Underground
 Storage
   Tanks:
 i
uilding
  n The Past

  TOP
   The Futur
       -7004
   ANNIVERSARY.

           A510-R-04-001

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Underground Storage Tanks: Building On The Past To Protect The Future
Word From  The  Assistant Administrator
                               Twenty years ago hundreds of thousands of underground stor-
                               age tanks  leaking petroleum were contaminating community
                               drinking water supplies. Since then, EPA's underground storage
                        tank program has contributed to a remarkable national success story by
                        protecting our nation's soil and groundwater from leaking tanks.
                        Partnerships have been the cornerstone of the program's success. Our
                        intergovernmental and private partnerships involving states and tribes
                        have resulted in closing over 1.5 million substandard tanks, cleaning up
                        over 300,000 releases of environmental contaminants, and reducing the
                        number of new releases.
                        In fact, over 18,500 cleanups were completed in Fiscal Year 2003; this
represents a 17 percent increase in the number of cleanups completed over the previous year. There
also has been an improvement in preventing releases and detecting leaks. Approximately 12,000 new
releases were reported in Fiscal Year 2003 - about 60 percent lower than the annual historical aver-
age of approximately 27,000.
But we cannot rest on this record.  There is still more we can do by working with facility owners and
operators in preventing releases and detecting them more quickly when they occur. With renewed
commitment and strong partnerships, we will continue to identify solutions to both old and new chal-
lenges related to underground storage tanks.
                                                              Marianne Lament Horinko
                                                                 Assistant Administrator
                                             Office of Solid Waste and Emergency Response
Word From The Assistant Administrator
MI

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Underground Storage Tanks: Building On The Past To Protect The Future
Contents
Executive Summary	1

Milestones In The Underground Tank Program	2

Underground Storage Tanks - A Program Of Partnership, Innovation, And Results	5
  Creating A Program To Implement The New Law	5
  EPA's Regulatory Program	7
  Strong Emphasis On Approving State Programs	10
  Fulfilling EPA's Responsibilties In Indian Country	11
  Compliance Assistance And Outreach Make A Difference	12

A Measure Of Our Success	15

Commitment To Finding Innovative Solutions	17
  Pay For Performance	17
  Risk-Based Corrective Action	18
  State Trust Funds	19

Continuing Challenges	21
  Improving Operational Compliance	22
  Completing Cleanups	23
  Minimizing Leaks From New And Upgraded Tank Systems	23
  Cleaning Up And Reusing Petroleum Brownfields	24
  Meeting New Challenges	26
iv                                                                         Contents

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                      Underground Storage Tanks:  Building On The Past To Protect The Future
Executive  Summary
       Tiis year, the national underground storage tank program celebrates its 20th anniversary. The purpose
       )f this report is to celebrate 20 years of strong partnerships, highlight some of our extraordinary
       iccomplishments, and offer a short program history, so that as we look to the future we can contin-
ue in the strong tradition of our past.

In 1983, the CBS program 60 Minutes aired a story called "Check the Water." The report brought national
attention to families suffering from the effects of gasoline leaking from underground storage tanks. Less than
a year later, Congress passed and the President signed a new law designed to protect the public from these
and other petroleum releases.

With this new law in place, the U. S. Environmental Protection Agency (EPA) faced the daunting task of regulat-
ing the nation's two million underground tanks storing petroleum and certain hazardous substances. The Agency
responded quickly and creatively. Because of the number of tanks, the diversity of ownership, and the need for
strong state involvement, EPA designed a program that was unlike any other regulatory program  at the time. In
less than four years, EPA built a new federal program — one noteworthy for its protective but flexible perform-
ance-based regulations; its aggressive approval of qualified state programs; its vigorous outreach and education;
and its strong partnerships with states, tribes, industry, and many other partners still involved to this day.
Through these partnerships, we have found new ways to tackle
old problems. And because of this innovative spirit, we have suc-
cessfully met many  of the expectations  Congress  and the
President had in 1984 when the program was created. Together,
EPA, states, tribes, and industry have  closed 1.5 million old,
unsafe tanks and  have upgraded or replaced nearly all other
underground storage tanks. Of the 400,000 plus known leaks,
nearly 70 percent have been cleaned up; the number of new leaks
being discovered each year has dropped dramatically, from a high
of over 66,000 in 1990 to roughly 12,000 last year.
As we celebrate the 20th anniversary and enter the third  decade
of our program,  new  challenges  lie ahead. These challenges
include cleaning up and encouraging reuse at 200,000 or more
abandoned gas stations and petroleum brownfield sites littering
our cities  and countryside; cleaning  up more than 100,000
remaining  known releases  at active sites; and improving opera-
tional compliance at every site to prevent new releases. Today's
and tomorrow's challenges may be as tough, if not tougher, than
what we faced before. As we face  them, we will need to rely, even
more, on our creativity and our enduring partnerships.
Executive Summary

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Underground Storage Tanks: Building On The Past To Protect The Future
Milestones In The Underground Tank Program
    President
    signs law
    creating
    the
    national
    under-
    ground
    storage
    tank
    program
EPA forms
the Office
of Under-
ground
Storage
Tanks
     I
       84    1985    19
President
signs law
establishing
the Leaking
Under-
ground
Storage
Tank Trust
Fund
EPA
publishes
final under-
ground
storage
tank
regulations

EPA and
states hold
first national
tank confer-
ence in
Santa Fe,
New Mexico
EPA
approves
first state
under-
ground
storage
tank
program,
Mississippi
EPA and
states hold
first state
fund con-
ference in
Rapid City,
South
Dakota

         Final
         deadline
         for owners
                                          ;o
                           8   1989    1
    Apple
    Computer
    unveils its
    Macintosh
    personal
    computer


    I
      Nintendo
      video games
      introduced
      in the US
                                          Berlin wall
                                          dismantled
                                              100,000
                                              releases
                                              confirmed
50,000
cleanups
completed touse
         leak
                                                                            detection
                                99    1
                           TV show
                           Seinfeld
                           debuts on
                           NBC
                                Worldwide
                                Web becomes
                                publicly
                                accessible
       What Else Was Happening
                                      Milestones In The Underground Tank Program

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                                Underground Storage Tanks: Building On The Past To Protect The Future
 200,000
 cleanups
 initiated

 100,000
 cleanups
 completed

EPA
launches
under-
ground
storage
tank
web site
www.epa.
gov/oust
EPA establishes
first partnership
to promote risk-
based cleanups
Final deadline
for owners to
close, upgrade,
or replace their
tanks
300,000
cleanups
initiated
         *
200,000
cleanups
completed
1994   19!
EPA
launches
initiatives
to:
accelerate
cleanups
improve
compliance
recycle gas
stations
evaluate
tank
systems
EPA sets
national
cleanup
goals

