New England Interstate
Water Pollution Control
Boott Mills South
1OO Foot of John Street
Lowell, Massachusetts
A Report On Federal & State Programs To Control Leaking: Underground Storage Tanks
Bulletin 47

Where flre  the Sites?

The Emerging Context for "USTfields"

by Charlie Bartsch

    Sherman Perk, a successful independent coffee
    shop developed on an odd-sized, triangular
    petroleum brownfield site, is located in the Sher-
man Park area of one of Milwaukee's most diverse
neighborhoods. The building on the site, which was
renovated to house the coffee shop, was built in 1939
and operated as a gas station for 50 years. The property
sat vacant for 10 years following the closure of the gas
station in 1989. It slipped into tax delinquency and
was boarded up.
   In the mid-1990s, a local community group, Grass-
lyn Manor, launched the process to register the gas sta-
tion with the City of Milwaukee's list of Historic
Properties. The building was one of the few remaining
unaltered examples of a Streamlined Moderne architec-
tural-style gas station in the Midwest, a feature that the
group felt could give it a unique commercial advantage.
   In the spring of 2000 a new  owner, Bob Olin,
acquired the property, this time because of its historic
value. But the site had serious problems. The City of
Milwaukee had ordered the gas station building to be
demolished because of the hazard it posed—the struc-
ture was seriously deteriorated and the site was contam-
inated due to fuel leakage over the years. In addition, the
site bore a significant financial burden that had discour-
aged developers from coming forward—the property
was nine years' tax delinquent.
   But the owner persevered, and in mid-May 2000 he
attended a meeting of the Sherman Park Historic
Preservation Council to express his interest in reviving
the idea of developing a coffee shop at the site. Olin was
aided in his effort by a new Wisconsin state law
designed to encourage reuse of tax-delinquent, contami-
nated properties by linking cleanup and reuse to tax
foreclosures, assigned tax liens, and a tax forgiveness
process. This statute became the tool that facilitated the
saving of the gas station, and the coffee shop project was
the pilot case under the new law.
                    • continued on page 2
       Sherman Perk,
             The Face of Brownfields Is Changing

             Lead Scavengers: A Leaded Gasoline Legacy?

             On-Site, On-Line Calculators

             Tracking Troubling Vapor Releases in New Hampshire

             The Limits of Leak Detection

             Pipes and Sumps: Thoughts from a Florida UST Inspector

             Trading Shoes: Risk-Communication Strategies

             Mandatory Training for UST Operators

             New Regulations Change UST Operation in California

             Time to Close the Gap Between Water Supply and UST Programs

             Field Notes: Making a List—Checking It Twice

LUSTLine Bulletin 47 • June 2004
m Where Are the Sites from page 1

In the case of Sherman Perk, the par-
ties to the foreclosure included the
City of Milwaukee and the Wiscon-
sin Department of Natural Resources
(DNR). The city's role was  to com-
mence with the tax foreclosure and
then place the property in the hands
of a developer (in this case, the cur-
rent owner), who would do what
was needed to get the property back
into  tax-paying status. DNR's role
was  to oversee the environmental
remediation of the property,  which it
did  through the  state   voluntary
cleanup program. After five months
of effort, the statute was applied and
the petroleum-contaminated  Sher-
man Park site was transferred to Mr.
Olin for cleanup and redevelopment.
    As  a  small, community-based
developer, Olin faced critical finan-
cial hurdles in getting his project
underway. He worked with a variety
of public agency partners to structure
a package of financial incentives that
made Sherman Perk a reality. The
           Ellen Frye, Editor
          Ricki Pappo, Layout
     Marcel Moreau, Technical Advisor
   Patricia Ellis, Ph.D., Technical Advisor
 Ronald Poltak, NEIWPCC Executive Director
     Lynn DePont, EPA Project Officer
 LUSTLine is a product of the New England
 Interstate Water Pollution Control Commis-
 sion (NEIWPCC). It is produced through a
   cooperative agreement (#1-830380-01)
     between NEIWPCC and the U.S.
    Environmental Protection Agency.
   LUSTLine is issued as a communication
      service for the Subtitle I RCRA
   Hazardous & Solid Waste Amendments
       rule promulgation process.
    LUSTLine is produced to promote
 information exchange on UST/LUST issues.
 The opinions and information stated herein
  are those of the authors and do not neces-
   sarily reflect the opinions of NEIWPCC.
     This publication may be copied.
     Please give credit to NEIWPCC.
   NEIWPCC was established by an Act of
   Congress in 1947 and remains the oldest
   agency in the Northeast United States
  concerned with coordination of the multi-
      media environmental activities
    of the states of Connecticut, Maine,
     Massachusetts, New Hampshire,
   New York, Rhode Island, and Vermont.

  Boott Mills South, 100 Foot of John Street
        LoweU, MA 01852-1124
        Telephone: (978) 323-7929
          Fax: (978) 323-7919

   4J§ LUSTLine is printed on Recycled Paper
city and county of Milwaukee pro-
vided $30,000 in grants to help cover
the costs of site cleanup,  including
removal of USTs, and the Wisconsin
Department of Commerce awarded
$100,000  through its  Brownfield
Revitalization   Program  to   help
finance redevelopment.
   The grand  opening of Sherman
Perk took place on August 20, 2001,
and the coffee shop  has  become a
thriving neighborhood anchor.  In
2003, Sherman Perk's owner paid the
greatest tribute possible to the oppor-
tunities  and process of converting an
abandoned petroleum brownfield
site—he did it again!
   Bob Olin recently opened a sec-
ond coffee shop at an old gas station
site in  the historic Kletzsch  Park
neighborhood in Glendale, Wiscon-
sin (not surprisingly called Kletzsch
Perk), and is looking for  two more
gas station sites for additional outlets.

Sites Are Everywhere!
There is an almost uncountable num-
ber of abandoned gas stations, not to
mention places like idle manufactur-
ing facilities that dealt with oil in
some way and dying shopping areas
that had oil tanks on site—the list is
as long as it is diverse. Thus, the chal-
lenge of  petroleum-contaminated
sites is significant. But this challenge
is being met, and communities that
are succeeding are doing so because
they have defined cleanup and reuse
in a new context for these properties.
They tend to:
  • Approach UST site reuse  as  an
   economic   development  issue
   with  an environmental twist,
   rather than as only a pollution
  • View UST projects as real-estate
   deals  that  further  community
   development goals, and in doing
   so,  they  turn  environmental
   issues into an approach that cre-
   ates value, attracts investment,
   and gathers support;
  • Begin cleanup and reuse with the
   end in mind, using  strategies
   such  as  risk-based corrective
   action (RBCA) to  guide   their
   efforts; and
  • Understand   that  regulatory
   processes need to dovetail with
   development time frames.
Economic Development with
an Environmental Twist
If contaminated petroleum sites are
viewed as only pollution problems,
disconnected from community revi-
talization goals and economic devel-
opment  strategies, then efforts to
reuse these sites will flounder. If,
however, localities and their partners
view USTfield projects as real-estate
deals that further community devel-
opment goals, then the environmen-
tal issues can be structured into an
approach that creates value, attracts
investment, and gathers support.
    This perspective on petroleum
site redevelopment also reflects the
emerging agenda of EPA, which is
increasing  the focus  of its waste
cleanup efforts on a community revi-
talization and land-use approach.
Moreover,   the  success  of  this
approach will be strengthened if it
helps create  strong  redevelopment
partnerships among localities, state
agencies, and the private sector.
    Most communities have many
sites within  their boundaries—far
more  than can be easily or readily
addressed. Therefore, the immediate
challenge is to prioritize. Anybody
can make a list, but if that list is to be
effective in leading to the next steps
of cleanup and reuse, then it must
meet   the  needs  of  prospective
reusers. And a first key need is a list
of  likely targets  that can meet
reusers'  needs.   An  appropriate
screening is enormously valuable—
prospective reusers are not interested
in having the  whole phonebook
when all they want is five listings.
    This inventorying process needs
to  be  conducted  in  a targeted,
focused manner. It can be high-tech,
using emerging geographic informa-
tion systems (GIS) and similar tools.
It can also be low-tech, with some-
thing as simple as a windshield tour
of a community area that officials
want to market for new use. To this
end, city or county  planning and
development departments—which
likely have prepared and sorted site
lists as part of their own economic
marketing activities—can be valuable
allies in what may naturally evolve
into a mutually advantageous effort.

The Legwork
Overall, it is more important to make
sites attractive and  marketable for

                                                                                    June 2004 • LUSTLine Bulletin 47
various types  of new uses. This
means taking the next step beyond
listing and inventorying to analyzing,
sorting, and prioritizing—helping to
do the first screen to meet the needs
of prospective reusers of petroleum-
contaminated sites. Local officials
and environmental agency staff can
take the following critical steps:
  • Proactively identify appropriate
   site reusers by working with con-
   tacts in sister agencies to point
   companies to abandoned gas sta-
   tions in locations that can meet
   their demographics but that they
   might have overlooked.
  • Provide a responsive regulatory
   process that includes a sense of
   time frames and requirements, as
   well as giving basic explanations
   of how liability relief works, iden-
   tifying who the right points of
   contact are, and pointing to an
   ombudsman if one is in place.
  • Link users  to various financial
   incentives that can be used to
   overcome the additional or up-
   front   costs   of   assessment,
   cleanup, and  site  preparation
   attributable to contamination—
   many such incentives exist at all
   levels of government.
  • Offer  marketing  support and
   outreach—including promoting
   site reusers as good corporate cit-
   izens—which will help them to
   justify their decision to take on a
   petroleum-contaminated site.
  • Help to make the critical connec-
   tion with the community, and
   support public participation and
   neighborhood outreach efforts
   pertaining to issues  such as type
   of cleanup, use of institutional
   controls, and other strategies that
   can be safely deployed to  cut
   costs while maintaining appro-
   priate health and environmental

Connecting the Dots
"Lists" are  enhanced  with  local
capacity to back them up and to carry
out the steps noted above. Local gov-
ernments are ideally situated to fos-
ter USTfield activities and promote
private-sector investment, and  the
state needs to be a key player in that
process. This partnership can involve
a number  of activities, and could
  •  assembling sufficient resources
    to build program capacity and
    leverage site-specific initiatives,
    which  may  mean  connecting
    UST and  brownfield  efforts
    where possible to leverage each
    other's resources
  •  recognizing that petroleum prop-
    erties may not fit within tradi-
    tional land-use approaches and
    may have to be considered site
    by site—and  may require state
    help in targeting priority sites for
    local attention
  •  considering public uses for petro-
    leum-contaminated  properties
    that complement adjoining pri-
    vate uses, such as post offices,
    police  stations  (e.g., Dallas),
    health clinics  (e.g.,  Tampa), or
    that can  serve as catalysts  for
    related developments
  •  enhancing local reuse capacity by
    identifying and educating visible
    local leadership  on  UST issues,
    which  could  include political
    leadership from the top as well as
    a day-to-day champion who can
    maintain project efforts over time
  •  integrating UST site activities
    into broader community devel-
    opment  goals,  for  example,
    through  approaches such  as
    tying them to related economic
    development  activities   like
    small-scale commercial develop-
    ment or infill housing
    Moreover, partnerships must go
beyond  the  public  sector.  Given
resource  constraints,  substantial
petroleum site reuse will only be real-
ized when  the  private  sector  is
engaged as an active partner. The
public sector cannot do all of this
    Partnerships based on a solid out-
reach effort are vital to  a  successful
UST effort because they foster com-
munication and the building of coop-
eration  and trust. Depending on the
specific project and its location and sit-
uation, potential private partners may
include  bankers, investors, develop-
ers, existing private business owners,
and lawyers, as well as environmental
professionals, private practitioners in
several areas (e.g., economic develop-
ment, engineering, technology ser-
vices), insurance providers, and even
the major oil companies.
    Partnership efforts could involve:
  •  forming good working partner-
    ships with potential redevelopers
    and reusers of sites, while pro-
    viding them with basic informa-
    tion and targeted inventories that
    can prove attractive to them as
    they go about their business
  •  enlightening private parties on
    how to  overcome  liability and
    other barriers  to  successfully
    redevelop and market tank sites,
    while explaining  key compo-
    nents of the reuse context to
    them, such as new laws and reg-
    ulations influencing site reuse,
    the economic benefits of cleaning
    and reusing these sites, and vari-
    ous public incentives (e.g., volun-
    tary  cleanup  program  (VCP)
    releases) and private tools (e.g.,
    environmental insurance)  avail-
    able that can help tie these pro-
    jects together
  •  forming good working partner-
    ships with, and  providing out-
    reach to, financiers and insurers
    of USTfields projects by teaching
    them about new technologies,
    the value of VCPs, and related
    elements that can advance their
    comfort and understanding
  •  starting to  build working rela-
    tionships with major oil compa-
    Where are the sites and how are
they being reused? More and more
examples of how these concepts are
coming together in practice can be
found. The Sherman Park story at the
beginning of this article provides one
example. Let's take a glance at exam-
ples in Montgomery Park, Maryland
and Chevy Place, New York.

Montgomery Park
Today's Montgomery Park in Balti-
more,   Maryland   is   yesterday's
26-acre, 1.3-million-square-foot Mont-
gomery Ward  catalog distribution
center, which was built in 1925. The
facility closed in 1985 and remained
vacant for 15 years, gradually deteri-
orating. The structure had the types
of contaminants that were common
to its era of construction—interior
and exterior lead paint, asbestos,
petroleum, and PCBs.  The site also
had six underground storage  tanks
that had to be removed. The cost of
cleanup was approximately $2 mil-
                 • continued on page 4

LUSTLine Bulletin 47 • June 2004
 i Where Are the Sites from
 Montgomery Park,  Baltimore, Maryland
    The Montgomery Park project
incorporated a  number  of green
building concepts.  And like many
sites  incorporating  an innovative
approach,  the  developers  used a
blend of public and private funding
sources to pull the project together. In
the end, this project converted an 80-
year-old historic structure into a
state-of-the-art green building. Cur-
rently, the eight-story building is 40
percent leased,  and 1,800 people
work there. The work force is pro-
jected to top 4,000 when the building
is fully leased.

Chevy Place
The 2.2-acre former Hallman Chevro-
let automobile dealership and service
garage, now known as Chevy Place,
is located in downtown Rochester,
New York. This site was redeveloped
primarily for residential purposes.
Some $10.6 million was invested in
Chevy Place, Rochester, New York

included a large, multi-bay service
and repair garage, as well as a gaso-
line station. The site was vacant from
1990 until  the city  purchased the
property in 1996. The project, which
ultimately  would take  five years
from start to finish, had to overcome
several challenges to the city and the
developer,     including    shifting
redevelopment plans, historic preser-
vation restrictions, street reconstruc-
tion, and funding constraints—and
these were in addition to the environ-
mental concerns at the site,  which
included several abandoned USTs.
    Total  cleanup   project  costs,
including both phases of remedia-
tion, were approximately $750,000.
Rochester financed the initial phase
of the cleanup with part of its HUD
Community   Development  Block
Grant  allocation. The  developer
funded  the second  phase of the
cleanup. In addition, the city assisted
Chevy Place for site preparation and
construction of 77  new residential
townhouses and apartments. Chevy
Place also included  the construction
of a below-grade parking garage, and
the renovation of the historically sig-
nificant Hallman Chevrolet show-
room as a restaurant.
    From 1930 until 1990, the site was
one  of the largest  new-car dealer-
ships in Rochester. The dealership
the developer with environmental
costs via direct reimbursement for
certain disposal costs, providing the
company with a $2.35  million loan
for the redevelopment project, and
reducing the purchase price of the
property due to the environmental
cleanup costs.
    But both  city  and  developer
agree that the project's benefits out-
weighed the hassles and were worth
the  investment.  Chevy  Place is
Rochester's  first new  downtown
apartment complex in 20 years. All 77
units are rented. Chevy Place's most
distinguishing architectural feature is
its  Art  Deco  showroom,  which
remains standing due to its historic
site designation. The former show-
room has been renovated as a 24-
hour coffee shop.  The apartment
complex is located in Rochester's east
end cultural and theater district, near
the  Little  Theatre, the  Eastman
School of Music, the Eastman The-
atre, and several  restaurants  and
museums. This project has been a cat-
alyst for additional private develop-
ment in the area.

