New England Interstate
Water Pollution Control
Commission
Boott Mills South
1OO Foot of John Street
Lowell, Massachusetts
O1S53-1124
LUST.
Bulletin 3S
June
1999
A Report On Federal & State Programs To Control Leaking Underground Storage Tanks
Where Do We Go From Here?
UST Program
Direction for 1999
and Beyond
by Sammy Ng
With the passing of the 1998
deadline for tank owners and
operators to comply with require-
ments for upgrading, replacing, or closing sub-
standard underground storage tanks (USTs), we've
heard some people suggest that UST program work is
now complete. Based on information from states and the
Petroleum Equipment Institute, EPA believes that the
rate of compliance with the 1998 deadline is approxi-
mately 80 percent (and continuing to go up)
nationwide. So, it is true that some of our
work is done—but the job of ensuring
that all owners comply with the techni-
cal requirements, including leak detec-
tion requirements, is far from over.
We are concerned, for example,
that although owners may have
installed leak detection equipment on
their tanks, a significant percentage of these systems
may not be operated or maintained properly. EPA and
states need to work with owners to raise leak detection
compliance awareness and, in doing that, ensure a higher
level of compliance. In short, we need to ensure that we
prevent the next generation of leaking tank systems.
We do not, however, plan to promulgate new regula-
tions as a means to make progress on the remaining work.
Instead, EPA will work closely with states to improve
compliance rates. We will also continue to work coopera-
tively with owners, industry, and regulators to ensure
that preventing releases from USTs becomes a common
business practice and that, if releases do occur, they are
addressed in an appropriate and cost-effective manner.
• continued on page 2
o
c
Combatting CP-Test Heartburn
guiTe^
Managing Your State Cleanup Fund—Part II
in Free Product—Rise Above It Witti PFP
MTBE, Fuel Oxygenates...Now What?
What Dp We Know About Ethanol?
Contamination of Heating Oil and Diesel Fuel with MTBE
Research Study Questions Need for Oxygenates in RFG
Some Enlightenment on Density
Coast to Coast
HQ Update
-------
LUSTLIne Bulletin 32
• Where Do We Go? from page 1
Over the past year, the EPA
Office of Underground Storage
Tanks (OUST) has worked with
environment
'tecied.
numerous UST program stakehold-
ers and gathered feedback regarding
the state of the UST program. This
research confirmed that we still have
a great deal of work to do to prevent
leaks, address the approximately
170,000 cleanups yet to be completed,
and ensure that human health and
the environment are protected.
for
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uiion "Control Commis-
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HEIWPCC
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LUSTLine It printed on Recycled Paper
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As a result, we've identified the
following priority areas where we
will focus our efforts over the next
few years: UST systems evaluation;
operation and maintenance of UST
systems; tanks temporarily closed to
meet the 1998 deadline; corrective
action; and USTs in Indian Country.
So let's look to the future of the
UST program and discuss how we
plan to use these initiatives to take
the program through 1999 and
beyond.
UST Systems Evaluation
A significant challenge to the UST
program is to prevent leaks by ensur-
ing that tank systems are safe and
managed properly. Although most
UST systems are equipped to meet
the technical requirements, we need
to ensure that properly equipped
UST systems do, in fact, protect the
environment. That means we need to
evaluate those systems.
EPA will work to help states
evaluate the effectiveness of UST sys-
tems, particularly in terms of leak
detection, cathodic protection, and
lined tanks, to ensure they operate
properly and to identify ways in
which they can be improved.
Anecdotal evidence suggests
that UST systems performance has
improved greatly compared with
that observed just a decade ago.
However, we need to conduct a more
comprehensive effort to check these
anecdotes against reality and identify
areas that need to be improved. EPA
is interested in field performance
over time, which portrays the real sit-
uation, rather than performance in
factory testing, which shows only the
best possible results.
The UST program is taking ini-
tial steps to begin this evaluation
work, including conducting a Uni-
versity of California-Davis study of
leak detection system performance,
gathering qualitative input from
experienced people in the business,
and compiling existing studies and
data bases. These efforts will help us
verify and validate how effectively
leak detection and other UST sys-
tems are working.
Operation and Maintenance
of UST Systems
To achieve the goal of preventing
another generation of leaking USTs,
EPA has targeted operation and
maintenance (O&M) of UST systems
as a priority. We've heard that own-
ers and operators often do not have
adequate knowledge of facility
equipment and procedures and that,
partly because of employee turnover,
owners and operators need to be kept
informed about and educated on the
proper methods for using their
equipment on a continuing basis.
EPA wants to work to resolve this
dilemma and ensure that owners and
operators are properly operating and
maintaining their UST systems and
employing quality tank management
practices.
As a preliminary step, we have
formed an EPA-state workgroup
whose goal is to develop ideas into
useful products. In addition, we are
working with the U.S. Postal Service
to assist the agency in developing its
O&M plan and to foster an exchange
of ideas and information between our
two agencies. Over the next few
months, we will gather O&M infor-
mation and work with the many
stakeholders (other EPA offices,
states, industry, trade associations,
and other interested parties) to
implement quality O&M ideas.
r • • ,,
r Although mast UST systems are
|U m m it Si U 1)
- equipped to meet the technical
',*. vim • ..Li,",.. ** L! *i" t*S".!I
* " ""
k> w
* thai properly equipped UST systems
"*
rfo, //? fact, protect the environment.
Temporarily Closed Tanks
To meet the 1998 upgrade require-
ments, many owners temporarily
closed their tank systems. EPA esti-
mates that, as of February 1999, the
number of temporarily closed tanks
was approximately 73,000. Perhaps
these owners were not ready or able
to make final decisions by December
1998 about the future of their tanks.
However, it is important for the own-
ers of these tanks to remember that
temporary closure of substandard
systems may not exceed 12 months,
unless the implementing agency
grants an extension.
-------
LUSTLine Bulletin 32
porary" limitation on their closure.
They should, be taking steps now to
close permanently, upgrade, or
replace their USTs within the 12-
month time limit. State and federal
regulators will be working to ensure
owners take appropriate action
regarding temporarily closed USTs.
Corrective Action
EPA's work in the corrective action
area has been, and will continue to
be, extremely important to the UST
program's success. As of March 1999,
there were approximately 170,000
cleanups that had not yet been com-
pleted; EPA estimates that as many
as 80,000 additional releases may be
confirmed before 2005. As you are
well aware, the UST program has a
reputation for keeping current with
change, as well as for serving as a
model for other environmental pro-
grams. In that vein, we are continu-
ing our corrective action efforts in
two innovative areas: risk-based
decision making (RBDM) and pay for
performance (PFP).
EPA is advocating the use of
RBDM at corrective action sites.
RBDM provides UST implementing
agencies with a reliable process to
help them determine the extent and
urgency of corrective action as well
as the scope and intensity of their
oversight of corrective actions.
We are seeing progress in this
area as the varied stakeholders—fed-
eral, state, and private sector—work
cooperatively to foster change. EPA
is measuring RBDM performance in
pilot programs by analyzing the
effects of RBDM on reducing risk,
expediting closure of impacted sites,
and improving cost control and
resource allocation. Some of the early
results we've seen suggest that where
states have used RBDM, they have
realized increased closure rates and
benefited from a decreased backlog
of releases.
We are also championing the use
of a pay for performance approach
for UST cleanup work. The PFP con-
cept is based on the premise that
states pay cleanup contractors only
for actual contamination reductions.
Real results are showing that these
PFP cleanups can reach environmen-
tal goals up to twice as fast as those
using traditional ways of paying for
UST cleanups—and they are as much
as 35 to 50 percent less costly! EPA is
working with states, other federal
agencies, and interested private Enti-
ties on ways to create and operate
PFP cleanup programs and is contin-
uing to document the effectiveryess
and efficiency of this concept. '.
EPA is also developing strategies
for reusing "USTfields," those com-
mercial and industrial sites where
gasoline and other regulated sub-
stances from underground storage
tanks have contaminated the envi-
ronment. After corrective action
work has been completed, USTfield
properties can be restored and
' It is important for the owners of
'-"• these tanks to remember that
^temporary closure of substandard
S»-
^systems may not exceed 12 months,
pjwj/fss the implementing agency
iuT1 \ grants an extension.
reused, and can serve as an asset to
the community. We are working to
prevent future USTfields and encour-
aging states to use scientifically
sound, rapid, and cost-effective cor-
rective action at leaking under-
ground storage tank sites. I
USTs iin Indian Country ]
EPA has primary responsibility;for
implementing the UST program in
Indian Country. There are approxi-
mately 3,000 active USTs in Indian
Country, as well as approximately
3,700 closed USTs that may need
additional remediation work. The
major challenges for these UST own-
ers and operators are finding the
resources to operate their USTs prop-
erly and paying for cleanups if a
release occurs. Because of some
national and state institutional barri-
ers for providing funds for UST work
in Indian Country, we are taking
steps to ensure that owners and oper-
ators will continue to make progress
on both counts.
Let's Keep Up the Good Work
Finally, we greatly appreciate the
exemplary efforts over many years of
all owners, industry members, and
regulators who have worked so dili-
gently to prevent and clean up leaks
from underground storage tanks,
thereby keeping the nation's ground-
water protected. Together we have
made significant progress and can be
quite proud of our accomplishments.
By continuing to work together, we
will make advances in making sure
that the prevention of leaks is a com-
mon business practice. •
Sammy Ng is the Acting Director of
the U.S. Environmental Protection
Agency's Office of Underground Stor-
age Tanks (OUST). He previously
served as the office's Director of the
Policy and Standards Division and as
chief of the Regulatory Analysis
Branch. Sammy has worked in OUST
since its inception in 1985.
JJUSJUNE INDEX
_^^ August 1985/BullteLin ffl - March 1999/Bulletin S31
At Long Last...
The missing piece to the LUSTLine puzzle is in
place!
The LUSTLine Index—the long and action-
packed story of USTs and LUSTs in the late 20th
century is here for ypu. (In fact, subscribers
received their copy livith this issue of LUSTLine.)
Copies are available from NEIWPCC
(978) 323-7929
-------
LUSTLine Bulletin 32
Leak Prevention
UST System Performance
Evaluation
Sorting Out the
Nature of the Beast
by David Wiley
"X Tbzw that the 1998 deadline for upgrading, replacing, or
JL \ closing substandard UST systems has passed, we may
need a rest—in fact, we may deserve a rest.
Break's over! Back to work.
The challenge of achieving sound
tank systems management is not
over—one of the remaining priorities
facing the UST program is improving
operation and maintenance. (See
"Where Do We Go From Here?" on
page 1.)
In keeping with this challenge,
we must also undertake the task of
evaluating of how well UST systems
are doing their job. We need to dig in
and try to find out whaf s working,
what's not, and why not. We need to
zero in on real-world performance—
in the field and over time—not just
fresh-from-the-factory performance.
Because no one entity has all the
relevant information needed to carry
out this task, cooperation from both
industry and regulatory agencies is
essential. It's a bit like the story of
blind-folded people describing an
elephant. If each one draws a conclu-
sion based on just one perspective,
the picture is likely to be somewhat
distorted. But if all parties talk (and
listen) to each other, the true nature
of the beast becomes dear.
Looking at Ail the Angles
The UST program is now following
plans to evaluate performance from
multiple angles. A nationwide study
of leak detection system performance
is now under way (but if s not too
late to become a participant!). We've
begun gathering existing studies and
databases, plus new information and
wisdom from "old hands" in the
business. Next, we'll beef up our peer
input (interested?), move partnering
with states and industry (thaf s you)
to an expanded level, analyze the
FEDERAL
AGENCIE5
A STATE
AGENCIES
situation, and, finally, make recom-
mendations for any needed
improvements. So we'll be looking
for a few good men and women,
and we'll be asking them questions:
• Are you an experienced contractor
or regulator with tales to tell?
• Do you have any studies of UST
system performance?
• Do you have both UST and LUST
site data (which would allow com-
parisons between the compo-
nents/technologies used and the
likelihood of leaks)?
• How well are UST systems doing
their job? What are the root causes
of remaining—or new—problems?
• What UST areas do you think
need more or less attention?
• Can you help us get a handle on
UST system performance (even if
it's just relating experience over
the phone)?
It is important that we do this
work well and with conviction—an
honest evaluation will benefit every-
one in the UST community, except
perhaps providers of poor equipment
and "fly-by-night" services. Let's
share our individual "views" of the
UST system animal as we move
ahead. If you are interested in partici-
pating in this evaluation effort as a
contributor of information or as an
independent peer reviewer, contact
David Wiley at wiley.david@epa.gov or
(703) 603-7178. •
David Wiley is an Environmental
Engineer with the EPA Office of
Underground Storage Tanks (OUST).
He coordinates OUST's leakpreven-
tion technical program, leads the EPA
portion of the UST system evaluation
effort, and participates in the national
Work Group on Leak Detection
Evaluation.
FYI
A recent EPA Office of Research and Development report, "Oxygenates in Water:
Critical Information and Research Needs," looked at all known research projects
related to determining the presence of oxygenates in water (and to keeping oxy-
genates out of water). As of December 1998, only 3 of 77 known projects dealt
with leak prevention. (U.S. EPA, EPA/600/R-98/048, Dec. 1998, Appendix 2)
-------
Leak Prevention
LUSTLine Bulletin 32
by W. David McCaskill '
David McCaskill is an Environmental Engineer with the Maine Department of Envi-
ronmental Protection. Tanks Down East is a regular feature o/LUSTLine. As '.
always, we welcome our readers' comments.
Convenience Is Nice, But UST
Systems Aren't Potato Chips
Life sure seems busy! During the week, we're busy filing into our local, super con-
venience store, fueling our car with gasoline and ourselves with designer coffee
and gourmet danishes. On the weekend, we spend time driving our gritty, salt-
sprayed, progeny-packed SUV back to the local convenience store to retrieve that show-
room shine at the high-tech, brushless car wash. Then when we need our 3,000-mile oil
and lube, we head right back to that very same convenience store. Yep, there's a lot '•
going on at your typical, modern, co-branded convenience store. And just as we cus-
tomers like our conveniences, so do tank owners and operators. '•
I'm thinking of one local convenience store just off 1-95 and right down the road
from a certain high-customer-traffic outlet town known for its rubber-bottom boots! The
store has a high-throughput, highly pressurized fueling system that is just as high-tech
as the coffee and the carwash. It's got double-walled tanks and piping, continuous inter-
stitial-space monitoring, automatic tank gauges, line leak detectors—the works. The
system is so well endowed, you'd think it could handle all its own affairs and make its
own coffee to boot. But that's where we often fail our UST systems—we depend on them
to do too much all by themselves. , '
Last March, the owner of this Maine facility got a major jolt that no high-test '
designer coffee could induce—raw gas came gurgling out of the adjacent storm drains'.
