New England Interstate
Water Pollution Control
Commission
www.neiwpcc.org/lustline.htm
116 John Street
Lowell, Massachusetts
01852-1124
yj.ST.yNE
A Report On Federal & State Programs To Control Leaking Underground Storage Tanks
Bulletin 56
August
2OO7
THE TROUBLE  WITH TRUCK STi
                         (and Other Hiqk-Tkrouqkpid Fuelinq Facilities)
                                          RJEL
                                POOD:
By Marcel Moreau

    The other day I spotted a tractor-trailer rig with a
    message on the side that caught my eye. It said,
    "You need it? It's in here." This message has often
been stated another way, "America's needs move by
truck." For better or for worse, these statements are no
exaggeration. When was the last time you saw a Wal-Mart
SuperCenter or a Home Depot or a Target or any other
stadium-sized store located near a railroad track or a ship
docking facility? The fact is that America's trucking indus-
try is a cornerstone of our economy and our culture.
   And all those trucks bringing all those goods within
convenient reach of all our homes, guzzle oceans of diesel
fuel that is dispensed at a relatively small number of fuel-
ing facilities. In 2004, U.S. vehicles consumed 37.3 billion
gallons of diesel fuel. According to the National Associa-
tion of Truckstop Operators (NATSO) website, three-
quarters of this diesel fuel is pumped through facilities
owned by their members. The average volume of fuel
pumped at a typical large-scale NATSO facility is a mil-
lion gallons per month. A throughput of a million gallons
a month means that on average a facility pumps better
than 33,000 gallons a day, or about 1,400 gallons an hour,
or about 23 gallons each minute of every day.
                    The leak detection implications of these massive
                  truck stop throughputs were the topic of a workshop pre-
                  sented by Steve Purpora of Purpora Engineering,LLC at
                  this year's National Tanks Conference in San Antonio.
                  Steve's dad, Bill, essentially founded the tank and piping
                  testing industry in the U.S. back in the early 1970s and
                  became the undisputed master of his trade. Steve began
                  his career in UST testing at the tender age of eight and is
                  passionate about leak detection. "Everybody can see that
                  there's a huge potential for problems at truck stops," says
                  Steve, "but because there are no simple answers, most
                                         • continued on page 2
                                Inside
                  4U Continual Reconciliation Applications for Active
                     Fueling Facilities

                  6() Florida's Leak Autopsy Study

                  8() Impact of Ethanol on Natural Attenuation of BTEX and MtBE

                  12() Results of NEIWPCC's 2006 Survey of State Tank Programs

                  16(J Two Years After the Energy Policy Act

                  17() Field Notes - PEI/RP600

                  18() FAQs from the NWGLDE—CITLDSs

                  19() STI-Labeled UST Warranty to be Reduced to 10 Years

                  20() Energy Policy Act Update

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LUSTLine Bulletin 56 • August 2007
 m Trouble with Truck Stops
 from page 1

everyone is content to be whistling
Dixie and crossing their fingers. I can
tell you from personal  knowledge
that this strategy is not working."
    The problem is that this kind of
very-high-volume-virtually-non-stop
throughput leaves little time for leak
detection. And because flowing fuel
equals cash flow, there is little desire
to interrupt fuel dispensing to allow
leak detection to occur. And the fact
is that  traditional  leak-detection
methods are woefully inadequate to
do their job in these high-throughput
systems. Let's look at available leak-
detection methods to find out why.

Leak-Detection Methods
in a High-Throughput
Environment
•  Inventory
A new facility less than 10 years old
might still be able to use inventory
control plus tightness testing every 5
years for leak detection. But with a
million gallons of throughput, a vari-
          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)
ance of 10,000 gallons "passes" the
federal standard  of 1  percent of
throughput plus 130 gallons. Clearly,
though it may be  legal, inventory
control is not going to be protective
of the environment at this level of
throughput.
•  Automatic Tank Gauging
(ATG)
Truck-stop tanks are never shut down
at night and most are manifolded
together, so ATGs that conduct peri-
odic tests don't qualify  as a leak-
detection method. ATGs that conduct
"continuous"  testing  still require
quiet intervals  when there  is no
pumping activity in order to gather
the data required to conclude that a
tank is tight or leaking. At through-
puts of more than just a few hundred
thousand gallons per month, how-
ever, these types of tank gauges typi-
cally do not have enough quiet time to
do  their leak-detection  job. While
ATGs can definitely help improve the
quality of inventory data,  at high-vol-
ume sites, they can serve no accept-
able leak-detection function.
•  Statistical Inventory
Reconciliation (SIR)
Traditional SIR methods  rely on
about 30 data points gathered on a
daily basis to determine whether a
leak is present. The SIR evaluation
protocol does not put a throughput
limit on the  applicability of a  SIR
method as the continuous ATG pro-
tocol does. It would be foolish to con-
clude from this, however, that a SIR
method can be used at a facility no
matter how high the throughput. I
do  not see how a  SIR method  can
reliably detect a 150-gallon loss  in a
million gallons of sales (that's 0.015
percent of  the sales volume) using
only 30 data points.
    There is a more recently devel-
oped "real-time" SIR that can auto-
matically gather thousands of data
points by taking "snapshots" of the
fueling activity at a site. One vendor
of this approach has been certified
for throughputs of  up to 2.7 million
gallons. This approach has promise,
especially because it offers facility
owners a means of keeping much
tighter control over their fuel inven-
tories  and thus   offers  business
advantages as well as leak detection.
    SIR methods alone will not do
the complete job of piping leak detec-
tion at a truck-stop facility. Truck
stops typically have satellite fuel dis-
pensers that allow tanks on both sides
of a truck to be fueled simultaneously
in a single sales transaction. Satellite
dispensers are typically connected to
the master dispenser via a relatively
short length of underground piping.
Inventory-based  methods  of leak
detection do not see any leakage that
may occur after the  fuel has passed
through  the metering mechanism in
the master dispenser. Thus, no  inven-
tory or  SIR-based method of leak
detection can be used for leak detec-
tion on satellite-dispenser piping.
•  Secondary Containment
Secondary containment with intersti-
tial monitoring is one  of  the few
methods of leak detection whose effi-
cacy is not affected by throughput
and could realistically be expected to
meet regulatory  requirements  for
monthly leak detection. However,
many existing truck  stops do not
have secondary containment. Replac-
ing existing storage  systems is a
costly  proposition,  and  not  just
because of the huge storage capacity
and  the  extensive piping network
required for the new system. The cost
of interrupting the fueling operations
in terms of lost profit as well as the
loss of customers to competing facili-
ties during the construction  of the
new storage system is likely to dwarf
the cost of the storage system itself.

•  Soil-Vapor Monitoring
Diesel fuel is not nearly as volatile as
gasoline, so soil-vapor monitoring is
not a particularly sensitive method
for  detecting  diesel-fuel  leaks.
Because fuel storage and dispensing
systems at truck stops are spread out
over a  large  area,  it would also
require  a  multitude  of sampling
points to achieve effective leak detec-
tion. Existing contamination at many
sites could  also  pose problems in
detecting new releases.

•  Groundwater Monitoring
The biggest restriction on groundwa-
ter monitoring is that it is only accept-
able where the groundwater  is less
than 20 feet from the ground surface.
Because of its questionable effective-
ness in detecting releases  and the
difficulties encountered  in distin-
guishing new   leaks  from  old,
groundwater monitoring is hardly
anybody's  favorite method of leak
detection. Like soil-vapor monitoring,

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                                                                                 August 2007 • LUSTLine Bulletin 56
effectively monitoring an entire truck-
stop  fueling  facility  would also
require an extensive network of wells.
•   Tightness Testing
Few facilities use inventory control
plus tightness testing as a method of
tank leak detection today. Tightness
testing primarily plays a role in the
annual testing plus line-leak-detec-
tion option for  pressurized-piping
leak detection. The biggest obstacle
here is cost—not the cost of the actual
tightness test but the cost of business
lost during the time required to  set
up and conduct the test.
    Few truck-stop designers had the
foresight to design a facility so that a
portion of the dispensers could be
shut down while the rest continued
to  operate.  "Truck-stop designers
apparently never heard that saying
about 'putting all your eggs in one
basket/" says Steve Purpora. "So
when something breaks  down, the
whole system is  down and there's a
huge rush to  get pumping  again.
Checking  for  leaks to be sure the
work has been done right is not even
a consideration."
    This  philosophy  places  great
pressure on the piping and distribu-
tion system  to  operate non-stop,
because taking the time for mainte-
nance, minor repairs (even of small
leaks), and testing is unacceptably
expensive due to the lost income
from the interruption of sales.
    Consequently, if tightness testing
is done, facility operators want the
testing to be conducted at night and
they want it done fast to minimize
costs and  inconvenience  to cus-
tomers. While this is all very under-
standable,   it  puts   substantial
pressure on tightness testers to  be
quick rather than accurate. "And,"
adds Steve Purpora,  "tired testers
working in the  dark around tired
truckers driving enormous rigs is
hardly the ideal situation from a
safety perspective."
•   Line-Leak Detectors
Perhaps the biggest deficiency associ-
ated with truck-stop leak detection is
the lack of line-leak detection on the
pressurized piping. Remember that
the regulatory definition of line-leak
detector is "a device that can detect a
leak rate of 3 gallons per hour at a
pressure of 10 psi within one hour."
All  line-leak  detectors, whether
mechanical or electronic, require that
the pump be cycled either from off to
on (mechanical LLDs) or  on to  off
(electronic LLDs) in order to conduct
a test. At a facility where the pumps
remain on for many hours at a time
(at many facilities the pumps may
not shut down for days at a time) the
line-leak-detection requirement is not
met because the pumps do not shut
down on an hourly basis. If a sizable
leak were to develop in a truck-stop
piping system,  it could very likely
not be detected  by a line-leak detec-
tor until many hours had passed.
   Truck stops stretch the limits of
LLDs in other regards as well. The
volume of the extensive, large-diame-
ter piping runs may easily exceed the
volume-limit restrictions on the line-
leak detector as determined by the
third-party evaluation. In addition, if
the lengthy piping runs are sloped
uniformly  towards the tanks, the
tanks may end up buried many feet
below grade. For mechanical LLDs,
this could create a scenario where the
static head pressure produced by the
product in the pipe would be suffi-
cient to  prevent the LLD from ever
"tripping" and detecting a  leak. (See
LUSTline #29, "Of Blabbermouths &
Tattletales - The Life & Times of Line
Leak Detectors" for a more detailed
discussion of this issue.)
   While in some jurisdictions, dou-
ble-walled piping with continuously
monitored sensors in tank-top and
dispenser sumps might be acceptable
as line-leak detectors, this is not a
position that I am particularly fond
of. But given existing technology and
the realities of truck-stop operations,
this may well be the best that can be
done  to  meet line-leak-detection
requirements.
• 0.2  Gallon  per Hour
Monthly Testing
Single-walled piping systems  are
increasingly using the automated  0.2
gph leak-detection capability of most
electronic LLDs to meet the monthly
piping leak-detection requirements.
These tests require the temperature
of the product in the piping to be sta-
ble in order for the test to be accurate,
so most  devices  conducting this type
of testing require a 30-minute or so
period of no dispensing before they
can run  the test. Thirty-minute quiet
periods  are virtually nonexistent at
truck stops, and so electronic LLDs
cannot be relied upon to meet leak-
detection requirements by conduct-
ing monthly 0.2-gph tests.

