Wew England Interstate
Water Pollution Control
            Boott Mills South
            1OO Foot of John Street
            Lowell, Massachusetts
                       Bulletin 33
A Report On Federal & State Programs To Control Leaking Underground Storage Tanks
                         EPA's Blue Ribbon Panel
                         Takes On the MTBE Specter
                         by Ellen Frye
                n July 27, after six months of meetings, information gathering, and delib-
                eration, EPA's Clean Air Act Advisory Committee Panel on Oxygenate
                Use in Gasoline, aka "the Blue Ribbon Panel," announced its findings
       and recommendations. In its report, the panel recognized that MTBE can pose risks to
      water supplies and that to minimize current and future threats to drinking water, "the
     use of MTBE should be reduced substantially." The panel also set forth a number of pur-
    poseful recommendations designed to "enhance, accelerate, and expand" existing federal,
     state, and local programs to protect, treat, and remediate water supplies.      -
        The report states emphatically that the recommendations are meant to be "imple-
     mented as a. single package of actions designed to simultaneously maintain air quality bene-
      fits while enhancing water quality protection and assuring a stable fuel supply at
      reasonable cost." There's some wisdom in this thinking—If you've got a holey bucket that
     won't hold water, and you mend just some of those holes, you've still got a bucket that
     won't hold water.                            '-
        . The panel urged "rapid" implementation of its recommendations. In announcing the
      findings, U.S. EPA Administrator Carol M. Browner said, "We must begin to significantly
       reduce the use of MTBE in
       gasoline as quickly as
        possible." She noted that
        when the panel was
    assembled, her goal was  "to
    protect public health and the
    environment by ensuring that
    Americans have both cleaner
    air and cleaner  water-—and
    never one at the expense of
   the other."
       Browner appointed  the
 panel of leading MTBE-related
experts in November 1998 to investi-
gate the air quality benefits and water quality concerns
associated with oxygenates in gasoline and to provide
independent advice and recommendations on ways to
maintain air quality while protecting water quality.

                         • continued on page 2
                                                 r~. ~~-&i£^'z^z^^^?jz^,.-;^zx?.%®z3*%K3W:
                                                 ing Water Standard forMTBE?
                                                 In Situ Biobarriers to Rapidly Degrade MTBE ~
                                                       vi,    "^T
                                                       Louis Service Station
                                                  'l^""i '.^-i^r-^,-"-V, .jfe.V- ;£KTV=.i-;i?r#;^?^c;-~*^^^
                                               ild Notes: Why Many UST Systems Are Not Leak-Proof
                                             Reevaluating Leak Detection Method Protocols?
  riere Has Our Petroleum Storage Capacity Gone?

 Coast to Coast •  . _'_,. _   ..,'_.._.... .,,.,_ ____
;: Tanks Down East: Trials and Tribulations of Leaking
                              ilips for aTig-Top Tank System ______
                               Mitigating Third-Party Damage Claims with PFP
                               EPA HQ Update

LUSTLine Bulletin 33
• Blue Ribbon Panel from page 1

    Many of the findings of the Blue
Ribbon Panel are similar to those of
the Advisory Panel on the Leak His-
tory of New and Upgraded UST Sys-
tems, convened by  the California
State Water Resources Control Board,
which issued its report in January
1999. That panel was asked to review
existing databases of UST contamina-
tion sites to determine whether a leak
history is associated with UST sys-
tems meeting the 1998 federal and
state standards and, if so, to identify
appropriate measures that  would
assure the prevention and detection
of oxygenate  releases  from retail
marketing facilities.

Can We Have Our Fuel and
Keep it Out of the
Environment, Too?
The states of California and Maine
have led the charge on the MTBE
front. Concern about the presence of
MTBE in  the  environment  has
prompted both states to take a num-
               [uct of the HewTSngland
                 produced through a "
                   mrr825782-oi-o) *
                as 4 comtn,unication
          , For trje Sub, title I RCRA     ;
        pus jj Sfil1" wag|e_An^ndments_
           romulgation process.
             produced to promote
       _ ....... _ ...... apgeonUST/LUSTJssues.J:
      inions and information stated herein ,
            trje opinions of NEIWPCC.  J
3Vffn$§ publicttori may be copied.
iiSiPlease eive credit toTSJEIWPCC.
            .and ,remair}s.&e,oi(iest  ;
               east United, States	^
                     Ethemulg-	j
       LUSTUne Is printed on Recycled Paper
                                                  tions are meant to
                                    simultaneously maintain ^guaiity
                                     /jtralit^jjmtection and assuring a
                                  ber of actions to assess the situation
                                  and find ways to prevent MTBE from
                                  escaping into the environment. These
                                  steps include California's decision to
                                  phase out the use of MTBE in gaso-
                                  line sold in the state  by December
                                  2002 and Maine's decision to opt out
                                  of the federal Reformulated Gasoline
                                  (RFC) Program.
                                      The lion's shares  of the recom-
                                  mendations of both the California
                                  and Blue Ribbon panels, regarding
                                  the UST program, reflect  the wish
                                  lists, if not the agendas, of state and
                                  federal UST regulators across  the
                                      "The Blue Ribbon Panel's recom-
                                  mendations dovetail real well with
                                  the  issues we identified  a  while
                                  back,"  says Sammy Ng, Acting
                                  Director of EPA's Office of Under-
                                  ground Storage Tanks, "in terms of
evaluating UST systems that are in
place to see how they are working
and the effectiveness of leak detec-
tion systems. We share many of the
priorities listed in the panel's report."
   Finding the  resources and the
political will to carry out such recom-
mendations to the fullest extent pos-
sible is the prickly part of the picture.
UST regulators have their work cut
out for them just in dealing with the
1998 deadline stragglers. Yet, here we
have  a series of recommendations
that  ask EPA (and the states) to
revisit existing standards and regula-
tions, increase enforcement, step up
research, and look into expanding the
universe  of regulated  tanks  to
include  underground and  above-
ground fuel tanks not currently regu-

Soooo... What Now?
The real question that we as a society
have not truly answered is this: Are
we willing to commit the resources
required to minimize the presence of
MTBE in the environment? The Blue
Ribbon Panel came up with recom-
mendations that are meant to keep
MTBE from escaping into the envi-
ronment. What remains to be seen is
how big a commitment our legisla-
tures, regulators, local governments,
and John Q. Citizens are willing to
make to achieve this goal. That being
said, let's see what the Blue Ribbon
Panel had to say.  •
                                           The real question that we as a society have not truly answered is this:
                                      Are we willing to commit the resources required to minimize the presence
                                                         of MTBE in the environment?
                                        BLUE RIBBON PANEL ISSUE PAPERS TO BE
                                        POSTED ON THE WEB
                                        Issue Summary papers will be posted on the Blue Ribbon Panel on Fuel
                                        Oxygenates Web page (http: / / www.epa.gov / oms / consumer / fuels /
                                        oxypanel / blueribb .htm) early this fall. The papers will cover the fol-
                                        lowing topics:
                                             • Water Contamination
                                             • Air Quality Benefits
                                             • Fuel Supply and Cost
                                             • Comparing the Fule Additives
                                             • Prevention, Treatment, and Remediation

                                                                                      LUSTLine Bulletin 33
The Findings and Recommendations  of the Blue Ribbon
Panel on Oxygenates in Gasoline (Condensed)
Based on its review of the issues, the panel came up with the following overall findings:
• The distribution, use, and combustion of gasoline pose risks to our environment and public health.
• RFG provides considerable air quality improvements and benefits for millions of U.S. citizens.
• Due to its persistence and mobility in water, MTBE is more likely to contaminate ground and surface water
  than the other components of gasoline.
• The occurrence of MTBE in drinking water supplies can and should be substantially reduced.
• MTBE is currently an integral component of the U.S. gasoline supply in terms of both volume and octane. As
  such, changes in its use, with the attendant capital construction and infrastructure modifications, must be
  implemented with sufficient time, certainty, and flexibility to maintain the stability of both the complex U.S.
  fuel supply system and gasoline prices.

According to the panel, the majority of these recommendations could be implemented by federal and state environ-
mental agencies without further legislative action. The panel urges all parties to work with Congress to implement
those recommendations that require legislative action.

• Take the following actions to enhance significantly the federal and state UST programs:
  • Accelerate enforcement of rules requiring the replacement of existing tank systems to conform with the fed-
    erally required December 22,1998, deadline for upgrade, including, at a minimum, moving to have all states
    prohibit fuel deliveries to nonupgraded tanks and adding enforcement and compliance resources to ensure
    prompt enforcement action.
  • Evaluate the field performance of current system design requirements and technology and, based on that
    evaluation, improve system requirements to minimize leaks / releases, particularly in vulnerable areas.
  • Strengthen release detection requirements to enhance early detection, particularly in vulnerable areas, and
    to ensure rapid repair and remediation.
  • Require monitoring and reporting of MTBE and other ethers in groundwater at all UST release sites.
  • Encourage states to require that the proximity to drinking water supplies, and the potential to  affect those
    supplies, be considered" in land-use planning and permitting decisions for siting of new UST facilities and
    petroleum pipelines.
  • Implement and / or expand programs to train and license UST system installers and maintenance personnel.
  • Work with Congress to examine  and, if needed, expand the universe of regulated tanks to include .under-
    ground and aboveground fuel storage systems that are not currently regulated yet pose a substantial risk to
    drinking water supplies.

• Enhance implementation of the federal and state Safe Drinking Water Act programs in the following ways:
  • Accelerate, particularly in those areas where RFG or oxygenated fuel is used, assessments of drinking water
    source protection areas required in Section 1453 of the 1996 Safe Drinking Water Act Amendments.
  • Coordinate the Source Water Assessment program in each state with federal and state UST programs using
    geographic information and other advanced data systems to determine the location of drinking water
    sources and to identify UST sites within source protection zones.
  • Increase ongoing federal, state, and local efforts in Wellhead Protection Areas as follows: enhance permit-
    ting, design, and system installation requirements for USTs and pipelines in these areas; strengthen efforts
    to ensure that nonoperating USTs are properly closed; enhance UST release prevention and detection; and
    improve inventory management of fuels.

                                                                                 continued on page 4 b+-

WSTUne Bulletin 33
   con tin tied from page 3
   • Enhance efforts to protect lakes and reservoirs that serve as drinking water supplies by restricting use of
     recreational watercraft, particularly those with older motors.

   • Implement expanded programs to protect private well users.

   • Implement, through public-private partnerships, expanded public education programs at the federal, state,
     and local levels on the proper handling and disposal of gasoline.

   • Develop and implement an integrated field research program into the groundwater behavior of gasoline and
     oxygenates that includes the following steps:
      •  Identifying and initiating research at a population of UST release sites and nearby drinking water supplies,
        including sites with MTBE, sites with ethanol, and sites using no oxygenates; and
      •  Conducting broader, comparative studies of levels of MTBE, ethanol, benzene, and other gasoline com-
        pounds in drinking water supplies in areas using primarily MTBE, areas using primarily ethanol, and areas
        using no or lower levels of oxygenates.

   Treatment and Remediation
   • EPA should work with Congress to expand resources available for the up-front funding of the treatment of
     drinking water supplies  contaminated with MTBE and other gasoline components  to ensure that affected sup-
     plies can be rapidly treated and returned to service, or that an alternative water supply can be provided. This
     effort could take a number of forms, including but not limited to:
      •  Enhancing the existing federal LUST Trust Fund by fully appropriating the annual available amount in the
        fund, ensuring that treatment of contaminated drinking water supplies can be funded, and streamlining the
        procedures for obtaining funding;
      •  Establishing another form of funding mechanism that ties the funding more directly to the source of contam-
        ination; and
      •  Encouraging states to consider targeting State Revolving Funds (SRF) to help accelerate treatment and reme-
        diation in high-priority areas.

   •  Given the different behavior of MTBE in groundwater as compared with that of other components of gasoline,
      states in RFC and oxyfuel areas should reexamine and enhance state and federal "triage" procedures for priori-
      tizing remediation efforts at UST sites based on their proximity to drinking water supplies.

   • Accelerate laboratory and field research, as well as pilot projects, for the development and implementation of
      cost-effective water supply treatment and remediation technology, and harmonize these efforts with other
      public/private efforts already under way.

   Inasmuch as even enhanced protection programs will not give adequate assurance that water supplies will be pro-
   tected, changes need to be  made to the RFC program to reduce the amount of MTBE being used, while ensuring
   that the air quality benefits  of RFC, as well as fuel supply and price stability, are maintained.
       Given the complexity of the national fuel system, the advantages and disadvantages of each of the fuel blend-
   ing options that the panel considered, and the need to maintain the air quality benefits of the current program, the
   panel recommended an integrated package of actions by both Congress and EPA that should be implemented as
   quickly as possible. The key elements of that package are as follows:

   •  Action to reduce the use of MTBE substantially, and action by Congress to clarify federal and state authority to
      regulate and/or eliminate the use of gasoline additives that threaten drinking water supplies;

   •  Action by Congress to remove the current 2 percent oxygen requirement to ensure that adequate fuel supplies
      can be blended in a cost-effective manner while quickly reducing usage of MTBE; and

   •  Action by EPA to ensure that there is no loss of current air quality benefits.

