New England Interstate
Water Pollution Control
Commission
www.neiwpcc.org/lustline.htm
116 John Street
Lowell, Massachusetts
01852-1124
Bulletin 57
November
2OO7
LOST. JNE
A Report On Federal & State Programs To Control Leaking Underground Storage Tanks
^^^^^^^^M
It's Always Something
That Element of Surprise in
Analyzing for Gasoline
Compounds
Petroleum products—gasoline, diesel fuel, heating oil—
are composed of hundreds of chemicals, some of which
are present in crude oil and some not. Fuels contain
various classes of compounds. The bulk of the fuel is com-
posed of petroleum hydrocarbon constituents that are
either present in crude oil or in very similar compounds
produced by refining (e.g., iso-octanes). The refineries
blend these compounds into a finished product according
to complex requirements derived from regulation, crude-oil
type, component abundance, and operating characteristics.
Additives are used for a wide variety of purposes. Some,
for example, are detergents required by the Clean Air Act
Amendments (CAAA) of 1990. Because fuel additives are
proprietary, we know little about their properties and envi-
ronmental behavior.
At the beginning of the underground storage tank pro-
gram our approach to site assessment at a fuel-release site
was to look for benzene, toluene, ethylbenzene, and
xylenes (BTEX). This was a logical approach for three key
reasons: benzene is a carcinogen; many gasoline com-
pounds have a very low effective water solubility; and
highly volatile compounds are quickly lost to the atmos-
phere. However, this approach began to change when
methyl terf-butyl ether (MtBE) usage and releases became
common in reformulated gasoline after the passage of the
CAAA.
Most of us now know that MtBE was used earlier as an
octane booster to replace leaded additives. Although some
warnings about MtBE were raised, most people in the
LUST program were unaware of the impending problems
this chemical would cause. And MtBE isn't the only fuel
additive whose use has resulted in unpleasant surprises:
ethers such as fert-amyl methyl ether (TAME), di-isopropyl
ether (DIPE), and to a lesser degree ethyl tert-butyl ether
(ETBE), and alcohols such as tertiary-butyl alcohol (TEA),
What is in these gasoline free-product samples-BTEX?
MtBE? 1BA? 1,2 DCA? TAME? DIPE? EDB? ETBE?...
ethanol, and methanol can also be found in various petro-
leum products.
As we've learned from New England Interstate Water
Pollution Control Commission surveys of state LUST pro-
gram experiences, many states don't analyze for these
compounds. (See LUSTLine #56, "The Results of
NEIWPCC's 2006 Survey of Tank Programs...") Because
the ethers are used to boost octane, they have been used in
conventional gasoline. Some states that may have thought
they didn't have these chemicals because they were not
required have been surprised.
And we're on the verge of another surprise—the lead
scavengers. These compounds, which were used until the
• continued on page 2
Inside
21) TEA, Go Away!
5() What About 1,2-DCA?
7() Musings on the UST Challenges of the Future
9Q The Gospel According to Phil
13() Egads, Not a Test!
14Q California Field Study on ATG and LLD Systems
14() Update on Bad Gas in West Virginia
16() STI Online Recertification for Cathodic-Protection Testers
-------
LUSTLine Bulletin 57 • November 2007
• Analyzing for Gasoline
Com pounds from page 1
late 1970s to prevent lead precipita-
tion on engine components, have per-
sisted in groundwater to this day.
So, it has become apparent that
our traditional approach to site char-
acterization does not serve us well for
anticipating problems and prevent-
ing exposure to chemicals in gaso-
line, including BTEX. (See articles on
monitoring wells, LUSTLine #42, and
diving plumes, LUSTLine #36.)
Just as we've taken some strides
to improve our site-characterization
approach by embracing new tech-
nologies (e.g., direct push sampling)
and employing "unconventional"
techniques (e.g., installing nested
monitoring wells to look for diving
plumes), we can also improve our
ability to prevent pollution from
LUST sites by evaluating product
composition in more detail than we
have previously. This suggestion can
take many forms. Some state pro-
grams, such as in Maine, are actively
monitoring the composition of petro-
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 ae
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
LoweU, MA 01852-1124
Telephone: (978) 323-7929
Fax: (978) 323-7919
lustline@neiwpcc.org
$S) LUSTLine is printed on Recycled Paper
i (NEIWPCC). It is produced through i
^operative agreement (#T-830380-01)
leum product that comes into their
states. This provides a statewide per-
spective on fuel composition.
Nationally, research into fuel
composition, as being undertaken by
USEPA ORD, is revealing previously
unknown aspects of fuel composi-
tion, even for conventional gasoline
and traditional chemicals such as
BTEX. At the site level, judgment is
needed for the use of all advanced
technologies, including product char-
acterization. A few judiciously cho-
sen product analyses may provide us
with the information we need to bet-
ter protect public or private drinking
water sources.
The following two articles, from
Minnesota and Delaware, provide
good examples of the kinds of sur-
prises that can pop up when a state
LUST program ventures beyond the
comfort of conventional thinking and
heads out on the road to enlighten-
ment.
TBA, Go Away!
by Patricia Ellis
Most LUSTLine readers probably know that I've been crusading against
MtBE (or rooting for an MtBE ban) for more than ten years. USEPA's Blue
Ribbon Panel on MtBE recommended that MtBE in gasoline be phased out
or its use substantially curtailed. Though it didn't happen, through the years more and
more states climbed on the "Ban MtBE" bandwagon, either because they saw impacts
to the groundwaters of their states, or because it was a way to increase ethanol usage.
Delaware proposed banning MtBE during several legislative sessions, but to my disap-
pointment, each time they failed to bring the issue up for vote. The Energy Policy Act of
2005, while not banning MtBE, accomplished much the same result by not granting
protection from lawsuits claiming that MtBE was a defective product. Between not
being protected from lawsuits and the requirement for increased use of renewable fuels,
refiners and blenders dropped MtBE like a
hot potato. To me, it wasn't quite as satis-
fying a way of getting MtBE out of the
gasoline, but at least the end result has
been nearly the same.
a *v>*3;f:
MtBE—Leaving a Legacy?
It's been a little over a year since
MtBE disappeared from Delaware's
gasoline (April-May 2006). Many of
my newer LUST sites started show-
ing significant decreases in MtBE
concentrations fairly quickly after its
disappearance, and some are just
now starting to show declining
trends in MtBE in the groundwater.
We'll get rid of it eventually. But I'm
still faced with another problem—
high levels of recalcitrant fert-butyl
alcohol (TBA). As a matter of fact,
some sites have shown massive
increases in TBA concentrations in
groundwater samples as the MtBE
has declined.
-------
November 2007 • LUSTLine Bulletin 57
Some of the sites show the classic
high levels of MtBE followed by a
decrease in MtBE concentrations and
a corresponding increase in TEA con-
centrations, indicating biodegrada-
tion of the MtBE to TEA. But what I
don't often see is a subsequent drop
in TEA levels as the MtBE supply is
exhausted and TBA-degrading bacte-
ria have kicked into high gear. TEA
seems to increase and stay high, or
increase and continue increasing.
Come on bugs, you can do it. It's
alcohol and doesn't smell or taste
nearly as bad as MtBE!
A few years ago, John Wilson,
from USEPA's Ada, Oklahoma lab,
performed some isotope analyses of
groundwater samples from one of
my sites. The results showed that
approximately 95 percent of the
MtBE had degraded under anaerobic,
methanogenic conditions. Unfortu-
nately, I now have a site with TEA
levels as high as 1,650,000 ppb TEA.
We've blasted the site on several
occasions with massive amounts of
an oxygen-releasing compound, and
managed to get respectable levels of
oxygen dissolved in the groundwa-
ter. The MtBE continues to decline,
but the TEA is definitely not showing
signs of going away.
I've got a number of other sites
where all other chemicals of concern
are below our cleanup levels, but
hundreds of thousands of parts per
billion TEA remain in the groundwa-
ter. Delaware's Risk-Based Correc-
tive Action (RBCA) program sets its
cleanup goals based on distances to a
point of compliance, rather than just
whether there are any specific recep-
tors within reach. One point of com-
pliance is the property boundary.