The Bottom Line
Because   of   their  extraordinary
throughputs  and extensive piping
systems, truck stops present time-
based and physics-based challenges
to effective leak detection. While sec-
ondary containment with interstitial
monitoring may be the most-likely-
to-succeed method of leak detection,
few  regulatory  agencies have the
clout to force existing single-walled
facilities to  upgrade to  secondary
containment.
   While it is true that the federal
Energy  Policy Act may by default
impose  secondary containment on
most of the nation's new storage sys-
tems, this is a double-edged sword.
The  increased replacement cost of
new storage  systems  means  that
owners will keep their existing sin-
gle-walled storage systems in service
as long as possible. And  because
most state   regulations have  no
mandatory retirement age for storage
systems, "as long as possible" means
until the  storage system can be
proven to be leaking. Coupled with
the ineffectiveness of leak detection
in detecting leaks, this is not a com-
forting prospect.
   Real-time  inventory  analysis
could provide leak detection relief for
many facilities with throughputs less
than 2.7 million gallons a month,
while providing fuel-management
benefits like verifying delivery vol-
umes and checking the calibration of
meters. Real-time inventory analysis
may provide the least objectionable
pathway for single-walled storage
systems to achieve compliance with
monthly  leak-detection   require-
ments. Keep in mind, however, that
leak  detection for satellite piping
would still need to  be addressed.
Line-leak-detection  requirements
remain problematic under any leak-
detection scenario that I can think of.
   In the meantime, Steve Purpora
is promoting a campaign of aware-
ness and incremental improvement.
"People need  to  know that  just
because the  rest rooms at a high-
volume facility are  clean doesn't
mean that everything below ground
is hunky-dory. Regulators need to
pay more attention to truck stops and
not be intimidated by their size or
                 • continued on page 4

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LUSTLine Bulletin 56 • August 2007
m Trouble with Truck Stops
from page 3

their complexity. Truck-stop opera-
tors need to be made aware of their
responsibilities and have their feet
held to the fire. At a minimum," con-
tinues  Steve, "a detailed annual
inspection, in daylight,  should be
conducted and fines assessed just like
for any other noncompliant facility."

Our High-Throughput
Challenge
The  continuing increase in  our
nation's fuel consumption (we used 2
billion more gallons of diesel fuel in
2004 than 2003, and 2.5 billion  more
gallons of gasoline), together with the
dramatic reduction in the number of
fuel-storage systems since the onset
of the  federal tank rules has pro-
duced a substantial increase in the
throughput volume of the "typical"
storage system.  As this trend of
increasing throughput continues, the
leak-detection methods formulated
for the storage systems of the 1980s
will be stretched to their effective
limits at an increasing number of
sites.  While leak-detection issues
associated with high throughput are
most obvious at truck stops, they are
present in  a growing  number of
today's convenience stores as well.
   So my crystal ball is as fuzzy as
ever, but I see in its misty depths a
growing need for "next-generation"
leak-detection methods like real-time
SIR and pressure-/vacuum-based
interstitial monitoring, as is  now
required for new facilities in Califor-
nia, to meet the leak-detection chal-
lenges of today's (and tomorrow's)
high-throughput fueling facilities. •
   NOTE: Curt Johnson chaired a ses-
sion at the National Tank Conference in
San Antonio entitled "Leak Detection —
The Next Generation" that provided
much interesting  information on  the
state-of-the-art of leak detection.  For a
copy of the slides presented during this
session  of  the   conference, go  to:
http://www. neiwpcc. org/tanks07/presen-
tations/LeakDetectionSession-All-Hand-
outs.pdf

Marcel Moreau is a nationally recog-
 nized petroleum storage tank spe-
cialist, whose column "Tank-nically
  Speaking" is a regular feature of
  LUSTLine. He can be reached at
     marcel.moreau@juno.com
Continual  Reconciliation
Applications for  Active
Fueling Facilities
 by William P. Jones
 T A Thile the population of regu-
  \/\/ lated USTs  has dropped
  V  V  dramatically since storage
 tank rules were first published in
 1988, there has been a  major trend in
 the retail petroleum industry toward
 the development of high-throughput
 fueling facilities. Hypermarket fuel-
 ing stations with customers at each
 dispenser, convenience stores active
 at all hours of the day, and travel cen-
 ters with delivery transports lined up
 to make their drops are now a com-
 mon sight. The  fueling public is
 drawn to these facilities because of
 their competitive  fuel prices. The
 business model that supports these
 complex operations relies upon mov-
 ing large amounts of fuel products on
 thin margins.
    Naturally, operation of these
 high-tempo sites imposes wear and
 tear on fueling equipment. From a
 leak-detection standpoint, the con-
 cern is whether product containment
 has been compromised in the face of
 all this activity. (See  "The Trouble
 with Truck Stops..." page 1.) From a
 business  perspective, costly  fuel-
 inventory losses can  take place at
 active sites because of problems with
 meters drifting out of calibration or
 improper blending ratios, theft at the
 dispenser or upon delivery,  or the
 effects of temperature fluctuations.
    Many companies with high-vol-
 ume sites have realized that the best
 way to manage their complex opera-
 tions is to rely upon precise measure-
 ments of fuel inventory.  Warren
 Rogers   Associates  (WRA)   has
 worked with operators of such sites
 to develop a Continual Reconciliation
 System to enable  them to manage
 their leak-detection requirements and
 all of the complex transactions and
 fueling equipment at high-through-
 put facilities where problems with
 fuel-inventory shrinkage are  en-
 demic.
The Continual
Reconciliation System
As shown in Figure 1, the Continual
Reconciliation System uses a proces-
sor ("OSP") installed at each facility
to acquire data from automatic tank
gauges, dispenser controllers, and
other related  systems.  The  OSP
records data for each dispenser and
compiles refined inventory data at
the conclusion of every sales transac-
tion by querying the tank gauge for
product  height  and  temperature
measurements. The OSP develops a
complete and ongoing record of fluid
flows, transfer, and storage occurring
on-site.1
   Because the Continual Reconcili-
ation System develops precise inven-
tory measurements, it is capable of
computing  delivery  volumes and
meter calibration. Further, the system
adjusts for the expansion and con-
traction of product due to tempera-
ture change on an ongoing basis. The
system also  identifies leakage as a
continuous  loss  of   product,  as
opposed to episodic delivery short-
falls,  theft, or  excess  product dis-
pensed due to meter miscalibration.
   Given that the Continual Recon-
ciliation System works while the UST
system is active, its leak-detection
applications function differently than
conventional automatic-tank-gauge
and line-leak detector monitoring.
Typically, volumetric  monitoring of
tanks and associated lines has taken
place when the tank systems are dor-
mant, an infrequent  occurrence at
high-volume sites. The Continual
Reconciliation System instead relies
on data from  both the static and
dynamic operations of the tank so
that ongoing monitoring of the tank
system can occur.
   Because the Continual Reconcili-
ation System tracks product from the
point of delivery to  the dispenser
meter, leaks from almost every com-
ponent of the storage  system can be
detected. We have found that leaks
originating in the tank  shell or buried

1. U.S. and foreign patents apply.

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                                                                                 August 2007 • LUSTLine Bulletin 56
  FIGURE 1.
OSP Site Communications Hub
piping runs are much less common
today than leaks in flexible connec-
tors, line-leak-detector components,
and dispenser components such as
impact valves, unions, and meters.
Though  common, many of these
types of leaks are often missed by tra-
ditional methods of leak detection.
   As a result of its ability to use all
of the available data from a tank sys-
tem, the Continual  Reconciliation
System is certified as an automatic
tank  gauge system method  for
monthly monitoring  of  tanks and
associated lines for complex mani-
folded tank systems up  to 100,000
gallons in capacity and nearly 3 mil-
lion gallons in monthly throughput.

What about Non-Leak
Losses?
The same data the system collects for
leak detection purposes can also be
used to quickly pinpoint and quan-
tify  non-leak losses.  Operational
problems  such  as   miscalibrated
meters, short deliveries, and theft at
the pump occur with far greater fre-
quency than leakage, and their costly
effects can mount up quickly at a
high-throughput site.
   For example, an active dispens-
ing position for diesel fuel could be
checked  for calibration by weights
and  measures  standards  and  be
found  to be operating within the
acceptable range. However, this same
                dispenser at an active travel center
                can be dispensing in excess of 300,000
                gallons monthly and during that time
                could be giving away 650 gallons of
                product  worth nearly  $2,000.00
                despite the fact that it's operating in
                conformance with required  toler-
                ances.
                   The  Continual Reconciliation
                System is able to identify such meter-
                drift effects because measurements
                are being recorded at the end of
                every transaction and set of overlap-
                ping transactions. Therefore the con-
                tribution of each individual meter to
                inventory variations can be identi-
                fied. Instances of both meter give-
                away and holdbacks  can then be
                identified to the owner/operator so
                that they can be corrected. Further,
                because the duration of transactions
                is also recorded, dispenser flow rates
                can  be  determined  to  identify
                clogged filters or problems with flow
                limiters.
                   Theft is also common at the point
                of delivery or at the dispenser, partic-
                ularly in this era of volatile fuel pric-
                ing. While delivery shortfalls may be
                apparent to  the operator of a low-
                throughput site, they are difficult to
                identify at a very active facility taking
                more than one delivery a day. Simi-
                larly, dispensers can be  jiggered at
                remote fueling positions  of  high-
                throughput sites, resulting in unau-
                thorized fueling transactions.
                                                                        Dispenser
            Dispenser  theft  at  a
        truck-stop   facility,   for
        example, is  not a trivial
        event, since  the losses of
        each individual event could
        be greatly in excess of 100
        gallons  of  product. The
        Continual  Reconciliation
        System can calculate on an
        ongoing basis the actual
        amount of product deliv-
        ered  to  a tank system as
        well as identify theft events
        by date, time, and amount.

        Marrying Business
        and  Environmental
        Concerns
        Continual  reconciliation
        has an  important role for
        volumetric  leak-detection
        monitoring     in    high-
        throughput UST systems. It
        is a way to motivate tank
        owner/operators  to pay
        attention to leak detection.
As a result of the reconciliation sys-
tem's ability to identify specific rea-
sons for loss of product—be it piping
or dispenser or theft or meter drift—a
report of leakage becomes more visi-
ble and understandable to the busi-
nessperson who  owns or operates
that  site. Leak detection is enfolded
into everyday business practices. If a
situation develops at a high-through-
put  site, the  operator can quickly
direct his/her attention to the prob-
lem at hand rather than undertake a
protracted "hit-or-miss" investiga-
tion that could allow a leak to persist.
It is a win-win solution for both the
businessperson and the environment.
   Currently  the Continual Recon-
ciliation System is in use at over 400
active travel centers nationwide as
well as at high-volume convenience
stores and truck terminals. To find
out more  about  this leak-detection
option, go to www.warrenrogersassoci
ates.com or consult the National Work
Group on Leak  Detection Evalua-
tion's website at www.nwglde.org and
look under the methods listed for
Continuous In-Tank Leak Detection
Systems. •

 Bill Jones is Executive Vice President of
 Warren Rogers Associates, Inc.  He can
           be reached at
  wjones@warrenrogersassociates.com.
          or 800.972.7472.

