United States
             Environmental Protection
             Agency
             Office Of The Administrator
             (A-101F6)
EPA 101/F-90/037
September 1990
r/EPA
Cleanup Of Underground
Storage Tank Releases
Using  Pump And Treat
Methods
            #90-3501
                                         Printed on Recycled Paper

-------
                          NNEMS RESEARCH PROJECT
                                  ABSTRACT
                             QUESTION #90-3501

                              Mary Ann Susavidge
The task posed for this NNEMS project was to identify Underground Injection Control
(UIC) and Underground Storage Tank (UST) information to develop a Memorandum of
Understanding (MOU), and an UST owner/operator informational brochure for U.S. EPA
Region III.  Under current regulations, when an owner/operator is faced with a leaking
UST, cleanup is required.  If a pump and treat method is used and involves treatment of
contaminated ground water and reinjection through a well, a permit may be required.
Because permits for remediation wells had not been issued in the past for leaking USTs,
an understanding of the number and types of corrective actions at leaking UST sites was
required.  A brochure was  created for owners/operators of USTs and environmental
consultants involved in cleanups.   A fact sheet was  developed  as an in-house tool to
inform both the UST and UIC sections.  The MOU between the Water Management and
Hazardous  Waste Management Divisions contains language necessary to provide an
information link between the UIC  and UST sections; however, much of the MOU is not
implemented to date.  Implementation of the current MOU should satisfy the goals of this
research project.

-------
                           DISCLAIMER

This report  was furnished  to  the  U.S.  Environmental Protection
Agency by  the  graduate student identified on the cover page, under
a National  Network for Environmental  Management  Studies
fellowship.

The  contents are essentially as  received from the author.   The
opinions,  findings,  and conclusions expressed are those of the author
and  not necessarily those of the U.S. Environmental  Protection
Agency.   Mention,  if any,  of  company, process, or product names  is
not to be considered  as an endorsement by the  U.S.  Environmental
Protection Agency.
                        ADDITIONAL COPIES

      To order additional copies of Cleanup of Underground Storage
Tank  Releases Using Pump and Treat Methods, please call the
National  Technical Information Service (NTIS)  of  the  U.S. Commerce
Department  at (703)  487-4650.   To  order this  report ask for report
number PB91-100149.  Both  paper copy and  microfiche  are
available.

-------
                          NNEMS RESEARCH PROJECT
                                 FINAL REPORT
                              QUESTION #90-3501
                              Mary Ann Susavidge
      The task posed for this NNEMS project was to identify pertinent Underground
Injection Control (UIC) and Underground Storage Tank (UST) programmatic information
for the development of a draft and final Memorandum of Understanding (MOU), and the
development of an UST owner/operator informational brochure for U.S. EPA Region III.
      From the general task, small subtasks were developed to. reach the final goals.
Initially, a review of the Code of Federal Regulations (40 CFR Parts 144, 146, 147, 280,
and 281) was performed to gain a basic knowledge of both the UST and UIC programs.
With the regulatory information and information provided by contacts in the UIC and
UST sections, the specific connection between  UIC and UST was defined.  When an
owner/operator is faced with a leaking UST, they are required under UST regulations to
perform initial cleanup and subsequent corrective actions. If a pump and treat method
involves the withdrawal and treatment of contaminated ground water and  reinjection
through a well  or infiltration gallery, a permit for the injection well may be required.
The UIC section classifies this type of well as a Class V remediation well, which is given
the code 5X26.  Uncertainties in issuing permits stems from the fact that the UST and
UIC programs  are implemented by  either the Region or the individual State agencies
depending on the State, and the UST and UIC programs are in separate divisions of the
EPA (UST is in Hazardous Waste Management and UIC is in Water Management). Since
the UST program is fairly new, implementation of the program for each State is through
the Region III office.  Of the six states in Region III, only a  few have applications in to
Region III to run their own programs.  In the UIC program, the District of Columbia and
the Commonwealths of Pennsylvania and Virginia are direct  implementation States with
Region III implementing the program.  Delaware, Maryland, and West Virginia each have
primacy and implement their own programs which would include the issuance of permits.
      To  define the  program  authority,  an  outline of the  regional  and  State
responsibilities was  developed.  Because permits for remediation wells had not been
issued  in the past for  leaking USTs, an understanding of the number and types of
corrective actions at leaking UST sites was required.  A table for the second quarter of
fiscal year 1990 was developed from regional in-house data and is included as Attachment
1. In order to pinpoint the number of remediations using injection wells, calls to each
State UST agency were  made. A standard list  of questions were posed to  each State
contact, see Attachment 2.
      A compilation of the UST and UIC regulations and the responses from the States
resulted in the brochure and fact sheet provided as Attachments 3 and 4, respectively.
The  brochure is directed primarily  to  owners/operators  of USTs,  as  well as,  to
environmental consultants involved in clean ups. A "quick look" reference of the various
regulations for particular items is included along with a question and answer section to

