New England Interstate
Water Pollution Control
Commission
www.neiwpcc.org/lustline.htm
116 John Street
Lowell, Massachusetts
01852-1124
510N05002
LUS.TUNE
A Report On Federal & State Programs To Control Leaking Underground Storage Tanks
Bulletin 5O
August
2OO5
"We Hope LUSTLine Will Be Useful..."
by Ellen Frye
leakin' out, mixin' up, leakin' out—copy oop.
Mixin' up, leakin' out, mixin' up—uppu up.
Gasoline, grounduioter
Drinking water, gas.
Mixin' up, leakin' out. Buried tank, fllas!
Uhoa, man! No man! Dis is profound!
"Gotta get that BT€X outta the ground!
Ulhoa man! Hey man, what's gain' down?
Gotta K€€P that gasoline outta the ground!
Subtitle I is passed.
Gotta stop the leakin' fast.
Chug Chug Chug Chug
Chuggie Chuggie Chuggie.
Notification
Interim prohibition
Technical standards
Financial responsibility
Inspection and enforcement
Corrective action.
Ruba dub dubby!
Marchin' words, big job—sis boom bah.
everybody tool up.
Rah, rah, rah.
Strategize, franchise, harmonize, analyze!
Build a better leaky trappy.
Clean up all the petro crappy.
lake the rules.
"Spread the word.
UJe're gonna try.
LUSTUne LUSTUne
Keepin' LUST bustin' alive!
• continued on page 2
LUSTLine Bulletin #1
August198i
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CD
( 15 ()
CUD
CUD
20
CUD
GOOD
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California's I
Tanks on Tribal Lands
A Message from Cliff Rothenstein: Got Water? _
EDB at South Carolina LUST Sites "',,"" 7./., *
Leaded Gasoline-What's in Those USTs? /; •
10,000 Facilities to Inspect-GIS Shines a Light
GER Analysis Methodology
County WebsHes to the Rescue
l*w Looked at Tanks from Both Sides Now
Making Sense of UL §71
Maryland's New Helium Test Protocol
Lightning Strikes Florida Tanks
-------
LUSTLnie Bulletin 50 • August 2005
m LUSTLine's 20th Anniversary
Issue from page I
Humor me. I haven't written any
"poems" since, oh, LUSTLine #12 in
1990. But, recognizing that some-
times art must trump enlightened
discourse to "soothe the savage
beast," I thought, okay, LUSTLine #50
would be as good a time as any to
insert a poem...for old time's sake.
Humor me, also, as I trip the leak
tank-tastick and reminisce, touching
on the timeline of tank issues, and
commenting on (with a little help
from my friends) where we are now
and where we might be going. Why?
Because August 2005 marks the 20th
anniversary of LUSTLinel
In 1985, U.S. EPA awarded the
New England Interstate Water
Pollution Control Commission
(NEIWPCC) a grant to publish and
distribute five issues of a bulletin that
would inform and update state and
federal regulatory agencies across the
country on topics related to the new
RCRA Subtitle I requirements. This
legislation called for U.S. EPA to pro-
IqnalJ f i '
' a
(
servke far t« J' JlCKA
Hazardous $ S»li Jfiftii fe AtBeHfl
rote pKMiiilgattdft process. "
LU§?O^tepw
-------
August 2005 • LUSTLme Bulletin 50
In the early days of the LIST program, when tanks were being yanked at unprecedented
rates, the dangers associated with tank removal and disposal were a big concern. While
health and safety will always be a concern, improved monitoring, inerting, cleaning, and
dismantling of tanks has minimized accidents. The days of finding tanks lying on the side of the road are mostly in the past. However, you might find
a bear or three calling a tank "home," as some of us did at an animal farm on the Olympic Peninsula in Washington State.
New Vork together For many
years to protect water quality,
including groundwater. Through
this N6IUDPCC connection I was
drafted to write an article with a
regional perspective for the first
issue of this new publication
called LUSTUne. That was 20
years ago. It's been covering all
the bases since then. Happy
20th, LUSTUne."
William Torrey, UST/IUST Regional Program
Manager, U.S. €Pfl - New England
To Thine Own Tank Be True
At the risk of subjecting readers to a
huge "Duh" moment, the only way
we can prevent a petroleum release
from an UST system is by ensuring
that all aspects of that system, includ-
ing product-delivery and -dispensing
operations, are designed, installed,
operated, and maintained such that a
release cannot occur. LUSTLine has
covered the gamut of technical issues
associated with petroleum storage,
including installer certification, prod-
uct delivery, facility inspection and
enforcement, and the 1998 deadline
for upgrading, replacing, or remov-
ing tank systems.
We've also covered related issues
such as abandoned tanks, health and
safety, heating-oil and other tanks
not regulated under the federal pro-
gram, the future of "mom and pop"
facilities, UST facility siting, product
compatibility with system compo-
nents, owner/operator training and
certification, and most recently,
vapor releases from UST systems.
The people who know those top-
ics best have written most of the arti-
cles on the many subjects we have
covered. LUSTLine would not be
what it is were it not for its contribu-
tors! And I thank you one and all. I
am particularly grateful to a core
group of contributors on whom I rely
not just for articles but also for
advice and content review. At the
top of this list is Marcel Moreau,
author of our "Tank-nically Speak-
ing" column.
I met Marcel in 1984, when he
was a geologist at the Maine Depart-
ment of Environmental Protection.
The New England states and New
York had been meeting at NEIWPCC
two or three times a year to discuss
concerns about impacts on ground-
water from UST-system releases.
Marcel, who attended these meet-
ings, clearly had a leg up on the sub-
ject. During his tenure at Maine DEP
and in his current role as an UST-
system consultant, he has served the
cause of release prevention with
dedication and integrity and has
been an invaluable friend, advisor,
and LUSTLine contributor—author-
ing or co-authoring about 40 articles
on all aspects of USTs, including the
human element. His articles add up
to a solid body of work that should
be required reading for anyone
involved with USTs.
In 1989, Bob Renkes, Executive
Vice President of the Petroleum
Equipment Institute (PEI), initiated
his column "Field Notes," giving
LUSTLine readers an industry per-
spective on UST-related issues.
Through the years, Bob has provided
concise and timely information on
the issues that most closely intersect
the interests of LUSTLine readers and
PEI members. He has also been a
very sensitive sounding board at
times when I have been flummoxed
by a particular topic.
Since 1992, David McCaskill of
Maine DEP (originally from Missis-
sippi) has provided us with his inim-
itable insight into tank issues in his
column "Tanks Downeast." Like
Marcel, David has a knack for choos-
ing topics that resonate nationwide.
He has covered a range of themes
including aboveground storage
tanks, heating-oil tanks, secondary
containment, waste-oil tanks, and
UST facility siting. For years, he's
been working (unsuccessfully) to get
me out in a sea kayak.
Thanks also to Marshall Mott-
Smith (Florida Department of
Environmental Protection), Ernest
Roggelin (Florida's Pinellas County
Health Department), Kevin Hender-
son (Mississippi Department of Envi-
ronmental Quality), Ben Thomas (Ben
Thomas Associates, Inc.), and Shahla
Faranak and Erin Ragazzi (formerly
with the California tank program) for
their bounteous input over the years.
• continued on page 4
-------
• LUSTLine's 20th Anniversary
Issue from page 3
Taking Rim at Site Cleanup
One driving theme from OUST in the
early stages of the UST/LUST pro-
gram was the need to work toward
continuous improvement. Looking
back at early LUSTLine articles, one
quickly realizes that our comfort
zone with cleaning up LUST sites
was quite narrow, but there was, and
still is, continuous improvement.
One of my early articles referred
to contaminated soil as the "new kid
on the block of national environmen-
tal concerns." But we've come a long
way. We learned that without ade-
quate site characterization, cleanup
strategies are essentially hit or miss.
Seems obvious to many of us now,
but maybe not so much once upon a
time. Over the years, cleanup tech-
nologies went from classic muck-
and-truck and pump-and-treat to in
situ approaches, such as air sparging,
air stripping, soil vapor extraction,
and even monitored natural attenua-
tion.
And, by the way, how clean is
clean? In January 1994, I wrote a
cover article called "Stop the
World...It's Time to Step Off and
Regroup," which was our first seri-
ous look at the subject of risk-based
corrective action (RBCA, now known
as risk-based decision making
(RBDM)). Despite our growing
understanding of the nature of the
corrective-action beast, there was a
growing backlog of LUST sites and a
lack of a commensurate number of
LUST site closures. Conditions were
ripe for RBCA. From what I can
gather from NEIWPCC's 2003 survey
on "State Experiences with MtBE and
Other Oxygenate Contamination at
LUST Sites," about 44 states now use
some form of RBDM in their correc-
tive-action protocols.
Then, just when it seemed like
we were getting the hang of cleaning
up the BTEXs, the TPHs, the PAHs,
the tra las, along came the gasoline
oxygenate methyl tertiary butyl ether
(MtBE), and new challenges
emerged. MtBE behaved differently
from the other contaminants of con-
cern—it's more soluble and mobile,
seemingly less degradable and treat-
able, and has no MCL. As it turns
out, we are recognizing that since we
don't want to be finding fuel-contam-
inant surprises in our drinking water,
we should probably be looking a bit
more closely at a wider selection of
gasoline components, such as TEA,
ethanol, TAME, DIPE, and EDB.
"Congratulations
to LUSTLine on its
20th anniversary and on this
milestone 50th issue! €Pfl
appreciates the integral role
LUSTLine has played in reaching
out to underground storage
tank partners over the history of
the national tank program.
LUSTLine has provided timely,
accurate, and useful information
about tank systems to many
stakeholders. €PR is proud to
have been a supporter of
LUSTLine over these many
years, and we look forward to
our continued partnership in
providing a Forum to share
information about tank issues."
Cliff Rothenstein, Director - Office of
Underground Storage Tanks, U.S. €PR
As OUST Director Cliff Rothen-
stein reminded us in LUSTLine #49,
"Our bottom-line job, day after day,
is to protect the environment and
human health from underground
storage tank releases and keep Amer-
ica's land and water clean and safe
for all citizens and future genera-
tions."
Once again, I want to thank the
many contributors who helped spread
the word as we grew in our collective
understanding of such corrective-
action enigmas as site characteriza-
tion, soil and water cleanup
technologies, RBCA, and MtBE and
other oxygenates. I've known Pat Ellis
(Delaware Department of Natural
Resources and Environmental Con-
trol, Tank Management Branch) for
many years. As I got to know her, I
found myself calling her more and
more with questions about corrective
issues, until she finally agreed to be
my official LUST technical adviser.
Once she finished serving on EPA's
Blue Ribbon Panel on MtBE, she knew
more than she ever hoped to know
about that subject. She wrote her first
LUSTLine article in March 2001.
Which brings me to my learned
friend Hal White at EPA OUST, with
whom I have had many thoughtful
discussions on anything and every-
thing related to LUST remediation.
Hal waded into the LUSTLine waters
in March 2002 with the article "Do
Monitoring Wells Monitor Well?" He
eventually wrote his own thought-
provoking column called "Wander-
LUST." When he bowed out, Pat Ellis
graciously picked up the column and
continued to run with it.
Two other people who have been
there for LUSTLine over the years,
writing and reviewing articles and
answering questions, are Bruce Bau-
man, Soil and Groundwater Research
Program Coordinator at the Ameri-
can Petroleum Institute, and Blayne
Hartman, a soil vapor methods and
analysis specialist.
The USTfields Renaissance
It seemed perfectly obvious to me
waaay back in graduate school, when
I was writing papers on reusing
abandoned mill buildings, that
reusing an existing property made a
heap more sense than taking a back-
hoe to a verdant copse. Likewise,
ignoring abandoned or idle petro-
leum-conteLininated sites 'cause it's
too much trouble to deal with the
issues and easier to move on to a
pretty little "greenfield," smacks of
hubris—the telltale mark of a throw-
away society.
Many s.tate LUST programs and
communities are seeing the benefits
of reusing these properties by uniting
economic development with site
cleanup efforts. LUSTLine first cov-
ered the subject of LUST sites in
brownfields in 1997, a time when the
federal Brownfields program did not
include petroleum contamination,
and state LUST programs were more
concerned with having to deal with
additional hurdles to clean up these
sites. But times, they are a changin'.
Now we hope to demonstrate that
our efforts to protect human health
and the environment from petroleum
releases also have a socioeconomic
benefit.
Special thanks to Gary Lynn,
New Hampshire Department of
Environmental Services, who, among
-------
t 2005 • LUSTLuie Bulletin 50
other things, has helped keep me up
to speed on USTfields, and Steve
McNeely, EPA OUST's USTfields/
Brownfields marriage broker.
As Steve once mused, "Hope-
fully, LUSTLine will be able to entice
those champions of change to share
their challenges, lessons learned, and
accomplishments so we're better
equipped to highlight our role in the
grand scheme of things." Yes, Steve,
LUSTLine will be there to help point
the way to good sense.
Taking Him at Paying for
Site Cleanup in Order to
€xpedite Site Cleanup!
It's so good to know that so many sharp
people are out there making sure you get
things right...like the author of the next
section, Chuck Schwer, Vermont
Department of Environmental Conser-
vation. I've known Chuck since the wee
hours of the program, and I knew that all
I had to do was ask and he would help me
out with the state fund part of this arti-
cle. Each year, Chuck and his staff con-
duct and summarize a state fund survey,
the results of which Chuck presents at
the Annual State fund Administrators
Conference. Take it away, Chuck.
It's hard to believe that the UST
program and LUSTLine have been
around for 20 years. There have been
so many challenges over those years:
more than a million unprotected
tanks, contamination everywhere,
programs understaffed and under-
funded, and my favorite, the concept
of financial responsibility (FR). It was
this FR requirement that set the stage
for the birth of state funds, as tank
owners were unable to secure private
insurance or find other means of
financial surety. By the end of 1990,
38 states had established state
cleanup funds, and by 1997, there
were 48. Only Hawaii and Oregon
chose not to create state funds.
For the 48 state-fund managers,
funds presented unprecedented chal-
lenges. But with the help of
LUSTLine, states worked together to
develop tools and strategies to take
on those challenges. One of the first
grim facts we all faced was the reality
that the cost of cleaning up all the
contamination caused by leaking
USTs was far greater than the funds
available. To respond to this reality,
states developed strong, enforceable
cost-control measures. These in-
cluded allowable costs, preapproval,
and limits on markups and overhead.
Site cleanups also needed to be prior-
itized, and RBCA was born.
And then there were those
nearly-impossible-to-prevent legisla-
tive raids on the funds. Despite our
best efforts to put strong language
into our rules to prevent such action,
legislative raids still present an ongo-
ing challenge.
Claims, claims, and more
claims—would they ever stop? States
had to develop streamlined claims-
processing systems to survive. But
what about all that fraud and abuse?
This became a real threat to many
state funds. Even with high-profile
cases being won against perpetrators
in Florida and North Carolina, state-
fund managers continue to battle
fraud and abuse on a daily basis.
Then came pay-for-performance
(PFP). Could this be a way to stop
fraud and abuse, speed up site
cleanup, and reduce paperwork? Fif-
teen states have implemented PFP
programs.
And what about the reemergence
of private insurance? For some states
this has become a reality. Eleven
states have transitioned to FR mecha-
nisms other than state funds. Some
"sunsetted" funds are still paying for
the cleanup at older sites, while oth-
ers are entirely done. One fund,
Michigan, declared dead when it was
deemed insolvent in 1995, has been
reborn to help with the challenges of
cleaning up contamination at older
sites.
As we look to the next 20 years,
we know that many of the issues we
deal with today will no longer exist.
However, we also know that to get
there, we will have to continue to
work to complete the many tasks set
out by state funds. There are still
more than 125,000 backlogged UST
sites yet to be cleaned up. We are also
discovering new sites every day—
more than 1,500 nationally in the last
six-month reporting period.
Vapor releases and flexible pip-
ing issues are new challenges to
keeping upgraded UST systems from
leaking petroleum into the environ-
ment. We all know prevention is the
key. But what's the best way to get at
this prevention? Third-party inspec-
tion programs? Environmental
results programs? Making compli-
ance a condition of fund coverage?