This was done specifically to mini-
mize impacts to other properties.
We can also justify closing a site
if a stable or shrinking plume can be
demonstrated, but on many of these
sites, the TEA really isn't showing
signs of decreasing. Our TEA stan-
dard is an action level, not a cleanup
number, but I really want to have
some sort of a warm fuzzy feeling
before I'll close a site, and a million
parts per billion doesn't make me feel
warm or fuzzy.
We're now armed with a new
guidance document from the Ameri-
can Petroleum Institute (API) for
evaluating the natural attenuation of
MtBE (Technical Protocol for Evaluat-
ing the Natural Attenuation of MtBE,
API Publication 4761, May 2007,
http://www.api.org/ehs/groundwater/ox
ygenates/upload/4761 new.pdf). How-
ever, when I apply these protocols to
TEA, the data indicate that the TEA is
not naturally attenuating to any sig-
nificant extent.
[See also LUSTLine #34, February
2000, "Tertiary Butyl Alcohol (TEA):
MtBE May Not Be the Only Gasoline
Oxygenate You Should be Worrying
About" by Steve Linder.]
Developing Action
Levels/Cleanup Standards
Which brings us to the question—
How do we come up with action lev-
els/cleanup levels for a chemical if
these levels are normally generated
by starting with some sort of
health-based information? The 2006
NEIWPCC Survey of State Experiences
with Petroleum and Hazardous Sub-
stance Releases at LUST Sites, Heating
Oil Sites, and Out of Service Tanks had
• continued on page 4
TABLE 1
A summary of the result of state responses to a question on state standards for
TBA in the 2006 NEIWPCC Survey of State Experiences with Petroleum and Hazardous Substance
Releases at LUST Sites, Heating Oil Sites, and Out of Service Tanks
State
CA
CT
DE
FL
KS
MA
Ml
MO
GW Action
Level
140 ppb
43 ppb
1000 ppb
3900 ppb
286 ppb
GW Cleanup
Level
1400 ppb
43 ppb
Soil Action
Level
0.05 ppm
100 ppm
78 ppm
0.563 ppm
Soil Cleanup
Level
5. 7 ppm
Primary Drinking
Water Std.
12 ppb
100 ppb
3900 ppb
Secondary Drinking
Water Std.
State (or other)
Advisory
NC Detection limit for all categories -Violation if exceeded
NH
NJ
NY
SC
VT
WY
1400 ppb
1ppb
2200 ppb
40 ppb
100 ppb
2200 ppb
4. 10 ppm
50 ppb
1400 ppb
-------
LUSTLine Bulletin 57 • November 2007
• Analyzing for Gasoline
Compounds - TBA/rom page 3
a question dealing with TEA soil and
groundwater action levels, cleanup
levels, and drinking water standards.
A number of states said that their
TEA numbers were site specific,
while many more states evidently are
not yet dealing with TEA. Judging
from the range of values in Table 1,
which summarizes the numbers from
the states that provided them, we've
all chosen different methods to come
up with our numbers. (See LUSTLine
#56 for more information about the
survey.)
I developed the Delaware num-
bers a few years ago (which are still
in draft form), using the only health-
based information that I could find at
the time, which happened to be the
California number. California had a
drinking water advisory level of 12
ppb, considering TEA as a probable
carcinogen. According to the 2005
survey that Mike Martinson of Delta
Environmental has on USEPA's web-
site, the California number is now an
enforceable Provisional Action Goal
http://www.epa.gov/swerustl/mtbe/oxyt
able.pdf.
I used that value to back-calculate
a reference dose, and then ran that
number through our RBCA software
to arrive at soil and groundwater
action levels. More recent evaluations
of the health risks associated with
TEA say that the mechanisms on
which the California number is based
are specific to rats and that the same
mechanism doesn't operate in
humans. Other studies find that the
kidney tumors induced in rats in that
study could be used for human risk
assessment. The study in question
(Cirvello et al, 1995) included such
phrases as "some evidence of carcino-
genicity" in male rats based on..., but
"no evidence of carcinogenicity" in
female rats; and "equivocal evidence
of carcinogenicity" based on...; and
"some evidence of carcinogenicity" in
female rats based on..." So who's to
say that I'll behave as a rat when
exposed to TEA?
There are two major recent com-
pilations of TEA health studies of
which I am aware. The first is a com-
pilation prepared by ENVIRON and
published by the American Petro-
leum Institute (Hazard Narrative for
Tertiary-Butyl Alcohol (TEA). API
Publication Number 4743, October
2005, http://www.api.org/ehs/ground-
water/upload/4743finalpdf). In that
study, analysis of various studies
resulted in a reference dose (RfD) of
220 micrograms/kg/day. Assuming
an average body weight of 70 kg and
an average daily water consumption
of 2 liters, the average drinking water
concentration for TEA associated
with the RfD would be approxi-
mately 8 mg/L. From Table 1, you
can see that no state has action levels,
cleanup levels, or drinking water
numbers as high as those that would
be generated from the Reference
Dose in the API report. I have not
tried to contact any of these states to
see how their numbers were
derived—I tried that once with MtBE
and it was a futile effort.
Five years from now we don't want to
be kicking ourselves because we
closed a few hundred (or thousand)
sites with significant TBA impacts that
we didn't think could cause a problem.
The second compilation, pre-
pared by the Production High Vol-
ume Chemicals Branch of EPA's
Office of Pollution Prevention and
Toxics (Screening-Level Hazard Charac-
terization of High Production Volume
Chemicals - t-Butyl Alcohol), was re-
leased in August 2007 and can be
accessed at http://iaspub.epa.gov/
oppthpv/hpv_hc_chamcterization.get_re
port (TEA is listed as 2-Propanol,2-
methyl-).
Among the conclusions of the
study are the following statements:
(l)TBA is not readily biodegradable in
the environment; (2) two carcinogenic-
ity studies provide some evidence for
carcinogenicity of t-butyl alcohol, and
(3) the potential health hazard of t-
butyl alcohol is moderate based on the
results of the repeated-dose and repro-
ductive / developmental toxicology. I
don't want it in my drinking water. Do
you want it in yours?
We're still waiting for a more
definitive health number from
USEPA for MtBE. According to the
USEPA document Regulatory Deter-
minations Support Document for
Selected Contaminants from the Second
Drinking Water Candidate List (EPA
Report 815-D-06-007, Chapter 14:
MtBE, http://www.epa.gov/safewater/
cd/pdfs/reg_determine2/report_cd2-
reg2_supportdocument_chl4_mtbe.pdf),
the health-risk assessment for MtBE
was scheduled for completion in
April 2007. The IRIS-tracking report
states that the MtBE assessment was
started in 1998, and the final edited
version is now scheduled for comple-
tion in 2009.1 guess I shouldn't hold
my breath until it's done.
USEPA is doing a literature
review on the health effects of TBA.
But in the meantime, I believe that we
need to err on the conservative side
to be protective of human health.
TBA doesn't have that early warning
stink that MtBE has, so we can't
expect people to stop drinking it
because they taste or smell it in their
water. Five years from now we don't
want to be kicking ourselves because
we closed a few hundred (or thou-
sand) sites with significant TBA
impacts that we didn't think could
cause a problem.
Oh, Did I Say MtBE Is Gone?
I am a member of Jim Weaver's
(USEPA ORD, Northeast Regional
Lab, Athens, Georgia) gasoline sam-
pling crew. He is studying the
regional and seasonal differences in
gasoline composition, RFG and non-
RFG areas, and which oxygenates are
being used in what areas. I recently
received the results of the February
2007 sampling and was amazed to
still see MtBE in several of the
Delaware gasoline samples eight or
nine months after we thought it
would be gone.
