New England Interstate
Water Pollution Control
Commission 01852-1124
www.neiwpcc.org/lustline.htm
116 John Street
Lowell, Massachusetts
Bulletin 54
February
2OO7
yj.ST.yNE
A Report On Federal & State Programs To Control Leaking Underground Storage Tanks
A Marriage Jttade /// (jroundwater
How State LIST, LUST, and Source Water Programs
Can Work Together to Protect Drinking Water
by Kara Sergeant
f/ \ espite our success in reducing the
I I magnitude of releases from underground
jl^r storage tank (UST) systems, these
systems still leak, and gasoline still finds its way
into people's drinking water. Recognizing m .'
the importance of protecting our
groundwater drinking water sources,
Congress sought to strengthen the
federal UST/LUST program by
including new UST compliance
provisions in the 2005 Energy Policy
Act (Title XV, Subtitle B). The new
provisions represent the largest
impact to the national UST/LUST
program since its inception more than •
twenty years ago. Yet, while some of
these provisions increase protection
for drinking water sources, it is going
to take more than the new state
regulations to protect drinking water.
And while I recognize that the state UST/LUST and
drinking water program managers have their hands full,
I'd like to challenge both entities to be as proactive as
possible in their approach to protecting drinking water
by going beyond the federal standards, by working with
each other, and by educating both tank owner/operators
and municipal officials.
• continued on page 2
5
8
11(
17(
18(
21 (
24(
26(
28(
It Should Never Have Happened
Army National Guard Tackles Petroleum Contamination
USTs and LUSTs of Biodiesel
Rothenstein: 2006 Finish Line
Tanks on Tribal Lands—Corrective Action at a Former
Trading Post
Are Vapor Leaks Still Relevant?
Field Notes - UST Industry Trends 2007
FAQs from the NWGLDE—Leak Detection and Alternative Fuels
EPA Enforcement Actions
-------
LUSTLine Bulletin 54 • February 2007
• USTs and Source Water
from page 1
Two Sides of the Same Coin
Tank programs have enough to
worry about—compliance, enforce-
ment, cleanup, reimbursement—so
why should a state UST program
have to take on the added job of
being proactive about protecting
drinking water? For one thing, more
than half of the people in the United
States get their drinking water from
groundwater sources, and, unfortu-
nately, contamination from leaking
tanks often finds its way into these
sources. Thus, with their limited
resources, it makes sense for both
state programs to work together to
become more effective at protecting
drinking water.
Drinking water protection can-
not rely on water treatment alone;
instead, most states adopt a multi-
barrier approach that includes
preventing contamination from
occurring in the first place. All public
water systems in the country have
completed source water assessment
L.U.S.T.Line
Ellen Frye, Editor
Ricki Pappo, Layout
Marcel Moreau, Technical Adviser
Patricia Ellis, Ph.D., Technical Adviser
Ronald Poltak, NEIWPCC Executive Director
Lynn DePont, EPA Project Officer
LUSTLine is a product of the New England
Interstate Water Pollution Control Commis-
sion (
cooperative <
between NEIWPCC and the U.S.
Environmental Protection Agency.
LUSTLine is issued as a communication
service for the Subtitle I RCRA
Hazardous & Solid Waste Amendments
rule promulgation process.
LUSTLine is produced to promote
information exchange on UST/LUST issues.
The opinions and information stated herein
are those of the authors and do not neces-
sarily reflect the opinions of NEIWPCC.
This publication may be copied.
Please give credit to NEIWPCC.
NEIWPCC was established by an Act of
Congress in 1947 and remains the oldest
agency in the Northeast United States
concerned with coordination of the multi-
media environmental activities
of the states of Connecticut, Maine,
Massachusetts, New Hampshire,
New York, Rhode Island, and Vermont.
NEIWPCC
116 John Street
Lowell, MA 01852-1124
Telephone: (978) 323-7929
Fax: (978) 323-7919
lustline@neiwpcc.org
@ LUSTLine is printed on Recycled Paper
sion (NEIWPCC). It is produced through;
cooperative agreement (#T-830380-01)
reports (SWAPs), which identify
each public water supply, its poten-
tial contamination threats, and how
susceptible it is to those threats. Once
states reviewed their SWAP reports
and analyzed the major threats, USTs
emerged as a major potential threat
nationwide.
Protecting drinking water is not
a new concept to UST/LUST pro-
grams. In fact, many state UST/
LUST programs have been working
with their drinking water program
for years. But for others, it took a
national initiative to open the lines of
communication with their drinking
water program, especially when the
program was located in a different
agency.
In 2004, the U.S. EPA Office of
Underground Storage Tanks (OUST)
made a commitment to protect
drinking water by co signing two
memos with the Office of Ground
Water and Drinking Water and hold-
ing collaborative state and regional
meetings on the subject. Both memos
are available on the OUST website
(http://epa.gov/oust/swanust. htm) and
are essential reading. They contain
several tips for states interested in
working with their drinking water
program.
The two Energy Policy Act pro-
visions that will have the biggest
impact on drinking water protection
are minimum three-year inspections
and secondary containment. Accord-
ing to the Act, states will need to
inspect all stations at least every
three years to ensure that tank sys-
tems are being operated and main-
tained properly to prevent system
failures and contamination.
The secondary containment pro-
visions (as opposed to the financial
responsibility alternative that a few
states will adopt) will apply to
almost all new UST facilities and
facilities where tank systems are
replaced. These provisions are specif-
ically meant to protect drinking
water sources. And lest we forget,
UST facilities themselves are drink-
ing water sources. They require
potable water for everyday func-
tions, whether it is the employee
restroom or a convenience store. UST
facilities are either connected to a
community water system, whose
pipes cross the property to connect
the facility, or they have an onsite
potable well. For states that do not
already have secondary containment
in one form or another, this new
requirement will add another layer of
protection to groundwater supplies.
How Can States Improve
the Drinking Water/UST
Connection?
For states that already meet the three-
year UST inspection frequency
requirement, one strategy for improv-
ing the drinking water/UST connec-
tion is to target UST facilities in more
susceptible areas for more frequent
inspections. Ask your drinking water
program for a list of sensitive source
water areas or those most at risk for
UST contamination. They will have
this information from SWAP reports
or can create it from GIS layers.
For example, as with many
states, Massachusetts and Arkansas
UST and Drinking Water programs
are located in different agencies, yet
they work together to prioritize UST
inspections in source protection
areas. One state is in the process of
arranging to tap the Drinking Water
State Revolving Fund to fund an
additional inspector position for the
tanks program. This person will
focus on inspections in source protec-
tion areas. This is a great way to
increase staff on limited resources.
Both Clark Conklin, Chief
Deputy of the Nebraska State Fire
Fuels Division, and Jack Daniel,
Administrator of Nebraska Health
and Human Services, paid a visit to
their governor to make the case for
adopting the secondary containment
option for the state's USTs. Accord-
ing to Conklin, Daniel also made a
strong case for the importance of the
UST program to drinking water pro-
tection.
Many tank and drinking water
programs share information through
their GIS. Oftentimes it is a matter of
overlaying several GIS layers to
locate tanks in source protection
areas. GIS is also a great tool for pri-
oritizing cleanups. However, not all
tanks are located on GIS layers—
addresses are not always maintained
electronically, new tanks have not
been entered, the addresses are
wrong, or the drinking water pro-
gram has a completely different data-
base system. To correct these
problems it takes additional re-
sources to update the information.
-------
February 2007 • LUSTLine Bulletin 54
Examples of how Utah, Min-
nesota, and New York share GIS loca-
tion information and the challenges
associated with these efforts can be
found on the National Tanks Confer-
ence website (http://www.neiwpcc.
org/tanksQ7/archives.asp). For instance,
Minnesota is improving spatial data
accuracy, and Utah is pursuing a dig-
italization project for source water
data.
Both U.S. EPA OUST and the
Office of Ground Water and Drink-
ing Water realize the importance of
GIS as a tool for protecting drinking
water. EPA is piloting a Drinking
Water Mapping Application (DWMA)
with several states and tribes to map
tanks and source water data through
a secure web-based mapping and
database technology.
Spread the Word
Outreach is a prime area for state
UST and source water program col-
laboration. It is important to target
outreach to tank owners, municipal
officials, and others. Municipal offi-
cials have a great deal of influence
over source water through planning
and other land-use decisions they
make that can impact source water.
The New England Interstate
Water Pollution Control Commission
(NEIWPCC) has published a guide
for municipal officials titled Protect-
ing Drinking Water Sources in Your
Community: Tools for Municipal Offi-
cials. (www.neiwpcc.org/sourcewater-
outreach) The guide features a whole
chapter dedicated to USTs, which
includes case studies and detailed
strategies for action.
To educate UST system owners
and operators about the importance
of source protection and how their
business can protect the source, states
can include a drinking water section
when developing their operator-
training program (another Energy
Policy Act requirement). It is an easy
way to reach UST owner/operators
and encourage them to improve their
practices.
UST programs can also work
with their drinking water program to
create specific outreach materials to
hand out during UST system inspec-
tions. For example, the Louisiana
Department of Environmental Qual-
ity (LDEQ) has staff who serve on
Drinking Water Protection Teams
that work with communities on a
parish or watershed level to involve
local officials, water system opera-
tors, community planners, busi-
nesses, citizens, students, and others
in the effort to protect drinking
water.
These teams are working to help
establish Drinking Water Protection
Committees in each Louisiana com-
munity targeted by the program.
These committees are comprised of
volunteers who want to participate in
continuing public education and
drinking water protection actions in
their own community. LDEQ has cre-
ated a two-page fact sheet titled Best
Management Practices for Underground
Storage Tanks to Prevent Drinking
Water Contamination, which is distrib-
uted by the local parishes directly to
UST owner/operators in their area
(http://www.deq. louisiana.gov/).
I'd like to challenge both entities [state
UST/LUSTand drinking water
programs] to be as proactive as
possible in their approach to protecting
drinking water by going beyond the
federal standards, by working with
each other, and by educating both
tank owner/operators and
municipal officials.
TNC Pilot Program
What happens when a gas station is a
public water supplier? More and
more existing gas stations are
expanding their business with mini-
mart/convenience store operations
to increase their profit margin. Often-
times, this means that companies sell
food and beverages that are prepared
onsite. As discussed earlier, to pro-
vide potable water or prepare bever-
ages such as coffee, facilities must
either be hooked up to the local pub-
lic drinking water supply or use an
onsite well. It is not known how
many gas stations operate onsite
wells.
The problem is that most UST
facility owner/operators don't know
that this expansion means their well
is now considered a transient non-
community public water supply
(TNC). If the gas station supplies the
water to 25 or more people per day
(direct or indirect consumption), then
it is required to meet certain state cri-
teria to ensure that its water quality is
adequate. States require that public
water supplies be operated by a certi-
fied operator, who is responsible for
having the well tested and sending
the results to the state drinking water
department. These tests indicate if
there are any water quality problems.
There have been instances of contam-
ination that prompted a need to bring
more attention to this issue. (See
LUSTLine #47 "Sugar? Cream?
MtBE? It's Time to Close the Gap
Between Water Supply and UST Pro-
grams.")
NEIWPCC received U.S. EPA
funding to initiate a pilot program in
the New England states and New
York that can be transferable to the
rest of the states. NEIWPCC will
develop and distribute a workbook,
slides, fact sheets, and training mate-
rials that tank owners and operators
can use to comply with state drinking
water regulations. Upon successful
completion of this pilot program,
NEIWPCC intends to develop and
distribute this material and training
efforts to other regions of the country
as funding allows.
LUST- Drinking Water
Coordination Also Critical
Coordination between state source
water and LUST cleanup programs is
also critical. Illinois, for example,
recently passed a regulatory amend-
ment requiring the identification of
potable water wells in relation to
LUST cleanup sites. The Arkansas
Department of Health and Human
Services and the Arkansas Depart-
ment of Environmental Quality
(ADEQ) signed a Memorandum of
Agreement that includes sharing
locational data on reported leaks and
spill and cleanup projects.
To understand how many state
LUST programs are interacting with
their drinking water programs,
NEIWPCC's latest LUST survey, State
Experiences with Petroleum and Haz-
ardous Substance Releases at LUST Sites,
Heating Oil Tanks, and Out of Service
Tanks, includes several drinking
water-related questions. Preliminary
results indicate that most states have
some level of interaction between
• continued on page 4
-------
LUSTLine Bulletin 54 • February 2007
• USTs and Source Water
from page 3
UST/LUST programs and Drinking
Water Programs with regard to shar-
ing information about releases and
analytical results and prioritizing
cleanups in source water areas. The
survey is still ongoing; preliminary
results will be presented at the
National Tanks Conference by Ellen
Frye. The final results will be avail-
able on the NEIWPCC website in
spring 2007.
So, How Do You Get Started?
Get in touch with your state source
water contact. A list can be found at
www.epa.gov/safewater or protectdrink-
ingwater.org. The latter is the website
for the Source Protection Collabora-
tive, a group of 15 national organi-
zations committed to protecting
drinking water. I urge you to check
out this website as well as other web-
sites mentioned in this article to
answer any general and topic-specific
questions you may have. There will
also be a source protection session at
the 2007 National Tanks Conference.
I challenge you to pursue at least
one suggestion mentioned here, and
if your state UST and drinking water
programs have established a success-
ful working relationship, please let
me know about it so I can share your
story at a future conference or in a
LUSTLine article. •
Kara Sergeant is an Environmental
Analyst at New England Interstate
Water Pollution Control Commission
(NEIWPCC). She has coordinated three
meetings on UST- source water coordi-
nation and was the project officer on
Protecting Drinking Water Sources
in Your Community: Tools for
Municipal Officials. She can lie
reached at ksergeant@neiwpcc.org.
Increasing Communication Between State
Source Water & UST Programs
State UST/LUST and source water programs need to talk among themselves on a
regular basis. If you are a state that needs to either establish communication with
your drinking water prog ram or strengthen an existing partnership, see the check-
list below for ideas on questions to ask and answer to get started.
Tank Siting
/Who verifies that a proposed UST system is within the allowable distance
from a water supply well?
/Are potential developers required to review the local source protection
plan/SWAP report or complete an environmental assessment? These docu-
ments may contain more detailed information on the vulnerability of a water
system that may not be clear of the state setback measurement.
/ Is the drinking water program notified if an UST system is proposed near a
water supply system or, at a minimum, before an approved well is installed?
/Are UST system owner/operators required to notify a downstream water
supplier in the event of a spill?
Existing Tanks
/Are your UST/LUST program personnel aware of source protection areas—
what they are and where they are?
/ Does your program prioritize UST inspections in source protection areas?
/ Do you notify the water program if an UST system in a source protection
area is noncompliant? Some violations may be more relevant to protecting
drinking water, such as poorly maintained spill buckets, rather than failing to
keep records onsite.
/ Do you use GPS to spatially reference tank sites?
/ Do you make an effort to locate and remove or properly close all abandoned
tanks?
Leaking Tank
/ Do you inform your state drinking water program or a water supplier when
there is a reported fuel spill in a source water protection area?
/ Do you receive information from the water program, utilities, or other water
supply sources concerning the detection of petroleum contaminants in pub-
lic or private water supplies?
/ Do you share monitoring well information (perhaps to see where a plume is
traveling) with your state drinking water program?
/ Does your program give cleanup priority to sites located in source water
protection areas?