As we take on our upcoming chal-
lenges, it is comforting to know that
LUSTLine will be there with tools and
ideas to help state-fund managers
work through these many difficult
issues.
L "Congratulations on
your 20th anniversary. Thought
you might like the contribution
of a photo of a gas station in
Cyprus from about the time your
publication first started. It was
situated close to a place called
Lara Beach where the turtles go
to lay their eggs. You can see
that I was impressed by the
storage and dispensing
arrangements...and used it to
refuel my rental car. Much has
happened to this station in 20
years—it is now very smart.
Cyprus is in the €uropean Union
and the storage tanks are now
underground and double-
walled steel with leak
detection, thus protecting the
turtles on the nearby beach!"
Jamie Thompson, Chair of the €uropean
Standards Committee for Gas Station Equip-
ment, former regulator for London, and
LUSTLine friend and contributor
I continued on page 6
-------
• LUSTLine's 20th Anniversary
Issue from page 5
The lUSTline Team
The LUSTLine team is all of you who
work with us to get appropriate and
timely information into each issue.
We really and truly value all feed-
back, and we depend heavily on your
input in the way of suggested stories,
topics to explore, and article and
photo contributions. And, we always
welcome new contributors.
Our core team consists of Ricki
Pappo, Hank Aho, our NEIWPCC
reviewer, Kara Sergeant, and our
EPA OUST project manager, Lynn
DePont.
Ricki, who designs and lays out
each issue, always, always goes the
extra mile. She tries to keep the bul-
letin looking light, often in the face of
pages of weighty
and lengthy
written material.
She is a skilled
professional
with a great
sense of humor.
Needless to say,
Ricki and I wel-
comed our car-
toonist, Hank
Aho, on board
with open arms.
Hank is Maine's
Uncontrolled
Hazardous Sub-
stance Sites Unit
Supervisor and
an artist. It was truly a miracle to
meet up with a cartoonist who actu-
ally understands the quirky world of
regulators and petroleum storage
systems. There's nothing like a Hank
LUSTLine Production Team: Ellen Frye, Hank Aho, and Ricki Pappo
cartoon to get us in the right frame of
mind to crank out a new issue.
LUSTLine is a wonderful partner-
ship among many people. We thank
you all. See' you next time. •
California's Designated UST Operator
Program's Lookin' Good
by Scott Bacon
As of January 1, 2005, each of
the 15,000+ UST facilities in
California was required to
have a Designated UST Operator
(D.O.) who is responsible for con-
ducting monthly UST-system inspec-
tions and providing basic on-the-job
training for facility employees. This
requirement is in addition to the
annual facility compliance inspection
conducted by the local UST regula-
tory agency. To serve as a D.O., an
individual must pass a standardized
certification exam demonstrating
that he or she has knowledge of UST
laws, regulations, and management
practices that minimize the risk of
release to the environment. The D.O.
certification must be renewed every
two years.
Our UST System Operator Exam
is based on the International Code
Council's (ICC's) National UST Sys-
tem Operator Exam, with minor
changes incorporated to address
California-specific regulations. ICC
developed the exam with the
assistance of the California Water
Resources Control Board (CWRCB).
ICC offers the exam at approximately
40 test centers throughout the state.
Information on ICC's various UST-
related exams can be found on its
website at http://www.iccsafe.org/
certification/.
Although exact figures are cur-
rently unavailable, regulatory inspec-
tors throughout California are
reporting that most UST facilities
have assigned D.O.s and are comply-
ing with the monthly inspection
requirements. Many UST owners
have become certified and are serv-
ing as their own D.O.s, while others
have chosen to contract with quali-
fied third parties to provide this ser-
vice. Nearly 3,500 individuals have
passed the California ICC D.O. certi-
fication exam since it was first offered
in August 2003, and the number of
certified D.O.s continues to grow.
Our D.O. program is still rela-
tively new, but it already appears to
be improving UST compliance in the
state. D.O.s are identifying deficien-
cies during their monthly inspec-
tions, and working with owner/
operators to make the necessary cor-
rections. D.O.s are also implementing
facility employee-training programs
and helping to ensure proper
responses to spills, overfills, and
alarms from monitoring systems. In
the coming months, CWRCB and
local regulatory agencies will con-
tinue education and enforcement
activities in an effort to achieve 100
percent compliance with D.O.
requirements. •
for more information on
California's Designated UST
Operator Program, visit the
California Water Board's website
at http://www.waterboards.
ca.gov/ust or contact
Scott Bacon at (916) 341-5870 or
sbacon@waterboards.ca.gov.
-------
LUSTLme bulletin 50
TRIMS an TRIBAL LRJIDX
Wzf/z t/zz's z'sswe o/LUSTLine we are delighted to introduce a new column, "Tanks on Tribal Lands." The column will provide
tribal members and all of our readers with insight into the unique logistical and geographic issues, activities, solutions, and suc-
cesses associated with USTs and LUSTs on tribal lands. We are honored to have Henry Haven, Jr. launch this column. Henry has
served the Navajo Nation's UST/LUST program with great purpose and dedication. Following Henry's article, "To Una
At'eeh," Mimi Newton, U.S. EPA Region 9, discusses U.S. EPA's new memorandum clarifying its position regarding the use of
federal LUST Trust Fund money at abandoned USTfacilities in Indian Country.
by Henry Haven, Jr.
Ya'a't'eeh means "greetings" in
the Navajo language. I want to
introduce the Navajo people,
briefly describe their traditional
beliefs on the environment, and then
end with a report on the UST and
LUST programs in the Navajo
Nation.
The Navajo Nation encompasses
portions of Arizona, New Mexico,
and Utah, covering more than 25,000
square miles of land—nearly the size
of West Virginia. In my view, the
Navajo Nation is the eighth wonder
of the world. I assert this because,
among other things, it is home to
Monument Valley and Shiprock.
Monument Valley is a scenic area in
Utah with dramatic landscapes,
where you'll find red mesas and tow-
ering, ancient red sandstone forma-
tions that seem to defy gravity. In the
northern part, near Shiprock, New
Mexico, is an igneous intrusion that
towers hundreds of feet above the
surrounding landscape. In Arizona,
grays and purples represent ancient
deposits of volcanic ash and petrified
wood, well preserved in the Chinle
Formation. Recent flows of black lava
and red cinder cones cover the land-
scape in the southern parts near
Flagstaff.
Navajo Traditional Beliefs
According to our traditional beliefs,
the Holy People laid down the laws
for the Navajo people, endowing
them with sophisticated healing cere-
monies for their well-being. The
Navajo creation story informs us of a
series of emergence and progression
through different worlds. The first
world was "dark world" and was
inhabited by insects. The second
world was "white as light" and was
bestowed to people. Then there was
"yellow world." Each world under-
went destructions and renewals.
"The 'fifth world/" as an old Navajo
said, "would not come for thousands
of years. Man does not know of its
coming. As long as the plants and
animals continue to live and grow,
we are in the 'fourth world.' When
they are gone, we will be somewhere
else."
We were given sacred cere-
monies with songs, prayers, and
poems to maintain our health and
harmony with Mother Earth, as we
are all a part of her. This means living
in balance with all living things,
elements of the universe, and our
environmental surroundings. Our
language perpetuates the Navajo
healing ceremonies that protect the
health of Mother Earth, Father Sky,
and the Navajo people.
Navajo Environmental
Viewpoint
In April 1995, the Navajo Nation
Tribal Council passed a resolution, a
part of which said, "In the Navajo way,
the Earth is our Mother, the mountains
are part of her sacred body, the water
courses are veins and arteries. When the
Earth is injured, the resultant instability,
imbalance, and disharmony bring illness
to life on Earth including humankind."
These Navajo beliefs hold as strong as
when the Holy People first bestowed
healing ceremonies on the Navajo
people to maintain and protect the
environment.
Water, or "to"' in the Navajo lan-
guage, is one of the three most
important elements for growth, nour-
ishment, and perpetuation of all liv-
ing things. Rivers, streams, springs,
and all other natural sources of water
are sacred. Water plays an integral
role in all healing ceremonies. Air, or
"nilchi," like water, is another sacred
element. Air sustains all living
things. The third element, sunlight,
or "adinidiin," is required for the
growth of plants, animals, and
people.
Our UST Program
The Navajo Nation Tribal Council
passed the Underground Storage
Tank Act in October 29,1998, when
they saw the need to protect precious
groundwater resources and to regu-
late the USTs located on the Navajo
Nation.
In 1999, I began work with
Navajo EPA to further focus the work
plans for the Navajo LUST and UST
program and to start the enforcement
of the Navajo Nation UST Act of
1998. In the last couple of years, using
grants from U.S. EPA, our program
hired additional staff to become UST
inspectors. Currently, there are four
certified UST inspectors. Previously,
the program averaged 1.6 persons to
conduct UST inspections and LUST
site assessments.
• continued on page 8
-------
I Water Is Life from
7
I undertook my first UST-inspec-
tion training program with U.S. EPA
in 1999 and realized for the first time
how huge the UST universe was on
the Navajo Nation. (See Figure 1.) My
initial training period consisted of
observing the U.S. EPA inspector
during joint U.S. EPA and Navajo
Nation EPA (NNEPA) inspections.
Later, I obtained an UST inspector
credential from the Inter-Tribal
Council of Arizona. I became the first
UST inspector for the Navajo UST
program office in November 2002.
I started by building an UST
database to identify operating, leak-
ing, abandoned, and questionable
Navajo UST sites in Arizona, New
Mexico, and Utah. With the help of
summer students, we prepared files
for all sites and ordered new filing
cabinets to start a filing system. We
ordered equipment such as a global
positioning system (GPS), explosime-
ter, compass, and topographic maps
for our program. We obtained GPS
data and plotted operating UST sites
on maps. We conducted field site
assessments to determine how many
tanks were operating and how many
were abandoned in place. We com-
piled data on inspected UST sites for
each year and recorded violations to
aid the program in targeting sites for
follow-up inspections.
There are approximately 1,200
USTs on the Navajo Nation; this
includes operating, permanently
closed, temporarily closed, aban-
doned, and questionable sites. There
are approximately 142 operating sites
on the Navajo Nation, with approxi-
mately 550 tanks in place. This num-
ber does not include Bureau of Indian
Affairs facilities. Our operating UST
sites include privately owned or oper-
ated service stations, Navajo Nation
government refueling stations, state
school bus barns, and state Depart-
ment of Transportation and Navajo
Housing Authority facilities.
In 2001, 45 joint U.S. EPA and
NNEPA inspections were conducted.
After 2001, the agencies averaged
approximately 53 UST inspections
per year on government-owned and
privately owned service stations. In
2001, U.S. EPA and NNEPA joint
UST inspections showed a compli-
ance rate of only 2 percent. By 2004,
the compliance rate had risen to 53
8
percent as a result of the partnership,
outreach, and increased inspection
rates.
Our LUST Program
Since 2001, approximately 40 USTs
have been closed and removed each
year. In 2004, 60 USTs were removed
and assessed for contamination at 24
sites. Six sites had USTs that leaked
and had shallow groundwater contam-
ination. Also in 2004, the Navajo LUST
program removed 46 abandoned USTs
from 16 sites and provided further
assessment of several leaking UST
sites. Approximately 86 abandoned
UST sites remain with about 200 USTs
still in place.
Section 703 of the Navajo Nation
UST Act of 1998 established a Leak-
ing Underground Storage Tank Fund
for corrective actions, removal of
abandoned tanks, and cleanup of
contaminated sites. The program
receives the proceeds of 1 cent from
every gallon of gasoline sold on
Navajo Nation lands.
In 2004, the NNEPA LUST pro-
gram set out for the first time to use
the $1.3 million of tariff fees collected
on gasoline sold on the Navajo
Nation. Navajo environmental con-
tractors were hired to go to 19 sites
that had been abandoned since the
1960s to remove USTs and remediate
where necessary. Navajo contractors
drilled monitoring wells to assess the
lateral and vertical extent of ground-
water contamination and remove
petroleum-contaminated soil. Of the
19 sites addressed by NNEPA in 2004
with remedial action, 17 will be
closed with no-further-action status.
The majority of our LUST sites
are located in Arizona and New Mex-
ico. Tuba City, Window Rock, and
Shiprock are the communities with
the most LUST sites. There are
approximately 43 leaking sites on the
Navajo Nation that have not been
addressed with aggressive cleanup
measures. Over 50 percent of the UST
sites on the Navajo Nation pose a
threat to shallow groundwater
resources at approximately 20 feet.
Recently, the Navajo LUST pro-
gram drafted preliminary groundwa-
ter and soil cleanup standards, which
are stricter than those of U.S. EPA
and the State of Arizona, to start
addressing contaminated ground-
water resources.
Looking to the Future
In recognition of the Navajo Nation's
UST/LUST program's phenomenal
success during the past five years,
U.S. EPA Region 9 awarded and rec-
ognized the Navajo program with a
national environmental award. The
future holds great promise, as U.S.
EPA and the Navajo Nation join
efforts this year to begin the cleanup
of contaminated groundwater sites.
This year the Navajo LUST program
will address seven sites to remove
abandoned underground storage
tanks.
-------
I am honored to have been given
the privilege to write an introductory
article for LUSTLine's new column,
"Tanks on Tribal Lands." I thank Lil-
lie Lane, Public Information Officer
with the Navajo Nation EPA, for her
assistance and U.S. EPA Region 9 for
their continued assistance in devel-
oping the LUST program for the
Navajo Nation. •
Henry Haven, Jr. is a Geologist with
the Navajo Nation EPA and can be
reached at hhavenjr@hotmail.com.
U.S. EPA Clarifies Circumstances Where LUST
Trust Funds May Be Used in Indian Country
by Mimi Newton
On February 24, 2005, the U.S.
EPA Offices of Underground
Storage Tanks and Site Reme-
diation Enforcement issued a memo-
randum clarifying the agency's
position regarding the use of federal
LUST Trust Fund money at aban-
doned UST facilities in Indian Coun-
try. As a result of the clarification,
U.S. EPA Regions with jurisdiction
over USTs on tribal lands may find it
easier to investigate and remediate
abandoned USTs with LUST Trust
Fund money.
Prior to the February 24 memo,
U.S. EPA guidance regarding the use
of federal LUST Trust Fund dollars
focused principally on LUST sites
outside of Indian Country, where
states are usually the implementing
agencies and typically take the lead
at LUST sites. At those sites, the use
of LUST Trust Fund money should
be limited to emergency situations,
because U.S. EPA is not the imple-
menting agency. However, the
Interim Final National Corrective
Action Policy for USTs in Indian
Country (EPA OSWER Directive
9610.9A, Oct. 26, 1995) established
that all sites in Indian Country—
where U.S. EPA is the implementing
agency—are eligible for LUST Trust
Fund money so long as they meet the
statutory criteria.
The federal Resource Conserva-
tion and Recovery Act (RCRA Sec-
tion 9003(h)(2)(A)-(D)) allows the use
of federal LUST Trust Fund money in
four situations: (1) where no owner
or operator can be found who is
capable of carrying out corrective
action properly; (2) where a situation
exists that requires prompt action to
protect human health and the envi-
ronment; (3) where corrective-action
costs at the facility exceed the amount
of coverage required for the facility;
and (4) where the owner or operator
has failed to comply with a correc-
tive-action order.
The primary focus of the Febru-
ary 24 memo is USTs abandoned on
tribal lands with known, suspected,
or possible contamination, where the
original UST owners/ operators are
unidentified, have not been located,
or are not financially viable. The
memo clarifies that federal LUST
Trust Fund dollars may be used at
such sites if they meet each of the fol-
lowing conditions:
• The United States is the trust
owner of the property for the
benefit of an Indian tribe or indi-
vidual.
• The Indian tribe or individual
did not operate or manage the
UST.
