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. ------- |