The troops, including the town fire brigade, a Maine Department of Environmental,
Protection (MDEP) responder, and the cleanup contractor with his ever-ready indus-
tanks and pining and my sophisticated leak oftwo weeks/ about 3r000 gallons of
detection system-l don't have to worry!! gasoline and water wer£ r*overedfbut
inventory records indicated that around
4,000 gallons were "missing"! '
Thankfully, the station was located in
an area served by town water, so groundwa-
ter contamination was not as much an issue
as public safety. In this installment of
"Tanks Down East,"your :
trusty gumshoe will deal
with the issue of siting
and maintain-
ing gasoline
convenience
and variety \
stores. :
The Murky Details
So how the heck did 4,000 gallons
slip through the multiple defenses of
this very model of a modern storage
system? Well, as with many such
cases, it was the combination of cas-
cading equipment failure combined
with faulty follow-up.
This UST system consisted of
double-walled fiberglass tanks and
pressurized double-walled piping. In
this type of piping system, the prod-
uct is moved from the tank to the dis-
penser and nozzles by a submersible
pump inside the tank. The product is
sucked out of the tank by the pump
to a manifold that sits on top of the
tank, where it is then pushed up
through the piping.
In this installation, the sub-
mersible pump manifold, which con-
tains electrical connections to the
motor and plumbing to the piping, is
housed in the containment sump so
that any leaks from the pump or pip-
ing can be contained and monitored.
The sump itself is attached to the
tank opening via a pressure plate and
rubber gaskets.
This piping system is monitored
for leaks in two ways. The first is a
line leak detector—a device used to
monitor for catastrophic piping leaks
(i.e., three gallons per hour or more )
and located, in most cases, in a port
on the submersible pump manifold.
The line leak detector will only detect
three gallon per hour leaks down-
stream of where it is installed.
Second, smaller leaks are
detected by leak detection sensors,
which are located near the bottom of
the containment sump. Most of these
probes are micro float switches,
• continued on page 6
-------
WSfflne Bulletin 32
B Tanks Down East from page 5
which, when immersed in liquid,
make an electrical contact, sending
an alarm to the control box.
The stage is set, so now let's see
how this chain reaction got started
and what kept it going.
On March 10, a contractor was
called to investigate a customer com-
plaint about a low-flow condition at
the dispenser nozzles. Gasoline was
found dribbling out of the pump
manifold, and about one-half gallon
had pooled in the bottom of the
sump. The pump manifold was
opened and fibers from an ingested
sorbant pad were found to be restrict-
ing the flow. A failed gasket was
replaced, and product was removed
from the sump.
On March 11, the gasoline gur-
gled out of the storm drain and the
troops arrived.
On March 12, the contractor was
called back to the site to test the prod-
uct line for the unleaded tank, which
was found to be tight; however,
when the containment sump was
tested by filling it with water, all the
water leaked out. Further investiga-
tion found that the gasket at the bot-
tom of the sump was torn and had
allowed product to leak out.
Later, a review of the electronic
alarm history by the MDEP showed
sump alarms on December 21,1998,
January 3,1999, and March 3,1999.
The owner stated that the first two
alarms were the result of water infil-
trating through the sump covers dur-
ing a storm event (rain). Each time
the alarm sounded, the manager had
removed about two inches of water
from the sumps. The owner stated
that the manager was not aware of
the March alarm.
A review of the inventory showed
a loss of around 4,000 gallons of gaso-
line from March 3 to March 11.
Vigilance Matters
What could have been done to pre-
vent this problem? It boils down to
maintenance and vigilance. The sys-
tem, as a whole—pump, line leak
detector, containment sump—missed
the boat, and someone didn't
respond to the sump probe alarm (or
at least not appropriately).
This UST system was literally
screaming for help, but unfortunately
the operator probably thought that it
was crying "water in the sump" wolf.
The clues to this catastrophe were all
there, but no one person heeded
them all or knew what they all
meant. Someone needed to step back
and put the whole thing together.
In the design of the storage sys-
tem, the owner could have elected to
install fiberglass sumps, which are
bonded directly to the tank and
thereby eliminate the reliance on a
gasket. Also, I believe that all contain-
ment sumps should be tested annu-
ally for leaks by filling with them
with water to see if any leaks out.
As for false alarms caused by
"nuisance" water coming through fit-
ting penetrations and sump covers,
the industry has been striving to
develop a totally liquid-tight sump
and, for the most part, has...well,
they're gettin' there. However, we
still have to contend with retrofitting
those older first- and second-genera-
tion sumps that remain.
Station owners need to be more
vigilant in inspecting and responding
to problems. Another long-time sta-
tion owner who now teaches UST
management courses told me of a
similar event at his station some years
ago. As in the first story, he had a
pressurized piping system with con-
tainment sumps, line leak detectors,
and leak detection float switches.
As a cagey, veteran service sta-
tion owner, he recognized the folly of
relying solely on the technology, so
once a month he would open up his
containment sumps to take a look-
see. During one of these monthly
walkovers, he found, much to his
horror, a sump a couple of inches shy
of being full of gasoline!
In this case, the leak occurred
near the top bolts of the actual line
leak detector; since it couldn't check
itself, it never "saw" the leak. The
sump leak detection floats were
physically stuck in place and could
not float up with the product and sig-
nal a leak.
Facility Siting Matters
The sites mentioned above were in
areas where water supplies were not
threatened. In the case of the station
mentioned in LUSTLine Bulletin 31,
"A Little Drop'll Do Ya," and Bulletin
#30, "The Holes in Our UST Systems,"
a modern convenience store was
allowed to be located within 1,000 feet
of a water supply well field.
For whatever
reasons, the town
carved an area out
of its mapped
wellhead protec-
tion zone so that
the station could
be built. Within
less than a year of
operation, MTBE
was found in low
ppb concentra-
tions in the water
district's monitor-
ing wells and production wells (7,000
ppb concentrations were found in the
tank excavation area).
The source of contamination was
most likely several 10-gallon over-
fills, something that happens when
fuel delivery truck drivers override
the overfill prevention device. A dri-
ver may think he's filling a 10,000-
gallon tank, but in reality, he is
dealing with a 9,700-gallon tank. So,
on occasion, he is stuck with a hose
full of product. Because he has more
in the truck compartment than the
UST can hold, he empties the hose
into the 3-gallon spill bucket and the
rest spills over and seeps into the sur-
rounding soil. Again, our fancy tech-
nologies will do little good if we don't
fully understand how they work.
One year after responding to the
MTBE problem at this site, per-
chloroethylene was detected in the
monitoring wells and traced back to
the store's septic tank and sink traps!
We don't know how or why perc
was poured down the cleaning sink.
The real lesson here is that this site is
too sensitive for a convenience store
or just about any other type of land
use that could accidentally discharge
a contaminant into the environment.
The real shame is that the water
district will abandon this precious
resource and pipe water at great
expense to the area from a surface
source.
Yes,, Facility Siting Matters
Another case I know of involves a
typical small mom and pop (except in
this case, pop has a ponytail) variety
store that sells gas. The store is
located less.than 1,000 feet from a
major sand and gravel municipal
water supply well.
For several years, the water dis-
trict fought to prevent the construc-
tion of the store. Nevertheless, in the
-------
LUSTLine Bulletin 32
earty 1980s ii came to be, decked out
with a suction piping system and
bare steel tanks. In 1990, MDEP staff
inspected this site and found that
piping under the pump island had
been damaged, most likely as the
result of a car running into the dis-
penser.
The investigation that followed
found minor contamination around
the fill pipe, but much more from
leaky aboveground suction pumps.
Again, the tanks and underground
piping were not the problem. The
problem was that the leaks could
have been caught early through sim-
ple, routine inspection.
By the grace of Gaia, the water
district had installed a monitoring
well system as part of its wellhead
protection plan. This system allowed
MDEP instant access to groundwater
data to help expedite its plan of
attack. Thankfully, the story ended
well, with only the fairy edge of the
gasoline plume tickling the produc-
tion well with low and ephemeral hits
of MTBE—but at a cost of $600,000 to
pay for a multiphase remediation sys-
tem and two years of water piped in
from the adjacent town
The Sermon
It's clear that some of these stations
should never have been allowed to
be built so close to major water sup-
plies. Unfortunately, many towns
and cities suffer from the all-consum-
ing lust for property taxes, and we,
the consumers, suffer from the insa-
tiable need for convenience. We're
such slaves to technology that we for-
get how far a little horse sense can go.
No matter how good the storage
technology, it is still true that an
ounce of siting prevention is worth
many hundreds of thousands of dol-
lars of remediation.
In many cases, tank owners and
operators think they can simply buy
the convenience of compliance. But
technology ain't all if s cracked up to
be, and it is up to owners and opera-
tors to keep a vigilant eye on things.
Large industrial plants go to great
lengths to physically check and dou-
ble-check processes that involve dan-
gerous chemicals. Station owners,
operators, and employees need to
treat their facilities in much the same
way, because gasoline is not potato
chips—it is a dangerous chemical
that is both toxic and flammable. •
TIPS FOR TANK OWNERS AMD OPERATORS
aintaining a modern gas station is a team effort. Here are some timely tips
i>r reducing your environmental impact.
Homers ' " " : ''" ~
_ JMSf?ffi££;":"'~ *_«,. ^J^^Lt £*•£.',
' Ejicpurage customers motto top off their tanks. This will reduce the ,
gJikelihood of spills thai could cause fires and contaminate groundwater
"Lflfid surface water. ... . .',
Place signs on the dispenser, encouraging customers to report prob-
lems, such as slow flow, excessive vapors, and spills, to the attendant.
Employees
__ HHold monthly environmental, health, and safety meetings to review
^emergency response protocols with employees.
Be sure employees know the meaning of all environmental and fire
j^Jsirms, the correct response, and the consequences for not reacting
L,* properly.
^Educate employees on the dangers of gasoline and other chemicals
^wiifch which they come in contact at work. (OSHA law 1910.12O, Haz-
yjr%usreginmjBnicatiojtts) ••" . ^
fwiiier/Operators
. JJmderstand how your UST system works, and read the operation man-
« ualfor your leak detection system.
*h? * * " f -. * ...,-•:.'-*? -e-~. „ • •:-'<• '.,,-. ,-- ,.-. ,,.,.- ,,.-,, ,, ..-..„. ;, • , ff ,.:,,; ,
' Make sure you know how much fuel you can actually put in your tanks.
You must know at what Liquid level your overfill prevention devices are
activated. Do not order more fuel than a tank can hold!
^Vgjk. you r facility site once a day to look for obvious signs of dis-
charges (e.g., strong vapor odor, distressed or dead vegetation).
' Inspect containment sumps and look under dispensers once a month.
nk and Pump Contractors
tnceayear:
Test and calibrate all electronic leak detection devices per manufac-
^Juj^r's^ecommendations.^^ _ ^ ^'w ^^ ^ _h ^^^ ^.^^ ^a^,.^,^a^
^Leak-test all containment sumps with water.
Jnspect all fire safety equipment (i.e., proper anchoring and operation
pf crash valves and hose breakaways). These devices prevent fuel from
spilling from pressurized piping systems if the dispenser is hit or a cus-
"^omerdrives offwith the hose still in thetanlk^ ^ ^ ,
.LRhysically check all leak detection probes for proper operation. Make
'"sure float sensors in containment sumps work by either immersing
them in water or employing some other method described in the opera-
tion manual, j
Physically inspect all overfill devices for proper operation (i.e., do they
shirt off or set off the alarm at the prescribed level?). This step includes
^ exl racting ball float valves to make sure the cage hasn't rusted away.
piHiSlVu.furf afflff irts^af-wiakBi*. »;- i *• *• 3Jl'^^::r^y,T^lVl':J^1.tl£!aiffl1.^!eli1*i^a^^
pei'form quantitative 3 gallon per hour leak tests on both mechanical
and electronic line leak detectors. These devices are very important,
because they are designed to guard against catastrophic releases.
Jtiel Delivery Drivers
V Contract with your fuel delivery company to ensure that all spill buck-
J~ ets are free of product after delivery, so that excess product does not
iJ^float out during a heavy rain.
• Be sure delivery drivers understand how your overfill prevention
F device works. ^ , •
' Observe your driver during a delivery to make sure that he or she is
^---requirements.
-------
LUSTLine Bulletin 32
nicalfy Speaking
by Marcel Moreau
recognized petroleum storage specialist I
|'whose column, Tank-nically Speaking, ,
f zs a regular feature o/LUSTLine. As 1
j' always, we welcome your comments and
shorts. If there are technical issues that\
you would like to have Marcel discuss, '
Combatting; CP-Test Heartburn
A Thoroughly Documented CP Test Is the
Recommended Antacid for Coping with Symptoms
Associated with the Common CP Inspection
After 10 long years, the '98 deadline can finally be talked about in the past tense. As predicted,
many storage system owners waited 'til the end was nigh and then wondered why finding
people to do the work was like looking for water in the desert. Amidst all this chaos, of course,
were the entrepreneurs who, upon seeing financial opportunity knocking, rummaged up workers and
provided the "services" needed to meet tank owner demands.
The result is that a lot of shoddy tank work has been done in recent years, especially in those areas
of the tank upgrade market that are attractive to tank owners on tight budgets—tank lin-
ing and cathodic protection (CP). Although the potential problems created by fly-by-
night lining contractors may be buried and hidden from the inquisitive eyes of the
typical UST inspector, there are some things that inspectors can see with regard to a
cathodic protection retrofit—things that can give an inspector pause, if not heartburn.
Unfortunately, no matter how poor the workmanship, an inspector has little
to say about the cathodic protection installation, as long as it has been
blessed by a legitimate "corrosion expert" as defined in the rules and
explained in EPA memos. (Refer to LUSTLine #23 for a description of
qualified personnel.)
