Pilot Project to Optimize Pump and Treat Systems at
State-Funded Leaking Underground Storage Tank
Sites: Summary Report and Lessons Learned
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Office of Solid Waste EPA 542-R-04-019
and Emergency Response September 2004
(5102G) www.epa.gov/tio
clu-in.org/optimization
Pilot Project to Optimize Pump and Treat Systems at
State-Funded Leaking Underground Storage Tank
Sites: Summary Report and Lessons Learned
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NOTICE AND DISCLAIMER
The U.S. Environmental Protection Agency funded the work described herein and the preparation of this
document by GeoTrans, Inc. under General Service Administration Contract GS06T02BND0723 to S&K
Technologies, Inc., Bremerton, Washington and under EPA Contract No. 68-C-02-092 to Dynamac
Corporation, Ada, Oklahoma. Mention of trade names or commercial products does not constitute
endorsement or recommendation for use.
This report has undergone review by the state site manager and EPA headquarters staff. For more
infomation about this project, contact: Joe Vescio (703-603-0003 orvescio.joseph@epa.gov) or Kathy
Yager (617-918-8362 or yager.kathleen@epa.gov).
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PREFACE
This report was prepared as part of a pilot project conducted by the United States Environmental
Protection Agency (U.S. EPA) Office of Underground Storage Tanks (OUST) and the Office of
Superfund Remediation and Technology Innovation (OSRTI). The objective of this project is to conduct
Remediation System Evaluations (RSEs) of pump and treat systems at State-funded underground storage
tank (UST) sites. The following organizations are implementing this project.
Organization
Key Contact
Contact Information
U.S. EPA Office of Underground
Storage Tanks
(OUST)
Joe Vescio
EPA Headquarters 5401G
Ariel Rios Building
1200 Pennsylvania Ave, N.W.
Washington, DC 20460
phone: 703-603-0003
fax: 703-603-0175
vescio.joseph@epa.gov
U.S. EPA Office of Superfund
Remediation and Technology
Innovation
(U.S. EPA OSRTI)
Kathy Yager
11 Technology Drive (ECA/OEME)
North Chelmsford, MA 01863
phone: 617-918-8362
fax:617-918-8427
yager.kathleen@epa.gov
U.S. EPA Office of Superfund
Remediation and Technology
Innovation
(U.S. EPA OSRTI)
Ellen Rubin
EPA Headquarters 5102G
Ariel Rios Building
1200 Pennsylvania Avenue, N.W.
Washington, DC 20460
phone: 703-603-0141
rubin.ellen@epa.gov
Dynamac Corporation
(Contractor to U.S. EPA)
Daniel F. Pope
Dynamac Corporation
3601 Oakridge Blvd.
Ada, OK 74820
phone: 580-436-6494
fax: 580-436-6496
dpope@dynamac.com
GeoTrans, Inc.
(Contractor to Dynamac)
Doug Sutton
GeoTrans, Inc.
2 Paragon Way
Freehold, NJ 07728
phone: 732-409-0344
fax: 732-409-3020
dsutton@geotransinc.com
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ACKNOWLEDGMENTS
The project team is grateful for the cooperation and participation of the New Jersey Department of
Environmental Protection (NJDEP) and the New York State Department of Environmental Conservation.
They were vital in transferring site documents to the RSE team, scheduling the site visits, providing
information during site visits, and reviewing the RSE reports. The authors also extend sincere thanks to
the principal investigators from the U.S. EPA Office of Superfund Remediation and Technology
Innovation (OSRTI) and the U.S. EPA Office of Underground Storage Tanks (OUST).