Presentations from the 2007 National
Tanks Conference on the NEIWPCC
Website
19th Annual National
TRNKS CONFERENCE]
Deep in the Heart of Tanks!
dNEIWPCC
Miss a session at the National Tanks Conference or want
to share a presentation with a colleague? Presentations
from the 19th Annual National Tanks Conference in San
Antonio, Texas from March 5-7,2007 will be available
on the New England Interstate Water Pollution Control
Commission website (www.neiwpcc.org/tanks07) following the conference. Presentations from previous years can also be
located using the Archives function. Also, check back on the website to find out about the 2008 conference location and call-
for-abstracts announcement. •
The Henry B. Gonzalez Convention Center
March 5-7.2007
-------
February 2007 • LUSTLine Bulletin 54
It Should Never Have Happened
The Story of a 27,000-Gallon Gasoline Release in Jacksonville,
Maryland, and Its Aftermath on This Rural Community
by Glen A. Thomas
On Friday, February 17, 2006,
at 5:30 p.m., I received a call
from Herbert M. Meade,
Administrator of the Maryland Depart-
ment of Environment (MDE) Oil Con-
trol Program. He advised me that the
had just been notified by ExxonMobil
that there was a gasoline leak reported
from their corporate-owned and leased
station in the center of Jacksonville. Mr.
Meade said that the leak reported was
significant, it had been going on for some
time, and that MDE had personnel on
site to begin their investigation and plan
recovery efforts. Mr. Meade had con-
tacted the community within hours of
MDE learning of the situation.
"Does MDE have plans to notify
residents in the immediate anticipated
area of pollution?" I asked Mr. Meade.
He replied that they did not have plans
other than to expedite their investigation
and begin recovery efforts. I asked for
permission to visit the station, where an
MDE engineer I had met a year earlier
during an MtBE issue was on site.
When I arrived at the station an
hour later, I was told that MDE had
found significant standing gasoline
product in numerous monitoring wells.
Based on station records, anticipated fuel
loss at that time was in the range of
25,000 gallons. The hydrogeology of the
area indicated that much of the leaked
fuel would migrate southwest from the
station, along a stream fault and bed,
and eventually to a major Baltimore
City-owned reservoir.
That evening the Greater Jack-
sonville Association, Inc., (GJA) con-
tacted its members in the target
community, alerting them to the spill
and asking that they notify neighbors. It
was the beginning of a three-day holiday
weekend. I remained in contact with
MDE daily as their preliminary findings
unfolded. What unfolded was one of the
largest gasoline leaks in Maryland his-
tory, an event that will most certainly
have a profound and lasting effect on the
people in my community.
Exxon personnel performing release investigation actions at the Jacksonville Exxon station
Welcome to Jacksonville
Jacksonville is a rural community
where development lies mostly
within its residentially zoned bound-
aries and significant land areas con-
tinue to be agricultural or forested. A
Community Plan to maintain the
rural nature of our area was adopted
as part of Baltimore County's Master
Plan 2010. Maryland has a strong
county government system, and local
elected representation for Baltimore
County rests with the county execu-
tive and a seven-member council.
The Greater Jacksonville Association,
Inc., is an umbrella community asso-
ciation that represents the homeown-
ers and businesses in the entire area
and includes several smaller neigh-
borhood associations.
There are approximately 4,000
homes within the represented area,
all reliant on private water supply
wells and septic systems, with the
exception of two smaller communi-
ties served by private community
well supplies. One of those private
wells was installed to serve homes
whose wells were contaminated
years ago by a Nike missile base
operational in the community during
the Cold War.
Another significant pollution
event in our area was from a now-
closed Exxon station south of the
town center. About 1,100 gallons of
gasoline leaked into the environment
in 1980, resulting in more than 12
years of recovery and remediation
before MDE closed its oversight. Sev-
eral properties remain undeveloped
as a result of groundwater contami-
nation from that leak.
Then, in December 2004, MDE
reported to the community that it
had detected significant MtBE leak-
age from a BP/Amoco station in the
center of town. Several private wells
in the commercial center of town
were contaminated by the suspected
release of gasoline vapor from under-
ground storage systems. MDE
required tank and line repairs at that
station and heightened monitoring
for all three existing gasoline stations
in town.
• continued on page 6
-------
LUSTLine Bulletin 54 • February 2007
m MD Gasoline Release from page 5
MDE provided GJA with routine
updates on BP/Amoco monitoring
activity. In light of that environmen-
tal oversight, Jacksonville thought it
was safe to assume that no further
underground environmental threats
could impact our quality of life. In
retrospect, that assumption was
painfully naive.
What Happened?
We have since learned that around
the second week of January 2006, a
contractor performing routine main-
tenance in the sump of an UST sys-
tem at the Exxon station installed a
sump penetration fitting. At the time
the tanks were installed at the Exxon
station, the state's UST installation
regulations dictated that there should
be proper clearance for product lines
within the proximity of the sump.
However, the installation of tanks
and lines did not meet those require-
ments, and the contractor's drill and
screw penetrated the improperly
placed unleaded product line located
within inches the sump.
Our understanding is that leak
detection alarms were triggered at
the time, and the tank in question
was shut off. The alarms were osten-
sibly ignored and the shut-off was
deactivated when a technician deter-
mined that there was no problem.
Daily product logs began to reflect
that what came close to three tanker
trucks full of unleaded gasoline were
disappearing. We also understand
that there were several subsequent
inquiries by ExxonMobil and/or the
operator, but that no action was
taken. The final reported fuel loss,
which took place over almost five
weeks, was 27,000 gallons. Clearly
someone had to know there was a
problem and that it was probably a
LUST problem.
Ongoing MDE investigations as
well as legal action, both by the state
of Maryland, against the owner and
operator, and by private law firms in
two class-action suits on behalf of
impacted property owners, affect our
ability to gain full access to all
records and investigation results.
We appreciate that the initial
cause of the leak was a freak accident,
but we also know that the breached
line should not have been where it
was and that someone was well
aware of the losses that went unre-
ported to MDE for over a month. We
also know what the impact has been
on our community over the past year
and that we will all be living with this
travesty and its lingering conse-
quences for years to come.
Community Reaction
Just prior to our regular membership
meeting the Tuesday after the release
was discovered, all the network news
stations in Baltimore had picked up
the story and had cameras and heli-
copters on site for the evening news.
An hour later we were greeted at the
local school by more than 250
alarmed residents. Through our con-
tact with MDE, GJA was at least in a
position to provide an ongoing
source of community news and
updates as the story unfolded.
Our next GJA meeting, in March
2006, was planned to bring represen-
tatives from MDE, including MDE
Secretary Kendl Philbrick, ExxonMo-
bil Global Remediation, the Baltimore
County Department of Environmen-
tal Protection (DEPRM), state and
county elected officials, and commu-
nity health representatives from the
University of Maryland School of
Nursing before the community.
We found it necessary to move to
a larger auditorium, as we had more
than 750 concerned neighbors in
attendance. The meeting went on for
almost three hours. It included fac-
tual and scientific presentations from
Exxon and the regulatory agencies,
comments from political representa-
tives, and questions from the audi-
ence. All four network news teams
were there, feeding live to their
evening news broadcasts. We did
manage to keep the meeting civil and
orderly in the face of clear and obvi-
ous anger, anxiety, contempt, and
real fear about long-term health and
well-being issues.
Immediate Investigation
and Recovery
MDE began aggressive testing of pri-
vate wells southwest of the leak and
had Exxon begin the installation of
monitoring and recovery wells at the
station site and in the neighborhood
located along the streambed down-
hill from the station. That was the
obvious travel line for the fuel. Con-
troversial parameters were set for
testing private wells. Initially, testing
was to be only a half-mile out within
the travel line quadrant from the
leak. GJA pressed MDE to consider
testing within a full half-mile radius
from the spill as a prudent precau-
tion. At the March GJA public meet-
ing, Secretary Philbrick announced
that MDE would expand the testing
to the full half-mile radius we
requested.
We were somewhat blessed by
two uncontrollable natural factors.
First, the gasoline product was
apparently trapped, initially, in an
unknown geological rock fault lying
directly under the center of Jack-
sonville, in a northeast-to-southwest
direction from the Exxon station. Sec-
ond, we had had no real measurable
rainfall from January through the end
of March 2006.
Since the community was reliant
on private wells, the drought was a
problem with regard to groundwater
levels, but the lack of rain helped
contain the liquid gasoline within a
tight area for some time. Exxon
moved fast to drill over 100 recovery
and monitoring wells and recovered
just under 11,000 gallons of liquid
product in the first few months.
However, the assumption about
the direction the migrating product
would take was quickly proven
wrong; a well located at a local bank
about 300 yards across the intersec-
tion to the northeast was found to
have major contamination and was
placed immediately on a portable
water tank supply. That changed the
assumptions and focus of recovery
and remediation. In fact, the greatest
concentration of all contamination
and remediation efforts today is in
the direction originally considered
safe—to the northeast.
Ongoing Recovery and
Remediation
There are now 275 monitoring and
recovery wells within the center of
Jacksonville. MDE has also ordered
an additional 33 monitoring wells to
be installed. They are located in four
identifiable neighborhoods and the
commercial center. This is in an area
that encompasses about 200 resi-
dences and nearly the entire commer-
cial center. It also includes an
elementary school that is already on
bottled water for issues related to
plumbing in the school.
-------
February 2007 • LUSTLine Bulletin 54
Exxon has purchased all of the
remaining undeveloped properties in
the town center and is leasing other
property for the storage and opera-
tion of recovery and remediation
equipment. The center of town has
turned into a 24-hour industrial oper-
ation with soil-vapor-extraction
(SVE) recovery equipment, ground-
water extraction and treatment tanks,
and bioremediation and incineration
operations.
False SVE Recovery Detected
By midsummer, Exxon was reporting
that it had recovered almost 12,000
gallons of equivalent gasoline
through SVE. Combined with the liq-
uid recovery, this was approaching
full recovery of lost product. Under
questioning from GJA, MDE had
been reporting confidence in the for-
mulas used for those calculations.
However, by this time, MDE
requested a restatement of these cal-
culations, and it was determined that
the instrumentation Exxon was using
to produce those calculations was
improperly calibrated. Exxon eventu-
ally restated its SVE calculations as
an estimate much lower than
reported, with a margin of error of
about 20 percent.
Nevertheless, given the geologi-
cal circumstances and the lack of
rainfall, we believe that a significant
amount of liquid and constituent
product has been recovered. No liq-
uid has been recovered since about
April 2006, and Exxon has also
extracted almost nine million gallons
of groundwater for treatment and
extraction of fuel components. Of
course, this water is coming out of
our groundwater supply, which has
concerned both MDE and local gov-
ernment officials. The contaminated
water was initially being trucked to
Delaware for treatment and dis-
charge into the Delaware River. It is
now being treated on site under MDE
oversight and being discharged into
two streams flowing to the Chesa-
peake watershed and the Loch Raven
Reservoir.
Water Supply Task Force
Close to 200 residential properties
have been directly or indirectly
affected, including those on required
private well water testing by Exxon;
and those with monitoring/recovery
wells on their property or in the
streets in front.
The commercial center has been
impacted by concerns over the safety
of water used in such places as gro-
cery stores and restaurants. In addi-
tion to concerns over health and
safety, there have been serious con-
cerns over property values. In fact,
GJA successfully intervened, through
assistance from MDE, in several cases
where property sale closings were in
jeopardy.
Six properties have private well
water supplies that have reached
actionable levels for MtBE (20 ppm in
Maryland). These properties have
been offered filtration systems by
Exxon under MDE requirements.
Many other properties have water
supplies with MtBE below action lev-
els for private water supplies, or they
have trace to significant levels of
gasoline components in the monitor-
ing wells on their property, but these
contaminants have not yet been
detected in their water supply wells.
However, when people know that
they had no MtBE in their water
before this spill, whether their mea-
surement is 0.1 ppm or 20 ppm, they
can't help but feel ill-at-ease about
having to live with the state action
levels—the contaminant was not
there before, and now it is.
We have established a task force
of state, county, and community rep-
resentatives to address the issues and
determine the parameters of any
potential replacement of lost private
well water, either on individual
properties or on a larger scale, if
required. MDE has recently asked
ExxonMobil to participate in paying
the cost of a feasibility study. This is a
contingency plan so that options are
measured in advance should cata-
strophic loss of water supply be
realized. This possibility is itself con-
troversial in an area that feels its rural
nature and residential density are
substantially protected by lack of
public water, which could lead to
denser development.
In some very significant respects,
greater Jacksonville has changed for-
ever. We have learned more than we
needed to know about the fuel indus-
try, LUSTs, governmental protection
and representation, regulatory limits,
and personal property vulnerability.
The cleanup activity in our quiet
town is pervasive, and we expect it to
continue for many years to come. No
one is suggesting anything less than
another ten years.
This situation could have been
prevented by adherence to estab-
lished installation and maintenance
requirements. It could have been con-
fined and contained if alarms and
warnings had been heeded when
they first sounded. It could have been
mitigated by proper management by
ExxonMobil, the owner, and the
lessee/operators. It should never have
happened. •
Glen A. Thomas is past president of
The Greater Jacksonville Association,
Inc. He can be reached at
gat3806@aol.com.
Presentations from U.S. EPA Region 3's Ethanol
Workshop Available on the Web
In response to a request by EPA Region 3 states, the Region organized an
Ethanol Workshop: Conversion from MtBE to Ethanol in Hagerstown, Maryland,
in October 2006. More than 60 LIST regulators attended. The workshop was
designed to provide a forum for states to share their experiences in addressing
the changeover from MtBE to ethanol in gasolines and to understand what is nec-
essary to ensure a transition that will be transparent to consumers. Industry and
government experts were invited to speak on issues related to ethanol (E10, E85)
remediation, compatibility, and insurance liability. Workshop presentations are
available on http://www.epa.gov/reg3wcmd/ethanoLworkshop.htm.
For more information, contact: Jack Hwang at U.S. EPA Region 3
(hwang.jack@epa.gov).
-------
LUSTLine Bulletin 54 • February 2007
ARMY NATIONAL GUARD TACKLES
PETROLEUM CONTAMINATION
Two tab of What It takes to Overcome the Obstacles
by June Taylor
Overcoming Oil Cleanup Challenges in Alaska's Tundra and Permafrost
And You Think You've Got
Problems?
Consider the dilemma of Norm
Straub, Compliance Manager for the
Army National Guard in Alaska. On
taking the job in 1996, he inherited a
backlog of oil-contaminated sites
spread over an area the size of New
England. In developing a priority list,
he found more. Almost all sites were
the result of heating oil spills, usually
from accidents, such as broken pipes
or tank overfills. There have been
some incidental spills related to jet or
helicopter fuels. However, given that
heating oil is the only source of heat in
most of Alaska and that Alaska is very
cold, there is a lot of heating oil use.
(Only the southern part of the state
has forests where wood can be cut for
fuel. Village corporations generate
electricity locally using diesel fuel, but
it is too expensive to use for heating.)
Debra Caillouet, with the Alaska
Department of Natural Resources,
says, "Norm has gone through about
75 [Army Guard] sites in the state,
many with some sort of heating oil
leak, and set up a priority system for
the worst spills with the most risk to
the environment—specifically our
tundra and permafrost ecosystems.
Then he's worked hard to deal with
the high costs and logistical hurdles
we face up here by piggy-backing
cleanup operations and equipment
wherever possible."
And Oh What Hurdles!
"The pool of knowledgeable contrac-
tors and the pool of equipment are
very limited," notes Straub. And
there is competition among agencies
and private companies for those
resources. Assuming you can find the
right equipment, getting it onto a site
is another challenge. Except in south-
eastern Alaska, there are virtually no
roads to villages. The way in and out
is by boat or by plane. Both trans-
8~
portation modes are routinely ham-
pered by bad weather. Many remote
villages only get barge deliveries in
the three months of summer—they
are ice-locked the rest of the year. Air
transport is the most reliable, but
expensive.
Now add the sensitivity of the
tundra ecosystem. Contrary to what
you might think, you don't want to
work in the warm season. Heavy
equipment would damage the tun-
dra, create dark tire tracks that would
absorb more heat and possibly melt
the underlying permafrost. All mili-
tary training in northern Alaska is
done in the winter, when the ground
is solid...and so is most of the Army
Guard's soil remediation. Contami-
nated soil has to be airlifted or barged
out—usually to Seattle for burning.
(There is one rotary kiln in southeast-
ern Alaska for burning petroleum-
contaminated soil.)