President
signs
Brownfields
Law to
address
petroleum
brownfields
300,000 cleanups
completed

400,000 cleanups
initiated

Santa Monica,
California and
petroleum compa-
nies reach land-
mark agreement to
clean and restore
the city's MTBE-
contaminated
drinking water
supply
                            1999
      U.S. space
      shuttle
      docks with
      Russian
      space station
      Mir for the
      first time
               At 77, John
               Glenn, the
               first American
               to orbit Earth,
               returns to
               orbit in the
               space shuttle
               Discovery

                  America Online
                  agrees to buy
                  Time Warner-
                  the biggest
                  merger in the
                  country at that
                  time

                           Concorde's
                           last flight
                           ends the
                           world's only
                           commercial
                           supersonic
                           travel
            Milestones In The Underground Tank Program

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Underground Storage Tanks: Building On The Past To Protect The Future

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                   Underground Storage Tanks: Building On The Past To Protect The Future


Underground  Storage  Tanks -  A  Program

Uf Partnership, Innovation, And  Results

P  I  ^ie Hatfields, an average American family, lived in Canob
      Park, Rhode Island about 12 miles from Providence. In
 -JL.  1980, this family had a big problem — they could not use
their tap water. They couldn't drink it, bathe in it, or cook with it.
Their well was contaminated with gasoline that migrated from the
neighborhood gas station, just a quarter of a mile from their house.
In December 1983, their story aired on the CBS show, 60 Minutes.
Buried gasoline tanks  gained the national spotlight when 60
Minutes released its investigative report, "Check the Water".
That report revealed other neighbors in Canob Park were in
the same situation — gasoline leaking from underground stor-
age tanks was contaminating their drinking water.

That report and similar  stories
prompted Congress to swiftly enact   ^.^ ^ f. ^ balance between technology,
legislation to create federal standards
to regulate these tanks, in November   industry, federal, state, private and public
1984, a year after the 60  Minutes  forces, yOU  can gef a lot dOH6. The UST
report aired, President Reagan signed
into law subtitle i of the Resource  program is an example where we found
Conservation and Recovery Act   the right balance. I'm very proud that I had
(RCRA). The new subtitle required        ,   .   ..„
           .              .     (A> HJlV ill' II.
the U.  S. Environmental Protection
Agency (EPA) to develop  a com-   Scoatof David Durenberger, Minnesota
prehensive regulatory  program for   introduced UST legislation in the U. S. Senate
underground storage tanks  (USTs)
storing petroleum and certain hazardous substances. In 1986,
Congress and the President went one step further and created
the Leaking Underground Storage Tank (LUST) Trust Fund
to pay  for the cleanup of releases from these tanks.

Creating A Program To Implement The
New Law
EPA quickly set out to develop a national underground stor-
age tank program to implement the new law. From the begin-
ning, EPA realized the immensity of the task. No one knew
Underground Storage Tanks - A Program Of Partnership,
Innovation, And Results

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Underground Storage Tanks: Building On The Past To Protect The Future
    "The UST regulated community is a very
 diverse group.  They range from small, one-
     station operations to big oil companies.
 Large companies have many resources and
understand that environmental compliance
    is one of the costs of doing business. EPA
 understood that smaller operations needed
 more environmental compliance assistance
                         and technical support"
the  exact  number  of  under-
ground storage tanks subject to
the federal law. Estimates were in
the millions, and thought to be
located in every Zip Code in the
United States. While some  of
these tanks were already  regulat-
ed by local and state fire codes
and health standards, the regula-
tions were often inconsistent and
incomplete. The new federal reg-
ulatory program  would  fill the
regulatory gaps and dwarf exist-
ing programs that EPA adminis-
tered.
                                          Lee Thomas
                             EPA Administrator, 1985-89
                                                        EPA knew there would never be
                                                        enough resources at the federal
                                 level to fully implement the program, to inspect every tank,
                                 and to oversee the cleanup of every release. To succeed, EPA
                                 needed to heavily involve states in implementing the program.
                                 EPA and states would have to become close partners.
                                 To understand the technical problems with underground stor-
                                 age tanks, EPA reached out to a wide range of experts — state
                                 and local officials, leaders from environmental groups, tank
                                 manufacturers, equipment installers, environmental consult-
                                 ants, gas station owners and operators, and many others. EPA
                                 sought their ideas and welcomed their input. EPA wanted the
                                 regulations to address the real problems with underground
                                 storage tanks, be  easily implemented by states, and under-
                                 stood by tank owners.
                                 EPA didn't stop there. Perhaps one of the most novel ideas,
                                 especially 20 years ago,  was to reach out to companies like
                                 Century 21, McDonald's, ServiceMaster, and 7-Eleven to see
                                 if the recipe for  their success would work for the under-
                                 ground storage tank program. To the Agency's surprise, while
                                 each company's line of business was different, they all shared
                                 a common thread — a franchise business arrangement. This
                                 arrangement allowed each company to set corporate policies
                                  Underground Storage Tanks - A Program Of Partnership,
                                                              Innovation, And Results

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                       Underground Storage Tanks: Building On The Past To Protect The Future
and standards to ensure product consistency and the  same
level of service, regardless of where stores were located. At
the same time it gave individual stores flexibility to develop
and implement marketing strategies tailored to their specific
needs.  It was clear to these companies this approach worked
because it used the strengths and knowledge of both the fran-
chisees, who ran the businesses  daily, and the franchiser, who
provided national policy, crucial support services, and technical
assistance.

EPA was convinced a franchise  approach would work for the
underground storage tank program because we faced issues sim-
ilar to Century 21 — the need to develop a national program with
a consistent set  of  standards that could be implemented  by all
50 states. So, EPA set out to develop a national program based
on the franchise approach, with the  Office of Underground
Storage Tanks (OUST)  being the national franchiser and EPA
regional offices working directly with states, the franchisees.

As the national franchiser, EPAs recipe  for success included
four key ingredients: promulgating performance-based federal
regulations; aggressively  approving qualified state  under-
ground storage tank programs; fullfilling EPAs responsibilities
in Indian Country; and providing vigorous compliance  assis-
tance and outreach.

EPA's Regulatory Program

In 1985, when EPA began developing its new regulatory pro-
gram  for underground storage tanks, the  stakes  were very
high. The Agency had  to  quickly  promulgate effective and
workable regulations that would prevent underground storage
tanks from leaking and clean up leaks that had occurred.