in
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IV
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EXECUTIVE SUMMARY
Based on previous success with conducting independent optimization evaluations at Fund-lead pump and
treat sites (i.e., those sites with pump and treat systems funded and managed by Superfund and the
States), the EPA Office of Superfund Remediation and Technology Innovation (OSRTI) and the Office of
Underground Storage Tanks (OUST) commissioned a study to pilot similar evaluations at State-funded
leaking underground storage tank (LUST) sites. During 2003 and 2004, independent evaluations were
performed at three State-funded UST sites by an independent EPA contractor. The Remediation System
Evaluation (RSE) process developed by the U.S. Army Corps of Engineers was used. For each of the
three sites, the RSE process included a review of site documents, a site tour to interview State project
managers, and preparation of an RSE report. The RSE reports provided site background, summarized the
findings from the site visit, and provided recommendations in the following categories:
• recommendations to improve system effectiveness in protecting human health and the
environment
• recommendations to reduce life-cycle operation and maintenance (O&M) costs
• recommendations for technical improvement
• recommendations to improve the likelihood of site closure
The three sites that received RSEs were selected by the EPA OSRTI and OUST based on nominations
provided by State project managers from the New Jersey Department of Environmental Protection
(NJDEP) and the New York State Department of Environmental Conservation (NYSDEC). Both of these
State organizations had expressed interest in the optimization process and a willingness to participate in
the pilot study. The evaluated sites have a number of similarities, including the following:
• the primary contaminants of concern at all three sites are typical gasoline constituents, such as
benzene, toluene, ethylbenzene, and xylene (BTEX)
• all three sites have free product at present
all three sites address contamination in unconsolidated material
The annual costs for operating the systems ranged from approximately $22,000 per year to $225,000 per
year.
The RSE team was able to provide recommendations for each of the three sites. Recommendations for
improving effectiveness in protecting human health and the environment and for technical improvement
were provided at all three sites. Recommendations for reducing costs and gaining site close out were
provided at two of the three sites.
Typical recommendations for improving effectiveness pertained to plume delineation, plume capture, and
sampling program effectiveness. Typical recommendations for reducing costs generally included reducing
number of sampling locations, replacing a treatment component with a more efficient technology, and
reducing granular activated carbon (GAC) change-out. If the cost reduction recommendations are
implemented at all the sites, the RSE team estimates that approximately $55,000 per year might be saved.
Technical improvement recommendations varied by site, but at two of the sites, the RSE team
recommended either instituting or enhancing performance reporting. With respect to gaining site close
out, recommendations included developing a site-specific exit strategy and considering alternative
remedial approaches.
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Based on the results of the RSEs, the RSE process is beneficial at State-funded UST sites. However, it
would be helpful to develop a streamlined evaluation process (an "RSE-lite") that could accomplish a
beneficial evaluation with a reduced scope of work and reduced cost. In addition, it would be helpful to
provide project managers with a tool that could be used to improve reporting of remedial progress.
VI
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TABLE OF CONTENTS
NOTICE i
PREFACE ii
ACKNOWLEDGMENTS iii
EXECUTIVE v
TABLE OF CONTENTS vii
1.0 INTRODUCTION 1
1.1 PROJECT BACKGROUND 1
1.2 THE RSE PROCESS 1
1.3 THE RSE REPORT 2
1.4 SITE SELECTION PROCESS 3
1.5 EVALUATED SITES AND SCHEDULE 3
2.0 SUMMARY OF RSE FINDINGS AND RECOMMENDATIONS 6
2.1 COMPARISON OF SITE/SYSTEM CHARACTERISTICS 6
2.2 COMMON THEMES REGARDING RECOMMENDATIONS FOR IMPROVING EFFECTIVENESS .. 6
2.3 COMMON THEMES REGARDING RECOMMENDATIONS FOR COST REDUCTION 7
2.4 COMMON THEMES REGARDING RECOMMENDATIONS FOR TECHNICAL IMPROVEMENT .. 7
2.5 COMMON THEMES REGARDING RECOMMENDATIONS FOR SITE CLOSURE 8
3.0 FEEDBACK ON THE RSE PROCESS FROM SITE STAKEHOLDERS 9
3.1 LESSONS LEARNED 9
3.2 RECOMMENDATIONS 9
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1.0 INTRODUCTION
1.1 PROJECT BACKGROUND
During fiscal years 2000, 2001, and 2002, Remediation System Evaluations (RSEs) were conducted at 24
Fund-lead pump and treat (P&T) sites (i.e., those sites with pump and treat systems funded and managed
by Superfund and the States). Due to the opportunities for system optimization that arose from those
RSEs, the EPA Office of Superfund Remediation and Technology Innovation (OSRTI) and the Office of
Underground Storage Tanks (OUST) commissioned a study to pilot RSEs at State-funded leaking
underground storage tank (LUST) sites with P&T systems. Starting in June 2003, RSEs at three State-
funded LUST sites were conducted to evaluate the effectiveness of the RSE process as an optimization
tool for this class of sites. Focus was placed on determining if the RSE process could help States address
these environmental liabilities given recent shortages in funding and resources. An independent
contractor conducted these evaluations, and representatives from EPA OUST attended the RSEs as
observers.
