
Environmental Control, Division of
Underground Storage Tank Manage-
ment. "This means that some 7,000
USTs will need to be upgraded,
replaced, or abandoned. The smaller
retail, nonretail, and government-
owned facilities lag behind the com-
pliance rate set by the national
marketers."
During the past year, the divi-
sion's field inspectors surveyed a sig-
nificant portion of tank owners to
determine their intentions regarding
the 1998 standards. Only about 10
percent of the tank owners did not
have a plan to comply. For planning
purposes, the results were extrapo-
lated against the total UST popula-
tion that does not meet the 1998
standards, and the following conclu-
sions were developed:
• Approximately 2,520 USTs are
expected to close prior to the
deadline. Some of these closures
may be temporary in order to
meet the compliance deadline. In
doing so, the tank owner or opera-
tor can legally delay permanent
closure or upgrading for one year.
• Approximately 3,360 USTs will be
upgraded (spill, overfill, and cor-
rosion protection) prior to the
deadline. The division will not
accept any contractor scheduling
problems as an "industry excuse"
to continue to operate beyond the
deadline.
• Approximately 1,120 new USTs
will be installed. During the past 2
years, between 400 and 500 new
USTs were installed annually.
Outreach Is Key
"Our inspectors have met every tank
owner, face to face, at least once,"
says Hutchinson. "We've had an
aggressive outreach program since
1993 and plan to continue on well
beyond the 1998 deadline. We feel
that outreach is a vital ingredient to a
successful UST program. No tank
owner or operator in this state can
say, 'We didn't know/"
"The division will continue to
publish a quarterly newsletter, send
18
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LUSTLine Bulletin 29
personal letters to TJST owners, meet
with individual owners or operators,
make presentations to related busi-
nesses, and use various media to
ensure that the regulated community
is aware of our requirements."
During the second quarter of
1998, the division's field staff met
with each owner/operator whose
tank systems do not meet upgrade
standards and explained once more
all of the requirements and conse-
quences of noncompliance.
The list of noncompliant USTs
will be published and distributed to
fuel distributors in North Carolina,
South Carolina, and Georgia during
the third quarter of 1998. Suppliers
will also receive information about
potential enforcement actions should
they introduce product into improp-
erly registered tanks. In addition, the
department's Freedom of Information
Office is providing both industry and
the general public with a list of UST
facilities with nonupgraded USTs.
In January, the division pro-
vided an annual report to the state
legislature to update members on the
status of the program. "For the most
part, we've had great support from
the legislature, our commissioner,
our board, the petroleum marketers,
and the suppliers," says Hutchinson.
"We've provided owners and opera-
tors with the tools to go down the
pathway of compliance, and I think
everyone appreciates this."
Prohibition of Fuel Delivery a
Powerful Incentive
"Our UST registration decal renewal
requirement will play a significant
role in our overall compliance strat-
egy," say Hutchinson. The fiscal year
1999 renewal decal (issued in July
1998) will have an expiration date of
December 21 (midnight), 1998, for
facilities that have not met upgrade
requirements. The expiration date
will appear on the decal, and the
owner will be advised of the expira-
tion date in a letter that will accom-
pany the decal when it is issued.
Petroleum suppliers who are
found placing product in an UST
that does not have a valid registra-
tion will be subject to enforcement as
authorized by the State Under-
ground Petroleum Environmental
Response Bank (SUPERB) Act.
Hutchinson expects that this prohibi-
tion of fuel delivery will become a
powerful incentive for owners and
operators to comply with the
upgrade requirements.
Compliance Tie-In With State
Fund
Another incentive for compliance
ties in with the SUPERB Account and
the SUPERB Financial Responsibility
Fund. An UST owner or operator
who has a release from a nonup-
graded UST that is operating after
the deadline will not be able to
access the SUPERB Account or the
Financial Responsibility Fund for
damages resulting from that release.
"Part of our outreach effort during
this year has been to emphasize this
loss of coverage for violating the
deadline," explains Hutchinson.
Post-Deadline Inspection
Strategy
"We now believe that our compliance
staff will be able to visit every non-
compliant site during January 1999,"
says Hutchinson. If the non-
upgraded USTs have been rendered
inoperable and are temporarily out of
service (TOS), the owner or operator
will be reminded that he or she is
required to empty the tanks and
secure all fill and dispenser piping
before March 22,1999 (90 days after
the deadline). The inspector will also
provide an explanation of the options
available to remain in compliance:
• Upgrade the system before
December 22,1999.