   Reducing the Use of MTBE
   The panel agreed broadly that, to minimize current and future threats to drinking water, the use of MTBE should
   be reduced substantially. Several members believed that the use of MTBE should be phased out completely.

                                                                                       continued on page 5 ta+-

                                                                                          LUSTLine Bulletin 33
The panel recommended that Congress act quickly to clarify federal and state authority to regulate and/or elimi-
nate the use of gasoline additives that pose a threat to drinking water supplies.
    Initial efforts to reduce additive levels should begin immediately, with substantial reductions to begin as soon
as the removal of the 2 percent oxygen requirement is implemented. Accomplishing any such major change in the
gasoline supply without disruptions to fuel supply and price will require adequate lead time—up to four years if
the use of MTBE is eliminated, sooner in the case of a substantial reduction (e.g., returning to historical levels of
MTBE use).
    The other ethers (e.g., ETBE, TAME, and DIPE) have been less widely used and studied than MTBE. To the
extent that they have been investigated, they appear to have similar, but not identical, chemical and hydrogeologic
characteristics. The panel recommended accelerated study of the health effects and groundwater characteristics of
these compounds before they are placed in widespread use.
    In addition, EPA and others should accelerate ongoing research efforts into the inhalation and ingestion health
effects, air emission transformation by-products, and environmental behavior of all oxygenates and other compo-
nents likely to increase in the absence of MTBE. This program should include research on ethanol, alkylates, and
aromatics, as well as on gasoline compositions containing those components.
    To ensure that any reduction is sufficient to protect water supplies, EPA, in conjunction with USGS, the
Departments of Agriculture and Energy, industry, and water suppliers, should move quickly to:

• Conduct short-term modeling analyses and other research based on existing data to estimate current and likely
   future threats of contamination;

• Establish routine  systems to collect and publish, at least annually, all available monitoring data on use of
   MTBE, other ethers, and ethanol; levels of MTBE, ethanol, and petroleum hydrocarbons found in ground, sur-
   face, and drinking water; and trends in detections and levels of MTBE, ethanol, and petroleum hydrocarbons in
   ground and drinking water; and

• Identify and begin to collect additional data necessary to adequately assist the current and potential future
   state of contamination.

The Wintertime Oxyfuel Program
The panel recommends that the Wintertime Oxyfuel program be continued (a) for as long as it provides a useful
compliance and/or maintenance tool for the affected states and metropolitan areas, and (b) assuming that the clari-
fication of state and federal authority described above is enacted, to enable states, where necessary, to regulate
and/or eliminate the use of gasoline additives that threaten drinking water supplies.

The introduction of reformulated gasoline has had substantial air quality benefits, but has also raised significant
questions that should be answered before the widespread introduction of any new, broadly used product. The
unanticipated effects of RFG on groundwater highlight the importance of exploring the potential for adverse effects
in all media (air, soil, and water), and on human and ecosystem health, before the widespread launch of any such
    To prevent such incidents in the future and to evaluate the effectiveness and impact of the RFG program, EPA

• Conduct a full, multimedia assessment (of effects on air, soil, and water) of any major new additive to gasoline
   prior to its introduction;

• Establish routine and statistically valid methods for assessing the actual composition of RFG and its air quality
   benefits, including the development, to the maximum extent possible, of field monitoring and emissions charac-
   terization techniques to assess "real world" effects of different blends on emissions;

• Establish a routine process, perhaps as part of the Annual Air Quality trends reporting process, for reporting on
   the air quality results from the RFG program; and

• Build on existing public health surveillance systems to measure the broader effects (both beneficial and adverse)
   of changes in gasoline formulations on public health and the environment.

The "Executive Summary and Recommendations of the Blue Ribbon Panel on Fuel Oxygenates" can be found on
|he panel's Web page: http://www.epa.gov/oms/consumer/fuels/oxypanel/blueribb.htm.  .	„
ijhe, "Report of the State Water Resources Control Board's Advisory Panel on the Leak History of New and ;
JJpgraded UST Systems" can be accessed at http: / / www.swrcb.ca.gov/ -cwphome /ust / usthmpg.htm.

LUSTLine Bulletin 33
A Drinking Water Standard for MTBE?
The  Ifs  and  Whens of Establishing; an  MCL
by Rachel Snkata

The Long and Winding Road
Many steps are involved in establish-
ing a drinking  water standard or
maximum contaminant level (MCL).
Drinking water standards are regula-
tions that the U.S. Environmental
Protection Agency (EPA) sets to con-
trol the level of contaminants in the
nation's drinking water. The Safe
Drinking Water Act (SDWA) identi-
fies  several factors that affect the
level at which an MCL is set: known
or anticipated adverse human health
effects, the ability of various tech-
nologies to remove the contaminant,
their effectiveness, and cost of treat-
ment. All MCLs are set at levels that
protect public health. The process of
establishing an MCL for a given cont-
aminant from start to finish can take
10 years or longer.
    Step number one in developing a
regulation is to identify  drinking
water problems. Currently, there are
thousands of  contaminants  that
could affect drinking water quality.
Priority contaminants are selected
carefully with an eye  toward ensur-
ing  that expenditures for  drinking
water protection are effective at the
federal, state, and local levels.
    If EPA determines that a contam-
inant poses a threat to human health,
it is placed on the agency's Contami-
nant Candidate List (CCL). Once
placed on this  list, these  contami-
nants  become the focus of EPA's
drinking  water  program  over a
period of years. EPA receives advice
on which contaminants to include on
the CCL from scientific advisory pan-
els  such  as the Science Advisory
Board (SAB), the National Drinking
Water Advisory Council (NDWAC),
and the public. Contaminants on the
CCL are classified into three cate-
gories: contaminants ready for regu-
latory    determinations,   those
requiring additional research, and
those for which more occurrence data
are needed.
   The SDWA mandates that EPA
make  regulatory  determinations
based on three factors:
• Risk that-a contaminant may pose
  to human health,
• The frequency with which a cont-
  aminant of concern  occurs  in
  drinking water supplies, and
• The "meaningful" opportunity for
  health risk reduction achieved
  through regulation of the contam-
 Mass- i*si3- ««iS^                    ^i!
 Spade, EPA will need approximately
 	«i|'	Hi	f	!»	MhiliW^
    • three and a half years for rule
 i'jevelopment. Thus, the earliest EPA
 in^«,'-^'fcte^wwr^ '';'>-V'^"^TY"*1 ^K^M^vTsvr;^- "--*"\.
       Once the contaminants have
been selected and .categorized on the
CCL, the SDWA  requires EPA to
select five or more contaminants
from the regulatory determination
priorities  category  and,  by  2001,
determine whether to regulate them.
If EPA determines that a regulation is
necessary, the agency has three  and a
half years to issue a final regulation.
The first CCL was published in Feb-
ruary 1998, meaning that the first reg-
ulations to result from that list will be
published in February 2005. The CCL
and the decision to regulate operate
on a five-year cycle; any contaminant
that is not chosen in this round will
not be regulated until 2010.
       If EPA feels  it does not have
the information to make a regulatory
determination for a  contaminant on
the CCL, then it is listed under the
occurrence and research priority lists.
The research priority list is designed
to address  additional  information
needed on health,  treatment  tech-
nologies, and analytical methods for
the contaminant. The
occurrence   priority
list addresses occur-
rence data gaps for
that contaminant.
The MTBE Timeline
So how does this MCL process relate
to MTBE? MTBE was placed on the
February 1998 CCL with the indica-
tion that further health effects, occur-
rence,  and treatment  technique
information was needed before a reg-
ulatory   determination  could be
made. Since then,  EPA has deter-
mined that suitable treatment tech-
nologies exist; however, more health
effects and occurrence information is
still needed.
    EPA will gather occurrence infor-
mation  through the  Unregulated
Contaminant   Monitoring   Rule
(UCMR), a vehicle for assisting the
agency in obtaining national occur-
rence information for MTBE, begin-
ning in 2001. EPA is also awaiting the
completion of ongoing health effects
    Inasmuch as EPA does not expect
to have this information for MTBE by
2001, when the agency makes its first
round of regulatory determinations
on contaminants on the CCL, a regu-
latory determination for MTBE could
not be made until 2006. Keep in mind,
however, this determination depends
on whether EPA decides  there is
enough information  for MTBE to
move into the regulatory determina-
tions category. If a regulatory deter-
mination is made, EPA will  need
approximately three and a half years
for rule development. Thus, the earli-
est EPA would have a regulation for
MTBE is 2010. •

   Rachel Sakata is an Environmental
   Protection Specialist with the U.S.
   Environmental Protection Agency
     Office of Ground Water and
          Drinking Water.

                                                                                        LUSTLine Bulletin 33
   Leak Prevention
 Are Upgraded UST Systems Leaking?
 The Santa Clara Valley  Water
 District's Study
 by Ron Kern

       As part of a  multipronged
       effort to protect Santa Clara
       County's water supplies, Cal-
 ifornia's Santa Clara Valley Water
 District (SCVWD) conducted a study
 to determine whether methyl tertiary
 butyl ether (MTBE) is leaking from
 UST  systems  that  comply with
 1998  federal- and state-mandated
. upgrade requirements. The results,
 although inconclusive for the main
 objective, are nonetheless significant
 in  other areas.  The three-volume
 Groundwater Vulnerability Pilot
 Study, Investigation of MTBE Occur-
 rence Associated with  Operating UST
 Systems, was finalized on July 22,
    The study  was  driven by  the
 SCVWD's growing awareness that,
 as shown by anecdotal information of
 undetected releases at 1998 upgrade-
 compliant UST facilities, UST releases
 and MTBE are still very much with
 us. The Water  District also  recog-
 nized that there were more detections
 of MTBE at active site LUSTs (83%)
 than at inactive site LUSTs (59%) in
 the county.
    Selection criteria for this study
 were threefold: candidate USTs had
 to be storing or distributing gasoline;
 have no known release of fuel con-
 taining MTBE based upon review of
 regulatory files and databases; and be
 in compliance with  1998 upgrade
 requirements. Using a database of
 more than 2,000 sites reporting petro-
 leum storage or use in the county, the
 USTs that fit the first three criteria
 were further winnowed by a ranking
 process that included proximity of
 the UST site to a known LUST site,
 proximity to a potable-use well, and
 prior land use. In addition, facilities
 selected provided a good cross sec-
 tion of UST systems with single- and
 double-walled tank construction, sin-
 gle- and double-walled piping, and
 fiberglass and steel UST material.
    The study population ultimately
consisted  of  28 facilities with 65
USTs. The SCVWD was able to gain
on-site access at 17 of the 28 facilities
but was able to conduct off-site inves-
tigations only for the remaining 11

The Investigation
Investigation methods were compre-
hensive and included a preliminary
site inspection and coordination with
the UST facility owner/operator. At
on-site locations, soil-gas surveys and
cone penetrometer testing (to deter-
mine soil types and depth to ground-
water) were conducted.  Continuous
core sampling was  used to obtain
lithologic and depth-to-water infor-
mation at off-site localities. Soil and
groundwater samples were collected
  •   The study was driven by the
   B-i«t stew *- J*i  jjj.  ifrte.  * ?•  mij(
 !jSGVWD's growing awareness that,
 tas shown by anecdotal information
   gfwidetectejljeleases atJ998
   ffigfade-compliant UST facilities,
 ^USTjeleases and MTBE are still
        very much with us.
at both on-site and off-site locations.
Sampling targeted the tank(s), dis-
penser island(s), and any surface and
other features that might collect or
localize fuel releases containing MTBE.
    The data were  compiled and
summarized  in  28  detailed site
reports, which make up the majority
of the more than 600-page  report.
Finally, statistical  determinations
were conducted  to  determine  the
relationship  between  MTBE   in
groundwater and various UST sys-
tem components or features at a site.