What Constitutes an
Acceptable CP Test?
I do believe, however, that the regu-
latory inspector has some say when it
comes time to evaluate the perfor-
mance of a cathodic protection sys-
tem by conducting the initial CP test
or the triennial CP test. Here's how:
The federal rule (40 CFR
280.31 (b)(2)) contains no specific CP
test criteria; it defers instead to indus-
try standards such as NACE RP0285,
"Control of External Corrosion on
Metallic Buried, Partially Buried, or
Submerged Liquid Storage Systems."
(The current edition of this docu-
ment, RP0285-95, has a slightly dif-
ferent title, "Standard Recommended
Practice—Corrosion Control of
Underground Storage Tank Systems
by Cathodic Protection.")
This NACE standard and others
that I have reviewed describe specific
testing criteria and methodologies for
making measurements but provide
8
precious little guidance about what
constitutes an adequate CP test.
There are no specifications concern-
ing how many measurements should
be made or how thoroughly a CP
tester should investigate a system.
These types of decisions are appar-
ently left to the discretion of the
tester, leaving the door wide open for
some testers to be thorough and oth-
ers to be quick.
Because the requirements for a
CP test are not specifically spelled
out in the federal regulations or
industry standards, it seems appro-
priate for regulators to fill the void
and set a minimum standard for
what constitutes an acceptable CP
test. The folks in EPA Region 4 did
just that; they developed a standard-
ized form to be used when docu-
menting the results of a CP test of an
UST system.
What data should be recorded
during a CP test and why are these
data important? A properly con-
ducted and documented CP test will
determine whether a CP system is
adequately protecting its associated
storage system. If the storage system
is not protected, then all of the bless-
ings of a CP expert are moot, and the
system must be made to work.
A thorough, properly docu-
mented CP test should enable a
knowledgeable reviewer to answer
three questions about an UST system:
• Are sufficient data presented in
the test report to evaluate the test
results?
H Were a sufficient number of appro-
priate measurements conducted
during the test to fully evaluate
the storage system?
H Were appropriate CP test criteria
used to arrive at a pass or fail test
result?
Let's review each of these questions.
But first, some caveats. To keep the
-------
LUSTLine Bulletin 32
following discussion from, becoming
an epic, I have limited the scope to
the "typical" underground storage
system at the "typical" convenience
store or service station. I am assum-
ing that the reader understands the
mechanics of making CP measure-
ments (See LUSTLine #25, "Testing
Cathodic Protection Systems," for a
refresher) and has some knowledge
of CP principles. While I believe the
discussion that follows is generally
applicable to most storage systems,
no doubt valid exceptions exist to the
information and opinions presented.
Are Sufficient Data Presented in
the Test Report to Evaluate the
Test Results?
All too many CP test reports merely
indicate that on a certain day a cer-
tain facility was tested and that the
storage system(s) "passed." In some
cases, a number may be added (e.g.,
"-0.911 volt—pass"). In some cases,
especially where the monitoring
results are less favorable, a number
(e.g., "-0.777"), without even a pass
or fail conclusion, is the extent of the
test documentation.
Such results are incapable of
being evaluated, because there is
nothing to evaluate. Simply not
enough information is presented to
determine whether the second and
third questions listed earlier have
been adequately answered.
My criterion for an adequately
documented CP test is simple: There
should be sufficient documentation
so that any knowledgeable CP tester
should be able to return to the facility
and make the same measurements in
the same places.
This criterion means that there
should be fairly exact descriptions of
where the reference cell was located,
where connections were made to the
cathodically protected structure, and
what types of measurements (e.g.,
continuity, current-on, instant-off,
polarization change) were con-
ducted. There should also be a
pass/fail conclusion and a statement
describing which CP criterion was
used to reach the pass/fail conclu-
sion for the test results.
Such detailed documentation is
critical to a long-term understanding
of what is happening to a CP system.
If performance of a system is to be
compared from one CP test to the
next, all CP tests must be conducted
in the same way. A remote "current-
on" reading cannot be compared to a
tank-top "current-off" reading. A
reading where the reference1 cell
comes in contact with soil cannot be
compcired to a reading where the ref-
erence cell is placed on concrete.
Unless measurements are made in a
nearly identical fashion each time a
CP system is evaluated, comparison
of CP test measurements conducted
at different times is meaningless.
'ecause the requirements for a CP
test are not specifically spelled out
'nthejederal regulations or industry
JLjJUSfl. fluM-M •* t P f W 1 t
i standards, it seems appropriate for
^regulators to fill the void and set a
minimum standard lor what
constitutes an acceptable CP test.
Were a Sufficient Number of
Appropriate Measurements
Conducted to Adequately Assess
the CP System? i
I have monitored many systems, both
impressed current and galvanic,
where portions of a tank met accept-
able criteria for cathodic protection,
but other portions of the same tank
did not Cathodic protection is not an
all-or-nothing phenomenon. It is the
rule, rather than the exception, that
different portions of a storage system
will hcive different levels of prcjtec-
tion, depending on distance from the
anodes, areas of localized coating
damage, variations in moisture con-
tent of the backfill around the storage
system, and a host of other variables.
Therefore, it seems unreasonable
to accept a single measurement with
a reference cell in a single location as
evidence that a storage system is ade-
quately protected. Yet many CPjtest
reports contain a single number for a
tank. In some cases, tests of galvanic
CP systems are conducted by moving
the reference cell around untjl a
"passing" reading can be obtained—
regardless of whether the reading is
local or remote, on concrete, or on the
metal ring of a manway. Once this
"passing" number is found, all other
readings are discarded. i
The UST rules require that all
portions of a storage system that rou-
tinely contain product and that come
in contact with the soil be adequately
protected against corrosion. Thus a
storage system must be thoroughly
evaluated to ascertain that all por-
tions of the tank and piping are pro-
tected—not just the end that happens
to be close to a working anode.
In my opinion, voltage measure-
ments for a standard-sized motor fuel
tank should be made with the refer-
ence cell in at least three locations:
one with the reference cell at one end
of the tank, one on the other end, and
one in the middle. The reference cell
should be placed as close as possible
to the top centerline of the tank. If the
tank is completely covered by con-
crete or asphalt, then holes should be
drilled into the concrete or test sta-
tions installed to provide access to
the soil for placement of the reference
ceU.
Voltage measurements fall into
two categories: current-on and cur-
rent-off. Current-on measurements
are conducted with the protective
current applied (i.e., with the sacrifi-
cial anodes connected or the rectifier
power turned on). Current-off mea-
surements are conducted with the
protective current turned off (i.e.,
with the sacrificial anodes discon-
nected or the rectifier power turned
off).
Current-on measurements are
the only option possible for virtually
all galvanic systems installed on stor-
age tanks, because the anodes are
permanently attached. Both current-
on and current-off measurements
should be conducted for impressed
current systems. The current-on mea-
surements indicate the distribution of
current on the structure and where
the weak spots in terms of protection
may be located.
The current-off (instant-off) mea-
surements indicate whether the 0.85
volt current-off criterion has been
met or what the starting point for the
100 millivolt polarization decay mea-
surement is. If the 0.85 volt current-
off criterion is not met, then voltage
readings tracking the polarization
decay should also be conducted and
recorded, unless native potential
readings are available to establish
that the 100 millivolt polarization
change criterion has been met.
Galvanic and impressed current
systems should also include a conti-
• continued on page 10
-------
LUSTUtteBttlletiH32
• Tank-nicaHy Speaking from page 9
maty survey to establish that compo-
nents, such as tank fittings, risers,
and vents, are either isolated (gal-
vanic systems) or continuous
(impressed current systems). (See
LUSTLinc #25, "Testing Cathodic
Protection Systems," for information
on how to conduct a continuity mea-
surement.)
Were Appropriate CP Test
Criteria Used to Arrive at a Pass
or Fail Test Result?
The appropriateness of CP criteria is
one of the more prominent hot but-
tons among CP professionals. (For a
great compilation of the CP criteria
literature, see the 500-page NACE
publication, "Cathodic Protection
Criteria—A Literature Survey," pub-
lished in 1989.) The 1995 edition of
NACE Standard RP0285, "Standard
Recommended Practice—Corrosion
Control of Underground Storage
Tank Systems by Cathodic Protec-
tion," contains three acceptable crite-
ria for cathodic protection:
• 0.85 volt (850 millivolts) current-
on, defined as follows:
A negative (cathodic) potential of
at least 850 mV with the cathodic
protection applied. The potential
is measured with respect to a satu-
rated copper/copper sulfate refer-
ence electrode contacting the elec-
trolyte. Voltage drops other than
those across the structure/elec-
trolyte boundary must be consid-
ered for valid interpretation of
this voltage measurement.
0.85 volt (850 mV) current-off,
defined as follows:
A negative polarized potential of
at least 850 mV relative to a satu-
rated copper/copper sulfate refer-
ence electrode.
I 0.1 volt (100 mV) of polarization
change, defined as follows:
A minimum of 100 mV of cathodic
polarization. The formation or
decay of polarization can be used
to satisfy this criterion.
wumenled CP test is simple: There
^nowJedSeatileWtester
e able to return Jo the
e same places.
What About the Criteria?
While the 0.85 volt current-on crite-
rion is one of the most commonly
used, it is also by far the most com-
monly abused. This criterion is most
appropriate for use in structures
where there is little current flowing
through the soil (the meaning of the
last sentence of the criterion), which,
in most cases, means structures that
are very well coated.
Application of this criterion to
structures that are essentially bare
(e.g., asphalt coated), whether the
system has been equipped with gal-
vanic or impressed current CP, in
most cases will produce apparently
"passing" results that are seriously in
error. This criterion should be limited
to well-coated, galvanically protected
structures, such as STI P3 tanks. It is
inappropriate for impressed current
systems.
The -0.85 volt current-off crite-
rion is simple and can be used on any
cathodically protected structure,
coated or uncoated, where it is possi-
ble to interrupt the protective
current, either by temporarily discon-
necting the anodes (galvanic sys-
tems) or temporarily turning off the
rectifier (impressed current systems).
If the potential (voltage) of the struc-
ture is -0.85 volt or greater (more
negative) immediately after the pro-
GP-TESTING MEASUREMENTS WELL COATED
Curtent-on readings with reference cell in at least three locations: both ends and middle of the tank.
For piping, reference ceil al both ends and every 10 feet along the piping run. *
Current-erf) readings with reference ceil in three locations: both ends and middle of the tank. For pip-
ing, reference cell at both ends and every 10 feet along the piping run.
Continuity testing for all metallic components connected to the tank or piping, including fill pipes, vent
lines, automatic tank gauge risers, electrical conduit, etc. x
Impressed current systems may also need to be evaluated for possible effects on adjacent structures,
such as metallic natural gas lines or water lines. This step would involve checking for continuity and
comparing current-on and current-off potentials on the adjacent structures.
Impressed current system test documentation to include the voltage and amperage output of the
rectifier.
GALVANIC IMPRESSED
POORLY COATED CURRENT
X X
X X
X X
X
X
To pass, the 0.85 volt current-on criterion must be met at all reference cell locations along the length
of ttts tank. x
To pass, the 0.85 volt current-off or 100 mV polarization change criterion must be met at all reference
cell locations along the length of the tank.
CP tests should be sufficiently documented so that any knowledgeable person can make the same
measurements in the same places. At a minimum, the CP test report should include a site sketch, the
reference cell locations, structure connections, voltmeter readings, type of measurement (e.g., conti-
nuity, current-on, instant-off), the criterion used to evaluate the storage system, and the conclusions
(r e,, protected or not protected against corrosion). X
X X
X X
10
-------
LUSTLine Bulletin 32
r
tective current is interrupted, the cri-
terion is met.
The -0.85 volt current-off crite-
rion is rarely relevant to galvanic sys-
tems because, in most cases, the
anodes cannot be disconnected. It can
be applied to impressed current sys-
tems. In my experience, however,
this criterion is rarely met on all por-
tions of a storage system.
Like the -0.85 volt current-off cri-
terion, the 100 millivolt polarization
change criterion is suitable for any
cathodically protected structure,
coated or uncoated, as long as the
protective current can be interrupted.
The application of this criterion in the
field is somewhat more involved.
Just as for the -0.85 volt current-off
criterion, the protective current is
interrupted to obtain an instant-off or
polarized potential, but the potential
that is measured must then be com-
pared with the potential of the struc-
ture prior to the application of any
CP (the "native" or "freely corrod-
ing" potential). The polarized poten-
tial must be 100 mV different from
the native potential.
If the native potential is known,
this comparison is quick and simple.
This statement assumes, though, that
the native potential has not changed
over time—an assumption that is
more likely to be true if the moisture
conditions around the storage system
were similar at the time of the CP test
measurement and at the time when
the native potential measurement
was made.
If the native potential is not
known, then the polarization on the
structure must be allowed to decay, a
process that can take from minutes to
as much as a day. This step can make
this criterion expensive and inconve-
nient to implement.
Note that this criterion has noth-
ing to do with -0.85 volt and that
storage systems with instant-off
readings well below -0.85 volt can
still pass.
In a Nutshell
My suggestions for the types of mea-
surements that should be conducted
and documented when evaluating
various types of CP systems are
described in the chart on page 10.
So these are my thoughts—What are
yours? •
Leak Prevention
Impressed Current Cathodic
Protection Systems...Just a
Warning
by Howard Barefoot
During the first seven years of
its UST program, Georgia,
like most other states, fo-
cused most of its attention , and
resources on leak detection. During
this period, leak detection outreach
efforts were extensive—lots of Work-
shops and seminars. At the end of
these sessions we'd toss out a little
reminder: "By the way, don't' for-
get—if you have steel tanks and/or
piping, you have to upgrade by
1998." There was no sense of urgency.
Toward the end of 1995, some
UST owners had decided that the
deadline was for real, and they were
getting on with the job of upgrading
or replacing their systems. By early
1996, we began getting calls and let-
ters from vendors, complaining
about the way their competitors were
installing impressed current cathodic
protection (ICCP) systems. One qf the
most disturbing complaints was that
the state was allowing cheap, isub-
standaird systems to be installed. \
With such accusations flying
around, I became concerned because,
after all, substandard facilities lead to
compliance problems. So I decided to
conduct a field evaluation of the
types and quality of ICCP systems
being installed. '
From April to June 1996, I
observed in detail the installation of
six ICCP systems from ground break-
ing to energizing. The sites involved
three vendors, each employing a
variety of techniques, equipment,
and materials to complete the job.