The Sites Are Out There
In short, local efforts to promote
cleanup and reuse of contaminated
petroleum sites have come a long
way since September 2001, when
EPA launched its USTfields pilot ini-
tiative to address "abandoned or idle
property where redevelopment is
hindered by petroleum contamina-
tion from abandoned, federally regu-
lated underground storage tanks."
    Those first 10 pilot communities
played a significant role in shifting
local UST activities from an approach
that focuses solely  on cleaning up
environmental   problems   to   an
emerging approach that considers
petroleum sites from a more compre-
hensive vantage point—one that also
considers real estate and community
benefits.  Increasingly, when  local
officials ask, "Where are the sites?"
they  are  seeking  responses  that
include opportunities for economic
and community revitalization—with
the appropriate environmental twist.
 Charlie Bartsch is a Senior Policy Ana-
  lyst at the Northeast-Midwest Insti-
     tute, where he has carried out
 considerable research and outreach on
 brownfields and USTfields. He can be
  contacted at

                                                                                 June 2004 • LUSTLine Bulletin 47
Director, U.S. EPA Office of Underground Storage Tanks

The Face of Brownfields Is Changing
       No longer are brownfields properties just those
       10-plus-acre former industrial facilities at the
       edge  of the  city. Today's brownfields  now
include the small, abandoned gas stations that were
deserted when traffic patterns changed or as super-sized
convenience stores replaced the small corner service sta-
tion. For years, investors and  developers  shied away
from these properties and the laws prevented us from
focusing on petroleum brownfields. The passage of the
new Brownfields Law has changed this landscape.
    For the first time, we have a law that specifically tar-
gets petroleum brownfields, earmarking 25 percent of the
annual federal brownfields grant money for identifying,
assessing, and cleaning up petroleum-contaminated
properties. Before this law, we provided a total of $4.8
million for USTfields pilots. Last year we announced
$22.5 million for 102 new petroleum brownfields grants.
    On June 15, U.S. EPA announced the second round
of brownfields grants,  and another $23.1 million was
awarded to address more petroleum brownfields proper-
ties. In the first year of the new Brownfields Law, we pro-
vided 10 times as much funding as was provided in the
entire 20 years of the UST program. (See page 32.)
    This money can be used to help identify and address
low-risk petroleum sites that might otherwise languish
for years. Since many of these abandoned properties do
not rank as high health or environmental risks, they are
often left unaddressed. The new brownfields grants can
provide a state with money to  remove these relatively
low-risk petroleum sites from the state's cleanup back-
log. By doing so, we protect our nation's groundwater/
drinking water and, at the same time, make now-tainted
land attractive for reuse.
    I strongly encourage all state UST programs to apply
for available brownfields resources and to develop part-
nerships to foster the identification and assessment of
petroleum-contaminated properties. Working together,
state and local environmental, economic, and planning
agencies can create a comprehensive inventory of aban-
doned gas stations. With this information in hand, poten-
tial hazards  can be prioritized and appropriately
addressed and, at the same time, we can make it easier
for others to consider beneficially reusing stigmatized
    With more than 200,000 abandoned gas stations scat-
tered across the country, these properties represent one
of the greatest untapped redevelopment reservoirs. To
some people, abandoned gas stations may seem too small
to worry about or too small to invest in. But I've seen
how cleaning up and reusing even a single gas station
can make a difference in a small town. For example, Ben
and Jerry began their now famous ice cream business in
an abandoned gas station in a small town in Vermont.
Many communities and businesses are now tapping into
this reservoir.
    It is up to federal and state regulators to assist com-
munities in understanding the potential risks these prop-
erties may present as well as  the value of this now-
neglected land. And these properties are not just attrac-
tive for new retail and commercial uses; there are many
examples of former service stations being turned into resi-
dential housing, community parks, and for public facili-
ties, such as fire stations and health clinics.
    To assist in these efforts, U.S. EPA is working to
develop guidelines on how to inventory abandoned gas
stations and how to market these properties once they
have been identified. As Charlie  Bartsch explains in
"Where Are the Sites?" we need to develop a better way
of identifying these sites and to provide communities
with a "how to" guide. We also need to work with com-
munities to integrate these properties into broader com-
munity development goals.
    Clustering sites can make these properties more
appealing to  groups interested in investing in communi-
ties. In the case of Kansas City, Missouri, an entire city
block was rejuvenated with new ethnic restaurants and
businesses in just this way.
    Whether these sites are reused as new businesses or
for public uses, it is important that we work with public
agencies, private sector investors, developers, and busi-
ness leaders to leverage resources for area-wide improve-
ments. By working together to identify these properties,
we may be able to benefit communities by protecting their
groundwater/drinking water and revitalizing economi-
cally stressed areas. Cleaning up and redeveloping these
abandoned properties exemplifies how environmental
and economic interests can and do work hand in hand. •

  For more information on the Brownfields Grant Program,
             visit U.S. EPA's Web page at:
Los Angeles Publishes Guide for Abandoned Gas Station Sites
The City of Los Angeles Brownfields Program has published a 55-page Guide to Resolving Environmental and Legal Issues at
Abandoned and Underutilized Gas Station Sites. The guide was written to assist public agencies and other stakeholders inter-
ested in redeveloping abandoned gas stations in Los Angeles (though readers in other cities could benefit from much of the
information as well). The guide describes the various environmental and legal steps and issues involved in locating and
acquiring old gas station sites in such chapters as "Gathering Information on a Site" and "Site Status Issues." The publication
includes appendices describing federal and state UST programs and resources available to those interested in cleaning  up and
reusing these sites. The guide can be accessed at •

LUSTLine Bulletin 47 • June 2004
Lead  Scavengers:  A Leaded
Gasoline Legacy?
by Ron Falta and Nimeesha Bulsara

     The removal of lead from gaso-
     line is probably one  of  the
     most important environmental
achievements of the last century. Lead
is a well-known poison, and blood
levels of lead in children in the United
States have dropped by 70 percent
since the elimination of lead from
gasoline (U.S.  EPA, 1996a). While
much attention has been justifiably
focused on the lead in leaded gasoline,
other toxic chemicals were an integral
part of the  lead antiknock additive
package. The halogenated organic
chemicals ethylene dibromide (EDB)
and  1,2-dichloroethane  (1,2-DCA)
were added in significant amounts to
all leaded automotive gasolines begin-
ning in the 1920s. These compounds
served as "lead scavengers," and their
purpose was to  prevent the formation
of solid lead oxide and lead sulfate
deposits in the engine combustion
chamber (Jacobs, 1980).
    Both EDB and 1,2-DCA are prob-
able carcinogens, and they have
extremely low maximum contami-
nant levels (MCLs)  of 0.05  micro-
grams per liter (ug/L) and 5 ug/L,
respectively. The MCL for EDB is
lower than that for any other organic
chemical except dioxin (U.S. EPA,
2001),  and  EDB is an  unusually
potent carcinogen (Alexeeff et al.,
1990; U.S. EPA, 1997). To make mat-
ters worse,  EDB and 1,2-DCA have
high solubilities in water, and they
are mobile and persistent in ground-
water (Falta, 2004).
    Given these facts, it is surprising
that there is relatively little interest in
EDB and 1,2-DCA at most  LUST
sites. The Association for Environ-
mental Health and Sciences (AEHS)
conducts periodic surveys of state
regulators to document state soil and
groundwater cleanup levels for sites
contaminated by petroleum  hydro-
carbons (AEHS, 2004). An analysis of
these data by  Falta  (2004) showed
that as of 2003, 34  states did  not
require testing for EDB or 1,2-DCA in
groundwater at sites contaminated
by gasoline. Of the  remaining  16
states,  only eight reported  clearly
defined limits for these compounds,
and in several cases, these regula-
tions have been implemented only in
the last few years.
   Similarly, a review of the litera-
ture on gasoline contamination and
remediation reveals only a handful of
references that discuss EDB and 1,2-
DCA  contamination from leaded
gasoline (Bruell and Hoag, 1984; Hall
and Mumford, 1987; Pignatello and
Cohen, 1990; Ellis, 2003; Landmeyer
et al., 2003). This small number of ref-
erences should be contrasted with the
hundreds of papers  and reports on
BTEX and MtBE contamination and

Composition of Leaded
Antiknock Mixes
The antiknock properties of lead in
gasoline were discovered by Midgley
and Boyd (1922). They found that the
addition of  only  a  few grams  of
tetraethyl lead per gallon of gasoline
would eliminate engine knock in test
engines. Shortly after this initial dis-
covery, they found that the lead also
caused engine fouling due to the for-
mation of solid lead deposits. How-
ever,  it was soon discovered that
compounds containing bromine, or a
mixture of  bromine  and chlorine,
could eliminate this fouling problem
by forming volatile lead halides
(Boyd, 1950).
   By the late 1920s and early 1930s,
EDB and 1,2-DCA were firmly estab-
lished as the lead scavengers in the
lead  antiknock mixtures (Table 1).
Lead scavengers are always added to
antiknock mixtures in molecular pro-
portion to the lead itself to insure
complete reaction with the lead. Over
time, the proportions of EDB and 1,2-
DCA in antiknock packages varied,
but the automotive mixture was stan-
dardized in 1942  at a ratio of 0.5
moles of EDB and one mole of  1,2-
DCA per mole of lead (Hirschler et
al., 1957; Jacobs, 1980; Lane, 1980;
Pignatello and Cohen, 1990; Thomas
et al., 1997). Aviation gasoline, used
in piston engine propeller planes,
uses only EDB, in the proportion of
one mole of EDB  per mole of lead
(Jacobs, 1980; Lane, 1980).
   Given the lead content of a gaso-
line, the concentrations of EDB and
1,2-DCA in the gasoline can be com-
puted using the molar ratios and mol-
ecular weights. Falta (2004) calculated
U.S. national average gasoline lead,
EDB, and 1,2-DCA levels  for  the
period from 1949 to 1988. Until the
U.S. EPA-mandated reduction began
in 1974, average lead levels in gasoline
were about 0.6 g/L to 0.7 g/L. These
correspond to EDB concentrations of
Table 1 Historical Lead Scavenger Ratios in Lead Antiknock
Additive Packages (from Jacobs, 1980)
(standard aviation mix)
(standard automotive mix)

                                                                                  June 2004 • LUSTLine Bulletin 47
0.27 g/L to 0.32 g/L, and 1,2-DCA
concentrations of 0.29 g/L to 0.34 g/L.
These levels dropped sharply after
1974. Lead was essentially eliminated
from automotive gasoline by 1988.
Leaded gasoline continues to be used
for aviation and for off road uses such
as racing, but these  uses currently
account for a minute fraction of over-
all gasoline consumption in the U.S.

Dissolution and Transport
The effective solubility of a gasoline
component in water is determined
primarily by its aqueous solubility
and by its concentration in the gaso-
line. EDB and 1,2-DCA have solubili-
ties of several grams per liter  in their
pure form (Table 2). As discussed
earlier, they were also present in sig-
nificant  concentrations in  leaded
gasoline, so it would be expected that
leaded gasoline spills could result in
high groundwater concentrations of
EDB and 1,2-DCA.
   The  maximum  (equilibrium)
groundwater concentration of a gaso-
line component near residual  or free-
product gasoline (LNAPL)  can be
calculated using the gasoline-water
partition coefficient,  Kp. This parti-
tion coefficient is defined as the ratio
of the concentration of the chemical
in the gasoline (Q) to the concentra-
tion of the chemical in water (Cw):
    The partition coefficient can be
measured experimentally, or it can be
estimated from the chemical proper-
ties of the component and the bulk
gasoline. Dividing the concentrations
of EDB and 1,2-DCA in gasoline by
their K   values gives the  expected
groundwater concentrations of these
compounds near residual  or free-
product  leaded gasoline (Table 2).
Comparing these concentrations to
the MCLs, it is clear that EDB and 1,
2-DCA  could  pose  a  threat  to
groundwater that is similar to that
posed by benzene (Falta, 2004).
    The chemical properties of EDB
and 1,2-DCA (Table 2) favor trans-
port in groundwater. These chemi-
cals are both volatile, but their high
solubilities in water result in very
low Henry's  constants. Chemicals
with low Henry's constants preferen-
tially partition into the water phase
instead of the gas phase. For this rea-
son, once these chemicals dissolve in
Comparison of Lead Scavenger Properties with Benzene
Molecular Weight
Aqueous Solubility
Vapor Pressure
Henry's Constant
Average Concentration
In Leaded Gasoline
Partition Coefficient
Maximum Groundwater
Concentration near a
Leaded Gasoline Release
0.29C g/L
98.96b g/mol
8,520b mg/L
0.31 c g/L
3,700 |jg/L
78.1 1b g/mol
8.00b kPa
Montgomery, 1997; "Bedientetal., 1999;cFalta, 2004; dAPI, 2002; ePignatello and Cohen, 1990;
'Clineetal., 1991
water, they would not have a ten-
dency to volatilize into soil gas, and
movement of EDB or 1,2-DCA vapors
in the vadose zone would be greatly
reduced by  partitioning  into soil
    EDB and 1,2-DCA also have very
low octanol-water partition coeffi-
cients (Table 2). The octanol-water
partition coefficient  is related to a
chemical's  tendency  to adsorb  to
aquifer materials. These low values
indicate that EDB and 1,2-DCA  do
not adsorb strongly. Both EDB and
1,2-DCA are expected to be  more
mobile than benzene, and 1,2-DCA
has a mobility in groundwater that is
similar to that of MtBE (Falta, 2004).

EDB was used as a pesticide from
1948 until 1983, when that use was
banned. As a result, laboratory and
field studies have been conducted to
document EDB degradation in soils
and groundwater. (See, for example,
Pignatello and Cohen, 1990.) Many of
these studies have found fairly rapid
aerobic and anaerobic degradation of
EDB in the subsurface, but low levels
of EDB (above the MCL) have been
found to persist  for decades  after
EDB releases (Pignatello and Cohen,
1990;  Steinberg et al., 1987). Falta
(2004) describes several large EDB
groundwater plumes at the Massa-
chusetts Military Reservation where
EDB does not appear to be degrading
significantly  (see  also  U.S. EPA,
2000a, b).
    1,2-DCA is a common industrial
feedstock and solvent, and ground-
water plumes of this chemical have
been  widely documented (Fetter,
1999;  Ravi et al., 1998;  Cox  et al.,
1998). The degradation of 1,2-DCA in
groundwater appears to occur under
both aerobic  and anaerobic condi-
tions (Cox et al., 1998; Cox and Major,
2000), but decay half lives can be long
compared  to  BTEX  compounds
(Bedientetal., 1999).
    While studies have focused on
EDB and 1,2-DCA degradation from
past agricultural or industrial uses,
we are not aware of any studies on
EDB or  1,2-DCA  degradation for
cases   involving  leaded  gasoline
releases. It is  likely that the aerobic
and anaerobic degradation of BTEX
compounds at  a LUST site  could
have important effects on the degra-
dation of EDB and 1,2-DCA, possibly
enhancing the reductive dehalogena-
tion process. This may be an impor-
tant area for future research.

Cancer Risks and Detection
U.S. EPA classifies EDB and 1,2-DCA
as probable carcinogens.  The low
MCLs for these compounds are based
on their potential for causing cancer
in humans. The lifetime risk of cancer
due to consumption of contaminated
                • continued on page 8

LUSTLine Bulletin 47 • June 2004
m Lead Scavengers from page 7

drinking water is estimated using a
slope factor, Pf, in an exponential
model that approaches 100 percent
risk at high doses:
where Cw  is the concentration in
water (mg/L), qw is the daily water
intake (L/d), and m is the body mass
(kg). The cancer risk slope factor has
units of risk (proportion of exposed
population with tumors) per mg of
contaminant per kg of body mass per
day  (U.S. EPA, 1992b).  At low risk
levels, this equation gives a linear
relationship between risk and dose
equivalent to
    Slope factors  for benzene (a
known carcinogen), EDB, and 1,2-
DCA are given in Table 3. The slope
factor can be used to calculate spe-
cific risks associated with different
drinking water concentrations. This
is typically done using the risk equa-
tion with a daily water intake of 2
Land a body mass  of 70  kg. The
drinking water unit risks in Table 3
are computed this way, and when
multiplied by the  drinking  water
concentration in ug/L, they give the
lifetime cancer risk. U.S. EPA recom-
mends that the slope-factor  model
only be used for risks that are less
than or equal to 1 in 100 because
slope at higher exposures may differ
Table 3 U.S. EPA values for Cancer Risk Assessment from
Contaminated Drinking Water
Cancer Risk Slope Factor
proportion of exposed population
with tumors per (mg/kg) per day
1. 5x1 0'2 to 5.5x1 0'2
9.1x1 0'2
Drinking Water Unit Risk
proportion of exposed
population with tumors per ug/L
4. 4x1 0'7 tot 6x1 0'6
2.6x1 0'6
aU.S. EPA (2003); bU.S. EPA (1991); CU.S. EPA (1997)
from that at lower exposures (U.S.
EPA, 1992a).
    The lifetime excess cancer risks
associated with different drinking
water concentrations are plotted in
Figure 1.  The potential cancer risk
from water contaminated by EDB is
much higher than the risk posed by
benzene at  a  given concentration,
while risk from 1,2-DCA contamina-
tion is similar to that of benzene. The
upper endpoints of these curves cor-
respond to the maximum expected
groundwater concentrations near a
leaded gasoline spill from Table 2.
Note that the risk from EDB is calcu-
lated to exceed 0.01 (dashed line), so
this upper  part  of  the risk curve
should  be  viewed  with  caution.
Nonetheless, it is apparent that dis-
solved EDB could pose a cancer risk
that greatly exceeds  the cancer risk
from benzene at sites where leaded
gasoline was released, considering
that groundwater concentrations of
EDB could easily exceed 100 ug/L.
 FIGURE 1. Calculated lifetime excess cancer risks due to consumption of contaminated drink-
 ing water. The upper endpoints of each curve correspond to maximum expected groundwater
 concentrations near a leaded gasoline spill (Table 2).
     1 .OOE-fOO
                           •  ethylene dibromide
                         	-ethylene dibromide (>0.01 risk)
                         ^K^—benzene (higher risk slope factor)
                         —£s—benzene (lower risk slope factor)
                               1      10     100    1000   10000  100000
                              Concentration, \ig/\-
    It is helpful to put these cancer
risks in perspective by considering
typical analytical methods used at
LUST sites. U.S. EPA Methods 8021B
and 8260B are commonly used to
measure BTEX concentrations, and
they can both be calibrated for EDB
and 1,2-DCA if these  chemicals are
included on  the target analyte list
(Ellis, 2003; U.S. EPA, 1996b, c). With
these  analytical methods, detection
limits for EDB range  from about 3
ug/L  for Method 8260B to about 8
ug/L  for Method 8021. From Figure
1, a concentration of 5 ug/L EDB cor-
responds to a cancer  risk just over
0.01 or 1 in 100. This risk is equivalent
to that posed by benzene at  7,700
ug/L to 28,200 ug/L. In other words,
if Method 8021 or 8260B is used to
quantify EDB at a LUST site, the can-
cer risk posed by EDB at the detec-
tion limit is comparable to that posed
by benzene near its effective solubil-
ity limit from gasoline.
    EDB concentrations in ground-
water can be quantified at  much
lower levels using U.S. EPA Method
8011 (U.S. EPA,  1992b).  This  is a
microextraction  technique  using
hexane   with  GC  analysis  with
an  electron-capture detector. This
method can achieve detection limits
as low as 0.01 ug/L.