Congress had laid out its expectations less than a year earlier.
On February 29,   1984 in the words  of Senator David
Durenberger, one  of the principal sponsors of Subtitle I in
the U.S. Senate, Congress wanted assurances that "new tanks
are built and installed as they should be and that old tanks are operat-
ed and maintained so  that the possibility of leaks is minimised. Leaks
which do occur should be detected quickly so that the chance of contami-
Underground Storage Tanks - A Program Of Partnership,
Innovation, And Results

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Underground Storage Tanks: Building On The Past To Protect The Future
                                  nation  is Ion1!'  Eight  months later on  October  5,  1984
                                  Congressman Jim Florio, one of the key sponsors of the leg-
                                  islation in the U.S. House of Representatives, articulated his
                                  vision  stating that, "implementation of these safeguards  durine the
                                            o       r         J      J o        o
                                  next decade and removal of leaking tanks will, in my view, go a long way
                                  toward preserving America's most precious natural resource, its freshwater
                                  aquifers!'
  "We wanted to be sure that the regulations    Wl*  ,these  expectf ^ns  ,m
                                                         mind, the Agency worked quick-
  were practical When OUST was developing    iy to  develop and promulgate
    the regulations we always thought of the    new underground sto<-age tank
                                                         regulations.  In less than four
   16-year old gas station worker measuring    years  from start to finish, EPA
 the tanks at 6 a.m. on a cold day.  Will he do    met ^ challenge, it wasn't easy
                                                         EPA knew that because of the
                      what we are asking him?"    magnitude  of the underground
                                                         storage tank problem, a tradi-
                                            Ron Brand    tional regulatory program would
        First Director, Office of Underground Storage Tanks    not work. Wlth over ^ miUl0n
                                                         petroleum  and hazardous sub-
                                  stance tanks in the ground — most of which were old bare
                                  steel tanks, many already corroding and causing leaks — the
                                  Agency knew a prescriptive one-size-fits-all regulation would
                                  not work.

       "EPA sought industry out and industry    Ins*ad' the f gency ,set off °" a
                                                         path  to crart regulations that
      made attempts to provide  accurate and    were  flexible,  performance
                   comprehensive  information:'    based' technol°gy forcin& and
                                                         perhaps  most  importantly,
                                               _.,        reflected the  needs  of  states
                                             JeffLeiter                         •  •   ,
                    _      „   ,.   ru^i/-i--      wno  would be the  principal
                    Former Co-chair of the Tank Coalition    .              r ,
                                                         implementors  or the program.
                                                         As  active  co-regulators,  states
                                  needed the flexibility to implement  the federal regulations and
                                  set their priorities in a way that would address their unique cir-
                                  cumstances and needs. States could go beyond the federal reg-
                                  ulations, and some states did in  order to protect sole source
                                  aquifers or environmentally sensitive areas. And the regulated
                                  Underground Storage Tanks - A Program Of Partnership,
                                                               Innovation, And Results

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                       Underground Storage Tanks: Building On The Past To Protect The Future
community  needed  flexibility to  choose among  effective
release prevention and leak detection equipment. At the same
time, the federal regulations needed to ensure flexibility didn't
come at the expense of protectiveness for all Americans. The
regulations had to assure a basic level of protection for every-
one regardless of where the tanks were located.

Following hundreds  of meetings, information  gathering
efforts, and countless hours of writing, EPA promulgated its
regulations in the fall of 1988. The preamble and the regula-
tions, covering 165 pages in the Federal Register, spelled out the
rationale for the regulations, requirements, deadlines, options,
and areas of flexibility available to  the regulated community.
The regulations required tank owners to cathodically protect
or otherwise close, upgrade, or replace their tanks within ten
years and put in place one of several leak detection methods
within five years. For leaks that had occurred, the regulations
required  owners to report them and clean them up according
to state-specific standards that are protective of human health
and the environment. Owners also had to choose one of sev-
eral financial assurance mechanisms to demonstrate they had
the financial resources to pay for the cleanups.

As comprehensive and technical as  these regulations were for
tank owners, the regulations were designed to  achieve three
simple goals:

•  Prevent leaks by requiring owners to close or upgrade
   old substandard tanks or  install new, better,  and safer
   tanks that won't easily corrode and leak.

•  Detect leaks quickly by requiring owners  to replace or
   supplement wooden dip sticks and other old,  outdated
   leak detection methods.

•  Clean up leaks quickly and safely by requiring tank own-
   ers to have the financial resources to do so.
These  three  simple but important goals, and the regulations
promulgated in 1988 designed to meet these goals, continue
to work for the program today.
Underground Storage Tanks - A Program Of Partnership,
Innovation, And Results

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Underground Storage Tanks: Building On The Past To Protect The Future
                                   Strong Emphasis On Approving State
                                   Programs
                                   As sound as EPA's new regulations were, the Agency realized
                                   that aggressive implementation of the program was the key
                                                           to success. With over two mil-
    "Having our own state program allowed us
 to come up with innovative solutions to solve
  UST problems that were unique to our state."
                                        Michael Kanner
                                           UST Manager
                      Minnesota Pollution Control Agency
                        lion  regulated  storage  tanks
                        buried all across America, it was
                        clear that the job was too big for
                        the  federal  government to
                        implement alone. In fact, in the
                        same February 29, 1984 speech
                        (quoted    earlier),    Senator
                        Durenberger laid out his expec-
                        tations  on the floor of the U.S.
                        Senate. "It is my expectation" he
said "that this program will be run by the State governments with very
little federal involvement"

It was  clear 20 years ago states had to play the key role in
implementing the underground storage tank program and
overseeing and enforcing the  regulations. EPA would only
succeed in implementing the program if states succeeded. To
meet Congress' expectations and EPA's desire for full state
                                    Cuirendy 33 states, the District of Columbia and the Commonwealth of
                                    Puerto Rico have EPA approved UST programs.
                                                                        £~^, Virgin Imlimh
                                                          1 (33 pluft DC and PR)
10
Underground Storage Tanks - A Program Of Partnership,
                             Innovation, And Results

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                      Underground Storage Tanks: Building On The Past To Protect The Future
implementation, the Agency had to develop rules that would
encourage states to seek  formal approval to  run their state
underground storage tank program in lieu of the federal pro-
gram. With so many corroding tanks and so many known and
yet-to-be-discovered releases,  the  Agency had to design a
process to get qualified states approved quickly and with min-
imal disruption  to their existing work.