This variety, coupled with the fact
that the rectifier may be the only part
of the system readily visible during
an inspection, makes it difficult to
determine why particular systems
fail. It also underlines the importance
of having a drawn-to-scale, as-built
plan for each site available on site.
ICCP—How's It Done?
• The Saw-Cut Method
This method is so named because it
uses a diamond-blade concrete saw
to make an approximate 1/3-inch-
wide cut in the pavement. The depths
of a cut may vary, depending on the
saw operator; however, I have rarely
seen cuts deeper than 4 inches. I have
observed some cuts that were less
than 1 inch deep. (See Photo 1.)
The width of a saw cut usually
conforms to the diameter of the cable
being used. For example, #10 HMW
Poly Cathodic Protection Cable is 0.3
inch in diameter and the accompany-
• continued on page 12
Photo! Saw
cuts less than
1/2 inch deep
with exposed
header cable—
doomed to
rapid failure.
11
-------
LllSTUne Bulletin 32
• impressed Current Cathodic
Protection Systems from page 11
ing saw cut will be approximately
033 inch in width. Sadly, I have seen
some installers use a screwdriver
blade to push a cable into the saw cut
when the cut was too narrow.
When placing the header cable in
the saw cut, the best technique is to
first place sealant in the bottom of the
cut, then place the cable on top of titie
sealant and cover the cable with
sealant to the top of the pavement.
The sealant should be the type used
by departments of transportation to
seal traffic detector loops, not com-
mon hardware-store caulking mater-
ial.
With this method, borings for the
anodes are first made using a small,
portable, power auger or air rotary
auger. Saw cuts are then made, link-
ing each boring (anode location),
back to the rectifier. Most commonly,
a single "header cable" connected to
the positive terminal of the rectifier is
installed in the saw cut and links all
of the anodes together.
Saw-cut installations almost
always involve cable splicing because
the saw cut is not wide enough or
deep enough to accommodate sepa-
rate anode lead wires for each anode.
The anode lead wire is spliced into
the header cable at the anode hole
location.
Splicing is usually accomplished
by soldering, clamping, aqua-sealing,
taping, and heat shrinking. It should
be noted that this five-step process is
employed in an attempt to ensure
that the splice is waterproof. Water-
proofing is an absolute necessity to
prevent rapid corrosion failure of the
anode lead wire and/or header cable.
In the opinion of some experts,
the saw-cut method does not comply
with the standards of the National
Electrical Code (NEC NFPA 70, Sec-
tion 300-5), which require direct-bury
electrical cable to be installed 24
inches below grade in traffic areas.
Whether meeting the electrical code
or not, the fact is that many of these
systems are already in place in many
states, Georgia included. At this
point, Georgia does not plan to have
these systems removed.
• The Trenching Method
This method requires the complete
cut-through and removal of a line of
pavement 4 to 18 inches wide and
excavation into the soil beneath the
pavement (Photo 2). Although the
NEC cable burial requirement in traf-
fic areas is 24 inches, none of the
installations I observed during the
1996 evaluation project placed the
cable any deeper than 12 inches
beneath the surface. The primary
objection to the 24-inch depth is the
risk of damaging the product lines,
which are typically buried at a depth
of 18 inches beneath the surface.
When trenching is used, rather
than splicing each anode wire into a
header cable, anodes with individual
lead wires long enough to reach the
rectifier are typically used. This
method avoids the problem of buried
splices, greatly improving the relia-
bility of the system. In addition,
wires are less likely to be damaged,
because they are buried deeper. If a
wire does break, only a single anode
is lost from the system.
ICCP Systems—Will They
Work?
If a system has been properly
installed, will it work? The answer is
Photo 2 Narrow trench with
anode wire buried about 14
inches deep. Although it does
not meet electrical codes,
this technique provides bet-
ter protection than the saw-
cut method.
"yes," but not if the owner/operator
fails to pay attention. From March
through May 1999, our program con-
ducted field evaluations of 100 ICCP
systems. Eighty-four percent of these
systems appeared to be operating as
intended (at least for that moment in
time). Six percent had unexplained
problems, where portions of the stor-
age system did not appear to be pro-
tected. The remaining 10 percent of
the systems were totally noncompli-
ant for the following reasons:
• The rectifier was off Rectifiers
on five systems were off. The most
common reasons for this type of fail-
ure are power surges from nearby
lightning strikes or overloaded cir-
cuits.
The federal UST rules require
that all CP systems be maintained
and operated to provide continuous
corrosion protection; however, the
same rules require only that ICCP
systems be inspected every 60 days.
• The rectifier was operating at
too low an output Three systems
did not appear to have adequate pro-
12
-------
LUSTLine Bulletin 32
p
P
tection. As it turned out, the rectifiers
were operating at half the amperage
required.
• Other Two additional systems
had unexplained problems with total
system failures. The rectifiers were
operating, but the storage systems
did not appear to be protected.
ICCP Systems—Will They
Last?
ICCP systems are expected to last 20
to 40 years or longer when properly
designed, installed, and operated.
However, one can readily recognize
that many factors will be at work
over such a long period of time that
could affect the integrity and
longevity of a system. The following
are key factors:
• Construction and paving The
cables and sometimes the anodes are
vulnerable to excavation activities. In
time, visible locations of anodes and
saw cuts/trenches are likely to be
paved over, emphasizing the need
for and dependency on drawn-to-
scale, as-built site ^lans. Of the 100
system evaluations we conducted to
date, only five had plans on site or
readily available. Owners had not
requested plans and contractors did
not provide them.
• Design Probably the one design
consideration that affects the life of
an ICCP system the most is the num-
ber of anodes. The minimum num-
ber of anodes recommended per tank
is two. As a rule of thumb, every part
of a tank should be looking at an
anode. I have evaluated some sys-
tems where fewer than two anodes
per tank were used, leaving one end
and / or side of a tank not visible to an
anode.
• Installation The following is a list
of problems, actual and potential,
that I have noted during my investi-
gations of ICCP systems. Although
some could be argued to be design
problems, installation techniques
could have improved the conditions:
• Failure to protect the header cable
in the saw cut from broken pave-
ment and sharp objects.
• Exposed negative cables that can
be damaged.
• Exposed header cables and anode
lead wires. (See Photos 3 and 4.)
PhotoS Transi-
tion of header
cable from
ground into saw
cut in concrete
PAD—not
much protec-
tion for this
important wire.
• Noriwaterproof splices. :
• Failure to connect the rectifier, to a
dedicated electrical circuit.
• Operation The number one :and
maybe the most serious operational
problem noted during our evaluation
was nonoperation (i.e., the rectifiers
were off). In every case, this condi-
tion existed without the owner /ojper-
ator's knowledge. '.
A Precarious Situation :
As I observed the ICCP system instal-
lations in 1996, I had my doubts
about some of the techniques being
used. Now, three years later, some of
the techniques I thought were mar-
ginally acceptable have already man-
ifested themselves as real problems.
Mainy installations out there are
precarious, to say the least, and more
failures will become evident in a few
years. This trend is likely to arise
because, during the last six months
before the upgrade deadline, ;the
quality of ICCP system installations
reached an all-time low, as less quali-
Photo 4
Exposed header
cable repaired
with tape—it
takes more than
a little tape to
ensure longevity
of header cables.
fied contractors jumped into the busi-
ness and joined in the rush to get to
the next site.
As regulators, we have a serious
educational problem on our hands.
In addition to having a poor under-
standing of cathodic protection, own-
ers and operators frequently feel that
they have spent enough money on
this upgrade business, and they
shouldn't have to worry about it.
Maybe they shouldn't have to
worry about it, but they should, at
least, be aware that their systems,
especially the rectifier, must be
checked every 60 days. Any time I'm
in the field, I advise owner/operators
of the importance of their ICCP sys-
tem and the requirement to check its
operation. At the marginal facilities,
I'll go so far as to say, "If it were me,
I'd check the rectifier every day." •
Howard Barefoot is Manager of the
Georgia Department of Natural
Resources UST Program Regulatory
Compliance Unit.
13
-------
LlfSTlinr Bulletin 32
State Cleanup Funds
The Good, the Bad, and the Ugly
Tips for Managing Your State
Cleanup Fund
by Mary-Ellen Kendall
It's a sure bet that when the Envi-
ronmental Protection Agency
(EPA) gave states the right to cre-
ate petroleum storage tank funds in
1990, no one had any idea to what
extent the states would buy into the
concept. However, based on the fact
that almost every state now has a
fund, it is fair to say tihat the idea was
an overwhelming success!
The language under which these
funds were created is fairly simple,
general, and innocuous:
An owner or operator may sat-
isfy the requirements of §280.93
for underground storage tanks
located in a state, where EPA is
administering the requirements
of this subpart, which assures
that monies will be available
from a state fund or state assur-
ance program to cover costs up
to the limits specified in §280.93
or otherwise assures that such
costs will be paid if the
Regional Administrator deter-
mines that the state's assurance
is at least equivalent to the
financial mechanisms specified
in this subpart. [40 C.F.R.
§280.101(a)]
At the time, one might have
thought that maybe a few states
would get around to creating funds
that were similar both in nature and
administration. Nothing, however,
could have been further from reality!
States came up with funds that were
uniquely tailored to individual state
philosophies, policies,
and statutes.
InLLZSTLme#30
(September 1998),
we discussed
some
"typical"
reim-
burse-
ment
funds, illustrating some of the differ-
ences, as well as some of the good
and bad points about state reim-
bursement funds.
There are other states, however,
that chose to create funds that are
very different from the reimburse-
ment-type fund. These funds are
structured to provide UST owners
and operators with financial assis-
tance for cleanup costs using insur-
ance rather than cash reimbursement
payments. As is true with the nonin-
surance funds, each insurance fund is
administered differently.
State Insurance Funds
Iowa, Missouri, Utah, West Virginia,
and Washington are five states that
use a form of insurance fund. At the
time their funds were created, little or
no private insurance was available
for owners of petroleum USTs. In the
late 1980s and early 1990s, most
insurance companies were unwilling
to assume the environmental risks
that had evolved at petroleum stor-
age facilities over the last 50 years.
Before 1988, the corner gas sta-
tion was virtually unregulated.
Although some industry standards
for the storage and handling of petro-
leum products existed, very few were
known to, or used by, the average gas
station owner. Many tank owners
were high-school-educated entrepre-
neurs who bought or managed gas
stations when they returned from
World War n. Their only contact with
the petroleum industry was with the
company that supplied petroleum.
Even if the station was associated
with a major oil company brand, no
environmental risk training was pro-
vided for small station owners.
Once the federal UST regulations
became effective in 1988, many major
oil companies sold tanks to the sta-
tion owner or operator for $1. (See
LUSTLine #31.) The corner gas station
Part II
owner or operator who purchased
these tanks was unaware of the
impact that the regulations would
have in the future. Even if the small
station owner had wanted to pur-
chase insurance in 1990, few compa-
nies were willing to insure older sites
that had the highest probability of
being contaminated.
The solutions that states with
insurance funds devised to address
this problem cover a wide range.
Some states created funds that pro-
vided coverage for sites with existing
contamination, some covered both
existing contaminated sites and new
installations, and some limited cover-
age to contamination that occurred
only after a policy was issued.
Participation in these funds can
be voluntary or mandatory. Initially,
participation in Utah's fund was
mandatory. After a constitutional
challenge, which Utah lost, participa-
tion became voluntary. (Utah later
won the case on appeal, but did not
change back to a mandatory partici-
pation requirement.)
Today, approximately 95 percent
of Utah's UST owners participate in
this fund. To opt out of the fund,
owners must be able to demonstrate
that they can meet federal financial
responsibility requirements on their
own. Because so many owners can-
not demonstrate financial responsi-
14
-------
The LUST. BUSTER
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The L.U.S.T. BUSTER pack includes all 3 UST
Training videos and companion booklets:
"Tank Closure Without Tears": An Inspector's Safety Guide
What Do We Have Here?'9: An Inspector's Guide to Site
Assessment at Tank Closure
"Searching for the Honest Tank...": A Guide to UST Facility
Compliance Inspections
PLUS a L.U.S.T. BUSTER T-shirt and Sweatshirt!
(available in M/L/XL/XXL)
These acclaimed training
videos detail inspection and
field testing methods for
Underground Storage Tanks.
The companion booklets feature
checklists and references on
safety, assessment and
compliance.
Available while supplies last!
Please forward me L.U.S.T. BUSTER Pack(s) with M/L/XL/XXL (please circle) shirts.
I enclose a check or money order for $.. made payable to NEIWPCC.
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Checks or Money Orders must be drawn on a U.S. bank. Send the completed form and payment to:
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New England Interstate Water
Pollution Control Commission
-------
-------
LUSTLine Bulletin 32
r
biHty at the required levels, they par-
ticipate in the Utah insurance fund.
Iowa's Two-Pronged Approach
One of the key questions that insur-
ance fund administrators must
address up front is whether to create
a fund that covers sites with prior
contamination. The standard in the
insurance industry is to insure
against future risks at a rate that
reflects market forces.
With a program based on market
forces, the premiums assessed reflect
the true cost of the policy without
any state subsidy. The companies
that underwrite this insurance
develop the premiums for specific
tank issues, such as leak detection. A
market force system provides a more
accurate picture of the true cost of
insurance. For example, Iowa's pre-
miums average $400 to $1,100 per
tank with a $500 minimum premium
for each tank owner.
Iowa took a very innovative
approach in developing its fund.
Because the state law governing
USTs did not permit the state to set
up a permanent assurance fund,
Iowa used a two-pronged approach
to solve the problem.