But you can't leave a hole in the
ground or, come summer, it will
cause the aforementioned heat/melt-
ing problems. So Straub has to barge
or airlift in backfill material—another
item that is simply not available in
the villages. Says Straub, "To save
money we try to work it so we use
the same containers that bring in the
backfill material to take out the cont-
aminated soil."
Making the Very Best Use of
Resources
Debra Caillouet gives credit to Straub
for teaming with other agencies, such
as the Air Force and Army Corps of
Engineer ("Corps"), to make the best
use of resources. "If the Air Force or
Corps has a front-end loader or drill
rig going into an area where we have
a cleanup site, we'll use the same
equipment," says Straub adding,
"There will be round-the-clock shifts;
the equipment is too precious to let it
sit idle."
Straub's efforts to coordinate
cleanup activities has helped save
taxpayer money at numerous sites—
for Federal Aviation Administration,
Air force, and Corps as well as the
National Guard. The Alaska Army
National Guard's cleanup efforts
have cost more than $4 million thus
far. Straub's process innovations
resulted in an estimated cost savings
of approximately 10 percent, repre-
senting more than $464,000.
In addition to cleaning up exist-
ing contamination, Straub's office has
pushed overall equipment upgrades
and training improvements. All heat-
ing oil storage tanks are now pump
activated, not gravity-fed, and soldier
training now places an emphasis on
spill prevention rather than cleanup.
All this effort made Norm Straub an
individual winner of both a National
Guard Environmental Security
Award (ESA) and a nominee for an
Army-level award.
"We see environmental steward-
ship as a good investment," says
Captain Nathlon Jackson, who over-
sees the Guard's ESAs. "We can't do
our main job of training soldiers if we
are shut down for environmental vio-
lations. Being proactive saves us time
and money." The awards are a high-
light of the annual National Environ-
mental Workshop (NEW), which
brings together all NGB environmen-
tal managers and specialists for train-
ing and information-sharing sessions.
"We have multiple interests in
our environmental stewardship
efforts," notes Colonel Jerry Walters,
who leads the Guard's overall envi-
ronmental program. "We are
guardians of a lot of land in the U.S.
with valuable natural areas as well as
cultural resources. We have a respon-
sibility to our soldiers, our local com-
munities, and our country to do our
best at both training and protecting
the environment."
-------
February 2007 • LUSTLine Bulletin 54
Diligence in Diesel Cleanup Yields Data on
More Contamination
The Michigan National Guard Adapts Equipment to
Save on Remediation Costs
Camp Grayling, located in cen-
tral northern Michigan, is the
largest military installation
east of the Mississippi River. Its
147,000 acres also make it the nation's
largest National Guard training site.
The Camp is used year-round for
training not only by the Guard, but
also active and reserve components
of the Army, Navy, Air Force, and
Marine Corps. This includes tank
maneuvers and small arms, mortar,
tank, artillery, and multiple launch
rocket system firings. Helicopter/
helicopter door gunnery and anti-
armor gunneries as well as fixed-
wing aircraft air-to-ground
munitions drops of up to 500 pounds
are also conducted on the installa-
tion. All of this activity takes fuel.
In 1988, the rupture of a diesel-
fuel line from three 50,000 gallon
tanks at a bulk-fuel storage facility
caused a plume of polluted ground-
water near the Camp's airfield. Camp
Grayling's Environmental Manager,
John Hunt, a geologist, and the
Guard's Environmental Compliance
Specialist, Gary Hoffmaster, brought
in a skilled contractor, MACTEC, to
design a bioremediation system.
Peter Neithercut, the MACTEC
project leader, installed two above-
ground tanks for in situ bioremedia-
tion. Contaminated groundwater
was pumped up, run through the
tanks with a combination of fertilizer
and bacteria culture to digest the
hydrocarbons from the spill, and
then reinjected upgradient. Petro-
leum, oils, and lubricant spills (POLs)
are common on installations, and the
Army has developed a special envi-
ronmental center to address such
issues. (See: http://aec.army.mil/usaec/
technology/deanupOSa.html)
According to John Hunt, the sys-
tem is closed-loop and similar to
wastewater treatment. He says this
form of remediation is a proven tech-
nique with no negative impacts to the
environment. "The plume flows
downgradient. By pumping from the
downgradient end into the 'treat-
ment system,' then reinjecting back
upgradient we're controlling the
FIGURE 1
movement of the contaminated water
and recirculating it through the sys-
tem until it's clean," explains Hunt.
Uh-Oh!
After four years of running this sys-
tem Camp Grayling's environmental
team thought they had cleaned up
the site. Hydrocarbon tests detected
no contamination, and tests for ben-
zene, toluene, ethyl benzene and
xylene (BTEX), the volatile compo-
nents commonly associated with
petroleum products, also came up
clean. "We thought we had it all
clean," says Gary Hoffmaster, "then
the state agency requested
that we do a full volatile
sample for chlorinated sol-
vents." Those tests re-
sulted in some bad news—
350 parts per billion (ppb)
of perchloroethylene (PCE)
—an "acceptable" level is 5
ppb in groundwater. The
tests also showed some de-
graded trichloroethylene
(TCE). Both are neurotox-
ins and in high doses can
cause cancer.
They knew these con-
taminants had to be from
another source—PCE and
TCE are solvents used for
metal degreasing; PCE,
often called "Perc," is also
commonly used in dry
cleaning. The discovery
led to a new site investigation. Gary
Huntington, the National Guard
Bureau's Environmental Manager for
the entire state of Michigan, points
out that in addition to running soil
probes on a 100-acre grid to identify
the sources and extent of the contam-
ination, they also talked to some old-
timers to figure out what had gone
on there in the past.
"We found out that back in the
1960s and into the 1980s the area had
been used to clean artillery tanks, like
the Abrams Ml," says Huntington.
"The guys would swab out the gun
barrels with solvents, using a five-
gallon bucket, and dump any extra
on the ground." Needless to say,
there was extensive contamination.
"The key was finding where it was
coming from," says Huntington,
"then we basically reached into our
tool box and came up with some bet-
ter methods to treat it."
Contractor Peter Neithercut
notes that PCE is not handled well by
bioremediation, so they addressed
the solvent sources with carbon
absorption (see Figure 1) and air
sparging. Because the plume had
moved close to the property line,
they added carbon adsorption to con-
trol any migration.
Typical Fixed Bed
Carbon Adsorption System
en
Source: Federal Remediation Technology Roundtable:
http://iviviv.frtr.gou/matrix2/section4/4-47.html
"The Michigan Department of
Environmental Quality was adamant
that we have active containment of
the plume due to risks to nearby resi-
dences with shallow wells," says Nei-
thercut. The system ended up solving
the problem more quickly than they
originally anticipated. "After only
about five years we got the source
areas down to 50 ppb in groundwa-
ter," says Huntington, "Finding the
sources in the soil really helped
knock it out." Camp Grayling's
Army Guard environmental team
expects to meet the 5 ppb cleanup
requirement perhaps as early as 2011.
• continued on page 10
-------
LUSTLine Bulletin 54 • February 2007
m Michigan National Guard
from page 9
The original projections were 2018 to
2020.
Piggybacking for Efficiency
Meanwhile, in May of 1995 another
spill—a mix of diesel and gasoline —
was found in the base's "cantonment
area." This is the base's mini city with
barracks, stores, and offices—a fairly
extensive area with some 700 build-
ings. Near Building #8 the Guard had
six underground tanks, totaling
40,000 gallons of fuel storage. Some-
where in the underground system
they had a leak. The Guard and its
contractor, MACTEC, did a site
investigation, removed the tanks,
and initiated a cleanup. They
replaced the underground system
with two larger aboveground storage
tanks—one for diesel, one for gas.
These new tanks have internal sec-
ondary containment, and all piping is
aboveground so it can be inspected.
MACTEC realized they could
save the Guard money by taking the
in situ bioremediation equipment
used at the airfield diesel spill
(described above) and retrofit it to
treat the new spill. The soils and geo-
logy were different, and there were
slight differences in the POLs. Nei-
thercut points out that, often, when
you use bioreactors you have natural
soil bacteria that help you. But sand
dunes are pretty sterile. So they had
to introduce a different mix of bacte-
ria and nutrients to activate the biore-
mediation. They ran the in situ
bioremediation system for five years
to get to acceptable "criteria" levels.
But, in Michigan, once you think
you're finished —after reaching the
acceptable "residential levels"—you
have to monitor for at least four quar-
ters. "They don't want the numbers
to creep back up," says Neithercut.
By the summer of 2006 they had eight
quarters (a precautionary measure
required by the state) at acceptable
very low levels, so they filed for clo-
sure in September. "The cleanup has
succeeded; you could put a nursery
school here," says Neithercut.
The project was completed under
the Michigan Army National Guard's
Installation Restoration Plan (IRP),
the military term for environmental
cleanups. It was supported by a vari-
ety of state and federal contracting
mechanisms. The Guard estimates
that by adapting and reusing existing
cleanup equipment, the environmen-
tal restoration team saved approxi-
mately $75,000 and reduced the total
cleanup time by about two years.
The four-man team that had the
most to do with the projects was
nominated for an Army Guard Envi-
ronmental Security Award. The team
included Gary Hoffmaster, John
Hunt, Greg Huntington, and contrac-
tor, Peter Neithercut. It is somewhat
unusual for a contractor to be nomi-
nated for a Department of Defense
award. It speaks to MACTEC's suc-
cessful long-term relationship with
the Guard and the Guard's recogni-
tion of the importance of high-quality
contractors in solving environmental
problems.
Camp Grayling continues to be a
major military training site while also
being open to the public in some
areas for recreation, including boat-
ing and fishing. It contains world-
class trout and fly-fishing streams—
clean waters that are being protected
by a conscientious National Guard
environmental team. •
June Taylor is head of Environmental
Communications, working on environ-
mental and human health policy, out-
reach, and education. She can be
reached at: taylorjune@aol.com.
Report on Route 66
Initiative Available on
Region 9's Website
Region 9 has published The Route
66 Partnership: Exploring Cleanup
and Redevelopment Opportunities,
which can be seen at http://www.
epa. go v/region9/waste/bro wn/66/
index.html. The report describes
the efforts of the Arizona Depart-
ment of Environmental Quality, EPA
Region 9, and their partners to revi-
talize the Arizona section of historic
Route 66 by cleaning up and
reusing the numerous old aban-
doned gas stations that plague it.
Others may find this description of
the partnership helpful in organiz-
ing similar aligned-site projects
(e.g., by corridor, riverfront, neigh-
borhood). (See also LUSTLine #54,
"Arizona's Route 66 Initiative Tack-
les Forgotten Gas Stations on a
Highway of History.") •
EPA Issues Final SPCC Rule and Proposes Extending Deadline
In December 2006, U.S. EPA Administrator Stephen L. Johnson signed a final
rule to amend the Spill Prevention, Control, and Countermeasure (SPCC)
rule at 40 CFR part 112. Proposed in December 2005, the final rule amend-
ments, effective February 26, 2007, streamline the requirements for the own-
ers/operators of qualified facilities with aboveground oil storage capacities of
10,000 gallons or less and certain containers and equipment regulated under the
rule.
The amendments include:
• Providing the option for owners and operators of facilities that store
10,000 gallons of oil or less and meet other qualifying criteria to self-certify
their SPCC plans in lieu of review and certification by a professional engi-
neer
• Exempting mobile refuelers that operate solely within a nontransportation
facility (e.g., airports and rail yards) from the sized secondary-
containment requirements for bulk oil storage containers
• Providing an alternative to the general secondary-containment require-
ment without a determination of "impracticability" for facilities that have
particular types of oil-filled equipment
• Extending the SPCC compliance dates indefinitely for farms, until a new
regulation is established.
In a separate rulemaking, EPA is proposing to extend the SPCC compliance
deadline for all facilities (with the exception of farms), including bulk plants,
from October 31, 2007, to July 1, 2009. The SPCC amendments are available at:
www.epa.gov/oilspill/spcc_dec06.htm. •
10
-------
February 2007 • LUSTLine Bulletin 54
The USTs and LUSTs of Biodiesel
Dr. Diesel's Perspicacious Vegetable Oil Prophecy
The concept of using vegetable oil
as a fuel dates back to 1895 when
Dr. Rudolph Diesel developed
the first diesel engine to run on veg-
etable oil. He demonstrated his
engine at the World Exhibition in
Paris in 1990 and described an exper-
iment using peanut oil as fuel in his
engine. In 1911, Rudolph Diesel
stated: "The diesel engine can be fed
with vegetable oils and would help
considerably in the development of
agriculture of the countries which use
it." In 1912, Diesel said "the use of
vegetable oils for engine fuels may
seem insignificant today, but such
fuels may become in the course of
time as important as petroleum and
the coal tar products of the present
time." (1)
Diesel's engine was powered by
peanut oil, though it was not strictly
biodiesel, since it was not transesteri-
fied—conversion of one organic acid
ester into another ester of that same
acid (see below). But Diesel believed
that in time, such oils might be as
important as petroleum-based oils.
Transesterification of a vegetable oil
by Duffy and Patrick in 1853 had
actually preceded the first diesel
engines by several decades. (2)
The primary difference between a
conventional automobile engine and a
diesel engine lies in the way the fuel-air
mixture is ignited. The first requires a
spark plug to create an explosion in the
cylinder. A diesel engine compresses the
mixture in the cylinder until it heats suffi-
ciently to explode on its own. The conven-
tional engine requires a lightweight fuel
distilled from petroleum, whereas a diesel
can run on a heavier derivative made from
crude oil, coal tar, or vegetable oil.
Source: http://www.federalsnstainability.org/initiatives/
biodiesel/biodieseltrg.htm
"The use of vegetable oils for engine
fuels may seem insignificant today.
But such oils may become in the
course of time as important as the
petroleum and coal tar products of the
present time."
Rudolph Diesel, 1912
What Is Biodiesel?
The technical definition of biodiesel
is "a fuel composed of mono-alkyl
esters of long fatty chain acids
derived from vegetable oils or
animal fats, designated as B100,
and meeting the requirements of
ASTM (American Society for
Testing and Materials) D6751
specification." Biodiesel is a clean-
burning, biodegradable, nontoxic
alternative fuel product produced
from renewable resources (animal
fats and plant oils) that can be
blended with petroleum diesel to
create a biodiesel blend (BXX,
where XX represents the percent-
age of biodiesel (i.e., B5 means 5%
biodiesel, 95% petroleum diesel).
Biodiesel is a processed fuel that
can be used readily in diesel-
engine vehicles, which distin-
guishes biodiesel from the
straight vegetable oils (SVO) or
waste vegetable oils (WVO) used
as fuels in some modified diesel
engines. The ASTM biodiesel
blend-stock standard describes
minimum standards for B100
biodiesel properties. The Depart-
ment of Defense has specifica-
tions for B20 blends. A vote on an
ASTM standard for B20 is sched-
uled for December 2006, with
final approval expected by summer
2007. (3) It is important to understand
that even though diesel is part of its
name, pure biodiesel does not con-
tain petroleum diesel or fossil fuel of
any sort.
• continued on page 12
11
-------
LUSTLine Bulletin 54 • February 2007
Biodiesel/rom page 11
How Is Biodiesel Made?
A variety of oils can be used to pro-
duce biodiesel. These include:
• Virgin oil feedstock—rapeseed
and soybean oils are most com-
monly used, though other crops
such as mustard, palm oil, hemp,
jatropha, and even algae show
promise.
• Waste vegetable oil (WVO)
• Animal fats, including tallow,
lard, yellow grease, and a
byproduct from the production
of Omega-3 fatty acids from fish
oil.
Biodiesel is typically produced
by chemically reacting a vegetable oil
or animal fats with an alcohol, such
as ethanol or methanol, in the pres-
ence of a catalyst to yield mono-alkyl
esters and glycerin. Methyl soyate, or
soydiesel, made by reacting
methanol with soybean oil, is the
main form of biodiesel in the United
States. Waste animal fats, used frying
oil, peanuts, cottonseed, sunflower
seed, and canola (a variant of rape-
seed) are also potential feedstocks
that are being investigated as a way
to reduce biodiesel production costs.