For more information regarding this project, including the individual RSE reports, please visit
www.cluin.org/optimization
1.2 THE RSE PROCESS
The RSE process was developed by the U.S. Army Corps of Engineers (USAGE) and is documented on
the following website:
http://\v\\'w.cnvironmcntal.usacc .army.mil/library/guidc/rscchk/rscchk.httnl
The RSE process is a comprehensive, independent expert evaluation of an operating remediation system.
For a P&T system, the RSE team includes one or more senior process engineers and one or more senior
hydrogeologists working with the site team (i.e., the site regulator, facility representative, and site
contractor). The RSE team evaluates the following items:
system goals
• site conceptual model
• extraction well network
above-ground treatment system
• ground water and treatment process monitoring
system effectiveness with respect to protection of human health and the environment
• data management
costs
The RSE process includes scheduling a site visit, reviewing site data, visiting the site for one to two days,
submitting a draft report for review by the site managers, and finalizing that report considering the
comments from the review. The RSE site visit generally needs to be scheduled a month in advance to
allow for transfer of key site documents to the RSE team for their review prior to the site visit. Once the
site visit is conducted, the draft RSE report is generally submitted in approximately 45 days. The time
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frame for finalizing the RSE report depends heavily on the time taken for the site managers to review the
draft report and send comments to the RSE team. The typical cost for an RSE is about $25,000.
During the site visit the RSE team tours the facility and surrounding area and interviews the site team.
The RSE report documents the findings and presents recommendations to improve the remedy. The
recommendations typically fall into the following categories:
recommendations to improve system effectiveness in protecting human health and the
environment
recommendations to reduce life-cycle operation and maintenance (O&M) costs
• recommendations for technical improvement
• recommendations to improve the likelihood of site closure
The recommendations obviously have the benefit of the operational data unavailable to the original
designers; therefore, an RSE is viewed as a team effort between the site managers and the RSE team
rather than a site audit.
1.3 THE RSE REPORT
The detailed RSE report for each site contains the following sections:
an introduction that details the purpose of the visit, the RSE team, the documents reviewed,
persons contacted, site location, history, hydrogeology, etc.
• a description of the remediation system including the extraction and treatment systems
• system objectives, plus performance and closure criteria
• findings and observations from the RSE site visit including system and component performance,
recurring problems, capture zone evaluation, and contaminant delineation
evaluation of the system effectiveness with respect to protection of human health and the
environment for ground water, surface water, air, and soils
• recommendations intended to
* enhance remedy effectiveness with respect to preventing plume migration and monitoring
other exposure pathways
* reduce life-cycle O&M costs
> improve technical operations
* gain site closeout
• a table summarizing the recommendations, including estimated capital costs and estimated annual
cost increases or decreases associated with each recommendation
The cost estimates provided in the RSE reports have levels of certainty comparable to those done for
CERCLA Feasibility Studies (-307+50%). The observations and recommendations presented in the RSE
reports are not intended to imply a deficiency in the work of either the designers, operators, or site
managers. They are offered as constructive suggestions that have the benefit of an independent review of
operational data that was unavailable to the original designers. In general, system improvements are
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merited because site conditions and/or available technologies have changed since design and installation
of the P&T systems.
1.4
SITE SELECTION PROCESS
EPA OUST and OSRTI selected the three sites to receive RSEs by soliciting nominations from the New
Jersey Department of Environmental Protection (NJDEP) and the New York State Department of
Environmental Conservation (NYSDEC). Both of these State organizations had expressed interest in the
optimization process and a willingness to participate in the pilot study. Both State agencies selected sites
that had relatively high remediation costs compared to their other State-funded sites.
1.5
EVALUATED SITES AND SCHEDULE
The three UST sites that were evaluated are listed in the following table along with the dates of various
milestones in the RSE process.
Site Name and Location
Morgan Terminal
Brooklyn, New York
Shorco South
Mahwah, New Jersey
A-Z Automotive
West Milford, New Jersey
Date of RSE Site
Visit
6/4/2003
7/29/2003
7/30/2003
Date Draft RSE
Report was
Submitted
7/18/2003
7/7/2004
7/27/2004
Date Final RSE
Report was
Submitted
6/11/2004
9/30/2004
9/30/2004
Note: Contracting difficulties that were beyond the control of EPA, the States, and the contractor resulted in a stoppage of work
from August 2003 through May 2004.