Field Data from UST Sites
South Carolina is one of the few
states in the  country  that has rou-
tinely required testing for EDB at
sites where leaded gasoline  could
have been released. Testing ground-
water at active UST  sites for EDB
began in the early 1990s, and current
South Carolina Department of Health
and Environmental Control (SCD-
HEC) procedures specify analytical
Method 8011 with a detection limit of
0.02 ug/L (SCDHEC, 2001). We have
been working closely with the SCD-
HEC  Bureau  of Land and Waste
Management Underground Storage

                                                                                   June 2004 • LUSTLine Bulletin 47
FIGURE 2. Maximum groundwater concentrations of EDB and ben-
zene at South Carolina UST sites where EDB has been detected
above the MCL: (a) maximum concentrations; (b) maximum con-
centrations divided by MCLs; (c) maximum concentrations divided
by 10-4 cancer risk concentrations.
 Fig. 2a
 Fig. 2c
Tank Program over the past several
months in an effort to quantify the
magnitude  of  the lead-scavenger
    According to the SCDHEC data-
base, there are 7,158 sites in the state
where petroleum  product releases
have been reported. Approximately
1,280 of these have been tested for
EDB, and EDB has been detected in
the groundwater above the MCL at
316 of these sites. It is important to
                note that the gaso-
                line release history
                at most UST sites is
                unknown. In many
                cases, the tanks at
                sites with reported
                releases    would
                have   contained
                both leaded  and
                unleaded gasoline
                over time, and the
                relative  amounts
                of leaded and un-
                leaded   gasoline
                spilled   are  un-
                    Figure 2a de-
                monstrates a com-
                parison of maximum
                EDB and benzene
                groundwater con-
                centrations at sites
                where EDB  was
                detected above the
                MCL.  The  total
                number of sites in
                this   graph  (i.e.,
                269)  is   slightly
                lower  than  the
                overall number of
                EDB sites (i.e., 316)
                due  to difficulties
                in  verifying  the
                maximum benzene
                concentration val-
                ues  reported  for
                some  sites.  EDB
                range  from  the
                MCL of 0.05 ug/L
                up to a maximum
                of  several  thou-
                sand ug/L. Signifi-
                cantly, more than
                half  of  the EDB
                maximum concen-
                trations are above
                5 ug/L, and about
                one-quarter   are
                above 50 ug/L. As
                would be expected
for gasoline spills, maximum ben-
zene concentrations are higher, with
typical maximum values in the 500
ug/L to 50,000 ug/L  range.  The
upper part of this range (20,000 ug/L
to 50,000 ug/L) usually indicates that
there is residual or free-product gaso-
line nearby.
    The maximum EDB and benzene
groundwater  concentrations  have
been divided by their MCLs in Figure
2b. Because of EDB's very low MCL,
the ratio of EDB concentration to its
MCL is similar to that for benzene,
even though the actual concentra-
tions of benzene at these sites are
much  higher. Both chemicals are
found  to exceed their MCLs by fac-
tors  of 1,000 or more at many sites.
Therefore, from a regulatory perspec-
tive, the impact of EDB at these sites
may be comparable to that  of ben-
zene, assuming a similar mobility
and persistence.
    The maximum EDB and benzene
groundwater  concentrations  are
divided by their 10"4 lifetime excess
cancer  risk drinking water concentra-
tions in Figure 2c. From Table 3 and
Figure 1, the 10"4 lifetime cancer risk
occurs  at a drinking water concentra-
tion of 0.04 ug/L for EDB, and at a
concentration of 63 ug/L to 230 ug/L
for benzene. The larger concentration
value was used for benzene in Figure
2c, because it also falls into the pub-
lished  U.S. EPA concentration range
(100 ug/L to 1000 ug/L) correspond-
ing to  a 10"4 cancer risk (U.S.  EPA,
    EDB appears to pose a larger can-
cer risk than benzene at most  of these
sites. Sixty percent of the maximum
EDB concentrations exceed the 10"4
cancer risk concentration by  a factor
of 100  or more, compared to only 7
percent of the  maximum benzene
concentrations. About 30 percent of
the EDB concentrations exceed the
10"4  cancer risk concentration by a
factor of 1,000 or more, while  none of
the benzene concentrations  pose a
cancer  risk this high.
    Using these measured ground-
water concentrations, it is apparent
that the dominant drinking water
cancer risk may come from EDB
rather  than from benzene  at sites
where  leaded gasoline was released.
Of course there is little risk unless the
contaminated water is consumed, so
the length and persistence  of EDB
plumes will be a critical variable in
any site risk assessment.

Unanswered Questions
At this stage there are more questions
than answers about the magnitude of
the lead-scavenger problem. It is cer-
tain that there have been tens of thou-
sands of releases of leaded gasoline
in the United States, but the typical
size and nature of EDB and 1,2-DCA

                • continued on page 10

LUSTLine Bulletin 47 • June 2004
m Lead Scavengers from page 9

groundwater plumes  is unknown.
Many old LUST sites have never been
analyzed for EDB or 1,2-DCA, so it is
not known to what extent these com-
pounds are  still  present  in  the
groundwater at these sites. There is
little or no published information on
the breakdown of these contaminants
under the biogeochemical conditions
that would occur in and downgradi-
ent of gasoline spills, so it is difficult
to predict their long-term behavior.
    We believe that a significant new
research effort focusing on EDB and
1,2-DCA contamination at UST sites
is justified. •

 Ron Falta, Ph.D., is Professor of Geol-
 ogy and Environmental Engineering at
   Clemson University. He teaches and
    conducts research in contaminant
 transport and remediation, hydrogeol-
    ogy, and petroleum engineering.
 Nimeesha Bulsam is an M.S. student in
 Hydrogeology at Clemson University.
   For more information, email Ron at
AEHS, 2004, State Summary of Cleanup Standards,
 Association for Environmental Health and Sciences,
Alexeeff, G.V., W.W. Kilgore, and M.Y. Li, 1990, Eth-
 ylene dibromide: toxicology and risk assessment,
 Reviews of Environmental Contamination and Toxicol-
 ogy, Vol. 112, pp. 49-122.
API, 2002, Evaluating Hydrocarbon Removal from Source
 Zones and Its Effect on Dissolved Plume Longevity and
 Magnitude, American Petroleum Institute Publica-
 tion No. 4715.
Bedient, P.B., H.S. Rifai, and C.J. Newell, 1999, Ground
 Water Contamination Transport and Remediation, 2nd
 Ed., Prentice Hall PTR, Upper Saddle River, NJ.
Boyd, T.A., 1950, Pathfinding in fuels and engines,
 SAE Quarterly Transactions, Vol. 4, No. 2, pp. 182-
 195. ~
Bruell, C.J., and G.E. Hoag, 1984, Capillary and
 packed-column gas chromatography of gasoline
 hydrocarbons  and  EDB, Proceedings  of the
 NWWA/API Conference on Petroleum Hydrocar-
 bons and Organic Chemicals in Ground Water —
 Prevention, Detection, and Restoration, November
 5-7, Houston, TX, pp. 234-266.
Cline, P.V., J.J. Delfino, and P.S.C. Rao, 1991, Parti-
 tioning of aromatic constituents into water from
 gasoline and other complex solvent mixtures, Envi-
 ronmental Science and Technology, Vol. 25, No. 5, pp.
Cox, E.E., M. McMaster, and D.W. Major,  1998, Nat-
 ural attenuation of 1,2-dichloroethane and chloro-
 form in groundwater  at a Superfund  site,
 Proceedings of the First International Conference
 on Remediation of Chlorinated and Recalcitrant
 Compounds, Monterey, CA, May 18-21,1998.
Cox, E.E., and D. Major, 2000, Natural attenuation of
 1,2-dichloroethane in groundwater at a chemical
 manufacturing facility, Proceedings of the Second
 International Conference on Remediation of Chlori-
 nated and Recalcitrant Compounds, Monterey, CA,
 May 22-25, 2000.
Ellis, P., 2003, A hot dog by any other name could be
 your  drinking water, LUSTLine, New  England
 Interstate Water Pollution Control Commission,
 Bulletin 44.
Falta, R.W., 2004, The potential for ground water con-
 tamination by the gasoline lead scavengers ethyl-
 ene dibromide and 1,2-dichloroethane, in press,
 Ground Water Monitoring and Remediation.
Fetter, C.W., 1999, Contaminant Hydrogeology, Prentice
 Hall, Upper Saddle River, NJ.
Hall, D.W., and R.L. Mumford, 1987, Interim private
 water well remediation using carbon adsorption,
 Ground Water Monitoring Review, Vol. 7, pp. 77-83.
Hirschler, D.A., L.F. Gilbert, F.W. Lamb, and L.M.
 Niebylski, 1957, Particulate lead compounds in
 automobile exhaust gas, Industrial and Engineering
 Chemistry, Vol. 49, No. 7, pp. 1131-1142.
Jacobs, E.S., 1980, Use and air quality impact of ethyl-
 ene dichloride and ethylene dibromide scavengers
 in leaded gasoline, in Ethylene Dichloride: A Potential
 Health Risk?, B.N. Ames, P. Infante, and R. Reitz,
 eds.,  Banbury Report No. 5, Cold Spring Harbor
 Laboratory, Cold Spring Harbor, NY, pp. 239-255.
Landmeyer, J.E., P.M. Bradley, and T.D. Bullen, 2003,
 Stable lead isotopes reveal a natural source of high
 lead concentrations to gasoline-contaminated ground-
 water, Environmental Geology, Vol. 45, pp. 12-22.
Lane, J.C., 1980, Gasoline and other motor fuels, Ency-
 clopedia of Chemical Technology, Vol. 11, pp. 652-695.
Midgley, T., and T.A. Boyd, 1922, The chemical con-
 trol of gaseous detonation with particular reference
 to the internal combustion engine, Industrial and
 Engineering Chemistry, Vol. 14, No. 10, pp. 894-898.
                 • continued on page 23
                             EPA/ASTSWMO Form  Team  to
              Delve  Into  EDB  and  1,2-DCA  in Groundwater
           Many state drinking water
           programs are finding eth-
           ylene  dibromide  (EDB)
 and 1,2-dichloroethane  (1,2-DCA)
 compounds in their water supplies.
 Both compounds were added  to
 leaded gasoline as lead scavengers
 until the late 1980s, when leaded
 gasoline was phased out. Both com-
 pounds have also had other uses—
 EDB  was  widely  used  as  an
 agricultural  fumigant  until it was
 banned in 1983, and 1,2-DCA is still
 used as an industrial solvent.  Both
 of these  compounds have federal
 maximum   contaminant   levels
 (MCLs) in drinking water—0.05 ppb
 for EDB and 5.0 ppb for 1,2-DCA.
     Given  the discussion  that has
 recently occurred regarding the cur-
 rent and historic use of EDB and 1,2-
 DCA, the Association of State and
 Territorial Waste Management Offi-
 cials (ASTSWMO) and  U.S.  EPA
 have a formed a team to explore the
 use  and  occurrence  of  these com-
 pounds and their potential impacts
 at LUST sites.
    Although  these   compounds
have not been used as gasoline addi-
tives for more  than a decade, as
information  in  the  article  "Lead
Scavengers:  A  Leaded  Gasoline
Legacy?" suggests, the possibility
exists  that these compounds  may
persist in the environment and affect
drinking water supplies. Since these
compounds have had other uses,
especially EDB  as an  agricultural
fumigant, the source of lead scav-
engers in the environment is unclear.
    To determine what problems, if
any, these lead  scavengers pose to
public health and the environment,
the  team  will take the  following

  •  Develop an understanding of
    the  potential  problem  as  it
    exists today.

    •  Compile existing background
       data, historical usage infor-
       mation,  and occurrence in
       drinking water supplies
   • Evaluate selected state data-
     bases  and  case  files   for
     information  on   sampling,
     monitoring, and remediation
     at LUST sites
   • Conduct a study on the effec-
     tiveness and cost of treatment
     and remediation technology
•  Assess whether or not there are
   any gaps in our current knowl-
   edge. If so, develop and imple-
   ment appropriate measures to
   fill the gaps.

   • Identify next steps. Evaluate
     the results  of the previous
     two steps. •
   for more information on this
  effort, contact Hal White, U.S.
    EPA Office of Underground
         Storage Tanks, at or (703) 603-
  7177. A copy of the team's full
  mission statement is available
     on the OUST Web site at:

                                                                          June 2004 • LUSTLine Bulletin 47
Oil-Site, Oil-Line Calculators
and  Training for Subsurface
Contaminant-Transport  Site
by Jim Weaver

     EPA has developed a suite of on-
     line calculators called "OnSite"
     for assessing transport of envi-
ronmental contaminants in the sub-
surface.  The  purpose  of  these
calculators is to provide methods
and data for common calculations
used in assessing impacts from sub-
surface contamination by petroleum
hydrocarbons and oxygenated addi-
tives. The calculators each contain
background information and a guide
to their formulas and data. The cal-
culators are available on the Internet
at athens/onsite.
They are divided  into  four cate-
gories, Model Input Parameter Esti-
mates, Simple Transport Models,
Unit Conversions, and Scientific
Demos, which include the following

Model Input Parameter

  • Hydraulic gradient (horizontal)
  • Vertical gradient
  • Moisture content in a sample
ultimately more scientifically sound
decision making. Web-site usage sta-
tistics show that even the simple cal-
culators are used frequently.
   A somewhat different class of
calculation is  represented  by the
effective solubility calculator, which
determines concentrations of chemi-
cals  in equilibrium with various
fuels. In contrast to the retardation
factor, the formula itself is much less
well-known, and the required input
data are not commonly available. In
this case, the calculator provides a
resource to the community as the
ability to calculate this quantity is not
expected to be widespread.
   The gradient is an example of the
formula calculators. Determining the
direction of groundwater flow is fun-
damental  in  assessing  potential
receptors. Figure 1 shows results for a
site with four wells that was sampled
over  six sampling rounds. These
data, which were confined to a small
area of the station property, did not
adequately allow determination of
the groundwater flow direction. Fig-
ure 1 shows indicated flow directions
which  ranged  from  90 to  270
degrees—essentially east to west. The
easterly directions occurred with the
lowest magnitude of gradients and
thus are the least certain.

Simple Transport Models
 • Plume diving
 • Steady plume length
 • One-dimensional transport from
   a pulse, continuing, or fuel
 • "Domenico" models: steady state
   centerline, unsteady
 • Uncertainty in transport calcula-
 • Vapor intrusion calculations with
   the Johnson-Ettinger model
   In this section, simple transport
models are provided for several sce-
narios. Research conducted at some
contaminated  sites showed that
plumes were pushed  downward,
rather than diluted. Development
and testing of assessment methodolo-
gies provided software for predicting
this behavior. Providing an on-line
calculator (plume diving) placed this
technology directly into the hands of
the  leaking underground storage
tank community.
              • continued on page 12
 FIGURE 1.  Groundwater flow magnitude and direction from a site with four wells sampled
 over six sampling rounds.
• ixeictructuoii ictcior
• Henry's constants
• Estimated longitudinal disper-
• Diffusion coefficients in air and
• Darcy's law
• Seepage velocity
• Effective solubility from fuels
• Multiphase mass distribution
Some of the parameter-estimation
calculators are designed to make sim-
ple calculations more convenient,
while others are designed to make
less well-known calculations more
commonly available. Even for experi-
enced analysts, the availability of
prepackaged calculations is viewed as
a convenience. Beyond obvious labor
savings, "convenience" facilitates cor-
rect application of the principles and




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180 -

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LUSTLine Bulletin 47 • June 2004
m On-Line, On-Site Calculators
from page 11

    Other calculators address conta-
minant transport. One of the newest
models  addresses  uncertainty  in
transport models. Given that model
inputs are uncertain, the impact on a
groundwater receptor can be deter-
mined  and a  guide to worst-case
parameter sets can be provided.
    As an example, the plume-diving
calculator was applied to the BTEX
and MtBE plume at East Patchogue,
New York.  To apply the calculator,
the water table was fitted to observed
data, and the amount of plume div-
ing was simulated by estimating the
recharge along the plume and other
aquifer properties.  Figure 2  shows
the fitted water table ("A"), the esti-
mated top of the plume ("B"), and
MtBE, benzene, and xylene plumes.
Wells  must be screened to depths
below the line "B" for the plumes to
be sampled at an appropriate depth.

Unit Conversions

  •  Flow rates
  •  Hydraulic conductivity
  •  Half lives/rate constants
  •  Henry's law constants
  •  Dates/sequential times
  •  Latitude-longitude to distance
  •  Degrees C to Fahrenheit
    Some unit conversions are fairly
unique to this field and misunder-
standing of  the several common unit
sets may cause problems for  site
assessment. Henry's law coefficients
are often given either as a dimension-
less constant or in units of pressure
divided by solubility. The numerical
magnitude of these constants differs
greatly. Similarly, a large group of
practitioners use units of centimeters
per second for hydraulic conductiv-
ity, while others understand  values
better in other unit sets such as feet or
meters per day.

Scientific Demos

  •  Darcy flow in a laboratory col-
  •  Unsteady mass balance
  •  Flow in a one-dimensional aquifer
  •  Borehole-concentration averaging
    These calculators  were  devel-
oped as aids to  a modeling  course

 FIGURE 2. Vertical cross section through the xylene (a), benzene (b,c) and MtBE (d,e) plumes
 at East Patchogue, New York. The flow, from left to right, is influenced by recharge, which
 causes the plume ("B ") to be pushed below the water table ("A ").
         40 -i
  -I    -40
  m    -80 H
 n^              i
4000           2000
  Distance (ft)
 Figure 3. Borehole-concentration averaging. Concentration data from a multilevel sampler
 are plotted with depth (red line) along with a representation of the well screened at a user-
 supplied depth.
 •f Label Drawing ?
 S elect F'ararneters:
   jj	Reset
      Ignore Conductivity Variation ?
 Range of Measured Values
 Estimated Borehole Concentration =
that has been taught to state regula-
tors and consultants since 1997. Aver-
aging in boreholes  is illustrated in
Figure 3, where concentration data
from a multilevel sampler are plotted
with depth (red line) along with a
representation of the well screened at
a user-supplied depth. The calculator
shows how the position and length of
the screen  influence  the apparent
concentration, which can differ sig-
nificantly from the highest concentra-
tion in the formation.
    Beginning this year, the course,
"Modeling Subsurface Transport of
Petroleum Hydrocarbons," can be
found at
learnlmodel.  Ideas for new calculators
      are developed from suggestions from
      users and in response to requests for
      information. These have come from
      state agencies, U.S. EPA regional and
      program offices, and the private sec-
      tor. Contact Jim Weaver at weaver. to discuss these concepts
      or suggest new ideas. •

       Jim Weaver, Ph.D., is with the Ecosys-
          tems Research Division of EPA's
       National Exposure Research Laboratory,
         Office of Research and Development
       (ORD), in Athens, Georgia. He can be
          reached at
       This paper his been reviewed in accordance with
       the U.S. Environmental Protection Agency's peer
            and administrative review policies
              and approved for publication.