Biodiesel is a mixture of fatty
acid methyl esters. Vegetable oils,
which chemically are triglycerides of
fatty acids, are not good biodiesels.
However, the oils can be combined
with methanol in a process known as
transesterification (see Figure 1) to
produce a material with better prop-
erties. The resulting mixture of fatty
acid methyl esters has chemical and
physical properties similar to those of
conventional diesel fuel.
Methanol is the most commonly
used alcohol for biodiesel produc-
tion, because it is the cheapest.
Ethanol can be used to produce an
ethyl-ester biodiesel and higher alco-
hols such as isopropanol and butanol
have also been used. Using alcohols
of higher molecular weights im-
proves the cold-flow properties of the
resulting ester, at the cost of a less
efficient transesterification reaction.
A byproduct of the transesterification
process is the production of glycerol.
A lipid transesterification production
process is used to convert the base oil
to the desired esters. Any free fatty
acids (FFAs) in the base oil are either
converted to soap and removed from
FIGURE 1
- - ••
p r D. en..
I
(t-C-D-CMp
a
Transesterificatjon of
Vegetable Oil to Biodiesel
„.!.
DUftt
OijOt"
riarm ••• nip rnrliii
'*-i •tvrl.'r IxM*
|. . - -
•
HD— Sm
I
I'E-C'l.
,-..--!
Source: http://www.dievron.com/products/prodserv/
fuels/bulletin/diesel/L2_4_8Js.htm
100 pounds of oil + 10 pounds of methanol =
100 pounds of biodiesel = 10 pounds of glycerol
(http://iviviv3.me.iastate.edu/biodiesel/Pages/biodiesell.html).
the process, or they are esterified
(yielding more biodiesel) using an
acid catalyst.
Biodiesel that has met the techni-
cal specifications of ASTM D 6751
ensures that the product has met
standards involving complete reac-
tion, removal of glycerin, removal of
catalyst, removal of alcohol, absence
of FFAs, and low sulfur content.
In Europe, there has been a thriv-
ing biodiesel industry for about 20
years. The fuel there is made from
rapeseed oil; rapeseed is a plant in
the mustard and turnip families. The
European variety of rapeseed is not
grown in the U.S. because of climatic
differences, but the canola variety of
the plant is grown in some parts of
the U.S. Most biodiesel produced in
the U.S. is made from a soybean feed-
stock. (4)
Chemical and Physical
Properties of Biodiesel vis-a-
vis Petroleum Diesel
Biodiesel properties are a direct func-
tion of the carbon chain length and
the proportion of saturated versus
unsaturated fatty acids in the fuel
plus the presence of additives. This
varies depending on the feedstock.
Biodiesel made from feedstocks that
contain highly saturated fatty acids
(e.g., yellow grease, beef tallow,
palm, and coconut oil) tend to exhibit
high cloud and pour points, high
cetane number, and better stability.
Cetane measures the tendency of
diesel to autoignite and is comparable
to the octane number of gasoline.
Higher cetane fuels have shorter igni-
tion-delay periods
than lower cetane
fuels. Fuels with a
cetane number lower
than the engine's min-
imum requirements
can cause rough
engine operation and
may make the engine
more difficult to start.
Biodiesel made from
feedstocks with high
polyunsaturated con-
tent (e.g., soy and sun-
flower) have low
freezing points, lower
cetane numbers, and
poor stability. (5)
In general, bio-
diesel has a higher
cetane number than typical petro-
leum diesel fuel. It also contains 11
percent oxygen by weight. The mini-
mum flash point (a measure of fire
safety) for biodiesel is higher than for
diesel to ensure that any excess alco-
hol used in the manufacturing
process has been removed. The vis-
cosity of biodiesel tends to be higher
than of typical diesel fuel.
Neat biodiesel (i.e., entirely
derived from biological materials) has
good lubricity properties and contains
essentially no sulfur or aromatics in
comparison with petroleum diesel.
One of the problems with ultra-low
sulfur diesel is its low lubricity.
Adding 1 to 2 percent biodiesel to
ultra-low sulfur petroleum diesel can
improve lubricity significantly.
Neat biodiesel has a relatively
high pour point, so it will tend to gel
and/or form crystals more quickly
than petroleum diesel in cold
weather conditions. The temperature
at which pure biodiesel starts to gel
depends upon the mix of esters and,
therefore, the feedstock oil used to
make the biodiesel. Biodiesel pro-
duced from canola oil starts to gel at
approximately -10°C, while biodiesel
produced from tallow tends to gel at
approximately +16°C.
A limited number of additives
are available that will reduce the gel
point of straight biodiesel. The addi-
tives reduce the tendency for the vis-
cosity to increase as biodiesel is
cooled and prevent cold temperature
crystallization. For cold-weather use,
biodiesel can also be blended with
other fuel oil, such as #2 low sulfur
diesel and #1 diesel/kerosene. (2)
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February 2007 • LUSTLine Bulletin 54
Biodiesel is hydrophilic. Water
can be a residual from processing, or
may come from condensation in stor-
age tanks. Water can reduce the heat
of combustion of the fuel, which can
result in smoking, less power, and
difficulty starting engines. Water can
also result in corrosion of fuel-system
components and accelerated micro-
bial growth, which can clog up fuel
filters. Biodiesel that is stored in
heated tanks can have microbial
problems. Water in the fuel can cause
ice crystals to form and accelerate
gelling of the fuel.
Due to the enhanced solvency
characteristic associated with methyl
esters, neat biodiesel has a tendency
to dissolve accumulated sediments in
diesel storage and engine fuel tanks.
This can result in clogged or burst
fuel filters. While the problem is
more common in higher percentage
blends of biodiesel, it may also hap-
pen with B20 and lower blends, par-
ticularly with vehicles that haven't
been exposed to the product before.
Minnesota has a biodiesel man-
date that took effect in September
2005. The mandate was suspended
three times during the first winter as
officials investigated problems
involving clogged fuel filters. Testing
revealed a variety of production,
storage, and delivery problems,
including fuel with concentrations as
high as 50 percent biodiesel that was
sold as B20, and excessive levels of
glycerin in the fuel that gelled in the
cold weather. (6)
Toxicity of Biodiesel Fuels
Biodiesel is the first alternative fuel to
have successfully completed the Tier I
and Tier II Health Effects Testing
requirements of Section 211(b) of the
Clean Air Act Amendments of 1990.
The first tier of health effects testing
was conducted by the Southwest
Research Institute and involved a
detailed analysis of biodiesel emis-
sions. Tier II was conducted by the
Lovelace Respiratory Research Insti-
tute, where a 90-day subchronic study
of biodiesel exhaust with specific
health assessments was completed.
Results of the testing concluded that
biodiesel is nontoxic and biodegrad-
able, posing no threat to human
health. Please note that Section 211
testing is based on exposure by
inhalation of biodiesel exhaust.
FIGURE 2
Comparing biodiesel emissions
to petroleum diesel emissions, the
findings include:
• The ozone (smog) forming
potential of hydrocarbon exhaust
emissions from biodiesel is 50
percent lower.
• The exhaust emissions of carbon
monoxide (which contributes to
the formation of smog and
ozone) are 50 percent lower.
• The exhaust emissions of particu-
late matter from biodiesel are 30
percent lower.
• The exhaust
emissions of
sulfur oxides
and sulfates
(contributors to
acid rain) from
biodiesel are
totally elimi-
nated.
• The exhaust
emissions of
hydrocarbons
(a contributing
factor to local-
ized formation
of smog and
ozone) are 95
percent lower.
• The exhaust emissions of aro-
matic compounds known as
PAH and NPAH compounds
(suspected carcinogens) are sub-
stantially reduced for biodiesel
compared to diesel. Most PAHs
were reduced by 75 to 85 percent.
All NPAHs were reduced by at
least 90 percent. (7)
Toxicity testing with rats, albino
rabbits, daphnia magna, and rainbow
trout has shown that biodiesel is con-
siderably less toxic than diesel fuel
but that one should still avoid ingest-
ing biodiesel or getting it on the skin.
(8)
Air Emissions
A U.S. EPA assessment showed that,
generally, increasing biodiesel-blend
concentration reduces HC, CO, and
particulate matter (PM) emissions,
but increases NOx emissions. (9) Lit-
tle information is available on emis-
sion characteristics of newer vehicles
equipped for lower particulates. The
chemical composition of the feed-
stock directly impacts the properties
of the fuel and, consequently, the
emissions associated with its use.
The EPA study discovered that
biodiesel impacts on emissions var-
ied depending on the type of
biodiesel (e.g., soybean, rapeseed,
animal fats) and on the type of con-
ventional diesel to which the
biodiesel was added. Biodiesel made
from feedstocks that contain higher
levels of unsaturated fatty acid chains
(e.g., soy, canola) tend to produce
higher NOx emissions than more sat-
urated feedstock materials (e.g., tal-
low). (10) (See Figure 2.)
Feedstock Type and NOx Emissions
Source:
http://www.federalsitstaimiUlity.org/initiatives/biodiesel/biodieseltrg.htm
TABLE 1
Tailpipe Emissions Percentage
Difference: Biodiesel Compared
to Petroleum Diesel
Total PM
HC
CO
NOx
SOx
n-PAH
PAH - range
PAH -average
B20
-6%
-19%
-10%
3%
-20%
-18%
-10% to -17%
-13%
B100
-30%
-95%
-50%
13%
-100%
-90%
-50% to -85%
-80%
Source: National Biodiesel Board / USEPA Tier 1
Health and Environmental Effects Testing for
Biofuels," Final Report, March 1998.
http://www.federalsustainability.org/initiatives/
biodiesel/biodiesel trg. htm
An EPA study comparing
exhaust emissions of conventional
diesel and biodiesel was not able to
identify an unambiguous difference
in exhaust CO2 emissions between
• continued on page 14
13
-------
LUSTLine Bulletin 54 • February 2007
Biodiesel/rom page 13
the two fuels. The CO2 benefits attrib-
uted to biodiesel are the result of the
renewability of the biodiesel itself, not
the comparative exhaust CO2 emis-
sions. (11) A study by the Department
of Energy found that biodiesel pro-
duction and use, in comparison with
petroleum biodiesel, produces 78 per-
cent less CO2 emissions. (12)
FIGURES
Average Emission Impacts of Biodiesel
for Heavy-Duty Highway Engines
rm-
Jll
Source: http://www.epa.gov/otaq/models/analysis/biodsl/p0200'L.pdf
Note: These data are for heavy-duty highway engines, which may or may
not correlate to the emissions from nonroad engines or light-duty vehicles.
A recent development involving
air emissions is a Texas Commission
on Environmental Quality (TCEQ)
decision to effectively ban biodiesel
in the state's largest markets. Accord-
ing to the TCEQ, biodiesel does not
meet stricter NOx standards recently
imposed on diesel and alternative
fuels for the state's 110 smoggiest
counties. The problem revolves
around a 2002 U.S. EPA study that
found that B20 blends emit 2 percent
more NOx emissions than the state
standard. A National Renewable
Energy Lab (NREL) study indicated
that biodiesel appears to cause no
change in NOx emissions. For now,
the ban is scheduled to take effect on
December 31,2006. (13)
BTU Differences
The energy content of neat biodiesel
is 8 percent lower (on a gallon basis)
compared with typical petroleum-
derived #2 diesel, so some reduction
in fuel economy and power can be
expected with fuels containing
biodiesel. Biodiesel is predicted to
reduce fuel economy by 1 to 2 per-
cent for a 20-volume percent bio-
diesel blend. Users of B20 or lower
blends in fleet demonstration tests
generally report little noticeable
reduction in vehicle performance and
fuel economy. (14)
Compatibility with
Vehicle Engines
Concerns have
been raised regard-
ing the impact of
biodiesel blends on
fuel-system com-
ponent durability.
Research has gener-
ally shown that B5
blends are compati-
ble with materials
and components
tested. Highly oxi-
dized B20 blends
may cause oper-
ability problems.
The lack of a con-
sensus on an
acceptable specifi-
cation for oxidation
has reportedly been
a major stumbling
block in the devel-
opment of an
ASTM standard for
finished blends of B20. Some manu-
facturers are approving the use of
blends up to B20 in fleet vehicles,
provided that the fuel meets U.S. mil-
itary specifications, which require
that the biodiesel fuel be used within
six months of production to alleviate
stability concerns.
The "World-Wide Fuel Charter"
published by automobile manufac-
turers recommends against use of
diesel fuel containing greater than 5
percent biodiesel by volume. This is
based on concerns that vegetable-
derived biodiesel has:
• High viscosity at low tempera-
tures
• A hygroscopic tendency and con-
sequent risk of corrosion due to
high water content
• Potential compatibility issues
associated with seals and com-
posite materials of fuel systems
in existing vehicles.
B100 may degrade some hoses,
gaskets, seals, elastomers, glues, and
plastics with prolonged exposure.
Natural or nitrile rubber compounds,
polypropylene, polyvinyl, and Tygon
materials are particularly vulnerable.
Most elastomers used after 1993 are
compatible with B100 (Viton/Teflon).
Teflon, Viton, and Nylon may be
used to update incompatible equip-
ment. (15) The same issues go for
metals as described in the section
below on storage compatibility.
Biodiesel is a better solvent than
petrodiesel and can break down
deposits of residue in the fuel lines of
vehicles that have previously run on
petrodiesel. Fuel filters may become
clogged with particulates if a quick
transition to pure biodiesel in made,
because biodiesel "cleans" the engine
in the process. Therefore, it is recom-
mended that the fuel filter be
changed within 600 to 800 miles after
first switching to a biodiesel blend.
(6)
Compatibility with Fuel
Storage Systems
The Petroleum Equipment Institute
has a new website with an online
database of ethanol- and biodiesel-
compatible equipment. Manufactur-
ers are responsible for providing lists
of equipment, the particular fuels
with which the equipment is compat-
ible, and the verification process used
to prove that the equipment is com-
patible with those fuels. For
biodiesel, B5, B20, and B100 blends
are included, (http://www.pei.org/
altfuels/ByFuel.asp)
Many of the same compatibility
issues apply to biodiesel as applied
for ethanol blends. Biodiesel can act
as a solvent in tanks, which may lead
to clogged or burst filters. The great-
est effect is shown at the higher levels
of biodiesel. The same issues apply
for gaskets, seals, and so on, as stated
in the section above.
Most tanks designed to store
diesel fuel will be adequate for stor-
ing B100. Acceptable storage tank
materials include aluminum, steel,
fluorinated polyethylene, fluorinated
polypropylene, Teflon, and most
fiberglasses.
Brass, bronze, copper, lead, tin,
and zinc may accelerate the oxidation
process of biodiesel, creating fuel
insolubles, or gels and salts. Lead sol-
ders and zinc linings should be
avoided, as should be copper pipes,
brass regulators, and copper fittings.
-------
February 2007 • LUSTLine Bulletin 54
Affected equipment should be
replaced with stainless steel, carbon
steel, or aluminum.
Biodiesel blends of 20 percent or
less reduce the impact of metal com-
patibility issues and should have a
lesser effect on other materials as
well. When handling blends of B20 or
less, normal monitoring of hoses and
gaskets for leaks should be sufficient.
With low-level blends such as B2,
effects are virtually nonexistent. (16)
Biodegradation
There is little published information
on the biodegradability of biodiesel.
Researchers at the University of
Idaho conducted studies in the mid-
1990s using neat oil and biodiesel
from a variety of feedstocks, includ-
ing soy, canola, and rapeseed. Both
methyl and ethyl esters were
included. Number 2 diesel was used
as a comparison in all the studies.
Various blends, from 100 percent #2
diesel to 100 percent methyl ester and
100 percent ethyl ester were studied
in the laboratory for biodegradabil-
ity, both in soils and aquatic environ-
ments.