The Findings, the Questions
MTBE was detected in soil gas at 9 of
the 17 on-site localities and in soil
samples at 15 of the 28 total facilities
(5.1 to 15,000 ^wg/kg). Groundwater
was encountered at 27 of the 28 facili-
ties, ranging from depths of 8 feet to
97 feet.  MTBE was  detected  in
groundwater at 13 of the 27 facilities
(0.55 to 200,000 pg/L), with 5 of the
facilities   having   concentrations
exceeding 1,000 ^fg/L. One or more
other  oxygenates  (DIPE,  ETBE,
TAME, or TEA) were also detected in
groundwater at these same 5 facili-
ties.   Benzene  was   detected  in
groundwater, but only at 7 of the 27
facilities  and at concentrations less
than 100 ffg/L.
   With the possible  exception of
one site, the SCVWD study was ulti-
mately unable to determine whether
releases of MTBE had occurred from
upgraded UST systems. The data do
indicate, however, that MTBE may be
contaminating groundwater at about
50 percent of UST facilities meeting
the 1998  upgrade requirements in
Santa Clara County.
   Furthermore, because there  were
no known releases of MTBE  from
these UST systems prior to the study,
these  facilities have  experienced
undetected releases of MTBE that have
had an impact on soils and poten-
tially groundwater. The question is,
Why? Are these leaks related to  a
particular component of the storage
or distribution system? Are releases
occurring from places  that  are
beyond the capacity of the leak detec-
tion method to detect? Are most  or all
of the leaks occurring as vapor-phase
releases?  Or, are the leak detection
methods inadequate or not properly
   Statistical correlations were con-
ducted to determine  whether the
probability of an MTBE release could
be related to any particular system
component. The only statistically sig-
nificant correlation  found in this
study was the likelihood of an MTBE
occurrence   associated   with   a
"vacuum-assisted" versus a "bal-
anced" Stage  II  vapor  recovery
             • continued on page 18

LUSTLine Bulletin 33
  Investigation and Remediation
Using In  Situ Biobarriers to  Rapidly Degrade
MTBE in  Subsoils  and  Groundwater
By Joseph Salanitro and Paul Johnson

     The Clean Air Act of 1990 man-
     dated the use of oxygenated
     chemicals (i.e., MTBE and/or
ethanol) in reformulated motor vehi-
cle gasoline (RFC) to reduce tailpipe
emissions  of  carbon  monoxide.
MTBE (methyl tertiary butyl ether),
however, is the most widely used
oxygenate. Although MTBE has been
used  as an  octane enhancer since
1979,  its current  use in  gasoline
varies from 11 to 15 percent on a vol-
ume/ volume basis (where used)
depending on the sale of fuel during
the summer/winter seasons. It is
now widely recognized that the pres-
ence  of varying concentrations of
MTBE in groundwater is the result of
the accidental release of MTBE from
storage tanks and delivery systems
at retail and nonretail fuel stations.
    Studies   conducted  by   the
Lawrence Livermore National Labo-
ratory, the U.S. Geological Survey,
the University of Texas, the Ameri-
can Petroleum Institute,  and  the
petroleum industry have shown that,
in  many  cases, the migration of
MTBE in aquifers behaves differently
than those of aromatic hydrocarbons
(e.g., BTEX). Analysis of the physical,
chemical, and biodegradability prop-
erties of MTBE indicate that this ether
is more water-soluble (28-280 times),
has a lower octanol/water partition
coefficient (6-60 times), has a lower
soil sorption coefficient (2-10 times),
and is much less biodegradable (5-10
times) than BTEX compounds.
    These inherent features of MTBE
indicate that groundwater plumes of
MTBE may be longer and more per-
sistent than those of BTEX alone. In
this respect, some  MTBE plumes
have  varied from a few hundred to
several thousand feet from the origi-
nal spill source. The extent of soluble
MTBE migration and its vertical and
horizontal distribution in groundwa-
 ter, however, are influenced by the
local  hydrogeology (i.e., soil type,
hydraulic conductivity, water table
gradient, and fluctuation), presence
of  a  confined  or
unconfined aquifer,
groundwater veloci-
ties, and advective
dispersion and dilu-
tion   along   the
aquifer  flow path.
Source areas contain-
ing free or residual-
phase gasoline also
affect the extent and
persistence of MTBE
plumes  because  of
"water   washing"
and seasonal water
table fluctuations in these zones.
Microbial Cultures That
Degrade MTBE
Research for determining the poten-
tial for biodegradation of MTBE
began in 1989 at the Shell Westhol-
low Technology Center, now part of
the Shell-Texaco alliance, as part of
an effort to  develop  cost-effective
technologies for soil and groundwa-
ter remediation and water treatment
of MTBE. Our current understanding
of the metabolism of MTBE indicates
that the ether is cleaved to t-butyl
alcohol (TEA), a primary but tran-
sient metabolite.  TEA is then oxi-
dized  via the  sequence  TEA—>
isopropyl alcohol —> acetone —> pyru-
vate —> acetate —> CO2.
   Mixed cultures [e.g., biological
culture (BC) consortia] developed in
our laboratory can metabolize MTBE
and all of its downstream metabolites
at high rates. BC bacterial cultures
can also oxidize several other ethers,
including ethyl-t-butyl ether (ETBE),
t-amyl methyl ether (TAME), diiso-
propyl ether (DIPE), n-butyl methyl
ether, and n-butyl efhyl ether.
    Three  types of naturally occur-
ring mixed or single  bacterial cul-
tures have been isolated  that can
degrade MTBE partially  or  com-
•  Cometabolic systems,  such as
   those requiring another substrate

  (e.g., propane, pentane, isoalka-
  nes, or cyclohexane) to induce an
  existing oxygenase enzyme sys-
  tem, have been shown to partially
  degrade (only to TEA) or com-
  pletely degrade  MTBE.  When
  using  cometabolic  substrates,
  however, it may be more difficult
  to maintain and sustain activity.
  There are also mixing and deliv-
  ery problems with gaseous sub-
  strates  in inducing aquifer soil
• Mixed  microbe  culture enrich-
  ments derived from refinery or
  chemical biotreaters can degrade
  MTBE to CO2.
• Aerobic single cultures (SC) such
  as Khodococcus sp. (SC-100) derived
  from our BC mixed culture or a
  Rubrivivax sp.  derived from a
  municipal biofilter enrichment are
  possible. These single cultures also
  degrade MTBE similarly to mixed
  consortia. Anaerobic transforma-
  tion of MTBE  appears  to be
  uncommon; in one case it has been
  shown that MTBE is metabolized
  to TEA only by a methanogenic
  river sediment culture.
    Our studies on the ability of BC
or SC cultures to grow on MTBE and
TEA as sole carbon sources indicate
that low cell yields are obtained. The
growth rate and low yields are 5 to 10
times lower than comparable growth
on  sugars, aromatic hydrocarbons
(e.g., BTEX), or alkanes.

                                                                                            LUSTLine Bulletin 33
The Case for Aquifer
Several of the gasoline releases from
USTs indicate  that  MTBE plumes
have extended beyond BTEX plumes.
Laboratory soil/groundwater micro-
cosm experiments with aquifer mate-
rial from these sites indicate that low
numbers   of , MTBE-degraders  or
weak ether-degrading activity is usu-
ally observed and is much less than
that for BTEX compounds.
    It is well known that BTEX plumes
.are largely  attenuated in  aerobic
aquifers because of the rapid growth
and metabolism of indigenous soil
microbes on these hydrocarbons. By
contrast, the natural decay of MTBE
occurs slowly or not at all because of
the low numbers of degraders and the
inability of bacteria to grow on  the
ether. In MTBE plumes, "microbial
enrichment" does not occur to any sig-
nificant  degree   and  the plume
"grows" primarily by advection with
dispersion and dilution. In  other
words, the microbial growth rate on
MTBE in the aquifer is much slower
than the groundwater velocity.
    We have investigated the effect
of adding specialized, high-activity,
MTBE-degrading  bacterial cultures
to  soils  and groundwater. Micro-
cosms prepared from  site aquifer
material amended with BTEX and
MTBE (5-80 mg/L)  and inoculated
with mixed (BC) or single (SC-100)
cultures of MTBE-degraders that we
have  identified  rapidly  degrade
MTBE at rates comparable to the nat-
ural decay of  BTEX compounds.
These results suggest that significant
in situ bioremediation  of MTBE in
aquifers is possible with the implan-
tation of high-activity cultures.
    The concept of a biobarrier is to
"seed"  (inject)  microbes  into  the
aquifer at an appropriate point. The
inoculant  is distributed  vertically
throughout the zone of contamina-
tion. An intermittent air or oxygen
injection manifold system installed
throughout the biobarrier ensures
that sufficient  dissolved  oxygen is
present in the seeded treatment zone
to  sustain MTBE biodegradation.
Bioaugmenting source zones contain-
ing residual-phase  gasoline  with
high-activity cultures has also been
shown to  reduce the "growth" of
MTBE plumes and lower the "bounce
back"  effect  when remaining non-
  JnJhe O2 and biobarrier plot, MTBE
  Declined in thejjteeded zone soon
   _aysr_ifnplantation of the BC-4
   : culture and was nondetectable
  ~/<1 ug/L) in shallow wells after 260
   fdays. TBA levels also declined
   JS.£- „—   —'f  t 1*V** *=       -* *T  -*t
  Ifie/oiv detectable levels (<10 ug/L)
  iLtC^, "H
      in the bioaugmented plot.
aqueous-phase liquid (NAPL) "feeds"
the plume.

The Port Hueneme
The first field demonstration of a bio-
barrier seeded with a high-activity
culture occurred in June 1999 at the
U.S. Naval  Construction Battalion
Center in Port Hueneme,  California.
Analysis of monitoring wells at the
base indicates that the MTBE plume
has traveled over 4,500 feet and is 400
feet wide. Although 75 percent of the
soluble plume is only MTBE, much of
the BTEX constituents have been
    The surficial aquifer is approxi-
mately 10 to 20 feet below the ground
surface,  and  the  apparent  the
groundwater velocities vary from 0.1
to 0.3 foot per day. Our test was
located midway down the advancing
MTBE plume and contained ether
concentrations from 2,000 to 8,000
^jg/L and dissolved oxygen (DO) lev-
els of less than or equal to 1 mg/L.
    We designed three test plots con-
sisting of: (1) O2 only, (2) O2 + BC-4
(MTBE-degrading culture)  seeded
biobarrier, and (3) a control, with no
treatment. Plot dimensions were 20
feet wide by 40 feet long, and moni-
toring wells were installed at differ-
ent depths throughout each test cell.
The oxygen delivery system in the O2
only and O2 + BC-4 plots  were simi-
lar and consisted of an O2-generating
system  and injection  wells that
sparged O2 intermittently. DO levels
increased in the sparged zones up to
5 to 20 mg/L. Groundwater samples
were taken before and during the 11-
month experiment for MTBE and
TBA levels and bioactivity.
    In shallow wells in the control
plot, DO was less than or equal to 1
mg/L and MTBE concentrations var-
ied from 800 to 8,000 >ig/L through-
out the 330-day experimental period.
In the O2 only plot, MTBE levels var-
ied from 500 to 7,000 ,wg/L and DO
was 5 to 20 mg/L for 185 days. After
260 days, the MTBE declined in this
plot to Wug/L.
    Initial bioactivity determinations
on samples of groundwater before
the start of the  experimental plots
indicated  that  low numbers  of
MTBE-degraders were present at the
site. The decline in MTBE in the O2
only cell, therefore, suggests that the
degraders that are present require O2
and a long adaptation period to initi-
ate metabolism  of the ether. Also,
TBA,  which was present in the
groundwater (50-250 ^tg/L), was not
degraded in the  O2 only plot. In the
O2  and  biobarrier  plot, MTBE
declined in the  seeded zone soon
after implantation of the BC-4 culture
and was nondetectable (< 1 /fg/L) in
shallow wells after 260 days. TBA
levels also declined below detectable
levels (< 10 ?ig/L) in the bioaug-
mented plot.

The Good News Is...
Our results when implementing an in
situ oxygenated biobarrier  in  an
aquifer to  control migration of an
advancing MTBE plume demonstrate
that MTBE can be degraded to below
drinking water standards (e.g., 5 /ig/L
in California) and without the accu-
mulation of TBA. The seeded biobar-
rier at Port Hueneme has been stable
and active for at least a year of opera-
tion. The bioaugmentation of aquifer
sediments with these highly special-
ized cultures appears to be a more
cost-effective method than traditional
"pump and treat" engineered systems
for controlling the migration of MTBE
plumes. Our seeded biobarrier tech-
nology  is  currently  being imple-
mented at several retail UST sites in
the United States. Because of our high
initial success, we intend  to assist
other companies and governmental
agencies  in remediating MTBE and
other oxygenates  early in 2000. •

    Joseph Salonitro is a Senior Staff
  Research Microbiologist at Equilon
   Enterprises and Paid Johnson is an
  Associate Professor in the Civil arid
  Environmental Engineering Dept. at
   Arizona St. University. For more
  information, contact Joe at jpsalani-
  tro@equilon.com or (281) 544-7552.