• If lease documentation can be
located,
- there is evidence that the
Bureau of Indian Affairs nego-
tiated the lease on behalf of
the Indian tribe or individual
and
- there is no evidence that the
Indian tribe or individual
actively participated in the
lease-negotiation process or
that any such participation
went beyond minimal
involvement (such as lease
approval or concurrence).
The memo provides guidance to
the Regions on the use of LUST Trust
Fund dollars to address potential or
confirmed releases from USTs on
tribal lands "if the Region determines
that the situation requires prompt
action" to protect human health and
the environment. The memo also pro-
vides some factors the Regions may
consider in determining whether a
situation requires prompt action.
These factors include determining
whether contamination has been dis-
covered or is suspected and the
extent of the negative impact on
human health or the environment
from an abandoned UST that has
remained unremediated for an
extended period of time.
The memo also makes it clear that
the Regions may take into account a
number of considerations relevant to
trust-land ownership in determining
whether or not to pursue cost recov-
ery against a tribe or individual trust
beneficiary after LUST Trust Fund
money has been expended. The
memo sets forth three examples of
such considerations: (1) the inability
of the tribe or individual to divest
itself of land ownership; (2) the nature
of the leasing documentation; and (3)
the participation or lack of participa-
tion of the tribe or individual in the
negotiation of the lease (if any).
Shortly after the issuance of the
memo, U.S. EPA's Pacific Southwest
Region (Region 9) obtained approval
from EPA headquarters for the use of
LUST Trust Fund money at nine
abandoned UST facilities. These nine
facilities are located on trust lands of
the San Carlos Apache and the Hopi.
Muni Newton works us a RCRA attor-
ney with EPA Region 9. She began her
legal career as a RCRA enforcement
attorney at EPA Headquarters in
Washington, D.C. The views expressed
in tliis article do not necessarily repre-
sent the views of U.S. EPA.
Mimi can he reached at
Newton.Mimi@epamail.epa.gov.
-------
A MESSAGE FROIVI CLIFF ROTHENSTEIN
Director, U.S. EPA Office of
Underground Storage Tanks
dot Water?
Wi
ith the lazy days of
summer upon us,
water becomes a big-
ger part of our lives as we
move our activities outside.
We drink more than a half gal-
lon of water a day, especially
on a hot summer afternoon;
and we each use about 50 gallons a day for cooking,
bathing, and keeping our lawns green and our cars clean..
On average, the typical family uses more than 100,000 gal-
lons of water during a year. Our businesses, factories, and
farms also depend on water. It takes almost 40,000 gallons
of water to manufacture a car; 60,000 gallons to produce a
ton of steel; and 1,500 gallons to process a barrel of beer.
Most of the time, we take our water for granted, and for
good reason—it's readily available and doesn't cost much.
The fact is water's a bargain, costing on average only about
$2 for every 1,000 gallons of water supplied to a home. And
most of the time we assume that our water will always be
available, plentiful, and clean.
But we all know that when gasoline leaks from an under-
ground tank it can easily contaminate the surrounding
groundwater. In fact, some states have identified USTs as the
leading threat to groundwater, the source of drinking water
for half of all Americans. And when a water source is contam-
inated, a lot of time, effort, and money go into cleaning it up,
treating the groundwater, rehabilitating the aquifer, or finding
an alternative water supply.
Prevention Is Essential
We know that preventing a release by making sure petroleum
does not contaminate soil and groundwater in the first place
costs much less than cleaning up a leak after it has polluted the
environment. I'm pleased that we've seen confirmed releases
drop significantly—approximately 35 percent over the last
year. So, we need to continue that trend and heed Ben
Franklin's byword—"An ounce of prevention is worth a pound
of cure"—and do everything possible to prevent releases and
detect them early.
In the United States, we have a universe of about
660,000 federally regulated tanks. It is important to inspect
these tanks on a routine basis to ensure that they are oper-
ated and maintained correctly and that the tank systems are
in compliance with release-prevention and leak-detection
requirements. Inspections are an important tool in determin-
ing whether owners and operators are operating and main-
taining their systems correctly.
Yet inspection rates vary greatly across the United
States—from once every year in some states to no more than
once every ten years in others. I know it takes more
resources—people and money—to increase inspections, but
that investment will pay off manyfold.
I urge you to make prevention a priority and use some of
the creative prevention approaches we've developed together.
Consider taking the following actions:
• Adapt the environmental results program (ERP) to help
improve owner and operator compliance with tank regu-
lations.
• Target UST facility inspections in source-water protec-
tion areas.
• Use our recently released UST-LUST Virtual Classroom
to more efficiently train inspectors
(http://www.epa.gov/oust/virtual.htm).
• Implement a third-party inspection program.
Cleanup Is Our Responsibility
Together we've accomplished much—over the past 20 years,
more than 323,000 cleanups have been completed. And just
this past year, more than 14,000 contaminated sites were
cleaned up. Nonetheless, we're seeing a decrease in the pace
of cleanups. Over the past year, the cleanup pace has fallen
by 22 percent from 18,518 in 2003 to 14,285 in 2004.
Although the cleanup backlog—currently at 125,000—is
at its lowest level since 1992, we still need to aggressively
tackle the backlog and each year do our best to achieve our
cleanup goals. I understand that some of the remaining
cleanups are those that are more complex and may require
lengthier cleanup processes because of complications, includ-
ing contamination from MtBE.
But we know it is important for our country's environ-
ment and America's citizens that we work diligently to clean
up sites. I urge you to apply some of the creative approaches
we've jointly developed. Consider taking the following steps:
• Target source-water areas to make the best use of
resources to reduce the risks UST releases pose to drink-
ing-water sources.
• Streamline cleanups to complete them faster and
cheaper by:
- Developing multi-site agreements
- Using the Triad approach where stakeholders evaluate
sites and make cleanup decisions collaboratively
- Applying lessons learned from optimizing cleanups at
difficult sites in pilot states
- Using pay-for-performance contracting.
• Apply some of the lessons learned from existing MtBE
sites.
And through petroleum Browrifields grants, we need to
facilitate cleanups in order to foster productive reuse—as
parks or recreation centers or municipal buildings—of sites
that previously blighted the surrounding communities.
We're Partners in This Work
Together states, tribes, local governments, and industry—
along with EPA—have done a great job of protecting Amer-
ica's precious water resources. I thank each of you for your
determination and tenacity and willingness to tackle this
huge job. And I remind you that we still have so much more
to do to ensure that future generations of Americans can
continue to drink, use, and play in clean water. •
10
-------
What South Carolina Is Learning
About Ethylene Dibromide (EDB)
at LUST Sites
by Read Miner
>»
On a daily basis, each state rou-
tinely reviews numerous
reports documenting assess-
ment and corrective-action activities
at UST sites. Commonly, project
managers review the projects and
make decisions based on the needs of
each individual project. Staff rarely
have the time or resources to compile
the data from numerous sites in
order to look for common trends
among sites, or to understand the
behavior of a particular chemical
such as ethylene dibromide (EDB or
1,2-dibromoethane). Because of
EDB's toxicity and prevalence, the
South Carolina Department of
Health and Environmental Control
(DHEC) UST program determined
that an in-depth inquiry was neces-
sary to evaluate policies regarding
the chemical.
EDB and 1,2-dichloroethane (1,2-
DCA) were both part of an antiknock
additive package used in leaded
gasoline from the 1920s through the
1980s. (See "Leaded Gasoline?" on
page 15 to learn how leaded gasoline
and these additives are used today.)
Although approximately 90 percent
of the EDB in the United States was
used in leaded gasoline during that
time period, it was also used as a pes-
ticide until approximately 1984.
The DHEC UST program first
started testing for EDB at LUST sites
in the early 1990s. Initially, we
requested that U.S. EPA analytical
methods 8260 and 8260B be used.
However, because of the toxicity of
EDB and its corresponding maxi-
mum contaminant level (MCL) of
0.05 ug/L, these methods were found
to be insufficient since their reporting
limit was 5 ug/L. EPA analytical
method 8011, with a lower reporting
limit of 0.02 ug/L, is now our stan-
dard. Last year, 1,2-DCA was added
to the list of analytes using EPA
method 8260B.
Our database allows us to elec-
tronically track the concentrations of
chemicals of concern at specific UST
sites. During 2003, Nimeesha Bul-
sara, a Clemson University graduate
student, queried the database to
determine the occurrence of EDB at
UST facilities in South Carolina as
part of her thesis. The results were
later published (Falta and Bulsara
2004 and Bulsara 2004).
Additional database queries by
Clemson University students James
Henderson and Richard Mayer were
conducted in December 2004 to build
on Bulsara's research. They found
that approximately half of the UST
sites assessed to date in South Car-
olina contain EDB in the groundwa-
ter (R. Falta et al. 2005). These
findings prompted UST program
staff to conduct a random survey of
104 of the confirmed EDB sites to bet-
ter quantify the magnitude of the
EDB problem.
Distribution of EDB in
South Carolina
The 104 facilities included in the ran-
dom survey are located in 14 coun-
We reviewed the technical files
for each facility and recorded the fol-
lowing information: permit number,
county, UST installation date, number
of wells in the monitoring network,
number of monitoring wells contain-
ing EDB, highest benzene and EDB
concentrations, length of the BTEX
and EDB plumes, and seepage veloc-
ity.
The data were evaluated and
several summary figures were pre-
pared. Figure 1 depicts the percent-
age of sites where EDB was detected
within a given range of concentra-
tions, reflecting the highest concen-
trations detected at each facility. The
highest concentration of EDB
detected to date in groundwater at a
South Carolina UST site was 6,550
ug/L. Approximately 1 percent of
facilities with EDB had concentra-
tions exceeding 1,000 ug/L. Almost
half of the sites had EDB concentra-
tions of less than 5 ug/L. This is an
important finding, as concentrations
FIGURE 1. EDB concentrations at UST facilities.
0.05-4.99 5.24 25-99 100-499 500-1,000
Concentration (ppb)
>1,000
ties. Nine of the counties are in the
coastal plain (primarily sedimentary
surface lithologies), and five counties
are in the piedmont province (com-
posed primarily of metamorphic rock
and saprolite). Sediments at the facili-
ties range from relatively clean sands
to silty sands, sandy silts, and clays
with a full range of seepage velocities.
are routinely found at levels below
the reporting threshold of some ana-
lytical methods.
If an analytical method such as
EPA method 8011 or an equivalent
method that can achieve a reporting
limit of <0.02 ug/L were not used,
approximately half of the EDB
• continued on page 12
11
-------
• EDB at LUST Sites from page 11
plumes in excess of the federal MCL
would go undetected.
Figure 2 plots benzene versus
EDB concentrations. The benzene
concentration was assumed to be
40,000 ug/L for each site containing
light non-aqueous-phase liquids
(LNAPL). Benzene and EDB concen-
trations do not appear to be corre-
lated. This lack of correlation could
reflect many possible factors, includ-
ing, but not limited to, unknown
release dates, multiple super-
imposed releases at each facility, and
differential degradation rates for
each chemical.
Figure 3 depicts the percentage
of sites in the survey with EDB plume
lengths falling within a given range.
Although EDB plumes as long as
2,800 feet have been confirmed at
UST facilities in South Carolina,
approximately 87 percent of the EDB
plumes appear to be limited to within
250 feet of the USTs, lines, and dis-
pensers. At about half of the EDB
sites, the length of the EDB plume
approximates the dimensions of the
BTEX plume. Approximately 44 per-
cent of the sites have longer BTEX
than EDB plumes and approximately
6 percent of EDB plumes exceed the
length of the BTEX plumes.
Unfortunately, EDB's fate and
transport mechanisms are not very
well understood. Based on EDB's low
Henry's constant, low retardation,
and recalcitrance to biodegradation,
one would expect most EDB plumes
to exceed the length of the BTEX
plumes. That the opposite was found
may be a direct result of the limita-
tions of typical assessment tech-
niques.
In South Carolina, petroleum
plumes are typically defined using
direct-push equipment and the semi-
quantitative analysis of organic con-
centrations using field-screening
methods capable of producing real-
time field data. The results of the field
screening are then used to determine
the optimum number and location of
monitoring wells and appropriate
screened intervals to define the BTEX
and MtBE plumes in three dimen-
sions. Unfortunately, typical field-
screening methods, such as PID, FID,
Immunoassay, and HACH Test Kits,
do not achieve the required reporting
limit for EDB of .02 ug/L. Further-
12
FIGURE 2. Benzene concentt^ffgitj ^fatiQffjlfrff^m
S" 45 000 -i
°- 40 000 JMMHK
C L*. ^
r^ is nnn PL,,,,,,,™
"re in nnn I,.,,,,,,,..,,.
| 2o'IJ|| l&
Q i_v,wvw | i-^sf 1"
Ib.UUU P^"""11
2 4-w
09 10,000 J^T
| 5,000 |s-
co n BEj
0 ^
0
f'i-!"1 "' '{"••-"-* "t "--~. ' - "•
>-X' >-'A" " t .%V •:• '
^C"t,%.:-.-X"-? •'*-r<': • ;>
^ v. ' 1" »%\"; . *\*'V ^' < ", . _
/-r*< ;' ...i^-^r".^ • -;4 - - i • -,
Si'f",^^*^;'^!* " .er;-''- • ->
tk-" . .. ,• . '. .. . v
200 400 60C
EDB Concentration (|
800
1,000
FIGURE 3. Lengths of EDBiplufnesW•iMacfiiMl
<100 100-250 251-500 501-800
Length of Plume (feet)
>800
FIGURE 4. Lengths of EDB plumes in relation to seepage velocities.
100 150 200 250
Seepage Velocity (feet/year)
300
350
more, PIDs and FIDs only look at
volatiles.
Based on a review of numerous
maps, the longer EDB plumes are
commonly very narrow, cigar-
shaped features. In addition, EDB
commonly dives with increasing dis-
tance from the source. Many cases
were also noted where EDB was pre-
sent in the deep monitoring wells but
was no longer present in the shal-
lower water table bracketing wells.
Because of these behaviors, it is likely
that an EDB plume may be missed by
a monitoring well network designed
for BTEX or MtBE. Field-screening
methods and monitoring networks
may need to be modified to better
address EDB.
Figure 4 plots the length of each
EDB plume against its corresponding
seepage velocity. Facilities with high
seepage velocities but very short EDB
plumes carmot be explained with the
available data. A short plume may be
caused by factors other than the seep-
age velocity, such as biodegradation,
or could indicate that the main EDB
-------
plume may be detached from the
source area. The facilities with very
low seepage velocities but long EDB
plumes could represent releases that
occurred more than 50 years ago.
This is an important finding because
it implies that EDB at these sites is
very recalcitrant to biodegradation.
Natural Attenuation
Further evidence of EDB's possible
recalcitrance to biodegradation
emerged when a large number of
additional UST releases were evalu-
ated for evidence of natural attenua-
tion. For each site, the data collected
during the assessment and subse-
quent monitoring phases were com-
piled and plotted against time. Each
facility showed evidence of benzene
degradation (some much more than
others).
Although the dimensions of the
EDB plumes appeared to be stable,
clear evidence of any EDB biodegra-
dation was not observed in monitor-
ing programs lasting as long as three
to four years, where groundwater
samples were analyzed using EPA
method 8011. Thus, we can reason-
ably conclude that if EDB biodegra-
dation is taking place, verification
may require much longer monitoring
programs.
Treatment of Sites
Containing EDB
The DHEC UST program establishes
site-specific target levels or cleanup
goals for each facility using a risk-
based corrective action (RBCA)
approach. Because of its toxicity,
mobility, and persistence, EDB was
identified as a chemical of concern
many years ago. Approximately 3
percent of the releases of EDB have
impacted water supply wells. In
order to restore or protect water sup-
ply wells, approximately 6 percent of
the corrective actions currently in
progress at UST facilities in the state
require treatment of EDB.
To further our understanding of
EDB, we reviewed the progress of
EDB remediation. The corrective
actions that were reviewed for this
purpose may or may not have been
geared to EDB remediation. Our gen-
eral observations, which are summa-
rized below, are related to EDB and
should in no way be misconstrued to
be a detailed analysis of site-specific
FIGURE 5. Temporal change in EDB concentrations near the UST basin.
a
LLJ
5678
Time (quarters)
10 11
12
FIGURE 6. Temporal change in EDB concentrations 80 feet downgradient from the
UST basin.