                                                                                June 2004 • LUSTLine Bulletin 47
                    Tracking Troubling Vapor Releases
                    in New Hampshire
                   by Gary Lynn
       New  Hampshire   regulations
       require routine groundwater
       monitoring whenever ground-
water quality standards are exceeded.
Because of this requirement, the state has
gained a  considerable  database  of
groundwater quality information  at
operating gas  stations where releases
have been identified. About four years
ago, the Department of Environmental
Services (DES) started to observe a trend
at many operating gas station sites in
which the concentration of MtBE was
increasing and all other contaminants
were stable  or decreasing. DES  con-
cluded that an ongoing release of MtBE
was occurring at these sites and imped-
ing site remediation and closure. To help
troubleshoot this problem, we began to
track all of these ongoing release sites.
We also began to  investigate whether
other states have observed and addressed
this issue. (Also see LUSTLine  #46,
March 2004, "Enhanced Leak Detection
in California—What We've Learned,"
by Randy Golding.)

Putting the Facts Together
Our  review of existing studies and
fieldwork  turned up  several very
interesting investigations:
• Santa Clara Valley Water District
A pilot study was commissioned to
determine whether there were unde-
tected releases of MtBE present at
1998 upgrade-compliant gas stations.
The  Water  District study (July 22,
1999) found MtBE contamination of
groundwater at 13 of the 27 sites that
were investigated. MtBE was  the
only petroleum constituent found in
five of the 13 contaminated sites. The
Water District attempted to statisti-
cally correlate the presence of conta-
mination with the various types of
UST system components present at
each site. The analysis concluded that
there was a statistically significant
association between the occurrence of
MtBE contamination and the pres-
ence  of a vacuum-assist Stage II
vapor-recovery system. DES believes
this study is significant because the
only plausible link between vacuum-
assist Stage II equipment and MtBE
groundwater contamination is the
existence of vapor releases, (http://

• University of California at Davis
and Tracer Research A joint report
on  an  UST System  Field-Based
Research Project was submitted on
May 31, 2002, to the California State
Water Resources  Control  Board.
Report.pdf.) The study evaluated the
occurrence and environmental signif-
icance of very small releases from
1998 upgrade-compliant  UST  sys-
tems. The researchers tested 182 UST
systems by inoculating the systems
with tracers and then collecting sub-
surface vapor samples and analyzing
them for the presence of the tracers.
    Detectable levels of tracers were
found at 61 percent of the tested sys-
tems. All but one of the tracer detec-
tions  were  judged to have  been
associated   with  a  vapor-phase
release. In addition, the study noted
that none of the releases observed
would likely have been detected by
leak-detection systems that meet cur-
rent performance standards of 0.1
gallons/hour. This study strongly
indicates that vapor releases com-
monly occur but are infrequently
detected by routine measures.
    The study also draws a distinc-
tion between balance and vacuum-
assist  Stage II  vapor  recovery
systems. Both types of systems are
found to produce positive tank pres-
sures during deliveries. According to
the study, the assist system "is more
likely to lead to pressurization of the
UST ullage space for longer periods
because of the tendency to return a
larger volume of air to the tank than
the volume of liquid product with-
drawn." In fact, a number of Stage II
vacuum-assist systems specify air-
return to liquid-removal ratios of 1.0
to 1.2.
    The study found a similar per-
centage of vapor-release detections
for  balance and assist Stage  II sys-
tems,  but  the  average detected
concentration of tracer was approxi-
mately 2.6 times higher for the assist
systems. The detection percentage
should be approximately the same
for   balance  and  assist  systems
because there is little difference in the
below-grade components of the two
systems; however,  the leak rate  for
the  vacuum-assist system would be
greater because of the greater operat-
ing  pressure within the system.

• Vermont Over the last two years,
the  Vermont UST program has been
routinely  assessing the  presence,
source,  and significance of  vapor
releases at operating UST facilities
with ongoing remedial groundwater
monitoring. The methodology  uti-
lizes a hand-held, direct-read vapor
measuring instrument, typically a
photo-ionization detector (FID), to
measure vapor concentrations in  the
vicinity of readily accessible tank-top
fittings. Measurements are usually
conducted as  part of a routine UST
compliance inspection.
    The vapor-concentration read-
ings can help  pinpoint potential
vapor-release   source   locations.
Volatile organic compound  (VOC)
concentrations ranging from 2.0 to
200 parts per million (ppm) have
been measured  in the vicinity of
tank-top features under normal oper-
ating conditions. Under pressurized
(delivery event) conditions, VOC
emissions concentrations show a sig-
nificant increase. Based on this infor-
mation, the Vermont UST program
has  determined that  the primary
vapor-release sources from operating
USTs are vent lines, ancillary risers,
caps, in-tank monitor wiring fittings,
and Stage I vapor-recovery poppets.
In general, any tank-top component
that could allow the emission of
               • continued on page 14

LUSTLine Bulletin 47 • June 2004
m Tracking Vapor Releases in NH
from page 13

VOCs under primary-tank pressur-
ization  is  considered a  potential
source of hydrocarbon vapors  that
could contribute to groundwater con-

• New Hampshire MtBE concentra-
tions found in reformulated gasoline
(RFC) are typically 9 to 11.5 percent
in New Hampshire. The MtBE  con-
centration in gasoline vapors is even
higher because the vapor composi-
tion emanating from a mixture of
chemicals like gasoline is dependent
on the mole fraction of each compo-
nent in the liquid phase and the pure-
phase  vapor  pressure   of  each
component. MtBE has a pure-phase
vapor pressure that is much higher
than other key constituents of  con-
cern (e.g., BTEX compounds).
    The combination of high MtBE
vapor pressure and high MtBE  con-
tent in RFC results in a vapor-phase
composition that is significantly
enriched in MtBE. There  is a good
discussion of this phenomenon and
calculation of the anticipated concen-
tration  of  MtBE in an  article by
Blayne  Hartman in LUSTLine  #30,
"The Great Escape."
    DES also found a Finnish analysis
that compared the composition of
regular gasoline and vapors in equi-
librium with the gasoline that indi-
cated a nearly three-fold increase in
the concentration of MtBE in the
vapor phase compared with the liq-
uid phase, (
2002/isbn951-802-491-X.pdf.) The take-
home message from these data is that
the composition of a vapor release of
MtBE-based reformulated gasoline
will include a very substantial MtBE

Vapor Releases and Tank
Based  on  the  information  we
reviewed,  we  decided that  vapor
releases could potentially explain the
data trends that were being observed
at our LUST monitoring  sites. We
decided that further investigation
was necessary to evaluate  vapor
releases from active USTs and set out
to explore the effects of tank pressur-
ization on vapor-phase releases.
    A working hypothesis was devel-
oped postulating that a combination
of the physical properties of MtBE,
the operating pressures found  in
Stage II tank systems, and leaks in
tank tops and tank-top fittings was
creating the elevated MtBE levels in
groundwater at our monitored LUST
sites. We conducted an investigation
to evaluate this hypothesis and estab-
lish the relationship between vapor
releases, UST system operating pres-
sures, and MtBE groundwater conta-
   To conduct  this investigation,
DES installed pressure-monitoring
equipment and a data logger on five
operating UST systems. The pressure
was  then monitored continuously
and recorded in each of the UST sys-
tems for approximately one week.
The   UST   systems   monitored
included a balance and four vacuum-
assist Stage II installations. DES con-
firmed a number of the results and
conclusions found in the California
field-based study, including the fol-
  • The monitored UST systems rou-
   tinely showed positive operating
   pressures  ranging  from just
   above  atmospheric  to  three
   inches of water column (the pres-
   sure-relief setting of the tank
  • The vacuum-assist tank systems
   in two of the  four systems moni-
   tored   showed   significantly
   higher pressure levels than  the
   balance system. The  other two
   vacuum-assist systems had rela-
   tively low operating pressures
   and  additional follow  up  is
   required  to determine whether
   the vacuum-assist systems were
   fully operational or operating at
   very low air-to-liquid ratios. The
   low level of pressure (except dur-
   ing deliveries) in the UST with a
   Stage II  balance  system was
   expected  because balance sys-
   tems use the slight positive pres-
   sure generated by adding fuel to
   a car's gas tank and a low-level
   vacuum in the UST  system to
   recover vapors created during
   car fueling.
  • The two Stage II vacuum-assist
   systems that showed positive
   pressures  showed daily cycles
   (accumulated pressure during
   the day because of fueling activi-
   ties and lost pressure at night,
   presumably  because of vapor
    releases). Both of these systems
    had six-figure MtBE contamina-
    tion in groundwater.
  •  All  observed  delivery  events
    resulted in strong pressure oscil-
    Figure 1 is an example of a vac-
uum-assist system pressure chart that
was generated during the research.
The data indicate that  the pressure
gradients that  are  integral  to the
operation of this Stage II vacuum-
assist system, in combination  with
the significant vapor-phase concen-
tration of MtBE, are a plausible expla-
nation for the MtBE contamination
observed  in groundwater for this
LUST site. Note: Each  tank-system
pressure profile  is different.  The
other vacuum-assist system  with a
known MtBE release exhibited much
larger daily pressure cycles (ranging
from  atmospheric to 3.5 inches of
water column), possibly because the
tank system was tighter.

The Vapor Release/
We decided that it was  important to
go  beyond  showing  that  vapor
releases were a plausible explanation
for what was being observed. We
decided to closely study one of our
ongoing release sites to see whether
manipulating the pressure in the UST
system would affect the MtBE con-
centration in the groundwater out-
side the UST system. We chose to
investigate an existing operating gas
station site with a well-established,
increasing MtBE concentration trend.
Pressure-monitoring   information
showed that the vacuum-assist sys-
tem was causing positive tank pres-
sures. Daily pressure cycles seemed
to indicate that the system lost pres-
sure overnight due to leakage. Note:
A review of multiple pressure-decay
tests  conducted  at   the  facility
revealed that the facility lost an aver-
age of 0.4 inches of water column of
pressure in just 10 minutes (each test
passed, but typical tests  passed by
just 0.1 inches of water column).
    The enhanced Tracer Tight test-
ing method was used on the tank sys-
tem to evaluate its  tightness. A
different tracer was added to  each
grade of gasoline and the release of
tracer was evaluated by sampling soil

                                                                                   June 2004 • LUSTLine Bulletin 47







fapor Release Research, New Hampshire
JST pressure (in inches of water column) vs. time

, — Pressure
/ Delivery Spike

, ji.j ,
fft 	 ^f^Juflf1^ ^..jpi^fPH^ ji{Pt*'t*fU'.^t*Tl ^"^irt,. , / '11!'**>t -r ^'«
\ V \ ' V
\ \ "
\ \ /
\ \ '
\ \ /
i — Positive .. Pressure /
DaV ouernjflht • /



'Hf^fT.-^TfTf t-i *r 'r> •'*-•:-- r-_ p».«
vapor adjacent to the storage system
and  testing it for the presence of
hydrocarbons and the tracer com-
pounds.  Concentrations of tracer
indicated that the super gas tank had
the most significant release, and the
regular tank also showed a release,
although almost an order of magni-
tude less than the super tank. We
compared the characteristics of the
release with the criteria used to eval-
uate the vapor-versus-liquid releases
in the California field-based research
study. The release exhibited the char-
acteristics of a vapor release (i.e., rela-
tively  low ratio of  total  volatile
hydrocarbons compared to tracer).
    DBS next evaluated the leakage
rate of the tracer after manipulating
tank-system pressures. For the pur-
pose of the research being  conducted,
DBS elected to utilize a commercially
available system designed to continu-
ously maintain the pressure inside
storage systems at or slightly below
atmospheric pressure. The technol-
ogy, supplied by OPW, and known
as a Vaporsaver, uses membrane sep-
aration technology  to concentrate
and condense gasoline vapors in the
storage tank, essentially filtering the
gasoline out of the air in the tank. The
gasoline-free air is exhausted to the
atmosphere, thus controlling the tank
pressure, while  liquid gasoline is
returned to  the tank. The vapor
processor is automatically controlled
by a pressure sensor to create an
average net negative pressure in the
tank. No repairs or other changes in
the UST equipment or operations
were  made;  all of  the  changes
observed in tracer releases from the
storage system were the direct result
of controlling tank-system pressures.
    The tracer test was repeated with
a different tracer after the Vaporsaver
system was installed. There was a
significant reduction  in the  tracer
concentrations observed in soil gas in
total volatile hydrocarbons in the
vicinity of the USTs was observed.
    DBS is evaluating the long-term
reliability of the Vaporsaver technol-
ogy. DBS believes that eliminating
the pressure in tank ullage spaces
will eliminate the driving force for
vapor releases and minimize gasoline
vapor  leakage rates—based on the
immediate impact in soil-gas contam-
inant levels  surrounding the tank
system observed at our test site after
the pressure was controlled.
    Groundwater at the experiment
site is being monitored  to determine
whether the changes in tank-system
operating pressures will also reduce
the high levels of MtBE groundwater
contamination observed  in nearby
wells. As can be seen in Table 1, dra-
matic reductions in MtBE concentra-
tions were observed in samples taken
approximately two months after the
Vaporsaver unit reduced UST system
operating pressures (February 18,
2004 was the date of system start-up).
All overburden wells near the USTs
had significant MtBE concentration
reductions; the only wells near the
tank system that did not see reduc-
tions were  the two deep wells that
are screened in bedrock. DES believes
these wells will respond more slowly
than the overburden wells.
Groundwater trends in wells adjacent to the tank installation
Monitoring Well
of MtBE in ppb
of MtBE in ppb
of MtBE in ppb
of MtBE in ppb
2 months after
start-up (4/21/04)
71 4 (96% reduction)
4,320 (97% reduction)
91 ,400 (66% reduction)
the vicinity of the tank system. The
reduction  in  tracer  levels   was
observed  at  nearly every sample
point. It should be noted  that the
Vaporsaver minimized but did not
eliminate the development of posi-
tive pressures during tank  delivery
(it kept up with normal operations
but not the spike in pressures that
occurs during a delivery) and that
there were periods of system down-
time caused by a combination of belt
and electrical problems. As a result,
DES did not observe a total elimina-
tion of the release of tracer; however,
a significant reduction in tracer and
    The  concentrations  of  MtBE
detected in wells JB-13/MW and JB-
14/MW were the lowest detected in
those wells since they were installed
in 1998. It should be noted that these
reductions were achieved during a
time period when  the Vaporsaver
unit was not operating full time due
to operational difficulties that have
since been resolved. DES  believes
that the data establish an extremely
strong relationship between tank-sys-
tem operating  pressures,  vapor
releases, and groundwater contami-
nation,  since  MtBE groundwater

               • continued on page 16


LUSTLine Bulletin 47 • June 2004
m Tracking Vapor Releases in NH
from page 13

contamination reductions occurred
solely because of the  reduction  in
tank-system pressure.

Follow-Up Analysis of
Ongoing Release Sites
Upon review of the data generated
by this research project, we decided
that it would be valuable to review
our  list of ongoing  release sites
(based on upward trends in ground-
water contamination by one or more
of the contaminants) versus the type
of Stage II system present at the facil-
ity. We compared the distribution of
Stage II systems for all of our LUST
sites at operating gas stations with
the distribution of systems believed
to be ongoing release sites.
requested that the consultant collect a
sample of the vapors from the influ-
ent of the SVE system when the PID
readings spike after a gasoline deliv-
ery. MtBE was detected at 415,000
ug/m3 in the sample. The next high-
est concentration detected was nearly
an order of magnitude lower (toluene
at 52,700 ug/m3).
   The consultant is slated to return
to the site for the next gasoline deliv-
ery to develop an accurate estimate of
the mass released via the potential
vapor leak during gasoline delivery.
Although the  fast response  time
seems inconsistent with a delivery-
induced liquid release, DBS intends to
evaluate this possibility by conduct-
ing an in-depth inspection and evalu-
ation of the tank system. We hope to
identify the cause of the release and
learn  more about the potential for
new nampsmre LUOI sues vs. ongoing release sues
Stage II system
Vacuum Assist
% of active LUST sites
47% / 253 sites
11% 761 sites
42% 7225 sites
% of ongoing release sites
14% 712 sites
9% / 8 sites
77% 779 sites
    As shown in Table 2, gas stations
that are exempt from Stage II system
requirements are significantly less
likely to experience ongoing releases,
and the vacuum-assist system sites
are much more likely to do so. This is
strong evidence that vapor releases
are responsible for the  increasing
concentrations of MtBE observed in
groundwater at ongoing release sites.
DBS believes that this is because vac-
uum-assist systems are more likely to
have  higher average  tank-system
pressures, based on our observations
at two of the four systems evaluated
and an understanding of vacuum-
assist system operation.
    Although our analysis of avail-
able data indicates that most of  the
exempt  systems  do  not  exhibit
increasing MtBE groundwater conta-
mination  trends,  DBS  does  not
believe that the Stage II-exempt sys-
tems   are   immune  from  vapor
releases. We have a Stage II-exempt-
tank system that is surrounded by a
soil vacuum extraction (SVE) system
with an extraction  point located in
the tank-system backfill. The consul-
tant has observed spikes in PID read-
ings at the SVE system immediately
following gasoline deliveries. DES
vapor  releases  during  deliveries.
Although the mass released is likely
to be small, DES notes that it was suf-
ficient to threaten nearby  private
drinking water wells and forced the
state fund to pay for the installation of
the SVE system.
    These data indicate that there are
at least small, episodic releases of
vapors from any system that is not
vapor tight, since all observed sys-
tems  had  tank-system  pressure
spikes during gasoline deliveries. It
should be noted that these spikes are
brief in duration (approximately 5 to
15 minutes) and thus do not consti-
tute a release of the same volume of
vapors as when a system is continu-
ously operating under positive pres-
sures. The much lower mass that is
released results in much lower con-
centrations of MtBE in groundwater,
making DES reviewers less likely to
associate these spikes with ongoing