Iffte ins'urajweJun'dsW'p^ the owners :
fl:: se&ftiat goffpjiance Tsa"'goojf[
|| Msiness practice tMfwiirexiena^
g:^1.i;;i!*;,..[.r>!v!,^,!;,;-*,»^;g^j,.,j^g^«j--j^^;^ii<-a
pthe life andjprofitahiiity of their
I facilities. This structure "weatesfr''
S?;- .' " « • • ••..'.<(, -••• ••^'<:..:^:.!.,-lr?:';,-r-;^i^,^v-v;jl's^^^^«!;:h'
win-win sftuatjprifoi'Iwih the ~
. l-^ni^lman^etBgy^s^'''"
cpfnjnujnity^ljtaisgpjrp^
environmehfhy VeSucfng"the*"*"
..'••N' !' •. 'i" ' H^-.Sjsrii';:^',''*'««,• >'. »'!,y."pstSj'H'jjg«wi*ss,iii(^t:M^i,'*,-.*j"n
potential for petroleum releases
J
a
™'^i
;J
vl
First, Iowa required everyone to
test their sites by October 26, 1990.
Seventy-one percent of the UST facili-
ties in Iowa were found to be contam-
inated and were eligible for the
remediation program. UST owners
could purchase insurance from the
fund voluntarily. Premiums were
based on compliance with statutory
and regulatory requirements.
By January 1, 1995, most of the
sites had been cleaned up, and the
state now bases its fund premiums
on the risk to the environment from a
particular tank. UST owners who are
serious about compliance see! an
immediate benefit in the form of
lower premiums. ;
Iowa is now entering the next
phase in the life of its fund. Because
the fund is supported solely by the
premiums paid by UST owners, a
nonprofit mutual company is being
formed that will allow the tank own-
ers to own the insurance company. It
will also end the state's involvement
in managing and administering the
fund. This move is consistent with
Iowa's statutory mandate that pro-
hibits the establishment of a long-
term, entrenched bureaucracy for
financial assurance. .
Washington's Reinsurance
Approach :
Washington developed an insurance
fund that insures future risk rather
than past activities. The fund serves
as a "reinsurer" of two private com-
panies to offset the insurer's objiga-
tion to pay $1 million per occurrence.
The private insurance companies pay
the insured for all cleanup costs cov-
ered by the policy but can then turn to
the fund if the costs exceed $75,000.
By encouraging competition
between the two insurance compa-
nies, Washington was able to reduce
premiums. This type of structure has
the same benefit as the Iowa fund in
that teink owners who are in compli-
ance with UST regulatory require-
ments pay lower premiums than
those who are not. ',
States with premiums that are
based on an arbitrary number (often
set by statute) normally establish
very l.ow premiums that are not in
line with commercial, private insur-
ers. Trie artificially low premiums
may provide a disincentive to the
owners, because the cost is not com-
mensTirate with the true cost of own-
ing and operating an UST. It is also
virtually impossible to attract any
private insurers, because they are not
able to compete with the state insur-
ance fund.
Deductibles and Claims
In addition to the premiums that tank
owners pay for policies, there is a
deductible associated with each
occurrence. Washington has three
deductible levels, ranging from
$10,000 to $25,000. West Virginia has
two deductibles ($5,000 or $50,000),
while Utah's deductible has been
reduced from $25,000 to $10,000. Sev-
eral of the insurance fund managers
stated that offering lower deductibles
for compliant tanks can be used as an
incentive to ensure that tank owners
comply with regulatory require-
ments, which should, in turn, reduce
the number of releases and/or the
cost to clean up these releases.
Claims are handled in a manner
similar to reimbursement funds.
Once the fund is notified of a release,
a claims adjuster visits the site and
approves the proposed cleanup activ-
ities. Because of the preapproval
process, Utah is able to process
claims within 30 days of receipt.
Missouri has tried several tech-
niques used by reimbursement fund
administrators to reduce the cost of
claims, such as requiring competitive
bids for all work and paying no
markups. Although these tools were
not very successful in reducing costs,
Missouri has now developed an
effective cost-saving tool: a strong
field presence. Fund staff are out
there verifying that work was actu-
ally performed and documenting the
true cost of each activity. They also
recommend that the fund or environ-
mental field staff attend every tank
closure, whether or not a release is
reported, to verify the tank owner's
compliance with the regulations
and/or the presence of contamina-
tion at the site.
The Compliance Carrot
One of the chief advantages of an
insurance fund from the state's per-
spective is that regulatory compli-
ance is required for participation.
Tank owners are given a monetary
incentive (in the form of lower premi-
ums or deductibles) to learn and
implement UST regulatory require-
ments.
• continued on page 21
15
-------
LUSTLitte Bulletin 32
Leak Prevention
Swamped in Free Product?
Rise Above It With PFP
by William Foskett, Dana Hayworth, and Bob Cohen
One of the first actions typi-
cally needed at a newly dis-
covered UST release is
removal of free product. In reality,
however, this step doesn't always
happen in a timely fashion. In fact,
free-product removal often gets out
of control, running up high cleanup
costs without solving the immediate
environmental problem and, per-
haps/ making it worse.
Gasoline held in residual form
above the water table will, in time,
affect groundwater qualify if it is not
remediated. When free-product
removal is delayed or too slow, the
seasonal rise and fall of the water
table can cause contamination to
"smear" into the vadose zone. Even
the process of conducting a pump
test can smear free product into pre-
viously uncontaminated areas.
Free product can also migrate
into utility conduits, surface water,
and basements. At a site in north
Florida, for example, free product
migrated into a pond resulting in sig-
nificant fish kills and a threat to the
heath and welfare of children playing
nearby. Early mitigation of the free
product would have prevented sig-
nificant environmental damage.
The time-and-mate-
rials (T&M) terms on
which cleanup contrac-
tors have customarily
been paid for free-product removal
practically invite such problems,
because T&M rewards slow and inef-
fective work. An alternative payment
approach, known as pay for perfor-
mance (PFP), is a system whereby
you pay the contractor for free-prod-
uct removal and keep yourself from
being swamped by spreading plumes
and rising costs. PFP fiscally rewards
quick starts and fast results with
prompt, low-hassle payment. It also
forces you to set clear, measurable
environmental goals and a firm, fixed
price for the free-product removal.
Here's How It Works
Under PFP, the cleanup contractor is
paid according to the amount of cont-
amination that is actually reduced
(e.g., decrease in free-product levels
measured in feet or inches), not for
the amount of time and materials
expended. No change orders are
allowed. In a large-scale, long-term
free-product removal (or full-scale
site cleanup), PFP payments are trig-
gered as contamination levels decline
to milestone levels set in the terms of
the PFP agreement.
Often in full-scale PFP cleanups,
a free-product reduction goal must
be reached as part of the criteria to
receive the first performance pay-
ment. In small-scale PFP free-product
removal work, the intermediate mile-
stone payments may be omitted and
the contractor may be paid simply on
attaining the end goal.
For example, if three wells are
identified with 12 inches of free prod-
uct, then a PFP milestone could be set
for when the measurable quantity of
free product is reduced 25 percent, or
3 inches, in each well. Successive
j} I ri » 'iiv ii' ft*1*1 tf mi Wif^ijnfe
F
-------
LUSTLme Bulletin 32
r
els directly in the environment at the
cleanup site. It should also include
data-collection locations and proce-
dures to alert you if the contractor's
approach begins to make the prob-
lem worse rather than better. In PFP
you are paying for a clean site—not
just a few clean measurement loca-
tions.
To measure free-product reduc-
tions for PFP milestone payments,
identify the wells that have free prod-
uct and record baseline levels of free
product before beginning removal.
For example, you can measure the
apparent thickness of product in the
aquifer by using an interface probe or
an oil sensor. Once each well is mea-
sured and free-product accumulation
recorded, set and measure the mile-
stone-payment levels of free product
in terms of thickness in each well.
Seasonal Water Table
Variations and Measuring
Free-Product Reductions
If free product is released during a
dry season in certain lithologies, but
its removal is delayed until (or
includes) a rainy season, then the
water table could later rise and smear
the free product into the vadose zone,
resulting in a misleading apparent
reduction in free-product thickness
as measured in the monitoring wells.
Appropriate configuration of the
measurement-payment criteria, sam-
pling locations, and data-collection
procedures will help to avoid this
problem. You should take care that
the free-product removal work really
is removing free product and not just
smearing it away into previously
uncontaminated areas.
Seasonal variations in the water
table should be taken into account
when the measurements that trigger
PFP payments are set up. Before you
make a judgment on the total amount
of measurable free product in each
well, you should know when the
water table has reached its peak and
then collect the measurement data.
This collection can be done, for
example, by preparing a hydrograph
that shows water table elevations
over time for the free-product
removal site. A hydrograph will
show potential smearing as opposed
to real reduction in thickness for free
product on the water table. It is also
wise to monitor for three to six
months after the goal is attained to
ensure that rebound does not occur
due to a falling water table.
Also, know the groundwater
flow rate and gradient to calculate
potential migration speed and spijead
of the product plume. To minimize
smearing across uncontaminated
zones, avoid any type of pumping
test that could cause free-product
migration.
Ways Not to Measure PFP
Free-Product Removal
Progress ;
It is theoretically possible to measure
free-product removal progress (and
goals) based on the reduction in over-
all size of the free-product plume.
Although software that may indi-
rectly assist in this undertaking is
being developed, it is not presently
available. Thus, this method is:not
yet sufficiently reliable to be used for
purposes of making PFP payments.
Do- not measure PFP free-product
removal progress by the amount of
"effluent" free product that ; the
removal system produces. It is not a
direct measure of the environment
that PFP is paying to dean up. In PFP
payment measurement, data should
be taken directly from the environ-
ment you are trying to clean up.
However, most states require that
influent data from the treatment sys-
tem be reported. Both influent and
effluent data can give you a check on
the "thickness" data used to trigger a
PFP milestone payment.
70 measure free-product reductions
bit M
jjjJi^ far PFP milestone payments,
^"identify the wells that have free
^product and record baseline levels
BS!ro/ free product Vefore beginning
removal.
j
Timing and Time Limits for
PFP Free-Product Removal
Timing is a practical consideration in
setting the schedule for PFP free-
product removal. If the free-product
release takes place at the beginning of
a period when the local water table is
normally low in sandy or sandy clay
lithologies, you should set the PFP
time limit so that your goal is: met
before the water table rises again.
If the free-product removal job
begins too late in your "dry" season
to reach your goal before the water
table rises again, then withold some
contractor performance payments
until the next dry season. Then make
those payments if the free product
has not exceeded your goal levels. If
the site does not remain at or below
goal levels, withhold payments and
have the contractor resume appropri-
ate remedial action until the site
reaches and retains your free-product
goals.
Goals for a PFP free-product
removal job can be set so that a spe-
cific thickness of free product must
be reached within a given time frame.
For example, a goal for a PFP free-
product removal might be to reach 1-
inch thickness within 60 days of the
effective date of the PFP contract.
Setting and Estimating the
PFP Fixed Price for a Free-
Product Removal Job
In PFP, we distinguish setting the
firm fixed price that caps the amount
to be paid out from estimating the
actual cost of a PFP cleanup. The
price is the dollar amount that the
buyer agrees to pay (or reimburse)
for reaching the cleanup goal. The
cost of the cleanup is the actual
amount of money spent to accom-
plish that goal. In reality, the cost can
turn out to be either more or less than
the price that was set for the job. The
PFP price does not change, regardless
of the actual cost. In PFP, Price minus
Cost equals Profit.
A PFP cleanup price may be set
(1) by public, competitive bidding, (2)
by negotiation between the payer
and the cleanup contractor, or (3) by
the state based on some "fair and rea-
sonable" rate schedule. Experience
shows you will pay the lowest price
for a PFP cleanup by using public,
competitive bidding, with award to
the lowest bidder.
Based on the number of bidders
attracted when South Carolina pub-
lishes requests for PFP bids, confi-
dent, competent cleanup contractors
find PFP cleanups an appealing busi-
ness opportunity. Besides the
prospect of gaining a healthy profit
for working smart, PFP progress pay-
ments are typically made within a
• continued on page 21
17
-------
LUSTLiw Bulletin 32
Investigation and Remediation
MTBE, Fuel Oxygenates...
ByJeffKuhn
After last month's announce-
ment of the phase out of
MTBE in the State of Califor-
nia and legislative action by some
States contemplating MTBE bans, we
are all left wondering, "Okay, now
what?" We've begun to move away
from a chemical that at best provided
questionable air quality benefits and
at worst has contaminated many
aquifers throughout the United
States, leaving cleanups that will con-
tinue for many years to come.
Adding to the large body of
MTBE information, the recently com-
pleted National Research Council
report, Ozone-Forming Potential of
Reformulated Gasoline, indicates that
better vehicle emission control sys-
tems and the other nonoxygenating
compounds of RFC—not the oxy-
genates—are responsible for reduc-
tion in ozone levels documented in
RFC areas throughout the country.
These conclusions demand recog-
nition in the context of the MTBE
debate. One could surmise that the
report demonstrates how easily deci-
sions allowing the use of specific
chemicals can be made before a thor-
ough scientific evaluation of human
health and environmental impacts is
completed and before other alterna-
tives (use of better emission control
technology) are considered. Most
Importantly, the report demonstrates
that, thanks to the computer age,
automobile technology may have at
least temporarily surpassed the goals
Of gasoline reformulation in control-
ling and reducing air quality emis-
sions and the perceived need for
some of the fuel oxygenates.
The NRC report hits at the heart
of the issue and the reason for the
complexity of the
debate: It is not
the presence of
oxygenates that has
led to air toxics reductions,
but rather the displace-
ment of the aromatic and
more carcinogenic frac-
tion of hydrocarbons by
oxygenates and the use
of better automotive
technology.
A Pause for Reflection
Between the announcement of the
California phase out and the antici-
pated results of the EPA Blue Ribbon
Panel on MTBE (due out in July),
there is somewhat of a lull in the
MTBE debate. While we await the
panel's findings, perhaps we need to
consider the MTBE debate from a
more philosophical perspective. Is
the concern over MTBE really that
different from the concern expressed
over benzene in the early 1980s?
Although there are some differences
(e.g., MTBE's solubility and recalci-
trance to biodegradation), the con-
cern over MTBE may mirror the
evolution of the LUST Program and
EPA in general.
It's probably safe to say that we
will never again take gasoline formu-
lation for granted. After all, EPA,
industry, and many states were
aware in the late 1980s that MTBE
created long plumes and could
potentially impact drinking water
wells located a great distance from
petroleum source areas. But the col-
lective "we" did nothing to address
the issue.