The following are brief descriptions of each of the evaluated sites. RSE findings and recommendations
are discussed in the Section 2.0 of this report.
Morgan Terminal - Brooklyn, New York
The Morgan Terminal site is an abandoned oil terminal located at 200 Morgan Avenue in Brooklyn, New
York. The site consists of a two story terminal operations building and maintenance building, seven bulk
fuel oil storage tanks, and several underground storage tanks. The site has historically been impacted by
diesel fuel and No. 6 fuel oil and dissolved hydrocarbons. Current contamination largely consists of No.
6 fuel oil. The surrounding area is comprised of industrial facilities and warehouses. Morgan Avenue
borders the site to the west, and the English Kills borders the site to the north and east.
Site-related contamination was first reported in 1992 by the Coast Guard when oil was found seeping into
the English Kills. Between December 1992 and January 1993 a remedial investigation (RI) was
conducted including the installation of 20 ground water monitoring wells and tank testing. Primary
recommendations included additional subsurface investigation, removal of floating product from
monitoring wells, emptying and cleaning of tanks, and design of a remediation system. Additional
investigations have occurred and the site now has over 40 monitoring wells. The tanks were cleaned in
1994, and a remediation system became operational in June 1995.
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The State does not own the property. The current owner reportedly lives in Florida and, at the time of the
interim consent order in 1994, over $800,000 in back taxes were owed. The State has a lien on the
property to recover costs if the property is ever sold.
Shorco South - Mahwah, New Jersey
The Shorco South site is located on the southbound side of Route 17 in the Township of Mahwah, New
Jersey. The Shorco South site is downgradient of the Shorco North site, which also has ground water
impacted with petroleum constituents. The Shorco South site remediation is currently being run by
NJDEP under the publicly funded cleanup program, while the Shorco North remediation is still being
operated by the responsible party. Ground water flows in a south to southwest direction across the Shorco
South site, towards the Ramapo River.
Dissolved benzene, methyl tertiary-butyl ether (MTBE), and tertiary-butyl alcohol (TEA) levels are
present in many wells above ground water criteria and are good "indicator parameters" for continuing
impacts at the site. Toluene, ethylbenzene, xylene, and lead only sporadically exceed the criteria, and
occur at wells within the plumes associated with the three indicator parameters (benzene, MTBE, and
TEA). On-site wells located upgradient of on-site sources ("upgradient" wells) are impacted, but at lower
concentrations than the "mid-plume" wells. Impacts at these "upgradient wells" are most likely due to
Shorco North, and concentrations at these wells are decreasing overtime. At the "mid-plume" wells
(impacted primarily by sources at Shorco South) the concentrations also appear to be decreasing over
time, though in some cases concentrations still remain several orders of magnitude above cleanup criteria.
A ground water pump and treat system was completed during 1991 which included 6 recovery wells.
Nine well points were added to the system in 1996 to improve containment at the downgradient south
corner of the site. The well points were not effective due to fouling problems. The current pump and treat
system consists of an approximately 200 foot long trench 14 to 16 feet deep that was installed in late
2001, but has not operated except for testing.
A-Z Automotive - West Mi I ford. New Jersey
The A-Z Automotive site is a former gasoline retail outlet and automobile service station located on
Union Valley Road between St. George Street and LouAnn Boulevard in West Milford, Passaic County,
New Jersey. Approximately 25 residences are located on St. George Street and LouAnn Boulevard to the
east of the A-Z site. Belcher Creek is about 1,000 feet further to the east of the subdivision. Petroleum
impacts were discovered at the site in 1989 initially due to a diesel spill that occurred during the filling of
a UST. Subsequent investigations found UST leaks, basement vapor issues, and potable well impacts.
Shallow ground water occurs in a glacial deposit overburden that is reported to be about 80 feet bgs. The
potable wells in the area are completed in the underlying bedrock (potable wells are reported to average
about 150 feet bgs). Between 1989 and 1992, potable well sampling indicated exceedances of New Jersey
Department of Environmental Protection (NJDEP) ground water standards at nine potable wells, and
detectable contaminant concentrations in twelve additional wells. Gasoline odors were noted at that time
in the basements of several residences. Approximately 19 point of entry treatment (POET) systems with
GAC treatment were in place as of May 1995 and most of these are still in place. Contaminants of
concern include typical gasoline constituents such as benzene, toluene, ethylbenzene, xylenes (BTEX),
MTBE, TEA. Benzene is present above NJDEP standards in the most widespread area. Analytical results
for ground water samples taken in July 2003 show a marked decrease in the extent and magnitude of
dissolved concentration from earlier results. Free product has been observed at the site, reaching as far as
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300 feet east of the abandoned gas station where up to three feet of product has been observed during
pumping conditions. There is concern that a large volume of product is trapped below the water table.