-------
clarify some of the regulations. Also, if the brochure reader needs more information, a
listing of the pertinent phone numbers and addresses is provided.  The fact sheet will be
used in-house as a tool to inform both the UST and UIC sections.  A description of each
program is provided, the use of remediation wells is  discussed, and the State's varying
policies on funds for clean up are noted.
      To gain an understanding of the permit process, a portion of the tasks performed
included assisting in the  permitting of two injection facilities that were remediating
leaking USTs in Washington, D.C.  Draft permits were written based on the information
provided by the  permittee's application and subsequent conversations with the permittee.
      The  MOU between the Water Management and Hazardous Waste  Management
Divisions contains most of the language necessary to provide an information link between
the UIC and UST sections; however, much of the MOU is not implemented to date. The
only revision deemed necessary was to include an agreement that the UIC section would
provide Class V  injection well permits to the UST section for review. Implementation of
the current MOU should satisfy the goals of this research project.

-------
ATTACHMENT 1

-------
                          LUST Program


    There are 2 million UST's at over  700,000 UST facilities

               LUST data as of FY 90 - 2nd quarter
State
 DC
 DE
 MD
 PA
 VA
 WV
^cleanups ^releases
initiated controlled
            tcomplete   #UST   ^confirmed
             cleanups closures   releases
    74
   338
  2903
   407
   739
   154
 116
  66
2858
 306
 147
 185*
 43
 23
417
124
182
 10
  29
 217
1491
2965
1153
 662
 127
 576
3458
 567
1063
 266
     * number not consistent with f of cleanups initiated

-------
ATTACHMENT 2

-------
                      State Lust  Information
State:
Contact:
Phone:
1. How many corrective action plans (CAPs) are using or have used
   injection for remediation and are permits issued?
2. What other types of remediation are typically used in the state?
3. Is there a list of contractors  that  the state generally deals
   with?
4. Is there a list of remediation sites and clean-up methods used?

-------
ATTACHMENT 3

-------
Contact the UST agency and UIC agency in your state or the
EPA Region HI UST/UIC agenda.

VS. EPA Region ffl
841 Chestnut Building
Philadelphia, PA 19107 Phone: 215/397-7354 UST Program
        For D.C, PA, and VA: 215/597-9928 UIC Program

Delaware UST Program
Dept of Natural Resources and Environmental Control
715 Grantham Lane
New Castle, DE 19720             Phone: 302/323-4588

District of Columbia UST Program
Pesticides & Hazardous Waste Mgml Branch
614 H Street, NW. Room 505
Washington, D.C. 20013            Phone: 202/783-3205
Maryland UST Program
Department of Environment
2500 Broening Highway
Baltimore, MD 21224
Phone: 301/631-3442
Pennsylvania UST Program
DER - Bureau of Water Quality Management
3600 Vartan Way - P.O. Box 8761
Harrisburg, PA  17105              Phone: 717/657-4080
Virginia UST Program
Virginia Water Control Board
2111 N. Hamilton Street
Richmond, VA 23230
Phone: 804/367-0970
West Virginia UST Program
Div. of Natural Resources - Waste Mgmt. Section
1356 Hansford Street
Charleston, WV 25301             Phone: 304/348-6371
Delaware UIC Program
DNREC - Water Supply Branch
89 Kings Highway
Dover. DE 19903
 Phone: 302/736-4793
 Maryland UIC Program
 Dept. of the Environment - Groundwater Div,
 2500 Broening Highway
 Baltimore, MD 21224              Phone: 301/631-3306
West Virginia UIC Program
Department of Natural Resources
1201 Greenbrier Street
Charleston. WV 25311
                          unuea auies
                          Environmental Protection
                          Agency
                                                                                       September 1990
                          Region ffl -UIC Section
     xx EPA