Two main methods were used
for determining rate and degree of
biodegradation. One method in-
volved measuring the generation of
CO2 as evidence for biodegradation.
The other method involved analysis
of samples by gas chromatograph to
determine biodegradation. Results
showed that all of the biodiesel fuels
were readily biodegradable in both
soil and aquatic environments. (9)
Predictions of biodegradability are
based on laboratory studies. Results
in the field may not be as rapid.
Tests sponsored by the Depart-
ment of Agriculture found that
biodiesel is "ten times less toxic than
table salt and biodegrades as fast as
dextrose (a test sugar)," and that
biodiesel degrades about four times
faster than petroleum diesel. (17)
A study by Speidel and Ahmed
(18) examined the aerobic biodegra-
dation potential of a number of alter-
native fuels. The ranking of
biodegradation potential, from high-
est to lowest, was: E85, biodiesel
(B100), B20, E-10, gasoline, and diesel.
Net Energy Content/Lifecycle
Energy Balance
A Department of Energy study con-
cluded that for every unit of fossil
energy used in the production of soy-
based biodiesel, 3.2 units of energy
are gained when the fuel is burned.
(19) Pimentel and Patzek found that
the energy balance is negative—
energy input for production was 2
percent higher than energy contained
in the fuel. (20) Other studies, such as
a UC Davis report (21) and an
Argonne National Laboratory Report
(22), calculated positive energy bal-
ances of +133% and +236%, respec-
tively. There are significant
differences in assumptions, data, def-
initions, and methodologies among
the various studies.
A recent paper in Proceedings of
the National Academy of Sciences of the
United States of America (23) on the
environmental, economic, and ener-
getic costs and benefits of biodiesel
and ethanol biofuels stated that
biodiesel yields 93 percent more
energy than the energy invested in its
production, whereas ethanol yields
25 percent more. Compared with
ethanol, biodiesel yields just 1.0 per-
cent, 8.3 percent, and 13 percent of
the agricultural nitrogen, phospho-
rus, and pesticide pollutants, respec-
tively, per net energy gain. Relative
to the fossil fuels that they displace,
greenhouse gas emissions are
reduced by 12 percent by the produc-
tion and combustion of ethanol and
41 percent by biodiesel. However,
even dedicating all U.S. corn and soy-
bean production to biofuels would
meet only 12 percent of gasoline
demand and 6 percent of diesel
demand.
The debate over the energy bal-
ance of biodiesel is ongoing. The
degree to which vegetable-based
biodiesel can displace petroleum
fuels is limited by both the availabil-
ity of cropland that provides the veg-
etable source and by the availability
of higher-value options for the use of
the biodiesel feedstock inputs. Using
traditional plants, most nations do
not have sufficient arable land to pro-
duce biofuel for the nation's vehicles.
One study published by the Soci-
ety of Automotive Engineers (24)
showed that devoting all the avail-
able land in Europe to produce the
rape seed methyl ester-based
biodiesel would reduce crude oil
demand by less than 3 percent. DOE
projections show that if all existing
and future feedstocks were devoted
to domestic biodiesel production,
only about 7 percent of the on-road
diesel demand could be met near-
term (2015). (25)
How Much Biodiesel Can We
Produce?
The feasibility of ramping up produc-
tion to the huge levels required to
power a significant percentage of
national or world vehicles depends
on feedstock yield efficiency. The
highest-yield feedstock is algae,
which can produce 250 times the
amount per acre as soybeans.
Feedstock US Gallons/Acre
Soybeans
Rapeseed
Mustard
Jatropha
Palm Oil
Algae
40
110
140
175
650
10,000
Source: http://www.answers.com/topic/biodiesel
In 2003, 73.4 million acres of soy-
beans were harvested in the U.S. Soy-
bean yield is normally between 35
and 40 bushels per acre. If all of the
soybeans in the U.S. were used to
produce biodiesel, the yield would be
about 2,936 million gallons. (26)
As of September 2006, there were
86 commercial biodiesel plants oper-
ating in the U.S., with an annual pro-
duction capacity of 580.5 million
gallons (These facilities are not neces-
sarily producing at capacity). Many
additional facilities are under con-
struction or expanding their capaci-
ties.
According to the National
Biodiesel Board, estimated U.S.
biodiesel production was 75 million
gallons in 2005. At 75 million gallons,
current domestic biodiesel produc-
tion constitutes less than 0.2 percent
of on-road diesel demand. With a
prediction of 30 percent growth in
total highway diesel demand, the
U.S. Department of Energy projects
that domestic biodiesel production
will meet no more than 7 percent of
on-road diesel consumption. (11)
State and Federal Activity,
Incentives, and Regulations
The National Biodiesel Board has
compiled highlights of state legisla-
tive activity concerning biodiesel
• continued on page 16
-------
LUSTLine Bulletin 54 • February 2007
m Biodiesel/rom page 15
passed through September 2006. This
legislation includes incentives, use
requirements, point of taxation clari-
fication, authorization of studies,
state fleet use requirements, and
biodiesel promotion. (27) For exam-
ple, recently-passed New York legis-
lation included:
• A biofuel production tax credit of
15 cents per gallon after the first
40,000 gallons produced
• Elimination of all motor fuel
taxes on alternative fuels
• Cost-share infrastructure grants
for private-sector gas stations to
install and/or convert pumps for
B20 or E85
• A residential BioHeat fuel tax
credit in residential heating
applications
• Illegality of contracts prohibiting
renewable fuels. (11)
Proposed regulations imple-
menting the Renewable Fuels Stan-
dard of EPACT 2005, which requires
an increase in the amount of renew-
able fuel (including ethanol and
biodiesel) used in the U.S. to 7.5 bil-
lion gallons by the year 2012, would
give refiners and other covered enti-
ties that blend biodiesel 1.5 times the
base RFS credit. The adjusted credit is
due to the high energy content of
biodiesel. (28) Additional informa-
tion about the legal requirements and
incentives for federal agencies to use
biodiesel can be found at
http://www.federalsustainability.org/ini-
tiatives/biodiesel/biodieseltrg.htm.
Availability of Diesel-
Powered Vehicles
While biodiesel is a relative new-
comer to the U.S., in Europe it has
had widespread acceptance as a vehi-
cle fuel (as well as a heating fuel in
some countries) due to deliberate
government tax policies that favor its
use. In Germany, diesel engines
power close to 40 percent of passen-
ger cars, and there are more than 188
filling stations offering biodiesel at a
price competitive with that of regular
diesel due to large tax breaks and
subsidies for alternative fuels. Ger-
many, France, and Italy combined
16
produce nearly 18 times more
biodiesel than the entire U.S. (29)
A number of vehicle manufactur-
ers make cargo vans or trucks that
use diesel fuel, but only a few cars or
SUVs are currently being produced
that are diesel-powered. These
include certain Hummers, Jeep Lib-
erty, two Mercedes-Benz models, and
some models of Volkswagen Golf,
Jetta, Beetle, and Touareg. Informa-
tion is available from Ford and
Volkswagen on their websites (30),
which states that fuels containing up
to 5 percent biodiesel can be used in
their engines.
Ten percent of Volkswagen sales
in North America are now diesels,
and 25 percent of Jettas come with a
diesel engine. Ford specifically men-
tions the World-Wide Fuel Charter
recommendation and provides a list
of unresolved technical concerns
with using biodiesel concentrations
higher than 5 percent. Every new
diesel-powered Jeep Liberty made in
Toledo, Ohio, is currently being
shipped with B5 in its fuel tank,
sourced from soybeans grown and
refined in Ohio.
DaimlerChrysler currently sanc-
tions the use of B20 in its 2007 Dodge
Ram 2500 and 3500 diesel pickups for
its military, government, and com-
mercial fleet customers only—and
only if they use B20, which meets
military specifications. (31) Mer-
cedes-Benz states that their diesel
engines are "not engineered for bio-
diesel. Based on its design, the vehi-
cle can, nonetheless, accept diesel
fuel with a maximum 5 percent
Biodiesel content. Any concentration
higher than 5 percent will result in
fuel system component damage,
which would not be covered under
the Manufacturers New Vehicle Lim-
ited Warranty." (Personal communi-
cation, 12/1/06, from Mark S.,
Customer Relations, Mercedes-Benz
USA LLC.) It is thought that more
automakers will endorse the use of
B20 when the ASTM B20 is standard-
ized.
Cost Differences
Biodiesel generally costs more to
manufacture than conventional
petroleum diesel. The feedstock cost
of the oil or grease used to make
biodiesel is the largest component of
its production cost. It takes 7.3
pounds of soybean oil, which costs 21
to 24 cents per pound, to produce a
gallon of biodiesel. Feedstock costs
alone, therefore, are at least $1.50 per
gallon of soy product. Fats and
greases cost less and produce less
expensive biodiesel, but their supply
is more limited and localized.
In March 2006, the before-tax
national average price of B100 was
$3.05/gallon; $2.14 per gallon for
B20; and $1.93/gallon for B2. In com-
parison, #2 diesel fuel cost was
$1.91/gallon. If you compared the
energy content of the various fuels,
the difference in costs would be even
greater because of the lower energy
content of neat biodiesel and of
biodiesel blends relative to #2 diesel.
(11)
Contributing to the higher costs
for biodiesel are increased costs for
blending, climatic and marketing
considerations, storage differences,
and the possible requirement to heat
the fuel in storage during winter
months to prevent gelling.
If You Build It, Will They
Come? If You Sell It, Will
They Buy It?
Delaware recently entered the
biodiesel-refining business with the
opening of the Mid-Atlantic Biodiesel
Company, LLC in Clayton,
Delaware, in August 2006. The plant
started up using soy oil as feedstock,
but it can handle both virgin and
used vegetable oils, and production
could grow from 6 million
gallons/year to about 15 million gal-
lons/year. Two-thirds of Delaware
farmers grow soybeans.
The plant purchased soybean oil,
rather than crushing it in-house. Offi-
cials are looking at opportunities to
develop additional local processing
capability to support the plant. Mid-
Atlantic has contracts with whole-
salers for the plant's output. The plant
received more than $5.7 million in
state and federal assistance through
grants and loan guarantees. (32)
In a recent series of legislative
hearings in Delaware concerned with
establishing retail E85 dispensing
facilities, one of the witnesses, Mark
Greco, described his experiences with
B20 sales. His company owns the
only three facilities in the state to
offer B20 soy diesel to the public. The
• continued on page 27
-------
February 2007 • LUSTLine Bulletin 54
A MESSAGE FROM CLIFF ROTHENSTEIN
Director, U.S. EPA Office of Underground Storage Tanks
The 2006 Finish Li
L
ooking back on
2006—at what we
^ -^^r\ I Jha^o accomplished
j^ in such a short time—it's
truly remarkable. All of
JA our partners nationwide
who contributed to the
ft J program's success should
feel a sense of great satis-
faction knowing that so much has been achieved. The pas-
sage of the Energy Policy Act of 2005 gave EPA and states
new tools designed to prevent releases from UST systems.
We had to redouble our efforts to implement the new pro-
visions and deadlines laid out in the law. Over this past
year, we developed a number of guidelines and strategies
to help implement the provisions. Some of what we've
accomplished includes publishing a new tribal strategy
and issuing guidelines for delivery prohibition and sec-
ondary containment.
Exceeding Our Goals
Many thanks to our regional and state partners for help-
ing us continue to make progress in cleaning up releases
from UST systems. With your diligence and hard work
the tanks program is moving forward and has exceeded
our goals for the 2006 fiscal year in almost every area. Last
year (FY 2006) we:
• Completed 14,493 cleanups—exceeding our national
goal by 893
Completed 43 cleanups in Indian Country-
ing our national goal by 13
sxceed-
• Reported 1,639 releases, well below our historical
average.
Nearly every year we have exceeded most of our
national goals, which has greatly contributed to the long-
term success of the UST program. Since the beginning of
the program, we have cleaned up almost 75 percent of
350,813 reported releases.
I am pleased to say that in FY 2006, the Office of Man-
agement and Budget rated the UST program as one of the
federal government's most successful programs. Without
the hard work of our partners we would not have
achieved this distinction.
We have also continued to make progress in bringing
tank owners into compliance. Last year, 62 percent of all
facilities were operating their UST systems properly.
Although we fell slightly below our goal, this shortfall
may be somewhat misleading. Some states are now tar-
geting their inspections at previously uninspected facili-
ties that are more likely to be out of compliance. Once all
of the states are on their three-year inspection cycle, as the
new Energy Policy Act requires, we expect compliance
rates to improve.
And Now for 2007...
Judging by the amount of work ahead, 2007 promises to
be just as fast-paced as 2006.
The New Year is barely under way and we have
already issued two new grant guidelines for states:
• Financial responsibility and installer certification
• Public record.
We also issued, for public comment, draft grant
guidelines for the state compliance report on govern-
ment USTs. We expect to finalize those guidelines this
spring. We also plan to issue draft inspection grant
guidelines for public comment in the spring; the final
guidelines will be available this summer.
The final and draft grant guidelines along with addi-
tional program information are available at: http://
www.epa.gov/oust.
And finally, this August, we will submit our Tribal
Report to Congress, focusing on the tanks program in
Indian Country.
State and Tribal Partners
Recognizing the resource and timing challenges under
the Energy Policy Act, we are also working closely with
our state and tribal partners to help ensure that the new
requirements are successfully carried out. As a commit-
ment to our partnership, we worked with Association of
State and Territorial Solid Waste Management Officials
(ASTWMO) to help ensure state participation in our
working groups, including our efforts to develop grant
guidelines. Flexibility is built into the guidelines for
states that demonstrate good faith in meeting program
requirements. We are looking for an approach to the pro-
gram that is tailored to the specific needs of the state—
not a "one-size-fits-all" formula.
We look forward to continuing to work with our
partners in Indian Country to strengthen the tribal UST
programs. While we cannot approve tribal programs, we
have worked very hard to fully integrate the tribes into
the UST program. At our national conference this March
in San Antonio, we will hold tribal sessions to continue
our dialogue on key issues. And, we will continue to
work with tribal governments throughout the year to
focus on UST/LUST issues in Indian Country.
Beyond the Energy Policy Act—Program
Priorities and Goals
In addition to the new requirements under the Energy
Policy Act, the UST program aims to achieve several
additional goals, which include cleaning up 13,000 con-
firmed releases next year and gaining a better under-
standing of the backlog of sites yet to be cleaned up.
Other key priorities for FY 2007 will be: increasing facil-
ity inspections, improving compliance, and minimizing
• continued on page 20
17
-------
LUSTLine Bulletin 54 • February 2007
TRflHX
TRIBAL LRI1DX
The Gila River Indian Community and
U.S. EPA Team Up to Activate Corrective
Action at a Former Trading Post
by Chris Prokop
On September 7, 2006, the Gila
River Indian Community
(GRIC) and the U.S. Environ-
mental Protection Agency (EPA) acti-
vated a cleanup system for
addressing hydrocarbon-contami-
nated soil at the Arizona Traders
LUST site. The soil-vapor extraction
(SVE) cleanup system consists of a
vacuum pump, piping, and SVE
wells to remove hydrocarbon vapors
from the soil. The system also
includes treatment for the extracted
soil vapor. The GRIC and EPA chose
this remedial approach in order to
address hydrocarbon contamination
in the soil caused by gasoline leaks
from two USTs used from 1963 until
1985 at the former Arizona Traders
Trading Post.
Although activating the cleanup
system was relatively simple, the sup-
port work provided by members of
the GRIC and EPA for almost four
years prior to this step was anything
but simple. During this period, the
GRIC and EPA worked closely during
two phases of site characterization, an
SVE pilot study, a feasibility study for
evaluating various potential remedial
alternatives, and final approval of the
remedial plan for the site. At the end
of what is expected to be a three-year
remedial period, the land will be
restored for productive reuse.
