,
INTERIM REPORT:
Leaking Underground Storage
Tanks Corrective Action
Case Histories
November 1,1988
Office of Research and Development
Risk Reduction Engineering Laboratory
Release Control Branch
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LEAKING UNDERGROUND STORAGE TANK
CORRECTIVE ACTION CASE HISTORIES
by
William M. Kaschak and Joyce K. Hargrove
COM Federal Programs Corporation
Fairfax, Virginia 22033
U.S. EPA Contract No. 68-03-3409
Technical Project Manager
Robert W. Hillger
U.S. Environmental Protection Agency
Risk Reduction Engineering Laboratory
Edison, New Jersey 08837
Risk Reduction Engineering Laboratory
Office of Research and Development
U.S. Environmental Protection Agency
Cincinnati, Ohio 45268
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DISCLAIMER
The information in this document has been funded by the United States
Environmental Protection Agency under Contract No. 68-03-3409 to CDM Federal
Programs Corporation. It has been subjected to the Agency's peer and
administrative review and has been approved for internal use only.
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FOREWORD
Today's rapidly developing and changing technologies and industrial
practices frequently carry with them the increased generation of solid and
hazardous wastes. These materials, if improperly dealt with, can threaten
both the public health and the environment. Abandoned waste sites and
accidental releases of toxic and hazardous substances also have important
health and environmental implications. The Risk Reduction Engineering
Laboratory assists in providing an authoritative and defensible engineering
basis for assessing and solving these problems. Its products support the
policies, programs, and regulations of the Environmental Protection Agency;
the permitting and other responsibilities of the state and local
governments; and the needs of both large and small businesses in handling
their wastes responsibly and economically.
This document summarizes the results of a project to collect case
history information on underground storage tank (UST) corrective actions
and to incorporate this information in an existing on-line computer system
for emergency and remedial response actions. The information generated
under this project will be the cornerstone for the UST Case_History_File.,
whichhas been designed toi_gcgjodg_a_£o.nm_for_Jdie_traisfejr of technical
information on the_eyolving UST_program.
For further information, please contact the Releases Control Branch,
Superfund Technology Demonstration Division of the Risk Reduction
Engineering Laboratory.
Tim Oppelt, Acting Director
Risk Reduction Engineering Laboratory
111
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PREFACE
This report presents the results of a project conducted by the U.S.
Environmental Protection Agency which included the collection of case
history information on 50 corrective actions conducted at sites with
leaking underground storage tanks (USTs). The report discusses the
existing Case History File, which was developed originally for removal and
remedial response actions and the additions and other modifications of the
system relevant to the UST corrective action program.
The collection of data involved visits to several states and UST sites;
direct interaction with the state personnel was a major factor in the
success of the project. Many of the Case History Files were provided by
the state personnel, and the remaining case histories were extracted by COM
Federal Programs Corporation personnel from individual site project files.
This report provides general observations and a summary of the data for
each subsection of the Case History File.
IV
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CONTENTS
Disclaimer ii
Foreword iii
Preface iv
Abstract vi
Figures vii
Tables viii
Abbreviations and Symbols ix
Acknowledgment x
1. Introduction 1
2. Conclusions 4
3. Recommendations 7
4. Approach 9
System Design 9
Data Collection 13
Key Aspects of the Case History File 16
5. Analysis of Data 20
General Information 20
Chemical Information .24
Effects of the Incident 25
Site Characteristics 26
Immediate Corrective Actions 28
Long-term Corrective Actions 33
Free Product Removal 38
Effectiveness of Corrective Actions 40
Operational Considerations 44
Termination of Response 48
APPENDICES
A. Case History File Check List 50
B. Case History File After-Action Report 52
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ABSTRACT
The Environmental Protection Agency's proposed regulations for
underground storage tanks (USTs) require that corrective action be taken in
response to a leaking UST. However, the experience of personnel in the EPA
Regions, the states, and the local environmental agencies in this new field
varies widely. As a result, what constitutes appropriate corrective action
for le,aking__underground storage tanks is not well defined. The EPA is
expanding its Case History File (File) database on emergency and remedial
response actions to include information on UST corrective actions. The
expanded database will facilitate technology transfer among the personnel
involved in the emerging field of UST corrective action and those involved
in hazardous waste site cleanup. This File is a component of EPAJs
Computerized On-Line Information System (COLIS). COLIS is operated and
maintained by Enviresponse, Inc., the operating contractor of the Technical
Information Exchange at the at the EPA's Edison, New Jersey, facility.
