United States Environmental Protection Agency Risk Reduction Engineering Laboratory Cincinnati Ohio 45268 Research and Development EPA/600/S2-91/044 Sept. 1991 EPA Project Summary Volumetric Leak Detection in Large Underground Storage Tanks James W. Starr, Richard F. Wise, and Joseph W. Maresca, Jr. A set of experiments was conducted to determine whether volumetric leak detection systems presently used to test underground storage tanks (USTs) up to 38,000 L (10,000 gal) In capacity could meet EPA's regulatory standards (40 CFR Parts 280 and 281) for tank tightness and automatic tank gauging systems when used to test tanks up to 190,000 L (50,000 gal) In capacity. The experiments, conducted on two partially filled 190,000-L (50,000-gal) USTs at Griffiss Air Force Base in upstate New York during late August 1990, showed that a system's performance in large tanks depends primarily on the accu- racy of the temperature compensation, which is inversely proportional to the volume of product in the tank. Errors in temperature compensation that were negligible in tests in small tanks were important in large tanks. The experi- ments suggest that volumetric systems now capable of meeting regulatory stan- dards when used to test 30,000- to 38,000-L (8,000- to 10,000-gal) tanks will also meet these standards when used to test 190,000-L (50,000-gal) tanks if (1) the duration of the test is increased from 1 or 2 h to 4 h or more to ensure that the vertical gradients are accurately measured and to reduce the ambient and instrumentation noise, (2) the num- ber of temperature sensors is increased from 5 to 10 or more so that the accu- racy of estimating the average ther- mally induced volume change in the layer of product surrounding each sen- sor increases, (3) the waiting period after any addition or removal of prod- uct is increased from 6 to 24 h or longer so that the horizontal and vertical tem- perature gradients dissipate, (4) the av- erage rate of change of temperature in any one layer or in the tank as a whole is small enough to allow accurate tem- perature compensation, and (5) an ac- curate experimental estimate of the constants necessary for converting level and temperature changes to vol- ume is made. The experiments further suggest that a multiple-test strategy Is required in order for such systems to meet the tank tightness regulatory stan- dard. This Project Summary was developed by EPA's Risk Reduction Engineering Laboratory, Cincinnati, OH, to announce key findings of the research project that Is fully documented In a separate report of the same title (see Project Report ordering Information at back). Introduction The U.S. Environmental Protection Agency (EPA) regulation for underground storage tanks (USTs), published in the Federal Register (40 CFR Parts 280 and 281) on September 23, 1988, specifies the technical standards and a variety of release detection options for minimizing the environmental impact of tank leakage. With several exceptions, the shop-as- sembled tanks covered by the regulation range in size from small (a few hundred gallons in capacity) to very large, with no clearly defined upper limit. (Requirements for large field-erected tanks have not yet been established). The number of large tanks (defined here as those between Printed on Recycled Paper ------- 57,000 and 190,000 L (15,000 and 50,000 gal) in capacity) represents a small but important portion of the total tank popula- tion. This number is increasing because of the preference of tank owners/opera- tors for a smaller number of larger tanks to meet storage needs. Many large-vol- ume storage facilities have tanks that are nominally 190,000 L (50,000 gal) in ca- pacity. Unfortunately, there is not enough information to help owners and operators of large tanks select a testing system that will be In compliance with the regulations. Furthermore, it is not known whether volu- metric tests can achieve the same level of performance in large tanks as they do in smaller ones. Objectives The program of experiments conducted at Griffiss Air Force Base was devised to expand the understanding of large under- ground storage tank behavior as it im- pacts the performance of volumetric leak detection testing. This report addresses three important questions about testing the larger underground storage tanks for leaks. First, can the EPA regulatory stan- dards be met when volumetric methods are used to test tanks up to 190,000 L (50,000 gal) in capacity? Second, what is the precision required of the temperature and level sensors and what'is the duration of the data collection period in order for a volumetric system to test larger tanks, par- ticularly those that are partially filled? Third, what are the important features of a volu- metric system that meets or exceeds the regulatory performance standards? Background Leak detection systems used as volu- metric tank tightness tests on tanks cur- rently covered by the EPA regulation (i.e., those up to 190,000 L (50,000 gal) in capacity) must be able to detect leaks as small as 0.38 L/h (0.10 gal/h) with a prob- ability of detection (PD) of at least 0.95 and a probability of false alarm (PFA) of 0.05. Leak detection systems used as monthly tests, such as automatic tank gauging systems, must be able to detect leaks as small as 0.76 L/h (0.2 gal/h) with a P0 of 0.95 and a