The Arizona Traders
LUST Site
The Arizona Traders Trading Post
was in operation for more that 20
years in Sacaton, Arizona, a town
located about 30 miles southeast of
Phoenix on the GRIC. The trading
post provided essential commercial
goods for the residents of Sacaton
and fuel for their automobiles. It also
met some of the social needs of the
community.
After 1985, the trading post build-
ing fell into disrepair, was vandal-
ized, and ultimately burned down in
1994. The only features of the trading
post remaining after the fire were the
concrete foundation and a section of
the adobe wall at the rear of the build-
ing. Despite its location in the central
part of Sacaton, the property was not
an attractive redevelopment prospect
due to the presence of buried USTs. In
addition to the redevelopment issue,
it was unknown if there was any soil
and/or ground water contamination
from the UST system.
Residual hydrocarbon contamina-
tion of soil and groundwater was doc-
umented when GRIC's Department of
Environmental Quality (GRIC-DEQ)
removed the two USTs in 1998. This
contamination, the result of many
years of gasoline leaks from the USTs
and piping, had gradually migrated
through the soil to the underlying
groundwater, currently about 80 feet
below ground surface. Following the
UST removals, discussions began
between GRIC-DEQ and EPA on the
best approach for addressing the cont-
amination at the site. These discus-
sions led to an innovative approach to
funding the cleanup.
Determining Eligibility for the
Federal LUST Trust Fund
Following the discussions between
GRIC-DEQ and EPA, EPA began the
process of determining the eligibility
of the Arizona Traders site for fund-
ing under the federal LUST Trust
Fund for conducting a site assess-
ment and, potentially, corrective
action. During this process, EPA
obtained financial records from the
UST owner/operator, who lives in
the community, and then conducted
an evaluation of the former opera-
tor's ability to pay for the site assess-
ment and remedial work.
The evaluation indicated that the
Arizona Traders site appeared eligi-
ble for funding under the LUST Trust
Fund, and EPA Region 9 presented
its findings to EPA headquarters.
When EPA headquarters subse-
quently approved this request, the
Arizona Traders site became the first
federally funded, EPA-lead, LUST
cleanup project in Region 9.
...And Then Came the
Statement of Work
Following EPA's approval to spend
federal LUST Trust Fund money at
the Arizona Traders site, there was
still a lot of work to be done to get the
site assessment and corrective action
off the ground. GRIC-DEQ and EPA
worked closely on developing a
statement of work (SOW) for site
assessment and corrective action at
the site by EPA's national LUST con-
tractor, Bristol Environmental and
Engineering Services Corporation
(BEESC), a Native American-owned
corporation. Extensive interagency
discussions took place during the
development of the SOW and during
the review of BEESC's work plan for
implementing the site assessment
and corrective action.
The Site Assessment Begins
In April 2002, Phase I site assessment
work began at the Arizona Traders
site. The Phase II site assessment
began in February 2004 and was
completed in May. During these two
phases of site assessment, 20 borings
were drilled, 13 monitoring wells
were installed, and over 100 soil and
groundwater samples were collected
and analyzed. Soil and groundwater
samples were analyzed for volatile
organic compounds (VOCs), total
petroleum hydrocarbons (TPH), and
lead. The four-inch-diameter moni-
toring wells were generally installed
to a depth of about 100 feet, and 40-
foot well screens were used to
address the historical groundwater
fluctuations at the site.
-------
February 2007 • LUSTLine Bulletin 54
The Advantages of Using
State-of-the-Art Technologies
At the direction of GRIC-DEQ and
EPA, BEESC used a number of state-
of-the-art approaches during the site
assessment in order to improve our
understanding of the hydrogeology
and the extent of contamination in
soil and groundwater. These included
the use of a mobile laboratory for
field-based analyses of soil and
groundwater samples, a percussion
hammer drill rig for drilling most of
the borings, a rotary sonic drill rig for
drilling a deep continuously sampled
boring for detailed geologic charac-
terization, and passive diffusion bag
samplers (PDBs) to augment the low-
flow groundwater sampling that was
being conducted with submersible
pumps.
Use of the mobile laboratory
ensured that same-day analyses of
soil and groundwater samples could
be obtained, and that decisions could
be made in the field with regard to
subsequent boring locations and the
placements of monitoring wells. This
avoided the additional downtime
and cost associated with remobiliza-
tion for subsequent phases of site
assessment.
Due to the extensive occurrence
of river gravel deposits at the site, the
conventional hollow-stem auger
drilling that was initially used was
quickly deemed ineffective as a result
of poor subsurface penetration. Per-
cussion hammer drilling was selected
as the drilling method of choice
shortly after the site assessment
began. This drilling technique, which
utilizes a diesel-powered pile ham-
mer to drive double-walled casing
into the ground, had no problem pen-
etrating the cobbley geologic materi-
als at the site. With a percussion
hammer, a boring could be drilled
and a well installed the same day.
A rotary sonic drill rig was also
used for one deep boring at the site in
order to obtain continuous core sam-
ples and precisely define the geologic
units. With the rotary sonic drilling
method, the drill stem and sampler
barrel are vibrated vertically at fre-
quencies between about 50 and 180
Hz (with rotation), and the sampler
barrel generally advances by displac-
ing rather than breaking the cobbles
(as with the percussion hammer).
Although slightly more expensive
than the percussion hammer, the
Margaret R. Cook, Executive Director, GRIC-DEQ; Jennifer Allison-Ray, Lieutenant Governor, |
GRIG; Jeff Scott, Director, Waste Management Division, U.S. EPA Region 9; and Chris Prokop |
gather to activate the Arizona Traders LUST site cleanup system. £
rotary sonic rig gave us the detailed
geologic information necessary to
characterize the site and design a
remedial alternative.
PDBs are low-density polyethyl-
ene bags that are usually suspended
in monitoring wells by polyethylene
ropes. Contaminants in groundwater
are collected by means of chemical
diffusion through the walls of the
PDBs. The PDBs are typically left in
monitoring wells for about two
weeks in order to ensure equilibrium
between the deionized water within
the PDBs and the surrounding
groundwater in the wells.
GRIC-DEQ and EPA decided to
use PDBs in the most contaminated
monitoring well at the site (MW-13)
to provide a second comparative
method for assessing groundwater
contamination and to evaluate the
potential for contaminant stratifica-
tion in the groundwater. The analyti-
cal data from the PDB sampling
showed that hydrocarbon concentra-
tions within the screened interval
fluctuated somewhat with depth. The
PDB analytical data also compared
favorably with the analytical data for
the groundwater sample collected
with a submersible pump at this
same well.
Results of the Site
Assessment
The site assessment confirmed that
soil and groundwater contamination
were present at the Arizona Traders
site. Although a number of hydrocar-
bon compounds were detected above
EPA Region 9's Preliminary Reme-
dial Goals (PRGs) and EPA's Maxi-
mum Contaminant Levels (MCLs),
the primary compound of concern at
the site was benzene, a known
human carcinogen.
The maximum benzene concen-
tration in soil was 16 milligrams per
kilogram (mg/kg), which was 25
times Region 9's 0.64 mg/kg PRG for
benzene in residential settings. This
soil sample was collected from a
depth interval of 25-27 feet below
ground surface. Based on the most
recent groundwater sampling data
for the site from August 2006, the
maximum benzene concentration in
groundwater was 900 micrograms
per liter (ug/1). This concentration
was 180 times EPA's 5 ug/1 MCL for
benzene..
The current depth to groundwa-
ter is approximately 80 feet, and
groundwater generally flows to the
west-northwest under a hydraulic
gradient of approximately 0.002 foot
per foot. A circular area that is about
70 feet in diameter, which includes the
former locations of the USTs, roughly
delineates the benzene contamination
in soil above the benzene PRG. A170 -
feet-long and 80-feet-wide oval area
that also includes the former locations
of the USTs roughly delineates the
benzene contamination in groundwa-
ter above the benzene MCL.
Based on the documented hydro-
carbon impacts to soil and groundwa-
ter at the site and the potential impacts
to human health, GRIC-DEQ and EPA
determined that corrective action was
needed. Although SVE was a proven
technology for addressing benzene
• continued on page 20
-------
LUSTLine Bulletin 54 • February 2007
m Tribal Lands from page 19
and other VOC contamination in
unsaturated soil, GRIC- DEQ and
EPA elected to conduct a pilot study
to assess the likely performance of
SVE at the site.
Pilot Study to Assess SVE
System Performance
The pilot study at the Arizona
Traders LUST site was conducted in
May 2004. The study involved
extracting air from the soil above the
water table by means of a vacuum
pump, piping, and SVE wells; moni-
toring the air flow rates and vacuum
levels in the SVE wells and multiple
observation wells; monitoring the
VOC concentrations within the SVE
system and in ambient air; and treat-
ing the extracted vapors.
Based on the significant recovery
of hydrocarbon mass by these SVE
wells and the acceptable radius of
influence of these wells, GRIC-DEQ
and EPA determined that SVE was
the appropriate remedy for the
hydrocarbon contamination in unsat-
urated soil at the site. GRIC-DEQ and
EPA also agreed that monitored nat-
ural attenuation (MNA) was the
appropriate remedial alternative for
the groundwater contamination at the
site. This decision was based on the
documented stability of the ground-
water plume, direct and indirect
chemical evidence of insitu biodegra-
dation of the dissolved hydrocarbons,
and the fact that the GRIC's drinking
water wells were not threatened by
the groundwater plume.
The MNA cleanup will require
ongoing groundwater monitoring
until the cleanup goals are met. This
monitoring data will be used to assess
the stability of the contaminant plume
in groundwater (i.e., whether the
plume is stable, shrinking, or expand-
ing), and the extent to which naturally
occuring bacteria in the subsurface are
biodegrading the hydrocarbons.
The Corrective Action
Approval Process
Before implementing SVE and MNA
at the site, GRIC-DEQ and EPA
needed the approval of residents of
District 3, the Natural Resources
Standing Committee (NRC), and the
Tribal Council. GRIC-DEQ and EPA
worked closely on developing an
announcement of the proposed rem-
edy for the site that appeared in the
Gila River Indian Newspaper. GRIC-
DEQ then met with the NRC and the
local community to discuss the bene-
fits of implementing SVE and MNA
at the site.
Following the NRC's recommen-
dation to the Tribal Council that SVE
and MNA were the appropriate
remedial measures, EPA met with the
Tribal Council on October 19, 2005, to
determine the Council's reaction to
the proposed remedial alternatives.
The Tribal Council fully supported
implementation of both SVE and
MNA at the site, which cleared the
way for construction and activation
of the SVE system in 2006. Remedia-
tion of the hydrocarbon contamina-
tion in soil with SVE is expected to
take approximately three years, and
remediation of the groundwater cont-
amination with MNA is expected to
take at least 10 years.
Paving the Way
The site assessment and corrective
action process that has been imple-
mented at the Arizona Traders site
illustrates how an effective EPA-
Tribal partnership can achieve a
mutual environmental goal. The
work conducted at the site has been
of a very high standard, and the ulti-
mate outcome of this effort will be a
property restored for beneficial
reuse. Our experience in developing
this solution will help pave the way
for approaching other similar
cleanup situations on tribal lands. It
should be noted that without the full
support of numerous individuals
within the GRIC, this positive out-
come could not have been achieved.
EPA Region 9 looks forward to work-
ing with the GRIC to complete the
remediation at the site. •
Chris Prokop is a hydrogeologist with
the EPA Region 9 UST program. He
can be reached at prokop.chris@epa.gov.
• Message from Cliff Rothenstein/rom page 17
the number of new releases. Also, the need to ensure
equity in compliance and cleanups in Indian Country
will continue to be important for us.
Last, but certainly not least, we will continue our
efforts to revitalize communities for the 21st century by
creating incentives through the petroleum brownfields
program to clean up abandoned gas stations. I will
encourage my staff and regional EPA program offices to
continue to look for opportunities such as our Route 66
initiative. (See LUSTLine #53, "Arizona's Route 66 Initia-
tive Tackles Forgotten Gas Stations on a Highway of
History.") Last autumn, we presented a check to officials
of the City of Flagstaff, Arizona, to help clean up old
abandoned gas station sites along their portion of his-
toric Route 66. This seed money gave a shot in the arm to
a community anxious to clean up an eyesore and begin
fostering revitalization and growth.
I would like to harness the energy and enthusiasm
of Route 66 and showcase what they have created and
market that to the rest of the country. We need every-
one's help to make this happen. We can transform these
forgotten gas station sites, which decades ago were
prime business locations, and help them to regain
prominence within local communities.
Meeting with Our Partners
Finally, we ended the year on a high note with an Asso-
ciation of State and Territorial Solid Waste Management
Officials (ASTSWMO) meeting held in our new Potomac
Yard facilities. There were representatives from nearly
all 50 states, and judging by the positive feedback we
received from the participants, the meeting was not only
productive, but very well received. The topics for discus-
sion included inspections, secondary containment,
financial responsibility, operator training, and other
areas of the Energy Policy Act. Our partnership with
ATSWMO and individual state programs has been very
productive. This meeting worked to further our partner-
ships so that we will be better able to meet the challenges
facing the tanks program in the coming year.
Thank you for your hard work. I look forward to
continuing our success in 2007. •
20
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February 2007 • LUSTLine Bulletin 54
In the (Sort of) Aftermath of MtBE
Are Vapor Leaks Still Relevant?
by Gary Lynn
MtBE levels in New Hampshire gasoline stocks were dramatically
reduced by early May 2006. Groundwater monitoring data is now
available for approximately 100 active gas stations, and there is a
downward trend in MtBE contamination levels in the wells located closest to the
active USTs. This is the first sign of a reversal of the existing trend at New Hamp-
shire sites where MtBE, TBA, and sometimes TAME contamination levels in
groundwater have remained significantly above standards, while BTEX and other
contaminant levels drop. The quick mitigation of MtBE groundwater contamina-
tion near active USTs confirms that the MtBE groundwater contamination was
from ongoing leaks. With the reduction of MtBE in the gasoline supply and improv-
ing groundwater quality data, regulators are faced with the question of whether small
ongoing leaks are still a major concern to our programs.
Since Congress eliminated the oxy-
gen requirement for reformulated
gas (RFC) in May 2006, the New
Hampshire Department of Environ-
mental Services (DBS) has collected a
limited amount of data on gasoline
composition—19 samples. These
samples contained 0 to 11 percent
ethanol, 0 to 0.7 percent MtBE (MtBE
concentrations highest in the pre-
mium grade), 0 to 0.1 percent TBA, 0
to 0.9 percent TAME, and 0 to 1.5 per-
cent ETBE.
Reports on MtBE's demise were
premature, inasmuch as we detected
MtBE in 13 of the 19 samples. The
MtBE content was dramatically
reduced, however, and is likely to
drop further after the implementa-
tion of additional MtBE bans in the
Northeast in 2007. TAME was the
next most commonly present oxy-
genate. ETBE was present in the sum-
mer but not in the late fall 2006
samples.
These results indicate that small
leaks may still merit attention
because MtBE and other ether com-
pounds that behave like MtBE are
still present. All of the ethers are pre-
sent at much lower levels than the
pre-May 2006 MtBE levels. These
results suggest that any problems
that will result from the ethers still
present in gasoline should be no
worse than those at sites where the
gasoline release contained MtBE at
octane-enhancement rather than RFG
levels (a few percent versus over 10
percent).
Based on public water supply
detection trends over time, MtBE
contamination issues were signifi-
cant but much less of a concern
prior to the introduction of RFG into
our state in 1995. However, indoor
air problems resulting from vapor
releases and groundwater contami-
nation from other ether compounds
remain a concern regardless of gaso-
line formulation.
For example, in October 2006,
ongoing research detected a 5 ppm
MtBE plume emanating from a large
vapor release of the lower MtBE con-
tent gasoline. Based on these find-
ings, a better understanding of small
releases is still valuable to help
ensure that future impacts are mini-
mized and/or prevented.
What We Are Learning About
Subsurface Vapor Releases
For subsurface vapor releases to
occur, two elements must be in place.
