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
-------
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,
-------
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
-------
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.
-------
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.
-------
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.
References
1. Wiedemeier, T.H.; Rafai, H.S.; Newell, C.J.; Wilson,
J.T. 1999. Natural Attenuation of Fuels and Chlori-
nated Solvents in the Subsurface. John Wiley & Sons,
New York, pp. 115-216.
2. Powers, S. E.; Hunt, C. S.; Heermann, S. E.;
Corseuil, H. X.; Rice, D.; Alvarez, P. J. J. The trans-
port and fate of ethanol and BTEX in groundwater
contaminated by gasohol. Critical Reviews in Envi-
ronmental Science and Technology. 2001, 31 (1), 79-
123.
3. Ruiz-Aguilar, G. M. L.; Fernandez-Sanchez, J. M.;
Kane, S. R.; Kim, D.; Alvarez, P. J. J. Effect of
ethanol and methyl-tert-butyl ether on monoaro-
matic hydrocarbon biodegradation: Response vari-
ability for different aquifer materials under various
electron-accepting conditions. Environmental Toxi-
cology and Chemistry. 2002, 21, 2631-2639.
4. Corseuil, H. X.; Hunt, C. S.; Dos Santos, R. C. P.;
Alvarez, P. J. J. The influence of the gasoline oxy-
genate ethanol on aerobic and anaerobic BTX
biodegradation. Water Research. 1998,32,2065-2072.
5. Da Silva, M. L. B.; Alvarez. P. J. J. Effects of ethanol
versus MTBE on BTEX migration and natural
attenuation in aquifer columns. ]ournal of Environ-
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.
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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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