The current P&T system consists of one main recovery well for hydraulic control (RW-13). Other wells
are periodically pumped to lower the water table for SVE application. The recent (May to July 2003)
system flow rate has been about 20 gpm. The current SVE system consists of several wells that can
recover vapors to prevent contaminant migration to residences, and to remove mass. The vapors are
extracted at a rate of approximately 70 to 100 cfm, and are currently treated by a catalytic oxidizer.
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2.0 SUMMARY OF RSE FINDINGS AND RECOMMENDATIONS
2.1 COMPARISON OF SITE/SYSTEM CHARACTERISTICS
The five evaluated systems had the following similarities:
• the primary contaminants of concern at all three sites were hydrocarbons, such as BTEX
compounds
all three sites either have or had non-aqueous phase liquid (NAPL) present
all three sites addressed contamination in unconsolidated material
two of the three facilities (A-Z Automotive and Morgan Terminal) were no longer active
annual O&M costs for the systems in increasing order were
• $21,600 per year (Morgan Terminal)
$103,000 per year (Shorco South)
$225,400 per year (A-Z Automotive)
• all three of the sites had potential ecological receptors; only one of the sites (A-Z Automotive)
had potential human receptors
More information about each site can be found in the individual RSE reports.
2.2 COMMON THEMES REGARDING RECOMMENDATIONS FOR
IMPROVING EFFECTIVENESS
Each of the three evaluated sites had recommendations for improving effectiveness. Those
recommendations generally pertained to plume delineation, plume capture (i.e., containing the
contaminant plume and preventing further plume migration), and effectiveness of the sampling program.
Installation of additional monitoring wells for further delineation of ground water impact was
recommended at A-Z Automotive. At a minimum, installation of a well pair was recommended
by the RSE team to serve as a sentinel well for plume migration.
With regard to plume capture, evaluation of capture was recommended at two of the three sites.
At A-Z Automotive, the RSE team believed capture was likely insufficient, allowing
contaminants to migrate from the site. The RSE team provided recommendations to improve
evaluation of capture. At Shorco South, the RSE team recommended additional data or further
analysis to confirm capture.
• Formalizing/modifying the sampling program was recommended at all three of the sites. The
RSE team recommended starting an annual ground water monitoring program at A-Z
Automotive, including indoor air sampling at nearby residences. At Morgan Terminal, the RSE
team recommended including sampling and analysis of chlorinated solvents because there was
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evidence this class of contaminants were present at the site. At Shorco South, the RSE team
recommended indoor air sampling in an on-site building.
Other recommendations in this category included obtaining a discharge permit/agreement and conducting
effluent sampling at Morgan Terminal. At the time of the RSE, the site did not have a documented
discharge permit or agreement and the discharge was not being sampled. Morgan Terminal could also
benefit from demolition of site structures and excavation of underlying contaminated soil. At the time of
the RSE, the site was a safety hazard and an attraction for vagrants and vandals.
2.3 COMMON THEMES REGARDING RECOMMENDATIONS FOR COST
REDUCTION
Recommendations to reduce cost were provided at two of the three sites (A-Z Automotive and Shorco
South). Those recommendations generally included modifying the sampling program, replacing a
treatment component with a more efficient technology, and reducing GAC change-out frequency.
At A-Z Automotive, the recommended modifications included the following:
The contractor scope should be clarified to assist the project manager with tracking activities and
costs.
• Vapor phase GAC units can be used to replace the catalytic oxidizer to lower electricity usage,
and the change-out frequency for the liquid phase GAC could be reduced from 12 per year to four
per year.
At Shorco South, the RSE team suggested the following modifications:
• The site team should reduce the number of wells for quarterly sampling.
• The site team should attempt to avoid TEA treatment by negotiating with the publicly-owned
treatment works (POTW) because it would be readily treated through the biological treatment
process at the POTW but would be expensive to treat on site.