The tank system must be pressurized
above ambient pressure, and leaks
must be present at pressures below
the pressure relief setting of the vent
cap (3.5 inches of water). DES col-
lected UST-system pressure data
from a total of 13 gasoline service sta-
tions equipped with Stage I and II
vapor recovery systems. All 13 sta-
tions exhibited positive pressure
spikes for approximately 15 to 20
minutes when the tanks received
deliveries of gasoline.
Stage I systems are designed to
return excess pressure to the delivery
Tanks behave badly under pressure.
truck, rather than directly vent the
displaced gasoline vapor to the
atmosphere. Although the systems
work well with respect to minimizing
venting to the atmosphere, the tank
systems build up positive pressures
prior to returning vapors into the
delivery tanker. This accumulation in
pressure can result in subsurface
releases of vapors if leaks in tank-top
features are present.
DES confirmed the presence of
Stage I hardware releases by collect-
ing data at sites with soil vacuum
extraction (SVE) systems with extrac-
tion points installed in or near tank-
system gravel packs. A rise in
influent concentrations was observed
at several of these stations shortly
after delivery. Observed PID read-
ings and SVE flow rates were used to
estimate that about 0.9 pounds of
total mass of VOCs was released dur-
ing one of the deliveries.
Based on DES's data, Stage I
vapor releases are limited to releases
during deliveries and from vapor
growth (pressure that results from
vapor recovery system air ingestion).
The combination of lower post-MtBE
ether concentrations as well as the
lower volatility and higher ground-
water standards for other ethers
(TAME, ETBE, and DIPE), limits the
post-MtBE transition vapor-release
• continued on page 22
21
-------
LUSTLine Bulletin 54 • February 2007
m Aftermath of MtBE/rom page 21
threat to groundwater from stations
solely equipped with Stage I vapor-
recovery equipment.
DBS reviewed the pressure data
for the 13 gas stations and found that
the Stage II vapor recovery systems
routinely resulted in positive pres-
sures in tanks. Although most sys-
tems operated at positive pressures,
in some cases we encountered nega-
tive pressures. Negative pressures
occur because of reductions in air to
liquid ratios (A/L) over time due to
blocked vapor-return lines or reduc-
tions in vacuum-pump efficiencies.
DBS also evaluated available
data on the potential for releases
from Stage II systems. Statistically
higher levels of MtBE groundwater
contamination were observed at sta-
tions with vacuum-assisted vapor
recovery. (See LUSTLine #47, "Track-
ing Troubling Vapor Releases in New
Hampshire"). Vacuum-assisted
vapor recovery is more likely to pres-
surize tanks because these systems
typically operate at A/L > 1; the per-
sistent positive pressures in tanks
with a Stage II system operating at
A/L > 1 result in larger releases than
at a station equipped solely with
Stage I hardware.
Finally, DBS evaluated the extent
of vapor leaks present at operating
facilities. We inspected 21 operating
service stations that were currently in
compliance with UST program rules.
We detected, on average, four leaks
per station. Dry breaks, ATGs,
threaded fittings, and gaskets were
the most common source of leaks
detected.
A Closer Look
DBS decided to conduct additional
research into vapor releases, based
on our findings that conditions are
present for vapor releases to be fre-
quently present at active gas stations.
The research effort was led by the
University of New Hampshire, in
partnership with DBS and a large
independent oil company. (Note: API
and U.S. EPA also provided very
valuable funding and technical assis-
tance.) As part of this research, seven
active gas stations were instru-
mented, and data was collected for
nearly one year. The data collection
included continuous monitoring of
22~
tank temperatures, groundwater lev-
els, tank internal pressure, and
atmospheric pressure. We also con-
ducted weekly monitoring of soil gas
and groundwater quality in the mon-
itoring well closest to the tanks.
The seven stations were divided
into four categories:
• One control site
• Three stations where vapor leaks
were addressed by a variety of
inspection and repair programs
• One station with a low-cost SVE
system and an extraction point in
the gravel pack
• Two stations equipped with
hardware to reduce tank system
pressures (a Healy ORVR com-
patible nozzle system and a VST
pressure management system
similar to ones also produced by
ARID and OPW).
No other changes were made to
the operations of the stations. Data
are still being collected, and the fol-
lowing results and findings may be
modified over time as the data are
fully analyzed.
Preliminary Findings
Four of the sites employed varying
approaches to inspecting tanks and
repairing leaks. The efficacy of these
approaches was examined by review-
ing: the continuous UST-pressure-
monitoring data for new leaks, the
soil-gas data, and groundwater-mon-
itoring trend data. The pressure-
monitoring data indicated that the
leak repairs significantly increased
internal UST pressures; however,
there was no evidence that all of the
existing leaks were located and/or
successfully repaired.
If all leaks had been repaired, the
USTs should have routinely reached
pressures sufficient to crack the pres-
sure-relief valve on the tanks. This
was never observed and is consistent
with the experience of Praxair and
California on the need for tracers and
other advanced leak-detection tech-
nologies to locate all leaks, so they
can be repaired in a way that makes a
tank system truly tight.
The second observed phenome-
non was that new leaks occurred fre-
quently—on the order of a new leak
every two months. The new leaks
were easily observable because the
operating pressures in the tanks
dropped rapidly. The new leaks fre-
quently occurred after deliveries of
product to the tanks. These data sug-
gest that components that are physi-
cally manipulated during deliveries
(e.g., dry breaks and fill caps) are the
source of a significant number of
leaks encountered. Dry breaks, in
particular, are subject to intermittent
leaks because sand and grit can pre-
vent them from sealing properly.
Once the material is dislodged, the
dry break can seat properly.
During the experiment, soil-gas
concentrations were collected during
a pressure-decay test at one station.
Elevated soil-gas contaminant levels
were observed. Significant leaks were
present at the station, and an entire
cylinder of high-pressure nitrogen
was used during the testing (over
1,000 gallons of volume at standard
temperature and pressure). Based on
our observations, the testing may
have temporarily increased the leak-
age rate due to the high pressures
used.
Groundwater quality and soil-
gas contamination levels did not
appear to improve significantly at
any of the sites undergoing inspec-
tion and repair efforts. The repairs
were probably not sufficient to signif-
icantly reduce the total mass of MtBE
released as vapors. Although the
pressures significantly increased in
the tank systems, the combination of
frequent reoccurrence of releases and
the shift of releases from a few larger
leaks to many smaller leaks likely
occurred as pressures increased.
Since no significant release of
excess pressure via the tank system
vent was observed, conservation of
mass supports the explanation that
the overall subsurface vapor-release
rate probably did not change much
even though significant effort was
expended on conventional inspec-
tion, pressure decay testing, and
repair efforts.
The two pressure management
sites behaved much differently than
the inspection and repair sites. The
Healy ORVR compatible nozzle
reduces pressures by blocking vapor
recovery from newer ORVR-equipped
cars. This effectively reduces the
overall effective A/L < 1 and results
in negative pressures in the tank sys-
tem. The negative pressures elimi-
nate the driving forces for leaks. The
-------
February 2007 • LUSTLine Bulletin 54
FIGURE 1 MtBE Contamination in Groundwater vs. Time
VSTOfWnttOMlZH
30O 33C-
Z^C" WC-
KQ.'ttH
i».o»
IW.01D
EC (Mil
*
\*
t*
5
First elh iKioldeliueiy
I En:i
I"THE'
Mi
••i'
Date
I&15
VST system reduces pressures by
separating the UST vapors into air
and gasoline components and then
returning the gasoline to the tanks
and exhausting the air to the atmos-
phere. The VST operates between
pressure set points.
Both of these technologies imme-
diately reduced tank system pres-
sures and subsurface soil-gas
concentrations. Over time, ground-
water contaminant levels were
reduced markedly. (See Figure 1.)
Operationally, the Healy nozzle had
a significant advantage when new
leaks occurred: the leaks resulted in
lower negative pressures and there-
fore soil-gas contaminant concentra-
tions were not observed to rise when
new leaks occurred.
Stay Vigilant!
Traditional inspection and repair
programs did not successfully elimi-
nate subsurface vapor releases
because they did not detect all of
the leaks and/or the leaks reoccurred
too frequently. Pressure-manage-
ment strategies (there are several
technologies available) successfully
addressed vapor releases.
Results available to date indicate
that vapor leaks are difficult to elimi-
nate in traditional Stage II tank sys-
tems without major program and
hardware changes. As a result, prob-
lems will occur with gasoline con-
stituents, such as MtBE, that are
relatively volatile, poorly biodegrad-
able, and very mobile.
Vapor releases may not be nearly
as significant an issue, however,
when gasoline does not contain
poorly biodegradable oxygenates
(e.g., MtBE, TAME, EtBE, and TEA).
Reduction in the total ether levels in
gasoline will definitely have a salu-
tary impact on groundwater plume
strength vis a vis vapor releases. The
optimist in me says take joy in the
downward MtBE trends. The pes-
simist in me says that EtBE levels in
gasoline can rise when events such as
Katrina result in higher European
imports. In truth, new troublesome
additives could well be added to
gasoline in the future. We must stay
vigilant.
It would be very useful for pol-
icy/program development to com-
pile existing data from states that
have transitioned away from MtBE
to evaluate the magnitude of the
vapor-release issue in a post-MtBE
environment. It would also be valu-
able to track gasoline composition
over time so that states can interpret
new contamination trends faster and
more reliably. In any case, the data
strongly indicate the need for careful
review of the environmental proper-
ties of new gasoline additives prior
to addition to the nation's gasoline
supply, since in spite of our best
efforts, leaks still do occur. •
Gary Lynn is the Petroleum Remedia-
tion Section Manager of the New
Hampshire DES. He can be reached at
glynn@des.stat e. nh. us.
Sources of Publicly Available Fuel-
Composition Data
Oi
In the nationwide level, there are few sources of publicly available fuel
composition data. To meet requirements of the Clean Air Act (1990),
U.S. EPA compiles industry-supplied survey results from reformulated
gasoline areas and posts them to its website (http://www.epa.gov/otaq/regs/
fuels/rfg/properf/rfgperf.ritm). These data reflect requirements of the Act and
report on benzene, aromatics, oxygen, oxygenates, and other parameters rel-
evant to emissions. Data for conventional gasoline production and importa-
tion are also compiled and summarized. These data are not directly related to
a state or specific location.
Industry collects data through a voluntary consortium currently man-
aged by Northrup-Grumman in Bartlesville, Oklahoma
(http://pps.ms.northropgrumman.com/de1ault.htm). This data set dates back
to the 1930s, but the number of samples, cities included, and measured
parameters changes from time to time. Reports are available for sampling of
gasoline (twice a year), diesel, jet fuels, and heating oils. The reports contain
regional and state summaries of samples and include data for benzene,
ethers, alcohols, and others.
The U.S. EPA Office of Research and Development samples gasoline
from around the United States and analyzes for 300-plus chemical con-
stituents. These data are drawn from fewer locations but include more detail
than the other sources.
(http://www.epa.gov/athens/research/regsupport/gasoline.html). •
23
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LUSTLine Bulletin 54 • February 2007
from Robert N. Renkes, Executive Vice President, Petroleum Equipment Institute
UST Industry Trends that Will Snap
Tit's cold outside across half the nation, but the spring thaw is right around the corner. To some, that means getting ready to
I play more golf or perhaps to replant the garden. To others, particularly those that either own, install and/or regulate under-
JL ground tanks, that means thinking about installing and upgrading some more tanks systems. Since I can't break 100 and I
only have bushes and trees around the house, I have no thoughts whatsoever to share with you on those first two subjects. So
what you'll get instead are some fearless prognostications about the UST industry around the country.
Prediction #1: The vast majority of the states will select
the secondary-containment option over the financial
responsibility for manufacturers and installers alterna-
tive to comply with the Energy Act of 2005. As of this
writing, we have heard from two states that will defi-
nitely go the financial responsibility route and about 30
that will opt for secondary containment. There are
about a dozen states that we don't hear from on a regu-
lar basis, but I figure we would hear from them if they
were considering PR for manufacturers/installers. That
leaves six states that still seem to be wrestling with the
decision. The regulators from those half dozen states
are leaning toward the prevention option (i.e., sec-
ondary containment), but are feeling heavy pressure
from tank owners to require the PR alternative. I'd
wager that five of those six will go secondary contain-
ment, leaving three states with PR for the installers and
manufacturers.
Prediction #2: The "mom-and-pop" station owners are
back. The large integrated oil companies with complete
departments staffed with lots of people whose sole
responsibility is to figure out the UST rules and regula-
tions, provide facts and figures on options, and make
sure the company's environmental compliance stays on
track will be a thing of the past. Consider these recent
announcements:
• ConocoPhillips will soon divest all of its 830 com-
pany-owned retail outlets in the United States,
which include its company-operated retail and
dealer-operated sites.
• Shell is transitioning to a branded-wholesale strat-
egy in all but nine core markets in the United States.
We expect Shell to sell all its stations in Alaska, Dal-
las, Hawaii, Houston, Kansas City, New Orleans,
Philadelphia/South New Jersey, Portland, and
Sacramento in 2007.
• Other major oil companies have gone on record
saying that they will continue to "reevaluate" their
marketing strategy and "redeploy" their assets to
provide maximum return to their shareholders.
The trend lately is that dealers, jobbers, and conve-
nience store giants get first crack at picking up these sta-
tions. They tend to purchase the top locations and leave
the second- and third-tier sites to individuals with
$100,000 to $600,000 to spend on a convenience store
offering gasoline and diesel. The new mom-and-pop
businesspeople will run these marginally viable stations
the best way they can but will not necessarily be in the
retail marketing and UST regulatory loop. Some will not
speak English as a first language. Explaining new rules
and regulations to these tank owners will be an increasing
challenge for tank regulators and inspectors.
Prediction #3: Getting additional initiatives, rules, and
regulations passed will become more difficult because of
the changing nature of the retail-petroleum tank owner
(see Prediction #2). Individuals who have one or two sta-
tions already own more than 60 percent of all convenience
stores in the United States, and that percentage is going
up annually.
For the most part, these stations have 1998-compliant
tank systems. A great many tank owners, back then,
invested in state-of-the-art systems that had all of the bells
and whistles lots of money could buy. Of course we all
know that there were a few others that spent the bare
minimum to upgrade their systems—but to them, that
was a lot of money as well. To require more money to be
spent to upgrade "perfectly good systems" will meet with
a lot of opposition, with mom-and-pop tank owners com-
plaining that any additional "upgrade" expenditures will
drive them out of business—and they probably aren't
blowing smoke.
Prediction #4: The drive to increase the number of sta-
tions offering motor fuel with ethanol concentrations
greater than 15 percent will stall in 2007 and the begin-
ning of 2008. So will the introduction of any new and dif-
ferent blend of gasoline or diesel. The driving reason for
this is the decision by Underwriters Laboratories (UL) to
suspend the use of its mark on components for fuel-dis-
pensing devices that specifically reference compatibility
with alcohol-blended fuels that contain greater than 15
percent alcohol.
UL was prompted to take this action because research
indicated that high concentrations of ethanol or other
alcohols in blended fuels makes these fuels significantly
more corrosive. UL believes that this may cause the fuel to
chemically attack the materials used in fuel-dispensing
components and cause them to fail. So, until we have reg-
ulatory officials and end-users out there who can be
assured that their dispensers can hold E85 and other alco-
hol-based fuels without leaking, we will see nowhere near
the percentage increase in E85 installations that we have
since passage of the Energy Act of 2005.