LUSTtine Bulletin 33
Explosion  Ruptures Two  Tanks During Video
Inspection at St. Louis  Service  Station
by Mark Lenox

   It was just before lunch. The ser-
   vice technician was sitting in his
   truck completing a video inspec-
tion of an underground storage tank
when the tank exploded. The camera
was blown out of the tank and one
end of the tank being inspected blew
off. The impact of  the explosion
caused the adjacent tank that had not
been emptied of product to rupture,
releasing around 3,000 gallons of
gasoline. The good news is that no
one was hurt.
   This event happened at a St.
Louis Shell station earlier this sum-
mer. The owner was preparing his
fiberglass tanks for a switch to refor-
mulated gasoline (RFC). Because he
was switching to an alcohol blend,
the tanks  needed to be upgraded,
inasmuch  as they were purchased
and installed years before there was
an approved alcohol-compatible list-
ing. The process required the tanks to
be cleaned. After cleaning, the tanks
were to be inspected visually by low-
ering a video camera down the fill
   The tank was one of three that
was being inspected by Tanknology,
Inc. It had been emptied of product
and then pressure-washed by lower-
ing a special nozzle down through
several tank risers,  such as the fill
port. After a preliminary inspection
with the video camera, the technician
determined that more cleaning was
necessary. The tank was further
washed and cleaned. Once the clean-
ing material was pumped out, the
camera was lowered back into the
tank; shortly thereafter the explosion
   Because gasoline was released to
the subsurface as a result of the tank
rupture, emergency response was
initiated. Due to the company's quick
response, most of the gasoline was
pumped out of the tank backfill area
before it had a chance to spread any

Why the Video Inspection?
The video inspection was conducted
to ensure that the tank was in condi-
tion  to  contain a
new  reformulated
gasoline containing
ethanol. Reformu-
lated gasoline (RFC)
is a formulation of
gas used to reduce
volatile    organic
compounds (VOCs).
RFG  requires the
use of oxygenates
such as ethanol or
MTBE, and it has a
lower benzene con-
tent than non-RFG
gasoline. As of June
1,1999, the alcohol
blend of RFG has
been  required in
the St. Louis area.
   When  switch-
ing to an alcohol
blend for the first
time, all water and
precipitated mater-
ial    must   be
removed from the
tank because of alcohol's propensity
to soak up any water in the tank. If
enough water is present in the water
bottom of a tank, the alcohol will sep-
arate from  the gas,  mix with  the
water, and settle to the bottom of the
tank, where it could get pumped into

  When switching to an alcohol blend
I   for the first time, all water and
    precipitated material must be
   removed from the tank because of
\  alcohol's propensity to soak up any
\ water in the tank. If enough water is

     _„                       i
  tank, the alcohol will separate from
   the gas, mix with the water, and
    settleto^the^bottomjoftjie tank^
   """""BE?1'**" """""* *•"*• "
mitt I wittlHIHlSl JiJii^ iJSiiiiFfts S ilLtaifc titeSf Wi
f **• where it could get pumpeff into
somebody's car. Cars run well on
gasohol, but they choke on this alco-
hol/water cocktail.

Why the Explosion?
The precise ignition source of the
explosion is as yet unknown. When
using a camera to inspect a tank, a
few important safety steps are typi-
cally taken. First, after the tank is
pumped  out and,  if necessary,
cleaned, the tank, camera, and truck
are grounded to discharge any static
electricity  that has built up. The
inside of the tank is then inerted to
displace oxygen with carbon dioxide.
   To ensure that the atmosphere is
inert, or noncombustible, the oxygen
level is checked using a meter that is
not affected by the high levels of car-
bon dioxide that are present. Read-
ings should be taken at the bottom,
middle, and top of the tank at both
ends and the middle of the tank. This
safety check is done several times
during the inspection. The grounding
connection should be in place during
             • continued on page 11

                                                                                         LUSTLine Bulletin 33
   from Robert N. Renkes, Executive Vice President, Petroleum Equipment Institute
    Why Many of Today's  UST Systems Are Not Leak-Proof
        The plan of action recommended to EPA and
        Congress by the Blue Ribbon Panel on Oxy-
        genates (see cover article) regarding the use of
   MTBE in gasoline involves a four-part strategy. One
   part of the strategy is to develop a comprehensive set
   of programs to enhance water protection. One specific
   recommendation in this regard is to "evaluate the
   field performance of current system design require-
   ments and technology and, based on that evaluation,
   improve system requirements to minimize  leaks/
   releases, particularly in vulnerable areas."
      Some say that the industry has done everything
   possible to minimize leaks. But the truth is that leaks
   and releases still happen—even to systems upgraded
   to 1998 standards. How are those upgraded UST sys-
   tems performing, and what can be done in the future
   to improve the systems that contain regulated sub-
      These issues were some of the subjects discussed
   at a recent focus group meeting convened by EPA and
   attended by members of the Petroleum Equipment
   Institute. The group was in complete agreement that
   UST systems in the ground today represent a vast
   improvement over the UST systems in use in the
   1980s. Nevertheless, the group was in substantial
   accord in the belief that many of the systems in opera-
   tion today are not leak-proof.
      The  group  pinpointed  four major causes  of
   releases and identified steps that can be taken to pre-
   vent such releases in the future:

   • Pressurized  piping systems are probably the
     biggest contributor (in terms of the number of gal-
                     lons lost) to the problems we have today.
                     Recommendation: Secondarily contain and peri-
                     odically test tanks and piping.

                   • Meter seals fail, impact valves wear out, unions
                     leak, and product spills when filters are changed
                     and meters are replaced.
                     Recommendation: Provide containment under
                     product dispensers.

                   • Releases occur at the turbine during servicing and,
                     over time, as a result of normal wear and tear.
                     Leaks from submerged turbines are often not dis-
                     covered until it's too late, because they are buried
                     and not subject to routine inspection.
                     Recommendation: Provide containment at the
                     submerged turbine.

                   • Proper  operation and maintenance of the UST sys-
                     tem are essential. Unfortunately, many tank own-
                     ers lapse into an "out of sight, out of mind" tank
                     management pattern, because they believe that the
                     hardware  installed over the last decade will take
                     care of all their problems.
                     Recommendation: Inspect the UST system period-
                     ically for compliance.

                      These conclusions and recommendations should
                   not come as a surprise to tank owners or UST regula-
                   tors. In fact, my sense is that at least the first three of
                   the recommendations listed are already incorporated
                   into the lion's share of UST systems installed today.
  I Explosion from page 10
the inerting procedure (and through-
out the entire inspection) in the event
of a static  charge buildup. Once
everything checks out,  the  visual
inspection can begin.
   A number of factors may have
been at work at this site to cause the
explosion. The visual inspection had
been interrupted for additional clean-
ing, and the tank's oxygen levels may
not have been checked again before
the second inspection. In this case,
gasoline vapors  and oxygen levels
could have reaccumulated inside the
tank, creating an explosive environ-
ment. The  vapor recovery  system
could also  have been a source of
vapors or oxygen. In either case, the
introduction of the camera and its
lighting system could have provided
the ignition source needed to set off
the explosion.
   According  to  Pudgie  Fewox,
DOT Safety Fleet Manager for Tank-
nology, the company has taken addi-
tional steps to tighten up its safety
procedures.   A  camera   is  now
installed at  the inspection site to
record the preliminary phase of the
inspection. This way, both the com-
pany and the client have a record of
the technician grounding  all equip-
ment, inerting the tank, and taking
oxygen concentration readings. Fur-
thermore, the  tank environment is
now   monitored    continuously
through electronic controls so that
any time the internal environment
exceeds predetermined safety levels,
the entire camera system automati-
cally shuts off. The inspection cannot
proceed until the tank environment is
again below safe limits.
   Even with the best safety proce-
dures in place, accidents can happen.
Ensuring that proper procedures are
followed consistently, however, can
greatly reduce the likelihood of such
accidents. •
   Mark Lenox is an Environmental
 Engineer with the Tanks Section of the
   Missouri Department of Natural
 Resources' Hazardous Waste Program.

LUSTLim Bulletin 33
                         nically Speaking
                         by Marcel Moreau
                                  "recogfiizeei petroleum storage "specialist
                                \_ whose column, Tarik-nically Speaking,
                                }'  is a regular feature o/LUSTLine. As   ",
                                * always, we welcome your comments and .
                                '-questions. If there are technical issues that:
                                  you would like to have Marcel discuss,
                                I           let us know.
Enough with the Walking Softly,

It's Time to Get  Out  the  Stick!
      The Federal UST program is now a full decade old—a number of state UST programs are
      even older. Yet an almost universal complaint from tank inspectors seems to be that com-
      pliance with UST operational requirements, specifically leak detection, is far less than
satisfactory. Historically, most, if not all, states (let me know if you're the exceptional state) have
focused on educating their UST owners and operators rather than hammering them. Some, I   ..
know, are restricted to an educational role by the local political climate. In most states, an out-
numbered regulatory staff tries to educate and reeducate an ever-changing and generally  ,
complacent tank-owning population. So the leaks go on, and while statistics are sparse, the
few data available indicate that the success rate in detecting releases is abysmal. As any
teacher or parent knows, gentle persuasion will take you only so far. There comes a time when it
is necessary to lay down the law.
Many Are Law Abiding, But
Few Are Saints
I consider myself to be a law-abiding
citizen. I also know that I am not a
candidate for sainthood.  Consider
this true story. Until I moved into a
home office last December, I had a
small office in downtown Portland,
Maine. I usually rode my bike to get
to the office, but there were days
when it was raining or snowing  or
when I was carting equipment when
I would take my car. My options for
parking  the  car  downtown were
either a parking garage that was a
short hike from the office ($l/hour)
or a curbside parking meter that was
typically a stone's throw away from
the office (50 cents/hour, two hour
limit). The parking meters were my
first choice when they were available.
    Initially,  I  put  money  in the
meter religiously. However, I often
got engrossed in my work and forgot
to add money after the meter ran out.
I also routinely exceeded the two
hour limit. But guess what? No park-
ing tickets appeared on my wind-
shield. Over time, I became more
bold in my transgression of the rules.
Before too long, I quit putting any
money in the meter. I found that on
most days I could park conveniently
the whole day for free. Once in a
great while, I would get a ticket, but
it was a mere five bucks. I didn't
need to do much calculating to figure
out that paying the occasional park-
ing ticket was more convenient and
much cheaper than any other alterna-
    What would you have  done? I
rationalized my behavior by saying
that I was still following the rules: I
paid the fine when it was levied.
    I was clearly not the only person
who had figured this point out. Port-
land merchants had long-standing
complaints about office workers who
parked all day in front of their stores
and prevented customers from find-
ing convenient parking. The  city
finally listened  and  decided  to
enforce the parking regulations. They
hired some meter attendants  and
raised the cost of the parking ticket to
    I learned about this change the
hard'way. Under the new system, I
got a ticket every single time I parked
without paying.  I started putting
money in the meter, but whenever I
was even  a few minutes late—
Darn!—another ticket. I then noticed
that nearly every time I looked out
my office window, there was a meter
attendant writing a ticket. I marveled
at how efficient he was.
He could put a ticket on a car in
about 15 seconds.
   I knew right then that my days of
hassle-free parking were over. Pretty
soon, the light dawned that the eco-
nomics had changed. The parking
garage was starting to look pretty
good. The thought  of ignoring the
tickets crossed my mind, until one
day I looked down  Congress Street
and saw a long string of bright yellow
boots on cars' front  wheels. I didn't
know how much it cost to get the boot
off, but I knew it wasn't cheap, and I
knew I'd have to pay my back tickets
and late payment fees as well.
   So my behavior changed. If I was
going to be at the office only a short
while, I'd park at a meter (they were
much easier to find now!). If I was
going to be more than two hours, I'd
park in the garage (it was much fuller
now!) and trek to the office.
   The moral of the story is that it is
very hard to be a saint. Law-abiding
citizens abide by laws that have con-
sequences for noncompliance.

Never Judge Another Until
You Have Walked a Mile in
His  Moccasins
Now put yourself behind the desk of
a tank owner. When was the last time

                                                                                          LUSTLine Bulletin 33




 you received anything but a friendly
 notice with lots of information that
 you don't have time to read from
 your UST regulator? When was the
 last time any regulator looked at your
 records or your equipment? When
 was the last time you paid a fine for
 noncompliance with tank rules?
    Chances are that your state has a
 tank fund that will pay a large chunk
 of your cleanup costs,  and you've
 heard through the grapevine that you
 don't even have to be very much in
 compliance to be eligible for the
 cleanup money. The  leak alarm on
 the wall is flashing, but the last  10
 times it's gone off it was because
 there was water in the sump, and
 you're tired of paying big bucks to
 have a contractor deal  with it. You
 just paid over $100,000 for new stor-
 age systems, so they can't be leaking.
    Meanwhile you've just  fired
 another employee for stealing and
 now you're short-handed; your com-
 petition is building new  stores across
 the street from several  of your best
 locations; your freezer just quit, and
 you've got 50 gallons of ice cream sit-
 ting in there melting; your new inte-
 grated data management system is
 crashing every other day, so you
 can't keep track of anything; and a
 customer is suing you for everything
 you've got, because a nozzle failed to
 shut off while she was topping off
 her tank and she got gas on her foot
 and she claims the MTBE in the gas
 has caused a severe reaction that pre-
         vents her from working,
         which has precipitated a
         nasty  divorce and  may
         lead to surgery to remove
         an obscene growth on her
         middle toe.
           Is it really any wonder
         that leak detection is so
         often ignored?