The Pressure of It All
Based on a review of existing studies
and DES data, it appears that vapor
releases are common at operating gas
stations. Additionally, DES data indi-
cate that this class of release poses a
groundwater contamination  threat
when MtBE is present in significant
concentrations in the gasoline. The
environmental significance of these
releases depends on a number of fac-
tors, including the size of the release,
gasoline composition, site-specific
geology, hydrogeology (e.g., depth to
groundwater,  groundwater  flow
velocity), and the presence of sensi-
tive receptors.  New Hampshire is
particularly vulnerable with its high
water table, its heavy use of ground-
water, and the relatively high concen-
tration of MtBE in gasoline supplied
to much of the state.
    The potential  for  releases is
dependent on tank-system installa-
tion practices and other factors; how-
ever, the vapor release rate is highly
dependent on tank-system operating
pressures. Vapor releases should be
evaluated as a  source of ongoing
releases at all active gas stations with
Stage II systems, especially vacuum-
assist Stage II systems, and  tank pres-
surization should  be minimized to
the extent practicable. Minimization
of tank pressures will reduce vapor
release rates.
    None of the  releases at ongoing
release sites were detected using con-
ventional leak-detection equipment
and technology. In fact, at most of the
sites where DES requested the identi-
fication and elimination of observed
leaks, the source of the release was
not identified using the traditional
leak-detection methods, such as pres-
sure decay and line-leak  detection
testing. This strongly suggests that
the existing leak-detection methods
do not detect vapor releases and that
the allowable leak rates specified in
the UST rules  are larger than  the
releases that are typically present.
The data strongly indicate that signif-
icant MtBE plumes can result from
these undetected releases and that
better  leak-detection methods  are
required to prevent MtBE contamina-
tion of groundwater.
    Although it appears that New
Hampshire's recent legislative MtBE
ban could address much of the vapor
release problem, as a state, we must
deal  with  our current  situation
because the ban will not take effect
unless U.S. EPA  approves of  the
state's efforts to  opt out of reformu-
lated  gasoline. Additional research
                • continued on page 30

                                                                                       June 2004 • LUSTLine Bulletin 47
                         -jnicaf/y  Speaking
                              by Marcel Moreau and Ken Wilcox
                                        Marcel Moreau is a nationally recognized
                                       petroleum storage specialist whose column,
                                        Tank-nically Speaking, is a regular feature
                                         o/LUSTLine. In this issue Ken Wilcox,
                                         President ofKWA, Inc., specialists in
                                          third-party testing of leak detection
                                         equipment, is Marcel's co-author. As
                                         always, we welcome your comments and
                                        questions. If there are technical issues you
                                        would like Marcel to discuss, let him know
The  Limits of
Leak Detection
              .yane. . .
    ...In the Land of Leaks, the King had
had enough. He had gotten used to leaky
faucets that ran continuously no matter
how tight he turned the faucet handle,
leaky bathtubs that drained out long
before he was ready to end his soak, and a
leaky fishbowl that kept his goldfish anx-
ious that his servants would not arrive to
refill the water before it drained out of the
fishbowl. The King had accepted as a fact
of life that his roof would always leak
onto his crown when he sat on the royal
throne, that the royal limousine  would
always be plagued with flat tires, and
that the royal soup bowl would forever
dribble onto its saucer.
     "Thank heavens for secondary con-
tainment, " he sighed in the midst of a
state dinner, thankful that the rich red
tomato soup leaking from his bowl into
his saucer would remain there  rather
than flow into his royal lap.
    The situation had not always been
so, but all memory of a leak-free time had
long ago faded into the dustbins of antiq-
uity. The royal records showed that the
King's great-grandfather had terminated
all maintenance in the kingdom to save
money and keep more gold in his coffers.
But the old King's mandate had acquired
a life of its own. People had just gotten
used to the results of poor maintenance
and had come to believe it was the only
way things could be.
    But on this day, the King had had
enough. He was wearing his favorite
white silk shirt and drinking a blueberry
smoothie. He had forgotten to don the
royal bib that was standard attire in the
kingdom. As he put down his goblet, he
spotted a chain of purple drops dripping
down the front of his shirt. He had had a
long rainy day,
dodging  drips
throughout   the
castle, enduring
the drops on his
head through the
interminable coun-
cil meeting, slogging
though  the  soggy
courtyard in his leaky
rubbers,  and    his
patience was short.
The blueberry medal-
lions decorating the
front of his shirt  simply
put him over the edge.
     "Call the Minister of Science and
Technology," he roared.
    The Minister arrived at a run and
out of breath.
     "I've had enough," said the King.
"From this day forward, I declare that there
shall be no more leaks in my kingdom. "
    The Minister of Science and Tech-
nology knew better than to argue with
the King when he was in this mood, so he
bowed and said, "Yes, your  majesty,"
and shuffled off on his mission to elimi-
nate leaks.
    A few months later, the King asked
his Minister of Science and Technology
for a progress report. He had noted just
that morning that although many things
had improved and the royal goldfish were
considerably more relaxed, his bathroom
faucet still exhibited a drip.
    '"Well, your majesty, we have made
remarkable progress. I believe your order
to eliminate  leaks has  been  accom-
plished," beamed  the Minister of Science
and Technology.
    "But," said the King, raising an eye-
brow, "why does my royal faucet still
    "Oh," said the Minister, somewhat
befuddled.  "As your highness has noted,
that is not a leak, that is a drip. "
    The King began to fume, thinking
his minister was playing word games
with him. '"What do you mean it is only a
drip, and therefore not a leak? I ordered
all leaks to be eliminated,  and  that
includes drips!"
     "Yes, your majesty," sighed the
Minister of Science and Technology, and
he dispatched a royal plumber to see to
the King's faucet.
    By the next week, the King was
pleased to note that the drip in the royal
sink had stopped. However, he noted that
the rim of the spout was showing a little
rust staining. The Minister of Science
and Technology came to investigate. He
donned a glove, smeared a little yellowish
paste on his index finder and touched the
tip of the faucet spout. The paste turned
bright red.
    "What's that?" asked the King.
    '"Water-finding  paste," said  the
Minister. "The change in color indicates
that there is water on the tip of the spout.
                 • continued on page 18

LUSTLine Bulletin 47 • June 2004
m Limits of Leak Detection from
page 17

I believe this indicates that water is still
weeping out of this faucet. "
    "What?" blurted the King. "I said I
want no more leaks!"
    "That's right," said  the Minister.
"We have eliminated leaks  and drips, but
I didn't know you wanted to eliminate
weeps as well. "
    "Well, I do," bellowed the King.
"See that you do it. "
                > a   ea
    The Minister of Science and Tech-
nology wept. His engineers had found it
relatively  simple,  though somewhat
expensive, to eliminate leaks. They had
groaned somewhat when he had asked
them  to eliminate drips, but they had
risen to the challenge and found ways to
do it.  He was sure that getting them to
eliminate weeps was going to take some
serious coddling and cajoling on his part.
    With some trepidation, he convened
all of the kingdom's ministers to see what
solutions  they might  come  up with.
"...So we need to eliminate weeps as well
as leaks and drips," he said to the assem-
bled group. As anticipated, a chorus of
groans arose from  the engineering staff.
    "When  is this going to  stop?"
demanded the  Minister of Standards.
"Every time we jump  over the bar, the
King  raises it.  We can't keep jumping
higher forever!"
    "The  King has spoken," said the
Minister of Science and  Technology.
"We must eliminate leaks. "
    "But what is the King's definition of
a leak?" asked the  Minister of Communi-
    "Aye," said the Minister of Science
and Technology, "there's the rub. "

Back in The Land of LUSTs...
Our frustrated king has unwittingly
created a dilemma for his ministers.
The king wants no leaks. The minis-
ters, however, need boundaries, lim-
its, and a  concrete definition of what
is to be achieved. For engineers to
even  begin to consider a  problem
such as building a bridge, they must
know the span  of the chasm to be
crossed, the weight  and number of
vehicles to be transported across the
bridge, the nature of the  geologic
materials  that  will  support  the
bridge, and the properties of the
materials that will be used to con-
struct the bridge.
    To achieve any engineering goal,
or arguably, nearly any goal, we need
to have parameters. We must have a
clear definition of the goal so that we
know  what we're  up against  and
know when we've reached it. Indeed,
defining the goal is often one of the
thornier issues that must be resolved
before  progress toward meeting that
goal is  possible.

In Days of Yore
The history of UST leak detection in
the United States provides a concrete
example of the need to  carefully
define  goals. Leak-detection vendors
in the 1980s made many outlandish
claims about the accuracy of their
equipment. They  could   do  this
because at the time there  was only
the following simplistic goal that had
been promulgated by the  fire code:
You must be able to detect leaks of
0.05 gallons per hour, taking  into
account temperature changes in the
product during the test.
    There was no standard way of
determining the accuracy of vendors'
claims, and many vendors "proved"
the accuracy of their equipment at
trade show venues by demonstrating
how they could measure remarkably
small leaks in small plexiglass tanks
holding a  few  gallons of colored
water.  That the demonstration bore
little resemblance to the reality of try-
ing to  accurately measure similarly
small leaks in the dynamic environ-
ment of a 10,000 gallon underground
gasoline storage tank was not even
recognized, let alone given any con-
    U.S. EPA's "Edison Study," con-
ducted in the mid 1980s, brought a
rude awakening to most leak-detec-
tion vendors; the results showed that
most claims of tightness-test accuracy
were not much more than wishful
thinking. The problem of a fuzzy goal
was remedied somewhat when the
federal tank regulations went  into
effect in December 1988. The rules
specified not only a detection leak
rate, but also a probability of detec-
tion, a  probability of false alarm, and
a list of factors influencing  tightness-
test results that had to be considered
when conducting a tightness test. The
regulations further resulted in  the
publication of  protocols to use to
evaluate  whether  leak-detection
equipment could in fact  meet  the
specifications of the regulations.
    With the  problem  more  com-
pletely defined, it became a relatively
simple task to engineer equipment
that would conform to the  goals
described. Through the 1990s, hun-
dreds of leak-detection methods were
developed and evaluated against the
standards set in the federal rules.

That Was Then, This Is Now
But now we are in a new century. The
leak-detection standards established
some 16 years  ago are still the law of
the land. Back  then, we measured PC
processing speeds in megahertz and
memory capacity  in  megabytes.
Today we are  talking gigahertz and
gigabytes—speeds and capacities a
thousand times  faster and  bigger.
Now we are exploring nanotechnolo-
gies that build structures on the scale
of molecules.
    Despite   substantial  technical
progress in a multitude of engineer-
ing disciplines in the last decade and
a half, our routine standard for leak
detection is still 0.2 gallons per  hour,
or 4.8 gallons per day, 144 gallons per
month, 1,752 gallons per year. The
presence of MtBE in our gasoline has
taught us that this standard is woe-
fully inadequate to prevent contami-
nation.  In  addition, our  existing
standard primarily addresses liquid
releases, while  studies show that
vapor releases may be much  more
common and in some circumstances
more significant than liquid releases
in terms of the mass of gasoline
released to  the  environment. (See
"Tracking   Troubling  Vapor  Re-
leases..." on page 13.)

Deja Vu All Over Again
But  change is in  the  wind. Some
states, notably California, have  tight-
ened or are contemplating tightening
the leak-detection standard estab-
lished 16 years  ago in the  federal
rules. Unfortunately, we are also see-
ing a repetition of the wild and wooly
1980s, because the new leak-detection
standard has,  to date, been incom-
pletely defined.
    California, for example, has spec-
ified a detectable leak rate of  0.005
gallons per hour at a probability of
detection of 95 percent and a proba-
bility of false alarm of 5 percent. But
additional parameters, such as the
pressure at  which the leak is  to be
defined or even something as basic as

                                                                                      June 2004 • LUSTLine Bulletin 47
whether the  leak  rate in question
relates to a leak of liquid or vapor,
have not been specified. In addition,
the  technologies being  developed
today are a far cry from the technolo-
gies contemplated when the leak-
detection evaluation protocols were
being written some 15 years ago.
    There is oftentimes only a poor
fit between the old protocol's proce-
dures  and the new  equipment's
design. The result is a  free-for-all
among vendors,  all  choosing  to
define their leaks and evaluate their
technologies  in the  way that  best
demonstrates  the capabilities of each
particular device.
Xea& defection?
    "Lei me tell you how we define a
leak," said the Minister of Petroleum.
"We estimate that our current technol-
ogy can find leaks of 2.4 gallons per day.
A few of our methods can find leaks of
0.120 gallons per day. Any leak rate less
than this we ignore because we cannot
reliably measure it. However, a vendor
came to me recently and showed me a
method he says can find leaks of a gallon
per year. "
    "A gallon per year is remarkable,"
interrupted the Minster of Standards,
"but if you are looking for leaks that are
that small, you will definitely be increas-
ing your rate of false alarms and you'll be
failing a lot of systems that are tight. "
    "Yes," said the Minister of Petro-
leum. "One of the problems this vendor
has had is that everything he tests fails
the test. But the leaks, if they are there,
are so small that no one can find them to
fix them. It's driving the storage system
owners and installers crazy. "
     "So," said the Minister of Reason,
"while I suppose the King would consider
a loss from a storage system of a gallon a
year a leak, I find myself compelled to
question whether we really need to find
leaks of a gallon a year or less. "

    We have lost sight of the goal.
Today, we are seeing  technologies
with the ability to detect phenome-
nally small leak  rates.  But the exis-
tence of these technologies begs  a
broader question: Are we really gain-
ing anything in terms  of protecting
human health and the  environment
from petroleum releases?
    Is "because we can" a sufficient
rationalization for  setting  a leak-
detection standard of a gallon a year
or a molecule a century? Is this really
the best place to spend our time and
money? Can leak detection be carried
too far?
    '"We need some basic facts," mused
the Minister of Reason. "We need to
answer the question, 'How small a leak is
relevant?' The answer will be different
for different situations, but we first need
to answer this question if we are going to
have an intelligent discussion about what
size leak is significant. "
    "Yes," said the Minister of Stan-
dards, "that is the fundamental question
that must be answered. To answer it, we
need some basic research. For example,
we need to know what happens when
gasoline leaks into the ground.  And if we
are going to put any new constituents in
the gasoline, we need to figure out what
that is going to do to the characteristics of
the gasoline that is  released. Then  we
need to figure out  what size  leak is
acceptable in different geologic and cul-
tural environments while still protecting
human health and the environment and
let that be our standard. "

    As our ministers note, a  difficulty
with using a "no-adverse-effect leak
rate" — the leak rate that is so small
that no measurable harm to human
health or the environment is likely to
result — as a leak-detection  standard
is that this leak rate will vary not only
with gasoline  constituents, but also
with the geologic environment into
which the gasoline is released and
the proximity of the receptor to the
release. But developing, implement-
ing,   and   regulating site-specific
acceptable leak rates does not seem
like a very workable scenario.
    From a practical standpoint, it
would be more realistic to develop an
acceptable  leak-rate number that
would be protective in 95 or 99 per-
cent of situations from a national per-
spective.  Individual jurisdictions
could impose stricter standards in
more sensitive areas.
    So what might the no-adverse-
effect leak rate be? We don't pretend
to know, but it seems to us  that it
would be worthwhile to determine
such a value. Our current leak-detec-
tion standard  of 0.2 gph was estab-
lished not because it was empirically
determined  to  be  protective  of
human health and  the environment,
but because of the technological limi-
tations of the leak-detection equip-
ment available at the time.
    Now that the old technological
limits can be superseded, we suspect
it is time to tighten the regulatory
standard. The question of how  much
to tighten the regulatory standard
should be answered by sound science
that documents what it takes to pro-
tect human health and the environ-
ment from petroleum releases from
storage systems.
A Draft Definition
"OK," sighed the Minister of Science and
Technology, "if we were to try to set a
limit on the size leak we are looking for,
how would we define it?"
     "As simply as possible," said the
Minister of Standards emphatically. "I
would suggest something like this: A
leak-detection method must be able to
detect a loss of some yet-to-be-determined
quantity X,  with the units mass/time,
from any portion of the storage system,
with a probability of detection of at least
99  percent and  a  probability of false
alarm of no less  than  1 percent. The
mass-release rate is to be  measured under
normal operating conditions for the sys-
tem. "

    We would add to  the minister's
definition that if secondary contain-
ment is used, both walls of the stor-
age system must be monitored. We
would support the minister's and our
definition with the  following  ratio-
  • Defining the leak  rate as a mass
    rather than a volume eliminates
    the need to distinguish between
    liquid  and vapor leaks.  What
    matters is the mass of  contami-
    nant released to the environment
    per unit of time, not whether the
    release occurs in liquid or vapor

  • The probability of detection is set
    at 99 percent because most exist-
    ing vendors  have chosen this
    standard  for their equipment,
    even though the current regula-
    tory minimum standard  is 95
    percent. If vendors believe that
    99 percent is  a more acceptable
    number to their customers, then
    why have the regulations  settle
    for less?
                 • continued on page 20


LUSTLine Bulletin 47 • June 2004
m Limits of Leak Detection from
page 19

 •  The leak rate would be defined
    at the operating condition of the
    storage  system  to take  into
    account the widely varying pres-
    sures in different storage-system
    components  (e.g.,  bottom  of
    tank, top of tank, pressurized

 •  While I still believe that sec-
    ondary containment holds  the
    most promise for very sensitive
    leak detection, we have learned
    that, in some cases, secondary
    containment is part of the prob-
                    lem rather than the solution. (See
                    "Pipes and Sumps—As I See
                    Them" below.) Monitoring both
                    walls of secondary-containment
                    systems will help to ensure that
                    these  systems  achieve  their
                    promise   of   fully  containing
                    petroleum releases from storage

                 The Bottom-Line Leak
                 We sense that the existing leak-detec-
                 tion standard of 0.2 gph is too  per-
                 missive. But if we are going to tighten
                 up leak  detection then we need to
                 have a rational standard for the size
                 of leak  to be detected and some
clearly drawn parameters to describe
the acceptable leak rate.
    Our king's  vision of a no-leak
kingdom is unachievable because our
modern-day  ability  to  measure
impossibly small quantities leads to a
scenario where all things are declared
to  be  leaking.   The   ministers'
approach of determining the size leak
that it makes sense to detect, care-
fully defining this leak, and then let-
ting the engineers do their work to
find ways of reliably detecting this
leak seems an eminently more practi-
cal solution to the problem. •

    What do you think?
Pipes  and Sumps—
As I  See  Them
Thoughts from a Florida UST Inspector
by Ernest M. Roggelin
     Since the  mid-
     1990s    there
     has  been an
increased level  of
interest, or perhaps
just  more  active
reporting and sharing of information,
among state and federal UST inspectors
regarding the deterioration  of storage
tank system components, specifically
nonmetallic underground piping and
containment sumps.
    Nonmetallic  piping  includes two
types: rigid  (thermoset) and  flexible
(thermoplastic). How do  you tell these
types or brands of pipe apart? First, get
to know the contractors in your area—
visit their shops, ask questions, and get
your "hands on" experience. Second, the
Internet is a wonderful tool, and most
manufacturers offer a wealth  of detailed
information for  the curious  (go to links to most manufac-
turers' Web sites). The sumps of concern
are  located at the  tank top  (piping
sumps), beneath  dispensers  (dispenser
sumps), and where piping goes from an
abovegrade  to a  below-grade location
(transition sumps).
    So  let's have a  look at  pipes and
sumps.  The photographs  used to  illus-
trate this article come from a variety of
governmental  agencies throughout the
United States.