• Permanently abandon the system
before December 22,1999.
• Conduct a site assessment and
request an extension for TOS sta-
tus before December 22,1999.
If the nonupgraded USTs have
not been rendered inoperable, the
inspector will issue a notice of viola-
tion on which enforcement action
will be taken. The inspector will
advise the owner/operator to imme-
diately place the tanks in TOS status.
Owners and operators will be
required to supply the division with
documentation that this action has
been taken.
After March 22,1999, follow-up
inspections will be conducted at
facilities where proper documenta-
tion was not provided. If the USTs
continue to hold product, the inspec-
tor will issue a notice of violation for
failure to properly maintain TOS sys-
tems, and the matter will be referred
to the Enforcement Section.
Enforcement
On December 22,1998, the division's
Enforcement Policy will be
expanded to include penalties for
operating nonupgraded USTs
beyond the deadline. The penalty
range for this violation will be $500
to $5,000 per tank, levied via consent
order, against the owner or operator.
Penalties may be lowered for those
who swiftly remove all product and
place the substandard tanks into
TOS status. During the time of tem-
porary closure, the owner or opera-
tor will be allowed to upgrade the
tanks to the 1998 standards and
resume operations.
If the conditions of temporary
closure are violated, the division
may pursue injunctions to stop oper-
ation or obtain the same end result
through the use of Administrative
Orders and higher civil penalties.
Over the; life of Michigan's UST pro-
gram, about"52,691 tanks have been
closed or removed. The Department
of Environmental Quality's Under-
ground Storage Tank Division
(USTD) is now focusing on the status
of the remaining 29,000 active tanks.
"Currently, two-thirds of our active
tanks are out of compliance," says
Art Nash, Chief of the UST Division.
"By December 22, 1998, we expect
that only about one-third of the
active tanks will still be out of com-
pliance—and thaf s a worst-case pro-
jection."
A recent survey conducted by
the USTD found that 45 percent of
the owners and operators of active
tanks say they will close, 51 percent
say they will upgrade, and the
remaining 4 percent aren't sure what
they will do.
"Our official position regarding
the 1998 deadline," says Nash, "is
that owners and operators cannot
operate substandard tanks after
• continued on page 23
19
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LUSTLhteButtetitt29
Coast to Coast is provided as a regular feature ofLUSTLine to update state and federal UST, LUST, and cleanup fund person-
mi about the activities of the Association of State and Territorial Solid Waste Management Officials' (ASTSWMO) Tanks
Subcommittee. If you ivant to learn more about the Tanks Subcommittee, contact the Subcommittee Chair, Scott Winters (CO)
at (303) 620-4008, or Stephen Crimaudo (ASTSWMO) at (202) 624-7883.
ASTSWMO's Tanks Subcommittee Issues Its Report Card
on the Federal UST/LUST Program
in 1996, the ASTSWMO Tanks Sub-
committee decided that some kind
of "report card" was needed to doc-
ument the scope and effectiveness of
the federal UST/LUST program
nationwide, as well as to measure
the projected workload to meet the
1998 technical standards. This type
of report could also serve as a
resource for states to use to compare
their programs with national trends
and other state programs. The sub-
committee ran with the idea, gather-
ing compliance and other historical
data for a program review and then
assessing the accomplishments of
the program to date. The report card
was completed in January 1998.
Data in the report were gathered in
early 1997.
Major Findings
The following are some of the sub-
committee's major findings:
• Since the inception of the regula-
tions in 1988, 65 percent of the
regulated tanks have been
removed or upgraded.
• There is a ten-to-one benefit-to-
cost ratio associated with leak
prevention. This means that a
$100,000 investment in state/fed-
eral compliance/enforcement
work, along with private sector
investments in leak prevention
and detection, will save $1 million
in government oversight cleanup
costs.
• It has cost society an estimated
$17 billion to clean up spills to
date. About $11 billion more will
be needed before the job is com-
pleted.
The UST program has shown
unprecedented success in both
pollution prevention and
cleanup. However, program
staffers have been so busy achiev-
ing these results that they have
not had the time to fully educate
the public and decision makers
about the successes of the pro-
gram. One way of communicat-
ing this message is through the
"Report Card on the Federal
UST/LUST Program."