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LUSTLine Bulletin 56 • August 2007
 Florida's Leak  Autopsy  Study for Storage Tank
 Systems: An Enlightening Work in Progress
 by Marshall T. Mott-Smith

     The  Florida  Department  of
     Environmental   Protection's
     (FLDEP's) Storage Tank Regu-
lation Section has been interested in
obtaining field data on the sources
and causes of discharges from under-
ground and aboveground storage
tank systems  since  the  program
began in 1983. As early as 1986, the
department entered into a contract
with a university engineering depart-
ment to evaluate the department's
Discharge Report  Forms. Things
came to a halt when the contract was
cancelled due to poor performance.
    A second study was initiated in
2001-2002 with the USEPA Office of
Underground  Storage Tanks (the
"Florida Cause of Leak Study"). This
joint effort collected 642 valid data
points from 2,280 file reviews. FLDEP
used USEPA funding to pay  for
County Tanks Program inspectors
under contract with the department
to perform file reviews of closure
inspection documents of  UST and
AST systems.
    The study focused on single-
walled and double-walled systems
and excluded data from unprotected
steel systems or those where the
source  of  the  discharge  was
unknown. The final data correlated
well with USEPA Region 4's leak
autopsy data, and echoed the find-
ings that  the main source of leaks
from UST systems was single-walled
piping  systems.  (Contact  EPA's
Office  of Underground  Storage
Tanks if you are interested in obtain-
ing a copy of the draft report.)
    FLDEP decided to continue the
Florida Cause of Leak Study, making
several revisions learned  from the
previous effort. Since January 1, 2003,
all 145 of  the FLDEP County Tanks
Program  inspectors  have  been
required to submit a leak autopsy
form for any new discharge.
    This new  study  is called the
Florida Leak Autopsy Study for Stor-
age Tank Systems. We believe it has
more credibility than the previous
study because the data  from this
effort is field-verified and submitted
 FIGURE 1.
 Mar 07
UST Leak Sources in Florida
                  Spill Buckets
                     48%
      Customer
      Vehicles
        1%

  Delivery vehicles
      2%
                         563 Sources
           Dispenser
             12%
            Dispenser &
           Piping sumps
               1%
                              Submersible
                            Turbine Pumps
                                 3%
                            Piping
                             14%
                       Fill & Remote Fill
                           pipes
                            1%
               Line Leak Flex-connectors - 3%
               Detectors
                 2%   Vent Lines
                        1%
 FIGURE 2.    USTs, Tanks as the Source, All Causes
 Feb07
 Mechanical/
Wear damage
    2%
                                    Overfill
                                      25%
   Unknown
      36%
                             56 Causes
                                          Vandalism
                                             2%

                                          Corrosion
                                             7%
           Weather
             2%
 Physical
 Damage
   16%
Material
Failure
  11%
by the inspector. In addition to the
form, each discharge file has a copy
of the Discharge Report Form, the
facility inspection report, and usually
contains photographs or supporting
data such as lab analyticals or test
results.
    After four years of data submit-
tal, some interesting trends  have
              emerged. Where underground pip-
              ing associated with USTs used to be
              the major source of leaks in Florida,
              the current most common source of
              discharges is the spill bucket. Nearly
              half of all new leaks are coming from
              spill-prevention systems, with mater-
              ial failure (cracking or splitting)
              being the major cause.

-------
                                                                               August 2007 • LUSTLine Bulletin 56
  FIGURE 3. USTs - Piping as the Source, Type of Piping
                 Double-wall
      Feb 07    Fiberglass
                    15%
        Double-wall
          Copper
            1%
 Double-wall
   Flexpipe primary
   within a Liner 1%
 Yellow
          Double-wall
           Flexpipe
             43%
                                                    78 Sources
                     Single-wall
                     Fiberglass
                        35%

                        Single-wall
                        Red

                           SW Steel
                          w/lmpressed
                            Current
                              3%
                    Fiberglass primary with
                    Flexible Secondary 1%
             SW Steel with
             Sacrificial
             Anodes 5%
  SW Steel
aboveground
     1%
  FIGURE 4.   USTs - Piping as the Source, All Causes
  Feb 07
                      Material
                       Failure
                        33%
                         88 Causes
       Weather 2%
           Physical
          Damage or
           Puncture
             20%
        Improper Installation
           or Repair 2%
                   Unknown
                     15%
            Corrosion
Mechanical     2%
Damage 12%
    Piping is the second most com-
mon  source of discharges,  with,
unfortunately, almost as many dis-
charges from double-walled systems
as from single-walled systems. This
finding can largely be attributed to
flexible polyethylene piping systems.
Tanks are the source of discharges in
only 10 percent of all discharges, and
most of those are associated with
tank overfills where the tank was the
source of the discharge, but the cause
was an overfill.
    For ASTs (aboveground storage
tanks), the most frequent source of
discharges  for  large  field-erected
tanks (greater than 50,000 gallons) is
underground bulk-product (larger
than three inches in diameter) steel
piping that is in contact with the soil.
If you include pumps, valves, and
other systems associated with these
steel piping systems, then nearly two
thirds of all discharges from these
types of tanks come from piping. For
smaller  shop-fabricated tanks, the
most frequent source of discharges is
the tank, and the major cause is over-
fills.
   The information obtained from
the Florida Cause of Leak Study has
been extremely valuable for program
management and rule-making deci-
sions and enables the department to
concentrate on the problem areas.
Whether it is an enforcement  case
before a judge or hearing officer, or
before a state rulemaking board, we
are now able to do something that we
were unable to do in the past—show
actual data to support our positions
instead  of  anecdotal  information
obtained from our inspectors.
   We hope that other state and fed-
eral tanks programs will benefit from
this  ongoing  study,  which  will
become even more statistically valid
as time goes on. We are  open to sug-
gestions from interested parties to
help us  refine and improve the
process. We will continue to provide
updated data on our Tanks Program
website at:
   http://www. dep.state.fl.us/waste/cat
egories/tanks/default.htm •

 Marshall T. Mott-Smith is Administra-
 tor of the Storage Tank Regulation Sec-
   tion Bureau of Petroleum Storage
  Systems at the Florida Department of
  Environmental Protection. He can be
      reached at marshall.mott-
        smith@dep.state.fl.us
         FIGURE 5.

         Performance of
         Double-Walled
         Piping
         Compared to
         Percent of
         Usage
                                  43 Discharges
                                  n Percent of
                                    Discharges

                                  • Percent of
                                    Double-wall
                                    piping
                                 Fiberglass
                                 11,179
                           Other
                           1455
                   18,274
                   Double-
                   wall Piping
                   Systems

-------
LUSTLine Bulletin 56 • August 2007
The Impact of  Ethanol  on the Natural

Attenuation of BTEX  and MtBE

A        research team comprised of members from University of California-Davis, Geomatrix Consultants, and
        USEPA conducted controlled field experiments at a typical fuel spill site to assess the impact of ethanol on
        natural attenuation of BTEX and pre-existing MtBE contamination. Because most fuel-contaminated sites in
 the United States overlie aquifers in which the dominant electron acceptor is sulfate (1), a sulfate-dominated site
 was selected for this research. The research was originally published in Environmental Science and Technology as
 two articles by D. M. Mackay, N. de Sieyes, M. Einarson, K. Feris, A. Pappas, I. Wood, L. Jacobson, L. Justice, M.
 Noske, K. Scow, and J. Wilson—"Impact of Ethanol on the Natural Attenuation of Benzene, Toluene, and o-Xylene
 in a Normally Sulfate-Reducing Aquifer," Vol. 40 (2006), pp. 6123-6130, and "Impact of Ethanol on the Natural
 Attenuation of MtBE in a Normally Sulfate-Reducing Aquifer, "Volume 41 (2007), pp. 2015-2021. These papers have
 been edited for LUSTLine by Ellen Frye.
Ethanol's Subsurface
Underbelly
As ethanol replaces methyl fert-butyl
ether (MtBE) and becomes an increas-
ingly common component of auto-
mobile  fuels,  it  is important  to
determine if it will pose any signifi-
cant direct or indirect risks  as  a
groundwater contaminant. Ethanol is
expected to  degrade  rapidly and
without  any  acclimation  period
under most redox conditions, unless
present at very high concentrations
such as might occur adjacent to fresh
spills  (2). Thus,  ethanol itself is
unlikely to pose much direct risk as a
groundwater  contaminant,  except
perhaps in unusual cases.
    However,  an  ethanol release
could pose an indirect risk due to its
impact on the natural bioattenuation
of other petroleum-associated conta-
minants caused by the rapid preferen-
tial biodegradation of  ethanol and
consequent depletion   of electron
acceptors and/or modification of the
microbial community (2-5). Ethanol
would  be expected to influence the
natural biodegradation of fuel compo-
nents, notably the BTEX compounds
(benzene, toluene, ethylbenzene, and
xylene isomers), due to  rapid prefer-
ential biodegradation of ethanol caus-
ing (a) depletion of readily available
electron acceptors, thus slowing or
stopping BTEX biodegradation by
native microbes, due to  slower kinet-
ics compared to more  energetically
favorable   metabolic   pathways,
and/or (b) reduction of the fraction of
the native microbial community able
to biodegrade BTEX (2-10).
    Release of ethanol may also cre-
ate and sustain strongly anaerobic
and sometimes methanogenic condi-
8
tions in groundwater. Studies have
provided evidence of transformation
of MtBE to fert-butyl alcohol (TEA)
and  other intermediates, both  in
microcosms under highly reduced
(including methanogenic) conditions
and in the methanogenic zones near
fuel spills (1,11-16). Laboratory stud-
ies measuring fractionation of stable
isotopes during anaerobic metabo-
lism of MtBE implicate acetogenic
bacteria in the process (14,15). Molec-
ular hydrogen produced by the fer-
mentation of BTEX compounds may
produce the hydrogen that can sup-
port anaerobic metabolism of MtBE
by acetogenic micro-organisms (13,
16).
    On the other hand, at sites where
natural  attenuation has depleted
BTEX compounds from a gasoline
spill that originally contained MtBE,
anaerobic biotransformation of MtBE
may slow or  stop altogether. This
could lead to  conditions where fer-
mentation of ethanol dominates and
where acetate and molecular hydro-
gen are generated as fermentation
products which may, in turn, support
microbial communities that acceler-
ate the biotransformation of any pre-
existing MtBE to TEA and  other
intermediates.
    To gain a clearer picture of the
indirect risk posed  by an  ethanol
release, the research team conducted
side-by-side experiments in a sulfate-
reducing aquifer, at a former fuel sta-
tion at Vandenberg Air Force Base
(VAFB), California, to  evaluate the
effect of an ethanol release (a) on
biodegradation of benzene, toluene,
and o-xylene (which will be referred
to as BTEX) and (b) on the fate of pre-
existing MtBE contamination.
The Site and Pre-
experimental Conditions
The goal of this  study was not to
examine the worst conditions that
might occur for  a  large and cata-
strophic gasohol  spill, but rather to
examine the likely more common
case of long-term,  small-volume
releases of gasohol to the subsurface
at an operating fuel service station
with no ongoing active remediation
of past spills.
    A gasoline leak was noted at the
VAFB site in 1994, tanks and piping
were excavated in 1995, and the exca-
vation was backfilled with materials
more permeable than the native sur-
ficial media. Figure 1 depicts the sur-
face boundary of  the excavated area
and location of  monitoring wells
installed  before  and during  the
experiments. The square demarks the
area of focus.
    In the vicinity of  the backfilled
excavation, several thin, essentially
horizontal, sandy layers exist within
8 meters of ground surface. (See Fig-
ure 2.) These include  the S2, within
the zone of water table fluctuation,
and the S3 and S4, always fully satu-
rated. Another layer, the SI,  lies
above the range of water table fluctu-
ation and is not depicted since it is
unrelated to this research. Layers of
silt or clayey silt separate these sandy
layers and are of considerably lower
permeability. The S2  sand pinches
out somewhere under Monroe Street,
whereas the S3 sand is  continuous for
several hundred feet downgradient
of the source area (i.e., beyond the
upper right corner of Figure 1). Mon-
itoring well  screens span the full ver-
tical interval of the sand unit.
    Pre-experimental  BTEX concen-
trations in  the S3  were very low