The File contains reports filed by On-Scene Coordinators (OSCS) and
Remedial Project Managers (RPMS) about the technical, administrative,
financial, institutional, and other aspects of spill and/or waste site
cleanups they have managed. The File consists of a database section which
allows computerized searches to be made, and a narrative section which
contains detailed information reports on various aspects of the incidents.
The narrative section has 10 subsections: General Information, Chemical
Information, Effects of the Incident, Site Characteristics, Containment
Actions, Removal/Cleanup Actions, Treatment Actions, Disposal Actions,
Operational Considerations, and Termination of the Response.
The File is being modified to incorporate additional data relevant to
USTs, such as methods of leak detection, causes of UST leaks, and
tank/piping construction. New reports are being added as the EPA receives
them from the states and Regions.
This report was prepared by COM Federal Programs Corporation under EPA
Contract No. 68-03-3409.
VI
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FIGURES
Number Page
Initial UST Case History File database
collection efforts 15
vii
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TABLES
Number Page
1 Database Categories of the
Case History File 10
2 Subsections of the Narrative Section 10
3 Functions of the Case History File Programs 12
4 Contents of the Case History Database
Narrative Section 18
5 Immediate Corrective Action Technologies 30
6 Groundwater Treatment Technologies 35
7 Soil Treatment/Disposal Technologies 37
8 Free Product Removal Methods 39
9 Effectiveness of Corrective Actions 41
10 End Point Criteria 43
11 Post-Treatment Monitoring Durations 44
Vlll
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ABBREVIATIONS
LIST OF ABBREVIATIONS AND SYMBOLS
API
BTEX
BTX
COLIS
EERU-TIX
EPA
MTBE
NFPA
NPDES
OSC
RPM
THC
TPH
UST
American Petroleum Institute
Benzene, toluene, ethylbenzene and xylene
Benzene, toluene, and xylene
Computerized On-Line Information System
Environmental Emergency Response Unit-Technical
Information Exchange
Environmental Protection Agency
Methyl tertiary-butyl ether
National Fire Protection Association
National Pollutant Discharge Elimination System
On-Scene Coordinator
Remedial Project Manager
Total Hydrocarbons
Total Petroleum Hydrocarbons
Underground Storage Tank
IX
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ACKNOWLEDGMENTS
This report was prepared for the U.S. Environmental Protection Agency
by CDM Federal Programs Corporation. The work was performed under the
auspices of the Risk Reduction Engineering Laboratory (RREL) of the Office
of Research and Development and the Office of Underground Storage Tanks (OUST)
Many individuals must be acknowledged for their energetic support and
efforts in completing this project. This project was completed under the
technical guidance and direction of Mr. Robert Hillger, Technical Project
Manager, and Mr. Richard Griffiths of the Releases Control Branch, Superfund
Technology Demonstration Division, RREL. Overall program direction was
provided by Mr. John S. Farlow, Chief, Releases Control Branch. Ms. Iris
Goodman, OUST, has been an active participant on the project.
The authors acknowledge the contribution of May Smith of Enviresponse,
Inc. and the staff of the Technical Information Exchange in the development
of the Computerized On-Line Informations Systems (COLIS) and the original
Case History File. The assistance of Rachel Simmons with data management
and documentation is gratefully acknowledged.
The authors acknowledge the support provided by the state personnel who
completed after-action reports and who took the time out of their busy
schedules to escort the project team on one of the several site visits.
The authors extend a special acknowledgment to Mr. James Begley of the
Massachusetts Department of Environmental Quality Engineering and Mr.
Phillip Cole of the New Jersey Department of Environmental Protection for
their professional assistance in critiquing the initial draft of: the Case
History File After-Action Report for USTs.
The project was completed by the staff of CDM Federal Programs
Corporation under the direction of Mr. William M. Kaschak, P.E. the work
assignment manager. The majority of the staff work was completed by Joyce
K. Hargrove. Other contributors to the project are William Koski, Harry
Lindenhofen, Michael Borst, Daniel Gilroy, Emily Cord-Duthinh, Paul
Travisano, Stefana Matarazza, Nylah Williams, and Mary Ferreira.