We should probably also ask
why no new health studies on the
effects of MTBE have been completed
or commissioned. Perhaps there is a
feeling that if MTBE will not be used
in the United States over the long
haul, why spend the money to con-
duct the research?
In the meantime, however, the
use of MTBE on a worldwide basis
continues to grow in response to
Now What?)
severe air quality problems
in developing countries.
Shouldn't the necessary
health studies still be com-
pleted? And what about the
health effects of whatever
comes next? Where do we
go from here? Time will tell
whether we have learned from
this experience and whether
we apply what we have
learned from addressing
MTBE cleanups in communi-
ties on a nationwide basis.
Perhaps EPA should
consider a more holistic
approach to exploring the human
health and environmental impacts of
new chemicals proposed for introduc-
tion into motor fuels. The various
branches of EPA need to work
together jointly to address proposed
gasoline reformulation issues in the
future so the MTBE catastrophe is not
repeated with a new oxygenate or
chemical additive. The agency should
also clearly communicate with state
agencies (e.g., UST, air, drinking water
programs) and encourage them to
work together as well.
The question remains: Are gains
in air toxics reductions through the
use of MTBE and other alkyl ether
oxygenates still worth risking conta-
mination to drinking water aquifers?
A standing panel of EPA, industry,
research, and state representatives,
similar to the Blue Ribbon Panel,
should be created to review proposed
changes to gasoline formulation.
Most importantly, the public
needs to be involved in understand-
ing the effect of gasoline formulation,
not just on the pocketbook, but also
on human health and the environ-
ment. We anxiously await the conclu-
sions of the Blue Ribbon Panel and
other research currently under way,
and look forward to the certain chal-
lenges ahead. •
JeffKuhn is with the Montana DEQ
Petroleum Release Section and is a
member of the ASTSWMO MTBE
Workgroup and editor of its
newsletter.
18
-------
LUSTLine Bulletin 32
Investigation and Remediation1
With the Possible Phase Out of MTBE,
What Do We Know About Ethanol?
Le
*
t
by Bruce Bauman
/et's
toast
the
fortunes of
humankind's
favorite beverage,
that inebriating
elixir—ethanol.
There is a rea-
sonably good
chance that within
the next five years,
.; the use of ethanol
. in gasoline could
increase as much
•—>: as 200 to 300 per-
cent! With luck,
that potential
surge in demand
won't drive up the cost
of your Saturday night Wild Turkey.
A quick recap will help explain
this possible boost to domestic fuel
ethanol utilization, and then on to
the UST/groundwater implications.
MTBE and ethanol are the two most
widely used oxygenates—according
to the Department of Energy, in 1997
about five times as much MTBE as
ethanol was used in gasoline in the
United States. Other oxygenates
(TAME, ETBE, DIPE, methanol, TEA)
are used in only a very small percent-
age of gasoline.
Oxygenates are blended into con-
ventional gasoline to provide eco-
nomical octane, typically at low
volumes (e.g., less than 1-5 vol %);
higher volumes are found in pre-
mium gasolines than in "regular."
Many urban areas of the United
States are required to use reformu-
lated gasoline (RFG) to reduce emis-
sions that contribute to ozone
formation. As required by Congress
in the 1990 Clean Air Act (CAA)
amendments, RFG must contain at
least 2 percent oxygen by weight
(about 11% volume MTBE or 6%
ethanol).
In a much smaller number of
urban areas, "oxyfuel" must be used
in winter months to reduce carbon
monoxide emissions. Oxyfuel must
contain at least 2.7 percent oxygen by
weight (about 15 % volume MTBE or
8% ethanol). EPA's Office of; Air
maintains an excellent Web site; that
can give you details on which parts
of the United States must use these
special gasolines (http://www.epa.
gov/oms/fuels.htm). (NOTE: Ethanol is
sometimes used at 10 percent voiume
in gasoline, because there is a 5.4
cent/gallon federal subsidy. Smaller
subsidies apply to gasoline using less
ethanol.) . j
You are probably familiar with
California's decision to phase out the
use of MTBE in gasoline by Decem-
ber 2002. Currently, about 70 percent
of the gasoline sold in California is
RFG. (California has some specific
regulcttory gasoline requirements
that make its RFG different than that
found in the rest of the country, but it
^s^^^^j^nnrn^jaj^^if^fVfK," •.
^n^|»^jB^i?^c/ose£fa/i^,3
"/LJjf!^\
"will have to
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"*"** "f'^Tn"^nycWjs^iiopjB'that':
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still needs to contain 2% oxygejn by
weight.) When MTBE is completely
phased out, ethanol is the logical
replacement oxygenate (assuming
the CAA "oxygen mandate" is not
repealed). This is no trivial issue from
the supply perspective. Given that
California uses so much gasoline and
currently uses very little ethanol,
this e thanol-for-MTBE substitution
would require almost 50 percent of
the current U.S. ethanol production
capacity! :
Ethainol in Groundwater? j
All of this information is just back-
ground to get around to the main
question: What do we know about the
behavior of ethanol in groundwater?
Many of you who are reading this
article have been responsible for over-
seeing UST sites where ethanol was
released—especially in parts of the
Midwest, where ethanol has found its
greatest marketability. States like
Nebraska have strongly supported
and subsidized ethanol production to
enhance both their economies and
promote "energy security" (i.e., every
barrel of ethanol produced for use in
gasoline means one less barrel of oil
that needs to be imported). In Illinois,
an ethanol-in-diesel ("biodiesel")
demonstration program is, in
progress.
For almost a decade, however, I
have attempted at infrequent inter-
vals to unearth real-world field
information on ethanol or ethanol-
gasoline releases, but I have not been
able to find much. I began my search
in the late 1980s, when the American
Petroleum Institute (API) was con-
ducting the only known field study
on alcohol fate and transport in
groundwater.
We looked at methanol, as it was
being seriously evaluated by Califor-
nia as a cleaner-burning gasoline sub-
stitute. We injected three simulated
dissolved plumes side by side in the
world-famous Borden Aquifer in
Canada: (1) a typical BTEX plume, (2)
a BTEX and MTBE plume, and (3) a
methanol and BTEX plume. The
plumes were monitored intensively
for about 16 months, and mass bal-
ances were performed at the end of
the experiment.
To briefly summarize the Univer-
sity of Waterloo report, the methanol
did biodegrade to below detection
limits (250 ppb), but the BTEX in that
plume biodegraded much less than
in the "BTEX only" plume, or the
MTBE-BTEX plume.
Unless someone can provide evi-
dence to the contrary, I would expect
that the subsurface fate/behavior of
methanol and ethanol would be
fairly similar. So what does this simi-
• continued on page 20
19
-------
LUSTUne Bulletin 32
• Ethanol ./row page 19
larity mean for real-world ethanol-
gasoline releases? It suggests that at
least for some release scenarios,
ethanol-BTEX plumes would likely
be a bit longer than "typical" BTEX
plumes.
From a practical perspective, this
potential plume elongation may not
be very relevant for most RBCA eval-
uations, especially if if s only 1 to 200
feet or so. However, it would seem
prudent for at least some situations,
especially in Midwestern states
where ethanol is the dominant oxy-
genate, to determine if ethanol is pre-
sent at the release site and assess
what its effects might be on the ben-
zene plume.
Biodegradability and Other
Knowledge Gaps
Despite this ethanol field data "black
hole," several recent assessments of
potential groundwater impacts from
such UST releases seem to rather
blithely assume that there will be no
impacts, because ethanol is consid-
ered to be so biodegradable. For
example, the comprehensive Univer-
sity of California evaluation of MTBE
that formed the basis for that state's
recent decision to phase out MTBE
states that "Ethanol plumes will
biodegrade fairly rapidly." The study
does raise the issue of "preferred sub-
strate utilization" and its potential
impacts on the length of BTEX
plumes (i.e., as the microbial popula-
tion will prefer to extract its energy
from the available ethanol, the onset
of significant biodegradation of BTEX
could be delayed by several days,
weeks, months, depending on
numerous site/release-specific fac-
tors).
The operative phrase here is
"biodegrade fairly rapidly." How
rapid is rapid? Furthermore, as no
field data exist on this topic , these
assessments are simply taking labo-
ratory biodegradation data and
extrapolating them to field situations.
Most of us would agree that one
must use a great deal of caution in
making that lab-to-field leap.
Finally, it is very important to
consider different release scenarios
and their implications for ethanol-
BTEX dissolved plume development.
Most folks would agree that for
small, slow, continuous releases (e.g.,
20
2-10 gal /day), dissolved ethanol
would be rapidly biodegraded. How-
ever, if there is a large sudden release
(e.g., 500-plus gallons in one day), the
mass of ethanol that might be dis-
solved would be very large, and it
might take a very long time
(months?) for it degrade.
I would suggest that there are a
uHimrw nnuur imf ia ^
»»?.,
|-F ethanol-gasoline releases may be
worse than MTBE releases. Based
n t u. I i i" * H T *
"*J ' on current information, it seems
, _ - - - -
-;
, , likely that their impacts on
_
i ' groundwaterjuality would be less
Mi u 7 "III " i1 1 ™B in iflii isf i\m Lii i * ii mi iir in ,11 1 HI ir, , ,1 il
Wthan those of MTBE. However, there
* clearly are some knowledge gaps
I that need to be addressed, and UST
f site managers should begin to
? „ consider some of these issues.
^^^^^^n^^^\ ^^^^^^^f^^^ inl
number of other issues regarding
ethanol-gasoline releases to ground-
water that need to be thought
through before we begin a massive
migration to dependence on ethanol
for all of our gasoline oxygen needs:
• Maximum dissolved ethanol
concentrations Because ethanol is
miscible with water (completely solu-
ble), very high concentrations are
likely to occur near the source of the
release, perhaps as high as 10,000
ppm or more. Although ethanol may
be rapidly biodegraded, at these con-
centrations it will be toxic to microor-
ganisms. Biodegradation will occur,
of course, at the diluted fringes of the
ethanol plume, but this much dis-
solved mass will take a long time to
biodegrade, even at very high sub-
strate utilization rates.
• Flume elongation caused by
electron acceptor depletion If the
rapid biodegradation of ethanol uses
up all of the available electron accep-
tors needed for aerobic and anaerobic
biodegradation (e.g., oxygen, iron,
sulfate), will BTEX biodegradation be
impeded?
• Cosolubility of BTEX Several
authors have looked at the potential
for methanol or ethanol to increase
the dissolved-phase concentration of
BTEX. In general, the lab results seem
to suggest that at the 5 to 10 percent
volume concentrations found in
gasoline, ethanol would not enhance
the solubility of BTEX significantly.
However, for releases of neat (pure)
ethanol (see below), cosolubility
effects would greatly increase dis-
solved BTEX.
• Trace compounds in fuel-grade
ethanol The presence of TEA in fuel-
grade MTBE has been identified as an
issue for MTBE release sites. Are
there trace compounds in fuel-grade
ethanol that might be of concern and
that would be less biodegradable
than ethanol?
• Neat ethanol releases Unlike
MTBE, which is blended at the refin-
ery and then shipped through
pipelines or tankers/barges, ethanol
must be blended at the distribution
terminal just prior to delivery to the
end user. This requirement arises
because the presence of as little as 1
percent water can cause "phase sepa-
ration" of an ethanol-gasoline mix-
ture into an alcohol-rich phase and a
hydrocarbon-rich phase. Thus pure
ethano! must be stored at terminals in
separate tankage, which could also
have a release and require remedia-
tion at some time.
I raise these issues not to imply
that ethanol-gasoline releases may be
worse those MTBE releases. Based on
current information, it seems likely
that their impacts on groundwater
quality would be less than those of
MTBE. However, there clearly are
some knowledge gaps that need to be
addressed, and UST site managers
should begin to consider some of
these issues.
What Information Is or Is Not
Yet Out There?
If you're looking for a good summary
of what we know and don't know
about ethanol in groundwater, get a
copy of Evaluation of the Fate and
Transport of Ethanol in the Envi-
ronment, a report from the American
Methanol Institute by Malcom-Pirnie
(keep in mind that methanol is a pri-
mary feedstock for making MTBE). It
is the single best source of informa-
tion available today.
Information on ethanol's health
effects and a much briefer environ-
-------
LUSTLine Bulletin 32
mental summary axe accessible from
the "Renewable Tuels Association, at
http://www.ethanolrfa.org/544_er_1999.
html (keep in mind that RFA is an
ethanol advocacy organization).
API is just beginning its
own ethanol literature review and
some laboratory studies evaluating
whether the "preferred substrate"
hypothesis is legitimate. It hopes to
have this complete within the next
four to six months.
Also of interest is some work
going in Brazil, where gasoline with
20 to 25 percent ethanol has long
been in use as a motor fuel. A field-
release experiment on this kind of
gasoline was just started by Brazilian
researchers late last year, and initial
results should be forthcoming within
another year or so.
Finally, as required in the MTBE
phase-out Executive Order Governor
Davis signed in March, CalEPA needs
to issue a report on ethanol environ-
mental impacts by the end of this
year. As this time, it is considering
contracting for $650,000 in ethanol
fate and transport studies in surface
and groundwater, trying to quickly
come up to speed. Ideally, the
agency's work will also shed some
much-needed light on this issue.
The Jury's Still Out
So will we actually see this large
increase in ethanol use in gasoline
over the next several years? It is diffi-
cult to say, as there are more than a
few tricky variables in this equation.
It is likely that MTBE use will decline,
and if the federal oxygen mandate is
not changed, increased ethanol use is
inevitable. However, Congress may
amend the CAA to specifically
address this MTBE-ethanol issue
through repeal of the oxygen man-
date. There is increasing evidence
that lots of oxygen is not really
needed in our gasoline.
Several mandate repeal bills are
under discussion in the Senate and
House, and others are being dis-
cussed for potential consideration.
Some of the bills would specifically
target California, as it has already
acted to phase out MTBE and is fac-
ing an ethanol mandate. (For an
interesting review of some of this
activity, see the testimony of a variety
of people at the May 6 Hotise of Rep-
resentatives Committee on Com-
merce hearing on HR 11, one of
California-specific bills, at http://com-
notes.house.gov/cchear/hearingsl06.nsf/
hemain.)