Just as the Agency had done with the technical regulations,
EPA took a different approach for approving state under-
ground storage tank programs. Because of the nature and
magnitude of the tank problem and the importance of getting
qualified  states approved quickly, the Agency designed a
streamlined process for approving qualified state programs.
Instead of requiring a  burdensome and time-consuming line-
by-line comparison between federal and state tank regulations,
the Agency would review a state program against eight pro-
gram specific objectives related to leak prevention, leak detec-
tion, cleanup, and financial assurance. States demonstrating
that their standards in the eight areas were no less stringent
than the federal  regulations  would be approved, provided
their programs  regulate the same universe of federally regu-
lated tanks, and they had adequate  enforcement.

In July 1990, EPA approved Mississippi as the first state to run
its own underground storage tank program in lieu of the fed-
eral program. Today, 33 states, the  District of Columbia, and
the Commonwealth of Puerto Rico have EPA approved pro-
grams. With rare exceptions, all other states are implementing
their own tank programs under EPA cooperative agreements.

Fulfilling EPA's Responsibilities In Indian
Country

Although the vast majority of the nation's underground stor-
age tanks are regulated by states, tanks in Indian Country pres-
ent a different challenge.  For the  roughly 2,600 active tanks
in Indian Country, EPA is responsible for directly implement-
ing the underground storage tank  regulations. Although the
number of tanks in Indian Country is relatively small in com-
Underground Storage Tanks - A Program Of Partnership,
Innovation, And Results
11

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Underground Storage Tanks: Building On The Past To Protect The Future
                                   parison to today's nearly 700,000 tanks nationwide, EPA is
                                   approaching its responsibility in  the same manner and with
                                   the same purpose.

                                   As the Agency did with states, EPA built strong partnerships
                                   with tribes and tribal consortia, and continues to strengthen
                                   these partnerships. Through these partnerships, EPA provided
                                   and still provides technical support, financial  resources, and
                                   compliance assistance. Over the last decade, EPA provided over
                                   $9 million to tribes and tribal consortia to train their own staff
                                   and to develop and manage their own underground storage tank
                                   programs. And to further support tribes, EPA conducts approx-
                                   imately 200 tank  site inspections annually, oversees cleanup
                                   activities, and where appropriate undertakes cleanups.

                                                           Through these partnerships, EPA
    "EPA provides real support to tribal tank    and  ^ have made conslder_
   compliance problems -  the Agency's assis-    able progress during the past 20
                                                           years.  Almost 5,200 old, unsafe
  tance is part of the solution, not a barrier    storage tanks m Indlan Country
  tO SUCCeSS. EPA approaches new and innO-    have been  permanently closed,
            ,r   , ,              , . ,                    ,    most leaks are promptly reported.
 vative tribal programs with an open  mind       ,   ,      ^     y 4  f   '
                                                           and almost  60 percent or all
  and WilUngneSS tO turn  ideas intO reality"    known releases have been cleaned
                                                           up. Today, nearly all owners of
                                           Bobby Short    gas stations and other regulated
                                Environmental Programs,    sites in Indian Country have the
                       Inter-Tribal Environmental Council    required equipment in place  and
                                                           most operate it properly.

                                    Compliance Assistance And Outreach Make
                                   A Difference
                                   By developing and implementing the technical and state pro-
                                   gram approval regulations, and building partnerships with
                                   tribes and tribal consortia, EPA was well on its way towards
                                    creating a  successful regulatory program for  underground
                                   storage tanks. But the fourth and final ingredient for success,
                                    compliance assistance and outreach, was just as challenging
                                   and important. The owners and operators  of  underground
12                                 Underground Storage Tanks - A Program Of Partnership,
                                                                 Innovation, And Results

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                      Underground Storage Tanks: Building On The Past To Protect The Future
storage tanks had to be educated about the new regulations.
Tank  owners spanned the spectrum from the largest oil
companies to the smallest mom-and-pop gas stations. As is
still the  case, the federal government also owned tanks, as
did state, local, and tribal governments, convenience stores,
taxicab  companies,  bus  companies, state transportation
authorities, fire  departments  and many others. Some were
large, sophisticated  companies  and organizations with
legions of  lawyers and environmental engineers on staff.
Others were one-person operations with little  or no knowl-
edge of  environmental regulations. EPA had to reach all of
these owners and provide them with the tools to understand
the regulations so they could  comply.

EPA began by writing the regulations in plain language before
that concept was well known or generally accepted. That
alone  was a big step, but EPA did more. The
Agency  produced  dozens of documents that
explained the regulations  in  language so simple
that a large and diverse audience could read and
understand the requirements. EPA also developed
documents explaining how to do things correctly
like inventory control and leak detection. In 1990,
EPA published its  first outreach document in
Spanish  in order to reach the diverse tank owner
community. Some of the more popular documents
included:

•  Musts for USTs — a comprehensive, easy-to-read
    summary of the  federal requirements  for
   underground storage tanks focusing on instal-
   lation, release detection, spill, overfill, and cor-
   rosion protection,  corrective action, closure,
   reporting, and recordkeeping requirements.

•   Operating and Ma:             "round Storage
    JO             O      O         O
    Tank Systems: Practical Help and Checklists - a
   manual to help  owners and operators under-
    stand how to properly operate and maintain
   their underground storage tank systems.
SERA
                    S2I
Operating And
Maintaining
Underground Storage
Tank Systems
Practical Help And
Checklists
             HAVE You
              CHECKED
             YOUR TANK
             _ TODAY?
                          Printed on ffecvcfrtf P
Underground Storage Tanks - A Program Of Partnership,
Innovation, And Results
                                        13

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Underground Storage Tanks: Building On The Past To Protect The Future
     "EPA  maintains an atmosphere of open
communication and encourages stakehold-
       ers to voice their opinions about their
   experiences. States, industry, and EPA are
  encouraged to learn from each other and
            to share successes and challenges."

                                   Kathy Stiller Banning
  Delaware UST Manager and Co-Chair of the Association of
 State and Territorial Solid Waste Management Officials Tank
                                         Subcommittee
•  Dollars and Sense — a booklet providing a plain language
   summary of owner and operator financial responsibili-
   ties under the federal regulations.

•  Straight Talk on  Tanks: Leak Detection Methods for Petroleum
   USTs and Piping — a booklet summarizing various leak detec-
   tion methods for underground storage tanks and piping as
   well as the regulatory requirements for leak detection.
EPA needed a distribution network to reach the diverse and
large group  of owners and operators. So, EPA turned to its
partners in the program — states, tribes, and private industry
— to  help publicize and distribute thousands of free copies
of these and other  documents. Today, EPA is taking advan-
tage  of the  internet by making most publications available
on the Web at http://www.epa.gov/oust/pubs/index.htm.