PFA of 0.05. Most state regulations, which require that a tank tight- ness test be done annually, are more strin- gent than the federal regulation. These standards are based on the results of an extensive experimental program conducted by the American Petroleum Institute (API) on 38,000-L (10,000-gal) tanks at retail stations and by the EPA on 30,000-L (8,000-gal) tanks at EPA's Underground Storage Tank Test Apparatus in Edison, NJ. The EPA described the important fea- tures of a generic volumetric tank tight- ness system that would yield the required level of performance in tests conducted in overfilled and partially filled tanks. The important features are the ones that com- pensate for or minimize errors in the mea- surement of volume changes not due to a leak; these errors, which are due to ambi- ent noise, are not associated with leaks and thus occur in both leaking and nonleaking tanks. Experiments on a 30,000-L (8,000-gal) tank showed that an array of five or more equally spaced tem- perature sensors, each weighted by the volume of product in the layer surrounding it, was sufficient to compensate for ther- mally induced volume changes. This tem- perature-sensing array was suitable providing that adequate wajting periods were observed after any addition of prod- uct, whether this addition represented a delivery to the tank or whether it consti- tuted topping of the tank (as is required when testing an overfilled tank). The addi- tion of product to the tank produced inhomogeneities in the temperature field that were large enough to prevent an ac- curate estimate of the mean rate of change of temperature. As a means of minimizing the effect of these thermal inhomo- geneities, waiting periods of at |east 3 h after topping and 4 to 6 h after a delivery were recommended. Any addition of prod- uct also changes the level of the liquid in the tank and, therefore, the pressure that is exerted on the tank walls. This change in pressure causes the tank to deform; observing a waiting period before the test allows deformation to subside, thus elimi- nating any errors that it might have pro- duced. The waiting period may have to be as long as 12 to 18 h, depending on the properties of the tank and of the backfill and native soil surrounding it. In tests conducted in overfilled tanks, there is a third source of potential error: the tem- perature- and/or pressure-induced expan- sion or contraction of any vapor trapped in the tank. If the amount of trapped vapor is significant, or if the range of tempera- ture and/or pressure changes within the trapped vapor is great, the error can have a detrimental impact on the test. Unfortu- nately, it is extremely difficult to identify the presence of small volumes of trapped vapor, and there is no satisfactory way to compensate for volume changes due to this phenomenon. A fourth source of po- tential error is unique to tests conducted in partially filled tanks: this is the error produced by evaporation or condensation at the liquid/vapor interface and the vapor/ tank-wall interface. It is believed that the effects of evaporation and condensation are usually small, but available data show that under some air-temperature and at- mospheric-pressure conditions they can be large enough to produce false alarms and missed detections. At the present time there is no systematic way to determine when these conditions will adversely af- fect the test; however, any adverse ef- fects can be minimized through the use of a multiple-test strategy. The other sources of error, which are produced by surface and internal waves, can affect the test results in both overfilled and underfilled tanks. These can be minimized by proper sampling of the level and temperature data. For best performance, the instrumenta- tion noise, or system noise, should be less than the ambient noise. In small tanks, whether partially filled or overfilled, this can be achieved. However, as the volume or the surface area of the product in the tank increases, this becomes proportion- ately more difficult. Because the EPA regulations (and the recommended "important features" of a volumetric tank tightness test that are de- scribed above) are based on experiments conducted on 30,000-L (8,000-gal) tanks, it is unclear whether a volumetric test that meets the EPA standard when used to test smaller tanks can achieve the same level of performance when used to test larger tanks. At the present time, there are no experimental data that can be used to make such an assessment, particularly for tanks as large as 190,000 L (50,000 gal). Additional information about the mag- nitude of the noise in large tanks would be required before such an assessment could be made. Based upon previous ex- perimental and analytical work, we ex- pected that four things would be necessary in order for a volumetric leak detection system to maintain the required level of performance when used to test large tanks: (1) more temperature sensors, (2) longer waiting periods after topping or after deliv- ery of product to the tank, (3) a longer test duration, and (4) an increase in the preci- sion requirements of the temperature and level measurement systems. Conclusions In the present study, limited-scope field experiments were conducted during late August 1990 on two partially filled 190,000- L (50,000-gal) underground storage