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SECTION I
INTRODUCTION
BACKGROUND
The Environmental Protection Agency (EPA) is planning regulations that
will require corrective action for leaking underground storage tanks
(USTs). However, the experience among EPA, state, and local response
personnel varies considerably in this new field; and what constitutes
appropriate corrective action is not always clear. To clarify this matter
and to improve technology transfer among response personnel, the EPA
expanded its Case History File (File) database for hazardous material
spills and waste site remedial actions to include information on UST
corrective actions. The File is a component of the EPA's Computerized
On-Line Information System (COLIS). It is maintained by the Environmental
Emergency Response Unit-Technical Information Exchange (EERU-TIX)
contractor, Enviresponse, Inc., at EPA's Edison, New Jersey facility. This
group established the original database using files of after-action report
forms submitted by On-Scene Coordinators (OSCs) and Remedial Project
Managers (RPMs). Several databases were established in accordance with
quality control procedures to ensure accuracy and reliability. Records are
maintained by the System Operator at TIX.
The system has experienced tremendous growth and development since the
initial programs were installed. Over time, the system has been refined,
enhanced, and thoroughly tested to ensure a viable system. The
computerized information retrieval system, beginning as the File, has
recently been expanded and renamed the TIX Computerized On-Line Information
System. It will include the original File, with the addition of the UST
data, the Countermeasure Selection System, and the Library Search System.
Documentation in the form of a tutorial user's guide will be distributed
and updated as each system becomes available.
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The UST corrective action program is an emerging program, and many_of
thej:esponse_-pe.r.s.onnel_,inyolyed at the federal and state programoffices^
are_predominately_new-s.ta£fI-wi.th-.limi.ted-or-_varvinq degrees_of_UST .program
_exper_ience. .Presently, no_mechanism_jLs in place_.tp_p.r.Qyjrde_j.he_transfer of
technological information-among—the—:£eder-al-^steate-and-priyate_communities
for the_UST-prog-r-am. The intent of the File is to facilitate technology
transfer among response personnel who need to select site-specific
corrective actions. The File is an easy-to-use informational tool that
eventually will include a significant amount of case history data.
The File is an on-line computerized system with a database section and
a narrative section: the database section allows searches to be made using
any combination of 27 different criteria, such as EPA Region, state,
hazardous substance, hydrology, UST construction, and corrective action
technologies. The narrative section of the File contains detailed reports
in a plain-text format. The narrative section has 10 subsections:
o General Information
o Chemical Information
o Effects of Incident
o Site Characteristics
o Containment Actions
o Removal/Cleanup Actions
o Treatment Actions
o Disposal Actions
o Operational Considerations
o Termination of Response
Most of the data in the database and the narrative sections have been
obtained from after-action reports submitted by On-Scene Coordinators
(OSCs) or Remedial Project Managers (RPMs). The Case History File enables
response personnel and planners to examine reports filed by those who faced
similar field problems and therefore benefit from the knowledge gained from
the data in these reports be it successes, discoveries, or failures. In
turn, the reviewer is urged to complete after-action reports to pass on
their own successes and problems. The Case History File will allow the
review of previous decisions on selecting cost-effective corrective actions
on the basis of past performance, cost, practicality, reliability, and
other factors. In addition, the File provides actual site information to
academic and research communities; this is essential to developing new and
innovative corrective action technologies.
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OBJECTIVES
The objectives of the project were to expand the existing database by
collecting information relevant to UST corrective actions and to collect
case history data on UST corrective actions involving a range of site
conditions, locations, and technologies. The initial Case History Files
for UST-related projects will be input into a national database for use by
UST response personnel.
The study area was limited to petroleum USTs and to sites with
completed or ongoing corrective actions. Therefore, there is a built in
bias in the data towards petroleum USTs and sites where corrective actions
were more urgent due to potential impacts on public health.
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SECTION 2
CONCLUSIONS
A variety of reliable technologies is being implemented at LIST sites to
address immediate corrective actions, free product removal, and long-term
corrective actions. The degree to which these technologies are being
applied to UST releases varies from state to state and from site to site,
depending on the potential or actual effects of the release on public
health and/or the environment.