567
Time (quarters)
10 11
12
FIGURE 7. Temporal change in EDB concentrations 140 feet downgradient from the
UST basin.
s
09
U
c
o
U
567
Time (quarters)
10 11
12
cleanups or the effectiveness of
cleanup technologies.
For each corrective action, moni-
toring wells are sampled every three
months (quarterly) to track the effec-
tiveness of the corrective-action sys-
tem. Since the treatment technologies
examined utilize injection and recov-
ery wells, the monitoring wells are
used solely to measure groundwater
quality. For each monitoring well
containing EDB, we plotted the con-
centrations of benzene and EDB
against time.
• Air Sparging
Air sparging has shown mixed
results for treatment of EDB. In one
case, where the EDB plume was con-
fined to the permeable UST basin,
and the air-sparge wells were
installed with overlapping radii of
influence, the EDB rapidly attenu-
ated to below laboratory detection
limits. In all other cases, the mea-
sured concentrations of EDB
increased in the vicinity of the USTs
subsequent to the initiation of air
sparging. Figure 5 depicts the
changes in EDB concentration after
air sparging began at a site located in
Jasper County, South Carolina. In
this example, EDB concentrations
increased in the UST basin two quar-
ters after air sparging commenced.
Because EDB has a fairly high vapor
pressure and a very low Henry's con-
stant, it is possible that the air sparging
• continued on page 14
13
-------
• EDB at LUST Sites from page 13
may evaporate EDB from the LNAPL,
but the vapors may then partition into
the pore water, resulting in elevated
EDB concentrations in the groundwater
(R. Falta, personal communication,
2005).
Figure 6 depicts the concentra-
tions of EDB through time at a point
located 80 feet hydraulically down-
gradient from the UST basin. A large
increase in EDB concentration was
seen five quarters after air sparging
began. Figure 7 shows a large
increase in EDB 140 feet hydrauli-
cally downgradient from the UST
basin during the seventh and tenth
quarters after air sparging started.
Although it is clear that air sparging
is remobilizing some of the EDB, it is
unknown to what extent the EDB
may be volatilized or bioremediated.
• Chemical Oxidation
At some EDB sites treated with
hydrogen-peroxide injection, EDB
concentrations have increased (two
years into cleanup) above precleanup
levels with subsequent erratic con-
centration fluctuations. At other sites,
EDB degradation is suggested. In all
cases, remobilization of EDB is indi-
cated.
• Enhanced In Situ Bioremediation
In the enhanced in situ bioremedia-
tion cases that were observed, EDB
concentrations in the source area
increased by one to two orders of
magnitude subsequent to injection of
the mixtures, and either continued to
increase or fluctuated significantly
during the first two to three years of
corrective action. No verifiable atten-
uation of EDB was observed at any of
the enhanced in situ bioremediation
sites. Note: Although it has not yet been
proven, research suggests that EDB may
degrade better in highly anaerobic set-
tings. If this is true, the addition of oxy-
gen to enhance BTEX degradation may
hinder the EDB breakdown process (R.
Falta, personal communication, 2005).
• Phoster II™
Phoster II, a patented technology
whereby air, nitrogen, and phospho-
rous are injected into the ground as a
vapor to make the nutrients more
readily available to the microorgan-
isms, has shown positive results at
one site where EDB was present. At
this site, the EDB concentration
14
increased from 31 to 49 ug/L one
year after treatment began. However,
during the subsequent two years of
treatment, EDB has shown an overall
reduction to 1 ug/L. Additional mon-
itoring of the ongoing corrective
action will be necessary to determine
whether this technology can reduce
EDB to less than 1 ug/L.
Because of these behaviors, it is
likely that an EDB plume may be
missed by a monitoring-well
network designed for BTEX or MtBE.
Field-screening methods and
monitoring networks may need to be
modified to better address EDB.
• Pump-and-Treat/
Bioremediation Combination
EDB reduction has been favorable at
two sites where a combination of
pump-and-treat and bioremediation
is being used. The cleanup strategy at
each of the facilities is to pump the
groundwater from the ground, treat
the water aboveground using an air
stripper, treat the water in a bioreac-
tor, and subsequently polish the
water using granular activated car-
bon. Nutrients are then added to the
treated water prior to subsurface
reinjection into the plume.
This treatment successfully
reduces EDB concentrations from as
high as 1,100 ug/L to less than 0.02
ug/L a majority of the time. How-
ever, sporadic breakthrough of EDB
at concentrations less than 1 ng/L
has been noted. While concentrations
of benzene and EDB have decreased
favorably in monitoring wells located
in the near-source portion of the
plume (within the capture zone of the
pumping wells), monitoring wells
located on the perimeter of the plume
(outside the capture zone of the
pumping wells) that were historically
clean are now showing low concen-
trations of EDB. Although pump-
and-treat/bioremediation appears to
be an effective combination for treat-
ment of EDB, complete containment
of the plume is still critical given
EDB's high mobility.
Can We Afford to
Ignore EDB?
Although a lot of work is still needed
to understand EDB at UST sites, it is
imperative that we expend time and
effort to quantify its presence at each
release where it is likely to have been
present and make appropriate risk-
based responses to protect human
health and environmental receptors.
EDB is found at approximately half
the releases that have been assessed
in South Carolina. It is toxic, mobile,
and persistent. Natural attenuation of
EDB is very slow and cannot be
relied on in time-sensitive cases with
threatened receptors.
The cleanup of EDB is necessary
at some site's. The available data from
South Carolina sites currently in cor-
rective action suggest that the com-
monly employed technologies for
benzene treatment may not work as
effectively 1'or EDB.
Research Needs
EDB presents many research needs.
A better understanding of the distrib-
ution of residual EDB in the source
areas is critical to developing a good
corrective-action strategy. We need
to better understand EDB's fate and
transport properties as well as its
degradation pathways and processes.
Once these factors are better under-
stood, treatment techniques need to
be adapted accordingly to maximize
the removal efficiency for BTEX,
MtBE, and EDB. •
Rend Miner is n Hydrogeologist with
the South Carolina Department of
Healtli and Environmental Control
Underground Storage Tank Program.
He can be reached at
minerrs@dhec.sc.gov. For more
information on EDB in the environ-
ment, see LUSTLine #47, "Lend Scav-
engers: A Leaded Gasoline Legacy?" by
Ron Falt'i and Nimeesha Bulsarn.
References
Bulsara, N , "The Occurrence of the Lead Scavengers
Ethylene Dibrorrude and 1,2-Dichloroethane in
Groundwater from Leaking Gasoline Underground
Storage Tanks with a Case Study in South Car-
olina," MS Thesis, Clemson University, December
2004
Falta, R. W and Bulsara, N , "Lead Scavengers A
Leaded Gasoline Legacy7" LUSTLine, New England
Interstate Water Pollution Control Commission
Bulletin 47, pp. 6-10, 2004, http://www.neiwpcc org
/lusthne htm
Falta, R. W., Bulsara, N., Mayer, R. A., and Hender-
son, J K., "EDB Contamination from Leaded Gaso-
line," Underground Tank Technology Update, Vol. 19,
No 2, pp. 2-5, March/April 2005.
-------
Leaded Gasoline?
Hmm, What's in Those Underground Storage Tanks?
by Steven Burton
A common misperception today is that leaded gasoline no longer exists. To most people, leaded gasoline
is a relic of the past—gone with the wind. In reality however, leaded fuels are still produced today and used
primarily in small-aircraft aviation and certain off-road vehicles. These leaded fuels are sometimes stored in USTs.
As I have learned, determining the specific constituents of leaded gasoline presents a challenge.
Lead Lives!...Off Road
Leaded gasoline was widely pro-
duced and used throughout the
United States from the early 1920s
until the phase-out of leaded gasoline
began in 1973 and was finalized in
1996, when the Clean Air Act banned
the sale of leaded gasoline for "on-
road" vehicles. Generally, for the
purpose of the ban, all cars, trucks,
and buses that are driven on streets
and highways are considered on-
road vehicles.
Most people today assume that
leaded gasoline no longer exists
because it's not usually available for
sale at most gasoline refueling sta-
tions. However, pilots of small-pis-
ton-engine-powered aircraft and
drivers of off-road vehicles, such as
racecars and racing boats, are well
aware of the existence of leaded fuel.
The types of piston-driven engines
found on small, general-aviation air-
craft, racecars, and the like have
higher performance requirements
due to their high compression ratios.
Leaded fuels found today usu-
ally contain much higher amounts of
octane-enhancing antiknock addi-
tives than normal unleaded fuels
and, as a result, leaded fuels are the
fuels of choice for use in high-perfor-
mance, piston-powered engines. The
Clean Air Act did not ban the use of
leaded fuels in aviation and off-road
vehicles.
What's in Leaded Aviation
and Racing Fuels?
In an attempt to determine what is
present in various leaded-gasoline
formulations, I conducted a limited
search on the Internet for publicly
available Material Safety Data Sheets
(MSDS) from the websites of various
suppliers and manufacturers of
leaded aviation and racing fuels. I
needed this information to support
comments I was preparing for a draft
document being compiled on the
lead scavengers ethylene dibromide
(EDB) and 1,2-dichloroethane (1,2-
DCA).
I obtained four MSDS from the
websites of four different suppliers of
leaded aviation fuels. The leaded avi-
ation fuel most commonly used in
reciprocating piston-engine aircraft is
known as Avgas, and it is usually
found in two main grades—Avgas
100 and Avgas 100LL (low lead). The
number 100 represents the octane rat-
ing of the fuel.
Avgas 100 has a high lead con-
tent and is dyed green for identifica-
tion purposes. Avgas 100LL is the
low-lead version of Avgas 100 and is
dyed blue. Avgas is available in a
variety of other octane ratings, but
the Avgas 100 octane rating appears
to be the most common. I also found
out that Avgas fuels should not be
confused with other aviation turbine
fuels, such as jet fuels, as these fuels
are unleaded. Both Avgas 100 and
100LL grades contain tetraethyl lead
(TEL), chemical abstract service
(CAS) number 78-00-2, which is used
as an anti-knock additive.
I also obtained a number of
MSDS from the websites of two rac-
ing-fuel suppliers. All of these MSDS
also indicated that TEL was a con-
stituent in the fuel formulations.
All of the MSDS had the stan-
dard laundry list of CERCLA haz-
ardous substances that are usually
and customarily found in gasoline,
such as benzene, toluene, ethyl ben-
zene, and xylene (BTEX). But I dis-
covered something was apparently
missing in all of the MSDS except one
of the Avgas 100LL MSDS.
Where There Are Leaded
Fuels, There Must Be Lead
Scavengers!
Recent articles by Dr. Ron Falta of
Clemson University have covered a
considerable amount of information
on EDB and 1,2-DCA, and I will not
duplicate all of that information here.
(See LUSTLine #47, "Lead Scav-
engers: A Leaded Gasoline Legacy?")
But as a quick refresher, both EDB
and 1,2-DCA are synthetic organic
chemicals used as lead scavengers in
leaded gasoline to prohibit the for-
mation of lead oxides on spark plugs
and exhaust valves in piston engines
during combustion.
Recently, I was involved in an
enforcement action and subsequent
court case involving USTs at an air-
port that stored Avgas. The enforce-
ment action required that the
contents of the tanks at the airport be
sampled and analyzed. One of the
tanks stored viable Avgas 100LL fuel.
The volatiles scan of the Avgas 100LL
sample indicated that EDB was pre-
sent in the fuel at 460 milligrams per
kilogram (mg/kg). The amount of
benzene detected in the sample was
120 mg/kg. My experience on this
enforcement case alerted me to the
fact that EDB was a constituent in
Avgas. I wondered why only one of
the Avgas 100LL MSDS listed EDB as
a constituent of the leaded gasoline's
formulation and the other Avgas
MSDS did not.
The Quest for More
Knowledge
I contacted one of the Avgas suppli-
ers whose 100LL MSDS did not list
any lead scavengers and inquired
about the apparent omission of EDB.
At the outset, a number of represen-
tatives denied that EDB was an ingre-
dient in the company's Avgas
formulations in accordance with its
MSDS. Not satisfied with these
answers, I inquired further until I
made contact with an engineer who
was knowledgeable about the com-
pany's aviation fuels and their for-
mulations.
• continued on page 16
15
-------
• Leaded Gasoline from page 15
At first, he also denied that EDB
was contained in the company's
Avgas 100LL fuel. I then asked, if
EDB was not a constituent in the
Avgas 100LL, then what substance
was being used to prevent the forma-
tion of lead oxides on the spark plugs
and exhaust valves during combus-
tion? He replied that he did not know
but would find the answer. Later, he
contacted me and revealed that EDB
was, in fact, a constituent in the
Avgas 100LL. He further explained
that EDB was apparently an additive
in the TEL package the company pur-
chased from a foreign supplier. The
contents of the TEL package are
blended in during the production of
the Avgas 100LL fuel.
Later, I contacted a supplier of
leaded racing fuels whose MSDS I
obtained from the Internet did not list
any lead scavengers and inquired
about what substances were being
used as lead scavengers in the com-
pany's racing fuels. Again, I was
transferred a number of times within
the company in an attempt to find
someone who could answer my ques-
tions. Finally, I made contact with a
knowledgeable company representa-
tive who informed me that the com-
pany's leaded racing fuels did indeed
contain both of the lead scavengers
EDB and 1,2-DCA.
The TEL Tells
In subsequent discussions with these
leaded-fuel suppliers, I was informed
that two suppliers provide TEL anti-
knock-compound packages that are
used in the production of Avgas and
leaded racing fuels in the United
States. I also discovered that both
TEL suppliers obtain their product
from the only remaining site in the
world that actually manufactures
TEL. This manufacturing site is
located in Europe.
I contacted both TEL suppliers
and obtained copies of the MSDS for
their respective TEL packages. All of
the MSDS listed either 1,2-DCA
and/or EDB as an ingredient in the
TEL package formulations. Repre-
sentatives from the TEL suppliers
informed me that generally two TEL
packages are produced, one for
Avgas and another for racing fuels.
Only EDB is used as a lead
scavenger in Avgas. Both EDB and
16
1,2-DCA are usually included as lead
scavengers in racing fuels, but some
racing fuels may contain only EDB.
After further examination of the TEL
MSDS, I found it interesting that the
concentration of EDB in the TEL
package for Avgas is 35.73 percent by
weight as compared to 17.86 percent
in the TEL package for racing fuels.
1,2-DCA is also found in leaded rac-
ing fuels at 18.81 percent by weight.
Be Aware
I have learned a couple of valuable
lessons thus far from this exercise.
First, lead scavengers are not to be
found just at older UST release sites;
they are still key ingredients in
Avgas and racing gasolines. Second,
MSDS do not necessarily list all of the
environmentally significant ingredi-
ents found in leaded fuels. So, when
responding to releases from tanks
storing these products, be aware that
the MSDS may not identify all of the
chemicals of concern, such as EDB or
1,2-DCA. Because of the extremely
low MCL for EDB in drinking water,
this could be especially critical infor-
mation at sites where direct exposure
is a concern.
Stay Tuned
The Occupational Safety and Health
Administration (OSHA) within the
Department of Labor is the federal
agency responsible for setting the
standards for MSDS. Copies of the
various MSDS I obtained from the
Internet have been forwarded to
OSHA's Atlanta Regional Office for
assessment regarding compliance
with OSHA's rules and require-
ments. The results of their review
may be discussed in a future LUST-
Line article. •
Sfci'ci! Burton is fin Environmental
Scientist u'lth U.S. EPA Region 4 and
manages the Region's LUST Trust
1'itiid. He can he reached at
burton.sleven@epa.gov. For more
nitornuitior about lend sctnvngers, visit
El'A's 1.,'iui Scavengers website at
http://www.epa.gov/oust/
pbscavms.pdf.