Both of the samples where MtBE
was detected were of 93 octane gaso-
line, and MtBE was detected at 0.21
and 0.44 percent, by volume. Neither
of the stations are very high-volume,
and I suspect that the operators of
both of these stations did not follow
our recommendations about having
their tanks cleaned prior to the switch
to ethanol, but I was still surprised
that after all these months, the MtBE
was still present. According to Jim,
some of the samples collected in
other areas also showed low levels of
MtBE, but it wasn't common. I've just
completed the August 2007 gasoline
sampling. I'll be curious to see if
we've managed to dilute it out of
those tanks by now.
For now, I'll just sit back and see
if any of my new groundwater analy-
-------
November 2007 • LUSTLine Bulletin 57
ses for ethanol will manage to exceed
the TEA numbers I've seen.
Ah....almost! I've got 1,300,000 ppb
ethanol in MW-2! At least I think that
the ethanol will disappear soon, but
it may have managed to remobilize
free product that we hadn't seen in
the last few years, because the free
product in some of the wells seems to
have a weathered look about it. •
Patricia Ellis, PhD., is a hydrologist
with the Delaware Department of Nat-
ural Resources and Environmental
Control, Tank Management Branch.
She writes the LUSTLine column,
"WanderLUST," and can be reached at
Patricia.EHis@state.de.us.
References:
Cirvello, J.D., Radovsky, A., Heath, J.E., Farnell, D.R.,
and Lindamood, C. 3rd (1995) Toxicity and carcino-
genicity of t-butyl alcohol in rats and mice follow-
ing chronic exposure in drinking water. Toxicol. Ind.
Health 11(2): 151-165.
Never Mind EDB, What About 1,2-DCA?
Minnesota's Curious Little Piece of the Puzzle
by Mark Toso
As state regulators, working the day-to-day grind of site remediation, we often only see what's happening in our own little
worlds. Because of this, we sometimes have information we've picked up along the way that could be beneficial to others but
that gets lost in the shuffle or filed away when the next big project comes along. This occurred to me one day while reading
through some past issues o/LUSTLine. While a few articles made it pretty obvious that there was a heightened national concern over
the leaded gasoline additive ethylene dibromide (EDB), my first reaction was: "Never mind EDB, what about 1,2-DCA?" (See LUST-
Line issues #47, "Lead Scavengers: A Leaded Gasoline Legacy?," #50, "What South Carolina Is Learning about Ethylene Dibromide
at LUST Sites," and #51, "Leaded Gasoline? Hmm, What's in Those USTs?")
Our Long-Term Scavenger
Hunt
Recent articles and presentations at
the National Tanks Conference by
other states (particularly South Car-
olina) have emphasized the need to
expand groundwater analysis to
include the leaded-gasoline additives
EDB and 1,2-dichloroethane (1,2-
DCA). In Minnesota we've been for-
tunate to have some very forward-
thinking people in our environmen-
tal programs. Since the creation of
our LUST program in 1987, volatile
organic compound (VOC) analysis
using USEPA method 8260 has been
required for all first-round ground-
water sampling. Our VOC-parameter
list was designated by our Health
Department lab and included the
leaded-gasoline additives EDB and
1,2-DCA (and with even more
impressive foresight, MtBE in 1989).
Although it's likely our VOC sam-
pling requirement was implemented
to screen for nonpetroleum contami-
nants (more than one chlorinated
plume was discovered this way),
we've been keeping track of EDB and
1,2-DCA for a long stretch.
As reported previously in LUST-
Line, both EDB and 1,2-DCA were
part of the tetraethyl lead (TEL) addi-
tive package designed to remove
excess lead from gasoline-engine
combustion chambers. Since 1942,
these two compounds were added in
molar ratios with lead that resulted in
almost equal quantities, ranging from
0.27 - 0.34 g/L, (Falta, June 2004). An
interesting side note is that EDB is
added to aviation gasoline because
chlorine from 1,2-DCA in the exhaust
would be corrosive to aluminum air-
frame parts. And since TEL was only
added to increase the octane rating
for gasoline engines, it would never
have been used in any turbine engine
(jet) fuels, which comprise the vast
majority of aviation fuels used today.
Minnesota's experience with
these two additives is that EDB is not
a significant problem. An informal
survey of Minnesota Pollution Con-
trol Agency (MPCA) petroleum-
remediation program staff found that
while we have numerous examples
of drinking water wells that are cont-
aminated with 1,2-DCA, only two are
known to contain EDB (up to 1.4
ug/L). In both cases, the 1,2-DCA
concentrations were much higher
than the EDB and also exceeded the
state drinking water standard of 4
ug/L (the federal MCL is 5 ug/L). In
addition, routine analysis of public
water supply wells by the Minnesota
Department of Health, using method
8260B, has never detected EDB; how-
ever, 1,2-DCA has been detected in
26 wells.
Looking Harder and Meaner
for EDB
Because of the extremely low drink-
ing water standards for EDB (0.004
ug/L state HRL and 0.05 ug/L fed-
eral MCL), the elevated detection
limits with method 8260B were a con-
cern. We began to think that perhaps
EDB was persistent below detection
levels, which typically are in the 0.4-
1.0 ug/L range. So when the USEPA
Office of Underground Storage
Tanks (OUST) in collaboration with
the USEPA Office of Research and
Development (ORD) got word out
that it was looking for leaded-gaso-
line release sites to sample for low-
level EDB using EPA method 8011
through the Kerr Environmental
Research Lab, we were more than
happy to participate.
One site we submitted repre-
sented a typical scenario seen in Min-
nesota. In the beautiful north central
city of Alexandria, a large petroleum-
distribution terminal is situated
above an aquifer consisting of pre-
dominantly sand, occurring from 80-
120 feet below grade. Separating this
deep aquifer from a shallow surficial
aquifer is a confining unit consisting
of clay-rich till that is 30-40 feet thick.
The deep aquifer is considered the
sole source for the city and surround-
• continued on page 6
-------
LUSTLine Bulletin 57 • November 2007
• Analyzing for Gasoline
Compounds - MN from page 5
ing area, and downgradient from the
terminal it is contaminated with 1,2-
DCA, but not EDB.
Since the terminal is located just
inside the city limits, approximately
300 deep-aquifer wells were
impacted in new residential develop-
ments outside the city. We have been
tracking 1,2-DCA concentrations of
up to 8.0 ug/L in select offsite wells
in this area; several have exceeded
the state standard of 4 ug/L (MCL is
5 ug/L). These levels have remained
relatively consistent over the last 12
years. The front edge of the plume
has been migrating slowly to the cur-
rent maximum extent of 3,200 feet
downgradient (ironically, the few
residences that have shallow sand-
point wells have no contamination).
With the exception of the rare,
extremely low-level detection of a
BTEX compound, 1,2-DCA was the
only compound detected.
The highest 1,2-DCA concentra-
tion seen in any onsite deep well was
20 ug/L, again without any
detectable EDB. The last EDB detec-
tion at the site was in a shallow
aquifer well in June 1994 at 1.2 ug/L.
There have been no detections of 1,2-
DCA in a shallow-aquifer well since
April 1999. This could be the result of
various remediation systems that
have operated entirely in the shallow
aquifer since the early 1990s.
A total of eight well samples
were submitted to the Kerr Environ-
mental Research Lab for low-level
method 8011 EDB analyses. Of these,
two were onsite-monitoring wells,
and the remaining six were offsite
private wells. These wells were all
selected based on historical detection
of 1,2-DCA. All samples were also
analyzed for VOCs using EPA
method 8260B. As shown in Table 1,
all but one well had a detection of
1,2-DCA. However, the 8011 analysis
did not detect EDB in any of the wells
at a level of 0.010 ug/L.
And the Winner Is... 1,2-DCA
As is typical of what we experience in
Minnesota, the 1,2-DCA outlived all
the other VOCs at this site. While the
degradation of these two additives in
leaded-gasoline releases is not well
understood, it's clear that at least in
Minnesota, EDB is attenuating at a
rapid rate and 1,2-DCA is not. In fact
our experience has been that of all the
VOCs we analyze for at petroleum-
release sites, 1,2-DCA is the longest-
lived, most traveled compound
we've seen. It may even rival MtBE
for risk to drinking water supplies
(incidentally, MtBE was found in the
onsite deep wells beginning in 2003).