-------
                                                                                 August 2007 • LUSTLine Bulletin 56
                                                       Aerobic  in situ
                                                       biobarrier
     Area addressed
     in later figures
  Surface
  boundary of
  excavation
                     •Background wells
                                                         m    15
 FIGURE 1. Map of the experimental zone at the fuel station site, Vandenberg
 Air Force Base (VAFB), CA, showing the source excavation, the locations of
 various transects of monitoring wells, etc. The dashed line B-B' shows the
 location of the schematic vertical section in Figure 2.
 Reprinted with permission from DM. MacKay et al. (2007). Copyright 2007 American Chemical Society.
B'
                                      ;S2 sand
                                      S3 sand
                                      S4 sand
           Backfill (not homogeneous)
                                                        Water level fluctuation
       Groundwater flow direction
 FIGURE 2. Conceptualization of the subsurface in and around the backfilled
 excavation. Locations of screened sections of wells are shown as blue or red
 rectangles. Note that the ER transect, including the injection wells,  was sev-
 eral meters downgradient of the contact of the S3 with the backfill. The red
 shading depicts the authors' conceptualization of the distribution of contami-
 nants in strata  shallower than the S3, and also their hypothesis that the
 organic contaminants still migrating from  the source area via the S3 aquifer
 (mainly MtBE and lesser amounts of TBA) are introduced to the groundwater
 flowing in the S3 from above by diffusion and/or slow advection.
 Reprinted with permission from DM. MacKay et al. (2007). Copyright 2007 American Chemical Society.
(most <10 ug/L) and discontinuous
due to previous bioattenuation activ-
ity under the predominantly sulfate-
reducing conditions. In contrast, a
significant reservoir of MtBE mass
remains in the strata above the S3
sand and mass flux downward into
the S3 sustains a nearly continuous
MtBE plume therein.  Prior to the
experiments  MtBE  concentrations
were quite high in the S2, with a max-
imum detected value of 72,900 ug/L.
Nevertheless,  the  maximum MtBE
concentration  in the S3 was much
lower  (1,260  ug/L).   The  mean
groundwater velocity during these
experiments was estimated to be 50
to 75 cm/d, with  seasonal fluctua-
tions lessening with distance down-
gradient of the backfill. Dissolved
sulfate is the predominant electron
acceptor controlling microbiological
reactions.

The Lingering Affect of
Ethanol on  BTEX
In  the  experiment  conducted to
determine the impact of ethanol on
BTEX  biodegradation,  the  team
injected groundwater amended with
1-3 mg/L BTEX on one side, or lane,
over a nine-month period.  On the
other side they injected the  same
amount of BTEX, adding about 500
mg/L  ethanol. Initially the BTEX
plumes on both  lanes extended
approximately the same  distance.
Thereafter, the plumes in the "No
Ethanol Lane" retracted significantly,
which  the team hypothesizes was
due to an initial acclimation period
followed by  improvement  in effi-
ciency of biodegradation under sul-
fate-reducing conditions.
    In the "With Ethanol Lane," the
BTEX plumes also retracted but more
slowly and not as far. The preferen-
tial  biodegradation   of  ethanol-
depleted dissolved  sulfate, leading to
methanogenic/acetogenic   condi-
tions. The researchers hypothesized
that BTEX in the ethanol-impacted
lane was biodegraded in part within
the methanogenic/acetogenic zone
and, in part, within sulfate-reducing
zones developing  along the plume
fringes due to mixing with  sulfate-
containing groundwater surrounding
the plumes due to dispersion and/or
shifts in flow direction.
    Overall, this research confirms
expectations that ethanol may reduce
rates of in situ biodegradation of aro-
matic fuel components in the subsur-
face, in  both transient and  near
steady-state  conditions.   In  the
ethanol-impacted lane, rapid degra-
dation of ethanol removed most of
the sulfate within a short distance

                • continued on page 10

-------
LUSTLine Bulletin 56 • August 2007
 i Impact of Ethanol from page 9
from the injection wells, causing a
shift in redox and geochemical condi-
tions. (See Figure 3.) A result of this
shift was that the established, and
otherwise effective, natural attenua-
tion of BTEX under sulfate-reducing
conditions     was    substantially
reduced.
    As discussed in the  published
research, implications of this experi-
ment for future assessments of poten-
tial impacts of ethanol on the fate of
BTEX species in the subsurface sug-
gest the importance of determining
the location of various reactions of
interest and utilizing rates of reactions
that are relevant to these redox reac-
tions. Though specific to the experi-
mental site  and  conditions,  these
Benzene Toluene o-Xylene
1,0

0,8
0.6
0.4
§
~~ 1.0

SE 0.8
0.6
0.4
0,2
No Ethanol
-•-12/6/2004
\-"- 1/1 1/2005
-•-29/2005


^ With Ethanol




VA -•- 12/6/2004
\\ik -"-1/11/2005
\\ -*- 2/9/2005
Nk
v~— — — —




No Ethanol
-•-12/6/2004


\ -"-1/11/2005
\ -»- 2/9/2005
1

With Ethanol
-•-12/6/2004



k-»-1/11Q005
-•-2/9/2005


No Ethanol
-•-12/6/2004
1 -"-1/11/2005
-•-2/9/2005
\

With Ethanol
-•_ i7,,'«/;jri;u
<\ -^1;11/200f-
YI -»-2/9/2005
\
W-_












0 10 20 30 40 0 10 20 30 40 0 10 20 30 40
distance (m)

FIGURE 3. Normalized mass discharge (Md/Mdo) for benzene, toluene, and
o-xylene versus distance along the flowpath in both lanes for the three final
snapshot sampling times.
Reprinted with permission from D.M. MacKayetal. (2006). Copyright 2006 American Chemical Society.


    The  team  hypothesized  that
biodegradation of BTEX was possible
under   the   newly   established
methanogenic  conditions  created
downgradient of the injection wells;
however,  it took many months to
reach a steady-state rate for each of
the species, and the new rates were
slower than those observed under
sulfate-reducing conditions.
    They  hypothesize that overall
degradation  rates for the mixed
redox  conditions  created in  the
ethanol-impacted lane were slower
than those observed under sulfate-
reducing  conditions  in  the  No
Ethanol Lane. Consequently, under
steady-state   conditions,   BTEX
migrated further in the With Ethanol
than in the No Ethanol Lane. Ulti-
mately, it appeared that biodegrada-
tion at the lateral boundaries of the
lane, under sulfate-reducing condi-
tions created by mixing due to dis-
persion or flow direction changes,
controlled the ultimate extent of the
benzene and o-xylene plumes in the
With Ethanol Lane.
results are useful in guiding future
modeling efforts  to examine other
scenarios of interest, including wider
sources, discontinuous sources, and
different concentrations of electron
acceptors and/or contaminants.
    Clearly,  modeling should con-
sider  the importance of anaerobic
biodegradation   processes,   both
within the  plume, where electron
acceptors may be depleted,  and at
boundaries where replenishment of
electron acceptors may occur by mix-
ing with surrounding electron-accep-
tor-rich groundwater. The results also
indicate that such predictive model-
ing should  consider mixing during
periods of steady flow direction as
well as  enhanced mixing that may
occur due to shifts in flow direction.

Ethanol + MtBE =
TBA...Sometimes
While  research  has  demonstrated
more certainty about the effect of
ethanol on attenuation of BTEX, less
has been understood about how or if
ethanol influences pre-existing MtBE
contamination in groundwater. In an
attempt to better understand this, the
research  team compared the influ-
ence of ethanol on the existing MtBE
by spiking groundwater with side-
by-side injections into the S3 in two
ways: (a)  groundwater spiked contin-
uously with BTEX (the No Ethanol
Lane), and (b) groundwater spiked
continuously with BTEX and ethanol
(the With Ethanol Lane).
    Over  a period of  9   months,
approximately   200  mL/min   of
spiked groundwater  was  injected
into  each  lane (split into thirds
directed  to three injection wells in
each lane). Ethanol was added to the
groundwater injected in the With
Ethanol Lane at approximately 500
mg/L. Tracers (SF6 or bromide) were
added to one or both lanes for short
periods of time.
    During the  injections, the input
of MtBE to the injected water migrat-
ing in the S3 was sustained by advec-
tion or diffusion from a significant
reservoir   in   shallower   strata.
Although introduction of MtBE to the
lanes was not controlled in the exper-
iments, the team hypothesized that
careful analysis of the experimental
data could yield valuable  insights
into MtBE fate under the very differ-
ent geochemical conditions gener-
ated in the two lanes.
    As the experiments progressed,
an MtBE-depleted zone developed in
the With Ethanol Lane, but there was
no similarly clear depletion of MtBE
in the No Ethanol Lane. A substantial
increase in tert-butyl alcohol (TBA) in
the With  Ethanol Lane strongly sug-
gests that MtBE was biotransforming
in the ethanol-impacted lane during
the experiments. An increase in TBA
did not occur in the No Ethanol Lane.
TBA concentrations observed during
the experiments ranged  up to 1,200
ug/L, whereas prior to  the experi-
ments the maximum detected value
was  120 ug/L with most measured
values below 20 ug/L. The increase
in TBA concentrations is consistent
with the  hypothesis that MtBE was
transformed  by  native  microbial
communities   under   the  meth-
anogenic and acetogenic conditions
created in the ethanol-impacted lane
after depletion of sulfate by preferen-
tial degradation of injected ethanol.
    By 2  months, transformation of
MtBE to  TBA was already evident,
suggesting a rapid acclimation time