Nationally, the .vast majority of
USTs have been registered with
state UST programs. From 1991
through 1997, approximately
347,000 unregistered USTs were
registered with state UST pro-
grams. Projections made in the
report show that from 1998
through 2003, only 32,000 cur-
rently unregistered USTs will still
need to be registered.
I As of early 1997, only 29.7 percent
of all active USTs were in full
compliance with the 1998
upgrade deadline requirements.
Although this percentage has
since increased, this statistic
shows the enormous workload
that remains to ensure compli-
ance with the standards.
I Since the inception of the UST
program in 1985, over 50 percent
of all USTs that were in the
ground have been closed; just
under 15 percent are still active
and in compliance with the
upgrade requirements; and
almost 35 percent are active and
out of compliance. Based on this
trend (if future trends hold to this
one), as many as 50 percent of
currently active USTs may end up
being removed in order to com-
ply with the 1998 deadline.
State Views on EPA's Future
Role
One of the most intriguing parts of
the report is Section 7, "Current and
Future Issues." In an effort to facili-
tate discussions concerning the
future of the UST program at both
the state and national levels, states
were asked what they thought
EPA's role should be in the UST pro-
gram after disinvestment. Some
state managers commented that
EPA should not disinvest in the UST
program because that would send
the message to the regulated com-
munity and potentially state legisla-
tures that the UST program had
completed its task and that there
was no need for a program at any
level. (Note: EPA does not have any
plans to disinvest in the UST pro-
gram.)
States were concerned about
the future of federal funding. Con-
tinued funding by EPA is essential
for states to complete their cleanup
and compliance tasks and to prevent
the abrupt cessation of the environ-
mental gains documented in the sur-
vey. A number of states felt that
EPA's ongoing role in the UST pro-
gram should be to provide technical
resources, serve as an information
• continued
20
-------
LUSTLine Bulletin 29
from Robert N. Renkes, Executive Vice President, Petroleum Equipment Institute
Trade Associations Embark on a National Survey of UST
Enforcement Strategies
As the.December 22,1998 compliance deadline
for upgrading, replacing, or removing USTs
nears, companies affected by EPA's regulations
are beginning to turn their thoughts to how these regu-
lations will be enforced. Tank owners, UST manufac-
turers, and UST service providers all have important
decisions to make by the end of the year (or sooner),
and enforcement is one of the issues they must con-
sider.
Over the years, trade associations representing
tank owners, UST manufacturers, and UST service
providers have been asked by their members to pro-
vide copies of UST-related regulations and guidance
documents made available by the states. One of the
more recent items association members have requested
is information on how the states and territories plan to
enforce the UST regulations that they've had on the
books for a decade or more.
Six trade associations—American Petroleum
Institute, National Association of Convenience Stores,
Petroleum Equipment Institute, Petroleum Marketers
Association of America, Society of Independent Gaso-
line Marketers of America, and Steel Tank Institute—
have gathered forces and resources to survey state and
territorial UST programs about their enforcement poli-
cies and procedures. The survey will be drafted in June
and mailed to the program managers by July 1.
Responses by the UST program managers will be made
available to interested parties as the participating trade
associations see fit.
There are several benefits in surveying UST pro-
gram managers at this time. First and foremost, the
associations participating in this program are in the
business of providing information of interest to their
members. Up until now, enforcement plans and proce-
dures have not been available to all members of the
regulated community. Second, by developing one sur-
vey and soliciting one response from UST program
managers, the task of supplying this vital information
should not be overly burdensome on the UST program
managers. Third, the availability of one comprehensive
national survey will make it easier for all interested
parties to compare program strategies. Fourth, the
responses to the survey can be quickly, uniformly, and
cost-effectively made available to interested parties.
Finally, UST program managers can benefit by having
access to the enforcement policies and procedures
developed by their colleagues in other jurisdictions.
Readers of LUSTLine who are interested in the
information provided by the UST program managers
should read the next issue to find out the best way to
access the responses. •
y^g^ifcjgg^^
• Coast to Coast continued
clearinghouse, set standards, orga-
nize and maintain statistical analy-
ses, and research and evaluate
emerging technologies and technical
issues.