         The Status Quo
         Convenience  store  loss
         prevention specialists say
         that the primary deterrent
         to employee theft is know-
         ing that you are going to
         get  caught and pay the
         consequences.  I suspect
         that the same holds true
         for UST compliance. Most
         UST owners and operators
         today  simply  do  not
         believe that they will be
         "caught," and for the most
part, they are right. So how do  we
convince UST operators that they are
going to get "caught"?
                    WMosfiJSf owners and operators
                    |i»-,*„.*.    j- .   ,
                   Joday simply do not believe that they
                           "caught," and for the most
                        \, they are right So how do we
                   Convince UST operators that they are
                   p__  going to get "caught"?
                      First, let's look at the status quo.
                  How do we catch UST rule violators?
                  In most cases, it involves a personal
                  visit from an UST inspector. The
                  inspection requires some  driving
                  time, a chunk of time inspecting
                  hardware, a chunk of time trying to
                  find records, and a big chunk of time
                  trying to explain to some presumably
                  responsible person exactly what he or
                  she is supposed to be doing.
                      Unless there  is a  field citation
                  program in place, the  odds of any
                  kind of a financial penalty  being
                  levied are pretty remote. The process
                  is time-consuming and inefficient,
                  and it has little long-term effect on
                  the behavior of  the tank owner  or
                      For this process to work, you
                  need a tremendous long-term finan-
                  cial investment in the regulatory pro-
                  gram. The State of Florida has made
such a commitment. Its inspection
program began in earnest in 1987,
and by 1990, had reached the point
where every UST facility in the state
was visited every year. Compliance
levels, which were initially about 3
percent,  have climbed slowly but
steadily. Today the "complete" com-
pliance level  (every "i" dotted and
"t" crossed) is around 85 percent,
with   "substantial"   compliance
(minor omissions, generally involv-
ing paperwork) levels running at 93
   This  achievement requires an
inspection force of about  150 con-
tracted county inspectors and 30 state
Department of Environmental Pro-
tection   inspectors  (who  inspect
county-owned facilities), who are
currently dealing with a tank popula-
tion of 35,000 active USTs. Eighty-
five thousand USTs have been closed
and not replaced since the program
began. Aboveground tanks are also
inspected annually.
    Since the inception of the pro-
gram,  nearly 300,000 inspections
have been completed. This effort
requires  an annual financial  invest-
ment of about $8 million. 'Marshall
Mott-Smith, director of the Florida
Tank Program,  says he hopes  to
increase  funding in the future  to
improve the quality and consistency
of the inspections.
    Mott-Smith notes that about 50
percent of all tanks in the state cur-
rently have secondary containment,
so many of these inspections  are less
time-consuming. With  secondary
containment, inventory records don't
have to be checked and release detec-
tion is much simpler.
    Based on Florida's experience,
then, if you're planning to achieve
compliance with the traditional phys-
ical inspection route, plan on a 10-
year effort at a cost of about $225 per
tank per year.
    So how does your program com-
pare? Let's do a survey. Send me an
e-mail with the  following informa-
• The number  of active USTs in
   your state
• The number of dollars you have to
   spend on UST compliance
• The number  of inspectors you

              • continued on page 14

LUSTLine Bulletin 33
• Tank-nically Speaking from page 13

• At your current level of inspection
   activity, how often you expect to
   visit each UST facility (annually,
   three years, five years, etc.)
Send the  information to marcel.
moreau@juno.com. Results of the
survey will appear in the next issue
of LUSTLine. I'm thinking your fig-
ures could help make the case for
how woefully underfunded the UST
program is on a national scale.

Beyond Status Quo
What are some alternatives? A few
states (e.g., Pennsylvania and Alaska)
have gone the route of third-party
inspectors. In this approach, private-
sector individuals are authorized to
conduct regulatory inspections and
report back to the regulatory agency.
This tactic shifts the cost of the
inspection to  the  private  sector,
because the tank owner now pays for
tlie inspection. Enforcement remains
the domain of the regulator, so fol-
lowing up on violations is still the
responsibility  of the   regulatory
agency. I believe this approach is
viable, but there needs to be careful
monitoring of inspector activities
(these people are not saints either)
and significant effort expended to
ensure consistency among inspectors.

A New Inspection Paradigm
Another  approach that I believe
holds some promise, though I  don't
know mat it has ever been tried, is to
change the inspection paradigm. In
my experience, UST violations today
stem primarily from recordkeeping.
ATGs on the wall and line leak detec-
tors on the submersible pumps are
commonplace.   Although  many
inspectors get in a dither wondering
whether the ATG is working on the
day of the inspection or whether the
operator knows how to run the ATG,
these issues are really of little rele-
vance  to  bottom-line compliance,
because these things are not regula-
tory requirements.
    The regulatory requirement is
that leak detection results for each
month must be on hand for the last
12 months. If the ATG is lying in
pieces on the floor on the day of the
inspection, but there are  12 months
worth of  passing test results, the
facility is in compliance. If the ATG is
working perfectly, and the operator
knows everything about it, but 12
months worth of test results cannot
be produced, the  facility is not in
    It is not the inspector's job to
teach people about ATGs or  any
other piece of UST hardware—it is
the equipment vendor's job. Because,
in most cases,  the  leak  detection
records are not kept at the UST facil-
ity, chasing down missing records is
an activity that is typically triggered
by an inspection; the records are
mailed or faxed to the inspector a few
days later.
    Here is my question: Is the on-
site visit really necessary? Why can't
an inspection consist simply of a cer-
tified mail request to produce paper-
work records of leak detection  and
maintenance? Failure to produce the
records within a specified time frame
becomes an automatic violation. If
inspection of the records reveals
other irregularities, such as missing
test results for a particular month or
failure to reconcile inventory, then
these violations  could be listed  in a
 "fiiT^eMyantage of the strictly paper
flMfspecfiofl is that I could probably
IJvjipfci^^             ," i*11-1:1-*, i-i'i-ys'iT'in ".•:"':. r •wwxri.vi11 -' it"!
   foni/tfcf 70 //mes ~asmariy6tfSese"
   S;';';':;;:	i1:!;""1;;;11!1;;,11,":11;1 j'1; 7,	n r yh|1l1;";iii;iv'j-"r; ;r':,'"/":, .''
                   ^' 'particularly^'
   out mailings and cataloging and
*.• reviewing the incoming paperwork.
notice of violation or an assessment
of a small fine (using something like
a consent agreement rather than full-
blown enforcement procedures), and,
of course,  educational materials
would be sent out out to the violator.
   I'll bet that more attention will be
paid  to the educational materials
when they arrive by certified mail
and are accompanied by a notice of
violation and a monetary penalty
than when they are handed over, in
person, by a smiling inspector, who
takes her leave saying that she hopes
to see improvement the next time she
The Blessings of the Paper
The advantage of the strictly paper
inspection is that I could probably
conduct 10 times as many of these
inspections in a month than I could
physical  inspections, particularly
once I have developed some semiau-
tomated process for sending  out
mailings and cataloging and review-
ing the incoming paperwork.
    Sure, I might miss a few things
(do you really think you catch every-
thing during an on-site inspection?),
but overall I could make my presence
felt more widely using this approach
than by driving my body all over the
state and talking to people who have
a thousand things they'd rather be
doing  than listening to  me. More
importantly, the regulated commu-
nity would come to learn that some-
one is  watching what they do  and
there are penalties (small ones, to be
sure)  to  pay  for  ignoring  UST
    Consider  this  point.  As  the
owner of a small business, I must file
an inordinate amount of paper (and
money) by very definite dates to an
abundance of state and federal agen-
cies. Over the years, I may have occa-
sionally missed a date by a few days
or a week. I have been impressed by
the fact that I inevitably receive a lit-
tle notice from whatever agency that
was supposed to receive something
and that sometimes I must pay a late
fee. Now my violations are small, as
are the penalties. But as I am writing
the check, I think, "Boy, I'd better not
try to pull anything over on these
guys because they are keeping pretty
close tabs on what I do."
    A variation on this paper inspec-
tion paradigm could be used for
those multiple-facility tank owners
who maintain  centralized records.
Rather than  traveling to facilities,
simply travel to the central office and
go through all  the records without
bothering to visit the facilities them-
selves. Cite the owner for all missing
records. I'll bet you could inspect
dozens of facilities a day in this way.
    Scofflaws who submit no records
or very poor records could be  tar-
geted for a repeat request for docu-
ments  in  a few months.  Lists of
names  of  facilities whose owners
have  failed  to submit  adequate
              • continued on page 16

                                                                                   LUSTLine Bulletin 33
 Leak Prevention
Anyone for Reevaluating Our  Leak
Detection  Method Protocols?
Results of a Third-Party Evaluation Test
Protocol Survey
by Shahla Dargahi Farahnak

    For many years, I have been
    reviewing leak detection equip-
    ment third-party certification
reports for the State of California and
also as a member of the National
Work Group on Leak Detection Eval-
uations. These reviews involve com-
paring  third-party  certification
reports with procedures described in
the applicable standard U.S. EPA test
protocol or the new and/or modified
ones. Over the years, new or modi-
fied test protocols have been devel-
oped in response to advances in leak
detection technology and broader
applications of some leak detection
methods and equipment.
   Through the experience gained
by reviewing these evaluations and
the  technical principles on which
these methods are developed, I and
the members of the work group occa-
sionally come across issues that have
not been adequately addressed in the
original (more than nine years old)
EPA protocols. At  times, we also
wonder about the adequacy and the
level of peer review for some of the
new and modified protocols. For
these reasons, we decided to reach
out and find out what the other state
regulators think about these test pro-
   My area of emphasis in the UST
program has been leak detection.  I
have worked on a few research pro-
jects involving the use of leak detec-
tion and its effectiveness in detecting
leaks once installed or implemented
in the field. To me, it seemed apropos
to expand the horizon and take a look
at the leak detection evaluation pro-
tocols by conducting a survey. My
goal was to present the results of the
survey to the work group members
so that we use this information to
identify some of the areas we need to
focus on for future activities and to
help EPA identify future project pri-
   At the March 1999 UST/LUST
conference and subsequent to that via
broadcast Internet mail, I distributed
a survey form to all states. A total of
23 responded to the survey. Consid-
ering that many of the states may not
have staff who are very familiar with
the leak detection evaluation proto-
cols, this is a good response rate, and
I thank the states that took the time to
participate in this survey.
   In the survey, the respondents
were asked to list acceptable leak
detection methods in their state for
both  single-walled and double-
walled tank and piping and to iden-
tify the three most common leak
detection methods for tank and pip-
ing systems. Most of  the states
responding to the survey stated that
they follow federal regulations for
acceptable methods of tank and pip-
ing leak detection. That means, in
these  states, single-walled system
leak detection methods, such as auto-
matic tank gauges and statistical
inventory reconciliation, are allowed
for double-walled tanks. Only a few
states require continuous interstitial
monitoring for double-walled sys-
tems. The following two tables sum-
marize the frequency with which the
most common leak detection meth-
ods for tanks and piping were listed
by the respondents:

IfoLWiQnitoring Methods for Tanks
g|^s- In Order of Frequency
Automatic Tank Gauge
SIR (monthly)
Tightness Testing
Inventory Control
SIR (annual)
Pmitoring Methods for Piping
1 _ ! of Frequency
in Order
Method States
Tightness Testing
Sump Monitoring
Electronic Line Leak Detector
SIR (monthly)
Mechanical Line Leak Detector
Safe Suction
Automatic Tank Gauge
Inventory Control
SIR (annual)
   The respondents were also asked
to list and rank the evaluation proto-
cols of concern and, for each one, to
list the items of concern. Three of the
respondents stated that they were not
familiar with the protocols, and three
others  stated that  they  had  no
concerns. For  the  remaining  14
responses, the protocols listed and
the number of times they were men-
tioned are summarized as follows:
pi-test Protocols # bfYinies Listed"
Statistical Inventory Reconciliation
Liquid-Phase Out-of-Tank
Continuous In-Tank Leak Detection
Volumetric Tank Tightness Test
Nonvolumetric Tank Tightness Test
Automatic Tank Gauge
Vapor-Phase Out-of-Tank
Pipeline Leak Detection
The following is the list of respon-
dent concerns (not edited) for each
evaluation protocol.  As you  will
notice, some are related to field appli-
cation  and  limitations and  not
directly to the evaluation the test pro-