            Facing the
        Unexpected...
   Cleanup  of Under-
ground  Storage Tank
Releases Using Pump
   and Treat Methods
                          injection
                          of treated
                         groundwater
                                   pump & treat
                                   contaminated
Phone: 304/348-3614
                                                           .     An owner/operator of a leaking underground
                                                           ~/\   storage tank (UST) may be faced with the
                                                           *"  formidable task of cleaning up the lite. Below
                                                       are some questions you may need to answer if a spill or
                                                       release occurs at your facility.
Q: What is a spill or overfill?
A: Discharge of a substance to (he ground surface that exceeds 25
  gallons or causes a sheen on surface water.

Q: Who should you contact when a tpfll occurs?
A: Report aspill to the implementing UST agency within24 hours.
  A list of contacts is provided in this brochure.

Q: What is t substance release?
A: Any spilling, leaking, emitting, discharging, escaping,
  leaching or disposing from an UST into groundwater, surface
  water, or subsurface soils.

Q: Who should you contact in the event of a release?
A: Report * release to the implementing UST agency within 24
  hours.  A list of contacts is provided in this brochure.

Q: How long do you have to confirm t release?
A: Investigate and confirm a release within 7 days. The
  investigation should include t system check and  site check.

Q: What initial measures must you take when t potential release
  occurs?
A: Release abatement measures should begin immediately and
  include:
  1. remove substance from UST to prevent further releases
  2. inspect and prevent further migration of the release
  3. monitor and mitigate hazards posed by the release
  4. remedy any hazards due to the release (complying with stale
    and local laws)
  5. measure for the presence of the release where contamination
    is most likely
  6. determine the presence of free product and begin product
    removal
 A report describing the measures used should be submitted to the
 implementing agency within 20 days of the release.

Q-. Are the initial abatement measures enough?
A: The implementing UST agency may require a Corrective
  Action Plan (CAP) including:
  1. free product characterization
  2. site hydrogeologic characterization
  3. proximity, quality, and uses of nearby surface and
    groundwater
  4. potential effects of residual contamination
  5. exposure assessment
 A report describing information on the nature and amount <
 release, site conditions, and results of the site and free prod
 check must be submitted within 45 days of the release even \
 CAP is not required. A free product removal report must also
 submitted within 45 days of the release.

Q: What remedial methods are available?
A: For contaminated soils, methods such as landftrming, soil
   venting, bioremediation, soil removal, and thermal strippu
   exist. For groundwater remediation, the general trend is u
   pump the water from drilled wells and then to route it to
   treatment systems such as: oil/water separators, air strippii
  or granular activated carbon. After treatment the water may
   sent to a sewer,  surface water, or may be reinjected throu
    well If necessary, a consultant should be contacted
   regarding the use of these methods.

Q: When cleanup involves injection wells, what are your
   responsibilities?
A: Cleanup using injection wells may begin under an emergen
   permit provided that you:
 1. notify the UST and UIC implementing agency of your
   cleanup intention
 2. obtain an emergency permit from the UIC implementing
   agency (EPA Region ffl) if located within the Common-
   wealth of Pennsylvania or Virginia or within the District c
   Columbia - the respective UIC implementing agencies in
   Delaware, Maryland, or West Virginia will determine wheth
   a permit is necessary in these states
 3. comply with conditions imposed by both the UST and UIC
   agencies
 4. incorporate the self-initiated cleanup in the CAP as require

Q: How "clean" must the soil and groundwater be after cleanup
   completed?
A: To the UST standards or Safe Drinking Water standards
   required by the Implementing agency. Contaminant level
   standards vary from state to state and must be determined c
   a site specific basis.

Q: When cleanup is completed, what happens to the drilled
   injection wells?
A: A plan for plugging and abandonment of the wells is require
   as part of die UIC permit application. Wells are to be proper
   sealed and abandoned when corrective action is terminated!
   that the movement of fluid into an underground source of
   drinking water (USDW) is prevented.