NEIWPCC Publishes Source-
Water Protection Guide
by Kara Sergeant, NEIWPCC
What steps can municipal officials take to protect public drinking
water supplies? NEIWPCC provides the answers in Water Today...
Water Tomorrow? Protecting Drinking Water Sources in Your Commu-
nity: Tools far Municipal Officials, a new 52-page guide funded iby U.S.
EPA. The target audience of municipal officials includes town employees
and volunteers on planning boards, conservation commission members, and other related posi-
tions. These are the people with the power to make decisions al the community level, such as
enforcing a new protective zoning ordinance or starting a septic-tank registration database.
For the most part, states have already begun the protection process by developing useful
Source Water Assessment Program (SWAP) reports that assess potential threats to public water
supplies for each area in the state. NEIWPCC created the guide and a companion series of fact
sheets to help officials understand these reports and identify ways they can implement protec-
tion at the municipal level. The guide even provides useful ideas for towns with mostly private
wells.
The guide focuses on five key areas of vulnerability as identified by state groundwater and
source-water protection managers—local regulations and ordinances, underground storage
tanks, on-site sewage disposal systems, hazardous materials storage, and stormwater runoff.
The guide features background materials for those who want to learn the basics of source-water
protection, and specific strategies for action on each of the five topics. The guide is color-coded,
so it is easy to find information on septic systems, for example, if that is the main concern in a
community. Each of the five topic chapters contains several case studies showcasing ways other
towns and communities have addressed those problems.
Written and designed for NEIWPCC by Enosis-The Environmental Outreach Group, the
guide and fact sheets have been widely distributed, and only a limited number of printed copies
remain. At this time, we must limit orders to one set of materials. The shipping charge for one
set of fact sheets and a guide is $2.50. To order a copy, send your name, address, and phone
number to NEIWPCC at the address on the back of LUSTLine. The guide and fact sheets can also
be downloaded for free at our website (www.neiwpcc.org/sourcewateroutreach).
For more information about the project, contact Kara Sergeant at ksergeant@neiwpcc.org.
-------
10,000 Facilities to Inspect!
GIS Shines a Light in the Long, Dark Tunnel
by Rebecca Jamison
Problem #1: More than six million people depend on groundwater as a source of drinking water in New York State (NYS)
(NYSDEC, 1986; NYSDEC, 1987). Many of these drinking-water source areas are underlain by highly permeable aquifer systems
that are vulnerable to contamination.
Problem #2: U.S. EPA Region 2 Ground Water Compliance Section (GWCS) (http://www.epa.gov/docs/Region2)
extensively supports the UST programs of New York, New Jersey, the Virgin Islands, and Puerto Rico and directly implements the
Underground Injection Control (UIC) programs in New York and the Virgin Islands. With a staff of 12 inspectors (five UST and
seven UIC), GWCS faces a huge challenge in implementing the programs. With a potential 120,000+ UIC locations in NYS alone,
and hundreds of UST referrals, our inspection staff faces a daunting task in determining where to go. Which areas are most vulnera-
ble to contaminants and which communities should we focus on first?
The Risk Focus
As a response, the Region began uti-
lizing a groundwater-endangerment-
risk analysis approach in 2002.
Charles Hillenbrand, of U.S. EPA
Region 2, laid the groundwork by
creating a regional Groundwater-
Endangerment-Risk Map for New
York State in 2001. This map consid-
ers the following key factors:
• Risk of introducing contaminants
at or near the surface of the earth
as a function of land use
• Susceptibility of aquifer systems
to contamination, which is a
function of vertical linear veloc-
ity of the unsaturated zone and
the depth to the water table
• Human use of groundwater as a
source of drinking water.1
To utilize Hillenbrand's hydro-
geological analysis, the following
map layers are imported:
• State/federal facility information
• Dunn and Bradstreet commercial
listings
• North American Industry Classi-
fication System (NAICS) data
• Land-use information from the
USGS
• Census data on sewered/non-
sewered communities.
These combined data layers indi-
cate the geographic regions with the
greatest potential for rapid transport
of contamination to drinking water—
high-risk areas. With this informa-
tion, the UST/UIC program then
utilizes ArcMap 9.0 to review inspec-
tion referrals, decide on focus areas,
and interpret and address agency pri-
orities (e.g., Environmental Justice,
Children's Health Initiative).
How Is the Risk Map Used?
With the information input into GIS,
EPA focuses on facilities that typi-
cally use significant quantities of haz-
ardous substances and that are
located in areas with the following
characteristics:
• relatively fast surface-to-ground-
water travel rate
• groundwater serves as the pri-
mary source of drinking water
(public and/or private)
• no public wastewater treatment
systems (nonsewered).
than the largest surface dimension
(length or width) of the disposal facil-
ity. UIC Class V wells are shallow
wells that inject nonhazardous
wastes. They are typically on-site dis-
posal systems, such as floor and sink
drains, leach fields, and similar types
of drainage wells. This category
includes the motor-vehicle waste-dis-
posal wells that are the subject of this
report.
Table 1 displays the results of
UIC Class V well inspections per-
formed during the first half of fiscal
year 2003 as compared to UIC facility
inspection results from the first half
of fiscal year 1997. The table consid-
ers facilities that have been inspected
and located by a global positioning
system (GPS).
TABLE 1 SUMMARY OF UIC WELL IDENTIFICATION— 1997 AND 2003.
Fiscal Year
1997
2003
Total
GPSed
UIC
Inspections
185
235
Class V
Wells
Discovered
29
78
Percentage
of Wells
Discovered
16%
33%
Wells in
High GER
Areas
2
78
Percentage
of Wells
found in
GER Areas
1%
33%
UIC Inspection-Targeting
Results
In October 2002, the UST/UIC pro-
gram began using the Risk Map for
UIC Class V wells, targeting well
inspections in NYS. The law defines
an injection well as any bored,
drilled, or driven shaft or dug hole
used to discharge fluids under-
ground, where the depth is greater
As shown in Table 1, of the 185
inspections performed in 1997,29 UIC
Class V wells were discovered. Of
these wells, only two were located in
areas of significant groundwater-
endangerment risk (GER). The 1997
rate of UIC Class V well discovery per
inspection was 16 percent, but only 1
percent of the inspections yielded UIC
Class V wells in areas of significant
groundwater-endangerment risk.
• continued on page 18
17
-------
\GlSfrompagel7
Table 1 also shows that in 2003,
235 UIC Class V well inspections
yielded the discovery of 78 UIC Class
V wells in areas of significant ground-
water-endangerment risk. In 2003,
UIC Class V well inspections yielded a
Class V well discovery rate of 33 per-
cent; the rate of discovery of UIC Class
V wells in areas of significant ground-
water-endangerment risk was also 33
percent.
UST Inspection-Targeting
Methodology
For UST inspection targeting, NYS
UST registration data is used to post
UST facilities in areas of significant
groundwater-endangerment risk.
The UST/UIC CIS liaison then identi-
fies UST facilities for inspection
based on (a) the risk rankings and (b)
desired focus (e.g., location, sector).
A map and a spreadsheet are created
to reference pertinent UST data and
information. Both are provided to the
inspectors in advance of their deploy-
ment.
Another target that may be con-
sidered when conducting UST
inspections is a location where vapor
intrusion may be an issue. Vapor
intrusion is the migration of volatile
chemicals from the subsurface into
overlying buildings. Volatile chemi-
cals in buried wastes and/or in cont-
aminated groundwater can emit
vapors that may migrate through the
subsurface and into air spaces of
overlying buildings.2
Adapting for Changing
Priorities
It is very easy to incorporate new and
emerging policy areas into GIS for use
in program planning and goal setting.
Within the last year, we have
smoothly integrated emerging agency
priorities into our overall methodolo-
gies. Below are three examples.
• Source Water
Assessment Program
During the past few years, the
national UST program has put an
emphasis on conducting more fre-
quent inspections in Source Water
Assessment Program (SWAP) areas.
A source-water assessment is a study
and report that provides basic infor-
18
High Risk Level 1
0 High Risk Level 2
High Risk Level 3
Inspection Targets
mation about the source used to sup-
ply drinking water to a particular
water system. The assessment identi-
fies drinking-water sources and the
areas of land that most directly con-
tribute the raw water for those
sources. Assessments also identify
the major potential sources of conta-
mination of drinking-water supplies.
This information is used to determine
how susceptible a water system is to
contamination.3
Region 2 has the ability and data
to include NYS surface water areas
(reservoirs and their drainage basins)
in targeting analyses. Surface water is
also used in heavily populated areas
of New York, such as Syracuse (Hem-
lock and Candace Lakes), New York
City (Croton Reservoir watershed),
and Albany (Alcove Reservoir).
With our mapping work, EPA
Region 2 is at the forefront of coordi-
nating UST and SWAP information.
Much of the GIS mapping done by
the GWCS from 1999 to 2004 incorpo-
rated 500-meter buffers around pub-
lic water supply wells. As the SWAP
areas are officially defined by state
and local agencies, EPA reviews New
York's UST risk areas (ranked from 1
to 3) and incorporates them into des-
ignated SWAP areas. Currently, the
NYS SWAP areas are in our highest
risk categories, levels 1 and 2.
• Environmental Justice
In 2004, Region 2 identified a poten-
tial Environmental Justice (EJ) area in
Rochester, New York. All media pro-
grams were asked to participate in
providing compliance assistance and
enforcement to the community.
Using the targeting methodology
described earlier, we faced a chal-
lenge. Given that Rochester (a) is
largely sewered, (b) has its source of
drinking water located at two reser-
voirs south of the city, and (c) has no
federally regulated UST facilities
within the prescribed EJ area, how
could we support the Region's Rochester
EJ initiative?
Using our Risk Map, we focused
on facilities around the two reser-
voirs south of Rochester as targets for
UST/UIC inspections, and created
buffer zones around the Genesee
River on the western boundary of
Rochester. The Genesee River origi-
nates in Pennsylvania and ends at
Lake Ontario in Rochester. The upper
Genesee River (southern New York)
is a well-known destination for
brown trout fishing, and in Rochester
itself surprising catches of salmon
have been noted. The east bank of the
Genesee in Rochester proper has a
history of heavy industrial usage.
Therefore, to support the
Region's EJ initiative, we focused on
the Monroe County portion of the
source of water for the EJ neighbor-
hood and on the urban Genesee
River, which is still heavily fished.
Then, utili/dng Dunn and Bradstreet
and the New York State Petroleum
Bulk Storage databases, we targeted
nearly 100 facilities for the initiative.
-------
• Changing Priorities and
Addressing Public Concerns
When public concerns arise via the
press, governmental leaders, or other
avenues, the Risk Map has proven to
be a very adaptable and flexible tool
while still ensuring the program's
focus on protecting groundwater.
When a particular business sector is
identified, by using an existent data-
base, such as state or federal registra-
tion information (e.g., environmental
or Department of Motor Vehicles)
and/or commercial listings (e.g.,
Dunn and Bradstreet and North
American Industry Classification
System (NAICS) identification), data
pulls can be undertaken to identify
potential facilities for review, com-
pliance assistance, and inspections.
The map can also focus in on par-
ticular geographic features, such as a
river, lake, or pond, a watershed area,
or a village, town, or county. A lot of
this information is now readily avail-
able from commercial (ESRI), state (GIS
programs), and federal sources (e.g., U.S.
Geoglogical Survey, U.S. EPA).
Cutting Down Hunting Time
The enormous amount of time
invested in creating and organizing a
groundwater protection mapping
system has paid off in how expedi-
tiously we are now able to handle
successive projects. This approach
has reduced the targeting process
from a multi-day analysis to one that
can be accomplished in less than an
hour, which includes generating a
complete list of facilities and a large
map for the inspector. Providing a
map to an inspector is a valuable
time-saver, especially if the inspector
is conducting routine inspections
alone rather than as part of a team.
Maps can be prepared that show the
locations of targeted facilities, major
transportation routes, nearby water
bodies including rivers and lakes,
public water supply wells, and any
other information an inspector feels
may be helpful. (See Figure 1.)
Overall, the use of GIS helps us
to refine our focus through objective
and measurable processes, assists us
in our endeavors to safeguard drink-
ing-water sources, and affords us
considerable time savings in target-
ing our compliance-assistance and
inspection efforts. Using GIS has
improved our ability to identify envi-
ronmentally sensitive areas and spe-
cific or potential threats to those
areas. Overall, our planning and effi-
ciency in protecting the environment
have been dramatically improved. •
Rebecca Jamison is a LIST and LUC
Injector at EPA Region 2. Slic also
conducts targeting for the tu'o pro-
grains using the Hillenbrand hi/dro-
geological model in CIS. She can be
contacted at
Jamison.rcbecca@epa.gov.
Notes
1 Hillenbrand, City University of New York, 2002
2 Evaluating the Vapor Intrusion into Indoor Air.
United States Environmental Protection Agency.
November 2002, EPA530-F-02-052 http://www.epa.
gov/correctiveactwn/eis/vapor/f02052,pdf
3 EPA Source Water Assessment Program website,
htifllwww epa.gov/safewater/protect/assessment.html
Methodology: Groundwater-Endangerment-
Risk Analysis
by Charles Hillenbrand
The use of GIS technology has
allowed U.S. EPA Region 2 to
prioritize areas for inspection
in New York State (NYS). A ground-
water-endangerment-risk (GER) grid
was devised based on a modified
Human Health Risk Index (HRI) for-
mula (Carney 1991). A GER value is
the result of dividing a land-use risk1
by aquifer susceptibility2 and multi-
plying the result by the ratio of a
population dependent upon ground-
water as a source of drinking water
to a total population.3
The risk-ranking scheme used to
create the GER grid is analogous to a
modified HRI formula (Carney
1991). The HRI is equal to the prod-
uct of Hazard and Exposure.
HRI = Hazard x Exposure
Hazard = (DI x DV)
Exposure = (( PE / PC ) x Ef)
DI = Degree of Impact
DV = Degree of Vulnerability
PE = Population Exposed
PC = Population in Community
Ef = Exposure Factor
The Hazard component of the
HRI formula is a product of Degree of
Impact and Degree of Vulnerability.
The Degree of Impact is a chemi-
cal-specific component in the HRI
that assesses the degrees of cancer
and noncancer potency, mutagenic-
ity, environmental fate, and pharma-
cokinetics. The GER analysis uses a
land-use-risk data layer4 to assign a
Degree of Impact. The U. S. Geologi-
cal Survey (USGS) Multi-Resolution
Land Characteristic data layer was
analyzed to produce a relative-envi-
ronmental-risk comparison of the 15
different land-use classifications.
This analysis assessed the risk of
introducing contaminants near the
surface of the state.
The Degree of Vulnerability com-
ponent in the HRI is a measure of the
vulnerability of the population to
adverse reaction due to exposure.
Factors such as age, lifestyle, and
pre-existing disease are quantified
when selecting a Degree of Vulnera-
bility. In the GER analysis, the
Degree of Vulnerability was assigned
according to the hydrogeologic vul-
nerability of the aquifer system to
receiving contaminants.
The GER analysis uses an inverse
of the aquifer-susceptibility grid as a
Degree of Vulnerability component.
USGS and NYS Geological Survey
hydrogeologic and geologic data lay-
ers were analyzed to produce an
aquifer-susceptibility grid for NYS.
Aquifer susceptibility is a value
that is derived by aerially comparing
relative vadose-zone residence times
under maximum load. Vadose-zone
residence time can be a predictor of
aquifer susceptibility—a short resi-
dence time indicates that contami-
nants may be introduced to the
• continued on page 27
19
-------
"Elite
Vi
A roving column by reporter P.itricia Ellis, a Hydrologist with the
Delaware Department of Natural Resources and Environmental
Control, Tank Management Branch. Pat served as a member of
U.S. EPA's Blue Ribbon Panel on MtBE. She welcomes your
comments and suggestions and can be reached at
Patricia.Ellis@state.deMS.
County Websites to the Rescue
There are days when you want
to throw your computer out
the window—the network is
slow, it locks up right when you're
almost finished with a time-consum-
ing task and haven't saved your
work yet, e-mails come flying in
every few minutes, interrupting, cre-
ating more stuff to do. But there are
also days when you want to hug it
for making life easier.