Why Minnesota's data seem to
contradict those of states such as
South Carolina, where EDB is more
prevalent, is a puzzle. This is espe-
TABLE 1 Benzene, 1 ,2-DCA, MtBE, and EDB in the Deep Aquifer
Alexandria Terminal, April 24, 200?
Well ID
HRL/HBV
Cemetery Shop
31 3 Agnes
Jerry's Bar
708 Kinkead
903 Van Dyke
1007 Van Dyke
MW-57D
MW-58D
Distance of well
from site (ft)
1215
1125
900
1665
2475
2790
-
-
Benzene
5
ND
ND
ND
ND
ND
ND
ND
ND
1,2-DCA
4
2.4
ND
3.6
2.5
2.1
1.8
8.2
6.0
MtBE
70
ND
ND
ND
ND
ND
ND
68
11
EDB
0.004
ND
ND
ND
ND
ND
ND
ND
ND
All results in pg/l = micrograms per liter
Analysis by Method 8260B except EDB by method 8011
ND = Not detected
HRL = Minnesota Department of Health, Health-Risk Limit
HBV = Minnesota Department of Health, Health-Based Value
dally interesting when you consider
that we see the same results across a
wide variety of geologic settings (i.e.,
glacial, carbonate, and igneous
bedrock formations). Perhaps there
are some significant differences in
geochemistry (there is the obvious
difference in temperature) or some
other factor. It's known that EDB had
been used as an agricultural pesticide
more widely in South Carolina and
that there might even be more recent
leaded-racing-gasoline releases than
Minnesota.
So far, there is nothing to suggest
that we need to make a change in our
investigation and cleanup policy.
However, if you are concerned about
EDB and not currently sampling for
1,2-DCA, you might want to think
about reevaluating your strategy.
And stay tuned for additional infor-
mation as we plan to develop this
and several other case studies as part
of the national evaluation of leaded-
gasoline scavengers.
But That's Not Quite the End
of Our Story
It's always something! We have also
been seeing occasional detections of
1,2-dichloropropane (1,2-DCP), which
is usually found associated with 1,2-
DCA. Often the levels are right at the
detection limits of method 8260B, but
some have been as high as 46.5 ug/L
(MCL is 5 ug/L). While one of the
listed uses of 1,2-DCP is as a lead
scavenger, a major manufacturer of
TEL additives claims its use was
extremely limited. There is the possi-
bility that 1,2-DCP is produced as a
byproduct during the manufacture of
1,2-DCA. However, there was appar-
ently an acute shortage of 1,2-DCA
between 1957 and 1960, and 1,2-DCP
was used as a replacement. This may
hold promise for dating some old
releases. We plan to investigate this
further as well. •
Mark Toso is a hydrogeologist with the
Minnesota Pollution Control Agency
in St. Paul. He can be reached at
mark.toso@pca.state.mn.us or
651-297-8669.
References
Falta, R. W. and Bulsara, N. 2004. "Lead Scavengers:
A Leaded Gasoline Legacy?" LUSTLine, New Eng-
land Interstate Water Pollution Control Commis-
sion. Bulletin 47, pp. 6-10, 2004, Mtp://www.neiwpcc.
org/lustlineMm
-------
November 2007 • LUSTLine Bulletin 57
W.
McCaskill
David McCaskill is an Environmental Engineer with the Maine Department of
Environmental Protection. "Tanks Down East" is a regular feature of
LUSTLine. David can be reached at David.Mccaskill@maine.gov.
As always, we welcome your comments.
,0$
While hypnotized by the gentle wash of waves on a pocket beach, numbed by the cold Labrador Current as it swept across the Gulf of
Maine, I got to thinking (heaven help me!) about tanks...about where the whole business of tanks and groundwater salvation and reg-
ulations was heading. And maybe with the various UST provisions of the Energy Act 0/2005 the future may be smoother than the
past 20 years, once we get that initial beach sand out of our shoes. When I finally snapped to, I decided it was time to start writing and
throw out some questions that we might want to ponder concerning the possible and probable future challenges that we face in our lit-
tle esoteric world of USTs and LUSTs. After all, if we don't ask the questions, we won't be able to answer them. If we don't answer
them, we might find some of those waves washing right over us.
Will Secondary Containment
Ever Contain?
As many avid LUSTHne readers
know, there have been various stud-
ies in California and New Hampshire
concerning vapor leaks and the
extreme measures needed to reduce
them. Will we need vapor-tight sec-
ondary containment for everyone?
Years ago we were asking the same
question about run-of-the-mill, liq-
uid-tight secondary containment.
"Vapor-tight" secondary wasn't even
in our lexicon back then! Here in
Maine, we moved to secondary con-
tainment in 1991, and now the
Energy Act will practically require it
nationwide. A good thing, but will
we now need a new generation of
secondary containment? One with
more expensive vapor-tight tanks,
piping, containment sumps, and
double-walled spill buckets to ensure
that our ever-vulnerable drinking
water supplies are protected?
Oh well, we are only in the 21st
century, a place that was always in
the future and where all problems
were supposed to be solved. And we
are only talking about storage of the
most dangerous and toxic and flam-
mable liquid that we routinely come
in contact with throughout our daily
lives. Why worry?
Who Owns These Tanks?
In the old days—and for all practical
purposes, we are talking about some
30 years ago in Maine—the "seven
sisters" major oil companies owned
most of the service-station tanks.
Now the majors have moved on to
tend their crops out in the Gulf,
North Sea, and North Slope, leaving
the feeding stations to the large oil
jobbers and mom 'n pops. In Maine,
it was basic market share, or lack of
it, that seemed to move the majors
out of our territory.
Also in Maine, as I would expect
elsewhere in the country, we've got
the very capable oil jobbers and mom
'n pops and then we've got those that
the Operator Training requirements
of the Energy Act will hopefully help
to become capable. With this change
of tank ownership we are also chal-
lenged with communicating with
some folks who are not fluent in the
language of the rules with which they
must comply. Being a nation of immi-
grants, this is not a new challenge.
But, considering the technical nature
of these rules, all training and infor-
mation will need to be clear and intu-
itive.
Will We Recognize the Right
Problem and Have the Right
Solution?
Are we going to be smart enough to
recognize the next MtBE or the next
flex-pipe fuel-compatibility issues
and head them off before they
become problems? Many of us are
already thinking about ethanol, espe-
cially E85, and its fate and transport
and equipment-compatibility issues.
Good training for the folks in charge
of forecasting the future! Maybe, as
was pointed out at the last "states
only" session during the 2007 Tanks
Conference, USEPA should sponsor
some/more up-front research on
these issues. We did get the message
that EPA will come up with some
UST component/ethanol compatibil-
ity guidance.
• continued on page 8
-------
LUSTLine Bulletin 57 • November 2007
• Tanks Down East/rom page 7
How Many Times Do We
Clean Up a Site?
First it was BTEX, then MtBE, and
now it's TEA and EDB and 1, 2-DCA.
What's next? Back to the future with
ethanol-mobilized BTEX plumes?
Know thy contaminant and thy risk!
What Happens When the Rug
Is Pulled Out from Under Us?
It has happened in the past. So it will
be true in the future. Some tank and
pipe companies will go out of busi-
ness, leaving the owners with little or
no technical support. And what
about the miles of first-generation,
recalled, flex pipe left in the ground
long after the manufacturer has gone
out of business?
And what about warranties? In
Maine, we require tanks to be
removed at the end of their warranty.
This is usually 20 years for cathodi-
cally protected (CP) steel tanks
installed before October 1985 and 30
years for most other tanks—be they
CP steel, fiberglass-reinforced plastic
(FRP), or jacketed steel. Now the
Steel Tank Institute has limited its
warranties to 10 years. Now what?