-------
                                                                                            August 2007 • LUSTLine Bulletin 56
a) without ethanol
b) with ethanol
    14
    12 -
    10 -
     2
 •  MTBE
-«-TBA
      -100
            -50
                        50
                             100
                                   150
                                         200
                                               250
                                                     300
             Days before (-) or after (+) start of injection
    12
     2 -
      -100
                             100
                                         200
                                                     300
             Days before (-) or after (+) start of injection
 FIGURE 4. Mass discharge (Md, mmol/d) of MtBE
 and TBA crossing the EH transect over time in the
 "Without Ethanol" and "With Ethanol" lanes.  The
 location of the EH transect is noted in Figure 1.
 Reprinted with permission from DM. MacKay et al. (2007). Copyright 2007
 American Chemical Society.
for this process. TBA was detected,
albeit at much lower concentrations,
in the S3 prior to the experiment, sug-
gesting that microorganisms capable
of transforming MtBE  to TBA may
already have been present in the S3.
Thus the primary limit on the overall
rate of transformation of MtBE at this
site may have been availability of a
readily degradable substrate and,
upon release  of ethanol,  a  much
broader zone of strongly reduced
conditions was quickly established
within  which the acclimated popula-
tion could flourish.
    Figure 4 presents mass discharge
(Mj) estimates, based on monitoring
data at the EH transect (approxi-
mately 40 meters  downgradient of
the  injection  wells),  for  MtBE and
TBA over time in the two lanes. The
contaminant  Md  is  presented  in
mmol/d to  facilitate  comparison of
                 MtBE and TBA val-
                 ues, since  stoichio-
                 metric    anaerobic
                 biotransformation of
                 one mole of  MtBE
                 yields one mole  of
                 TBA. Frame (a) indi-
                 cates no significant
                 change in the Md for
                 MtBE or TBA in the
                 Without    Ethanol
                 Lane,  and  that the
                 Md of TBA is essen-
                 tially   zero.  Thus
                 there is no evidence
                 of biotransformation
                 of MtBE under sul-
                 fate-reducing condi-
                 tions in the absence
                 of  ethanol  at  any
                 time in the experi-
                 ments.
                     In    the   With
                 Ethanol  Lane   in
                 frame (b), although
                 the Md for MtBE and
                 TBA remain  con-
                 stant for two snap-
                 shots  prior  to the
                 experiments, during
                 the experiments the
                 Md for MtBE gener-
                 ally decreases with
                 time while  that for
                 TBA increases.  The
                 decrease in Md for
                 MtBE (-11 mmol/d)
                 was similar to the
                 increase  in Md  for
                 TBA (-10 mmol/d).
This suggests that MtBE disappear-
ing in the ethanol-impacted lane was
transformed to TBA quantitatively,
or nearly so.
    Based on these results, the inves-
tigators hypothesize that products of
ethanol metabolism (acetate, propi-
onate, possibly molecular hydrogen)
were carried downgradient from the
very limited zone of ethanol degrada-
tion to zones that supported biotrans-
formation  of  MtBE to  TBA. Rapid
subsurface transformation of MtBE to
TBA may be expected where strongly
anaerobic  conditions are sustained
and fluxes of requisite nutrients and
electron  donors  support develop-
ment of a biologically active, possibly
acetogenic, zone.
    To better  evaluate the potential
for ethanol-blended fuels to impact
MtBE transformation, we need more
measurements of the fate and indi-
rect effects of ethanol associated with
a broad range of anticipated sources
(neat  spills, and gasohols ranging
from low to high percent ethanol)
and typical site conditions. •


Disclaimer
The U.S.  Environmental Protection Agency
through its Office of Research and Develop-
ment partially funded and collaborated in the
research described here under an in-house
project (Task 5857, MNA of MtBE). It has not
been subjected to agency review and therefore
does not necessarily reflect the views of the
agency, and no official endorsement should be
inferred.

Acknowledgements
This research was funded primarily by the Cal-
ifornia Department of Health Services as one
deliverable of Contract 01-16433 ($1,149,684).
Seed funding for early characterization and
other initial work was provided by the Ameri-
can Petroleum Institute. Additional support to
Scow was provided by grant number 5 P42
ES04699 from the National Institute of Envi-
ronmental Health Sciences, NIH. The papers'
contents are solely the responsibility of the
authors and do not necessarily represent the
official views of the NIEHS, NIH.


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  mental Engineering. 2002,128, 862-867.
6. Deeb, R. A.; Sharp, J. O.; Stocking, A.; McDonald,
  S.; West, K.  A.;  Laugier, M.; Alvarez,  P. J.;
  Kavanaugh, M. C.; Alvarez-Cohen, L. Impact of
  ethanol on benzene plume lengths: Microbial and
  modeling studies. Journal of Environmental Engineer-
  ing. 2002,128 (9), 868-875.
7. Lovanh, N.; Hunt, C. S.; Alvarez, P. J. J. Effect of
  ethanol on BTEX biodegradation kinetics: Aerobic
  continuous culture experiments. Water Research.
  2002, 36 (15), 3739-3746.
8. Ruiz-Aguilar, G. M. L.; O'Reilly, K.; Alvarez, P. J. J.
  A comparison of benzene and toluene plume
  lengths for sites contaminated with regular vs.
  ethanol-amended gasoline. Ground Water Monitor-
  ing and Remediation. 2003,23 (1), 48-53.
9. Corseuil, H. X.; Aires, J. R.; Alvarez, P. J. J. Implica-
  tions of the presence of ethanol on intrinsic biore-
  mediation of  BTX plumes in Brazil. Hazardous
  Waste and Hazardous Materials. 1996,13 (2), 213-221.
10. Corseuil, H. X.; Alvarez, P. J. J. Natural bioremedi-
   ation perspective for BTX-contaminated ground-
   water in Brazil: Effect of ethanol. Water Science and
   Technology. 1996,34 (7-8 pt 4), 311-318.

                  • continued on page 15
                                                                                                                       11

-------
LUSTLine Bulletin 56 • August 2007
 The Results of NHWPCC's 2006 Survey of State Tank
 Programs Can Pe Found at a NHWPCC Website Near You
 by Ellen Frye


       Okay, the survey was long.
       Some of the questions were
       really irritating. A few state
respondents  plowed  through  a
preternatural cyberspace logjam. A
few didn't have much to say. Several
poured the heart and soul of their
program's database into the ques-
tions at hand. It was the best of times.
It was the worst of times, but we got
through it. And it was good. And
now the results of this survey called
State Experiences with Petroleum and
Hazardous Substance Releases at LUST
Sites, Heating Oil Tanks, and Out of
Service Tanks—this ponderous, mag-
nificent snapshot in history—is there
for you to inhale  and behold at
http://www.neiwpcc.org/mtbe.asp.
   Remember 2000 and 2003, when
the New  England Interstate Water
Pollution  Control   Commission
(NEIWPCC) conducted surveys on
state experiences with MtBE and oxy-
genate contamination at LUST sites?
Well in an effort to outdo itself, in
2006, NEIWPCC bit into a grant from
the USEPA Office of Underground
Storage Tanks to develop and con-
duct  a  new  survey that  would
address primarily  topical  LUST-
related issues but also other pro-
grammatic areas that would help
provide insight into  state  experi-
ences.
   And yes, I, Ellen Frye, developed
and  conducted  the   survey  for
NEIWPCC, but not without accom-
plices. For one, I worked closely with
Patricia Ellis, a hydrologist with the
Delaware Department of Department
of Natural Resources and Environ-
mental Control's Tank Management
Branch and LUSTLine's "Wander-
LUST" columnist, to develop a draft
set of survey categories and ques-
tions.  (Pat has provided invaluable
input  for all three NEIWPCC sur-
veys.)
   The draft was circulated for com-
ments and further refinement to the
following dedicated group of state
LUST  program staff members: Gary

12
Lynn and Fred McGarry (NH), Read
Minor  (SC), Richard  Spiese (VT),
John Menotti (UT), Jeff Kuhn (MT),
Greg Hattan  (KS), Bruce Hunter
(ME), Tim Kelley (CO),  and  Kevin
Graves (CA). Input was also solicited
and received from  Kara Sergeant,
NEIWPCC's project manager for the
survey; Mike Martinson, Delta Envi-
ronmental (standards and cleanup
issues);  Bruce  Bauman, American
Petroleum Institute; and Blayne Hart-
man, H&P Mobile Geochemistry (for
soil vapor issues). Thank you one and
all!
   The completed  questionnaire
consists of the following 12 topic sec-
tions within which there  are a num-
ber of questions and subparts:
  1.  State Standards for
     Specific Gasoline
     Additives/Blends
  2.  Fuel Blend/Additive
     Analysis
  3.  Site Assessment
  4.  Drinking  Water Impacts
  5.  Remediation
  6.  Remediation Costs Impacts
  7.  Vapor-Intrusion Pathway
  8.  Hazardous Substance USTs
  9.  Heating Oil Tanks
10.  Out of Service Tanks
11.  Ethanol
12.  Miscellany
The Nature of the Beast
The survey differs from the previous
ones in that it is entirely electronic.
State LUST program contacts (or
other appropriate personnel) were
asked to complete it online by log-
ging in, protecting their information
by using their own password. Marcel
Moreau Associates  of  Portland,
Maine,  handled the electronic and
data management aspect of the sur-
vey. Although it was beta tested, the
substantial length of the survey, as
well as glitches that were not antici-
pated, made for a challenging jour-
ney to closure.  A few questions
posed problems because  answers
entered did not register. A consider-
able  amount  of time was spent
reviewing the survey responses in
order to follow up state submissions
with supplications for either clarifica-
tions or answers for the unanswered.
Betty Snowman of Marcel Moreau
Associates graciously and patiently
worked with me to manage the data-
base and  address problems as they
popped up.
   All 50 state LUST program con-
tacts or their designees logged in to
the survey. Keep  in mind  that
responding  to  this  survey  was
entirely voluntary.  Hence, we are
pleased to report that all states com-
pleted at least Section 1.  Only three
states  (IN, GA, LA) left  the survey
less than half completed. Forty-seven
states  substantially answered the
questions, and  some gave us an
amazingly thorough level  of detail
and thought. The goodwill and pro-
fessionalism of the state personnel
who  worked  on the survey  and
responded  to  our  questions  and
glitches was  truly remarkable!
   It  is important to note that by
their nature, many questions lend
themselves to judgments/estimates
based on the professional experience
of the respondent and  should be
taken as an indication of trend. All
state  representations  are  taken
directly from the database, except in
the rare instance when  a  personal
clarification was needed. All states
were given an opportunity to check
their answers.
   Given the fact that this survey
was designed to provide states with a
snapshot of what their peers in other
states are doing about relevant issues
at this point in time, we hope that
those  in the state UST/LUST pro-
grams will take the time to find out
how each other answered. Others in

-------
                                                                               August 2007 • LUSTLine Bulletin 56
the industry may also find the infor-
mation provided in the survey help-
ful in understanding state responses
to areas of interest. Some questions
parallel those asked  in 2003, and
some of the results are compared in
the  "State  Response  Summary"
attachment.  The  many comments
states made regarding these ques-
tions  are  of  particular   interest
because they provide nuance that
underlines the uniqueness of these 50
programs.  (Unfortunately,  some
comments were cut off due to charac-
ter limits programmed within each
question.) We hope that by conduct-
ing this survey,  more  states  will
begin to seek answers to the kinds of
questions we've asked.
   Besides finding out about what
kind of information states can pro-
vide, it is also worth pointing out that
there  are  many "don't  know"
responses that also tell us something.
It is not always clear whether a state
database does not have this informa-
tion,  whether it is  difficult  to
access...or what. When a state does
keep a thorough database, it has the
invaluable ability to call up informa-
tional and programmatic profiles that
can serve many purposes...like fill-
ing out surveys.