tanks located at Griffiss Air Force Base in up- state New York. The purpose of the ex- periments was to determine whether volumetric systems intended for 30,000- to 38,000-L (8,000- to 10,000-gal) tanks could successfully be used with larger tanks. The Griffiss tanks were 254.3 m (77.5 ft) long and 320 cm (10.5 ft) in ------- diameter. A level sensor with a precision of 0.0005 cm (0.00025 in.) and an array of 10 submerged thermistors spaced at 30-cm (12-in.) intervals, each thermistor having a precision of 0.001 °C (0.002°F), were used to collect the data. All experi- ments were conducted in partially filled tanks. Changes in product level were ef- fected by shunting product from one tank to another by means of a pump. The addi- tion or removal of product produced changes in the temperature of the product that effected volume changes of several liters per hour or more. The following observations were made: • Temperature fluctuations observed throughout the tank after approxi- mately 38,000 L (10,000 gal) of prod- uct had been added or removed were too great, unless at least 4 h had elapsed, to permit an accurate leak detection test. (The addition of 38,000 L (10,000 gal) simulated a delivery of product to the tank.) • Temperature fluctuations observed after the addition of approximately 19 L (5 gal) of product 25°C warmer or 8°C cooler than the in situ product were too great, unless 2 to 3 h had elapsed, to permit an accurate leak detection test. (The addition of 19 L (5 gal) simulated the topping of an overfilled tank.) • The average rate of change of tem- perature between any two locations along the long axis of the tank, as measured by any two thermistors at the same height, but distanced hori- zontally, was less than 0.001 °C/h beginning 4 h or more after product additions or removals. Furthermore, the mean temperature along the centeriine of the tank was the same at each height, i.e., the horizontal gradient was negligible at the centeriine. • A horizontal gradient in the mean temperature was observed in the mid-region of the tank in the area between the centeriine and the wall of the tank. The rate of change of temperature, as measured by three thermistors spaced at horizontal in- tervals of 30 cm (12 in.), was lower in the area of the centeriine and higher in the area of the tank wall, an observation that is consistent with the physical process of heat transfer between the backfill surrounding the tank and the product inside it. The difference between the rate of change of temperature measured at the centeriine of the tank and at locations off the centeriine was large enough to suggest that a single ver- tical array is not sufficient for tem- perature compensation unless at least 18 h has elapsed since any product addition or removal. Addi- tional horizontally oriented ther- mistors must be incorporated into the arrays to compensate for these temperature changes, or the test must not be started until the rate of change of temperature has subsided. • The area near the bottom of the tank exhibited the largest vertical gra- dient and the greatest rate of change of temperature. In this region, a spac- ing of 30 cm i(12 in.) between ther- mistors was 'not adequate, in the experiments conducted, for correct temperature compensation unless at least 10 h had elapsed since the last addition or removal of product. • The temperature fluctuations that fol- lowed changes in product level in these experiments were so large that changes due to deformation were masked. As a consequence, none of the classical exponential level changes associated with tank defor- mation was observed in these ex- periments. ' Analysis of the level data revealed the presence of surface waves (seiches) having periods of 2 to 10 s and peak-to-peak amplitudes of 1 to 2 L. These waves were consistent with the fundamental and first har- monic of waves propagating along the long and short axes of the tank. Analysis of the temperature data re- vealed the presence of internal waves having periods of 3 to 30 min. These subsurface waves were large enough to produce periodic sur- face waves. Experimental estimates of the height- to-volume conversion factor were within 5% of the theoretical estimates made with a tank chart. When 10 h had elapsed after a prod- uct addition or removal, and ther- mistors spaced at 30-cm (12-in.) intervals were used for thermal com- pensation, the residual volume changes in each of three tests on nonleaking tanks were 0.36, 0.67, and -0.22 L/h (0.095, 0.177, and 0.058 gal/h) respectively. When 2 h had elapsed after topping and 20 h after a product addition or removal, residual volume changes in each of two tests were 0.036 and -0.043 L/h (0.0095 and -0.011 gal/h) respec- tively. These residual volume changes can be attributed to inad- equate temperature compensation. (There was insufficient coverage near the surface of the product, at the bottom of the tank, and in the area between the centeriine and the tank wall, all locations where large tem- perature gradients were present.) The effects of evaporation and con- densation within the tank could not be quantified, but their contribution to the residual volume changes ap- pears to be smaller than the errors in temperature compensation. The data collected during these experi- ments, combined with theoretical analy- sis, were sufficient