             • continued on page 16

 • Protocol Survey from page 15
Comments and Concerns by
Automatic Tank Gauging Systems
•  Range for threshold varies too greatly
   between vendors
•  Effect of the level of ground-water on
   the test performed
•  ATGs rarely test the full capacity of
   the tank, having to show only one
   passing  test per  month  without
   requiring a level of 90% full or better
Continuous In-Tank Leak Detection
   Field verification
   Throughput limitation as a function of
   tank size
   Embedded SIR
   Using created quiet-time data
   Modifications to existing systems—
   need standardized method of updat-
   ing certification
Liquid-Phase Out-of-Tank and
Interstitial Product Detectors
•  When groundwater is not in contact
   with the tank,  the amount of time
   between the initial release and this
   method's ability to detect it is too great
•  No protection
•  Capability not stringent
•  Should be eliminated as a leak detec-
   tion method
Nonvolumetric Tank Tightness
Testing Methods
•  Most do not specify the level of the
   product in the tank
•  Do not specify how they check for
   groundwater and  pressure on the
   tank from the outside
   Water ingress measurement
   Evaluation of acoustic systems
 'Ipeline Leak Detection Systems
   Number of tests and test facilities
   Reuse of data
Statistical Inventory Reconciliation
   High throughput
   Manifolded tanks
   Stand-alone and hybrid SIR
   Pipeline LD. Does SIR 0.2 gph equal
   0.2 gph pipeline test? Test times differ.
   Bogus leak threshold
   Numbers provided by the vendor for
   third-party evaluation do not test the
   system adequately
   Improvement needed in all areas
   Movable threshold
   Set threshold value
   Clarify substitution of data (e.g., using
   last two months of data to fill out this
   Clarify use of ATG to gather data
•  Nonvolumetric (qualitative?) is not
•  Reporting is not adequate on 0.2 gph
•  Error ID needed
•  Vendor's data manipulated
•  Standards for qualifying report-outs
•  Groundwater effects
•  Automated improvements
•  Vendors seem reluctant to fail data
•  Adjustment for "outliers"
•  Real-world leak data vs. simulated
•  Better  defined data  sets with "real
   data and operational noise"
•  Systems can pass current protocol, but
   may not perform in the field
•  Size limits and number of tanks deter-
   mined by evaluator
•  Control over the reuse of data
•  Reliability of data
•  Amount of data needed
•  Statistical method for the calculation
   of pass/fail
Vapor-Phase Out-of-Tank Detectors
•  Should be eliminated as a leak detec-
   tion method
•  Sensitivity
Volumetric Tank Tightness Testing
•  Does or doesn't it test suction lines?
•  Application to system test

It's Time to Review the
With the present concerns about the
release of oxygenated fuels to the
environment, now is a good time for
EPA to initiate efforts to have proto-
col documents reviewed and revised.
We also need a formal process for the
extensive review of new and modi-
fied protocols. The extent  to which
each leak detection method is used
and the significance and relevance of
the listed concerns about its perfor-
mance could be used to help set pri-
   In my mind, at least, one ques-
tion   still   remains   unanswered.
Would this effort help improve per-
formance of leak detection? Maybe
yes, maybe not! One thing that is evi-
dent, however, is that more realistic
and stringent evaluation protocols
may help  weed out  some  poorly
designed systems. But definitely,
there is more to making leak detec-
tion work than just enhancing the
evaluation protocols. •

   Shahla Dargahi Farahnak, P.E., is
   Senior Engineer with the California
  State Water Resources Control Board.
   For more information about this
       survey, contact Shahla at
• Tank-nically Speaking from page 14

records could be published in local
newspapers. Recalcitrant individuals
could be targeted for EPA inspec-
tions where field citation authority
could be used to get their attention.
Eventually, UST owners would get
the idea that someone is indeed
watching what they do and they had
better not try to get away with too
    Perhaps   some   UST  owners
would see the wisdom of farming out
their compliance activities to knowl-
edgeable firms whose primary busi-
ness  is  keeping  customers   in
compliance with UST requirements.
Because of problems with employee
turnover, trying to manage multiple
facilities, and the multitude of other
activities typically associated with
running today's fueling facilities, I
believe  that third-party monitoring
of USTs is the long-term future of
UST management. For third-party
management to become cost-effective
to the UST owner, however, noncom-
pliance  must become more costly
than it currently is.

Better, Faster, Cheaper
The LUST  people long ago learned
the  mantra  of  "better,  faster,
cheaper" cleanups. While the LUST
challenge   remains   formidable,
remarkable progress has been made.
Now it's time for the UST side of the
program to learn the  same mantra
and apply it to enforcement.
    We  have made great strides in
reducing the environmental threats
from USTs in the last decade. But to
achieve the full  environmental pro-
tection  potential  of the  program,
operational compliance levels must
be improved dramatically. Walking
softly with an armful of educational
materials is not going to do it.  It's
time to  get out the stick and figure
out how to slap as many wrists as
possible as  efficiently as possible. If s
either that,  or figure out how to con-
vert tank owners and operators into
saints. •

As always, your thoughts on this issue
are welcome.

                                                                                         LUSTLine Bulletin 33
Where Has Our  Petroleum Storage Capacity
Gone?                     „,  -U/4-r^U,	-^   .   _               i                I
 by Wayne Geyer

      Tracking the success or failure
      of the federal underground
      storage tank program is a dif-
 ficult task. One of the most telling
 statistics publicly available is the
 number of storage tanks in the feder-
 ally  regulated  tank universe  that
 remain in service.  When the  U.S.
 Environmental Protection Agency
 (EPA) began its program, an  esti-
 mated 2 million federally regulated
 tanks existed. According to a recent
 survey sponsored by the Petroleum
 Equipment Institute,  only about
 750,000 tanks remain—a 62.5 percent
 decrease in the number of tank units.
 These figures suggest that  five of
 every eight tanks in existence in 1988
 are no longer in service.
    Environmentalists might say that
 the program is an overwhelming suc-
 cess—over half of the potential leak-
 ing tank systems have been  erased.
 An    equipment   manufacturer,
 installer,  or petroleum storage sys-
 tem user might have other thoughts.
 After all, fewer tanks means less busi-
 ness for manufacturers and installers
 and less product availability for con-
 sumers. Or does it? Are we as a soci-
 ety inconvenienced because of this
 drastic reduction in regulated under-
 ground storage tank units?
    As I  travel down  the  federal
 highway system, my first impression
 is that the downsizing of our tank
 universe has had very little impact. I
 continue to see a tremendous number
 of motor vehicles on the road. For
 example, NPN reported that in the
 United States, motor vehicles were
 driven a total of 2.48 trillion miles in
 1996, an increase of 2.2 percent over
 the 1995 figures. According  to NPN
 Market Facts, an annual statistical
 guide of the petroleum industry,
 gasoline consumption has increased
 from 114.7 trillion gallons in 1988 to
 128.9 trillion gallons in 1998, a 12.7
 percent increase over the past 10
     According to NPN, however,  the
 number of retail service stations in
 the  United  States dropped  from
• 210,120 in 1991 to 182,596 in 1998, a

  13  percent decrease over the  past
  seven years. Despite this decrease, lit-
  tle media commentary has emerged
  regarding  public inconveniences,
  except perhaps in a few remote areas
  left without a nearby service station.
  In fact, as older facilities take their
  leave, new service stations continue
  to be built with better conveniences
  and in  more desirable  locations.
  Many fabricators tell me that a large
  percentage of their constructed tanks
  are being installed at new facilities.

  Can Less Be More?
  So, if vehicle miles traveled are way
  up, the tank universe is way down,
  and the public has not been terribly
  inconvenienced, what has happened
  to all of the previous storage  tank
  capacity? A number of theories have
  been put forth to explain this curios-
     Some say that much of the 1988
  regulated tank population was either
  not in use or  little used. Others
  hypothesize that oil companies and
  petroleum marketers today exercise
  greater control over the amount of
  product stored—a large inventory of
  product on hand is bad for the bot-
  tom  line.  Keep product moving,
  because if less product sits idle in a
  tank, fewer tanks are necessary.
     In December 1927, an industry
  report noted that 317,000 gas stations
  dispensed fuels. The report made the
  assumption that it took 15 minutes to
  dispense 5 gallons of gasoline, half
  the actual dispensing rate of that time
  period.  Furthermore,   with   the
  604,000 dispensers in existence then,
  the report  calculated that the nation
  could dispense five times its needs in
  an eight-hour day. The report con-
  cluded that a glut of tanks and ser-
  vice stations existed then.
     If we use that type of analysis, we
  can obtain a  further comparison
  between 1988 and 1998. Lefs assume
      1999 • 750,000 TANKS

that the average tank is operating 10
hours per day, 300 days per year, dis-
pensing fuel at a rate of 8 gallons per
minute (gpm), and storing gasoline.
Also, let's assume that 60 percent of
the regulated USTs in existence dur-
ing the past decade stored gasoline.
   With some sophisticated sixth-
grade mathematics, we can calculate
that the average tank dispensed gaso-
line 4.25 minutes out of every hour in
1988 and 12.75 minutes out of every
hour in 1998. That rate is nearly a 300
percent increase in tank usage. On
the other hand, the usage rate of 12.75
minutes dispensed out of every hour
today could also tell us that the tanks
are not yet fully utilized.
   Remember,  not every UST is
located at a retail service station, nor
does it store gasoline. So don't go to
Las Vegas with the assumptions and
calculations made above.  Some gas
stations pump 2 to 5 million gallons
of gasoline per year. As a matter of
fact, new stations are built today on
the premise that 1.2 million gallons of
gasoline  will be dispensed  annu-
ally—at a minimum.
   For comparison  purposes, 1.2
million gallons  dispensed annually
equates to a tank usage rate of 14.6
minutes out of every hour, assuming
3 gasoline tanks per service station,
365 days of operation for 10 hours
per day, and a fuel dispensed rate of
8 gpm. My main point here  is that
many of the unused or underutilized
tanks in place in 1988 are gone and
that the utilization rate of tanks has
    Blending fuel grades on-site, the
use of compartmented tanks, and the
shift to aboveground tanks are addi-
tional reasons why there  are fewer
tanks  installed  and used under-
ground today.
    But I have another fact to throw
into the mix. I checked out the Steel
             • continued on page 18

LUSTLine Bulletin 33
 • Storage Capacity from page 17
Tank Institute's (STI's) registration
database  and engaged  in some
undercover  detective  work.  STI
keeps detailed computer records on
every new steel underground and
aboveground storage tank that bears
the STI label.
    STI records indicate that over
1,000,000,000  gallons  of new  STI-
labeled underground  steel  storage
tank capacity was installed between
1988 and 1998. That's right, 1 billion
gallons!  This  time period  corre-
sponds \vith EPA's UST regulatory
compliance time frame.
    On further examination of the
most recent 10 years of data, we find
some startling trends. The average
STI-labeled UST tank capacity has
increased by over one-third, to nearly
8,000 gallons of capacity today. For
example, STI statistics for ACT-100
and  Permatank tank  technologies
show that the average tank capacity
is approximately  10,000  gallons,
more than a 20 percent increase dur-
ing a seven- to eight-year time frame.
    In the mid- to late 1980s, the typi-
cal sti-P3 tank capacity was around
5,500 gallons. The sti-P3 tank was the
only nationally standardized, corro-
sion-resistant  steel  tank available
back then. It provides preengineered
cathodic  protection  via galvanic
anodes of zinc or magnesium metal
attached to the tank.  In 1987 and
1988, more than 30,000 of these P3
tanks were built and installed each
year. Today, fewer than 25 percent of
that number of tank units are being
built with the P3 label. Other under-
ground steel storage tank technolo-
gies  that  do not use cathodic
protection, such as composite tanks
and  jacketed tanks, have displaced
some of the P3 tank installations.