Who's next? What's next?
In Maine, we have documented
about a dozen (and more on the hori-
zon) cases where a double-walled CP
or jacketed-steel tank's primary shell
has been breached due to internal
corrosion. The good news is that the
secondary containment worked and
nothing got into the environment.
But the bad news is that the owner
only got 15 years of life out of the
tank, rather than the warranted 30
years.
I recall the sagely prognostica-
tion of one of my colleagues 20 years
ago when he said, "Now that we are
protected against external corrosion
we'll start seeing internal corrosion."
If double-walled tanks are leaking
from internal corrosion at 15 years,
might not the single-walled tanks be
leaking as well? We have now insti-
tuted a policy to take water samples
at the tap of convenience stores with
single-walled CP tanks located
within 300 feet of a private well.
Maybe we'll catch some horse-out-of-
the-barn leaks before they run too far.
8
What about Those Errant
Delivery Drivers?
Many states have trained UST tank
installers and inspectors and, thanks
to the Energy Act requirements, will
hopefully be training operators, but
what about delivery drivers? These
are the folks who are responsible for
safely filling tanks and preventing
spills and overfills. To my knowl-
edge, there are currently neither
requirements for that sort of training
nor any regulatory hook to hold them
accountable.
Talk about being out of the loop!
Who's going to train these folks? Our
spill-response records rank overfills
as the leading source of releases from
all tanks—above or below ground.
We recently sponsored an overfill
module as part of a half-day industry
hazmat training session for heating
oil and transport truck drivers, which
was organized by the Maine Oil
Dealers Association. This federally
required hazmat training deals with
placarding and emergency response
and is also a good way to get much-
needed UST and AST overfill train-
ing to the drivers, since they are
gathered together and in training
mode already. The feedback on the
training was positive, and we plan to
continue this collaboration with the
Maine Oil Dealers Association.
As part of the Energy Act deliv-
ery-prohibition requirements there is
a regulatory hook that makes deliv-
ery drivers liable for filling out-of-
compliance ("red tag") tanks. This
seems to be a good start toward get-
ting them involved in the UST regu-
latory chain, but in order to actually
prevent overfills in the future they
need to be trained, as well.
Will We Ever Get Spill
Buckets Right?
Spill buckets—they are not just
future problems; they are ongoing
problems in the here and now!
Florida's Leak Autopsy Study shows
that spill buckets in that state have a
relatively short working lifespan. I
shudder to think what the lifespan of
the spill bucket is here in Maine, with
sand and salt continuously washing
into them during the winter months,
not to mention snow plows playing
hockey with their puck-shaped lids.
Coupled with malfunctioning
and misused overfill devices, releases
at this human/UST system interface
will no doubt persist. Will double-
walled 15 gallon spill buckets solve
the problem? In Maine, we have a
requirement that all new and replace-
ment spill buckets have a capacity of
15 gallons to hopefully capture the
contents of the delivery hose when
delivery "mistakes" are made. (See
"Small Spills Count The Spill
Drill," LUSTHne #49). I guess now we
need to contemplate the prospect of
double-walled spill buckets. We per-
severe
Out Over the Horizon
Woven throughout the future of the
UST program are the provisions of
the Energy Act—and any subsequent
provisions. We will likely see both
positive and perhaps not so positive
effects. I believe that since many of
the provisions in the Act were
already on our wish list, the future
problems may be more predictable in
our regulatory minds. As far as the
unforeseen problems are concerned,
maybe we, as states, territories, and
tribes, should come together with our
brain trust of knowledge and peer
out to the horizon with an eye to
preparing for any gathering storms,
rather than blithely wait for future
problems to wash up and over us. •
•Snapshots from
• • • • the Field • • • •
Midwest "Biowillie"
Dispenser
-------
November 2007 • LUSTLine Bulletin 57
nically Speaking
by Marcel Moreau
Marcel Moreau is a nationally
recognized petroleum storage specialist
whose column, Tank-nically Speaking,
is a regular feature o/LUSTLine. As
always, we welcome your comments and
questions. If there are technical issues
that you would like to have Marcel
discuss, let him know at
marcel.moreau@juno.com
The Gospel According to Phi
"Be Sure You Know What
You Are Talking About!"
One of my best and most
respected mentors during the
mid 1980s, when I was a reg-
ulator at the Maine Department of
Environmental Protection, was a ser-
vice station owner named Phil. This
was back in the days when a gas sta-
tion was a place you went to get your
car fixed and to buy gasoline, but not
to buy beer and groceries. Phil was
active in his industry and was a fre-
quent spokesperson for the state's
gasoline retailers, so we often found
ourselves on opposite sides of tank
regulatory issues. But because of a
deep respect for one another, these
differences often led to great debates
and discussions rather than great ani-
mosity.
As I began to investigate the
more or less newly recognized tank
problem in the state, Phil was one of
the first people I visited to learn more
about the tank owner's perspective
on tank issues. I remember he took
me into a cramped office that was
just barely big enough for a desk and
talked to me about the challenges of
running a service station. He told me
about some of the tricks attendants
used to steal money from him or his
customers, how to keep customers
coming back ("Always tell them the
truth"), and, very importantly for me,
how to keep fuel-inventory records.
Phil had a shelf full of binders with
many years worth of carefully
detailed fuel-inventory records. He
kept inventory not because anybody
said he had to but because he thought
anybody who didn't was foolish.
And Phil was definitely no fool.
I recall one day, over a drink, he
leaned across the table, and I saw
from the look in his eye that he had
something important to say. "Do you
know who you are when you walk
into a gas station?," he asked. I was a
bit stumped; I wasn't sure what he
was driving at. "Well," I began
slowly, "I guess I am a representative
of the state."
"No," he said. "That may be the
way you see yourself, but to the per-
son on the other side of the counter or
desk, you are GOD." I must have
looked somewhat puzzled, because
Phil went on to explain. "When you
walk in to a gas station, the owner or
attendant believes that you have the
power to do anything you want to his
• continued on page 10
-------
LUSTLine Bulletin 57 • November 2007
• Tank-nically Speaking
from page 9
business, and that whatever you say
is the law. So you'd better know what
you're talking about."
There have always been, and
there always will be, business owners
who have little respect for regulators
or regulations. But there is also a sig-
nificant percentage of tank owners
who generally strive to do the right
thing. It is this latter group that tends
to hear the regulator's word as
gospel. These are also the people who
complain to me about situations
where regulators have given them
various erroneous or illogical inter-
pretations of regulatory require-
ments. When I ask them why they
don't point these things out to the
regulators, there is typically a shrug
of the shoulders, a look of resigna-
tion, and silence. In the silence I hear
Phil's answer: "What can we do ...?"
Consider some of the complaints
concerning regulators I have heard of
late.
The Mistaken Swing Joint
A regulator inspected a new tank
installation and refused to approve it
because of a couple of elbows con-
nected by a short length of pipe. Tra-
ditionally, this combination of
fittings was known as a swing joint,
and it was used to provide flexibility
for galvanized steel piping. Swing
joints are generally not acceptable as
a means of providing flexibility, but
in this particular case, the fittings
were installed not to provide flexibil-
ity (the piping was flex pipe) but to
facilitate the alignment of the pump
outlet with the flexible piping. Thus
while the fittings used were those of
a traditional swing joint, the function
of the fittings was completely differ-
ent—and completely acceptable.
In this case, the inability of the
regulator to differentiate between the
two uses of the fittings (providing
flexibility versus aligning the piping)
caused much gnashing of teeth on
the part of the installer.
The Redundant Ball Float
There are a number of tank installa-
tions where both ball-float valves and
drop-tube shutoff overfill devices are
installed. To be clear, this is a practice
I would discourage, but that is a topic
for a different article. Because they
10
treat both of these devices as overfill-
prevention devices, there are regula-
tors who require that the ball float be
set at 90 percent of tank capacity and
the shutoff device at 95 percent.