Along with  publications, EPA also organized, co-sponsored,
and continues to host with states, two  annual conferences.
These national conferences provide a good opportunity for
EPA, states, tribes, and others to share experiences and
                        improve the program. Both con-
                        ferences  provide  a  forum  to
                        exchange information on new
                        technologies  and   regulatory
                        innovations at all levels of gov-
                        ernment. And they  provide a
                        place  for  stakeholders  from
                        across the nation to  share their
                        success  stories  and  lessons
                        learned, which leads to  better
                        compliance and more effective
                        cleanup.
14
Underground Storage Tanks - A Program Of Partnership,
                             Innovation, And Results

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                       Underground Storage Tanks: Building On The Past To Protect The Future
A Measure  Of  Our  Success
I
n 1984, the Congressional Research Service (CRS) pub-
lished a study about the enormous regulatory task EPA
and states faced. CRS noted in its study:
"An estimated 1.4 million underground tanks in the United States store
gasoline. An unknown additional number of tanks store a variety of petro-
leum products .... Of the 1.4 million underground tanks storing gasoline,
approximately 85 percent are made of steel with no corrosion protection and
were buried over 20years ago. Although few data exist, some petroleum indus-
try experts estimate that 75,000 - 100,000 of these underground gasoline
tanks may currently be leaking... into the ground and groundwater supplies
and perhaps up to 350,000 tanks may be leaking within the next'five'years."

Twenty years later,  the  accuracy of  the CRS estimates is
remarkable. EPA now knows  there  were over 2.1 million
underground storage tanks and over 400,000 releases have
since occurred. As a result of the federal regu-
lations, strong state and tribal partners, aggres-
sive outreach, and the combined efforts of our
public  and private  partners,  we have made
tremendous progress in tackling the problems
described by CRS in  1984.
Working together, EPA and its partners have
closed over 1.5 million old, substandard tanks
and cleaned up over 300,000 petroleum leaks,
almost 70 percent of all releases. Through our
combined  efforts, we have  averaged almost
19,000 completed cleanups annually. This has
not been easy. Cleaning up BTEX (benzene,
toluene,  ethylbenzene, and xylene - the basic
contaminants in gasoline) is tough enough; but
in  the  mid-1990s  states began  to  discover
MTBE (methyl tertiary butyl ether - a gasoline
additive) in the nation's groundwater.

We have now found MTBE in many places and, if
left unchecked,  MTBE   can  cause  significant
groundwater contamination problems. And while
MTBE is  frequently  detected,  Santa  Monica,
California and Long Island, New York were the first
cities  to experience widespread contamination
                                             Cleanups Completed: Historical flverage, 1999-2003
                                              40.000
                                              35.000
                                              30.000

                                              25.000

                                              20.000

                                              15.000

                                              10.000

                                               5.000
                                                                                         19.000
                                           All numbers rounded to nearest thousand.
                                            Confirmed Releases: Historical Average, 1999-2003
                                               All numbers rounded to nearest thousand.
A Measure Of Our Success
                                                                                          15

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Underground Storage Tanks: Building On The Past To Protect The Future
          "Twenty years later, the unconventional
     programs developed by EPA's UST program
         have proven to be effective at protecting
              public health and the environment."
                                                  Tom Dunne
           EPA Office of Solid Waste and Emergency Response
                                      Associate Administrator
                affecting large populations. Up to
                300,000 residents were affected in
                Santa Monica and 2.6 million peo-
                ple were affected in Long Island.
                Like many other challenges the tank
                program faced, by working together
                and  relying  on each partners'
                strengths, we are beginning to make
                a  difference in  these and other
                                                                 areas. EPA's financial and technical
                                       assistance had a great impact in Santa Monica where a landmark
                                       MTBE settlement was reached last year between the city and sever-
                                       al major oil companies. In the words of Wayne Nastri, Regional
                                       Administrator of EPA Region 9, "The Santa Monica agreement proves
                                       that when allkvels of government— local, state and federal work together, we serve
                                       the common good and produce a comprehensive solution to a difficult problem"
 Decreasing UST National Cleanup Backlog, 1999-2003
                 2000      2001     2002     2003
All numbers rounded to nearest thousand.
    National OST Cleanups Completed, 1992-2003
       1992 1993 1994  1995
All numbers rounded to nearest thousand.
On the prevention side, the results are just as impres-
sive. Through combined efforts, nearly all substan-
dard tanks have been closed, replaced, or upgraded.
And because of these improvements, our nation has
seen a dramatic drop in new releases. Over the his-
tory of the underground storage tank program, EPA
and states have discovered  just  over 27,000 new
releases a year and as many as 66,000 in 1990. In 2003,
we  discovered approximately 12,000  confirmed
releases, about 60 percent less than the historical aver-
age. This dramatic reduction in the number of releases
proves the tank program is making a difference.

Much of  this reduction is due to better designed
tanks and improved compliance on the part of the
regulated community. Twenty years ago, CRS believed
that 85  percent of  the buried  tanks  were made of
bare steel without any corrosion  protection. Today,
nearly all underground storage tanks are cathodically
protected or have been replaced with newer and better
tanks. And tank owners have done more than close,
upgrade, or replace  their older  tanks. At the end of
2003, tank owners were operating their spill, overfill,
corrosion protection, and leak  detection equipment
properly at more than  70 percent of all tank sites.
16
                 A Measure Of Our Success

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                    Underground Storage Tanks: Building On The Past To Protect The Future
Commitment To Finding Innovative Solutions
     Statistics alone cannot fully cap-
     ture the collective success of the
     underground storage tank pro-
gram. The performance-based tank
regulations  were  technology-forcing,
encouraging  industry  to  develop
newer and better methods to prevent,
detect, and clean up leaks. In the same
vein, EPA  encourages and supports
states, tribes, and local partners to con-
tinuously look for new and better ways
to prevent leaks and clean them up quickly and effectively. This
proactive attitude has paid off in keeping the tank program
fresh with new ideas even after 20 years. And while program
innovations came from many sources, states have been at the
forefront in developing new approaches. Pay for performance
contracting, risk-based corrective action, and state trust funds
are three of the most innovative and noteworthy solutions.