I've had several projects involv-
ing a large number of properties in
addition to the property where tanks
have leaked. One of the difficulties in
dealing with projects like this is that a
large number of property owners
may need to be notified for one rea-
son or another—to sample wells in
their area and send out sample
results afterward, to notify people
about community information meet-
ings, or to get permission and signa-
tures on permits to install monitoring
wells at off-site locations. In the past,
we've had to sketch out an area in the
hope that the county tax office would
help with names and addresses. This
process could take weeks. It was even
harder for many of the consultants
working on these projects who were
from out of state.
With the Web, this information is
now available with just a few key-
strokes. Each of Delaware's three
counties now has this information
available online. The design of each
of the sites varies, as does the amount
of detail available, but the basics are
there. I can get great maps showing
tax parcels, and then zoom in to get
the maps to be just about any scale I
might need. Once I've located the
20
parcel numbers, it's quick to get
property owners' names and
addresses.
For one of my projects, located in
the Rehoboth Beach resort area,
about half of the property owners are
full-time residents and the other half
are weekend or summer residents.
The website gives me the addresses
where the tax bills are mailed, so I
can reach homeowners in Virginia,
New Jersey, or Pennsylvania—wher-
ever they call home when they're not
at the beach. Also, I'd much rather
address a letter to a real person than
to "Resident," or something equally
impersonal.
Once I've gotten the names and
addresses that I need, it does take
longer to track down phone numbers.
I use a combination of the Internet
white pages, local phone books, and
directory assistance.
For some areas,
we have the criss-
cross index avail-
able, where I can
look up street
addresses and get
phone numbers for
many of the resi-
dents. Using a vari-
ety of sources, I can
usually manage to
track down most of
the phone numbers
for the residents in
a neighborhood.
The neighbors are
sometimes willing
to help out with
phone numbers as
well.
Bird's-Eye Views
All three of our county websites
have been updated so that aerial
photographs are also available
online. I've now got a bird's-eye
view of any of my sites. I can see a
large area, or I can zoom in and
locate the tank field, the dispensers,
and even where some of the utilities
are that might dictate where moni-
toring wells can't be located. Some-
times I can spot other potential
sources without even leaving the
office! One of the county websites
even tells me whether there is a base-
ment in the building (potential path-
way for vapor intrusion), and
whether the property is served by
public water.
The three county websites vary
in their searchability. I can search by
street address, property owner, or
Screenshot of Kent County "Smart Map" Web page showing a tax-
parcel map. Once the tax-parcel number is obtained, a different sec-
tion of the county website will give owner information. Different
data layers can be toggled on and off
-------
Screenshot of New Castle County Web page showing the layer with recent (color) aerial photo-
graph. The parcel in the center of the photograph shows a gas station, where the canopy; con-
crete pad over the tank field; patches in the paving from removal of a diesel tank, dispensers and
product lines; and patches from installation of the Stage II vapor-recovery lines are clearly visible.
parcel number, or I can just keep
zooming in until I find my site. There
are lots of other layers that can be
toggled on and off to provide addi-
tional information. Two of the three
county sites tell me the year when
each building on a property was
built. I know that if most of the
homes in an area with no public
water were built in the 1950s, I'm
probably not going to be able to get
much information about well-con-
struction details because most of the
wells pre-date the permitting
requirements.
The DataMIL
The Delaware DataMIL (Delaware
Mapping and Data Integration Labo-
ratory) is a joint project of the United
States Geologic Survey, Delaware
Geologic Survey, University of
Delaware, and Delaware Geographic
Data Committee. It's an online GIS-
based pilot project for the National
Map (http://datamil.delaware.gov/home.
asp). From this website, I can pull up
the most recent topographic maps for
an area. The DataMIL allows me to
save maps that I have created and to
extract various layers for use in other
GIS projects. The ability to import
information into other applications
makes the DataMIL a more flexible
tool than the county websites.
I've got parcel maps that I've
downloaded for most of the projects
where I deal regularly with a large
number of residents. It's a good
graphic display of who's who in an
area, so when I get calls from resi-
dents, it's easy to visualize where
they are with respect to the source
and the plume.
Zoom Zoom Zoom
We recently got a call from our public
health people reporting a well with
MtBE contamination. We were able
to quickly pull up a tax-parcel map
showing the property and surround-
ing area. The aerial photograph
showed which properties had homes
and farm outbuildings, so we could
determine how many properties
would need to have wells sampled.
We made arrangements with the lab
to have a fairly firm number of sam-
ples analyzed. Addresses for all
nearby property owners were
quickly obtained so residents could
be notified in advance that our
department wanted to collect well
samples and why. Having the ability
to pull this information off the Web
in advance eliminated the need to
make a preliminary reconnaissance
trip.
So, kudos to each of our three
counties! Their websites may have
different designs for providing tax-
parcel information, and the amount
of detail may differ from site to site.
But each of the three counties has cre-
ated a tool that helps make at least
one part of managing my projects a
little easier. •
UST-SWP: Programs
Work Together to
Protect Drinking Water
The New England Interstate Water
Pollution Control Commission
(NEIWPCC) initiated meetings in
Illinois and Minnesota (Region 5) to
facilitate discussion between UST and
source-water protection (SWP) pro-
grams on ways to reduce potential
drinking-water contamination from
USTs. Since these programs have lim-
ited resources, it makes sense to part-
ner together to protect water supplies.
The goal of the meetings was to
develop a written agreement, perhaps
in the form of a memorandum of
understanding (MOD). Both states
were at different levels of integration,
but their programs were split between
different agencies.
The Illinois Source Water Protection
program offered to train state UST pro-
gram personnel on how to use the
GEOcode system—the electronic data-
base on source-protection areas and
threats—in order to prioritize inspec-
tions in those areas. The UST program
agreed to share inspection results with
the drinking-water program. Partici-
pants also identified other partners that
play key roles in implementing this
effort on the local level, including
boards of health and the Rural Water
Association.
The Minnesota Source Water Protec-
tion program already has an MOU with
its LUST program. An important goal
established at the meeting was to find
out whether the state's source-water
inventory matches UST location data,
since both maintain separate data sys-
tems. SWP personnel agreed to iden-
tify areas they felt were most
threatened by USTs, using the data
from source -water protection reports.
EPA Region 5 agreed to perform a per-
centage of its federal inspections in
source-water protection areas and to
follow up with both states as they
move forward with their collaborative
efforts. •
21
-------
nically Speaking
by Marcel Moreau
Marcel Moreau is a nationally
recognized petroleum storage specialist
whose column, Tank-nically Speaking,
is a regular feature o/LUSTLine. As
always, we welcome your comments and
questions. If there are technical issues
that you would like to have Marcel
discuss, let him know at
marcel.moreau@juno.com
I've Looked at Tanks from forth Sides
Some years ago, I was speaking
about UST inspections at an UST
conference to a roomful of sev-
eral hundred tank owners and opera-
tors (O/Os). To try to warm up the
audience, I was foolhardy enough to
ask for a show of hands of those who
thought that regulatory inspections
were a useful thing. I was soon gaz-
ing at a roomful of the stoniest faces I
have ever seen from a podium. The
chill in the air was palpable.
Sensing I had perhaps succeeded
in creating an instant iceberg where I
had hoped to break some ice, I said
with somewhat of a gulp, "Nobody,
huh?" Fortunately, I was rescued by
one brave soul who finally raised his
hand and said, "I think inspections
are great. They let me know what I'm
doing right or wrong, and I know
that they help keep my competition
honest too." I thanked the man and,
with not much enthusiasm, launched
into my talk.
That day, I became painfully
aware of the depth of my misunder-
standing of my O/O audience. Since
then, I've recognized the importance
of trying to see things from both sides
of the table.
So when John Cochran (New
Mexico Environment Department
UST Program) called to see if I
wanted to talk about inspections at
this year's UST/LUST National Con-
ference in Seattle, we began to brain-
storm about creating an opportunity
for inspectors and O/Os to share
their views about inspections, and for
each side to try their hand at guess-
ing what the other side would say.
We figured this would be a good way
to get a reality check on how well
each side understands the other.
We invited some regulators and
O/O representatives to join our
panel. These people were not ran-
domly selected and we made no
22
hat's not
what the last
inspector said.
Why can't they
get their story
straight?
effort to determine how representa-
tive they were of the inspector or
O/O general populations. This was
not intended to be a statistical study,
but rather a vehicle for fostering dis-
cussion.
We gave the panel some basic
questions to think about ahead of
time, but we didn't really know what
they were going to say. During the
session, we asked three questions:
• What is the purpose of an UST
compliance inspection?
• What are the benefits of an UST
compliance inspection?
• What are the problems with UST
compliance inspections?
Panelists were asked to answer
each question, first wearing their
own "hats" and then making a
switch to what they thought the other
side would say. The audience was
also invited to provide their input.
Comments were summarized "live"
and presented to the group via a
computer projector. The answers we
received are summarized in the
tables that accompany this article. My
thoughts upon reviewing the
answers an? as follows.
What Is the Purpose of an
UST Compliance Inspection?
Speaking from their respective points
of view, inspectors and O/Os agreed
on many of the purposes of an
inspection. Noticeably lacking from
the O/O perspective was protection
of human health and the environ-
ment (although this thought did
show up as a compliance inspection
benefit when O/Os were speaking as
inspectors). A key concern of O/Os
that came out in these answers, even
though it doesn't directly address the
question, was fairness in the inspec-
tion process.
When guessing what they
thought the other side would say in
-------
response to the question, the O/Os
seemed to have a pretty good under-
standing of the inspector's point of
view. Inspectors' answers didn't cor-
relate quite so well, but my suspicion
is that the inspectors may have been
voicing some typical "mom and pop"
O/O concerns (e.g., Why pick me?
What's going to happen to me? Look-
ing for free consulting) and mom-
and-pop O/Os were not represented
among the O/O panelists.
What Are the Benefits of an
UST Compliance Inspection?
I find it interesting that when speaking
from their respective points of view,
the O/Os' and inspectors' responses
were quite consistent in so far as they
went, but the inspectors' list of benefits
was substantially longer than the
O/Os'. I was encouraged to see that
both sides recognized that inspections
are an opportunity to establish rapport
between inspectors and O/Os.
Both sides were reasonably accu-
rate in predicting what the other side
would say. Again, the inspectors
speaking as O/Os included some
thoughts that are more likely to come
from mom-and-pop operations than
from the O/O representatives on our
panel.
What Are the Problems with
UST Compliance
Inspections?
This question raised the most con-
trasting viewpoints and provided
some food for thought on both sides.
While inspectors felt that the O/Os'
reluctance to ask for help and igno-
rance about UST systems were signif-
icant problems, O/Os emphasized
inconsistencies in the interpretation
of the rules and in inspections over
time.
What inspectors saw as a failure
of O/Os to ask for help, O/Os saw as
a failure of inspectors to clearly
explain expectations. Inspectors saw
a lack of knowledge (i.e., training)
regarding storage systems on the part
of O/Os, while O/Os pointed to a
lack of training of state inspectors
(O/Os also acknowledged that O/Os
are in need of training). Overall, it
seems to me that communication,
consistency, and training are areas
that both inspectors and O/Os could
improve on.
When O/Os put their inspector
hats on, they came up with a list of
problems that was quite consistent
with that of the inspectors. Inspectors
wearing O/O hats, however, focused
on a perception on the part of the
O/Os that inspections are inconve-
nient, and completely missed the
O/Os' concerns for consistency and
clear communication. Again, this
may be due to the inspectors' focus
on the mom-and-pop response to
inspections rather than the larger
companies represented on the panel.
Parting Thoughts
This session reaffirmed for me that
frank dialogue is critical to "seeing
ourselves as others see us." Assessing
issues from different points of view is
a very valuable tool in determining the
kinds of changes that might promote
improved performance. Creating
opportunities for dialogue might be an
important first step in making life eas-
ier for both inspectors and O/Os.
Some years ago, I visited a Ger-
man tank-fabrication plant on the
same day that the regulatory inspec-
tor was due for a visit. I was struck
at the time by the plant manager's
apparent eager anticipation of the
inspector's visit. The plant manager
explained that the inspection would
consist of the inspector picking a few
tanks off the production line at ran-
dom and running some tests. The
plant manager was not at all con-
cerned that the tanks might fail. The
tank-construction standards were
clear and his production techniques
were careful.
The plant manager was, how-
ever, planning to take the inspector
to lunch. He had some tricky steel
fabricating to do on a project and he
was hoping the inspector would
give him some tips on how to do it.
In Germany, being an inspector is
not an introductory position; it is a
position you achieve after much
study and many years of experience
in your field.
While I do not expect that the
German model of inspections will
be adopted in this country, the idea
of inspectors and O/Os sitting
down to lunch together does hold
some appeal...even if it's just a
brown-bag affair. Imagine how dif-
ferent life might be if on a monthly
basis a brown-bag luncheon were
held at some VFW hall or other neu-
tral, low-key venue with the stated
purpose of allowing inspectors and
O/Os to sit down, get to know each
other, and discuss issues of common
concern.
These are my thoughts. What are
yours? •
What Is the Purpose of an UST Compliance Inspection?
Inspector Speaking as Inspector
0/0 Speaking as 0/0
Ensure compliance
Provide compliance assistance
Look for leaks
Allow level playing field
Keep O/Os on their toes
Protect health and environment
See if O/Os are operating responsibly
Determine compliance
Provide education for 0/0
Respond to threats
Allow level playing field
Ensure recordkeeping
Fairness expected
0/0 Speaking as Inspector
Inspector Speaking as 0/0
Ensure compliance
Help 0/0 with compliance
Identify faulty components
Determine that equipment is operating properly
How do I measure up to regs?
What do I need to do?
Why pick me?
What's going to happen to me?
Looking for free consulting
continued on page 24
23
-------
Inspector Speaking as Inspector
What Are the Benefits of an UST Compliance
0/0 Speaking as 0/0
Allow face-to-face contact (personalize bureaucracy)
Provide two-way education
Get to know 0/0 (educate me)
Correct problems
Deter violations
Discover problems, releases
Encourage compliance through credibility of inspector
(we are doing our job)
Reduce risk to environment
Provide outreach to small 0/0
Can save 0/0 cost of unnecessary testing
Protect investment in property
Can allow discussion on issues concerning contractors
(misinformation, poor workmanship)
Establish rapport
Audit processes to be sure they're working
Point out deficiencies
Offer quality assurance (another set of eyes to look at
operation)
0/0 Speaking as Inspector
Inspector Speaking as 0/0
Provide face-to-face meeting
Establish a presence
Even the playing field
Ensure things are working
Make sure leak detection is in effect
Allow inspector to see who is a good 0/0 and who is not
Protect environment
Verify maintenance and operation of equipment
Let 0/0 know about the penalties (especially red tag)
• Establish rapport
• Personalize bureaucracy
• Maintain a level playing field (I know you are out here)
• I'm glad you told me what to do
• Unbiased opinion about leak detection and work that needs
to be done (misinformation from contractors)
• Hear directly from regulator what needs to be done
• Get management's attention
What Are the Problems with UST Compliance Inspections?
Inspector Speaking as Inspector
0/0 Speaking as 0/0
• Find compliance—not violations
• 0/0 don't ask for help
• Failure of 0/0 to communicate needs to agency BEFORE
inspector gets on-site
• Insufficient records or information
• Lack of knowledge about UST system
• Language barriers
• Apathetic attitude on part of 0/0
• Attitude of inspector (help? or enforce?)
• Inconsistent interpretation of the rules
• Inconsistent inspections over time
• On-site personnel often do not communicate problems dis-
covered to upper management so that they can be
addressed
• Need for clarity in explaining the violation and basis in rules
• No clear expectations (what do you want?)