  Because of space constraints and because it will be
  more helpful if you view the photos for this article
 in color, we have chosen to make all 65 of the photos
 Ernest provided to illustrate this article available to
      our readers on the NEIWPCC Web site at:
                 First the Piping

                 • Thermoset Piping
                 Thermoset or rigid fiberglass-rein-
                 forced plastic (FRP) piping has been
                 around for at least as long as I have
                 been inspecting tank facilities. Typi-
                 cally, someone has  to "do" some-
                 thing foolish or deliberate (e.g., step
                 on it, drill through it, score it, impact
                 it), improperly install it, or have it be
                 subjected to ground movement (i.e.,
                 shearing) to create a problem. I have
                 not  observed any deterioration of
                 thermoset materials from exposure
                 to petroleum products.

                 • Thermoplastic Piping
                 Thermoplastic piping, especially the
                 polyurethane and early polyethylene
                 flexible compositions, have been sub-
                 jected to intense scrutiny over the
                 past several years.  Following the
                 introduction of polyurethane-based
                 piping  in the  early 1990s,  Florida
                 began seeing microbial growth and
                 degradation in the outer jacket of
FIGURE 1. Black mold growth; degradation of
single-walled pipe's external cover

some single-walled piping within
three to five years of installation. (See
Figure 1.) Manufacturers typically
replaced the affected sections and
often the entire run at a given station
with the latest version of the pipe.
There was no mandatory recall of the
initial pipe. Replacement was appar-
ently based on the individual behav-
ior or response of the pipe.
    Fast-forward five to seven years,
or approximately 10 years from instal-
lation, and  we've  found that an
increasing number of thermoplastic
piping systems at Florida facilities
have been experiencing a variety of
pipe-deterioration conditions. In ret-
rospect, most of the initial product
lines  manufactured had  a  10-year
warranty.  A warranty refers to the

                                                                                   June 2004 • LUSTLine Bulletin 47
expected lifetime of any given prod-
uct. This is not to say the pipe has to
reach the end of its warranty period to
experience problems, although time
may be a unifying factor. So, should
we be surprised at the events?

Signs of Concern
What are inspectors seeing during
the course of their site visits?

  •  Exterior  and  interior  color
    change in the pipe
  •  Mold growth on the outside of
    the pipe
  •  Softening or jelling of the pipe
  •  "Blowout,"  a  term  used  to
    describe the rupture of the outer
    jacket of the primary pipe
  •  Cold growth or lengthening of
    the pipe, including backing off
    fittings, and movement of equip-
    ment out of position (see Figures
    2 and 4)
  •  Brittle interior core and cracking
    of the carrier portion, cracking
    of the secondary wall, and loss of
    internal integrity of the pipe (see
    Figure 3)
  •  Loss of  communication within
    the interstice of a coaxial pipe
  •  "Alligatoring" or rippling of the
    outer layer
  •  Fitting failure

Initially, manufacturers' response to
the piping problems was to direct the
blame to the installation contractors.
However, contractors are all required
to be manufacturer trained in piping
installation, so this logic is somewhat
circular. As  states began sharing
information about a widening pool of
incidents at various types of facilities,
this rationale became implausible. I
would be remiss if I did not attribute
some level of responsibility for  the
problems to "contractor error," as
problems do occur because of devia-
tion from standard practices.
    Next in line for blame were  the
facility owners. Manufacturers  in-
sisted that the exteriors  of their prod-
ucts were not designed to  be in
contact  with  petroleum for  an
extended time period (e.g., beyond 72
hours). They implied that the initial
designs assumed pristine, well-main-
 FIGURE 2. Growing pipe meets fitting
FIGURE 3. Split of secondary pipe; apparent failure of primary
layer underneath
tained piping runs that were not sub-
ject to long-term exposure to petro-
leum products. Failure to maintain
these conditions was obviously a fail-
ure in piping maintenance on the
part of owners, though the require-
ment that these products be main-
tained in such a pristine environment
is not stated on any manufacturers'
sales literature that I have seen.
    Exposure of the exterior of the
pipe to petroleum can occur within
an interstitial space of a coaxial pipe,
within  a  secondary or  tertiary
"chase" pipe, or from environmental
exposure due to soil and/or ground-
water contamination at a  facility.
Given that in the real world exposure
of the piping exterior to  petroleum
will occur, how is an owner to return
the piping to "pristine" condition?
    There are two areas of concern
associated with post-exposure clean-
ing.  First, the separate-component
primary and secondary pipes do not
             all  have  the  smooth
             bore  typical of ther-
             moset fiberglass pipe.
             Thermoplastics  typi-
             cally have what I call a
             corrugated chase that
             has  the potential  to
             retain liquids  within
             the separate cells of the
             corrugation.   Second,
             with the coaxial style of
             pipe, there is a question
             of how to  flush  the
             interstice of  product
             once   exposure  has
             occurred. Furthermore,
             how  can the cleanli-
             ness  of the interstice
             for either type of pipe
             ever be verified?

             "Hey, there are com-
             patibility standards in
             the regulations," you
             say. Sure, Florida has a
             number   of    them,
             including UL 971 from
             Underwriters Labora-
             tories (UL).
                 One of my duties
             is to  represent  the
             Florida Department of
             Environmental Protec-
             tion (DEP) on the UL's
             971 Standard Technical
	  Panel.  The  panel  is
             composed of represen-
 tatives from manufacturing, indus-
 try, interested parties, and regulatory
 authorities that meet  and by consen-
 sus develop new and revised stan-
 dards  capable  of  evaluating   a
 specified  product. The regulatory
 authority  input has  been a recent
 change to the panel's makeup.
    One  point of discovery that
 became evident during the technical
 panel's evaluation process for the UL
 971 standard was  that the existing
 standard focused on the testing of the
 primary  carrier  portions of  the
 pipe—the exterior of the pipe was
 ignored.  The new standard under
 development at present will evaluate
 the entire pipe—both inner and outer

 Now the Containment Sumps
 So what about containment sumps?
 States have different requirements...
                • continued on page 22


LUSTLine Bulletin 47 • June 2004
 m Pipes and Sumps/rom page 21

let alone the federal rule. Florida has
specific language requiring dispenser
sumps or at least a method of  sub-
dispenser containment; but the typi-
cal piping sump is not a requirement.
The facility just has to have a method
of providing  access to the piping
interstice for monitoring. Granted,
most new facilities have some form
of sump, but many existing facilities
have earthen or gravel "pits" beneath
a traffic lid—pits that serve as excel-
lent conduits to groundwater.
   What do  inspectors see when
they look into a containment sump?
There  are facilities with discrete
sumps and  facilities with factory-
mated units.  By factory-mated,  I
mean  those sumps that  are heat-
welded to the tank shell and those
where a mating collar is an integral
part of the tank shell.  The factory-
mated units can be made of ther-
moset or thermoplastic materials.
Again, the thermoset types are most
likely to suffer from impact damage
or contractor error. They  do not
appear to deteriorate from contact
with petroleum or  to deform from
external ground or water-table pres-

Signs of Concern
Thermoplastic sumps have exhibited
the following types of problems:
  • Rippling,  collapse, or  inward
   movement of walls from external
   pressure. (See Figure 4.)

  • Distortion  of the  floor  from
   apparent "long-term" exposure
   to petroleum.

  • Groundwater  upwelling pres-
   sures or lack of backfill support
   causing some of the floor distor-
   tion on the discrete models. The
   floor distortion for the factory-
   mated type is more of a concern
   since it is typically the tank's sec-
   ondary  containment  that  is
   undergoing this deformation.

  • Sump penetration boot failures.
   (See Figure 4.)
   Discrete sumps have their share
of contractor  errors, especially by
electrical  contractors, who  are not
typically concerned with maintaining
the liquid-tightness of sumps. These
errors are all readily visible to the

FIGURE 4. Ripple in sump wall; torn boots; shin in pipe position within
secondary pipe
experienced and patient inspector
during  the installation  oversight
process.  Thermoset  sumps  require
foreknowledge by the inspector of
the correct angle of penetration of
piping through the sump walls and
the use of appropriate penetration fit-
    Thermoplastic sumps, especially
older  thin-walled  models,  can
deform in response to soil movement
and/or shallow groundwater levels.
As mentioned, bulging of the walls is
a readily noticeable event, along with
cracking of structural features.  In
addition, there is the reaction of the
"plastic" to long-term exposure to
petroleum, whether it is free product,
petroleum contact water, or vapor.
    Manufacturers  have  failed  to
provide  sufficient  guidance  on
"how"  these  structures  can   be
cleaned after exposure. Complicating
the issue is the designation of most of
these sub-grade structures  as con-
fined-space entry points. An addi-
tional concern from the facility owner
perspective is the waste disposal cost
of flushing a secondary-containment
unit with water or an emulsifying
agent. When  thermoplastic sumps
are damaged, there does not appear
to be a manufacturer's recommenda-
tion on how to repair them.

In Florida, DEP and Local Program
(county-level) inspectors are out in
the  field   routinely   performing
annual, follow-up, installation, clo-
sure, discharge, and quality-control
                  inspections.   A
                  heck of a lot of
                  inspections!  For
                  example,     my
                  local   program
                  has  performed
                  814  inspections
                  since July 1,2003.
                  On a statewide
                  level, more than
                  25,000    inspec-
                  tions  are  per-
                  formed annually!
                      What  is  the
                  incentive  for a
                  facility to maintain
                  its system in "full
                  compliance"? Pro-
                  tecting a signifi-
                  cant investment?
                  Avoiding    the
potential  to  receive a regulatory
penalty? Even in light of problems
with long-term exposure of sumps
and piping to petroleum, the regula-
tory focus has not increased in this
area. Granted, inspectors in Florida
are tasked to specifically note  the
type and condition of piping at a
given facility, but this item typically
remains  a  "minor" infraction. The
bulk of the responsibility rests with
the facility owner/ operator, some of
whom contract  out the monthly
release detection monitoring to third
    In summary, there are problems
with certain components of UST sys-
tems. Inspectors, owners, their con-
sultants, and  contractors can  and
must frequently evaluate the condi-
tion of their systems, maintain  the
equipment properly, and act in a
timely and responsible manner upon
the discovery of  problems. Many
facility owners mistakenly  believe
that secondary containment is  the
cure for all their petroleum storage
ills. What they do not recognize is
that, in some cases, secondary con-
tainment is part of the problem,  not
the solution. •

 Ernest M. Roggelin is an Environmen-
  tal Manager with the DOH Pinellas
 County Health Department - Environ-
 mental Engineering Division. Pinellas
  CHD is a contracted Local Program
   with the Florida DEP, inspecting
 above- and underground storage tank
    systems. He may be contacted at

                                                                                           June 2004  • LUSTLine Bulletin 47
m Lead Scavengers References
from page 10
Montgomery, J.H., 1997, Agrochemicals Desk Reference,
 2nd Edition, CRC Lewis Publishers, Boca Raton, PL.
Pignatello, J.J., and S.Z. Cohen, 1990, Environmental
 chemistry of ethylene dibromide in soil and ground
 water, Reviews of Environmental Contamination and
 Toxicology, Vol. 112, pp. 2-47.
Ravi, V., J.S. Chen, and W. Gierke, 1998, Evaluating
 the natural attenuation of transient-source com-
 pounds in groundwater, Proceedings of the First
 International Conference on Remediation of Chlori-
 nated and Recalcitrant Compounds, Monterey, CA,
 May 18-21,1998.
SCDHEC, 2001, South Carolina Risk-Based Correc-
 tive Action for Petroleum Releases, Bureau of Land
 and Waste Management, Underground Storage
 Tank Program, Columbia, SC.
Steinberg, S.M., J.J.  Pignatello, and B.L. Sawhney,
 1987, Persistence  of 1,2-dibromoethane in soils:
 entrapment in intraparticle micropores, Environ-
 mental Science and Technology, Vol. 21, No. 12.
Thomas, V.M., J.A. Bedford, and R.J. Cicerone, 1997,
 Bromine emissions from leaded gasoline, Geophysi-
 cal Research Letters,  Vol. 24, No. 11, pp. 1371-1374.
U.S. EPA, 1991, Integrated Risk Information System,
 1,2-Dichloroethane, quick-
U.S. EPA, 1992a, EPA's Approach for Assessing the
 Risks Associated with Chronic Exposure to Car-
U.S. EPA, 1992b, Method 8011 1,2-Dibromoethane
 and l,2-Dibromo-3-Chloropropane by Microextrac-
 tion and Gas Chromatography, Revision 0.
U.S. EPA, 1996a, Press Release: EPA Takes Final Step
 In   Phaseout   of   Leaded    Gasoline,
U.S. EPA, 1996b, Method 8021B Aromatic and Halo-
 genated Volatiles by Gas Chromatography Using
 Photoionization and/or Electrolytic Conductivity
 Detectors, Revision 2.
U.S. EPA, 1996c, Method 8260B Volatile Organic
 Compounds by Gas Chromatography/Mass Spec-
 trometry (GC/MS), Revision 2.
U.S. EPA, 1997, Integrated Risk Information System,
U.S. EPA, 2000a, EPA Superfund Record of Decision:
 Otis Air National Guard Base/Camp Edwards,
 EPA ID: MA2570024487, OU 06, Falmouth, MA,
 EPA/ROD/RO1-00/128 2000.
U.S. EPA, 2000b, EPA Superfund Record of Decision:
 Otis Air National Guard Base/Camp Edwards,
 EPA ID: MA2570024487, OU 19, Falmouth, MA,
 EPA/ROD/RO1-00/005 2001.
U.S. EPA, 2001, National Primary Drinking Water
 Regulations, EPA 816-H-01-001.
US EPA, 2003, Integrated Risk Information System,
It's Time to Get Heated Up
About Heating Oil Tanks
    Cliff Rothenstein's article in the
March 2004 LUSTLine celebrates the
successes of the 20 years in which the
UST program has been in existence.
He says we  worked  effectively to
ensure  that all UST systems in use
today   meet  federal   standards.
But...he is speaking of federally reg-
ulated USTs, and there are a huge
number of petroleum-storing USTs
that  are not federally  regulated.
These heating oil tanks are often bare
steel and have been in the ground for
years, some for decades, without test-
ing or  upgrade.  Who knows how
many of them are leaking? Does any-
one even know how many heating oil
tanks there are?
    The states are left to decide for
themselves what degree of regulation
they  will impose on these tanks,
without any federal guidance, stan-
dardization,  or funding. And the
states are on their own in having to to
overcome huge pressure  from those
who  support doing nothing more
than the minimum required by the
feds. The decision to exempt heating
oil tanks from federal regulation 20
years ago was no doubt based on pol-
itics and economics, but can we con-
tinue to ignore this big elephant in
the room?
    While heating oil tanks were not
federally regulated for the first 20
years, hasn't the time come for this
huge chunk of the tank universe to be
addressed? Isn't  this  an important
enough issue? Shouldn't the envi-
ronmental impact of leaving aged
and  aging heating oil tanks in the
ground for the next 20 years without
federal  regulation be viewed as sim-
ply unacceptable?
    There has been considerable fed-
eral interest in cleaning up brownfield
sites. Petroleum cleanup costs are now
eligible  for federal funding at these
sites. Doesn't it  follow  that there
should be equal federal interest in reg-
ulation of the heating oil tanks that
have  contributed  to  the  petroleum
contamination for the purpose of
release prevention? The same political
and economic disincentives in play 20
years ago are probably still there, but
if we, the UST regulatory community,
don't consider heating up this envi-
ronmental issue, who will?