Pay For Performance
In the program's early years, many state officials were look-
ing  for a  faster, streamlined approach for  completing
cleanups. After attending the  annual national tank confer-
ence, a manager from New Mexico's tank program came up
with a new idea of paying contractors for their performance
rather than for their time and materials. Following the con-
ference, pay for performance contracting, more popularly
known as PFP, was born. Other states have adopted and
expanded that concept for their own use.
 "The UST regulations ensured a market
 which provided incentives for those manu-
facturing tanks, piping and leak detection
 systems to develop new and better products"
 Sullivan Quran P.E.
 Executive Director, Fiberglass Tank and Pipe Institute
PFP contracting holds the contractor account-
able by tying contractor payments  to meeting
firm, measurable cleanup goals.  By doing so,
cleanups are often  faster,  less expensive, and
more  likely to  rely on new, more  effective
cleanup methods. As an added benefit, there is
less paperwork and a lighter administrative load
because there is no need for extensive reviews of
contractor billings.
            In pay for performance cleanups, con-
            tractors are paid a set amount of
            money for reaching specific contami-
            nation reduction goals (within a set
            time limit), which are predetermined
            by state cleanup experts.
 Commitment To Finding Innovative Solutions
                                                 17

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Underground Storage Tanks: Building On The Past To Protect The Future
                                     Successes

                                     South Carolina has been a trendsetter when it comes to the
                                     use of PFP contracting. The state first used PFP contracting
                                     in 1997 and quickly made it an integral part of its approach to
                                     cleaning up leaks  from underground  storage tanks. South
                                     Carolina has not only seen a reduction in the amount of time
                                     required for cleanups, but has also been getting the same or
                                     higher quality work while paying less. South Carolina reports
                                     an average savings  of $215,000 per site cleanup with reduced
                                     staff project management time needed. The state's ability to
                                     set clear time  lines for cleanup and to monitor contractors'
                                     progress is the key to success. South Carolina mandates quar-
                                     terly  reports from contractors on contamination levels and
                                     ensures cleanup projects remain on track for completion. The
                                     state's PFP program has been so effective that South Carolina
                                     was  awarded  an  Engineering  Excellence  Award  by  the
                                     Consulting Engineers of South Carolina Association.

                                     Similar success has occurred throughout the country. Many
                                     states have used the example  set by South Carolina to develop
                                     PFP   programs  of their  own. Florida,  Utah, Georgia,
                                     California, Vermont, Oklahoma, Nebraska, and others  have
                                     also taken the initiative and developed unique approaches to
                                     PFP  contracting.
                                     Risk-Based Corrective Action
  Risk-Based Corrective Action (RBCA) is
  a streamlined approach that integrates
  exposure and risk assessment prac-
  tices 'with traditional components of
  the corrective action process to
  ensure that appropriate and cost-effec-
  tive  remedies are selected and that lim-
  ited  resources are properly allocated.
   During the 1980s, EPA, states, and tribes faced
   the  daunting task of assessing and cleaning up
   hundreds  of  thousands  of  leaks  quickly  and
   effectively. It became obvious that because of the
   number of leaks, EPA and states needed a way to
   set priorities. So  over the course  of two years,
   EPA — along with partners from states, industry,
   and  the  American Society  for  Testing  and
   Materials   — developed  Risk-Based Corrective
   Action (RBCA). This tool helps states evaluate
18
Commitment To Finding Innovative Solutions

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                      Underground Storage Tanks: Building On The Past To Protect The Future
the cleanup priority of each site based on relative
risks to human health and the environment. Today
nearly all states use risk-based decision making to
protect human health and the environment.
Successes
The benefits of applying risk-based decision mak-
ing to  cleanups is  perhaps best illustrated in a
March  2000  study, published  by  the American
Society for Testing and Materials. The study high-
lighted risk-based  cleanup  programs  in  Illinois,
Iowa, Texas, North Carolina, and Utah and evalu-
ated each program's performance  from 1990 to
1999. Astonishingly, the study showed that imme-
diately  following implementation  of  risk-based  decision
making, four of the five pilot states observed a dramatic
spike in annual number of cleanups completed and, in some
circumstances, a decline in their backlog of cleanups to be
completed. Utah's cleanup completion rate increased by 120
percent during the first year. The monetary benefits of risk-
based decision making were also encouraging. Between 1994
and 1998, remediation costs in Texas dropped by 77 percent
for soil-only sites (median cost reduced to $24,000 per site
from $80,000 per site) and by 58 percent for low risk ground-
water impact sites (to $107,000 per site from  $250,000 per
site).

State Trust Funds

The financial responsibility regulation EPA promulgated in
1988 required tank owners to show they have the financial
resources to  clean up a site if a release occurred. The regula-
tion gave  owners  a variety  of compliance   options.
Unfortunately, private insurance was not widely available or
was extremely  costly,  especially  for  small  businesses.
Additionally,  private insurance did  not cover the  costs of
cleaning up the thousands of known releases.
Risk-Based Decision Making is a process
that UST implementing agencies can use to:
• Focus site assessment data gathering.
• Categorize or classify sites.
• Determine what, if any, further action is
  necessary to remediate a site.
• Help establish cleanup goals.
• Decide on the level of oversight provided
  to cleanups conducted by UST owners
  and operators.
            S.EPA
Financing Underground
Storage Tank Work:
Federal and Slate Assistance Programs
Commitment To Finding Innovative Solutions
                                          19

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Underground Storage Tanks: Building On The Past To Protect The Future
                                      Successes
                                      To create a way to pay for cleaning up known releases and to
                                      meet the financial responsibility requirements, one  of  the
                                      most creative tools — state trust funds — was born. No fed-
                                      eral mandate required states to create these funds. But state
                                      officials, seeing how their peers in other states had responded
                                      to the needs of their tank owners, especially small businesses,
                                      developed their own funds.

                                      While each state  fund is somewhat different, they all enable
                                      tank owners  to  comply  with  the  financial  responsibility
                                      requirements and provide money to clean up releases.

                                      By all accounts, these funds have worked. Today 40 states
                                      have funds that provide money to clean up underground stor-
                                      age tank releases. States raise and spend more than $1 billion
                                      annually. And, over the life of  the program, states have spent
                                      more than $11 billion to  help clean up more  than 300,000
                                      petroleum releases.
20
Commitment To Finding Innovative Solutions

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                    Underground Storage Tanks: Building On The Past To Protect The Future
Continuing  Challenges
A  I  ^wenty years ago, the Hatfields of Canob Park, Rhode
      Island and countless other Americans in other states
      had to live with the effects  of  leaking underground
storage tanks  from nearby gasoline  stations,  convenience
stores, and other locations. No one  knew where all of these
tanks were located, what they were made of, or whether they
were leaking. It was not uncommon  in 1984 that the first and
only sign gasoline had leaked from  an underground storage
tank was a strong odor coming out of the shower or a bad
taste from the tap water.