   To  see the full  report  go to:
http://www.neiwpcc.org/mtbe.asp
   The report has three important
Attachments:
  • Attachment 1 - "State Response
   Summary"

  • Attachment 2 - "State Standard
   Summaries"

  • Attachment 3 - "Contact List for
   State LUST Site Action Levels,
   Cleanup Levels,  and Drinking
   Water Standards"

  • Attachment 4 - "Compiled 2006
   Survey Results" for all the states.

A Brief Overview of
the Results

• State Standards for Specific
Gasoline Additives/Blends
   Section 1 of the survey consists of
17 questions, most of which with sub-
parts, that focus on gasoline addi-
tives and blends. Why do we care
about this?  Those who have been
dealing with LUSTs for more than 15
years will probably remember that
MtBE was barely, if ever, mentioned
in cleanup discussions in the early
days of the LUST programs. But that
changed as states began looking for
and finding MtBE in soil and ground-
water, particularly in RFC areas.
    Despite the fact that there wasn't
and  still isn't a federal MCL  for
MtBE, many states tried to address
the problem by adopting action and
cleanup levels based on the USEPA
Drinking Water Advisory or some
toxicity or risk-based criteria.  Now,
because of lawsuits, state bans, the
removal of the 2 percent oxygenate
mandate for  RFG as  part  of  the
Energy  Policy  Act of 2005, and
USEPA's subsequent rule to amend
the RFG regulations in order to elimi-
nate regulatory standards requiring
the use of oxygenates in RFG, MtBE
is  fast disappearing from gasoline.
But that doesn't mean that we're off
the hook and  back to analytical
basics.
    If there is one thing we should
have learned from MtBE it is that it is
a very good idea to pay attention to
the kinds of  compounds that  are
being added  or blended into our
gasoline, not only from a  specific
health risk point of view, but also in
terms of how that compound inter-
acts  with or  affects another com-
pound  in   that   gasoline   in  a
groundwater/soil setting.
    Through this  survey, we have
sought to better  understand how
much states are paying attention to
certain components of a gasoline
release, the occurrence and extent of
potentially harmful fuel additives
and blends in LUST-related soil and
groundwater  environs, and what
states have learned. The first section
of the survey asks questions about
state action levels, cleanup levels, or
drinking water standards for 12 dif-
ferent  compounds—MtBE,  TEA,
ethanol, TAME, ETBE, DIPE, EDB,
1,2 DCA, lead, TBF,  ETBA, and
TAA—and if states have standards,
what are they?
    Except for EDB, 1,2 DCA, and
lead, the compounds of interest in
this survey do not have federal MCLs
and thus may or may not have stan-
dards.  If they do have standards,
they are either risk-based or highly
variable  state-specific  standards.
Regarding MtBE, 41 states have stan-
dards  of some kind.  This time
around, Vermont has set the lowest
groundwater action level of 1 ppb for
MtBE, TEA, ethanol, TAME, ETBE,
and DIPE.
    Regarding TEA, ethanol, TAME,
ETBE, and DIPE, more states have
standards today than in 2003—for
TEA, 15 states indicated they have
standards  versus  7 in  2003;  for
ethanol, 7 states indicated they have
standards  versus  4 in  2003;  for
TAME, 11 states indicated they have
standards versus 4 in 2003; for ETBE,
10 states indicated they have stan-
dards versus 3 in 2003; and for DIPE,
11 states indicated they have stan-
dards versus  6 in 2003. A few more
states indicated that action levels for
some of these compounds are in the
works.
•   Fuel Blend/Additive Analysis
    According to state responses in
this section, 11 states receive informa-
tion on the composition of fuels in
their  state,  and  that  information
comes primarily from state weights
and measures  offices.  This section
seeks  more information on if, when,
and for what fuel blends/additives
states require sampling  and analysis
in groundwater  and  soil. Again,
MtBE  gets the  most attention,
although EDB,  1,2 DCA, and lead are
getting some attention on a site-spe-
cific basis in gasoline. When asked
how often, during sampling events at
their LUST sites, groundwater sam-
ples are analyzed for  each  of  the
group of compounds of interest, 31
states   selected  the   option   of
81%-100% of the time for MtBE; the
other  compounds were substantially
lower in frequency.
    This section asks about detection
limits/analytical  methods for  the
various compounds  of interest in
groundwater and soil.  The  "State
Response  Summary"  provides a
chart  that shows the state responses
for groundwater.  For example, the
chart  shows that USEPA SW-846
Method 8240/8260 (GC/MS) is the
most widely used method  for all of
the analytes. Within this  method,
detection limits range from 0.2 to 70
ppb for MtBE. For EDB, however,
this method is used as well as USEPA
Drinking   Water  Method    524
(GC/MS), SW-846 Method 8011, and
USEPA Method 504.

               • continued on page 14

-------
 LUSTLine Bulletin 56 • August 2007
m NEIWPCC's 2006 Survey
from page 13

 •   Site Assessment
     This section asks states about
 various aspects of site assessment.
 Asked if  they are using  USEPA
 TRIAD  or similar expedited  site-
 characterization approaches,  10 states
 said "yes," 2 said "most of the time,"
 22 said "no," 15 said "rarely," and
 one "don't know." Asked if they use
 advanced  site characterization tech-
 nologies  (e.g.,  MIPS,  geophysical
 investigation), 12 states said "yes," 1
 said "most of the time," 10 said "no,"
 and 26 "rarely." With regard to ques-
 tions on considering diving plumes
 and conducting vertical characteriza-
 tion of groundwater at LUST sites,
 most states do this on a site-specific
 basis. Fourteen states say they see
 constituents other than MtBE in div-
 ing plumes.  Thirty-one states say
 they use a 10-foot monitoring well
 screen interval.  Other  questions
 address cross-contamination inci-
 dents, changes in observed MtBE lev-
 els as the compound exits gasoline,
 and frequency with which contami-
 nants exceed action levels. This sec-
 tion also contains a series of charts
 that document hotspot levels for the
 compounds of concern, levels  at
 receptors,  and distances  between
 hotspots and receptors.

 •   Drinking Water Impacts
     Due to the very mutual interests
 of drinking water/groundwater pro-
 tection and UST/LUST programs,
 this section has a line of questioning
 meant to ascertain how much state
 drinking water and LUST programs
 communicate and share information.
 The survey responses indicate that
 there is communication between pro-
 grams at some level, but it doesn't
 appear that many states have made a
 concerted  effort to connect. Thirty-
 four states say they give cleanup pri-
 ority to sites located in source water
 protection areas, another seven say
 they do sometimes.
     In 2003, 24 states reported that
 their   drinking  water  program
 requires routine analysis for  MtBE in
 drinking water. (This number was
 the same in 2000.) In this 2006 survey,
 21 states say their drinking water
 program requires routine analysis for
 MtBE. But there is another option in
 this survey that wasn't in the previ-
ous surveys—"not required, but ana-
lyzed"—which eight states checked
off.
    A summary chart for questions 4-
6 provides information on numbers
of private, public community, and
private  non-community wells that
have been contaminated with MtBE.
Fifteen states did not know or did not
have access to information. In com-
paring the results from the 2003 and
2006 surveys, the 2006 numbers were
slightly lower in the private and pub-
lic community well categories, except
for numbers of wells ranging from
500 to more than 900. In 2003, two


 Through this survey, we have sought to
     better understand how much
  states are paying attention to certain
      components of a gasoline
  release, the occurrence and extent of
       potentially harmful fuel
  additives and blends in LUST-related
    soil and groundwater environs,
    and what states have learned.
states answered that they had more
than  500 MtBE-impacted private
wells. In 2006, three states had 501 to
700 MtBE-impacted wells and two
states had more than  900 MtBE-
impacted wells. One state had more
than 900 impacted public community
wells  and one  state  had 501-700
impacted public  non-community
wells.
    We attempted to find out if any
of the other compounds of interest
had impacted  wells. While most
responses were "don't know," there
were a few cases of impacts by TEA,
TAME,  EDB,  and  1,2  DCA.  Two
questions address whether or how
many private well users have been
provided with bottled water or point-
of-use treatment or if private wells
have been replaced with new wells or
public  water   because  of  fuel
blends/additive contamination.


•  Remediation
    In this section we attempted find
out about state  experiences with
remediating EDB, 1,2 DCA, and E10
and E85.  While this section is heavy
with  "don't  knows,"  this  was
expected  because, especially  for
ethanol, states don't have much expe-
rience. For example, eight states have
remediated sites with EDB and/or
1,2 DCA contamination and provide
information on  technologies used
(primarily pump and treat and  soil
vapor extraction) and if they worked
(looks good). With regard to ethanol
releases, a few states have noted  fate
and transport characteristics associ-
ated  with cosolvency,  anaerobic
groundwater,  methane gas genera-
tion, and remobilization of  NAPL.
This section also has a group of ques-
tions concerning NAPL removal  and
allowable levels for closure.   We
asked respondents to rate effective-
ness of  free-product removal tech-
nologies.  Excavation,   multiphase
extraction, and soil vapor extraction
had the highest ratings.


•   Remediation Cost Impacts
    We  asked  states to indicate the
percentage of sites where MtBE has
had a noticeable impact on the cost of
remediation. This set of answers is
provided in a table. While a large
portion of states feel MtBE  has
caused  no increase in the cost of
remediation, there are a number of
states that feel that MtBE increases
costs at  some sites a little bit, signifi-
cantly, and very significantly.  We
asked about increased cleanup costs
associated with other compounds of
interest. Again,  while most states
said "no," a few others said "yes,"
especially for  TEA, EDB, 1,2 DCA,
and lead. Top factors that drive up
costs include longer plumes, longer
monitoring period, and substance
recalcitrance.
•   Vapor-Intrusion Pathway
    Forty-one states say that vapor
intrusion is a concern at LUST sites in
their state. Twenty-eight states have
guidance/policy for evaluating the
vapor-intrusion pathway. Ten states
say they are considering implement-
ing vapor-intrusion pathway guid-
ance. States provided websites if they
have guidance.


•   Hazardous Substance USTs
    When asked how many federally
regulated hazardous substance (non-

-------
                                                                                    August 2007 • LUSTLine Bulletin 56
petroleum) USTs are registered in
their state, 18 states answered, "don't
know"  or didn't answer. This  is
partly because these tanks are some-
times regulated  under  a  different
state  program. But with  18 states
answering "don't know," all hopes of
getting any sense  of the total number
of hazardous substance USTs in the
United States faded.  Nevertheless, 34
states have provided this informa-
tion.  They also provided state web-
sites  if  the state  has  developed
guidance/regulations for hazardous
substance USTs (at least 32 have) and
an indication of how frequently these
tanks  are  inspected.  Very   few
releases from these tanks have been
reported and thus there was little
information about product released
and no information on fate and trans-
port.  We asked  about these tanks
because  there is  so  little at all  said
about them; however, most are now
aboveground.