for the researchers to address each of the technical objectives of this study. A summary of the key con- clusions of this research project are pro- vided below. Volumetric leak detection systems can meet EPA's performance standards for testing tanks up to 190,000 L (50,000 gal) In capacity. The experiments on 190,000-L (50,000-gal) tanks suggest that volumetric leak detection systems can meet the EPA standards for both volumet- ric tank testing and automatic tank gaug- ing. That is, they can detect leaks of 0.38 L/h (0.10 gal/h) with a PD of 0.95 and a PF/> of 0.05, which is the performance re- quired of tank tightness tests. (By defini- tion they can also meet the requirement for automatic tank gauging systems, which is the ability to detect a leak of 0.76 L/h (0.20 gal/h) with a Pp of 0.95 and a PFA of 0.05.) However, achieving this goal is very difficult and probably requires a multiple- test strategy. A 0.76-L/h (0.2-gal/h) leak was detect- able with the thermistor array used in these experiments, but a smaller leak of 0.38 L/ h (0.1 gal/h) could not be reliably de- tected. However, leaks as small as 0.38 L/h (0.1 gal/h) were detectable if the wait- ing period after any addition or removal of product from the tank was at least 18 h. After some analysis, this was explained by the fact that there was an insufficient number of thermistors at the bottom of the tank, near the surface of the product, and between the centeriine and the walls of the tank, areas where either the rate of change of temperature or the gradient in the rate of change of temperature was greater than in other parts of the tank. The upper portion of the layer closest to the surface was influenced by large changes in the temperature of the vapor, so that the implicit assumption that the rate of change of temperature varied lin- ------- early through the layer was violated. The thermistor closest to the surface was not physically centered in the layer, and the product surrounding it was not equally dis- tributed above and below it. When the thermistor was too far away from the sur- face (e.g., 25 cm (10 in.)), the contribution from the surface was not properly included in the average. Any error in measuring the average rate of change of tempera- ture was magnified by the volume of prod- uct in the layer. The error in measuring the average rate of change in tempera- ture was even greater in the layer of prod- uct at the bottom of the tank. (In measurements made at the bottom, how- ever, the magnitude of the error decreased with time; in measurements made near the surface it did not.) Although the tem- perature sensor is indeed centered in this bottom layer, the curvature of the tank is such that the volume of the product above the sensor is significantly greater than that below it. The average rate of change of temperature and the gradient in the rate of change of temperature were significantly greater here than in any other layer. While errors of similar magnitude in measuring the average rate of change of tempera- ture are present in small tanks, the vol- ume of each layer in a small tank is significantly less than in a large tank, par- ticularly near the bottom. The largest source of error in measuring the average rate of change of temperature was due to horizontal gradients in the rate of change of temperature between the centerline of the tank and the wall of the tank. Better temperature compensation would have been achieved if additional temperature sensors had been located near the bot- tom of the tank and near the product sur- face, ensuring a better estimate of the rate of change of temperature in the layer surrounding each thermistor, or if a longer waiting period had been used, thus mini- mizing the rate of change of temperature in these layers and throughout the tank as a whole. The Important features of a generic volumetric leak detection system that can meet the EPA performance stan- dards have been Identified. The experi- ments on 190,000-L (50,000-gal) tanks allowed us to identify the key feature that a volumetric leak detection system used on larger tanks must possess in order to meet the EPA standard. K must have bet- ter temperature compensation than what is deemed sufficient for a 30,000- to 38,000-L (8,000- to 10,000-gal) tank, and it must have longer waiting periods and a longer test duration. All the other features required for accurate detection of leaks in small tanks are applicable equally to the detection of leaks in large tanks. Five things are necessary for success- ful temperature compensation in tanks as large as 190,000-L (50,000-gal). First, a test must not be started until the horizon- tal gradients in the rate of change of tem- perature between the centerline and the tank walls have dissipated. Second, the number of temperature sensors must be sufficient that the volume of product in the layer around each sensor is not too great; the smaller the volume in each layer, the less likely it is that a temperature mea- surement error, when summed with mea- surements from the other layers, will adversely affect the test. Third, the dura- tion of the test must be bng enough that (1) the fluctuations in volume observed 6 h or more after any product additions or removals can be averaged, and (2) the precision of the temperature and level is sufficient to detect a leak with a