It  took  swift Congressional and   «RpA mad& a sincere effort fo involve stake-
Presidential action to enact federal
legislation to create  a  national   holders in developing UST regulations.
underground  storage tank pro-  AnyQne wbo was interested and thought
gram.  Iwenty years ago, EPAs rirst
major challenge was how to impie-   they had something valuable to add was
merit  this  new legislation. Given   ^^^ fe ^^ g^ mggesttons. EPA bas
the size or the regulated universe,
the unknown number of leaks, and   Created UST regulations that hOV6 Survived,
the great diversity of owners, EPA   -,           ,        ,      ,   -,      ..  „
,  /                    '        been understood,  and substantially com-
had to  adopt new  approaches,
write the regulations,  and imple-  plied With"
ment the national program. Based
on the franchise approach, EPA   Robert Renkes
built  strong  partnerships  with   Executive Vice President and General Counsel
states, tribes, and private industry   for the Petroleum Equipment Institute
to  tackle this  problem. By many
measures, the program has  suc-
ceeded and served the nation well.  Through these partner-
ships, we have made great progress by designing better and
safer tanks, cleaning up two-thirds of all leaks, and cutting the
number of new leaks by 70 percent.

But as the tank program celebrates its 20th anniversary, there
is still much left to be done. Some of the new challenges that
lie ahead include improving operational compliance, complet-
ing cleanups, minimizing leaks from  new and upgraded tanks,
and cleaning up and reusing abandoned gas stations and other
petroleum brownfields. By carrying on the original principles


Continuing Challenges                                                             21

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Underground Storage Tanks: Building On The Past To Protect The Future
                                       of partnerships and innovation that were established 20 years
                                       ago and tested and strengthened over time, together we will
                                       continue to find new ways to solve the challenges of today and
                                       tomorrow.

                                       Improving Operational Compliance
                                       While tremendous strides have been  made in reducing the
                                       number of new releases, thousands of newly discovered leaks
                                       still occur each year. The lack of  proper operation and main-
                                       tenance is one of the major causes of  new releases.  EPA and
                                       states are working together on several major efforts to address
                                       the challenge.
                                       One way to improve operational compliance is to increase the fre-
                                       quency of tank inspections. A few states conduct annual inspec-
                                       tions, but most inspect tanks on average less than once every three
                                       years. To  increase the number of inspections, some states have
                                       developed innovative methods such as the use of certified third
                                       party inspectors or contracting with local fire and health depart-
                                       ments. We need to explore these  and other methods.
                                                 In addition to conducting more inspections, we need to
                                                 ensure inspectors are well trained. Well-trained inspec-
                                                 tors are integral to  helping owners  and  operators
                                                 achieve and maintain operational compliance. To meet
                                                 this need, EPA and states are developing web-based
                                                 training for federal and state  tank inspectors and site
                                                 cleanup managers. The on-line modules, available later
                                                 this year, will provide basic instruction for tank inspec-
                                                 tors and cleanup managers. EPA is planning to com-
                                                 plete more advanced modules in future years.
                                                 Over the years, EPA has produced dozens of compli-
                                                 ance assistance documents to help owners and opera-
                                                 tors deal with a wide variety of tank topics. Continuing
                                                 that effort, EPA and states are developing an easy-to-
                                                 use, model workbook that can be tailored to individual
                                                 states and used by tank owners to determine if they are
                                                 in compliance and identify what needs to be done to
                                                 reach and maintain compliance.
22
Continuing Challenges

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                      Underground Storage Tanks: Building On The Past To Protect The Future
Completing Cleanups
EPA and its partners have made enormous progress by clean-
ing up over 300,000  contaminated sites. Still,  130,000 con-
taminated sites need to be cleaned up. EPA and our partners
are committed to cutting this number in half by 2007 and
continuing the legacy of finding faster, more innovative, and
less costly ways to get the job done.

EPA is helping states and tribes reach their cleanup goals by
characterizing the types of sites  that still need to be cleaned
up. The Agency is also taking a targeted and intensive look
at how to move  difficult cleanups  forward and get them
completed. This review should help identify fresh approaches
for expediting cleanups. EPA is also encouraging multi-site
cleanup approaches and wider use of  pay for performance
contracts, both of which accelerate cleanups and reduce
costs and administrative burdens.

As is the case for inspectors, EPA and states have a continual need
to train new staff who oversee cleanups. Well-trained staff are
integral to ensuring cleanups are initiated and completed properly.
EPA and states are developing introductory, web-based training,
available later this year, for federal, state, and tribal  site cleanup
staff. More advanced modules are being planned for the future.

While EPA  and states  are  focusing efforts  on  completing
cleanups, there is still a need to ensure that sites not yet cleaned
up  are managed properly to protect human health  and the
environment over the long-term. Tracking and enforcing insti-
tutional controls that lay out limitations for using sites are key
to managing contaminated sites  responsibly  over time. EPA
and states are  continuing their partnership to develop tools
which improve long-term site management.

Minimizing Leaks From New And  Upgraded
Tank Systems
Over the past 20 years, EPA and its partners have  closed over
1.5 million old, outdated underground storage  tanks. Today,
nearly all underground storage tank  systems  in this  country
Continuing Challenges
23

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Underground Storage Tanks: Building On The Past To Protect The Future
                                     have the required leak prevention and leak detection systems
                                     and are less likely to corrode and leak than the tank systems
                                     of the previous generation. Nevertheless, many new tank sys-
                                     tems are continuing to leak. While we don't know how many
                                     are leaking or all of the reasons, we are beginning to learn that
                                     some of the problems are due  to faulty equipment, improper
                                     installation, and lack of proper operation and maintenance of
                                     the equipment.
                                     Anecdotal information indicates that releases from piping, as
                                     well  as spills and overfills during delivery, are still prevalent
                                     and releases from dispensers  have emerged as a leading source
                                     of contamination. States again have been in the forefront of
                                     addressing these problems.  In addition  to taking proactive
                                     program and regulatory steps  to improve tank system  per-
                                     formance, several states have undertaken studies to quantify
                                     tank system performance.
                                     EPA is also evaluating tank system performance and working
                                     with state and industry  partners to determine the  primary
                                     sources and causes of problems.  Once completed, this evalu-
                                     ation will help EPA, states, and industry guide future training
                                     efforts; identify research needs;  focus inspection resources;
                                     and improve tank system installation methods, operation and
                                     maintenance procedures, and underground storage tank sys-
                                     tem equipment.
                                     This effort is essential to ensure we not only retain the signif-
                                     icant improvements we've made over the  past 20 years, but
                                     continue to move the program forward toward a better and
                                     cleaner future. This commitment to continuous improvement
                                     has been a hallmark of  the underground storage  tank pro-
                                     gram since its inception  and continues to be a driving force
                                     within the program.