•  Heating Oil Tanks
    Many states do not rely on heat-
ing oil and therefore do  not have to
worry about heating oil tanks. North-
ern states are most likely to have  sub-
stantial numbers of heating oil tanks,
especially  home  heating oil tanks.
Some  of these  tanks  are  buried
underground,  some  are  outdoors
aboveground, and others are indoors
in a basement or shed.  There is no
question that heating oil tanks leak.
In many cases realtors and/or banks
have  pushed for  the removal of
buried tanks, instead placing them
indoors or outdoors in  a well-con-
structed system where owners can
see them. But to the extent that we
were able to get information from the
states on heating oil tanks for  this
survey, we have to admit it is sketchy
from a big picture perspective.  The
fact that most heating oil  tanks either
are not regulated or are minimally
regulated  explains  why  so  many
states  couldn't really answer  the
questions in this section.
    On the heating oil cleanup side,
18 states have a state fund that covers
heating oil tanks in some form or
fashion. Five states have some other
type of fund that  helps out when
needed. There is  a little bit of infor-
mation on the percentage of cleanup
fund  monies spent on  heating oil
tanks and the percentage of UST
releases that come from heating oil
tanks.

•   Out of Service Tanks
    We asked states about numbers
of tanks in the following categories of
out-of-service  tanks—Temporarily
Closed (legal), Permanently Closed
(closed in place or removed) (legal),
and Orphaned/Abandoned (out of
service but not properly closed with
or without known responsible party).
We got very  good hard data  from
most of the states. We wanted to pro-
vide a national snapshot of where the
states are now with these tanks. Nine
state answered "don't  know"  for
temporarily closed and seven for per-
manently   closed;  however,   the
remaining state responses give us a
good sense of the magnitude of tanks
that have been permanently closed
and the large number of temporarily
closed tanks that are being monitored
and inspected pretty  much in  the
same way as in-service tanks. A few
states noted that  these tanks can be
problematic during property transfer
or if owners/operators don't follow
the rules when they  put tanks in
temporary  status.  The  orphaned/
abandoned tanks are less well docu-
mented, but 22 states have estimates
or hard numbers for these tanks as
well. Seventeen states  indicated that
they  have  programs to  remove
orphaned/abandoned tanks.
•   Ethanol
    One thing  seems  clear  with
regard to ethanol and USTs: we are in
the early stages of understanding
what this substance will mean to fuel
storage systems and the potential for
releases and the effect of a release on
the environment. In this survey, 34
states said that E85 is used in their
state. Clearly, there are just a few
here and there in each case. Only two
states, Iowa and Minnesota, knew of
E85 releases in their state. On a  more
general level, 14  states  said  they
knew of ethanol  releases  in  their
state, from E10 to neat ethanol. On
ethanol compatibility issues states
still know more about concerns they
have read about than that they have
seen. Michigan  expressed  concern
that tank owners would not consider
compatibility issues  before filling
tanks with E85 and that not all E85
tanks are registering as required.
•   Miscellany
    We asked states to rank the pri-
mary ways releases are identified/
reported in their state. Tank removal
was ranked highest, followed by
property transfer and leak detection.
We asked  states  to rank tank leak-
detection methods. Top ranking was
interstitial monitoring, followed by
automatic tank gauges and tank tests.
We asked states to rank piping leak-
detection methods. Top ranking was
electric LLDs, followed by  piping
tests,  interstitial  monitoring,  and
mechanical LLDs.
    Seventeen states said they have a
pay-for-performance (PFP) program.
Delaware is just getting started. But it
doesn't appear that PFP is chugging
along in most of those states. Only
two states  indicated they use PFP at
76-100  percent of their sites.  The
remaining states said they used it at
1-25 percent of their sites.
    Only five states said their UST
leak-prevention rules address MtBE
vapor releases. However, 16 states
said they  have sites where vapor
releases are believed to be the source
of contamination.
    Finally, responses  to the  last
question in the  survey show  that
more than 30 states consider the com-
pounds  of concern in this  survey
other than MtBE to be a current,
impending, potential, or unknown
problem. •
• Impact of Ethanol from page 11

11. Wilson, J.T.; ChO/ J. S.; Wilson, B. H.; Vardy, J. A.
   2000. Natural Attenuation of MTBE in the Sub-
   surface under  Methanogenic   Conditions.
   EPA/600/R-00/006.
12. Wilson, J.T.; Kaiser, P.M.; Adair, C. 2005. Moni-
   tored Natural Attenuation of MTBE as a Risk
   Management Option at Leaking Underground
   Storage Tank Sites. EPA 600/R 04/179.
13. Wilson, J.T.; Adair, C.; Kaiser, P.M.; Kolhatkar, R.
   Anaerobic biodegradation of MTBE at a gasoline
   spill site. Ground Water Monitoring and Remedia-
   tion. 2005, 25(3), 103-115.
14. Somsamak, P.; Richnow, H.H.; Haggblom, M.M.
   Carbon isotopic fractionation during anaerobic
   biotransformation of methyl tert-butyl ether and
   tert-amyl methyl ether. Environmental Science &
   Technology. 2005, 39(1), 103-109.
15. Kuder, T.; Wilson, J.T.; Kaiser, P.; Kolhatkar, R.;
   Philp, P.; Allen, J. Enrichment of stable carbon and
   hydrogen isotopes during anaerobic biodegrada-
   tion of MTBE:  Microcosm and field evidence.
   Environmental Science & Technology. 2005,39(1),
   213-220.
16. Mormille, M.R.; Liu, S.; Suflita, J.M. Anaerobic
   biodegradation of gasoline oxygenates: Extrapola-
   tion of information to multiple sites and redox
   conditions. Environmental Science & Technology.
   1994, 28(9):1727-1732.


                               15

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LUSTLine Bulletin 56 • August 2007
                                A MESSAGE FROM CLIFF ROTHENSTEIN
                                Director, U.S. EPA Office of Underground Storage Tanks

                                Two  Years  After  the
                                Energy  Policy Act
                                  It seems like only yes-
                                  terday, but on August
                                  8, 2007, we celebrated
                                the two-year anniversary
                                of the signing of the
                                Energy Policy Act, a law
  that included about 40 pages of new requirements that have
  significantly changed the Underground Storage Tank (UST)
  program. Since that time, it has been a very interesting, excit-
  ing, and busy two years for all of us.
    At EPA, we have been issuing guidelines, while throughout
  the country, state UST managers have been working overtime
  to meet the new requirements. Our tribal  partners have also
  been busy helping us implement our new tribal strategy. All
  of our state and tribal partners as well as many other stake-
  holders deserve kudos for their tireless efforts to  meet the
  numerous deadlines and requirements of the Energy Policy
  Act.
    I  know it hasn't been easy to inspect all previously unin-
  spected tanks in your states by this August, while at the same
  time also running your existing programs, but because of
  your efforts, much has been accomplished during this short
  period. So I will  briefly highlight just some of our accom-
  plishments with regard to our grant guidelines and our new
  tribal website.

  EPA's New Energy Policy Act Grant
  Guidelines
  Over the past two years, OUST staff and managers were hard
  at work developing new grants guidelines. With the help of
  EPA regions, states, and other stakeholders, we have met
  every statutory deadline so far and have issued more than a
  half dozen new guidelines. These guidelines provide  the foun-
  dation for states to develop their own specific programs for
  meeting the Energy Policy Act requirements.
    Many of the new guidelines are  aimed at further reducing
  UST petroleum releases to the environment. For instance, the
  Secondary Containment guidelines we issued in November
  2006 require new or replaced USTs, piping, and dispensers
  within 1,000 feet of drinking water to  be secondarily con-
  tained. The Operator Training guidelines we issued in August
  2007 require that those who operate UST  systems,  including
  emergency responders, be trained by 2012.
    The Inspection guidelines we issued  in April 2007 require
  that all federally regulated USTs be inspected every three
  years. The Delivery  Prohibition guidelines we issued in
  August 2006 spell out the process and procedures for pro-
  hibiting fuel delivery to USTs that are out of compliance. And
finally, the Financial Responsibility and Installer Certification
guidelines that we issued in January 2007 outline the finan-
cial responsibility requirements for UST installers and manu-
facturers.
   While these guidelines are aimed at improving our UST
programs and helping to prevent future releases, issuing
these guidelines is just the tip of the iceberg. The hard work
really begins as states develop their own programs and reg-
ulations to implement the guidelines. We are also crafting a
process to develop regulations that will help ensure consis-
tency of the implementation of the Energy Policy Act require-
ments in Indian country. So while we have all been busy
during the past two years, the next two years promise to be
just as eventful.

OUST's New Tribal Website
Access to information is among the most important steps
we can take to ensure a successful  program. So, to provide
better and more readily available information to our partners
in Indian country, OUST launched a new UST tribal website
in July 2007. The website at www.epa.gov/oust/tribalpro-
vides tribes and others with UST program, resource, and
training information in one convenient place. Most impor-
tantly, it is a central information resource about the UST pro-
gram in Indian country,.
   The  website includes links to EPA's August 8,  2007,
report to Congress on the status of implementing the UST
program in Indian country. In addition to  facts about cleanup
and compliance progress, the report highlights several tribal
success stories that we can all be proud of.
   While the report to Congress is essentially a snapshot of
our past accomplishments, the new website includes a link
to OUST's tribal strategy, which describes our plans for the
future. The strategy, published in August 2006, identifies the
objectives and numerous actions that EPA and tribes can
take to further tank program cleanup and compliance in
Indian country.
   Besides important information on funding, training, and
other available resources, the website also provides a conve-
nient compilation  of UST laws, regulation, guidance, poli-
cies, and OUST's "how to" publications, information for UST
inspectors, and information from other EPA offices, includ-
ing the American Indian Environmental Office (AIEO).
   While OUST's new tribal website provides a wealth of
information, primarily about  USTs, AlEO's  new website
www.epa.gov/indian, and  the new Tribal Portal on EPA's web-
site www.epa.gov/tribalportal, will further enhance the infor-
mation flow so we can more effectively run our programs.H
16

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                                                                           August 2007 • LUSTLine Bulletin 56
   from Robert N. Renkes, Executive Vice President, Petroleum Equipment Institute (PEI)
New AST Overfill  Prevention  Document
Available from PEI
      Early in January 2005, freezing rain and snow fell
      in the  Midwest for days.  The precipitation
      caused the normal and emergency vents at a
 bulk plant to freeze shut. As the transport driver was
 making his delivery into a 15,000-gallon aboveground
 tank at the bulk plant, the tank ruptured, forcing gaso-
 line out a 9-inch gash. Product went over the dike wall
 and into the intake of the transport truck engine. It also
 covered the driver, who was standing near the truck.
 The engine ignited the gasoline. The fire spread from
 the  refined-fuel  storage area to  propane delivery
 trucks. Officials estimated that over 10 million gallons
 of water were used to cool the storage vessels. The
 transport driver died as a result of his injuries.