The level of detail and the questions answered among the 50 Case
History File After-Action Reports varied widely. This variability is more
noticeable for those sites where the OSC/RPM completed the after-action
report; however, for those incidents where site files were used to prepare
the reports, many of the questions could not be answered from the file
material alone, specifically, the subjective questions referring to sug-
gesting improvements or alternative methods to site cleanup and an
assessment of the effectiveness of the technology to effectuate site
cleanup.
A significant amount of followup was necessary to obtain completed
after-action reports, site files and follow up questions of the preparer.
Many respondents complained of the length of the after-action report and
the detail of the questions that were asked as reasons for not completing
the information as it conflicted with other job responsibilities.
However, as a result of the field visits to states and individual UST
sites, some state personnel welcomed the opportunity to participate on the
project to establish a mechanism to promote technology transfer for the UST
program. The responses to the Case History File After-Action Reports
indicated the information requested is thorough in capturing the
information that would be useful in responding to leaking USTs. The state
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personnel also acknowledged their willingness to work with a computerized
database system and indicated a need for such a system, particularly with
assisting and educating new staff.
The key conclusions drawn from the analysis of the data and information
reported in the narrative section of the Case History File are:
o Most of the leaks were detected by smell (22 sites) and/or
inventory records (21 sites).
o Confirmation tests using either a tank tightness test or line
testing were reported at 21 sites.
,U o At 26 of the 50 sites, drinking water supplies were either
7r
\ contaminated or could potentially be contaminated with carcinogens.
o Indicator compounds are used extensively to determine the extent of
contamination.
o Immediate corrective actions were implemented at 46 of the 50
sites.
o The predominant treatment technologies reported for groundwater
are air stripping and activated carbon, and several included the
combination of these technologies.
o Treatment of contaminated soil consists primarily of excavation and
off-site disposal with limited information reported on the final
disposition of the soil.
o There are several effective technologies used for the recovery of
free product.
o The degree and complexity of post-treatment monitoring periods
varied from three months to two years.
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Permits were required at 26 of the 50 incidents, primarily for
effluent discharges and groundwater treatment.
The degree of clean up varied from state-to-state as well as from
site-to-site.
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SECTION 3
RECOMMENDATIONS
The recommendations derived from this project address thejneed for
technology transfer in the UST progr.am_and the short and long-term
development of the Case History File.
There is a definite need for a systematic approach for technology
transfer within the UST Program. The areas well suitedfor technology
transfer__are leak detection and verification_me.thods, .si.te_characterization
and^_assessment techniques, immediate co.r.rje.c.ti-ve-.actions including_UST
sy§tem_repj.acjement, free product removal,_and long-term corrective actions.
The forum to promote technology transfer is well suited to a computerized
on-line database because of its ease of operation, access of information by
the user and ability to maintain updated information on the state-of-the-
art techniques, developments and technologies.
The Case History File provides such a forum for technology transfer.
The initial data collection efforts of the UST incidents have been well
received by the state personnel responsible for their respective UST
programs. Several actions should be planned over the next few years to
ensure the Case History File becomes a widely used system within the UST
industry. The key actions are as follows:
o There should be a follow up with the states that participated in
the project to provide a hands-on demonstration of the system.
Concurrent with the system demonstrations, follow-up information
should be obtained for the initial incidents.
o The states that were not involved with the initial project should
be contacted to enlist their participation in the project and to
provide a hands-on demonstration of the system. This demonstra-
tion would also provide the opportunity to solicit Case History
Files for additional sites. This should be coordinated with the
respective EPA Region UST Coordinators.
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In addition to voluntary inputs, there should be a systematic
approach for collecting Case History Files on additional sites.
As the benefits of using the system become more apparent with
time, a more voluntary system would be adequate.
After there has been substantial use of the system in the field
and there is a better handle on the information and understanding
of the needs of the LIST program staff, the Case History File
should be reviewed and updated to ensure the information being
obtained is of use to the UST community.
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SECTION 4
APPROACH
The project approach included (1) an expansion of the existing Case
History File to include information on UST corrective actions and (2) data
collection efforts to establish the initial database for UST responses.