When only one of these devices is
installed in a tank this is reasonable,
because this is one version of what
the tank rules require when these
devices are installed for overfill pre-
vention.
When both devices are installed,
however, locating the ball float at 90
percent and the shutoff device at 95
percent is a problem, because the
ball-float valve will operate first,
since it is set at a lower level in the
tank. Once the ball float closes and
reduces the fuel flow into the tank,
the shutoff device is essentially dis-
abled. This is because the flow rate of
the fuel down the drop tube is
reduced to less than what is required
to close the shutoff valve.
Not only is the shutoff valve ren-
dered useless, the hapless delivery
driver who fills the tank past the
point where the ball float closes will
be in for a rude surprise. Because the
driver likely observed that a shutoff
valve was installed, he would reason-
ably assume that the shutoff device
was the overfill device on the tank.
While a shutoff device allows a dri-
ver to drain the delivery hose very
soon after the shutoff device oper-
ates, a ball float requires a substantial
delay to relieve the pressure in the
tank. If the driver mistakenly
assumes that he is dealing with a
shutoff valve rather than a ball float,
and does not wait before he discon-
nects the hose, he will likely get a
bath in fuel as the backpressure in the
tank forces product out of the hose.
(For more information on the opera-
tion of ball floats, see LUSTline #21,
December 1994, "What Every Tank
Owner Should Know About Overfill
Prevention.")
It is for these reasons that PEI
RP100-05, Recommended Practices for
Installation of Underground Liquid
Storage Systems warns against the
installation of ball-float valves lower
than the activation point of a drop-
tube shutoff valve (Section 7.3.3). An
incomplete understanding of the
operation and function of equipment
by regulators can create hazardous
situations. While the tank manager
who told me this story opted not to
install the ball float at all as a result of
this requirement, other, less informed
owners may have to pay the price of
a delivery spill because of misguided
regulatory policy or interpretation.
Needless to say, the regulator's credi-
bility with the regulated community
also suffers.
To Lift a 42-Inch Manhole
Cover
There is at least one state that wants
to include as part of its operator
training information the recommen-
dation that operators visually inspect
submersible pumps on a weekly
basis. There are many hazards associ-
ated with inspecting submersible
pumps. For starters, there is a sub-
stantial traffic hazard because the
tank pad is frequently located in a
traffic area, the lids are often difficult
to remove and heavier than many
store personnel can safely handle—
and there could be flammable vapors
present. Frequent removal of the lids
will also encourage the omission of
seals and gaskets that help to keep
precipitation out of secondary-con-
tainment sumps. Is inspection of sub-
mersible pumps an appropriate task
for store clerks and facility man-
agers?
The PEI UST Inspection and
Maintenance Committee discussed
the issue of submersible pump
inspection in producing PEI RP900,
Recommended Practices for the Inspec-
tion and Maintenance of UST Systems.
(See "Field Notes" on page 13.) The
Committee decided that large man-
way inspection was too hazardous to
be conducted by store personnel. The
document recommends that such
below-grade components be in-
spected annually by qualified per-
sonnel (e.g., service technicians), not
store personnel.
I agree with the RP900 Commit-
tee that routine visual inspection of
submersible pumps by store person-
nel is a practice to be avoided rather
than encouraged. Regulators who
promote such a practice ignore basic
safety and common-sense considera-
tions. From its inception, the goal of
the tank program has been to protect
human health and the environment.
Let us not forget that human health
comes first. The "safe" way to keep an
eye on submersible pumps is to install
them in liquid-tight sumps with con-
tinuously monitored sensors.
-------
November 2007 • LUSTLine Bulletin 57
Electronic versus
Mechanical LLD
Another state is proposing that all
line-leak detectors (LLDs) shut down
the submersible pump when a 3 gal-
lon per hour leak is detected. This
change would essentially force a
switch from mechanical to electronic
line-leak detectors. Now generally
speaking, I think this is probably a
good way to go. Electronic line-leak
detectors offer the ability to periodi-
cally test for smaller leaks as well as 3
gallon per hour leaks, and have diag-
nostic features that can facilitate trou-
bleshooting. There are some
situations, however, where mechani-
cal LLDs may have an edge over elec-
tronic ones. This is because electronic
LLDs generally take a longer time to
detect 3 gallon per hour leaks than
mechanical ones.
Many electronic LLDs incorpo-
rate a multiple-test feature to help
reduce false alarms due to tempera-
ture effects in the piping. Remember
that volume changes due to tempera-
ture are a significant cause of false
alarms in mechanical LLDs. (See "Of
Blabbermouths & Tattletales, The Life
and Times of Line Leak Detectors,"
LUSTline #29, June 1998).
Because volume changes due to
temperature diminish over time,
repeating a test cycle is a good way to
distinguish temperature effects from
real leaks. If the measured volume or
pressure loss diminishes over time, it
is likely due to temperature. If the
measured volume or pressure loss is
consistent over time, it is likely due to
a leak. So, although not declaring a
leak until several tests have been run
is a good way to evaluate whether
temperature effects are influencing
the results of a test, it takes time to
run these multiple tests.
The test cycle of electronic LLDs
is generally interrupted if a customer
activates the pump to dispense fuel.
This means that a period of several
minutes of uninterrupted quiet time
sufficient for several tests to be run is
generally required for a leak to be
declared. One brand of electronic
LLD requires upwards of 10 minutes
of uninterrupted quiet time to
declare a leak. At very high-volume
facilities, this amount of quiet time is
going to be infrequent at best, if it is
present at all.
While very active facilities pose
problems for both mechanical and
electronic LLDs because the pumps
are "on" most of the time, there is no
question that most electronic LLDs
require a longer time to find 3 gallon
per hour leaks (minutes) than
mechanical LLDs do (seconds). (See
"The Trouble with Truck Stops,"
LUSTline #56.) Thus for very active
facilities, mechanical LLDs may be a
better choice in terms of timely detec-
tion of large leaks than electronic
LLDs. While this seems counterintu-
itive at first, I believe that this is a fac-
tor that should be considered before
deciding whether electronic or
mechanical LLDs are a better bet for
leak detection.
There is a solution here in the
form of hybrid LLDs that essentially
use a mechanical LLD to activate a
switch that will cut off power to the
pump, but these types of LLDs are
not as widely known as the standard
electronic LLDs. The point is that
today's leak-detection technologies
and gas station operating characteris-
tics must be carefully evaluated to
determine the "best" method of leak
detection for a particular facility.
"Be Sure You Know What
You're Talking About."
For better or for worse, a regulator's
words may be taken as gospel by
tank owners who are doing their best
to obey the rules and are unwilling to
gainsay a voice endowed with regu-
latory authority. Whether or not their
proclamations are regarded as provi-
dential, in my view, regulators have
an obligation to be sure that the posi-
tions they take with regard to regula-
tory requirements are sound.
I expect there are many more
examples of regulatory misinforma-
tion and shortsightedness that could
be cited. These are just examples that
I have recently come across. There is
much attention being focused these
days on the proper training of UST
operators. Let us not presume that
UST operators are the only ones in
need of training. To be credible and
effective, regulators must be knowl-
edgeable and exercise a reasonable
degree of common sense.
As the Energy Act's three-year
inspection requirements are imple-
mented and regulator/tank operator
encounters become more frequent,
keep in mind the simple but pithy
gospel according to Phil. •
11
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LUSTLine Bulletin 57 • November 2007
SPEAKING OF TRUCK STOPS
Marcel Moreau's cover article, "The Trouble with Truck Stops...," in our last issue (LUSTLine #56) was followed up with
news of a recent release at a truck stop in Missouri and a note from Kevin Henderson (Mississippi Department of Environ-
mental Quality LIST program) with examples of truck-stop releases in that state.
Missouri
The appearance of fuel in a
stormwater retention pond in
June 2007 was the first indica-
tion of a release at this high-vol-
ume truck stop, located on an
interstate highway. Investigation
into the cause of the leak and
why the leak-detection equip-
ment failed to detect it, is still
underway. Cleanup costs will be
significant; more than $300,000
was spent for the initial response, which included excavation of impacted soil and installation of a recovery trench.