Other bills would remove the
mandate for the entire country. Con-
gress Is very aware of the activities of
the EPA Oxygenate Blue Ribbon
Panel,, which appears to be leaning
toward recommending a removal of
the mandate, and also the National
Research Council's recent report that
downplayed the benefits of oxygenate
use for ozone reduction. But if you
think that science and facts will win
the day with the political poohbahs in
the Capitol, maybe you've had a little
too much to drink. •
Bruce Bauman, Ph.D., is the Ground-
water Research Program Coordinator
for API. For more information, contact
Bruce, at bauman@api.org. If you have
real-world information on ethandl-
release sites, he would love to
hear about it!
• Free Product from page 17
few days of confirmed progress doc-
umentation.
PFP also has mechanisms for
assuring that the contractor is held
responsible to reach the free-product
removal goal within both the time
limit and the fixed price that is set for
the cleanup, regardless of the cost of
the work. In general, the cost of a
free-product removal cleanup at a
given site can be estimated and the
price can be set based on the thick-
ness and size of the plume and the
physical characteristics of the site.
Strong PFP Fiscal Incentives
and Good Contamination
Measurement Foster
Success
PFP is a very effective framework for
accomplishing free-product removal
quickly and with minimal further
environmental harm at the best pos-
sible price. PFP accomplishes this
goal because it gives the contractor a
strong financial incentive to reach
clearly set goals as quickly as possi-
ble. For more information about
PFP, e-mail Bill Foskett at
foskett.william@epa.gov. •
Bill Foskett is with the U.S. EPA's
Office of Underground Storage Tanks
(OUST) and is the PFP Staff Lead.
Dana Hayworth is a Geologist with
EPA Region 4, specializing in cleanup
pricing. Bob Cohen, a Geologist, spe-
cializes in LUST cost-containment
issues and is currently on contract
with OUST to conduct PFP
workshops.
.
• Managing Your State Cleanup
Fund from page 15
Although eligibility is open to
all tank owners, the insurance funds
are also advantageous to the regu-
lated community. Many small sta-
tion owners would be unable to
meet the federal financial responsi-
bility requirements without some
form of state assurance fund. The
insurance funds help the owners see
that compliance is a good business
practice that will extend the life and
profitability of their facilities. This
structure creates a win-win situation
for both the regulator and the regu-
lated community. It also protects the
environment by reducing the poten-
tial for petroleum releases from
USTs.
A final advantage of insurance
funds is that they are normally sup-
ported by premiums and fees paid by
the regulated community, which
places the cost associated with oper-
ating a petroleum storage tank
squarely in the pocket of the person
who stands to profit from its opera-
tion. This approach reduces the use
of public funds and prompts stajtes to
develop innovative ways to reduce
costs. Stakeholders in the states.cited
in this article have a high degree" of
customer satisfaction with this type
of state fund.
If you have any questions or
would like additional information on
the problems/solutions discussed in
this article, contact Pat Rounds, Iowa;
Carol Eighmey, Missouri; Doug
Hansen, Utah; Jim Sims, Washington;
or Gil Sattler, West Virginia. •
Mary-Ellen Kendall, J.D., M.B.A., is the
Financial Programs Manager for the
Virginia Department of Environmental
Quality. She is responsible for making
liability and fund eligibility determina-
tions for the Virginia UST Program.
21
-------
LUSTUnc Bulletin 32
Investigation and Remediation
Evidence for Contamination of Heating Oil and
Diesel Fuel with MTBE
by Gary A. Rabbins and Brent J. Henebry
The widespread use of methyl
tert-butyl ether (MTBE) at high
concentrations in gasoline
began in Connecticut and other areas
of the United States in the early 1990s
in response to requirements of the
1990 Clean Air Act Amendments.
Relative to other gasoline contami-
nants of interest, MTBE has a higher
affinity for groundwater and a lower
potential for natural biodegradation
and retardation. For this reason,
MTBE has emerged as a common
groundwater contaminant associated
with gasoline releases and has
become the focus of an ongoing
national debate regarding its contin-
ued use.
To add to this debate, recent
research conducted by the University
of Connecticut Hydrogeology Pro-
gram provides evidence for wide-
spread contamination of heating oil
and diesel fuel with MTBE. Inasmuch
as MTBE is a fuel oxygenate that is
blended with gasoline, its presence in
heating oil and diesel fuel is trouble-
some. This article will summarize
what we've found through our
research and describe our ongoing
investigation of this issue.
Evidence for MTBE in Diesel
Fuel
Our story begins at the University of
Connecticut Motor Pool, a gasoline
fueling facility. Post-LUST-remedia-
tion groundwater monitoring in
November 1997 and March 1998
revealed the presence of elevated lev-
els of MTBE at the pump island. No
BTEX or PNA constituents were pre-
sent.
One hypothesis developed to
explain these findings attributed the
problem to spills of MTBE-contami-
nated diesel fuel. To investigate this
hypothesis, four samples of diesel
fuel were collected from the motor
pool in March 1998 for analysis. The
results of the analyses indicated the
presence of MTBE in all four samples
at levels ranging from 61 to 66 mg/L.
Equilibrium octanol water parti-
tion calculations revealed that if this
diesel fuel were to come into contact
with groundwater, an MTBE concen-
tration of up to 6,000 ?fg/L could be
achieved. This level of contamination
was in the range of that observed in
the groundwater at the motor pool
site.
of gasoline containing 15 percent
A simple calculation was con-
ducted to assess the amount of gaso-
line required to contaminate the
diesel fuel to the concentrations
detected. We determined that only
2.7 gallons of gasoline containing 15
percent MTBE by volume would be
needed to contaminate a 5,000-gallon
diesel tank to these levels.
Evidence for MTBE in
Heating Oil
The motor pool diesel fuel findings
were reported to the Connecticut
Department of Environmental Pro-
tection's (CTDEP's) LUST Trust Pro-
gram. Upon a preliminary file
review, the department determined
that MTBE groundwater contamina-
tion was often found in association
with heating oil releases. In Decem-
ber 1998, we carefully reviewed a
total of 78 case files to determine the
frequency and magnitude of MTBE
detection at heating oil release sites.
We looked for sites that met the
following criteria:
• The site had been affected by a
heating oil release and had no
nearby source of gasoline contam-
ination (e.g., gasoline station,
automotive repair shop);
• Groundwater analysis for MTBE
had been conducted; and
• Petroleum product groundwater
contamination had been detected
through analysis of near-field
groundwater.
A total of 37 sites met these criteria
and were used as a population for a
statistical evaluation.
MTBE was detected in ground-
water at 27 (73 percent) of the 37 sites.
The maximum reported MTBE con-
centrations ranged from 1 to 4,100
^g/L. With respect to regulatory lim-
its, 19 percent of the sites had MTBE
groundwater contamination levels
that exceeded the CTDEP groundwa-
ter protection criteria of 100 ^g/L.
With respect to the U.S. EPA
Drinking Water Advisory, 32 percent
of the sites exceeded the upper limit
of 40 /ig/L and 46 percent of the sites
exceeded the lower limit of 20 ^g/L.
For ,a detailed description of this
research, refer to "Evidence for
MTBE in Heating Oil" in the Spring
1999 issue of Groundwater Monitoring
and Review.
Consequences
The source of the MTBE contamina-
tion of diesel fuel and heating oil is
currently not known. Contamination
could result from the use of similar
lines or vehicles during transporta-
tion from the refinery to end users.
The presence of MTBE in fuel oil and
diesel fuel is troubling, not only
because it indicates that potential
sources of MTBE contamination are
widespread, but also because it could
well result in increased remediation
costs for heating oil and diesel fuel
releases and increased litigation
between home owners, insurance
companies, and oil companies.
Current Research
Additional research is under way to
determine the source and magnitude
22
-------
LUSTLine Bulletin 32
he presence of
fuel oil and diesel fuel is
troubling, not only
because it indicates that
potential sources of
MTBE contamination are
widespread, but also
because it could well
result in increased
remediation costs for
Cheating oil and diesel
fuel releases and
Increased litigation
of the MTBE contamination. We are
currently testing an analytical
method that can detect MTBE in
product at low levels (ppb range) for
reproducibility and accuracy. The
method being tested is a static head-
Space procedure using gas chro-
matography. Quantification is made
using a standard addition procedure.
Once the method has been veri-
fied, we will collect product at vari-
ous key points in the fuel transfer
chain to determine the source and
magnitude of the contamination.
Also, diesel fuel and heating oil will
be collected from several locations at
four different times during the year
to determine the extent of seasonal
variations of contamination levels. •
Gary A. Robbins is a Professor of
Hydrogeology in the Department of
Geology & Geophysics at the Univer-
sity of Connecticut. During the last 20
years, he has been developing field
screening methods and investigatory
approaches for improving site investi-
gations at leaking underground storage
tank sites. Gary can be reached at
gary.robbins@uconn.edu.
Brent J. Henebry is a graduate student
pursuing an M.S. in hydrogeology at
the University of Connecticut.
Investigation and Remediation
National Research Council
Study Questions Need for
Oxygenates in RFG
by Ron Kern
On May 11,1999, the National
| Research Council (NRC),
which is the main opera-
tional unit of the National Academy
of Sciences and the National Acad-
emy of Engineering, issued a press
release stating that "oxygen addi-
tives used in reformulated gasolines
in the United States contribute little
to reducing ozone pollution." ,The
study, funded by the U.S. EPA, was
conducted to evaluate differences
between MTBE and ethanol in refor-
mulated gasolines (RFG). :
The federal Clean Air Act
Amendments of 1990 require use of
RFG with oxygenates in major urban
areas of the United States that have
significant ozone pollution. The NRC
committee found, however, that the
factors that have been most signifi-
cant in lowering ozone levels are bet-
ter vehicle emissions control
equipment and the other nonoxy-
genating chemical components of
RFG. The study further concluded
that the potential for RFG with MTBE
to curtail smog levels is low and also
that, by comparison, RFG with
ethanol results in an increased poten-
tial of vehicle emissions to form
ozone.
The NRC predicted that vehicle
emissions will continue to decrease
over the next few years as newer
vehicle emission technologies are
implemented. The study did note,
however, that a high proportion of
pollutants originate from older vehi-
cles, which do not tend to be the tar-
gets of tests related to RFG.
Consequently, the effects of RFG on
older vehicles are uncertain, making
it difficult to estimate both total vehi-
cle emissions and the effects of differ-
ent fuel formulations.
In response to the NRC report,
the Oxygenated Fuels Association
(OFA) stated that the report disre-
garded the findings of other state and
federal environmental agencies and
overlooked the benefits of RFG in
reducing "both the exhaust and
evaporative emissions from motor
vehicles, including carbon monox-
ide." The Renewable Fuels Associa-
tion (RFA) expressed concerns that
the NRC report does not consider
either the dilutive effects of oxy-
genates in RFG or the potential
"impact on air quality of the gasoline
components that might be used to
replace the large volume and octane
lost if oxygenates were not used in
RFG." •
Ron Kern is LUST Program
Manager for the Arizona DEQ.
he complete NRC press release and information for obtaining copies of the
i report, Ozone Forming Potential of Reformulated Gasoline, can be found on the
•National A'cademy of Science's Web s[fe:htfp://www2.nas.edu/whatsnew/
J2aJ!6.titnil, Mitional toormajion on the NRC's report and excerpted responses
llfprhtM^
If RFA) areI obtamable at: hiip://www.enn~com/enn-hews-archive/1999/05/
" 051399/rfgs_3180.asp.
IOFA'S response to the NRC report is obtainable at:
T
I
is obtainable at:
23
-------
LUSTUne Bulletin 32
Investigation and Remediation
Some Enlightenment on Density
by Blayne Harhnan
Editor's Note: This is the fourth in a series of articles reviewing some of the
physical/chemical properties that are commonly used in environmental assessment
arid remediation. This article will focus on the property of density.
Okay, the quiz for today is:
A DNAPL is:
(a) A liquid more
(b) A new oxyger
(c) A new EPA offr
Matural Atte;
aan water.
"\
ice MTBE.
Department of
Eolicy and Logistics.
(d) A competitor ofsnapple.
Bet you got this one, didn't you? For those who did not,
the correct answer is (a). Translated into everyday Eng-
lish, a DNAPL (dense nonaqueous phase liquid) is a liq-
uid that does not mix with water and is heavier (more
dense—that is, a sinker). An LNAPL (light nonaqueous
phase liquid), on the other hand, is a liquid that is lighter
than water (less dense—that is, a floater). Oil floating on
Vinegar salad dressing, for example, is an LNAPL. (I was
enlightened by one student, who said you can observe the
same effect when making margaritas from scratch in a
blender.)
Okay, let's name some DNAPLs. How about:
trichloroethane (TCA), trichloroethylene (TCE),
perchloroethylene (PCE), dibromoethane (EDB)
And some LNAPLs:
gasoline, diesel, motor oil, cooking oil
See Any Trends Here?
To understand whaf s going on, we need to review a few
basic concepts relating to the relative weight of a liquid
versus water. To do this, we need to start with the ele-
ments that make up these materials.
Notice that all of the LNAPLs listed above are com-
mon fuel products or oils—hydrocarbons. Hydrocarbons
are compounds that consist primarily of two elements:
hydrogen and carbon. Put the names together and you get
"fiydrocarbon."
Water is also composed of two elements: hydrogen
and oxygen. (Do you ever wonder why we don't call
water hydro-oxygen? I do.) Notice that hydrogen is com-
mon to both hydrocarbons and water—in both cases,
there are about two atoms of hydrogen for each carbon or
oxygen atom. So, in essence, the difference between
hydrocarbons and water is that the former contains car-
bon and the latter oxygen. Carbon has an atomic weight of
12. Oxygen has an atomic weight of 16. So, as a first
approximation, it is reasonable to expect hydrocarbons to
weigh less than water.
24~~
Now let's look at DNAPLs. Most chlorinated and
brominated solvents are simply hydrocarbon molecules
(e.g., ethane, ethylene) that contain one or more chlorine
or bromine atoms. The atomic weight of chlorine is 35.5.
The atomic weight of bromine is 80. Both of these atoms
are very much heavier than the oxygen in water, so we
can reasonably expect materials with these elements in
them to weigh more than water.