-------
ATTACHMENT 4

-------
                       DIC/DST Fact Sheet  (1990)
Background

     With the inception of the 1984 Hazardous and Solid Waste
Amendments (HSWA) to the Resource Conservation and Recovery Act
(RCRA) came the mandate for regulation of Underground Storage
Tanks (USTs). The USEPA promulgated UST regulations to protect
human health and the environment which led to many State
implemented programs having regulatory and spill clean-up
oversight.  Spills linked to USTs require corrective action which
can be performed by a number of methods.   When the material
released from a leaking underground storage tank (LUST) can be
recovered, usually true for gasoline and petroleum products,
remediation by well recovery may be viable.  The product can be
recovered and treated by various techniques.   Once the free
product is removed, the remaining ground water is either
discharged to a sewer, a surface water source under a National
Pollutant Discharge Elimination System (NPDES) permit, or may be
injected back into the ground water source.  As surface water
sources of drinking water diminish, the quality of underground
sources of drinking water (USDW) becomes more critical.  To
prevent contamination of USDW the Safe Drinking Water Act (SDWA)
of 1974 established the Underground Injection Control (UIC)
program.  When injection wells are used to return fluids to the
ground water, the UIC program must be complied with.  Injection
can only be authorized when approval comes from the appropriate
regulatory agency which can be either the state agency or in
states that do not have primacy, the USEPA.  Both the UST and UIC
requirements can be found in Title 40 of the Code of Federal
Regulations.
     Currently there are over 210,000 USTs in Region III.  Over
6000 confirmed releases have been reported as of the 2nd quarter
of 1990 with nearly 5000 cleanups underway.  Approximately 25
sites out of the 5000 cleanups undertaken are using Class V
injection wells.

-------
Definitions

"Class V injection well" refers to the category of wells that
     remedial injection wells (5X26) are classified under

"CERCIA" means the Comprehensive Environmental Response,
     Compensation, and Liability Act of 1980, as amended

"Free product" refers to a regulated substance that is present as
     a non-aqueous phase liquid

"Implementing agency" means EPA or in the case of a state with
     primacy, the designated state agency responsible for
     carrying out an approved UST/UIC program

"Owner" means any person who owns an active UST system since
     November 8, 1984 or any person who owned an UST system that
     was in use prior to November 8, 1984 but is not in use now

"RCRA" means the Solid Waste Disposal Act as amended by the
     Resource Conservation and Recovery Act of 1976

"Release" means any spilling, leaking, emitting, discharging,
     escaping, leaching or disposing from an UST into
     ground water, surface water or subsurface soils

"Underground injection" means the subsurface emplacement of
     "fluids" through a bored, drilled, or driven "well;" or
     through a dug well, where the depth of the dug well is
     areater than the largest surface dimension

"Underground source of drinking water" (USDW) means an aquifer or
     its portion which supplies any public water system or
     contains a sufficient amount of ground water to supply a
     public water system and contains fewer than 10,000 mg/1
     total dissolved solids

"Underground storage tank" (UST) means any one or combination of
     tanks (including underground pipes connected thereto) that
     is used to contain an accumulation of regulated substances
     and whose volume is 10 percent or more beneath the ground
     surface

-------
UIC Program Components

     Included in the Class V well category are 30 well types
ranging from simple cesspools which are barely deeper than they
are wide to sophisticated geothermal reinjection wells which may
be thousands of feet deep.  In the case of ground water
contamination, remediation of the aquifer would be done using a
well which is used to prevent, control, or remediate aquifer
pollution.  Under the UIC program, the type of well used for this
type of remediation is a 5X26.  A cross-section of a typical well
type is shown in the figure below.
     Protection of USDW's require that an injection operation
involving ground water remediation be regulated by a permit when
performing corrective action.  In EPA Region III, permits are
issued through the EPA regional office for the District of
Columbia, Pennsylvania, and Virginia.  Delaware and West Virginia
have primacy and issue permits through their respective state UIC
agency.  Maryland does not require the issuance of a permit for
Class V wells.  In the event that endangerment to the public
health exists, an emergency permit may be granted in each state
within the region.  Injectate standards vary on a site specific
basis and are evaluated by the implementing agency.