The RSE team estimates that implementing these recommendations at the two sites could save
approximately $55,000 per year.
2.4 COMMON THEMES REGARDING RECOMMENDATIONS FOR
TECHNICAL IMPROVEMENT
The recommendations for technical improvement were provided at all three sites. The recommendations
varied by site and included, removing a GAC effluent tank, repairing insulation or relocating treatment
component indoors, and improving housekeeping. Technical improvement recommendations at two of
the sites pertained to reporting. At A-Z Automotive, the RSE team recommended instituting a quarterly
system performance report and an annual ground water report. At Morgan Terminal, the RSE team
recommended improving the content of semi-annual reports and reducing errors.
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2.5 COMMON THEMES REGARDING RECOMMENDATIONS FOR SITE
CLOSURE
The RSE team provided recommendations in this category at all three sites, as summarized below:
At A-Z Automotive, the RSE team recommended considering an exit strategy that could serve as
a plan for the duration of the remedy. An evaluation should be made as to whether aquifer
restoration is achievable with the current system. A time frame for shutting down the system
should be estimated, and a specific monitoring program to indicate when the system can be shut
off should be determined.
At two of the sites, the RSE team suggested alternative or additional remedial approaches. At
Morgan Terminal, several alternative remedial approaches were recommended to replace current
remediation system because it does not appear to be effective. At the Shorco South, vacuum
enhanced short-term extraction at hot-spot wells was suggested to accelerate site cleanup. An air
sparging or biosparging system could also be considered instead of ground water extraction once
the hydraulic containment is no longer necessary.
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3.0 FEEDBACK ON THE RSE PROCESS FROM SITE STAKEHOLDERS
3.1 LESSONS LEARNED
The primary lessons learned are as follows:
• Although the LUST sites evaluated in this project are generally not as complex as the Superfund
sites or RCRA sites evaluated in other RSE pilot projects, they are sufficiently complex to merit
long-term remedial actions and can benefit from RSEs or other forms of independent optimization
evaluations.
The RSEs yielded potential opportunities to improve remedy effectiveness. The RSE team
generally found it important to improve the evaluation of plume capture at these sites, to better
refine remedial objectives, to conduct adequate sampling, and to address source areas.
The RSEs generally identified potential opportunities for cost reduction. However, because the
remedies evaluated during this pilot had relatively low costs compared to previously reviewed
Superfund and RCRA remedies, the potential for cost reduction was not as substantial. The RSE
process would be more cost effective if the process could be streamlined and conducted for a
reduced cost.
Reporting at the UST sites is generally not as comprehensive as the reporting at the more
complicated sites. More effective reporting, particularly at A-Z Automotive and Morgan
Terminal, would likely facilitate site management. In general, more comprehensive reporting
would facilitate the implementation of a streamlined RSE process.
• Conducting RSEs at UST sites that are not State funded could also be beneficial to State UST
programs. State programs might also benefit by conducting RSEs at responsible party sites that
demand substantial personnel resources or that are part of a reimbursement program. However,
conducting RSEs at these sites would be a different dynamic than conducting RSEs at State-
funded sites because a responsible party would be involved, and an evaluation would not be
considered independent if it were used for enforcement purposes.
3.2 RECOMMENDATIONS
Based on the above lessons learned, the following items are recommended:
The development of a template progress report with template tables and example figures
specifically aimed at UST sites would likely facilitate future reporting efforts at UST sites. The
resulting improvements in reporting would likely improve site management and facilitate the
implementation of streamlined optimization evaluations.
• A streamlined optimization evaluation (e.g., an "RSE-lite") specifically developed for UST sites
would make optimization more cost-effective at UST sites and would enable many more sites to
benefit from optimization. The RSE-lite would not likely include a site visit. Rather, it would
primarily rely on document review, conference calls, and email exchanges. By eliminating the
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site visit and streamlining the actual RSE report, it is hoped that the cost for an RSE-lite at UST
sites might be as low as $5,000.
The above-mentioned template and RSE-lite process should be piloted at UST sites. Once again,
emphasis could be placed on State-funded UST sites; however, if the States find it beneficial to
include responsible party sites, such sites could also be included. If this is the case, the States
would need to identify responsible party sites that were willing to participate in the pilot. The
States and the responsible party would need to understand that the RSE process is intended as an
independent evaluation and should not be used as a tool for enforcement.
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