specified performance. Fourth, a test should not begin unless the average rate of change of temperature in the tank as a whole or in any one layer is small enough to allow accurate temperature compensation. Fifth, an accurate experimental estimate of the constants necessary for converting level and temperature changes to volume is required: these constants include the co- efficient of thermal expansion, the volume of product in the tank or in each layer, and the height-to-volume conversion fac- tor. How long must the waiting period be? In testing tanks up to 190,000 L (50,000 gal) in capacity, the length of the required waiting period is controlled by the gradi- ent in the rate of change of temperature between the centerline and the wall of the tank. This waiting period must be suffi- ciently long that the temperature fluctua- tions and tank deformation associated with a product addition or removal will have time to subside. A waiting period of 24 h or bnger may be required. The data suggest that the minimum du- ration of a test should be at least 4 h, bng enough that an average of the ambient volume fluctuations can be made. Whether 4 h is sufficient depends on the resolution and precision of the temperature and level instrumentation. The spacing between thermistors in a 190,000-L (50,000-gal) tank may need to be as small as 15 cm (6 in.) to detect leaks as small as 0.38 L/h (0.1 gal/h), particularly near the bottom and top of the tank where more dense coverage will re- sult in a more accurate estimate of the rate of change of temperature. Since er- rors in temperature compensation increase as the average rate of change of tem- perature increases, the most direct way to avoid errors is to wait until the average rate of change of temperature has dimin- ished before starting a test. The precision of the Instrumentation used to measure temperature and level changes establishes the minimum du- ration of a test. In order for a volumetric leak detection system to meet the EPA standards, the length of a test must be appropriate for the precision of the system's instrumentatbn for temperature and level measurement. Given a certain level of precision, the optimum duration of a test can be calculated. As part of the experiments, calculations were made to estimate the minimum duration of a test conducted on a 182,000-L (48,000-gal) tank as a function of the precision of the temperature and level sensors, ft was as- sumed in the calculations that the resolu- tion of the sensors was 2 to 3 times smaller than the most extreme level change that occurred over the duration of the test. The calculations indicated that the test dura- tion must be at least 2 h in the case of a level sensor having a precision of 0.0005 cm (0.00025 in.) and a temperature sen- sor having a precision of 0.001°C (0.002°F). When the instrumentation is less precise, the test duration must be com- mensurately longer. For example, if the level sensor had a precision of 0.0025 cm (0.001 in.), the test would have to be at least 4 h long. Recommendations The recommendations developed from this research project are based on a lim- ited set of data. The recommendations for controlling the key sources of noise might be further refined if additional experiments were conducted. We believe, however, that additional data would not have any sub- stantial impact on the general nature of the recommendations made here, and that further refinements to these recommenda- tions would not materially change the ef- fort or cost involved in developing or modifying a method of testing large tanks. Although the experiments were limited to tests conducted on partially filled tanks, many of the conclusions are applicable to the use of volumetric systems in overfilled tanks as well. The recommendations that emerged from this research project fall under two headings. Temperature Compensation The single most important cause of er- rors in testing large tanks with volumetric leak detection systems appears to be in- accurate temperature compensation. Two things are necessary for successful tem- perature compensation. First, the number L. ------- of temperature sensors must be sufficient that the volume of product in the layer around each one is not too great; the smaller the volume in each layer, the less likely it is that a measurement error, when averaged with measurements from the other layers, will adversely affect the test. Second, a test must not be started if the average rate of change of temperature of the product in the tank as a whole, or even in a single layer, is great enough to prevent the system from detecting a leak of given size. The following procedure is recom- mended for compensating for the thermal expansion or contraction of the product: • Place the lowest temperature sen- sor approximately 8 cm (3 in.) from the bottom of the tank and the up- permost sensor approximately 8 cm (3 in.) below the surface. • Space the temperature sensors at intervals of 15 to 30 cm (6 to 12 in.) or less along the vertical axis of the tank; space the sensors at intervals of 15 cm (6 in.) or less in the bottom 46 cm (18 in.) of the tank and in the 15 to 30 cm (6 to 12 in.) of product located immediately beneath the sur- face. (A 30-cm (12-in.) spacing can be used if the rate of change of temperature between adjacent lay- ers of product throughout the