• High fines for innocent paperwork violations
• Multiple inspections by multiple agencies (e.g., UST, food,
air, weights, and measures)
• Surprise inspections
• Lack of training of 0/Os and inspectors
0/0 Speaking as Inspector
Inspector Speaking as 0/0
Frustration with repeat offenses
Scheduling
Cultural and language barriers
Availability of paperwork
Lack of knowledge of rules on part of 0/0
Lack of training on part of 0/0
Not having right people on-site (unannounced inspections)
Not having right equipment (e.g., dispenser keys, tools to
remove sump lids)
0/0 attitude may be a problem
I have to count twinkies (0/0 has more important things
to do)
You're interfering with my day
This is costing me money
Why do you inspect me so often? (Note: Because many
0/Os do not distinguish between state-agency and EPA
personnel, they feel unfairly targeted when both agencies
happen to inspect the same facility.)
24
-------
Making; Sense of UL 971
The Revised Nonmetallic Piping Standard
by Laura Chaddock
On January 2, 2004, Underwrit-
ers Laboratories Inc. (UL)
revised its standard for Non-
metallic Underground Piping for Flam-
mable Liquids (UL 971). The revised
standard became fully effective on
July 1, 2005. In order for manufactur-
ers to continue to apply the UL mark
to piping manufactured on or after
July 1, 2005, their piping must
undergo a review and be tested for
compliance with the revised stan-
dard. Only piping that UL finds to be
in compliance with the revised stan-
dard will be authorized to continue
to bear the UL mark. The following
questions and answers are intended
to provide a brief overview of the
new UL 971.
Why was UL 971 revised?
Nationwide reports of nonmetallic
underground storage tank pipe fail-
ures and reports indicating that not
all nonmetallic pipe is performing as
intended prompted UL to take a criti-
cal look at UL 971. UL reports that
these nonmetallic pipe failures are a
result of improper pipe system instal-
lation, inadequate pipe system main-
tenance, failure to properly respond
to leak-detection alarms, and other
unspecified causes.
What are some of the differ-
ences between pre- and post-
July 1, 2005, UL 971-listed pipe?
The most critical difference between
pre- and post-July 1, 2005, UL 971-
listed pipe is the physical testing to
which the pipe is subjected. The
revised UL 971 standard requires
more stringent physical testing,
which is intended to better simulate
long-term use and real field condi-
tions and therby improve the ability
of post-July 1,2005, pipe to withstand
the conditions found at operating
UST facilities.
For example, prior to undergoing
compatibility and permeability test-
ing, pipe samples will be precondi-
tioned by being subjected to bend,
drop, and impact tests. Conducting
compatibility and permeability tests
on pipe that has been preconditioned
with the usual abuse pipe experi-
ences during transport, assembly,
and installation better approximates
true installation and field conditions.
As another example, to address pipe
degradation resulting from long-term
exposure to fuel, pipe samples will
now be subject to more stringent
compatibility and permeability test-
ing that incorporates new criteria for
dimensional stability and increased
minimum-retention values.
Other major revisions to UL 971
include evaluating piping as a system
(rather than evaluating individual
components) and a requirement for
installation of pipe by qualified per-
sons.
In summary, the standard was
revised to incorporate more stringent
testing and installation requirements
so that pipe systems manufactured to
meet this revised standard have less
chance of experiencing the failures
we have seen in the past. (See LUST-
Line Bulletins 47, 45, 43, and 42 for
more information on nonmetallic
piping failures.)
Does pre-July 1, 2005, UL 971
pipe maintain its listing?
July 1, 2005, is when newly manufac-
tured pipe must meet the revised UL
971 standard. It does not affect the
listing of existing pipe manufactured
prior to July 1, 2005. Therefore, UL
971-listed pipe manufactured prior to
July 1, 2005, can remain in the
ground. It should be noted that after
July 1, 2005, some states might not
allow piping to be installed that does
not meet the revised UL 971
standard. Owners /operators and
installers should check with their
state UST programs before installing
nonmetallic pipe after July 1,2005.
Note: Inspectors and owners/opera-
tors should know that purchasing UL-
listed pipe after July 1, 2005, does not
guarantee that the pipe was manufac-
tured after July 1, 2005, and meets the
revised UL 971 standard. In fact, it may
take months or even years before the pre-
July 1, 2005, pipe stock is depleted.
How do I identify pipe
manufactured on or after
July 1,2005?
Pipe manufacturers are required by
UL to mark the date of manufacture
on the pipe at ten-foot intervals, and
on fittings or fitting bulk packaging.
Most pipe manufacturers use what is
called a modified "Julian Date Code."
This code typically consists of a two-
digit code for the year in which the
pipe was made (for example, 2005
reads as 05), and a three-digit code
for the day of the year (from 001 to
365) or a four-digit calendar month
and day notation (for example, 0101
for January 1).
Depending on the pipe manufac-
turer, a modified Julian Date Code for
piping manufactured on May 12,2005
could read 05132 (two-digit year
identified first, followed by the three-
digit code for the day of the year), or
13205 (three-digit day of year identi-
fied first, followed by the two-digit
year code), or 050512 (two-digit year
identified first, followed by two-digit
calendar month, ending with the cal-
endar day).
Because manufacturers use differ-
ent Julian Date Codes, it will take time
and research to determine the date on
which a given pipe was manufac-
tured. If you are unable to locate or
decipher the date, you can contact the
supplier or manufacturer of the pipe
for assistance. Also note that there are
some differences in labeling (e.g.,
changes to product types and fuel
types), which might also serve as a way
to determine the difference between
pre- and post-July 1,2005, pipe.
Can pipe manufacturers use list-
ings from an independent test-
ing organization other than UL?
There are several nationally recog-
nized independent testing organiza-
tions under which pipe may be listed,
and several pipe manufacturers hold
• continued on page 26
25
-------
I UL 971 from page 25
listings under more than one inde-
pendent testing organization. There-
fore, it could be possible that pipe
manufacturers that fail to meet the
revised UL 971 standard will con-
tinue to manufacture and sell their
pipe using one of their other inde-
pendent testing organization listings.
How is California transitioning
to the revised UL 971?
In California, both the UL 971 stan-
dard and California's design and
construction requirements must be
considered when determining the
appropriate use of pipe manufac-
tured pre- or post-July 1, 2005. Cali-
fornia Health and Safety Code
Chapter 6.7 not only requires an
independent testing organization list-
ing, but also requires that primary
containment be compatible with the
hazardous substance stored and that
secondary containment be con-
structed to prevent structural weak-
ening as a result of contact with any
hazardous substance released from
the primary containment.
The Future of UL 971
The January 2, 2004, revision of UL
971 is just a stepping-stone toward
addressing the nonmetallic pipe fail-
ures we've seen in the field. In fact,
UL 971 is currently under revision to
include even more stringent testing
and to set higher performance criteria
so that nonmetallic piping manufac-
tured in the future will not experi-
ence the problems that we have seen
in the past. So, be vigilant and con-
tinue to report those piping failures
to UL at www.ul.com. •
Laura Clmddock is Chief of the LIST
Leak Prevention Technical Unit at the
California Water Resources Control
Board. For more information on Cali-
fornia's transition to the revised non-
metallic piping standard, contact Laura
at (916) 341-5870 or
lchaddock@waterboards.ca.gov.
The Energy Policy Act
of 2005?
On August 8, President Bush signed
the Energy Policy Act ot 2005 into law.
The act contains a number of provi-
sions that will impact state and federal
UST/LUST programs. Over the next
few months we will all be studying the
act to find out just what it requires. In
the next issue of LUSTLine, we'll pro-
vide an update on the act as well as
some state perspectives.
Meanwhile, A PDF file of the Energy
Bill can be found at following Senate
website: http://energy.senate.gov/pub-
lic/. Once at this Senate Energy and
Commerce Committee home page,
look to the right margin and under
"Featured Items" click on "Text of Con-
ference Report of Energy Policy Act of
2005." The text of the UST Compliance
Subtitle B, Title XV, begins at page
1564 through 1607. It runs from Sec-
tions 1521 through 1541. •
from Robert N. Renkes, Executive Vice President, Petroleum Equipment Institute (PEI)
Results of PEI's UL 971 Piping Survey Available
UL 971, Nonmetallic Underground Piping for Flam-
mable Liquids, contains requirements that cover
primary carrier, secondary containment, inte-
gral primary/secondary containment, normal vent
and vapor recovery, nonmetallic pipe, fittings, and
products intended for use underground in the distrib-
ution of petroleum-based flammable and combustible
liquids, alcohols, and alcohol-blended fuels.
From October 1995 through June 30, 2005, non-
metallic underground piping was produced in accor-
dance with the UL 971 standard dated October 30,
1995. Revisions were made to the 1995 standard in
response to improper piping-system installation, inad-
equate piping-system maintenance practices, and fail-
ure to properly respond to leak-detection alarms. The
performance requirements of the "new" UL 971
became effective on July 1, 2005. That means products
manufactured on or after July 1, 2005, must comply
with the new requirements to be considered UL-listed.
As far as UL is concerned, the UL mark on a prod-
uct serves as the manufacturer's declaration that the
product complied with the UL requirements that were
in effect at the time the product was produced. In other
words, as long as the UL mark is on the pipe, UL con-
siders the product listed. Piping produced to the 1995
standard is still UL-listed, even though it can no longer
be produced.
There is some confusion in the industry about how
the states will handle the "old" UL-listed pipe (manu-
factured from October 1995 through June 30, 2005) and
"new" UL-listed pipe. More specifically, will states
allow piping listed to the 1995 standard to be installed
now that the new UL 971 requirements are effective?
To help tank owners, piping manufacturers, and
tank-system installers understand what the states will
allow to be installed after July 1, 2005, PEI recently sur-
veyed the each state. While printing deadlines do not
permit us to summarize the results of the survey in this
article, the results (state by state) of the survey are avail-
able at www.pei.org. You will note that the vast majority
of states have permitted piping manufactured to the old
standard to be used after July 1, 2005.
A complete listing of all UL certifications is avail-
able through UL's website at www.ul.com. Select the
"certifications" menu item from the UL home page.
Click on "standard number," on the next page, type in
971, and then select the piping option. The website will
provide information on all currently certified products.
Only those products that are certified to the new
requirements are identified. •
26
-------
• Risk Analysis from page 19
aquifer more readily than if there
were a long residence time. Attenua-
tion of contaminants is minimized
with high linear velocity and short
travel distance because the solute will
have a short period of vadose-zone
residence time and therefore will not
have substantial time to react with
the geologic matrix and existing air
components of porosity.
Groundwater risk was calculated
by dividing the land-use-risk grid by
the aquifer-susceptibility grid. A
groundwater-risk calculation is anal-
ogous to the HRI hazard component.
Groundwater risk demonstrates the
risks associated with introducing
contaminants both at the surface
and to an unconfined aquifer at the
water table. Existing CERCLA NPL
groundwater-contamination sites
display a strong correlation to areas
of significant risk on the groundwa-
ter-risk grid. This grid does not take
into consideration population expo-
sure.5
The HRI exposure component is
equal to the ratio of the population
exposed to the total population mul-
tiplied by the Exposure factor. The
Exposure factor (Ef) assesses the per-
centage of population exposure over
time. In the GER study, this value
was defaulted to one. The GER analy-
sis constructed a ratio of population
using groundwater as a source of
drinking water grid from census tract
and public water supply wellhead
protection area data layers.3
The value for population using
groundwater as a source of drinking
water was assumed to conform to the
Source Water Assessment Areas
(SWAPs) around public water supply
wells. SWAP areas were provided by
state and local agencies. The ratio of
population using groundwater as a
source of drinking water to total pop-
ulation is analogous to the HRI expo-
sure factor.
The GER, which assesses the risk
of introducing contaminants at the
surface in NYS and the risk of thoses
contaminants percolating through
the vadose zone and being intro-
duced to an aquifer at the water table
in areas where humans use ground-
water as a source of drinking water,
is analogous to the HRI value as out-
lined below:
HRI = ((DI x DV) x (PE / PC ) x Ef)
Assuming Ef = 1, then
HRI = (DI x DV x (PE/PC ))
The GER formula follows, with
LUR analogous to DI, the inverse of
AS analogous to DV, and PGW equal
to (PE/PC):
GER = (LUR /AS) x PGW
GER = Groundwater-endangerment
risk
LUR = Land-use risk
AS = Aquifer susceptibility
PGW = Ratio of population using
groundwater as a source of drinking
water to total population
The GER grid can be used by the
GIS to statistically compare the mean
UIC GER values of counties, zip
codes, wellhead protection areas, or
any other areas defined with bound-
aries. Mean GER values of zip codes,
as an example, can be used to priori-
tize UST and UIC inspection target
areas. Higher numbers indicate
higher risk. In order to relate the grid
to practical inspector deployment,
counties and zip codes were
processed to display mean GER per
county and zip code. By targeting a
high-risk county, then a high-risk
zipcode, specific areas possessing
substantial GER may be identified.
These areas may be sited for UST or
UIC inspections. Facilities located in
these areas may be targeted for UST
or UIC inspections. •
Charles Hillenbrand is with the U.S.
EPA Region 2's Water Compliance
Branch. He can be reached at
Hillenbrand.charles@epa.gov.
References:
Carney, G. R, Human Health Risk Index, Draft docu-
ment, Policy and Analysis Section, U S. EPA Region
6,1991.
Notes
1 Hillenbrand and Simpson, in press.
2 Hillenbrand and Friedman, in press.
3 Hillenbrand, Hansen, and Friedman, in press.
4 Hillenbrand and Simpson, in press
5 Hillenbrand and Ferri, in press
New Publication on
Design, Construction,
Modification,
Maintenance and
Decommissioning UST
Systems from the UK
Design, Construction, Modifica-
tion, Maintenance and Decom-
missioning of Filling Stations
is the title of a publication produced
jointly by the Association for Petro-
leum and Explosives Administration
(APEA) and the Service Station Panel
of the Energy Institute. The 242-page
book contains information based
largely on experience from the United
Kingdom and makes frequent refer-
ence to legislation applicable in the
UK; however, the authors anticipate
that the general principles will be
applicable to most regions of the
world. Copies can be obtained from
Portland Customer Services, Com-
merce Way, Whitehall Industrial
Estate, Colchester C02 8HP, United
Kingdom. Phone: (44) 1206 796 351.
E-mail: sales@portland-services.com.
Sierra Club Calls LUSTs
a Threat to the Nation's
Drinking Water
In April, the Sierra Club released a
22-page report that describes in
depth the threats to public health
and the environment from LUSTs.
The report details the detrimental
impact that leaks of gasoline and toxic
substances from USTs have on the
nation's groundwater, the source of
drinking water for 50 percent of the
population. The report also looks at
current federal and state efforts to
prevent and clean up leaks from USTs
and concludes that they are inade-
quate to protect public health. The
report notes the current slowdown in
the number of LUST cleanups com-
pleted each year and predicts a rever-
sal of years of progress in cleaning up
the nation's backlog of LUST sites if
current trends continue. The full
report can be seen at http://www.sier-
raclub.org/toxics/Leaking_USTs/index
.asp.
27
-------
LUSJLine Bulletin 50 • August 2005
Maryland's New Helium
Test Protocol
by Herb Meade
The Maryland Department of
the Environment (MDE) deter-
mined that a cost-effective
evaluation tool was needed to assist
LUST investigators in pinpointing
the locations of vapor releases from
gasoline UST systems. The tool,
which needed to be both cost effec-
tive and easy to implement, is the
outcome of our ongoing struggle
with increasing incidents of MtBE-
impacted groundwater from fully
compliant UST systems across the
state. MtBE releases at a portion of
these sites could be tracked to small-
volume releases from catchbasin and
sump failures, spills at the dis-
pensers, and poor maintenance prac-
tices. However, we also recognized
that vapor releases were a main con-
tributing source for MtBE levels in
groundwater at these sites.
MDE reviewed the many UST-
testing methods currently available
for system evaluation. We found that
none of the commercially available
tests fulfilled our immediate needs.
Ultimately, we drew from our own
testing knowledge to meet our
requirements. We realized that folks
in the UST industry, as well as other
release-investigation industries, have
had experience with helium as a test-
ing compound for well over 25 years.
Therefore, we decided to take a brave
step and write our own protocol for
UST helium testing, knowing full
well this would be a first in the
nation.