This section describes the system design, data collection efforts, and key
aspects of the Case History File.
SYSTEM DESIGN
Logical Structure of the Case History File
The Case History File's data are organized into two sections: a
database section and a narrative section. The database section allows
searches by using key words. The user selects one of 27 available search
criteria. Then the user selects either a key word or a numeric value
appropriate for the criterion. The Case History File includes the 27
search criteria shown in Table 1.
The five search criteria identified with an asterisk (*) were added to
the database section to accommodate information of specific interest to
OSCs who conduct UST corrective actions.
The narrative section of the Case History File contains detailed
reports in a plain-text format. The narratives are organized into 10
subsections as shown in Table 2.
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TABLE 1. DATABASE CATEGORIES OF THE CASE HISTORY FILE
1 - Incident number 14 - Resources affected
2 - Date of incident 15 - Area affected
3 - Date of report* 16 - Population affected
4 - Type of incident 17 - Geography
5 - EPA Region 18 - Hydrology
6 - State 19 - Depth to ground water
7 - NPL rank 20 - Annual precipitation
8 - Site name 21 - Ground materials
9 - Chemicals 22 - UST construction*
10 - Quantity 23 - Site uses
11 - Origin 24 - Containment
12 - Detection method* 25 - Removal/cleanup
13 - Main effects 26 - Site treatment
27 - Disposal
TABLE 2. SUBSECTIONS OF THE NARRATIVE SECTION
Subsection Contents
1 General Information
2 Chemical Information
3 Effects of the Incident
4 Site Characteristics
5 Containment Actions
6 Removal/Cleanup Actions
7 Treatment Actions
8 Disposal Actions
9 Operational Considerations
10 Termination of Response
10
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A user starts a search using the database section. When the user
specifies a search category and a key word or numeric value for that
category, the system creates a user's file that contains a list of all the
incidents that match the user's criterion. The user may create up to 10
files that have 10 different criteria. The user may view the data for the
incidents in any one of these 10 files at any time. Also, the user may
perform more sophisticated searches by combining files using AND/OR logic.
For example, a user may create one file by specifying EPA Region 5 (filel)
and another by specifying benzene (file2) as a chemical. The user may then
create a file of all incidents in Region 5 that involved benzene by
combining filel AND file2. The system will produce a third file (file3)
that contains a list of the incidents common to filel and file2.
Users may save the results of their searches on the host computer. The
results may be retrieved and re-used during subsequent searches at a later
date.
Hardware and Software
The system is currently running on an AT-type IBM-compatible
microcomputer with an Everex 300/1200/2400 bps modem. The microcomputer
has a 30-megabyte hard-disk drive, but only a few megabytes are used by the
Case History File.
Telecommunications are handled by the program REMOTE by Microstuf.
The Case History File programs are written entirely in dBASE II. dBASE
II was chosen over dBASE III and later versions, because it provides all
the features needed to implement the File and because it is "well behaved."
That is, it uses the operating system's functions for input and output,
whereas the later versions of dBASE use BIOS functions or direct hardware
access. dBASE III will not work properly with telecommunications utilities
like REMOTE.
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The Case History File consists of numerous small programs and
databases. Table 3 shows the roles or functions of the programs, with
indentations indicating hierarchy.
The databases are organized into third normal form. Most are very
simple databases of only two fields. This allows an unlimited number of
key words, under a given search criterion, for any one incident (subject
only to the limitations of dBASE II).
TABLE 3. FUNCTIONS OF THE CASE HISTORY FILE PROGRAMS
Main Menu
Search Menu
Search by Incident Number
Search by Date of Incident
• * •
(27 search routines in all)
• • •
Search by Disposal Technology
Display Results
View Abstract of Incident
Narrative Report Menu
View Narratives Page-by-page
Combine Results
Save Results
Recall Old Results
Leave a Note to the Operator
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The Users' Equipment
People who want to access and use the Case History File need not be
concerned with the particular hardware and software that comprise the File.
Users do not need an IBM AT microcomputer or dBase II or need to know the
command structure of dBase.
A user must have microcomputer, a modem, and a communications program
that can emulate a commonly used terminal, such as a DEC VT-100. Most
modern modem communication programs provide this capability.