entire tank is nearly identical.) • Partition the tank into layers, each . of which is centered about a tem- "• perature sensor. Then calculate the volume of product in each layer. • Wait at least 24 h for horizontal gra- dients in the rate of change of tem- perature to dissipate. (These horizontal gradients occur between the centerline and the wall of the ' tank.) Alternatively, measure these horizontal gradients directly, and do not attempt to compensate for tem- perature until they have dissipated. If the compensated volume rate ex- ceeds the threshold, continue to test until the measured volume rate ceases to decrease and remains constant. • Using real-time measurements, wait for the rate of change of tempera- ture to diminish sufficiently that the maximum potential error in measur- ing the average rate of temperature for each test is small. The accept- able rate of temperature change de- pends on the number of thermistors, the precision of each thermistor, and the degree of compensation that can be achieved with the array of ther- mistors. A very conservative ap- proach is to incorporate the follow- ing analysis tests. - Do not begin a test if the rate of change of temperature is great enough in any one layer to pro- duce a volume change that will exceed the detection threshold. (When using a threshold of 0.19 L/h (0.05 gal/h) in a tank contain- ing JP-4 fuel, this would limit the rate of change in temperature to less than 0.008°C in the largest layers of ,a 190,000-L (50,000- gal) tank divided into ten layers.) - Do not begin a test if the aver- age rate pf change of tempera- ture throughout the tank is great enough to produce volume changes that exceed the thresh- old based on an average level of compensation to be achieved. (When using a threshold of 0.05 gal/h in a: tank containing JP-4 fuel, this would limit the rate of change in temperature to less than 0.019°C throughout a 190,000-L'(50,000-gal) tank if on average the method is able to compensate for 95% of the tem- perature changes.) • Use the most precise temperature and level measurement systems available and calibrate them fre- quently and properly, ft is recom- mended that temperature sensors have a precision of 0.001 °C and the level sensors have a precision of 0.00025 cm (0.0001 in.). • Check that all sensors function prop- erly during a test. If a sensor mal- functions, the test should be repeated. • Make sure the test is at least 4 h long so that ambient fluctuations will be properly averaged and will not affect the test., Longer tests may be required depending on the resolu- tion and precision of the level and temperature sensors. • Measure the coefficient of thermal expansion experimentally. • Determine the height-to-volume con- version factor used to convert level measurements to volume measure- ments experimentally. • Use a multiplexes! strategy. Whether this temperature compensation procedure is sufficiently adequate for a volumetric leak detection system to meet the EPA's regulatory standard for a tank tightness test (or a monthly monitoring test) will not be known until an actual performance evaluation is conducted on a system that incorporates some or all of these procedures. Evaluating a Volumetric Leak Detection System Volumetric leak detection systems that will be used on large tanks should be experimentally evaluated according to the EPA's standard test procedure for evalu- ating volumetric tank tightness tests. This includes the performance of the system in terms of probability of detection and prob- ability of false alarm. The primary features that should be examined are the method of temperature compensation, the waiting periods, and the duration of the test. The results of the present study suggest that, when a volumetric leak detection system is used to test larger tanks, longer waiting periods, a longer test duration and better temperature compensation are required if leaks are to be detected with reliability. Unfortunately, none of the existing facili- ties specializing in evaluations is equipped with 190,000-L (50,000-gal) tanks. There- fore, systems must be evaluated at large- volume storage facilities that are operational, and the EPA's standard test procedure should be modified to accom- modate this type of evaluation. The full report was submitted in fulfill- ment of Contract No. 68-03-3409 by Vista Research, Inc., under the sponsorship of the U.S. Environmental Protection Agency. 'U.S. Government Printing Office: 1992 — 648-080/60042 ------- ------- ------- James W. Starr, Richard F. Wise, and Joseph W. Maresca, Jr., are with Vista Research, Inc., Mountain View, CA 94042. Robert W. Hlllger is the EPA Project Off her, (see below). The complete report, entitled "Volumetric Leak Detection in Large Underground Storage Tanks," (Order No. PB91-227942/AS; Cost:$23.00, subject to change) will be available only from: National Technical Information Service 5285 Port Royal Road Springfield,VA22161 Telephone: 703-487-4650 The EPA Project Officer can be contacted at: Risk Reduction Engineering Laboratory U.S. Environmental Protection Agency Edison, NJ 08837 United States Environmental Protection Agency Center for Environmental Research Information Cincinnati, OH 45268 BULK RATE POSTAGE & FEES PAID EPA PERMIT No. G-35 Official Business Penalty for Private Use $300 EPA/600/S2-91/044 ------- |