     Error in judgment resulting in tank overfills or
 over-pressurization is the most common cause of a fuel
 release to the environment from an aboveground stor-
 age tank. In many cases, the volume of fuel released is
 small and the consequences are minor, although clean-
 ing up a release can still be costly. Occasionally, how-
 ever, the volume  released is  very  large and  the
 consequences are catastrophic, resulting in personal
 injuries, large fires, and extensive property damage.

     Filling an aboveground storage tank offers several
 unique challenges. First, the transfer of large quantities
 of fuel  into the tank usually involves a variety of
 pumps, pipes, valves, and controls, which are often
 unique  to each storage-tank facility. Second, the only
 person  typically on site to manage the fuel-transfer
operation is the tank-vehicle driver. Finally, there have
not been adequate industry standards for fuel-transfer
procedures and equipment for the driver and facility
owner to reference.

    The Petroleum Equipment Institute, recognizing the
need for a comprehensive reference guide that the indus-
try and regulators could use to minimize aboveground
tank overfill incidents, has published a new document
entitled Recommended Practices for Overfill Prevention
of Shop-Fabricated Aboveground Tanks (PEI/RP600).
The goal of the document is to:
 • Prevent loss of life

 • Protect the environment

 • Promote best practices for safely transferring fuel
   into tanks

 • Prevent overfills

 • Prevent damage to property resulting from overfills

 • Minimize costs from cleanups and remediation.

    The recommended practice is limited to the installa-
tion, operation, inspection, maintenance, and testing of
overfill-prevention equipment used on shop-fabricated,
stationary,  and  atmospheric  aboveground  tanks
intended for the storage or supply of liquid petroleum
and alternative fuels. The recommended practices may
be applied to tanks used for:
           • Bulk storage

           • Motor-fuel dispensing

           • Emergency-generator systems

           • Residential and commercial heating-oil
              supply systems

           • Used-oil storage systems.

         If you either regulate or manage aboveground
      storage tanks, this publication will serve as a valu-
      able reference.  PEI/RP600-07 is copyrighted and
      may not be photocopied or otherwise reproduced.
      Order copies  online  at www.pei.org.shopping
      or  request an order form by calling PEI at
      918-494-9696. •

      Overfilling of tanks can have catastrophic consequences.
      Proper delivery procedures and overfill-prevention equipment
      are required to protect against overfill incidents.
                                                                                                 17

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LUSTLine Bulletin 56 • August 2007
 FAQs  from  the  NWGLDE
 ... All you ever wanted to know aboHtl
                                                              ,id to ask.
 What  Is CITLDS Leak Detection All  About?
  In this issue of FAQs from the National Work Group on Leak Detection Evaluations (NWGLDE), we follow-up on a FAQ from LUST-
  Line #50 (August 2005). At that time we discussed protocols used for evaluating CITLDS without explaining what CITLDS leak
  detection is all about. We now present the rest of the story. (Please note: the views expressed in this column represent those of the
  work group and not necessarily those of any implementing agency.)
Q
      What exactly is a CITLDS?

      CITLDS stands for "Continuous  In-Tank Leak-
      Detection System." It is a volumetric leak-detection
      method that does not require an extended shut-
      down period in order to conduct a leak test. The sys-
      tem gathers pieces of data from all designated input
      devices during tank "quiet time" and then performs
      the leak-test calculations when enough data have
      been recorded. The term continuous, in this situa-
      tion, implies that data are collected on a regular basis
      and when available. Most CITLDS methods employ
      the use of an  Automatic Tank Gauge ("ATG") to
      gather product-level data and some use additional
      information from input devices such as the  dis-
      penser totalizers and point-of-sale records.
      CITLDS are well suited to facilities that are open
      24/7, as long as the volume of product sold from the
      storage system does not exceed the throughput limit
      of the CITLDS method. There must be sufficient data
      collected in order to perform the leak-test calcula-
      tions. For example, if there is not enough "quiet
      time," then not enough data will have been collected
      to complete a test. If enough suitable data have not
      been collected during the month to perform a leak
      test, the tank system must be shut down and a "sta-
      tic" test performed.

      Why are there two separate line entries in the "List"
      index for Continuous In-Tank Leak Detection Sys-
      tems?
      Currently there are two types of CITLDS methods
      on the NWGLDE List. These types are referred to as
      CITLDS "Continuous Automatic Tank Gauging"
      and CITLDS "Continual Reconciliation." The pri-
      mary distinction between these two is that the ATG
      systems use only product-level data to conduct a test
      and are most similar to standard, or static, ATGs that
      test only the tank. Reconciliation systems use both
      product-level  data and sales data to see if the  vol-
      ume of fuel dispensed from the tank, as measured
      from ATG readings, is equal to the volume of fuel
      measured by the meter in the dispenser.
      "Continuous Automatic Tank Gauging" systems use
      an ATG probe to collect data  during tank "quiet
      time." An algorithm  then combines data from a
      number of such periods until there is enough evi-
      dence to make a determination about the leak status
      of the tank. Because these systems typically monitor
      only the liquid level in the tank, they test only the
      tank, not the piping. This type of system functions
    like an ATG, except that it does not require the tank
    to be taken out of service for a set period of time
    whenever a test is conducted. Instead, it uses data
    from shorter, stable time periods and combines the
    results to estimate a leak rate. If sufficient good-qual-
    ity data has not been obtained over the month, the
    system may be programmed to default to a static or
    shut-down ATG test which requires the tank to be
    out of service for a few hours.
    "Continual Reconciliation" systems combine contin-
    uous product-level and  temperature monitoring
    from the  tank with data  from dispensing meters.
    Data from delivery and point-of-sale records may
    also be included. Because of multiple-device data
    input, the system is  capable of detecting leaks or
    unexplained losses of product from the tank, pres-
    surized lines, or even dispensers. In addition, it can
    combine data from times when the tank is static (no
    dispensing  activity)  as well as when the tank is
    active to monitor  the system for a leak. (For a more
    in-depth discussion of "Continual Reconciliation,"
    refer to "Continual Reconciliation Applications for
    Active Fueling Facilities" on page 4 of this issue of
    LUSTLine.
    All CITLDS methods are volumetric and designed to
    operate continuously  or  nearly continuously in
    order to collect the necessary data for the determina-
    tion of a quantitative leak rate. They may use differ-
    ent combinations  of data and inputs but they share
    the same  characteristic of monitoring tank and/or
    other data continuously for days, weeks, or months,
    and then  providing leak-detection capabilities and
    leak status on demand once the initial data require-
    ments are met. •

About the NWGLDE
The NWGLDE is an independent work group comprising 10 members,
including 9 state and  1 U.S. EPA member. This column provides
answers to frequently asked questions (FAQs) the NWGLDE receives
from regulators 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 determine if each eval-
uation was performed in accordance with an acceptable leak-detection
test method protocol and ensure that the leak-detection system meets
USEPA 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 equivalency standards stated in the USEPA standard test proce-
dures.
• Make the results of such  reviews available to interested parties.
18

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                                                                       August 2007 • LUSTLine Bulletin 56
STI-Labeled UST Warranty to
be Reduced  to  10 Years
    The Steel Tank Institute/Steel
    Plate  Fabricators  Association
    (STI/SPFA) has changed the
limited warranty requirements of all
STI-labeled USTs, effective January 1,
2008, from a 30-year to a  10-year war-
ranty duration. The new warranty
was to take effect on July 1, 2007;
however, the organization deter-
mined that  "an industry-wide back-
log of orders made it  prudent to
postpone the start of the new war-
ranty and eliminate marketplace con-
fusion," according to Wayne Geyer,
Executive Vice President  of STI/
SPFA.
   Geyer explains that the need for a
30-year warranty duration on STI-
labeled USTs has  diminished as the
storage tank market has changed,
                              moving away from predominantly
                              single-walled USTs to increased
                              demand  for aboveground storage
                              tanks (ASTs) and, with regard to
                              USTs, a trend  to  larger-capacity
                              tanks, fewer tanks overall, and an ele-
                              vated demand for production of sec-
                              ondary-containment  USTs   and
                              compartmented tanks.
                                 A 30-year warranty is almost
                              unheard of for  any manufactured
                              product. As Geyer  explains in the
                              STI/SPFA newsletter Tank Talk, even
                              a 10-year warranty is a very substan-
                              tial guarantee for a specific product
                              line.  According to Geyer, "In an
                              industry  that  is  manufacturing
                              underground tanks for hazardous
                              substance storage, particularly in this
                              time  of new and evolving fuels, a
10-year limited warranty is a very
proactive approach in showing sup-
port for steel tank owners and is con-
sistent  in  length   with   other
petroleum equipment warranties."
   The warranty only covers either
the  replacement of the  warranted
tank with a new tank of the same size
and design, the repair of the tank, or
a refund of the original purchase
price. While most tank manufacturer
warranties  are similar,  with STI-
labeled tanks the manufacturer pur-
chases a warranty policy from a
third-party  insurance company. The
tank is not self-warranted by an indi-
vidual  manufacturer. Third-party
coverage is significant, since many
tank manufacturers have come and
gone since 1988.
   To read the details as explained
by STI/SPFA, see the June 2007 issue
of Tank Talk at www.steeltank.com. •
                           Call  for Abstracts!
                                                               There is still time to submit
                                                                   an abstract or idea.
                                                                  Check our website for
                                                                      more details!
WM> Annual .\attonal
TRNKS CONFERENCE
                     >EXPO
               I ~^A.  *• •* Im \
ANEIWKC SB*
                               The 20th Annual National Tanks Conference & Expo
                               will be held on March 17-19 in Atlanta, Georgia.
                               "^ Submit your abstract or idea!
                               "^ Propose a workshop or training session!
                               "^ Reserve booth space or poster session space!
                               Send any questions to: NTCinfo@neiwpcc.org
                                          NEW CONFERENCE WEBSITE-
                                       www.neiwpcc.org/tanksconference
                                  Subscription Form
   Name
   Company/Agency.

   Mailing Address _
   E-mail Address
   J 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
                                                                                           19

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     Update on USEPA Progress and State Deadlines
               Regarding Implementing the
       Underground Storage Tank Provisions of the
               Energy Policy Act of 2005
Energy Policy Act
Requirement
Inspections
Secondary Containment
or Financial Responsibility
Delivery Prohibition
State Compliance Reports
on Government-Owned
USTs
Public Record
Operator Training
Tribal Strategy
Indian Country USTs
Report to Congress
EPA Issued Grant Guidelines/
Tribal Strategy and Report
4/24/07
11/15/06
1/22/07
8/7/06
4/24/07
1/22/07
8/8/07
8/7/06
8/8/07
Deadlines for States
to Implement Requirements
8/8/07 - first inspection deadline
8/8/10 -three-year inspection deadline
2/8/07 - implement either secondary
containment orfinancial responsibility
8/8/07 - implement delivery prohibition
8/8/07 - report on the compliance status of
federal, state, and local-government owned
and operated USTs
10/1/07 - develop a program for gathering
information and begin gathering data
12/08 - make the public record available to
the general public
8/8/09 - develop state-specific operator train-
ing requirements
8/8/12 - ensure all three classes of operators
are training according to state-specific
requirements
(not applicable to states)
(not applicable to states)
LU.S.T.UNE
New England Interstate Water
Pollution Control Commission
116 John Street
Lowell, MA 01852-1124

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