    Paula-Jean Therrien
    Principal Environmental Scientist
    RIDEM/UST Management

"Finishing Strong"
Resonates in Germany
[Edited to improve clarity.]
    I am head of the Industrial Envi-
ronmental Protection section in the
Umweltamt, Diisseldorf, Germany.
In my section we are responsible for
the fueling sites in Diisseldorf. As a
frequent reader of LUSTLine, I love
the very informative and in many
cases  also  entertaining way you
[Robert Renkes] and all the  other
authors share their experience about
USTs. Although we have in many
ways a different regulation and com-
pliance system for USTs in Germany,
I found it very  interesting  to  read
your article, "Finishing Strong," in
LUSTLine #46.
    We have quite the same experi-
ences  and observations with  our
updated UST systems and  fueling
facilities—especially your descrip-
tion of  the "modern" tank owner,
which  illustrated  the  exact  same
findings that we made. We found out
that in many cases the  site  owners
are more  interested in registering
and controlling  the temperature of
the refrigerators in the convenience
stores (in Germany up to three times
a day !!) than to register the "little red
light"on their leak detector.
    In a site inspection campaign we
conducted in 2002, we found out that
at six of 70 stations this little red light
was glowing without evoking any
reaction from the site owner.  Some of
the owners (mostly the newcomers)
did not even know what the  installa-
tion was for or where exactly it was
located!! One owner did not realize
that he had tanks on his site!!
                                                                                     Holger Stiirmer

LUSTLine Bulletin 47 • June 2004
Trading  Shoes
Risk-Communication Strategies
A      few years ago, a state environmental agency held a series of public meetings in an area where a number of LUST sites had
      been impacted nearby domestic wells, (The state shall remain nameless to protect the guilty.) Some of these meetings had hun-
      dreds of people in attendance. From the descriptions in the news articles, some of the meetings got a little bit ugly. At one of
the public meetings attended by more than 500 people, the state official was booed when he tried to curtail heated comments from the
audience. He commented, "This is my meeting. We don't have to be here." In response to this, a woman screamed from the crowd,
"Yes, you do. You work for us. " That's something to keep in mind — always.
    Picture the scene: You are the
state's environmental project man-
ager, and you are meeting with the
residents whose drinking water wells
have been impacted by a gasoline
plume. They have been drinking and
bathing in contaminated groundwa-
ter for heaven only knows how long.
Worse, their kids have been exposed
to this contamination. They want
answers, and they want them now.
They want to know who is responsi-
ble, and they want it cleaned up—
immediately. They don't want to be
told repeatedly, "The investigation is
ongoing." So they wait. They won-
der. They worry. Can they shower,
brush their teeth, and cook with the
water? The experts say, "It's a minor
risk." Will they ever be able  to sell
their houses?  Appraisers say  not
without clean water. Is there any con-
nection between their physical ail-
ments   and  the  contamination?
Experts  say that there's almost  no
way to tell.
    Would you want to hear  vague
answers? You deal with these issues
on a daily basis, but this is something
new and scary for the impacted par-
ties. As regulators, the best thing you
can do is make sure that all parties
are included in the information loop
as soon as possible. And, when you

are planning how you want to get
these people in the information loop,
one of the most important things that
you can do is to put yourself in their
    Imagine that you are "Trading
Shoes." If this were your family with
the contaminated well, what ques-
tions would you be asking? Imagine
yourself to be Uncle  Joe or Aunt
Mary, who haven't had all of the
environmental training that you've
had. You need to explain everything
to them in terms they can under-
    At a single meeting you may find
yourself in the position of communi-
cating potential risks simultaneously
to residents who (a) haven't been
exposed to  contaminants  in  their
water, (b) have been exposed at levels
below state or federal standards, (c)
have been exposed to contaminants
above  established  "safe"  levels,
and/or (d) have been exposed to con-
taminants for  which "safe" levels
have not yet been established. Each
of these  scenarios  would  pose a
unique  risk-communication  chal-
lenge. Couple this with the fact that,
if you are the impacted party,  no
amount of contamination is accept-
able in your water, whether or not it
is "safe."
    So before you face the crowd that
has gathered at the local school or
town hall, carefully plan what needs
to be said and how it should be said.
You probably don't want to find
yourself crawling away licking your
wounds, looking forward to the hey-
day the press will make of the meet-
ing, anticipating the angry calls that
you will field for days or weeks to
come, and knowing that your rela-
tionship with the public has gotten
off to a rocky start and will probably
remain that way.

Strategic Planning
Before you have your first interac-
tions with the public, gather a team
together and develop a communica-
tion strategy. How are you going to
communicate with the public? There
are lots of possibilities—big public
meetings, small group sessions, one-
on-one, press releases or news con-
ferences, neighborhood newsletters,
open-house  meetings.  There is  a
place for each of these types of com-
munication at some time during the
    The public wants and needs to be
kept informed.  They want  to be
included in  the decision-making
process; they want their concerns to

                                                                                 June 2004 • LUSTLine Bulletin 47
be listened to and acted upon. Keep
in mind, however, that the informa-
tion you may want to present to them
may not be  the  information they
want to hear.
   With your team, hone your take-
home message. It needs to be clear,
concise, and consistent,  and if you
want your message to get across, the
public needs to believe that you are
trustworthy and credible.
   Dr. Vincent Covello of the Center
for Risk Communication in New
York City states that there are four
factors that affect the public's percep-
tion of trust and credibility:
  • Showing that you are caring and
   that you  sincerely  empathize
   with their problems

  • Showing that you are dedicated
   and committed to addressing
   their problems

  • Conveying your  honesty  and

  • Assuring all concerned that the
   problem is being dealt with by
   people with  competence  and

   If you can't show these traits in
meeting with the public, then maybe
someone else needs to be doing the

How Do You Establish Trust
and Credibility?
Trust and credibility won't happen
with a "trust me,  I'm with the gov-
ernment" attitude. That trust has got
to be earned. Let's flesh out the fac-
tors listed above with some pointers.

• Caring and Empathy - Let people
know that you care—both verbally
and nonverbally.  Watch your body
language. Make eye contact. Say you
care! Be prepared to listen to people,
not just talk at them. Let people vent,
but keep it under control. Let them
know that they will all have a chance
to express their concerns, but that
melees aren't allowed.

• Dedication and Commitment - Be
open  and accessible. Know what
you're doing—people can tell who
knows and who doesn't. Follow up
on issues that you promise to follow
up on. Allow enough time to talk to
those who want to talk to you.

• Honesty and Openness - Be proac-
tive in your communication. If you
make a mistake, admit it. Avoid tech-
nical jargon and acronyms! The pub-
lic doesn't know the alphabet soup of
acronyms that we use every day.
Don't hide behind a podium.  Stand
out in front of it, close to the audi-
ence. Again, it's the body language.
Arms crossed in front of the chest
give the message that you are closed
to what they are saying. Always tell
the truth. If  you don't know  the
answer to a  question, say so,  say
you'll research it and get back to

• Competence and Expertise - Let
people know your credentials and
experience. Be able to cite similar
cases. Use  clear  and concise lan-
guage. Speak to the level of education
or expertise in the audience, without
talking down to them. Above all, be

Outrage, Power Ball,
and People
According to Dr. Peter Sandman of
Rutgers University, "The public pays
little attention to hazard; the experts
pay absolutely no attention to out-
rage." The public can get worked up
about what the experts might see as a
relatively minor risk  (e.g., that one-
in-a-million increase in the possibility
of getting cancer). These are the same
people who buy a Power Ball ticket
with a  one-in-a-million chance of
winning several million dollars. They
don't want to be that one-in-a-million
person who gets the cancer from the
water they are drinking.
    The "experts" can't understand
how everyone can get so lathered up
about what for them is encountered
in their normal working day. The
experts know the science and  the
risks. They know how long each step
in the project might take. It takes time
to  conduct   investigations   and
develop remediation  plans.  You
know that, but they  don't. For the
public,  it's the  uncertainty that
increases  anxiety,  so  the   more
informed you can keep them, the eas-
ier it will be to get past the outrage
and anger and deliver a message that
can be heard.
    Risk information often  comes
from people who are professionally
inclined (possibly even trained) to
ignore  feelings.  How do people
respond when their feelings  are
ignored? They  yell  louder,  cry
louder, listen less! That stiffens the
experts, which further provokes the
audience. Acknowledging people's
feelings in advance can reduce the
chances of conflict between the cold
bureaucrat and the hysterical citizen.

Planning Your Public
Once you have your planning group
together, decide on the type of out-
reach event that would be most effec-
tive  for the situation. How wide  a
group needs the information? Decide
on  the  key  messages  that  you
need/want to convey. Key messages
should be stated clearly and  con-
cisely. Some guidance suggests that
each key message should be no
longer than twelve words.  Have sup-
porting information to back up the
key messages.
   During the course of your pre-
sentation, repeat the message several
times to be sure that it sinks in. Antic-
ipate the difficult questions that the
audience might ask and decide how
you want to answer them.  Practice in
front of an audience beforehand. This
is probably not the time to assign the
task  to  someone with no public-
speaking  experience. It can be an
ugly sight to have your main speaker
get that deer-in-the-headlights look
when he or she stands up to speak
before a restless or angry crowd.
   In situations where hostility may
develop, emotions peak, and fear or
worry  bubble up, communicating
with the public takes special skills.
Communicating in a manner that is
clear, concise, and positive enhances
the opportunity for the message to
come across clearly. Environmental
communication requires a two-way,
interactive dialogue between regula-
tory  agency staff and affected stake-
holders—communication in which
stakeholder concerns, opinions, and
reactions regarding programs, sites,
projects, or issues are addressed.

As Hard as You Try...
It is  not always possible to please
everyone. In one of my current pro-
jects, 14  domestic  wells have been
impacted in a neighborhood of about
100 homes. After listing all the pros
and  cons of replacing wells with
deep, double-cased wells versus
extending  a nearby public water
               • continued on page 26


LUSTLine Bulletin 47 • June 2004
  Risk Communication// n/;; page 25
main, the DNREC made the decision
to extend the public water line. Resi-
dences  with impacted  wells and
nearby wells that are threatened will
be tied to the water line at no expense
to the residents except the quarterly
water bills.
    Due to the layout of the neigh-
borhood, the water  line will also
extend past houses with wells that
are not threatened. These people will
be allowed to connect to the line vol-
untarily, but they will have to pay for
the connection from the water main
to their houses. We have been deal-
ing with people who are upset that
they will now have a water bill when
they hadn't before, people who wish
that we would consider them threat-
ened  so they can be connected for
free, and people in other areas of the
neighborhood whose wells are not
threatened, and to which the water
line won't be extended, who feel that
we are not treating the entire neigh-
borhood as a unit. There actually are
a number of people who are grateful
that they will soon be getting rid of
the carbon filters that are removing
the gasoline from their water and get-
ting supplied with  water that is
tested regularly by the water utility.
    No matter which choice we made
to try to solve the water contamina-
tion problem in this neighborhood,
some people would be  unhappy.
Much of the recent interaction with
the  public for this project has been
one-on-one, in person,  or on  the
phone. Since the project is in a resort
area, about half of the residents are
seasonal; many of the  others  are
retirees on fixed incomes. Mailed
newsletters have also provided infor-
mation to the residents.
    By not holding large meetings,
we have taken away the opportunity
for rabble-rousers to grandstand, and
people in the neighborhood have
seen that we are willing to listen to
their concerns. The seasonal residents
have  been  kept in the  loop  on
progress even though they may live
several states away. Public outreach
has been extensive and time-consum-
ing, and we've hit a few rough spots,
but in general things have moved rel-
atively smoothly.
    We've learned that you can never
please all of the people all of the time,
and that there are some people that

you can never please. But the resi-
dents know that we will try to keep
them informed about what is going
on, listen  to  their  concerns, and
explain anything  that  they don't

Be Prepared
We have tried to follow the sugges-
tions in the literature on risk commu-
nication.  There  is  a  wealth  of
guidance available in the literature
on developing risk-communication
strategies. If I can offer one key sug-
gestion, it is that you should develop
a general strategy for risk communi-
cation before you need it. When the
need arises, assemble your planning
  Stop and think about what kinds of
  questions you would be asking if it
   were your well that was impacted
     and your family was drinking
            the water.
team and customize your approach.
    Provide as much information as
you can as soon as you can. Have
someone  present  information  at
meetings who  can  do  so without
using a lot of technical jargon and
acronyms.   Analogies  can  help
explain concentrations—a part  per
million is equal to one drop of gaso-
line in a full-size car's tankful of gas.
You may understand groundwater
hydrology  and the engineering of
remedial systems, but the average
homeowner doesn't.
    Have someone  available from
Public Health who can explain poten-
tial health risks. A good explanation
of the kinds of safety factors that are
built into developing maximum cont-
aminant levels (MCLs) can go a long
way toward easing someone's fears.
In addition to the regulatory agency,
the responsible party and his or her
consultant should also be available to
make presentations or answer ques-
    Be able to present a timeline for
what is going to happen next. Public
meetings are good, but you can also
send   out   periodic  community
newsletters  to provide updates on the
progress of investigations or remedi-
ation. Provide the phone number and
name of the person who will be avail-
able  to   answer  questions  and
respond quickly to all requests for

You Would Cry Too if It
Happened to You
Stop and think about what kinds of
questions you would be asking if it
were your well that was impacted
and your  family was drinking the
water. Those of us in the DNREC got
to experience this frustration first-
hand. There was a case (not ours)
where low, but rising, contamination
levels of bis (2-chloroethyl) ether, or
BCEE, forced the closure of four pub-
lic  wells  supplying  about  5,000
customers (approximately 13,000 res-
    BCEE, considered a probable car-
cinogen, is normally found  only near
chemical plants or chemical waste
sites. Federal drinking water rules do
not  require routine  testing for it
because it is rarely found in ground-
water. The chemical was detected in
monitoring wells as part of a moni-
toring program in place because of
four nearby Superfund sites.
    In what became a protracted and
complicated failure-to-communicate
situation—which I will spare you—it
finally occurred to someone that our
own building, which was also adja-
cent to the same Superfund sites, also
received its water from the contami-
nated well field. We hadn't been
invited to the earlier public meetings
for impacted residents.
    We soon found ourselves sitting
there in the audience listening to the
explanations about our exposure to
this chemical, and many of us were
not the least bit shy  about asking
some fairly pointed questions. Why
did it take so long to notice that the
containment   pumping  had   de-
creased?  Why hasn't  BCEE always
been on the analyte list for the Super-
fund wells since it had been detected
early on  in the studies? Who was
asleep at the wheel? Why the heck
did it take so long for U.S. EPA and
our  own  agency to notify  public
health officials and the water com-
pany? Why wasn't a lower action
level set when public  wells were in
the area?
    Public health officials  said that
they were unsure how long  cus-
tomers had been drinking contami-
nated  water.  We'll  never  know

                                                                                      June 2004 • LUSTLine Bulletin 47
because monitoring wasn't being
done. What was the maximum level
to which we were exposed? The fact
sheet developed  by Public Health
states that the "possible human car-
cinogen" classification is based on
sufficient evidence of carcinogenicity
in animals and a lack of adequate
human study data. Ingestion of BCEE
has been shown to cause liver cancer
(hepatomas) in mice. What are  the
possible health effects if I also have
some other health issues or exposure
to other contaminants? I'm not  a
mouse, so what  do those numbers
mean to me? At no time in the meet-
ing did I hear any reason or apology
for the oversights and delays  that
were involved in the project.
    None of us regulators like to have
one of our projects come back to bite
us on the you-know-what, so we try to
manage them  all so that they  will
stand up to technical, legal, and public
scrutiny. On those occasions when
that fails,  get  the information out
quickly, fully, and truthfully, and put
yourself in the other guy's shoes when
it comes to planning that outreach.
While I did not attend the original
meeting for the public, I felt that there
was much room for improvement in
the way that our in-house information
meeting was conducted. •

Suggested Readings
• Abkowitz, M.D., 2002, Environmental Risk Com-
 munication, Environmental Pollution, Nov.-Dec.
 2002, pp. 44-49.
• ATSDR (Agency for Toxic Substances and Disease
 Registry), A Primer on Health Risk Communication
 Principles and Practices,
• Barr, C., The Art of Risk Communication: Overcom-
 ing the Public Fear Surrounding Controversial Pro-
• Brown, S., June 1998, Communicating Environmen-
 tal Risk. LUSTLine Bulletin 29, p. 12.
• Brown, S,, Septe. 1998, Risk Communication: Trust
 and Credibility. LUSTLine Bulletin 30, p. 27.
' Butcher, S., 2002, Setting the Stage, Environmental
 Pollution, June 2002, pp. 64-65.
• Covello, V. and P. Allen, 1988, Seven Cardinal Sins
 of Risk Communication, U.S. EPA, Office of Policy
 Analysis,  Washington,   DC,  OPA   87-020,
• Johnson, B. and P. M. Sandman, 1992, Outrage and
 Technical Detail: The Impact of Agency Behavior
 on Community Risk Perception.  New Jersey
 Department  of   Environmental   Protection,
' Sandman, P.M. 1986, Explaining Environmental
 Risk. Environmental Protection Agency, Office of
 Toxic Substances. Washington, DC.  http://
' Sandman, P., 1987, Risk Communication: Facing
 Public Outrage. EPA Journal, Nov. 1987, pp. 21-22,
' Sandman, P., 1987, Explaining Risk to Non-Experts:
 A Communication Challenge, Emergency Prepared-
 ness  Digest,  Oct.-Dec.  1987,  pp.  25-29,
' Sandman, P., 1994, Risk Communication. Encyclo-
 pedia of the Environment, ed. by R. A. Eblen, and
 W. R. Eblen, Houghton Mifflin, Boston, MA, pp.
' U.S. Department of Health and Human Services,
 2002, Communicating in a Crisis: Risk Communica-
 tion Guidelines for Public Officials, Washington,
Mandatory Training for  UST Operators

Observations  from the Oregon Front Line
by Ben Thomas
An ambitious deadline. A new series of requirements. A constant barrage of reminders. A limited number of service providers. Con-
fused tank owners. Thousands of tanks at stake. Is it the 1998 upgrade deadline? Not exactly, but close.
       On  March  1,  2004,  Oregon
       became the first state to have
       set a regulatory deadline for
training UST operators. By that date,
every owner of fuel-dispensing UST
systems in Oregon must have desig-
nated a person as the official "opera-
tor"  and  have  proven  that  the
operator received  formal training on
all of Oregon's UST rules. They had
nine months to do it. No problem.
    Oregon met the challenge in a
unique way that didn't require a sig-
nificant  resource burden  on  the
Department of Environmental Qual-
ity (DEQ). In fact there was virtually
no burden; the department relied on
private  enterprise  to deliver  the
whole thing.  First, DEQ  created
guidance to qualify training vendors.
Then it created guidance for would-
be  instructors  to follow.  Then it
invited the instructors to post their
contact  information  and  training
dates on the state's Web site. Then
the DEQ broadcast letters statewide
alerting   operators  that  training
options were now available. Later
the agency would audit classes to
make sure the trainers were doing
the right thing.
    As a listed vendor, I personally
trained more than 25 percent of all
Oregon operators from June 2003 to
April 2004. That's more than 500 peo-
ple in 30 classes in nine months. Stu-
dents had to take my eight-hour class
on  UST  regulations,  including
lessons in administrative rules, finan-
cial responsibility, enforcement, leak
detection, spill and overfill preven-
tion, corrosion protection, suspected
releases, and other applicable codes.
Eight hours bought them a full-day
lecture,  a  reference  guide, two
quizzes, multiple classroom exer-
cises, and a certificate of completion.

Welcome Ladies and
When a large number of people are
forced to take a class in a topic many
of them have been working in  for
years, you  learn  some interesting
things. Some thought they knew
enough to get by. Some didn't know
where to begin. Some simply didn't
want to burn up eight hours in a
classroom. One day last summer at a
class, an older gentleman crossed his
arms and  said  loudly, "I've  been
pumping gas for 45 years and I'll be
damned if I'm gonna sit here and let
some  pissant kid tell  me how to
pump gas." Needless to  say,  he
needed  some  convincing on the
value of the day that lay ahead.
    Provided below are my personal
observations of  the great Oregon
UST operator training  experiment.
It's nothing scientific, but it is based
on talking to hundreds of operators,
fielding more than a thousand ques-
tions,  chatting  with area  service
providers, and reading  several hun-
dred class  quizzes  and  feedback
forms. Because it is the only training
summary  of  its  kind  to date, I
thought the readers might find these
                • continued on page 28


LUSTLine Bulletin 47 • June 2004
m Mandatory Training from page 27

reflections useful if they decide to
bring a comprehensive training pack-
age to other states.