Yes, It Can!
For hypothetical purposes, then, lef s
say that the average tank capacity in
the ground prior to 1989 was 4,000
gallons (20 percent less than the aver-
age  reflected  by  STI statistics to
accommodate the probability  that
older tanks were smaller). Two mil-
lion tanks multiplied by a 4,000-gal-
lon average tank capacity  yields a
total of 8 billion gallons of regulated
capacity at the start of the EPA pro-
gram. Lef s also say that the average
tank size in the ground today is 8,000
gallons. So, 750,000 tanks multiplied
by 8,000 gallons average tank capac-
ity yields 6 billion gallons of regu-
lated tank capacity, a 25 percent drop
in tank capacity over the past 10
    Thus, the  decline  in storage
capacity is much smaller than the
decline in tank numbers. This point
correlates well with our calculation of
average tank throughput—we are
selling more fuel from fewer tanks.
    While retail petroleum market-
ing is still predominantly conducted
using USTs, the same is not true for
nonretail storage. Many smaller fleet
fueling operations  and emergency
generator tank owners have turned
to ASTs.  Much of  the 25 percent
decline in UST storage capacity could
be accounted for aboveground if we
looked hard enough.
  Thus. the^decHnejn storage capacity
  [iS'smil ...... |||llrliB,li!!!!!iH!iill!"iii*iil' iriSnTWrilifWih'nilHSI'IB'ig-1'' "vn.rt- 1 sad ': '? if''",' lii'ilpj * r i y,. "H" MM fr '' S.^^hf'i** 'Mi' ' "-.H M

  s throughput—we are selling more
  RJf^f^SwBfrrjrsircTOHWTTO ;wb?r -^ ?;r --*
    Statistics  on   shop-fabricated
ASTs are difficult to collect because
of the far greater varieties of storage
tank types. So it is more difficult for
me to be absolute in reaching conclu-
sions  on  total storage  capacity.
Nonetheless, some trends are appar-
ent. For example, in 1998, STI's statis-
tics for double-walled F921 ASTs and
secondary-contained, protected Fire-
guard tanks indicated a 45 percent
growth in tank units built.
    Not surprisingly, an increase in
tank capacity is clearly evident here
as well. The Fireguard tank experi-
enced an 80 percent increase in aver-
age tank capacity over the past five
years—the average capacity today is
more than 4,000 gallons. STI mem-
bers are building ASTs to USTs at a
2:1 ratio, quite different from 10 years
ago, when USTs far outnumbered
    The trends associated with sec-
ondary containment of aboveground
storage tanks are indicative of those
associated with secondary contain-
ment of  all regulated shop-built
tanks. In 1988,  STI was registering
fewer than 18 percent of its tanks as
secondary-contained P3s. As a matter
of fact, 1984 was  the first year in
which significant numbers of double-
walled tanks were being built. Their
numbers  have easily  doubled in
recent  years. When accounting for
other types of steel-jacketed tanks
that do not bear  the STI  label,  it
appears that over 50 percent of the
steel USTs built today are secondary
    So  the bottom line is that, with-
out a doubt, the number of USTs has
declined since the UST regulations
were promulgated. However, more
product than ever is flowing through
the remaining storage tank systems—
through larger tanks and in tanks
located both under and above the
ground. •

  Wayne Geyer is Executive Director of
       the Steel Tank Institute.
 • Santa Clara Study from page 7

 system. Depth to water and lithol-
 ogy were apparently not significant
 factors in contamination of ground-
 water by MTBE at the study sites.
    The SCVWD conducted a good,
 well-documented study, but, as
 such, it leaves us with a number of
 unanswered questions: Where are
 the MTBE releases coming from at
 these  sites?  Why   weren't   the
 releases detected prior to the study?
 Is current release detection technol-
 ogy adequate for protecting ground-
 water from MTBE leaks? Are MTBE
 vapor releases a significant  source
 of contamination in  groundwater?
 For  the SCVWD to adequately
 assess  the  vulnerability   of  its
 groundwater resources to releases
 of MTBE (and for all of us to better
 understand the nature of the beast),
 additional research  is  definitely
 needed to address these questions.
    The  complete study can be
 accessed on  Santa  Clara  Valley
 Water  District's  Website:  http:
 www.scvwd.dst.ca.us / wtrqual / fact
 mtbe.htm. •

  Ron Kern is Manager of the UST &
  Program Support Section at the Ari-
  zona Department of Environmental

                                                                                        LUSTLine Bulletin 33
      rom  the  ASTSWMO Tanks Subcommittee
Coast to Coast is provided as a regular feature of LUSTLine to update state and federal UST, LUST, and cleanup fund person-
nel about the activities of the AssociationofState 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           ;   :
State Symposium on MTBE
Remediation Held
The ASTSWMO MTBE work group
sponsored a two-day symposium
on MTBE remediation in Washing-
ton,  D.C.,  on July 26-27.  The
symposium was attended by repre-
sentatives from 35 states, five EPA
regions, four EPA HQ offices, and
the U.S. Geological Survey, and by
several industry and state associa-
tion representatives and consul-
tants. There were presentations on
research findings in the areas of
remediation, toxicology, and drink-
ing water treatment. Other specific
topics addressed were  natural
attenuation, impacts to water sup-
plies, the Blue Ribbon Panel find-
ings and recommendations, and
state remediation experiences.
    Toward the end of the sympo-
sium, the group was divided into
four subgroups.  Each subgroup
was asked to develop four critical
issues related to MTBE and to sug-
gest ways  that state and federal
agencies  could  address  these
issues. The  MTBE work group
plans to prepare a synopsis of criti-
cal issues identified at the sympo-
sium and detail those concerns in
the next issue of LUSTLine. Notes
from the meeting will be produced
8th Annual State Fund
Administrators Conference
The Kentucky Petroleum Storage
Tank Environmental Assurance
Fund,  the Association of State
Underground Storage Tank Clean-
up Funds (supported ASTSWMO),
the New England Interstate Water
Pollution Control  Commission,
and OUST  co-hosted  the  8th
Annual State Fund Administrators
Conference on June 6-9 in Lexing-
ton, Kentucky. The conference was
attended by approximately  150
people  representing  state fund
managers and staff, EPA regions,
state  commissions, tank owners
and operators, cleanup consultants,
and insurance underwriters, plus
one state trooper who investigates
cleanup crime and fraud.
    State Fund  Success Awards
were given to three states in recog-
nition of their accomplishments in
three award categories: Washing-
ton for Financial Success, Kansas
for Corrective Action, and Vermont
for Legal/Management. Alabama
won the award for "Best Fund for
Getting the Job Done," the most
successful fund, overall, based on
its submissions in all three award
categories.  Congratulations  to
these states and to  all of the states
that submitted award applications
this year.
    Hot  topics  on this  year's
agenda included the effects of the
December 22 compliance deadline
on state funds, the impact of MTBE
on fund reimbursement,  above-
ground storage  tank  cleanups
(which more funds are now being
mandated to pay for), and cost con-
trol  (a never-ending  issue).  The
conference also showcased its 1st
Annual State Fund Fair, which was
patterned after the state fair held
during  OUST's  UST/LUST  Na-
tional Conference. Sixteen exhibits
featured a range of topics,  from
database management systems to
an MTBE detection (sniff test) sur-
vey. Next year's conference will be
held June  4-7 in Scottsdale, Ari-
         We're on the Case! —Are EPA's UST Rules and Standards Doing the Deed?
   If you cup your ears, you will be hard pressed not to take in
   the increasingly audible hubbub surrounding LIST systems
   performance and tank and pipe design standards. With the
  1998 deadline 10 months behind us and the recommenda-
  tions of the Blue Ribbon Panel on Oxygenates in Gasoline;
  fairly fresh on the table, many state, federal, and local UST
  regulators find themselves drifting back to the future, asking
  questions about UST systems proteetiveness that were asked
  during rule making in the mid 1980s.
      Does EPA have answers to these questions? Anedtodai?
  Yes. Real data? Not much. EPA and many of the states have
                 told LUSTLine that theywould love to have some real perfor-
                 mance data for the various types of storage systems and leak
                 /detection systems.Jhey would also like to learn more about
                 the life expectancy of various tanks/piping systems, and other
                     Who, if anyone, will provide this vital information? That
                 answer's on the murky side, right now. But folks, LUSTLine
                 will do its best to stay focused on these issues and to keep
                 you up-to-date and primed for optimal  performance. So stay
                 tuned, and, above all, let us know about anything that you
                 might be ableto add to the discussion. •   ;

  LUSTUne Bulletin 33
   Tanks   Down

  by W. David McCaskill
  David McCaskill is an Environmental Engineer with the Maine Department of Environ-
  mental Protection. Tanks Down East is a regular feature o/LUSTLine. In this edition,
  David, at long last, provides a second installment of his popular June 1994 article, "Those
  Tanks in America's Backyards and Basements." This update describes Maine's strategy for
  dealing with the problem of spills and leaks from aboveground home heating oil tanks. As always,'
  we welcome our readers' comments.

  Those Tanks in America's Backyards and Basements—Part 2

  A Report from  Maine on the Trials and Tribulations  of

  Leaking  Aboveground Home Heating Oil Tanks
f     j^
                     : life ofspend-
           ' ing the summer in a cot-
            tage on a coastal island in
   Maine. The picture  of evergreens
   marching down to the rocky, wave-
   washed shores, accented with a touch
   of wispy fog, is so beautiful it just
   plain hurts. Many an out-of-stater
   has purchased his or  her own little
   slice of the Maine coast. Many of
   these folks summer in small cottage i
      '.tnunities year afj^^year^arfdjrj:.
     Such was the case on one island
  in Casco Bay in the fall of 1996, except
  the comfort level diminished when
  the contents of one particular tank at
  one particular cottage "mysteriously"
  escaped their confines. Whether this
  spill was the result of an overfill or a
  damaged oil filter, we'll never know.
  Nevertheless, by the time the Maine
  Department of Environmental Protec-
  tion (MDEP) found out about the
  problem, the fractured bedrock arter-
  ies of this rocky island made sure that
  the tank had shared its contents with
  the entire cottage community.
     Needless  to  say,  some  old
  summer  friendships,  like   the
  bedrock,  were  now  fractured—
around $80, 000 would be spent on
this site. This scenario was nothing
new for those of us at MDEP, inas-
much as  we'd spent the last five
years responding to an ever-increas-
ing number of these types of releases
from aboveground home heating oil
   Shortly after the spill was dis-
covered, I was asked to take a gan-
der at the then "fixed" offending
tank. While at  the site, one of my
coworkers pointed out a neighbor-
ing cottage whose tank rested at a
precarious slant on rickety, five-foot
high wooden legs. We attempted to
contact the out-of-state owner to pro-
vide counsel on the condition of this
"tippy tank" (MDEP has no jurisdic-
tion over these tanks), but  not in
time to avoid  it  falling over two
weeks  later during  an autumn
storm, adding  its contents  to the
   You betcha, we were more than
frustrated about our lack of preven-
tative powers. In fact, our boss
demanded that we come up with
some scheme to take a more proac-
tive role in addressing our burgeon-
ing problem of leaking aboveground
home heating oil tanks.

The Grim Statistics
Since  1991, MDEP  has  seen  an
increasing number of aboveground
home heating oil tank releases. Until
the Casco Bay island affair, however,
our efforts at addressing the prob-
lem had been limited to working
with  the  state's oil industry  to
develop a series of public service
announcements  and informational
pamphlets to alert the public of the
need to pay attention to these tanks.
After dealing with the situation on
the island, we moved toward a more
proactive approach—to replace these
tanks, especially in sensitive areas,
such as coastal islands and peninsu-
las, where shallow bedrock and lim-
ited alternative water supplies hinder
cleanup of an invaluable resource.
   But before our department was
to undertake this new initiative, our
industry "stakeholders" wanted to
see some data. With the gauntlet
thrown down, we looked over spill
records from 1994 to 1997. We deter-
mined that we were responding, on
average, to one home heating oil
tank/piping leak or spill per day!
   We also had some data from a
case study performed by a staff mem-
ber on home heating oil tank releases
in the three southern Maine counties.
Out of 498 incidents investigated
during a period between 1994 and
1996,17 percent of the spills resulted
from internal corrosion, 11 percent
from breakage of piping and filters,
10 percent from tank overfills, and 6
percent from corrosion of buried pip-
ing. The other remaining categories
included vandalism  (3%),  poor/
improper installation  (8%), human
error (10%), other piping/valve fail-
ures (12%), storm damage (5%), other
(12%), and unknown (5%). We felt
that this information was fairly typi-
cal of the rest of the state. The fre-

                                                                                           LUSTLine Bulletin 33
quency and causes coupled with the
long-term cleanup costs associated
with these releases  really got the
industry's attention!
    Spills associated with damage to
the oil filter and lines (often caused
by falling snow and ice)  or a cor-
roded tank bottom  are one thing;
they are usually noticed and cleaned
up relatively quickly. Releases from
corroding buried piping,  however,
are more insidious, because by the
time they are discovered, the damage
is done.
    Here's a real-life example of a
grim, corroded, buried-pipe statistic.
Picture this. It's Super Bowl Sunday.
A husband and wife sit glued to the
television watching the game, when
the wife notices the  sweet smell of
fuel oil. They investigate and find a
pool of oil around  the tank in the
garage. They later find that it's been
seeping up from a leak in the copper
line buried in the concrete slab run-
ning from the tank to the furnace.
    The MDEP investigates and finds
that the soil  and water under the
home are contaminated. The MDEP
Groundwater Cleanup Fund will pay
for the  remediation, but  they still
have the aggravation of having their
yard dug up and a remediation sys-
tem full of  pumps and blowers
housed on their property. To add to
the confusion, the husband is to be
transferred to another state in several
months  and the couple are afraid
(rightly so!) that the house won't sell.
    According to the MDEP and its
consultant, the  cleanup  will take
years, but some relative tells the wife
that digging the contaminated soil
from under the house will do the
trick. The couple talks the MDEP into
letting them manage this portion of
the cleanup, which means gutting the
bottom story of their house down to
the studs so that a bobcat with a front
end loader can come in and dig up
the soil.  It comes to pass, the soil is
removed, the house  is   put back
together, and  months later  it sells.
What fun. All that hassle caused by
something most people think about
as often as they think about their hot
water heater or the inner workings of
their toilet!