Prediction #5: Although we will not see the same steady
increase in stations dispensing E85 for a while (see
24
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February 2007 • LUSTLine Bulletin 54
Prediction #4), that does not mean other factors aimed at
increasing ethanol availability will not be at work. For
example, there will be just about twice as many tanks stor-
ing ethanol at the distillery in 2007 because the amount of
capacity currently under construction in the U.S. is
roughly equal to the amount of capacity already in opera-
tion. And Congress will be proposing—and in my crystal
ball, passing—new biofuels legislation in 2007. Signaling
the aggressive push in the Senate for biofuels, a bipartisan
group introduced a bill on the first day of the 100th Con-
gress to ramp up ethanol use in gasoline and to promote
E85. The bill proposes a new renewable fuels standard
that calls for 60 billion gallons of ethanol and biodiesel
use in motor fuels by 2030. The bill would also require
large oil companies still in the marketing business (see
Prediction #1) to install E85 pumps at their stations,
increasing by five percentage points annually over the
next 10 years. •
A FORMER UST INSPECTOR'S PICTURE-PERFECT VACATION
Ben Thomas, formerly with the Alaska UST program, and now with Ben Thomas Associates in Washington State, took a trip
last summer along the highways and byways of some state (that will remain nameless) out there in the Northwest of the U. S.
of A. He shares his photo memories with us along with some insightful captions.
Does this facility W
need employee UST
training or \e a mixology
degree sufficient?
This cleverly placed nylon
sleeve will guarantee that
direct burial steel product
pipe with never, ever, ever
come in contact with
earth and will, therefore,
never, ever, ever rust. "V
^ Note the beautiful
grain on this craftsman-
style, custom-built
plywood sump lid. Also
note Its water-tight seal
to the sump walls.
, This Installation
contractor must have run
out of concrete while
pouring the form for this
custom-made sump. Or
was this Intentional so
the sc\uare lid would fit
over the round sump?
If you have any UST/LUST-related snapshots from the field that you would like to shire with our readers, please send them to Ellen Frye c/o NEIWPCC.
25
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LUSTLine Bulletin 54 • February 2007
FAQs from the NWGLDE
...All you ever wanted to know about leak detection, but were afraid to
Leak-Detection Equipment and Alternative Fuels
(e.g., ESS and Biodiesel Blends)
. Is leak-detection equipment compatible with alter-
native fuels?
A . Third -party evaluations are a useful tool to verify
leak-detection equipment performance, but evalua-
tion protocols do not require testing for long-term
compatibility with any stored product. Because of
this, the NWGLDE makes no representations as to
the compatibility of leak-detection equipment with
the product stored. (See "Disclaimer" at
nwglde.org/disclaimer.) UST owners and regulators
may wish to request supplemental test data from
the manufacturers to determine long-term material
compatibility. Refer to LUSTLine #52 (May 2006) for
more information on materials compatibility with
alternative fuels.
In this issue's FAQs from the National Work Group on Leak Detection Evaluations (NWGLDE), the Work Group discusses the effects
that alternative fuels may have on leak-detection equipment performance and what we can infer from third-party evaluations.
(Please Note: the views expressed in this column represent those of the work group and not necessarily those of any implementing
agency.)
on the detection of water at the tank bottom may be
less effective in ethanol blends, where water will
homogenize with the stored product rather than set-
tle into a separate layer. Some leak-detection equip-
ment, such as simple float-based interstitial liquid
sensors, should perform well with any product suf-
ficiently dense to raise the float mechanism. In cases
where the performance of a leak-detection method
in alternative fuels is in question, it may be appro-
priate to request that the manufacturer supply sup-
plemental test data to verify performance with the
specific product that will be monitored.
NWGLDE listings provide a summary of third-
party evaluation results and important information
contained in the equipment manufacturer's installa-
tion and operating manuals. The NWGLDE list is a
tool that can be used to better understand the capa-
bilities and limitations of leak-detection equipment,
but it is ultimately up to the regulatory agency to
decide whether or not specific leak-detection equip-
ment can be used within their jurisdiction.
About NWGLDE
The NWGLDE is an independent work group compris-
ing 10 members including 9 state and 1 U.S. EPA mem-
bers. This column provides answers to frequently asked
questions (FAQs) the NWGLDE receives from regula-
tors and people in the industry on leak detection. If you
have questions for the group, please contact them at
questions@nwglde. org.
NWGLDE's mission:
• Review leak-detection system evaluations to deter-
mine if each evaluation was performed in accor-
dance with an acceptable leak-detection test method
protocol and ensure that the leak-detection system
meets U.S. EPA and/or other applicable regulatory
performance standards.
• Review only draft and final leak-detection test
method protocols submitted to the work group by a
peer review committee to ensure they meet equiva-
lency standards stated in the U.S. EPA standard test
procedures.
• Make the results of such reviews available to inter-
ested parties.
Does the appearance of leak-detection equipment on
the NWGLDE list mean that it will perform ade-
quately with alternative fuels?
EPA Standard Protocols state that "Any commercial
petroleum product of grade 2 or lighter may be used
for testing. . .The choice of product is up to the evalu-
ating organization." The majority of equipment on
the NWGLDE list (other than sensors) was evalu-
ated using diesel fuel, which is readily available and
easier to work with than gasoline or ethanol-blend
fuels. The "Applicability" sections in the NWGLDE
listings include several other stored products that
were not used in the evaluation but that the third-
party evaluator and vendor claimed were accept-
able for use with the equipment. The absence of a
specific product does not necessarily mean that the
equipment cannot perform adequately with that
product. As stated in most "Applicability" sections,
"Other liquids may be tested after consultation with
the manufacturer."
There is leak-detection equipment currently listed
by the NWGLDE that will not perform adequately
with alternative fuels. Specifically, automatic tank
gauges with capacitance probes will not work when
used with ethanol fuels. In other cases, physical
properties of alternative fuels that differ signifi-
cantly from conventional gasoline or diesel may
lead to degraded performance of certain leak-detec-
tion equipment. For example, test methods that rely
26
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February 2007 • LUSTLine Bulletin 54
Biodiesel/rom page 16
combined sales of B20 from the three
stations average less than 3,000 gal-
lons per month. If each installation
cost $50,000, and they make an aver-
age of 15 cents per gallon on 1,000
gallons per month, it will take 333
months (27 years, 9 months) to
recoup his investment. How many
"green" customers are willing to pay
the cost differential for B20, if petro-
leum diesel is selling for 20 to 25
cents less per gallon? How do you
create demand for a product that is
more expensive than the alternative?
Are subsidies and tax incentives the
answer? •
References
(1) http:ffwww.wnbiodiesd.com/technologyMml
(2) http://www.answers.com/topic/biodiesel
(3) http://www.biodiesel.org/resources/firessreleases/
gen/20061024_astm_standard_updates.pdf
(4) http://www.edmunds.com.advice/fueleconomy/arti-
cles/102946.article.html
(5) http://www.nrel.gov/uehiclesandfuels/
npbflpdfs/39451.pdf
(6) http://www.greencarcongress.com/
2006/02/oems_bullish_on.html
(7) http://www.eere.energy.gov/afdc/
pdfsftier2Jiealth.pdf
(8) http://www.uidaho.edu/bioenergy/BiodieselEd/pub-
lication/04.pdf
(9) U.S. Environmental Protection Agency, A Com-
prehensive Analysis ofBiodiesel Impacts on Exhaust
Emissions, Draft Technical Report, EPA420-P-02-
001, October 2002
(10) http://new.api.org/aboutoilgas/sectors/segments/
upload/renewablefuelsdiesel.pdfand
http://www.federalsustainability.org/initmtives/biod
iesel/biodieseltrg.htm
(11) http://www.epa.gov/otaa/models/
analysis/biodsl/p02001 .pdf
(12 http://www.nrel.gov/vehiclesandfuels/
nptf/pdfs/40555.pdfand
http://www.eere.energy.gov/tribalenergy/guide/pdfs/
shaine_tyson_biodiesel.pdf
(13) http://www.alternative-energy-news.info/biodiesel-
banned-texas/print/
(14) http://www.nrel.gov/vehiclesandfuels/npbf/fidfs/
39451.pdf, http://www.biodiesel.org,
http://www.afdc.die.gov
(15) http://www.biodiesel.org/pdf_Jiles/fuelfactsheets/
Matermls_Compatibility.pdf
(16) http://www.biodiesel.org/pdf_ftles/fuelfactsheets/
Materials_Compatibility.pdf
(17) http://www.biodiesel.org/pdf_ftles/Environment_
Safety.pdf
(18) Speidel and Ahmed, Biodegradability Characteris-
tics of Current and Newly Developed Alternative
Fuels. SAE Technical Paper Series 1999-01-3518.
(19) http://www.nrel.gov/docs/legosti/fy98/24089.pdf,
and http://www.biodiesel.org/pdf_files/fuelfact-
sheets/LifeCycle_Summary.PDF).
(20) Pimentel and Patzek. 2005. "Ethanol Production
Using Corn, Switchgrass, and Wood; Biodiesel
Production Using Soybean and Sunflower."
Natural Resources Research 14 (1): 65-76.
(21) Delucchi, Mark A., Dec. 2003. A Lifecycle Emis-
sions Model(LEM): Lifecycle Emissions from Trans-
portation Fuels, Motor Vehicles, Transportation
Modes, Electricity Use, Heating and Cooking Fuels,
and Materials (UC Davis Report UCD-ITS-RR-
03-17).
(22) Argonne National Laboratory, GREET 1.5 -
Transportation Fuel-Cycle Model (Report No.
ANL/ESD39 vol. 1, Aug, 1999.
(23) Hill, J. et al. "Environmental, Economic, and
Energetic Costs and Benefits of Biodeisel and
Ethanol Biofuels." Proceedings of the National
Academy of Sciences of the United States of America,
vol. 103, no. 30, July 25, 2006, p. 11206-11210.
(24) Rickeard et al., A Review of the Potential for Bio-
Fuels as Transportation Fuels. Society of Automo-
tive Engineers, Technical Paper #932778, Oct.
1993.
(25) Tyson et al., National Renewable Energy Labo-
ratory, Report No. NREL/TP-510-34796, June
2004, and http://www.eia.doe.gov/oiaf/aeo/supple-
ment/supref.html
(26) http://www.soystats.com/2004/index04.htm
(27) www.biodiesel.org/2006leg.htm
(28) http://www.biodiesel.org/resources/vressreleases/
gen/20060908_aircjualityforum Jinal_.pdf
(29) Pahl G., 2005. Biodiesel: Growing a New Energy
Economy, Chelsea Green, 224 pp.
(30) http://www.fieet.ford.com/showroom/environmen-
tal_vehicles/BiodieselTechnology.aspand
http://www.vw.com/contactus/faqs.html
(31) http://www.greencarcongress.com/2006/01/
chrysler_sancti.html
(32) http://www.alternative-energy-news.info/delaware-
biodiesel-refinery-opens/
Of Square Pegs
and Round Tanks
A LUSTLine Story
Worth Revisiting
Sometimes a story is just a bit ahead
of its time, which is the case with
Marcel Moreau's Tank-nically Speak-
ing article "Of Square Pegs and
Round Tanks or...What If Tank Oper-
ators Knew How to Operate Tanks?"
published in LUSTLine#40, March
2002. This short article is very rele-
vant to today's discussion of the
mandatory operator training provi-
sion of the 2005 Energy Policy Act.
For this reason, we have posted on
the NEIWPCC website at
www.neiwpcc.org. Check it out.
Updated List of Known UST Insurance Providers Available
The EPA Office of Underground Storage Tanks (OUST) List of Known Insurance
Providers for Underground Storage Tank Owners and Operators has been
updated and is available on the OUST website at
http://www.epa.gov/oust/pubs/inslist.htm. The list supplies UST owners and
operators with information on insurance providers that may be able to help them
comply with financial responsibility requirements. This edition replaces all earlier
editions. •
L*U*S*1*LINI Subscription Form
Name
Company/Agency.
Mailing Address _
E-mail Address
LJ One-year subscription. $18.00.
Q Federal, state, or local government. Exempt from fee. (For home delivery,include request on agency letterhead.)
Please enclose a check or money order (drawn on a U.S. bank) made payable to NEIWPCC.
Send to: New England Interstate Water Pollution Control Commission
116 John Street, Lowell, MA 01852-1124
Phone: (978) 323-7929 • Fax: (978) 323-7919 • lustline@neiwpcc.org • www.neiwpcc.org
27
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EPA Consent Agreement
with Baltimore Company
Covers 32 Maryland
Facilities
In a consent agreement with U.S.
EPA, the Carroll Independent Fuel
Company has agreed to pay a
$284,156 civil penalty and complete
a special environmental project to
settle an EPA complaint involving
USTs at 32 of its facilities in Mary-
land. EPA cited Carroll for a variety
of UST violations, including failure
to perform release detection, test the
operation of the line-leak detectors
annually, meet the new UST system
performance standards for spill and
overfill prevention, provide corro-
sion protection on the metal piping,
investigate a suspected release, re-
port a suspected release, and per-
form line tightness testing.
These alleged violations were
documented through multifacility
UST compliance audit reports sub-
mitted to EPA by Carroll's auditor
after Carroll entered into a consent
agreement and final order in June
30, 2003, to perform a compliance
audit of its facilities.
"This has been a win-win situa-
tion because Carroll Independent
Fuel Co. recognized that shortcom-
ings existed within its system and
EPA Enforcement Actions
volunteered to perform a self-audit
at its 70 facilities," said Donald S.
Welsh, regional administrator for
EPA's mid-Atlantic region.
As part of the settlement, Carroll
Independent Fuel Co. has neither
admitted nor denied liability for
these violations. Carroll has also
agreed to implement a $447,000 sup-
plemental environmental project, to
be determined, that is intended to
secure significant environmental or
public health protections.
EPA Fines Euclid of
Virginia, Inc. $3.1 Million
for UST Violations in
Three States
A U.S. EPA Administrative Law
Judge assessed a $3.1 million
penalty against Euclid of Virginia,
Inc. for not taking required mea-
sures to detect and prevent leaks
from USTs at 23 gas stations in
Maryland, Virginia, and the District
of Columbia. In a 118-page decision,
Judge Carl C. Charneski imposed
the largest penalty ever assessed by
an EPA Administrative Law Judge
for violations of any federal environ-
mental statute. The judge ruled that
Euclid failed to maintain required
leak-detection and control equip-
ment and perform required leak-
detection activities for 72 UST
systems at 23 gas stations.
The judge found that, for certain
facilities, Euclid failed to comply
with corrosion-prevention standards,
and to install or maintain equipment
to prevent releases of gasoline due to
the overfilling of tanks or other spills
when tanks are being filled. The judge
also ruled that Euclid did not main-
tain required financial assurances to
respond and clean up potential fuel
leaks or spills for its facilities in the
District of Columbia.
The size of the penalty was due
in part to the number of facilities
and storage tanks and the extended
period of violations. In addition, the
penalty was justified by what the
judge referred to as Euclid's "high
degree of negligence" in allowing
violations to continue despite
numerous warnings.
Although the case was prose-
cuted by EPA, it was the result of
close cooperation with the Maryland
Department of the Environment, the
Virginia Department of Environ-
mental Quality, and the District of
Columbia Department of the Envi-
ronment. The full text of the decision
is available at http://www.epa.gov/oalj/
orders/eudidof-va-id-110906.pdf.
UTTU PUBLISHES FINAL ISSUE
Readers of the Underground Tank Technology Update Newsletter (UTTU) received word from Phil O'Leary, UTTU Project Direc-
tor, that the publication would cease after the November/December 2006 issue. The University of Wisconsin-Madison and the U.S.
EPA initiated UTTU in 1987 as a service to federal, state, and local officials and to others working in the soil, groundwater, and stor-
age tank fields to help keep them current with the latest LUST remediation information and technologies. Over the 20-year period,
the staff produced 120 issues in 20 volumes.
The UTTU website, http://uttu.engr.wisc.edu, contains pdf versions of all issues from 1998 to the present. The University will
maintain the UTTU website for four years, through December of 2010.
Contributors to UTTU are invited to contact Ellen Frye, LUSTLine editor, at ellen.enosis@gmail.com if they have articles to pro-
pose for submittal to LUSTLine. We will do our best to help with filling the void left be the absence of UTTU.
LUSTLINE
New England Interstate Water
Pollution Control Commission
116 John Street
Lowell, MA 01852-1124
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