Mississippi
"Having read The Trouble with Truck Stops' in the last issue of LUSTLine, I
was reminded of some incidents we have experienced with truck stops. The
photo in Figure 1 depicts what happened when a customer drove off with the
nozzle still in the fuel tank. As a result of the drive-off, the dispenser cabinet
was pulled from the mounting frame and the shear valve did not properly
function. The system continued pumping until it was manually shut down by
a store clerk—but not before some 1,300 gallons of fuel were released.
Obviously, the fact that the leak-detection system was unable to recognize
that this sudden and catastrophic release was occurring at this high-capacity
pumping system leaves us with a lot to be desired.
loves
Figure 2 depicts an incident that occurred in 2003 that also resulted in a
catastrophic release, although this one occurred over a relatively long
period of time. In this case, a relatively small leak in the underground
piping system went undetected until it was eventually visually detected.
Fuel came up through the expansion joints in the truck-stop parking lot
and then made its way to the drainage ditch shown in Figure 3. Upon
subsequent testing and excavation, it was revealed that the piping had
failed near one of the dispenser-containment sumps.
IGURE 2
Although the pipe
failure shown in Fig-
ure 3 appears to be
catastrophic, it was
actually not as bad as it looks. Further investigation revealed that the path
the leak was taking through this multi-layered pipe was such that the pipe
would only leak if the line pressure was above 7 psi. Because this was a
very high-volume truck stop, the mechanical automatic line-leak detector
that was installed in the system had virtually no chance of detecting the
leak. The fact that the leak would stop at 7 psi and that the facility was
high volume meant that the line pressure would probably never decay to
the 1 psi or less needed for the mechanical leak detector to go into the
leak-detection mode. Clearly, we deserve better than this."
FIGURE 3
If you have any UST/LUST-related snapshots from the field that you would like to share with our readers, please send them to Ellen Frye at lusi opcc.org
12
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November 2007 • LUSTLine Bulletin 57
from Robert N. Renkes, Executive Vice President, Petroleum Equipment Institute (PEI)
Egads, Not a Test!
The Petroleum Equipment Institute (PEI) has pub-
lished seven recommended practices to date,
with two more slated to be completed within the
next year. The documents have been widely accepted
by the contractors for which they were written.
Because the subject matter of most of the documents
involves either aboveground or underground storage
tanks, LUSTLine readers and tank regulators also seem
to find the documents useful.
If there is one knock on the recommended prac-
tices, it is that there is no means to gauge how well the
users of the document understand what they read until
they are out in the field—which for some contractors is
too late. PEI is attempting to fill that void by preparing
tests for each of the recommended practices it pub-
lishes. We began work on the project this summer and
hope to have tests for all recommended practices com-
pleted by March 2008.
The tests are being written and proofed by the
technical committees responsible for each document.
The questions are in a multiple-choice format. Delivery
and scoring will be available through the Internet. PEI
will have a bank of questions available, so no two tests
will be the same. We estimate that most tests will
include around 70 questions and take 30 to 45 minutes to
complete.
The contractors that we talk to about the tests are
delighted with the prospect of giving the test to job
applicants who claim to have experience in tank installa-
tion and/or inspection. Contractors also tell us that they
would use the tests for refresher training and before they
promote people from within their construction depart-
ment.
We are not sure if tank regulators have a use for
these tests. We think that they might be used for licens-
ing and certification purposes. On the other hand, they
have probably developed their own tests by now. Train-
ing and continuing education of inspectors is another
possible use for the tests.
Pricing of the tests has not been determined. We
want to keep them affordable to our contractor members
and any regulatory agency that wants to use them. If you
have a use in mind and want to discuss how you and PEI
might work together in product delivery and pricing
schemes, please let me hear from you. As the saying
goes, I'm from private industry and I'm here to help.
Email: rrenkes@pei.org. Phone: 918-494-9696 •
Veeder-Root Issues Alert About Red Jacket
FX Leak Detector
On August 1, 2007, the Veeder-Root Company notified its customers that a small percentage of Red Jacket Leak Detec-
tors manufactured from December 2006 through May 2007 might not seal when installed into a submersible turbine
pump packer-manifold. The company notes that this condition, if present, will not compromise the leak-detection func-
tion of the units. To detect this condition, the
pump must be running with the line pressur-
ized. If an improper seal is present, it can be
found by making a visual inspection to see if
seepage is occurring at the joint between the
leak detector and the packer-manifold.
The equipment affected is unit FX1V Part
numbers 116-056-5 and 116-058-5, and unit
FX2V Part numbers 116-057-5 and 116-059-5.
The date code, printed on the name tag of the
leak detector, indicates the manufacture date of
the unit. Units manufactured during the affected
time period will have a date code of X1206,
0107, X0207, X0307, X0407, orX0507.
For more information, contact the Veeder-
Root customer service department at
(800) 873-3313. •
13
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LUSTLine Bulletin 57 • November 2007
California Publishes a Field Study
of ATG and LLD Systems
The California State Water
Resources Control Board
(SWRCB) recently published a
project report entitled Field Evaluation
of Automatic Tank Gauging Systems,
Electronic Line Leak Detection Systems,
and Mechanical Line Leak Detectors. As
the title suggests, this project
involved testing the effectiveness of
ATG and LLD systems in the field.
Using funding from the USEPA
Office of Underground Storage
Tanks, the SWRCB contracted with
Ken Wilcox Associates to simulate
leaks of 0.1 gph, 0.2 gph, and 3 gph at
106 UST facilities throughout Califor-
nia and assess how effective the ATG
and LLD systems were at detecting
the simulated leaks. As many indi-
viduals experienced with UST leak
detection might expect, the results
were encouraging in some cases and
somewhat of a concern in others.
Summary of Findings for
ATGs
The overall probability of detection
of a leak of 0.20-gal/hr was estimated
as 86%, somewhat less than the 95%
prescribed by the USEPA perfor-
mance standards. The probability of
detection was significantly associated
with the product in the tank, the
material or type of construction of the
tank, and the size of the tank. The
probability of detection was 95% for
tanks of 8,000 gallons and less; 84%
for tanks from 8,000 gallons to 25,000
gallons; and only 63% for tanks of
26,000 gallons up to 50,000 gallons.
Summary of Findings for
MLLDs
The overall probability of detection
of a 3-gal/hr leak rate was estimated
as 63%, but 76% of the MLLDs
detected a leak rate of 5-gal/hr, and
88% detected leak rates up to 10-
gal/hr.
Summary of Findings
for ELLDs
The estimated probability of detec-
tion for ELLDs was 71% at the 3-
gal/hr level and 76% at the 5-gal/hr
level. A specific problem was identi-
fied when a Veeder-Root ELLD was
used with an F.E.Petro turbine, lead-
ing to a failure of the ELLD to detect
the 3-gal/hr leak rate. A maintenance
bulletin had been issued earlier per-
taining to this issue, but evidently it
had not been implemented fully.
With this corrected, the probability of
detection of 3-gal/hr should increase
substantially.
The overall probability of detec-
tion was estimated to be 80% for the
0.1-gal/hr leak rate. The overall prob-
ability of detection at the 0.2-gal/hr
leak rate was estimated to be 70%.
Nearly all of the missed detections
were traced to an improper installa-
tion. Among the ELLDs that were
correctly installed, the probability of
detection was 96%.
If you are interested in knowing
more about how ATG and LLD sys-
tems perform in the field, a complete
project report for this field study is
available at http://www.waterboards.ca.
gov/ust/leak_prevention/lld_atg_study/i
ndex.html
Update on the Bad Gas in West Virginia Story
by Ellen Frye
Back in March 2003 (LUSTLine
#43), I wrote a story called
"Tanks Systems in a Jam—
Contaminated Gasoline from a Ken-
tucky Refinery Spurs a Flurry of
Tank Cleanups and Lingering Con-
cern." Since you may have forgotten
some of the details of this case in the
intervening years since that article, I
will give you a short synopsis. From
2000 to 2002, Marathon Ashland
Petroleum's Catlettsburg, Kentucky,
refinery produced gasoline that con-
tained rust, spent caustic, and mer-
captan scavenger. This contaminated
gasoline was then distributed to
wholesalers and jobbers, who trans-
ported and sold it to gasoline sta-
tions throughout the State of West
Virginia under various brand names.