We began by drafting an evalua-
tion protocol based on the experience
of MDE staff who had backgrounds
in testing UST systems for both tight-
ness and vapor-recovery operation.
We then conducted a forum with sev-
eral active tank-testing firms in our
state with helium-testing experience.
With these firms we were able to
fine-tune the protocol and perform
field-test trials. The real-world field-
test trials assisted a great deal in the
development of the final protocol.
Currently, vapor evaluation is
required on all gasoline UST systems
that have Stage II vapor recovery and
are located within the High Risk
28
Groundwater Use Area of our state.
Most tank owners are having the
evaluation performed in conjunction
with the required annual Stage II
vapor-recovery testing when the air-
to-liquid ratio and pressure-decay
tests are performed. The vapor-eval-
uation protocol has added $300 to
$600 to the annual Stage II testing. As
tank testers become more experi-
enced with the protocol and previ-
ously unidentified vapor problems
areas are repaired, we expect the
price to decrease.
We feel that we have provided
tank owners and testers with an eval-
uation tool that is meeting our goal of
discovering small vapor releases from
active gasoline UST systems. Testers
in Maryland are discovering numer-
ous tank-top fitting failures. These
failures are now easily repaired and
doing so prevents continuous vapor
leaks into the environment. The
helium test section of the new Mary-
land protocol appears below. For the
full protocol, visit MDE's website at:
www.mde. state.md.us/Programs/Land
Progmms/OiljControl/Factsheets
Publications. •
Herb Meadf is the Administrator of the Oil
Control Program, Maryland Department of
the Environment. He can be reached at
hmeade@mde. state, md. us.
Performing the Helium-Test
1 . Initially perform California Air Resources Soard (CARB) Test Procedure TP-201 ,3 using com-
mercial-grade nitrogen as required. Report test failure to the OH Control Program and Air and
Radiation Manag ement Administration within two hours in accordance with Code of Maryland
Regulation (CQMAR 26.10.08.01 A), Record any corrections made prior to and during the test-
ing to achieve a passed test.
2. Once CARB test has toeen successfully completed, remove the pressure/vacuum (P/V) vent
cap(s) on UST(s) to be tested and 1-psi pressure relief valve,
3. Note: The UST systems should be in operating condition minus toe vent cap. Instill all filf and
Stip I liu&tcaps foriw duration tf me halium test.
4. Begin introducing! helium into the system following the specifications as stated in CAR! proce-
dure TP-201.3. Do not exceed 1 :0 inch of water column, Matte pressure in tit tan* con-
stantly. r
5. Confirm helium is prts tut in all areas to bt tested. Check test connectteimto verify they ire
" '
,
6. life to all sumps, teMi|*top cornponirts,, api diijehiers shou$ rernajn m pltcp t«l they art
7. Test for hiluw -if tanl-iop sMl areas lit t|» 'ttewsfrial pump-Island
QRwfe ptt'tli ,h«iBtifB ^i^^t^^^^p'^fl^4"m^f^oMM,. ,'.•
9,Ripeitsi*pi#;f»rii^ • •." • •
1Q, Once Is 'preisBreto ft.O inches of wider column antf steps
11. testing is somptgte;peiio tf§;fj indies of water .cotomw In ill ind
manwiys, at arty rt|fl«*'to|'iOrnp(in»tereif arm Record ihrflwwme-
ter p-resswit antf tori p .aJfrtloBil mtnutet ani wcord fit
again. If pjtsiyri Js, iflo* trtng prsisyre lack tfcSJ of water
' cotami and.rBslntifrtW.ii |wBtt»'«ni>*;«d|!r«s$«r«s, ffjwfe&tiif increase: Js obsWed*
also record. A & my itafista erf tmitm OF $ny tioi&y vf pmsufe aft/at aehMytog 5.0
12.|reak dowpteslefli||p|nirt IW vent caps.
13. If sicondarf piping' eias,t muslilQ be tested.
14. Introduce helium tHroufltt one test port on the tine being tested. Place a second oju*o farthest
from the area where thi helium Is being applied. Lines may have to be connected flumped)
inside dispensers to perform test loosen the secondary boot/hoses slightly on specie pipe
being tested and cftscl with the helium detector to verify helium is present throuflhout the
entire pipe. Once helium is detected, seal all boots/hoses ti§ht Charge line to 2.0 inches of
water column and watch for decay. If line Is decaying, check boots/hoses with helitim detector.
Tighten boots/hoses as needed. If no helium is detected at the boot ends and pressure contin-
ues to decay, record decay rate if possible (inches of water column/minute or second). If pres-
sure is not Increasing or sustained, or is not confirmed at each boot end, record a failure.
Point-source testing may be needed to Identify area(s) of failure. If pressure maintains or
increases after holding for 10 minutes, increase pressure to 5.0 inches of water column and
repeat test Pressure must be maintained for 10 minutes at 5.0 Inches of water column, •
-------
August 2005 • LUSTLme Bulletin
FAQs from the NWGLDE
.. .All you ever wanted to know about leak detection, but were afraid to ask.
Old and New CITLDS Protocols—What's That About?
This instalment o
titm Evaluations
protocols ag&J to tcertify contmums
tem$ (CITLDS) #$ mil as iMtlch proto»|,
believes meets
tiflcatton of equipment performance, Please "Mate;
expressed in this column represent those of ?fr s
not necessarily those of my implementing agencjf
Q Has any CITLDS equipment that was evaluate*!
* and third-party certified using the old maMfac-
turers' protocols been accepted by the NWGLDB?
A We can get to the answer by first looking at the
" history of CITLDS protocols. CITLDS had not yet
been invented when U.S. EPA published proto-
cols in 1990 for testing leak-detection methods.
When CITLDS equipment came along later and
the manufacturers wanted to evaluate their equip-
ment, they had to develop their own protocols.
The manufacturers developed their own protocols
and had their equipment tested using these proto-
cols. None of these protocols were alike, and most
did not require very stringent tests of the opera-
tion of the equipment. Since this was before the
first NWGDLE list was issued, many states
reviewed and accepted CITLDS evaluations that
had been performed using the manufacturers'
protocols.
When NWGLDE began to review available
CITLDS evaluations, it determined that most of
the protocols were not sufficient. As a result,
NWGLDE only listed one manufacturer's CITLDS
equipment in the 3rd Edition NWGLDB list on
April 18, 1997. The California State Water
Resources Control Board volunteered to take the
lead to try to encourage CITLDS manufacturers to
come together and write an improved protocol
that all manufacturers could use.
Dr. Jairus D. Flora, Jr. wrote a new protocol, and
the California State Water Resources Control
Board and NWGLDE, both of which provided
technical reviews of the protocol, accepted the
new protocol on January 7,2000. The new proto-
col covered three types of continuous systems:
continuous automatic tank gauging systems
(ATGS), continual reconciliation, and automatic
monthly inventory control. It required more strin-
gent testing of CITLDS equipment as well as test-
ing at both laboratories and operating fueling
facilities. It also addressed the operation of the
equipment in manifolded tanks, limited the oper-
I oil jfaw|p^ujk and
optional inclusion
-------
LUSTLme Bulletin 50 • August 2005
Take One Part Premium, One Part Diesel,
and a Stroke of Lightning
by Ernest Roggelin
On June 28, 2005, an intense
early evening rain and light-
ning storm delivered a light-
ning strike to the canopy and
perhaps the pad of a Circle K conve-
nience store in Pinellas Park, Florida.
The station had three 10,000-gallon,
single-walled fiberglass USTs con-
taining diesel, regular unleaded
gasoline, and premium unleaded
gasoline. The vents for this station
were located within the canopy
structure. The facility did not have
lightning rods.
Based on reports from observers
at the station during the incident, the
following initial sequence of events
took place as a result of the lightning
bolt strike:
• The tank pad rose three to five
feet. (The pad is 36 x 40 x 1 feet of
reinforced concrete, with an
approximate weight of 63 U.S.
tons.) The pad partially slumped
into the tank excavation. A sub-
surface explosion would support
this movement.
• There was a flash fire on the sur-
face of the pad.
• A 36-inch circular sump traffic
lid was blown 60 to 70 feet into
the air and then sliced down
through the canopy.
• A customer dispensing fuel into
her vehicle immediately drove
off, disconnecting the nozzle at
the breakaway fitting.
• The concrete pad in the vicinity
of the spill containment/vapor
recovery ports was displaced.
Post Mortem
It has been theorized that the light-
ning strike delivered a spark to the
vapor near the dual atmospheric
vents. (The diesel and premium are
together, and the regular is separate.)
The spark followed a vapor trail back
to at least the premium unleaded
tank. At the time of the event, the
premium tank contained approxi-
mately 4,055 gallons of product; the
diesel contained approximately 5,220
30
The lightning-impacted site showing subsidence of the tank pad over the USTarea.
gallons. Both the diesel and premium
unleaded gasoline tanks suffered cat-
astrophic failure. The regular
unleaded tank, which did not rup-
ture, contained 1,821 gallons.
On June 28, the Pinellas Park Fire
Department, Pinellas County Haz-
mat, Bureau of Emergency Response,
and representatives of Circle K were
the initial responders. Circle K's con-
struction manager, Daryl Gottilla,
and its remediation manager, Alan
Cubberley, provided direction
throughout the initial and following
days. Circle K was very proactive,
fully meeting the Florida Department
of Environmental Protection's "con-
tain, remove, abate" criteria follow-
ing a discharge event.
Circle K arranged for the con-
tents of the regular tank and for free
product on the groundwater inter-
face (at five feet below land surface)
to be transferred by vacuum truck
(SWS & US Filter) to a 20,000-gallon
FRAC-tank. The tanks had been
installed in a crushed-rock backfill
material. Circle K's consultant, Envi-
ronmental Compliance Services,
began installing observation wells
around the perimeter of the tank field
that same evening.
On June 29, additional free prod-
uct was removed. The exact amount
of free product recovered has not
been determined—the failure of both
tanks was at or below the ground-
water table elevation. Sections of the
slab were removed, allowing work-
ers to observe that the center portions
of the premium and diesel tanks
between the turbine sumps and the
opposite end-cap were "missing"
above the groundwater level (about
25 feet of tank). The Pinellas Park Fire
Department monitored vapor levels
during the excavation process. The
weather was hot and humid with lit-
tle wind to disperse the strong vapor
presence. Later in the day, the
remainder of the concrete pad was
removed.
On June 30, the regular unleaded
tank was exposed and removed
intact from the excavation. A well-
drilling contractor was on-site to
install permanent and temporary
wells. The accessible portions of the
damaged USTs were removed. Prod-
uct piping and vent lines were not
removed at this time.
On July 1, the contractor back-
filled the excavation with clean fill
material and placed four 6-inch prod-
-------
4 Firefighter examining tank
The excavation showing the
remains of the diesel and
premium tanks along with
product,
uct-recovery wells. Dur-
ing the cleanup of the
concrete and steel rebar
scrap, sparks from a
quick-cut saw ignited
crushed-fiberglass tank
parts in the construction
dumpster, necessitating
a visit by the fire depart-
ment.
The retrofit schedule
was advanced to initiate
tank replacement by
mid-summer. The initial site-prepara-
tion involved installing sheet-piling
with well-points. The effluent from
the points was air stripped and stored
in a FRAC-tank. During this site-
preparation process, the excavation
was thoroughly cleaned of failed-
tank remnants, all piping compo-
nents, and concrete debris. The vent
pipes were moved out from the
canopy and toward the edge of the
property. This closure-completion
and installation-initiation process
began on July 13.
The World Weighs In
A brief synopsis of the event, gleaned
from media reports, was distributed
worldwide via the Internet in a
moderated newsgroup, "Dangerous
Goods & HazMat." This led to a
series of e-mails from industry con-
sultants opining on the cause of the
tank failures. One position indicated
that the vapor-rich ullage would not
support ignition, nor would it allow
the movement of a spark or ignition
pathway back down the tank vent
pipe. Other positions suggested a
possible ignition of product vapors in
the crushed-rock backfill beneath the
pad, or the flash boiling of ground-
water to create a steam explosion. •
Ernest Roggelm is an Environmental
Manager with Florida's PineUns
County Healtli Department Storage
Tank Program. He can be reached at
ernest_roggelin@doh.state.fl.us.
Photos are courtesi/ of Ernest Roggelin,
Lisa Frazier, Jamie Burnett, and
Michael Flanen/ of the Pinellas CHD
Storage Tank Program.
18th Annual National
Tanks Conference _
Call for Abstracts
NEIWPCC is accepting abstracts for
professional papers to be consid-
ered for presentation at the 18th
Annual National Tanks Conference
& Exposition to be held March
20-22, 2006, at the Memphis Cook
Convention Center in Memphis,
Tennessee. The deadline for sub-
mitting abstracts is September 9,
2005. Complete instructions and
the online submittal form can be
accessed through NEIWPCC's web-
site, www.neiwpcc.org/tanks06.
Also, check this website for infor-
mation on updates and exhibiting
opportunities.
L«U*S*I*1*INE Subscription Form
Name
Company/Agency
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
116 John Street, Lowell, MA 01852-1124
Phone: (978) 323-7929 • Fax: (978) 323-7919 • lustline@neiwpcc.org • www.neiwpcc.org
31
-------
EPA Denies RFC Waivers
On June 2, U.S. EPA announced that
it would deny separate requests from
California, New York, and Connecti-
cut to waive the oxygenate require-
ment for reformulated gasoline
(RFG). Reformulated gasoline con-
tains 2 percent oxygen by weight.
Since California, New York, and Con-
necticut ban the use of MtBE, RFG in
those states contains only ethanol.
EPA's RCRA/SF/OUST/EPCRA
Call Center Discontinues
Support of UST Program
As of April 1, EPA's RCRA/SF/
OUST/EPCRA Call Center is no
longer providing information about
EPA's UST/LUST program. For
information about the UST/LUST
program, see the EPA OUST website
at www.epa.gov/oust. To order publi-
cations developed by OUST, call
EPA's publications distribution cen-
ter at (800) 490-9198.
New UST-LUST Virtual
Classroom Unveiled
OUST introduced a new online,
Internet-accessible training tool on
the UST program at the UST/LUST
National Conference in Seattle. The
UST-LUST Virtual Classroom, cur-
rently has two training modules. The
first, "Introduction to the Under-
ground Storage Tank (UST) Pro-
gram," explains tank regulations,
describes the differences between the
UST and LUST programs, discusses
financial responsibility, and orients
new users to the components of a
tank system. The second module,
"Basic UST Inspector Training,"
describes how inspectors can prepare
for and conduct compliance inspec-
tions at typical UST sites. A third
module providing training for LUST
site managers will be added this year.
The UST-LUST Virtual Classroom is
available 24 hours a day through
EPA's website at http://www.epa.
gov/oust/virtual.html.
OUST Publishes Maintenance
Manual for UST Sumps and
Spill Buckets
UST Systems: Inspecting and Maintain-
ing Sumps and Spill Buckets - Practical
Help and Checklist (EPA 510-R-05-001)
was published in May. The manual,
which was reviewed by EPA, states,
and industry, is intended to help UST
owners and operators improve the
operation and maintenance of their
UST-systern sumps and spill buckets
by presenting recommended inspec-
tion guidelines and best management
practices.
The manual will help owners
identify and inspect the sumps and
spill buckets associated with their
UST systems; explain some simple
steps owners can take to maintain
their sumps and spill buckets and
identify potential problems; and pro-
vide owners with tips for fixing com-
mon problems before they cause a
release of petroleum products to the
environment. The manual includes
safety considerations, a general intro-
duction to the kinds of sumps, basic
maintenance procedures for sumps
and spill buckets, and a sump and
spill bucket inspection checklist.
The manual can be viewed and
downloaded from the OUST website
at http://www.epa.gov/oust/pubs/sump
manl.htm, and free printed copies are
available from NSCEP at (800) 490-
9198.
LUSJ.UNE
New England Interstate Water
Pollution Control Commission
116 John Street
Lowell, MA 01852-1124
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