Are you starting to get the picture? In the discussion
so far, I have made one tacit assumption: that the space
that each compound takes up (i.e., its molar volume) is the
same. In other words, a hydrocarbon, solvent molecule,
and water molecule take up the same space. In actuality,
this is not the case. So when determining whether a com-
pound will or won't float in water, it is important to com-
pare not just the weight of a material, but the weight for
the same volume occupied.
This ratio of a compound's weight to volume is
known as its density. Commonly, the density of a liquid is
compared to that of water. The ratio of a compound's den-
sity to the density of water is known as the specific grav-
ity. Specific gravity is a convenient reference point,
because liquids with specific gravities greater than 1 are
sinkers and those with specific gravities less than 1 are
floaters.
So What?
Assuming you haven't memorized die specific gravity of
many compounds, you can estimate whether a liquid is a
LNAPL or DNAPL by comparing the atomic weight of the
element in addition to hydrogen with the atomic weight
of oxygen. For petroleum hydrocarbons, carbon is the pri-
mary element besides hydrogen, carbon weighs less than
-------
LUSTLine Bulletin 32
oxygen, and therefore liquid hydrocarbons are likely to
float on water (and they do). For a compound containing
chlorine or bromine, both of these elements are much
heavier than oxygen, and it is likely that compounds with
these elements will sink (and they do). Remember, this is
an estimation only, because density is not dependent on
atomic weight alone.
Wondering about MTBE? The above technique
applies only to liquids (not gases or solids) that do not mix
with water. MTBE mixes with water well enough that it
does not form a separate fluid layer; hence it does not
form a NAPL (non-aqueous-phase liquid).
Vapor Density
Now that you've got the concept of liquid density
down, try this quiz:
You conduct a soil-gas survey at a facility containing
aboveground tanks inside a building and find large
concentrations of MTBE and TPH in the soil gas. You
take soil samples to define the contamination and the
soil analyses all are below detection. What's the expla-
nation?
(a) VOC analyses in thej>oil are not always reliable
due to volatile loss/
(b) The volatility of MTB
soil contamination rm
rated) into the soil
PH is high, so the
-have volatilized (evapo-
(c) The contammationlftarted as a vapor.
(d) Get a new lab.
Those of you who have managed to get through some of
my previous articles (see "The Downward Migration of
Vapors," LUSTLine #28) should know the answer to this
quiz. For those of you who didn't (or those of you who
have forgotten), the answer to this question reqinires us to
consider the concept of vapor density.
The vapor density of a compound relative to air is
approximately equal to the molecular weight of the com-
pound divided by the molecular weight of air, or
Pv = MWi/MWair
Since the molecular weight of air is equal to 29 g/mole,
Pv = MWj/29
A familiar example is helium. With a molecular1 weight of
4 g/mole, it has a vapor density only 1/7 that of air, so of
course, balloons filled with helium rise. Now, let's try a
few of our favorite petroleum compounds:
Because many of the compounds associated with
petroleum hydrocarbons have vapor densities signifi-
cantly larger ithan air (two to four times), vapor density can
play an important role in situations where petroleum
hydrocarbons, such as fuels, are used or stored in an
indoor, confined space. In these situations, the vapors
emanating from a container or from liquid leaks can sink
to the floor because of their high vapor density. Gas and
electric companies are well aware of this behavior, which
is why they require hot water heaters in garages to be a
minimum distance off the floor to prevent the ignition of
dense gasoline vapors "flowing" along the floor.
If air flow is restricted, such as in a closed room, the
dense vapors can penetrate the concrete floor and enter the
upper vadose zone. Such bulk dense vapor movement can
continue to drive the vapor downward through the vadose
zone until it is diluted to concentrations low enough (<1%)
that density ;is no longer an important factor in the vapor
transport process.
Vapor clouds reaching tens of feet into the uppermost
vadose zone have been attributed, at least in part, to den-
sity-driven flow. Businesses and commercial operations
that deal with chlorinated solvents (e.g., dry cleaners,
vapor degreasers, spray facilities) are the most susceptible
to this situation. Vapor clouds are a common occurrence
beneath dry cleaners. The situation is not as common for
petroleum hydrocarbons, because they rarely are stored
indoors in confined spaces (due to their flammability).
However, as far as USTs are concerned, leaks of "dense
vapor" are possible from vent pipes, pipe joints, and tank
bungs.
So, the answer to the quiz? Although there is currently
much debate over the optimum way to measure VOCs in
soils, it is likely that some would have been identified if
the contamination was in the soil. Also, it is extremely
unlikely that all of the soil contamination would have been
lost to the vapor phase, especially if any moisture or car-
bon were present in the soil. Since you have no reason to
doubt your lab, the remaining choice is (c). The measured
contamination may have started as a vapor, penetrated
into the vadose zone, and has yet to "equilibrate" with the
surrounding soils, so it is detected in the soil vapor, but not
in the soils themselves.
Two quizzes this time. I hope you enjoyed them. •
Blayne Hartman is a regular contributor to LUSTLine. This
article is taken from a presentation on physical!chemical -prop-
erties that'he gives as part of a training course on environ-
mental geochemistry. For more information, either e-mail
Blayne at bh@tegenv.com or check out the information on his
Web page at www.tegenv.com.
Benzene:
MTBE:
Gasoline:
Molecular weight: 78
Molecular weight: 88
Molecular weight -100
; Vapor density: 78/29 = 2.5
Vapor density: 88/29 = 3.0
I Vapor density: 1 00/29 = 3.3
25
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LUSTUne Bulletin 32
Coast t^Cgast, is provided as a regular feature o/LUSTLine to update state and federal UST, LUST, and cleanup fund person-
: lid about the activities of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) Tanks Sub-
committee. To find out more about the Tanks Subcommittee, contact Chairperson Scott Winters (CO) at (303) 620-4008 or
Stephen Crimaudo (ASTSWMO) at (202) 624-7883
Tanks Subcommittee
The Tanks Subcommittee had a
very successful mid-year meeting
in April in Denver, Colorado.
Issues discussed during this meet-
ing included preparation for the
2000 OUST National Conference,
MTBE conference planning, impli-
cations of the 12/22/99 deadline
for temporary tank closures, EPA's
UST compliance/enforcement pol-
icy, USTfields, and budget num-
bers.
The Tanks Subcommittee
members were active participants
in the llth Annual UST/LUST
National Conference held in Day-
tona Beach, Florida, in March,
drafting the agenda and planning,
organizing, and speaking at a vari-
ety of the sessions. At the "State
Fair" session, the Subcommittee
presented results from informal
surveys conducted during the past
year: Survey of Residential Under-
ground Storage Tank Enforcement
and Contractor Certification; Aver-
age Cost per Site for Meeting the
1998 Upgrade Requirements; and
Comparison of State UST and AST
Leak Detection Requirements.
The Subcommittee is in the
process of updating its "Report
Card on the Federal UST/LUST
Program." To date, 16 states have
replied with all or most of the data
requested. The results have been
compiled and members will
review the data and consider revis-
ing the questionnaire again to
increase the amount of responses
with usable data.
The Subcommittee also orga-
nized one peer match, allowing the
Assistant^Attorney General, Envi-
ronment Division, State of Utah, to
meet with the Assistant Attorney
General for the State of Iowa in
December to learn from Iowa's
experience in LUST-site remedia-
tion cost recovery and witness an
operator jury trial.
UST Task Force
The UST Task Force conducted a
survey of state 1998 compliance
data: "Where Are We with Respect
to Meeting the 1998 Technical
Standards?" Seventeen states
replied, and the results were pre-
sented at the EPA National Confer-
ence "State Fair." Estimates, based
on the survey of 17 states data-
bases in early 1999 are as follows:
59.7 percent of the existing active
tanks meet the 1998 technical com-
pliance standards; 71.5 percent
meet release detection require-
ments; 64.7 percent meet spill pre-
vention requirements; 63.3 percent
meet overfill protection require-
ments; and 64.3 percent meet cor-
rosion protection requirements.
The UST Task Force is cur-
rently looking for new members.
For more information on UST Task
Force activities, contact Task Force
cochairs Dale Marx (UT) at (801)
536-4100 or Juan Sexton (KS) at
(785)296-1685.
LUST Task Force
The LUST Task Force is preparing
to present a 50-state MTBE (methyl
tertiary butyl ether) conference,
sponsored by ASTSWMO, on July
26-27, 1999 in Washington, D.C.
The conference will bring together
MTBE expertise from U.S. EPA,
states, industry, and academia.
The MTBE Workgroup, a sub-
set of the LUST Task Force, contin-
ues to publish its quarterly MTBE
Newsletter, which includes updates
of how state LUST managers are
coping with MTBE contamination
at LUST remediation sites. The
workgroup produced MTBE
Newsletter #5, January 1999. It can
be found on the ASTSWMO Web
page at http://www.astswmo.org/
Publications/summaries.htm#MTBE.
The MTBE Workgroup has
produced a total of five newslet-
ters. The first provided back-
ground on the Workgroup and the
latest four include in-depth infor-
mation on MTBE research and ref-
erence sources. Newsletter #6 will
be out this summer.
LUST Task Force members are
participating in the development
of two new ASTM standards, one
on evaluating remedial decisions
and another on integrated site
management. Members are also
working with EPA-OUST on
adding an ORC (oxygen-releasing
compounds) chapter to the
agency's alternative technology
guide.
For more information on LUST
Task Force activities, contact
cochairs Kevin Kratina (NJ) at
• continued on page 27
26
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LUSTLine Bulletin 32
. Coast to Coast from page 26
r
(609) 633-1415 or Richard Spiese
(VT) at (802) 241-3880.
L
State Cleanup Funds Task
Force
The State Cleanup Funds Task
Force has spent much of the last
six months planning for what
turned out to be a very successful
Eighth Annual State Fund
Administrators Conference held
in Lexington, Kentucky on June
6-9, 1999. This year's "State
Cleanup Funds Success Stories
Compendium, Fourth Edition" in-
cluded entries in Financial Suc-
cess, Corrective Action, and
Legal/Management. The State
Funds Association honored
Alabama as the "Best Fund for
Getting the Job Done," Washing-
ton for Financial Success, Kansas
for Corrective Action, and Ver-
mont for Legal/Management.
Next year's conference will be
held in June in Scottsdale, Ari-
zona.
For more information on the
State Cleanup Funds Task Force
activities or on the Annual Con-
ferences, contact George Matthis
(NC) at (919) 733-1332.
TIE Task Force
The Training and Information
Exchange (TIE) Committee
worked hard to ensure the suc-
cessful planning and implementa-
tion of the mid-year meeting in
Denver. The TIE Task Force is cur-
rently working with the MTBE
Workgroup on planning the
MTBE National Conference. The
TIE Task Force continues to work
on and update ASTSWMO's
Internet home page.
For more information on TIE
Task Force activities, contact Task
Force chairperson Kathy Stiller
(DE) at (302) 323-4588. :
L.U.S.T. Buster T-Shirts
& Sweatshirts!
Tee's: M,L, XL, XXL
Sweats: M, L, XL, XXL
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We welcome your comments and suggestions on any of our articles.
27
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Updated Booklet on
Financing UST Work
OUST has updated its 1995 booklet,
Financing Underground Storage Tank
Work: Federal and State Assistance.
The updated booklet will help UST
owners and operators, including
those with tanks in Indian Country,
obtain information about loans or
grants for financing the costs of
upgrading, replacing, or dosing an
UST, or of cleaning up an UST
release.
The booklet describes federal
loan and grant programs that, while
not designed specifically for UST
work, provide funding that owners
and operators maybe able to use for
these activities. It also provides
addresses and telephone numbers
for potential sources of financial
assistance in states.
OUST will include this revised
tool in its compliance assistance
packet being mailed to marketers
and nonmarketers. Copies of the
new booklet will be sent to regional
and state UST program offices; the
booklet will also be available on
OUST's home page, www.epa.govl
OUST under "OUST Publications."
EPA HQ UPDATE
OSWER Monitored Natural
Attenuation Directive
The final version of a new OSWER
Directive (9200.4-17P), Use of Moni-
tored Natural Attenuation at Super-
fund, RCRA Corrective Action, and
Underground Storage Tank Sites, is
now available. The purpose of this
directive is to clarify EPA's policy
regarding the use of monitored nat-
ural attenuation (MNA) for the
remediation of contaminated soil
and groundwater at sites adminis-
tered by OSWER. The effective date
is April 21,1999.,
This directive replaces the
interim draft released in December
1997. Copies of the directive are
being distributed by OSWER
offices. The directive is available on
EPA's Web site at www.epa.gov/
swerustl/directiv/d9200417.htm. For
more information, contact Hal
White at (703) 603-7177.
RBCA Fate and Transport
Models: Compendium and
Selection Guidance
The American Society of Testing
and Materials (ASTM) and OUST
announce the release of RBCA Fate
and Transport Models: Compendium
and Selection Guidance.
This document is a compendium of
commonly used fate and transport
models and contains information to
aid in the selection of appropriate
models to be used in the risk-based
corrective action (RBCA) process.
This guidance is presented so that
information can be used by audi-
ences with varying levels of experi-
ence in fate and transport modeling.
The information addresses all
chemical fate and transport path-
ways, including vapor migration,
soil leaching, and groundwater
transport pathways. The guidance
presents easy-to-use comparison
tables, matrices, and flowcharts to
convey and compare key informa-
tion on specific models, such as
equations, applicability, key/sensi-
tive input parameters, model out-
put formats, and limitations.
The document is an ASTM pub-
lication and was funded and techni-
cally coordinated by OUST under
an assistance agreement. It received
extensive review from states, EPA,
and the National Partnership in
RBCA Implementation (PIRI). Gov-
ernment agencies and the public
may obtain the document at no cost
by contacting EPA's National Ser-
vice Center for Environemental
Publications at (800) 490-9198. Busi-
nesses may obtain copies by con-
tacting ASTM at (610) 832-9685.
The document can be downloaded
from OUST's home page at
www.epa.gov/oust/rbdm/rbdmfnt.htm.
LU.ST.UNE
New England Interstate Water
Pollution Control Commission
Boott Mills South
100 Foot of John Street
Lowell, MA 01852-1124
Forwarding and return postage guaranteed.
Address correction requested.
28
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