Some state program managers
responded to this question by stat-
ing what EPA- should not do. For
example, some felt that EPA should
relax its oversight of state programs,
including not making enforcement
actions in a state without concur-
rence from the state and deferring
all programmatic decisions to the
states.
Other areas where state pro-
gram managers believed EPA could
play a vital role include:
• Pushing for standardized report-
ing practices from the states,
including using environmental
indicators.
• Taking enforcement actions that
would lead to court cases. Court
rulings at the national level are
needed to clarify ownership as
well as other UST issues.
• Providing projections on future
funding after the 1998 upgrade
deadline. Future funding projec-
tions are important to states that
are trying to develop long-term
strategies for compliance.
EPA is taking all these suggestions
under advisement as it plans for the
future of the UST/LUST program in
the 21st century.
Much Accomplished, Much to
Be Done
The report card, which was pre-
pared by Paul Sausville of New
York, Kathy Stiller of Delaware,
Richard Spiese of Vermont, Pat Jor-
dan of Wyoming, and Steve
Crimaudo of ASTSWMO and pre-
sented by Scott Winters of Colorado
and Chair of the ASTSWMO Tanks
Subcommittee, was written in an
attempt to provide a snapshot of the
UST/LUST program. The results
show that while much work
remains to be completed, much has
also been accomplished. This pro-
gram demonstrates that effective
communications and sharing of
experiences among states, EPA, and
ASTSWMO can provide for a suc-
cessful environmental program. The
Tanks Subcommittee of ASTSWMO
welcomes your comments on this
report. Comments may be given to
any of the authors of this report, or
to any Subcommittee member. For
copies of this report, contact Steve
Crimaudo at ASTSWMO at (202)
624-5828.
-------
LUSTLitie Bulletin 28
New Publications from
OUST
• Getting the Most Out of Your
Automatic Tank Gauging Sys-
tem (EPA-510-F-98-011) was
released in March. The audience
is UST owners and operators
using automatic tank gauging
systems to comply with federal
leak detection requirements.
This leaflet provides UST own-
ers and operators with a basic
checklist they can use to make
sure their automatic tank gaug-
ing systems work effectively. As
a compliance assistance tool, the
leaflet focuses on what actions
the UST owner and operator
must take to comply with leak
detection requirements and pre-
vent significant cleanup prob-
lems. Like OUST's other leaflets,
this one urges readers to check
with state and local regulatory
authorities for additional or
more stringent requirements.
* Catalog Of EPA Materials On
Underground Storage Tanks
(EPA-510-B-98-001) was re-
leased in March. Its target audi-
ence is state and regional UST
programs, UST owners/opera-
tors, UST contractors, UST trade
and professional associations,
and members of the general
public who are interested in
UST-related issues. The catalog
provides an annotated list of
UST materials and includes
ordering information. Many of
the informational leaflets, book-
lets, videos, and software items
listed are designed to provide
UST owners and operators with
information to help them com-
ply with the federal UST
requirements. (Note that these
materials frequently urge read-
ers to check with state and local
regulatory authorities for addi-
tional or more stringent require-
ments.) Some materials provide
state and regional UST pro-
grams and UST contractors with
more technical information
regarding such matters as build-
ing state programs and conduct-
[EPA HQ UPDATE
ing corrective action. Most
materials are available at no
cost. Note that the catalog
replaces the September 1994
"Guide to EPA Materials on
USTs" (EPA-510-B-94-007). If
you still have copies of the old
"Guide," please recycle them.
I Underground Storage Tank Pro-
gram: Regional and State Con-
tacts (EPA 510-F-98-014) was
released in April. This listing
includes the names, addresses,
phone, and fax numbers for all
of the regional program man-
agers and the addresses (street
and electronic) and phone and
fax numbers for all of the state
UST/LUST programs. You can
download this publication from
WMrw.epa.gov/OUST/ and you
can link from there to many
state and regional home pages.
Leak Detection Fact Sheet #1 for
Some USTs, Inventory Control
"Expires" December 22, 1998
(EPA-510-F-98-012) was
released in May. The audience is
owners and operators of certain
older UST systems (installed
before December 22,1988); they
will no longer be able to use a
combination of inventory con-
trol and tank tightness testing to
meet federal leak detection
requirements. The fact sheet
identifies the affected UST sys-
tems, explains the requirement
to change leak detection moni-
toring for these tanks, and notes
that owners and operators
should check with their imple-
menting agencies for additional
guidance.