Going with the Program
Back  to MDEP's efforts  to curtail
heating oil releases. With the data in
hand and the problem defined, it was
up to us to devise a strategy to pre-
vent tank and piping leaks. The first
thing we did was to meet with the oil
industry and the Oil and Solid Fuel
Board (OSFB), the state agency that
licenses oil technicians and sets the
tank  standards. Our goal was to
upgrade the state  code to address
some of the problems that we were
    As in most states where heating
oil  fuel is  used, OSFB adopts the
National Fire  Protection  Code 31,
Installation of Oil-Burning Equipment,
with some modifications. In February
1998, the state rules were amended to
include requirements for a layer of
well-drained, crushed rock or gravel
under the tank pad to prevent the
tippy tank scenario; overhead protec-
tion from ice and snow falling off the
roof; and sleeving for underslab or
buried copper lines.
!*- Spills associated with damage to
"tiie oil filter and lines (often caused
   by tailing show and ice) or a
corroded tank bottom are one thing;
'jeyare usually noticed and cleaned
upjelatively quickly. Releases from
    fjjtiing buried piping, however,
       •e insidious, because by the
              discovered, the

    The oil industry recommended
that a two-year compliance schedule
be set for upgrading buried copper
lines  and a five-year schedule for
overhead protection and padding.
These deadlines turned out to be a bit
too aggressive, inasmuch as there are
more than 250,000 oil heating cus-
tomers in the state.  So, after some
public and political pressure, the pip-
ing deadline  was  extended  from
February 2000 to September 2000.
Extending the deadline into a non-
heating season makes sense and has
given the OSFB, MDEP, and the oil
industry more time to get the word
    The other prong of our strategy is
a two-year pilot project, negotiated
with  our  Groundwater Cleanup
Fund stakeholders, that will allow
MDEP to spend $250,000 per year for
two years to replace tanks in sensitive
areas at no cost to the homeowner.
This project is focused on  coastal
islands   and   peninsulas,  where
groundwater is especially valuable
and vulnerable.
    Another reason to focus on off-
shore islands is because some islands,
such  as Monhegan (one of  our
replacement sites), are several miles
from the mainland, and the logistics
of cleaning up a major release would
cost many  times  more  than  an
onshore cleanup. So far, MDEP has
replaced 150 tanks on two  coastal
islands and one peninsula and plans
to replace  over 100 tanks on two
more islands.  We provide  grant
monies for these communities; they,
in turn, contract out the work.
    We have also contracted with the
Community Action Program (CAP—
a program set up to help low-income
families) to use $750,000 per year for
two years to replace tank systems at
low-income homes. In Maine, there
are around 30,000 CAP clients who
use heating oil, so finding places to
spend the money is not an issue. So
far, CAP has replaced around 1,000
tanks, giving priority to homes that
are on  private wells.  MDEP and
OSFB audit/inspect a number of the
installations to see whether they meet
state requirements and specifications
and to find out about any unforeseen
problems with implementation of the
    MDEP keeps a balance of about
$25,000 that can be used for'quick
tank replacement when field staff run
across a  questionable tank that has
the potential to contaminate multiple

Contentious  Specifications
For the purposes of our replacement
program, MDEP developed a set of
storage system specifications that
include several items not included in
the OSFB rules or NFPA 31. The most
contentious requirements involve
tank specifications. We specified that:
• Each heating oil tank be an Under-
  writers Laboratory (U.L.) listed
  tank (Standard for Steel Oil Fur-
  nace Tanks-U.L;-80) that has a bot-
  tom outlet  so that  water and
  sludge drain into the fuel filter
              • continued on page 22

LUSTLine Bulletin 33
• Tanks Down East from page 21
  and don't cause tank bottom cor-
• Tanks be painted a light color to
  reduce condensation and, thereby,
  help  reduce tank bottom corro-
• The tank  end be welded to  the
  body of the tank using a lap joint
  rather than a crimp connection to
  prevent rupture caused by joint
  fatigue resulting from repeated
    We  knew  that these features
were not found on the standard tank
in Maine, and we were willing to pay
extra for them.
    Sounds good, huh? But you'd
think that we had asked for the sun
and moon! Many oil burner techni-
cians don't like the bottom outlet
because they want the water and
sludge to stay in the tank and  not
plug the lines, which results in mid-
night service calls. However, other
         suldhelp us succeed
service technicians assure us that
with proper maintenance and filter
replacement this issue should not be
a problem. The tanks come with only
a black primer so the  technician
would have to paint them, which we
are willing to pay for. The stronger
end weld is one  of the approved
welds found in U.L. 80 and offered
by some tank manufacturers; still it is
different, and technicians need to
make the adjustment. By the way, in
the next version of U.L. 80 (published
July 30,1999, and effective 18 months
later), the "crimped," U.L. 80 weld
number 25 will no longer be allowed.

As Maine Goes...
We are now in the second year of our
program and are quite pleased with
             • continued on page 23
Make Your Tank a Super Tank

Tips for a Tip-Top Tank System

The Tank
• Make sure that the tank is U.L. listed. It should
  include a bottom outlet, according to U.L. 80, to
  allow water and sludge to drain and
  to prevent bottom corrosion in
  the tank.
• Be sure that tank ends form
  a tight lap joint using a fillet
  weld with the tank shell. We
  recommend a capped rather than
  a crimped end to guard against
  joint fatigue caused by flexing of
  the tank end during filling.
• Use horizontal or flat tanks whenever
  possible. Homeowners need to check with
  their professional oil heat technician  to
  find out if their furnace will run with
  this configuration.
• Paint all outside tanks a light color to
  reduce condensation, which can lead to
  bottom corrosion.
• Rest all outside vertical tanks on
  a 3-inch, reinforced concrete
  slab that is underlain with
  6 inches of well-drained
  gravel or crushed  rock.
  Four-inch solid concrete blocks placed under each leg are sufficient for
  horizontal or flat tanks, along with the 6-inch crushed stone or gravel.
• Be sure that the filter is protected from falling ice and snow. Ideally,
  tanks should be located at the gable end of the house. If this setup is
  not possible, filter protectors can be installed. (Check with Peter Moul-
  ton at MDEP for details.)
• Provide the tank with a gauge and a whistle so that the delivery person
  knows that the tank is full. This setup has always been a requirement,
  but it has often been overlooked.

The Piping
• Protect all piping. If copper lines are buried under or in a concrete or
  grout-filled trench, replace the lines aboveground and keep them out of
  the way of traffic. Most lines can be run overhead (again, homeowners
  need to ask their service technician if this option will work with their fur-
  nace pump) or along the wall. If the lines must go back under the base-
  ment or garage floor, sleeve them in plastic pipe or conduit. We also
  recommend that all aboveground piping be run in a protected sleeve.
• Run vent and fill lines to the outside of the basement or garage.

Care and Feeding
• Routinely check the tank for leaks and weeps.
• Have the oil dealer add a fuel  additive to prevent sludge buildup and
  displace any water.
• Fill tanks in late spring to keep them full throughout the summer to
  reduce condensation.

                                                                                     LUSTLine Bulletin 33
• Tanks Down East from page 22
the results. In fact, there is a good
indication that our legislature will
approve our proposal to continue the
project until 2005 (when our Ground-
water Fund will be severely cut back).
Still, we are targeting only a small
portion of the population and it is
going to be up to the people of Maine
to comply with the OSFB rules.
   Meanwhile, our sister states here
in northern New England and our
Canadian Maritime cousins have had
to deal with this problem as well. In a
recent meeting of the NFPA 31 Tech-
nical Committee, the New Hampshire
delegates proposed that NFPA adopt
many of the requirements currently
found in Maine's rules. This problem
is a very regional issue, but it does
affect a large number of people. If s a
groundwater and indoor air quality
issue. Ideally, the combination of pub-
lic outreach, retrofit deadlines, and
industry support should help us suc-
ceed in reducing the environmental
and health and safety effects of sub-
standard home heating oil tanks.
   For a detailed copy ofMDEP's spec-
ification,  e-mail  Peter  Moulton  at
peter. t.moulton@state.me. us. •
Mitigating; Third-Party
Damage Claims  with Pay
for Performance
by Bill Foskett

     Pay-for-performance (PFP) UST
     cleanups might prove to be a
     tool for mitigating third-party
damage claims associated with UST
releases and related litigation. If a
plume can be quickly and success-
fully remediated, the case for third-
party damage may be nipped in the
bud or mitigated if already filed.
   Many time and materials (T&M)
cleanups go on for years, run up high
costs, and give no  guarantee of a
clean site. PFP cleanups offer a fixed
price and a fixed time for reducing
contamination below levels at which
third-party damage claims are likely
to be sustained.
   The uncertain time and cost asso-
ciated with T&M cleanups can invite
larger third-party damage  claims.
Furthermore, the slowness of T&M
cleanups  can nurture  third-party
damages  litigation.  As the T&M
cleanup grinds on and on with  no
apparent end in sight, a neighbor
might begin to believe that the seem-
ingly endless cleanup has stigma-
tized his or her own property, even if
it has not been contaminated by an
off-site plume. These parties assert
that the endless neighboring cleanup
diminishes their ability to sell or refi-
nance their property.
   At least one state is anticipating
such claims and is using PFP as a
means to reduce contamination at
various  sites expeditiously so that
levels will be low enough within a
short time frame to deter claims, if
made. More detail on third-party
damage claims and the use of PFP to
mitigate them will be provided in the
next issue of LUSTLine.

  Bill Foskett is with EPA's Office of
 Underground Storage Tanks and is the
          PFP Staff Lead.
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   We welcome your comments and suggestions on any of our articles.

                   EPA HQ UPDATE
   OUST Releases Basic
   Compliance Checklist
   After incorporating  comments
   received from state and regional
   reviewers,  the EPA Office  of
   Underground  Storage  Tanks
   (OUST) has released its final ver-
   sion of A Basic Checklist for USTs.
   Copies of the checklist have been
   to regulatory partners in states
   and regions. The checklist is also
   posted on OUST's Web site under
   the  "Compliance  Assistance"
   icon (at http:/ /www.epa.gov/
   swerustl / cmplastc / index.htm).
   OUST hopes that the checklist
   will prove to be a very useful
   compliance  assistance tool  for
   UST owners and operators  as
   they self-evaluate their compli-
   ance status. The checklist is not
   presented as an enforcement tool
   and is clearly caveated on each
   page to alert the user that filling
   out the checklist is not a guaran-
   tee of compliance  status. For
   more information, contact Jay
   Evans  at   703-603-7149   or
List of Known Insurance
Providers for USTs
UST owners and operators seek-
ing a way to comply with federal
financial responsibility require-
ments for USTs can check out
OUST's List of Known Insurance
Providers for Underground Storage
Tanks  (EPA 510-B-99-003), pub-
lished in July 1999. The booklet
provides  a  list  of  insurance
providers that may be able to
help UST owners and operators
comply  with  their  financial
responsibility requirements  by
providing a  suitable insurance
mechanism. OUST will update
the list periodically on its Web
site  and  less  frequently  as
updated printed material.

Copies are  available  free  of
charge from NSCEP at (800) 490-
9198 or EPA's RCRA Hotline at
(800) 424-9346. If you need more
than 30 copies, contact Jay Evans
at (703) 603-7149.

The document is also available
on   OUST's   Web    site   at
http:/ /www.epa.gov/swerustl/
pubs / index.htm#inslist.
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       Boott Mills South
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  August 1985/Bulletlu ffl -March 1999/BuUetlu »31
 The LUSTLine Index—the
 long and action-packed
 story of USTs and LUSTs
 in the late 20th century is
 now available.
    Copies are available
       from NEIWPCC
       (978) 323-7929
New England Interstate Water
Pollution Control Commission
Boott Mills South
100 Foot of John Street
Lowell, MA 01852-1124
Fonvarding and return postage guaranteed.
Address correction requested.