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
x°x 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.
------- |