• The need to upgrade the operator
Nearly everyone I talked to had an
automatic tank gauge, a number of
operators knew it did a test, but on
average  they didn't know  much
more. Items like keeping the tank full
enough to get a  valid test, 12 months
of  record  history, responding to
invalid tests, proving third-party cer-
tification, and periodic maintenance
and calibration seemed like novel
topics of discussions.

• Tanks  101: C+ I found the average
attendee had a fundamental grasp on
tank system basics. They knew they
had certain alarm capabilities. They
knew they had a tank "computer"
that did  something or other. They
generally knew whether they had
steel or fiberglass systems. What they
didn't know was how to organize all
these UST rules  into one manageable
bundle. One student commented, "I
wish this class had been available
years ago."

• What  did  they  know? Virtually
everyone with pressurized  line had
line leak  detectors  (or  so  they
claimed). A decent number of opera-
tors knew they needed an annual line
tightness test and line leak  detector
function  test, but  I wasn't so sure
these tests were widely done each
and every year. Many with double-
walled pipes didn't know about the
importance of keeping containment
sumps clean and free of liquid. When
I  asked what certain alarms meant, I
was met with plenty of blank stares.

• Old news  to some A few large
companies already had progressive
recordkeeping  and  training  pro-
grams in place. For example, Cono-
coPhillips  in  particular  has   an
excellent record-tracking system to
which all of its dealers must adhere.
These students tended to understand
the  more in-depth requirements and
asked  more  complex compliance
questions during class.

• A pleasant surprise When sur-
veyed, the majority of students found
the  class relevant  and useful. That
surprised  me,  given  that nearly

everyone who took the class did so
against their will. For a population of
students who have a grasp on tank-
system basics, that tells me there is
still much to learn and much that can
be learned (especially when taking a
class is required).

• Side effects I haven't been able to
quantify it, but I think I created a lot
of work for service providers doing
testing  and maintenance in  the
Northwest. The  main  grumble I
heard at the end of the  day  was,
"Boy, am I due for a checkup." One
thing I really encourage operators to
do is to set up an annual "tank physi-
cal" so their systems can be given a
top-to-bottom inspection on a routine

• Any value in it? Operators over-
whelmingly felt that the eight-hour
course better prepared them for a
compliance inspection. I spoke with a
few operators who  were  inspected
shortly after the class. They all told
me they passed with flying colors.
They told me they now understood
the equipment, what the inspectors
wanted, and how  to get into compli-
ance, based on what they were doing
wrong when they first came to class.

• Did they learn anything? 1 gave all
students a 10-question  multiple-
choice quiz on basic UST rules before
each class. The average score coming
into the class cold was 50  percent. I
gave the same quiz at the end of the
day. The average score jumped up to
90 percent. That tells me that people
were paying attention and snowed
improvement  on  their comprehen-
sion of basic UST rules.

Ready for Inspection
DEQ inspectors have told me they
have seen  a noticeable increase in
preparedness for compliance inspec-
tions. That might be an obvious con-
clusion, since the  owner must now,
by law, designate an operator to han-
dle UST matters,  but the inspectors
are thrilled nonetheless. The more
ready an operator is, the quicker the
compliance inspection and, hope-
fully, the fewer the violations to fol-
low up on.
    So now that  the deadline  has
passed, what's the compliance rate
for training? Not bad. DEQ estimates
that more than 80  percent of the UST
systems in Oregon now have desig-
nated, trained operators. Officials say
it  might be more like 90 percent
because they are still receiving verifi-
cations  around  the  state.  That's
impressive given the state  didn't
enforce the requirement but rather
encouraged people to get trained
using the state's normal outreach
    And what about the cranky old
fellow who didn't want me telling
him what to do? Over the course of
the  day,  a  slow  transformation
occurred. He eventually quit glaring
at me, uncrossed his arms, picked up
his pen,  and started  taking notes.
Soon he was asking questions. By the
end of the day he was smiling and
joking.  As  he  was  leaving,  he
approached me and agreed, almost
seemingly against his better judg-
ment, that the course has been worth
his while. He said he had to get back
to the station  to make himself a
recordkeeping  binder for the next
inspection. •

 Ben Thomas ran the Alaska UST leak-
 prevention program from 1995 to 2002.
 He now has a consulting and training
    business in Washington State.
  For more information on the Oregon
          program, go to, or
  e-mail Ben at
   LUSTLine T-Shirts
          Back of shirt     ~""«w
       TWO WACKY designs
      created by LUSTLine cartoonist, HankAho
      TWO colors... red and black
   TWO versions... long and short sleeve

           Long sleeve $17.00
           Short sleeve $13.00
                           Short sleeve
           Sizes: M,L, X, XXL
 ro OM>ER: Send check or money order (dnm
                       lU.S. tolls only) to:
     Boott Mills South, 100 Foot of John Street,
          Lowell, MA 01852-1124
     Tel: (978) 323-7929 • Fax: (978) 323-7919

                                                                                June 2004 • LUSTLine Bulletin 47
                        New Regulations Change UST
                        Operation in California
 ~j~n California, new regulations were
 1 recently adopted that will change the
JL way UST systems are operated. The
regulations, mandated by California's
legislature, will require UST owners,
operators, installers, service technicians,
and inspectors to meet minimum indus-
try-established training criteria. Addi-
tionally, a new "red tag" enforcement
tool has been adopted to help address sig-
nificant violations and recalcitrant own-

Training and Certification
California has required manufacturer
training and state licensing of UST
installation contractors and service
technicians for several years.  New
regulations enhance this program by
requiring an additional certification
exam for these individuals. The certi-
fication exams are developed and
administered by the International
Code Council (ICC), a  non-profit
organization with vast experience in
developing codes (e.g., fire, building,
electrical) and testing individuals for
their knowledge of those codes. ICC
followed recognized test-develop-
ment procedures and worked closely
with a group of industry experts to
create the certification exams.
    Beginning January 1, 2005, every
UST facility must have a "Designated
UST Operator" who is certified by
passing the ICC "California UST Sys-
tem Operator" exam. Service techni-
cians have until July 1, 2005 to obtain
    The Designated UST Operator
must conduct monthly visual inspec-
tions of the UST facility and provide
on-the-job training annually to  all
other facility employees. The regula-
tions were designed to minimize the
impact on UST owners by requiring
only one individual to be certified,
while  the  remainder  of  facility
employees  are required  only  to
attend a simple on-the-job training
provided annually by the certified
    Any individual can serve as a
Designated UST Operator as long as
he or she possesses a current ICC
California UST System Operator cer-
tificate. Because there is no regula-
tion specifying who can serve as a
Designated UST Operator, UST own-
ers have several options available to
satisfy the  requirement.  Owners
 •  choose to become their own Des-
    ignated UST Operator,
 •  have one individual serve as the
    Designated UST Operator for
    several facilities, or
 •  contract out with a service com-
    pany that will provide a certified
    individual to serve as a Desig-
    nated UST Operator.

    This requirement places a mini-
mal burden on UST owners  yet
ensures that each UST facility will be
inspected monthly by an individual
with knowledge of UST  laws and
management practices.
    For more information on Califor-
nia's new UST training and certifica-
tion   requirements,   visit   the
California State Water Resources
Control Board's UST Program Web
site at

Red-Tag Regulations
On June 13, 2004, California adopted
regulations allowing inspectors to
prohibit fuel delivery by affixing a
red tag to the  fill pipe  of any UST
system system found to have one or
more "significant violations." The
term "significant violation" means
the  failure of  a person to comply
with any requirement of Chapter 6.7
of the Health and Safety Code or any
regulation  adopted pursuant  to
Chapter 6.7 that involves any of the
 •  Violation(s)   that  cause   or
    threaten to cause a liquid release
 •  Violation(s) that impair an UST
    system's ability to detect a liquid
    leak or contain a liquid release
 •  Chronic or recalcitrant violators
    If the significant violation poses
an imminent threat to human health,
safety,  or  the environment,  the
inspector may affix the red tag imme-
diately upon discovery of the viola-
tion. If the significant violation does
not pose such a threat, the inspector
must first notify the owner or opera-
tor, giving the owner or operator
seven days to correct  the violation
before a red tag may be affixed to the
fill pipe.
    After the owner or operator of a
red-tagged UST system corrects the
violation and notifies the inspector,
the inspector must re-inspect the UST
system within five days to determine
whether it continues to be in signifi-
cant violation. If the inspector deter-
mines that the significant violation
has been corrected, the red tag must
be removed immediately.
    If fuel  is  delivered  to a red-
tagged UST system, California state
law allows enforcement action to be
taken against the UST owner, the
UST operator, and/or the person
who delivered the fuel. State law also
prohibits tampering with a red tag. In
addition,  state law  prohibits  the
removal of a red tag by an owner or
operator unless  the  violation  has
been corrected and the regulatory
agency has given written authoriza-
tion to  the owner or operator for
    Civil penalties of up to $5,000 per
day for violation of the above red-tag
requirement may be assessed by the
regulatory agencies. For more infor-
mation, contact Leslie J. Alford at
916-341-5810   or   email   her  at •


LUSTLine Bulletin 47 • June 2004
Sugar? Cream?  MtBE?
It's Time to Close the Gap Between Water Supply and
UST  Programs
by Kara Sergeant
I   don't drink coffee on a regular
   basis, but I do know that the last
   thing you want in your coffee is a
splash of MtBE. Yet this is exactly
what was occurring at a Dunkin'
Donuts operated  in  conjunction
with a Mobil gasoline station in Rut-
land, Massachusetts. The discovery
of 2,200 ppb MtBE in the facility's
well in February opened the eyes of
environmental   regulators   and
industry to the potential for other
such cases of public drinking water
contamination. Officials do not
know how long the well has been
    The well was identified during a
larger investigation of food service
establishments located near  haz-
ardous waste facilities to make sure
the establishments have the neces-
sary permits. State officials discov-
              ered   that   the
              Dunkin'    Donuts
              had been operating
              at  the gas station
              for two years with-
              out       having
              obtained  a water
              supply permit from
              the state.
                  The  facility  is
              classified   as  a
              transient non-com-
              munity (TNC) pub-
              lic water  supply,
              because   its   well
              provides water  to
              more than 25 peo-
              ple at least 60 days
a year. Other examples of TNCs
include restaurants, motels, and rest
stops. TNCs are  required to meet
federal and state regulations, which
in Massachusetts include enforcing a
100-foot protective radius around
the well  and sending monitoring
reports to the state.
    The  2,200  ppb  MtBE  level
exceeds the state's guideline level of
70 ppb. The facility owner also did
not  maintain  a  protective  zone
around the  well.  The  Dunkin'

Donuts was immediately shut down,
and local private wells were tested
for contamination. One home adja-
cent to the station had trace amounts
of MtBE.
   The  facility owner  hired  a
licensed site professional to perform
preliminary tests on the site, includ-
ing a soil-gas survey, borings, moni-
toring wells, and tank-tightness tests,
including spill  bucket  and  dis-
pensers checks. Although MtBE was
detected, the source was not located.
All USTs tested tight, and there was
no apparent upgradient source. The
state is waiting for the consultant to
submit the findings of the site assess-
ments, at which time the state will
propose Immediate Response Action
plans (the next  step required by
DEP). Dunkin' Donuts, based in
Randolph, Massachusetts, has coop-
erated fully with the state's investi-
   It is important to  realize that this
is a water supply issue. In most cases
a business may operate a food estab-
lishment  in conjunction with a gas
station even if it has onsite wells, but
it must be registered with the appro-
priate state authorities so that public
health can be adequately protected.
   The good  news is that some
states are working to improve com-
munication between the UST/LUST
and drinking water programs. The
New  England  Interstate  Water
Pollution  Control   Commission
(NEIWPCC)  held a meeting with
New England and New York state
and federal program staff in May to
discuss ways to improve the partner-
ships between the programs in an
effort to better  protect  drinking
water supplies.
   The Dunkin' Donuts case  was
one of the issues that came up at the
meeting.  As a result, several states
are attempting to identify food estab-
lishments located  in  conjunction
with gasoline  stations. One  idea
states had was for UST inspectors to
note on their inspection form if a
food service, such as a convenience
store or coffee service, is present on
the site and to pass this information
along to their drinking water coun-
terparts. Inspectors could even go so
far as to ask operators if they know if
they're hooked up to the municipal
system or  whether they have an
onsite well. Also, industry represen-
tatives should determine the source
of drinking water at their sites and
check with their state drinking water
program to see  what regulations
apply. •

   Kara Sergeant is an Environmental
  Analyst with the New England Inter-
  state Water Pollution Control Com-
  mission, which publishes LUSTLine.
        She can be reached at
• Tracking Vapor Releases in NH
from page 16

 might lead to information on mea-
 sures that can be taken—apart from
 national or state policy decisions on
 fuel  content—to mitigate   vapor
 releases. For example, research on
 Stage II systems should be encour-
 aged and information made avail-
 able that  compares  the amount of
 pressurization caused by the various
 Stage  II systems. Stage II system
 designs  should be  evaluated  to
 determine  whether  equipment
 changes can be  made that  would
 allow  a reduction in air-to-liquid
 ratios and increase onboard refuel-
 ing vapor-recovery (ORVR) compat-
 ibility with Stage II systems. Finally,
 new methods of vapor-release detec-
 tion should be developed and imple-

  Gary Lynn is the Petroleum Remedia-
   tion Section Manager of the State of
  New Hampshire. He can be contacted

                                                                               June 2004 • LUSTLine Bulletin 47
from Robert N. Renkes, Executive Vice President, Petroleum Equipment Institute

     The new and upgraded under-
     ground storage tank systems
     currently in the ground are
made up of a complex collection of
mechanical and electronic devices
that can fail under certain circum-
stances. Although tank system fail-
ures are uncommon, almost all can
be prevented or quickly detected as
long as the systems are properly
operated and continuously main-
    The  Petroleum Equipment
Institute's (PEI's) Board of Direc-
tors believes  regular,  periodic
equipment inspections will  save
UST owners/operators a consider-
able amount of money over time by
(a) preventing leaks and spills; (b)
discovering small problems before
they become large ones; (c) promot-
ing good  operation and mainte-
nance practices; (d) extending the
overall life of UST systems; and (e)
avoiding  fines,  penalties,   and
enforcement action.
    PEI  recognizes that inspection
checklists designed to organize and
identify proper UST system opera-
tions and maintenance procedures
are not available to all tank owners
and has initiated a project to draft
such a document. The association has
begun  the  process  of collecting
inspection and maintenance check-
lists from state  UST regulators,
equipment manufacturers, and tank
    Once a representative sample has
been received, PEI's Tank Installation
Committee will publish a recom-
mended checklist that will be avail-
able to  anyone that might benefit
from it, such as tank owners, regula-
tors, and UST service companies.
PEI  envisions that the list will
include recommended frequencies
for inspecting and/or testing the
following equipment: tanks, pip-
ing,  tank and line leak-detection
systems,  monitoring wells, dis-
penser sumps,  vent lines,  spill
buckets, cathodic protection, and
flex connectors.
   PEI hopes to make its checklist
available in October. If you have a
checklist that you are  willing to
share with the PEI Tank Installation
Committee, please mail it to Bob
Renkes, P.O. Box 2380, Tulsa, Okla-
homa  74101  or  e-mail  it  to If you are interested
in receiving the PEI Checklist when
it becomes available in October,
contact Bob Renkes at the address
above. •
          L*U*S*T*LINI    Subscription Form

 Mailing Address _
 E-mail Address
 Q  One-year subscription. $18.00.

 Q  Federal, state, or local government. Exempt from fee. (For home delivery,
 include request on agency letterhead.)
 Please enclose a check or money order (drawn on a U.S. bank) made payable to NEIWPCC.

 Send to:  New England Interstate Water Pollution Control Commission
         Boott Mills South, 100 Foot of John Street, Lowell, MA 01852-1124
         Phone: (978) 323-7929  • Fax: (978) 323-7919 •


EPA Grants Awarded to

Petroleum Brownfields Sites

      Of the $75 million in Brownfields grants announced
      on June 15, $23.1 million, or 25 percent, will be
      used to address petroleum brownfields. These
grants were awarded to 111 entities and  include 88
assessment grants, 22 cleanup grants, and six revolving
loan fund grants. The $23.1 million for petroleum Brown-
fields grants will demonstrate that petroleum-contami-
nated properties, such as abandoned gas stations, can be
successfully and profitably cleaned up and reused.
    A number of state UST programs applied for avail-
able Brownfields funds for petroleum sites this year. The
four state UST programs to receive petroleum assessment
grants are: the Michigan Department of Environmental
Quality ($200,000), the Missouri Department of Natural
Resources ($200,000), the South Carolina Department of
Health and Environmental Control ($25,000), and the
Utah Department of Environmental Quality ($200,000).
For more  information  see,
fields/archive/pilot _arch. htm.U
              Hear Ye, Hear Ye,
    ...and  the  photos  are  in  color  too.  Go  to The LUSTLine Index is
    online too—just click on "LUSTLine Index".
New CD on

OPW  and  the  North
American Nozzles Manu-
facturers have initiated a
refueling awareness pro-
gram to inform and edu-
cate the public about the hazards of refueling vehicles.
The program is a  cooperative effort among OPW, Husky,
Catlow, Emco Wheaton, and other nozzle manufacturers
in the United States.
   Changes to fuel-dispensing products initiated by this
group include:
   • New Hose Warning Tags for every hose point to warn
     of the hazards of refueling
   • Permanent  warnings printed on the nozzle covers
   • Prepay-style nozzles per NFPA 30A and the Uniform
     Fire Code
   • Flowlock nozzles
   • Do's and Don'ts At The Gas Pump - video in CD-
     mpeg format

   The free video has essential information for cus-
tomers as well as service station employees. It can be
copied or downloaded from the  OPW Web site at  and can be viewed on most computers
with CD readers.  For more information, call 1-800-422-
2525. •
 New England Interstate Water
 Pollution Control Commission
 Boott Mills South
 100 Foot of John Street
 Lowell, MA 01852-1124