UST Program Components

     To prevent releases in new tanks, spill and overfill
prevention equipment, as well as, corrosion abatement devices are
used.  With proper operation and maintenance of this equipment,
spills and releases should be minimized in the future.  Existing
tanks must be upgraded to fulfill the federal regulations.  The
potential for releases however still exists.  When a release to
the environment is detected and exceeds 25 gallons or an amount
reportable under CERCLA Part 302, or causes a sheen on a surface
water body, prompt abatement measures are required and must be
reported to the appropriate implementing agency.  A corrective
action plan stating the proposed response for clean-up must be
submitted to the implementing agency for approval.  When
injection using 5X26 wells is chosen as the corrective action
alternative, the UIC implementing agency, with the exception of
Maryland, must be notified to obtain a permit for injection.
Emergency permits may be issued so that cleanup can be initiated
in a timely manner.

-------
Responsible Parties

     Currently, the EPA is assisting the Region III states in the
development and approval of state UST programs.  State program
grants are to be negotiated and oversight is provided by the EPA
regional office.  In terms of oversight, the EPA, for both the
UST and UIC programs, will receive state referrals of violations
and conduct enforcement actions when the state lacks the
necessary authority.  The EPA will also act as field or service
representatives to the states and will provide UST training.
Permits for 5X26 injection wells are issued by either the EPA
regional office or by states that have primacy for the UIC
program.
     As programs are approved in the transition period, the
states will be operating and enforcing the UST program. The
states will provide compliance assistance to owners and operators
and develop state-supported mechanisms to promote compliance.
Enforcement activities will be conducted using the UST Trust Fund
and state funds.  States will also provide guidance and oversight
for clean-ups and ensure that responsible parties are performing
corrective action promptly and properly.
     Owners and operators are responsible for abiding by the
installation, release prevention, corrosion prevention, and
release detection guidelines set by the Code of Federal
Regulations (CFR) Title 40.  In the event of a release, the owner
or operator must contain, promptly remediate, and report to the
implementing agency within a reasonable time period specified by
the agency.  Corrective action must be implemented in accordance
with the agency regulations.  Permits necessary to perform
corrective action must be obtained.  Owners/operators are
financially responsible in the event of a release.


Trust Funds Available for Cleanup

     The term "trust fund" takes on several meanings when
remediation of LUST sites is the issue.  When an owner/operator
installs an UST they must demonstrate financial responsibility
under CFR  280.93.  Financial responsibility may be satisfied by
 280.101 where the EPA administers the requirements assuring
that monies will be available from a state fund or state
assurance program.  The owner/operator can also establish a trust
fund conforming to the requirements of  280.102 to satisfy 
280.93.  The federal LUST Trust fund is currently used by the
Region III states to fund remediation actions.  Monies for this

-------
fund are distributed by the EPA regional office according to the
individual state needs.  The states of Delaware, Pennsylvania,
Virginia, and West Virginia have developed plans for State Trust
funds, however, these plans have yet to be submitted to the EPA
regional office for approval.  A summary of the proposed plans
follows:

Delaware - A trust fund was developed in 1987 and became
     effective in January 1989 which covers state corrective
     action clean-ups at $1 million per occurrence with a
     deductible of $100,000. The source of the fund is from state
     revenues.
District of Columbia - Legislation is currently pending and no
     trust fund exists to date.
Maryland - A state trust fund does not exist to date.
Pennsylvania - A trust fund was established in 1989 covering
     state corrective action clean-ups at $1 million per
     occurrence with a deductible of $75,000.  The source of the
     fund consists of fees to be paid by the owner/operator.
     These fees have yet to be determined.
Virginia - A trust fund was developed effective December 1989
     covering state corrective action clean-ups at $1 million per
     occurrence with a deductible of $50,000 or $200,000
     annually.  A cap of $20 million has been placed on the fund.
     The fund's source is from a $0.002/gallon tax on motor fuels
     which the owner/operator is mandated to pay.
West Virginia - The trust fund for this state is effective the
     date a premium is paid by the owner.  An annual premium is
     based on the age of tanks and deductibles ($100-$1000/tank).
     Coverage limits for the fund have yet to be established,
     however, an option of $5000, $15,000, or $25,000 deductibles
     has been set.  The fees would be mandatory for the first
     year and optional thereafter.

An important note is that owners/operators can not use these
funds to pay for clean-ups or use them to demonstrate financial
responsibility.  State funds are to be used for state corrective
action remediation.

-------