                                     Cleaning Up And Reusing Petroleum
                                     Brownfields
                                     For the past 20 years, regulating tanks at active gas stations and
                                     other fueling sites has been the principal  focus of the under-
                                     ground tank program. But old  abandoned gas stations can be
24
Continuing Challenges

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                     Underground Storage Tanks: Building On The Past To Protect The Future
eyesores and  blight communities.
The 2002 Brownfields Law is giv-
ing EPA,  states, cities, entrepre-
neurs, and community leaders an
opportunity and new tools to clean
up and return to productive reuse
many of the  200,000  abandoned
petroleum sites scattered through-
out America. Using the foundation
upon which the underground stor-
age tank program was built — partnerships, creativity, and hard
work — we can meet this new challenge.

In 2000, building on the success of the Brownfields program,
EPA created USTfields and began in earnest to focus on aban-
doned petroleum sites. EPA provided almost $5 million to fund
50 USTfields pilots. Three years later, EPA awarded almost $23
million  for 102 new petroleum grants, under the 2002
Brownfields Law. These grants are helping states and cities
assess, cleanup, and reuse petroleum brownfields.  Some com-
munities are already seeing results. In Nashua, New Hampshire,
New England's largest bicycle  dealer  is now located on a
cleaned up petroleum-contaminated industrial site. In Trenton,
New Jersey, the city reclaimed  an abandoned gas station and
built a new firehouse.

In addition to the grants, EPA  and states are continuing their
legacy of developing and disseminating innovative  tools to
address  petroleum brownfields.  Issuing a Ready-for-Reuse
determination is one such  tool. It is  being  used in  Sayre,
Oklahoma and in other places to acknowledge that the site has
been cleaned up and is ready and available for a particular type
of reuse. Site inventories are helping bring property owners
together with end users who  may want to use the property. And
Triad is a comprehensive approach for planning, managing, and
implementing  area-wide cleanups quickly and efficiently.

Ultimately, we  need to strengthen our existing partnerships and
build new ones to  meet the new petroleum brownfields chal-
lenge. In some ways, this challenge may be tougher than oth-
 "The entire petroleum brownfields agenda
 is a critically important task of the  UST
program and is a  major part of the
 vision for the future"
 Timothy Fields
 Former Office of Solid Waste and Emergency Response
 Assistant Administrator
                         Located in a part of Chicago with
                         minimal green space, the West
                         Ogden Pocket Park was formerly
                         a service station. The site was an
                         eyesore and contained a derelict
                         building used for illegal dumping
                         and 11 USTs that ranged in size
                         from 600 to 10,000 gallons.
                         Cooperation between the Chicago
                         Department of Buildings, Depart-
                         ment of the Environment, and
                         Department of Transportation led
                         to tank removal, site remediation,
                         and restoration. In the summer of
                         2001, the West Ogden Pocket
                         Park opened, adding much needed
                         green space to the neighborhood.
Continuing Challenges
                                                       25

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Underground Storage Tanks: Building On The Past To Protect The Future
                                     ers because of the need to include additional partners — prop-
                                     erty owners, end users, bankers, cleanup contractors — as well
                                     as  traditional regulatory  partners. Even though developing
                                     these partnerships is  time consuming,  some are already in
                                     place and making progress. Through a new partnership with
                                     Habitat for Humanity, the City of  Oakland, California, and
                                     EPA, an old gas station with four buried tanks was cleaned up.
                                     Now in its place are four new homes for low income families.

                                     By expanding old partnerships, creating new ones, developing
                                     user-friendly tools, and taking advantage of the new opportu-
                                     nities in the Brownfields Law, EPA, states  and  other public
                                     and private partners can clean up and reuse thousands of old
                                     abandoned gas stations.

                                     Meeting New Challenges

                                     Partnerships, innovative solutions, cooperation, feedback,
                                     striving to improve.

                                     Over the  last 20 years, EPA used these principles to  set in
                                     place a framework and foundation for partnerships to suc-
                                     cessfully manage America's tank systems. And the choices we
                                       made and used throughout the program's history helped us
                              20 YEARS OF PROGRESS
                     BUILDING ON THE PAST
                   TO PROTECT THE FUTURE
    enter the third decade of the under-
 round storage  tank  program,  new  chal-
 lenges  lie  ahead and a great  deal  more
  work needs to be done. We are commit-
   ted to  continuing the past  ideals that
   have taken the tank program to where it
   is today. And we are dedicated to ensur-
   ing continued success in protecting the
   nation's environment and human health
   from underground storage tank releases.
  With the  continued support of  our part-
 ners,  we will keep our nation's land and
ater safe for our and future generations.
26
               Continuing Challenges

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RBf iBCtiOHS                           "ERA sought technical expertise from all sources - tank owners and
                                            vendors, state and local government agencies, and franchise operations.
                                            We sought to fully understand the operation of these tanks and find
                                            ways to improve the process from within."
                                            Louise Wise
                                            Former OUST Division Director responsible for developing
                                            the regulations
                                            "We worked towards compromises that would achieve tank standards while
                                            being realistic about what it would mean for those actually doing the work."
                                            Carrie Wehling
                                            One of the original EPA lawyers who worked on the UST regulations
                                            "Outreach was of great importance in the underground storage tank pro-
                                                         J o      r                 o         o     r
                                           gram from the very beginning, since our mission was to try to  change the
                                            tank management practices of 175,000 owners and operators with very
                                            diverse backgrounds and education levels.  To getpeople's attention, we creat-
                                            ed, for example, a lively brochure called Musts for USTs that explained the
                                            new tank management requirements in very simple and clear terms and even
                                            used cartoons depicting comical scenes to make the text interesting to read."
                                            Helga Butler
                                            The first OUST Branch Chief of Communications
                                            "Many of the principles that led to the success of the UST program (cus-
                                            tomer orientation, continuous improvement, flexibility, partnerships) were
                                            considered quite innovative, even rebellious, in the mid-1980s. Today, these
                                           principles have become commonplace in many of EPA's programs."

                                            John Heffelfinger
                                            One of the original OUST staff members
                                            "The theme of the office was to make states successful. We appreciated
                                            how OUST empowered states and offered tools and flexibility so that
                                            states could find creative solutions to UST challenges."
                                            Bill Torrey
                                            EPA New England Regional UST Program Manager

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&EPA
United States               Office of Solid Waste          Office of               www.epa.gov/oust
Environmental              and Emergency              Underground            March 2004
Protection Agency           Response                  Storage Tanks
Recycled/Recyclable. Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 50% Postconsumer)

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