To obtain the information listed
above:
For hard copies, call NCEPI at
(800) 490-9198 or EPA's RCRA
Hotline a8424H9546 You
can use the Internet to down-
load a copy (in WordPerfect 6.1
format) by going to OUST's
World Wide Web home page at
11 www.epa.g6v/OUST/ and se-
lecting "OUST Publications."
EPA Issues List of Integrity
Assessment Evaluations
EPA has released a list of vendors
whose procedures to assess the
integrity of bare steel tanks have
been evaluated and certified by
qualified, independent third par-
ties to meet specified criteria. So
far, three procedures have been
evaluated and certified: MTCF®
(Mean Time to Corrosion Failure®)
from Corrpro Companies, Inc. and
Warren Rogers Associates, Inc.;
Tank Environmental Profiling®
(TEP) from International Lubrica-
tion and Fuel Consultants, Inc.; and
Petroscope® from Tanknology-
NDE, Inc. (one of four assessment
parts).
Federal UST rules require
that existing steel tanks that do not
have corrosion protection be
assessed for structural integrity
before cathodic protection can be
added to meet corrosion protection
requirements. Assessment can be
accomplished either through
human-entry internal inspection or
by other "alternative" integrity
assessment procedures. State
implementing agencies may or
may not allow the use of alterna-
tive procedures.
In making decisions about
alternative integrity assessment
procedures that can be used to
comply with December 1998
upgrade requirements, most states
are following recommendations
released by EPA last July, whereby
states agencies allow only those
procedures that either conform to a
valid national code of practice or
have been evaluated by a third
party to meet certain performance
standards. Since there is no such
national code of practice, the third-
party evaluation is the only alter-
native to human inspection.
EPA will update this List of
Integrity Assessment Evaluations
for Underground Storage Tanks as
additional evaluations are com-
pleted. This listing will be posted
on EPA's UST Web site at
www.epa.gov/swerustl /altasses.
htm, or you may contact EPA's
RCRA Hotline at (800) 424-9346.
22
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LUSTLine Bulletin 29
• Enforcement from page 19
1998. We have been diligent in
preparing the regulated community
for the deadline so that no one could
say, 'I didn't know/"
Getting the Word Out
Besides the usual outreach methods,
such as mailings and seminars, last
spring, USTD inspectors visited and
inspected all UST facilities that were
installed prior to December 22,1988,
when the UST regulations became
effective. The inspections revealed
that many of the tanks had already
been closed but had not been prop-
erly abandoned.
At the time of these initial
inspections, owners and operators
received a packet with information
that explained what they had to do
to meet regulatory standards. Last
fall, inspectors began another round
of inspections to these facilities, this
time, giving each owner or operator
a "report card."
The USTD will permit USTs to
be upgraded or closed after Decem-
ber 22,1998; however, the tank will
not be allowed to remain in service.
Even if owners and operators have
contracts or purchase orders for
which upgrade work is scheduled,
they will still not be allowed to oper-
ate their UST if it is substandard.
"By the deadline we will have
inspected all noncompliant facili-
ties," says Nash. "We have had good
cooperation from the industry. We
meet with our stakeholders work-
group just about every month."
Red Tags—The Strategy of
Choice
Michigan's primary method of
enforcing the upgrade requirements
will be though the use of red tags,
which will be affixed to the fill pipes
of USTs that are found, upon inspec-
tion, to be out of compliance. Tanks
that have been red-tagged will be
considered to be out-of-service and
must either be closed or upgraded
within 12 months. Red-tagged'tanks
can dispense fuel until they are
empty. Anyone who knowingly fills
a tagged tank will be committing a
misdemeanor.
"We have been using this
method of enforcement for leak
detection violations," says Nash,
"and have found it to be the most
effective and efficient use of our staff
resources." The USTD has 21 inspec-
tors throughout the state.
How Enforcement Will Work
The USTD will forward a letter to all
LU.S.T.LINE
One-year subscription. $30.00.
owners and operators who, accord-
ing to the database, have not
complied with the upgrade require-
ments, informing them of the dead-
line and of USTD's intention to
red-tag all tanks that are out of com-
pliance after December 23,1998.