The Catlettsburg refinery supplies
about 85 percent of the gasoline sold
in West Virginia. In September 2002,
Marathon undertook remedial efforts
to remove the contaminants from the
affected USTs.
However, many tank owners
believed that Marathon's UST-sys-
tem cleanup project (Project Moun-
taineer) was not effective and that
their tanks are now damaged. In Sep-
tember 2004, four gasoline retailers
from West Virginia filed suit in the
United States District Court for the
Southern District of West Virginia,
Huntington Division (civil action
number 3:04-0966, Loudermilk Ser-
vices, Inc., et al. v. Marathon Petro-
leum Company LLC). The suit was
filed on behalf of the four retailers
and as representatives of all compa-
nies and persons in West Virginia
that received the contaminated gaso-
line from the defendants. The suit
requested the creation of a fund to
monitor, test, repair, and potentially
replace any USTs affected by the con-
taminated gasoline.
The first step of the legal process
has now been accomplished—the
court has certified a "class" for all
owners and operators of under-
ground storage tanks in West Virginia
who received contaminated gasoline
from Marathon Petroleum Company
from February 1, 2000 through June
30,2004. The trial date has been set for
September 23, 2008. The court
appointed as class counsel Richard
Rowe of Goodwin & Goodwin, LLP,
rer@goodwingoodwin.com; Robert T.
Cunningham, Jr., Gregory B.
Breedlove, Richard T. Dorman, and
Bryan Comer of Cunningham, Bounds,
Crowder, Brown and Breedlove, LLC;
and James M. Cawley, Jr. of James M.
Cawley, Jr., PLLC,}ay@jaycawley.net.
You can contact the attorneys listed
above for details of the case and a
copy of the court order. •
14
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November 2007 • LUSTLine Bulletin 57
FromMNtoMA-
Jim Pearson Joins NEIWPCC
After serving for many years as
Executive Director of Min-
nesota's Petroleum Tank
Release Cleanup Fund, Jim Pearson is
familiar to many in the tanks commu-
nity. Now, he's taking on a new chal-
lenge: Pearson has been named the
Director of Drinking Water and Under-
ground Storage Tanks Programs at the
New England Interstate Water Pollu-
tion Control Commission. NEIWPCC,
which publishes LUSTLine, is based in
Lowell, Massachusetts.
The job is new for Pearson and for
NEIWPCC, which for the first time is
placing its drinking water and under-
ground storage tanks programs under
the authority of one person. It's not a
light load. Pearson will plan and facili-
tate meetings of NEIWPCC's various
workgroups in these arenas, manage
multiple projects including the cre-
ation of guidance documents, and
support state and federal staff on the
development and implementation of
programs and regulations. He'll do
everything from coordinating re-
gional comments on federal policy
initiatives to overseeing preparations
for such events as the National Tanks
Conference.
Pearson should be served well by
his vast experience in state govern-
ment in Minnesota, where he estab-
lished a reputation for successfully
building consensus around tough
policy issues. His achievements
included designing and implement-
ing a statewide abandoned UST
removal program that led to the
removal of over 100 tanks. Despite his
success in Minnesota, Pearson was
ready for something new.
"This is a tremendous opportu-
nity," Pearson said. "I'm keeping one
foot in the tanks world, where I've
enjoyed working for years, and I'll
have the other in the drinking water
realm, which is exciting on so many
levels. It's also a great honor to be at
NEIWPCC, which works to solve
problems collaboratively, the same as
I always have."
Pearson, who started work at
NEIWPCC on Sept. 10, can be reached
at 978-323-7929 ext. 233 or via email at
jpearson@neiwpcc.org. •
L*U*S*1*LINIE 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
UL Not Quite Ready to
List E85 Dispensers
Underwriters Laboratories (UL),
Northbrook, Illinois, has determined
that certain commercially available
gasket and seal materials perform accept-
ably when exposed to concentrated
ethanol blends such as E85, while other
materials experience significant deteriora-
tion. In October, UL announced that it has
established certification requirements for
E85 fuel-dispensing equipment and is
now accepting submittals for certification
investigations.
In October 2006 UL suspended autho-
rization for manufacturers to use UL list-
ing or recognition on components for
fuel-dispensing devices that specifically
reference compatibility with alcohol-
blended fuels containing greater than 15
percent alcohol (i.e., ethanol, methanol,
other alcohols). The suspension was
issued because studies on ethanol indi-
cated that ethanol in high concentrations
may significantly degrade equipment.
Some states have gone ahead and cer-
tified. According to the U.S. Department
of Energy's Alternative Fuels Data Center
(http://www.eere.energy.gov/afdc/resourc
es/technology_bulletin_0307.htm[), sev-
eral states (i.e., CO, IL, IA, Ml, MN, NY,
OH, OR) and organizations have chosen
to grant variances/waivers or have
produced a written stance on the E85
Underwriter Laboratories Certification re-
quirements. The website provides letters
from these state officials. •
15
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STI/SPFA Offers Online
Recertification for STI
Cathodic-Protection Testers
The Steel Tank Institute/Steel Plate Fabricators Associ-
ation (STI/SPFA) has announced that cathodic-pro-
tection testers for USTs can gain recertification
through a new, online examination offered through STI.
According to STI, the easy-to-follow, interactive exam is
available to cathodic-protection testers currently certified
by STI or NACE International. The exam is structured so
that answers must reflect the body of knowledge in STI's
recommended practice for cathodic-protection testing. All
who wish to take the test must provide proof of active
engagement in the field of cathodic-protection monitoring.
In addition, cathodic-protection testers whose STI certifica-
tions have expired will be permitted to recertify under this
program until February 29,2008.
Lorri Grainawi, director of technical services for
STI/SPFA, says that for several years STI has offered certi-
fication programs that require cathodic-protection testers
to travel to various locations to obtain and maintain certifi-
cation. "The online exam decreases time and cost commit-
ments substantially," says Grainawi. "Testers can take the
recertification exam from their offices or homes—even on a
weekend, if they don't want to disrupt their work sched-
ules."
To register for the exam, which costs $395, visit
www.steeltank.com, where a library of downloadable review
materials is available. After obtaining the materials, the
registrant has 59 days to take the recertification exam. After
starting the actual exam, the registrant will have 24 hours
in which to complete the effort. To date, most testers have
finished the exam within two to four hours.
Although the STI certification is generally accepted
throughout the United States, some regulatory agencies
may have additional requirements. STI recommends that
those who wish to take the test check with regulators to
ensure that they are aware of all cathodic-protection moni-
toring mandates in their service areas. •
Getting Ready
for the 2008
Notionol Tonks
Conference
2Oii> Annual National
TRNKS CONFERENCE
r^pexpo
dNEIWPCC SERA ASTSHMO j^V } ^^S
The 20th Annual National Tanks
Conference & Expo will be held on
March 17-19 in Atlanta, Georgia.
It's time to:
"^ Reserve booth space or poster
session space!
n^ Register online for the conference
and workshops!
Send any questions to: NTCinfo@neiwpcc.org
The conference provides learning and networking
opportunities for federal, state, and tribal UST/LUST
regulators. The focus is on building on our progress,
setting priorities, and developing plans for reaching
our common goal—to find new and better ways to
work together to protect human health and the envi-
ronment by preventing tank releases and quickly and
efficiently cleanup releases that do occur.
Visit our new conference website
www.neiwpcc.org/tanksconference
LU.S.T.UNE
New England Interstate Water
Pollution Control Commission
116 John Street
Lowell, MA 01852-1124
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