"We have a tracking system
and will distribute the names of the
red-tagged facilities to our district
offices," says Nash. "We'll also place
the names and locations of red
tagged facilities on our home page,
which is updated weekly, so that
suppliers and other interested par-
ties can easily obtain this informa-
tion without creating an undue
burden on our staff."
If red-tagging a facility like an
emergency generator tank for a hos-
pital creates a life safety hazard, the
USTD will work with the facility to
secure an alternate fuel supply.
USTD inspectors will also let local
officials know if they are going to
shut down the only fueling facilities
in a community.
Other enforcement methods,
such as criminal arrest and civil
penalties, may be considered for
owners and operators of facilities
where the red tag proves to be an
ineffective method of ensuring that
tanks are no longer in use. •
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.)
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f
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
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Phone: 978/658-0500 • Fax: 978/658-5509 • lustline@neiwpcc.org • www.neiwpcc.org
We welcome your comments and suggestions on any of our articles.
ZIP
23
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EPA's SW-846 (Final Update III) Protocols
Spark Uncertainty in the Field
EPA's publication, SW-846, Test Methods for Evaluat-
ing Solid Waste, Physical/Chemical Methods, is the
Office of Solid Waste's (OSW's) official com-
pendium of analytical and sampling methods that have
been evaluated and approved for use in complying with
the RCRA regulations. SW-846 functions primarily as a
guidance document that sets forth acceptable, although
not required, methods for the regulated and regulatory
communities to use hi responding to RCRA-related sam-
pling and analysis requirements.
SW-846 is a multivolume document that changes
over time as new information and data are developed. It
has been issued by EPA since 1980 and is currently in its
third edition. Advances in analytical instrumentation
and techniques are continually reviewed by OSW and
incorporated into periodic updates to SW-846 to support
changes in the regulatory program and to improve
method performances and cost-effectiveness. The
updated and fully integrated manual contains approxi-
mately 3,500 pages.
EPA's newest version of SW-846 (Final Update III)
includes a number of changes in the collection, prepara-
tion, and analysis of soil samples for volatile organic
compounds (VOCs). Analytical methods 8010 (halo-
genated hydrocarbons), 8020 (aromatic hydrocarbons),
and 8240 (volatiles by GC-MS) have been eliminated and
replaced by methods 8021 (halogenated and aromatic
hydrocarbons) and 8260 (GC-MS). Samples for VOCs
may be prepared for analysis by a variety of techniques,
Including headspace (Method 5021), conventional purge
and trap (Method 5030), and a new, closed-system purge
and trap method (5035).
The new methods also include protocols for sample
collection and sample preservation in the field that are
designed to minimize volatile loss from collection to
analysis. While methanol preservation of soil samples for
VOC analysis is not new (see LUSTLine #28), the sam-
pling, collection, and preservation procedures in Final
Update III contain a number of new protocols that have
created some confusion among regulatory, laboratory,
and consulting community. Consequently, many states
are refraining from implementing the new methods until
the confusion is resolved. EPA plans to issue an
announcement sometime this summer to clarify some of
the concerns. In the next issue of LUSTLine, we'll examine
these new methods and try to bring you up-to-date 0n
what is happening.
How to Obtain a Copy
• An electronic copy of the complete SW-846 manual is
expected to be available this June from the OSW Web
site:
www.epa.gov/epaoswer/hazwaste/test/sw846.htm.
• The National Technical Information Service (NTIS)
offers copies of the current, fully integrated manual
(PB97-156111GEI, $239.00) and the individual copies of
Final Update IE (PB97-156137GEI, $150.00).
• NTIS also offers SW-846 on CD-ROM. It is compatible
with both Windows and Macintosh operating systems.
The CD-ROM utilizes Adobe Acrobat, with a powerful
text search engine and the means to electronically jump
to selected methods via hypertext links. Version 2 of the
CD-ROM includes the entire, official version of SW-846,
Third Edition, as amended through Final Update III.
To order either the paper version or the CD-ROM, contact:
National Technical Information Service
U.S. Department of Commerce
5285 Port Royal Road
Springfield, VA 22161
(800) 553-6847
Prices are subject to change.' To receive a fax with the latest
information about copies of SW-846 from NTIS, call (703)
487-4140 and enter publication number code 8698. •
LU.ST.UNE
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. Buster T-Shirts &
Sweatshirts!
S9.00pp
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