A user's guide is available from TIX that provide information on how to
make a telephone connection to the COLIS computer and how to search through
the Case History File.
DATA COLLECTION
Data collection began with the 10 EPA regional UST coordinators. The
EPA UST coordinators indicated that the detailed information on UST sites
was located at both state and local offices and recommended states in which
to begin the initial data collection efforts. The states were recommended
on the probability of obtaining the case history information sought for the
project. The EPA UST coordinators provided the names and telephone numbers
of the state personnel. A check list requesting general site information
was sent to 28 states and the District of Columbia.
The check list was developed to collect initial information on sites
and used as a screening tool to reduce the number of sites for the initial
data collection efforts to a manageable number. The check list was
tailored to ensure that sites selected initially would provide a good
representation of diverse hydrogeological conditions, environmental
13
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settings, geographical areas, and corrective action technologies. The
check list contains information on tank locations, tank size, quantities
and durations of leaks, types of product, hydrogeological data, corrective
action technologies used, and cleanup target levels. In addition, the
sites were limited to those involving petroleum products. An example of
the check list used for screening sites is provided in Appendix A.
The check lists were reviewed, and sites were selected for possible
inclusion in the case history database. Sites that had completed
corrective actions were preferred; however, very_few sites.,haye_completed
corrective actions involving_ground_yate,r. Therefore, the criteria were
— - - ~ "' f
relaxed slightly to ensure that some groundwater cleanup activities were
included. Sites with corrective actions of sufficient duration to evaluate
their effectiveness were also considered for inclusion in the database.
The OSC/RPM for each selected site was then contacted to determine whether
they preferred to complete an after-action report themselves, provide
copies of other reports and files so that a project team could complete an
after-action report, or have the project team visit the office of the
OSC/RPM to complete the report. Whenever possible, site visits were
arranged in order to observe the corrective action in progress.
After-action reports were sent to 24 states and the District of
Columbia. Individuals who agreed to a site visit were sent after-action
reports in advance to familiarize them with the required information.
The states that participated in the initial data collection efforts,
the information they provided, and the locations of site visits are shown
in Figure 1. Site visits were made for 14 ongoing corrective actions in 7
states. A total of 50 after-action reports have been collected from 16
states and 7 local offices. Twenty-nine after-action reports were
completed from copies of files, 9 were obtained through site visits, and 12
were completed by OSCs.
14
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Exxon-Gull
Olympic Pipeline*
Caltrans
Armour Oil
City of Cypress
J.C. Penney
Mobil
Exxon
States provided the following:
Both Check Ust(s) and After-Action Report(s) tXXX
After-Action Report(s) 1/SA
Site Visit(s) . u-*-a
Exxon
Union 76
Albright-Wilson
Summervllle Pantry
Cltgo
Hammocks Fire Station
Figure 1. Initial UST Case History File database collection efforts.
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KEY ASPECTS OF THE CASE HISTORY FILE
The headings of the narrative subsections of the after-action report
have not been altered; however, the information requested in the
after-action report has been modified extensively to solicit more
UST-related data from the reporter.
The after-action report has also been modified to solicit information
of specific interest to OSCs/RPMs for UST corrective actions, in addition,
the terminology has been changed slightly to accommodate the jargon of the
UST industry and the proposed UST regulations. The modifications to the
narrative section can be grouped in three major categories: (1) site
characterization and assessment, (2) corrective action technologies, and
(3) implementation and cost information. These modifications are described
below.
Site Characterization and Assessment
This Section includes the subsections on general information, chemical
information, effects of the incident, and site characteristics. The
general information section was expanded to obtain site history information
on the UST facility and the tanks, the nature of the release, and leak
detection activities. To capture information on the extent of
contamination, the chemical information subsection requests data on the
contaminants such as average and maximum product concentrations, and
sampling locations for both soil and ground water. The effects subsection
was amended to assess the immediate threat due to the release, such as the
potential for fire or explosion, the impact on public health and the
environment, and the involvement of emergency service organizations. The
site characteristics subsection was expanded to collect information on
hydrogeologic studies, and site investigation techniques that were used
(e.g., soil gas surveys). This information is intended to provide the OSCs
and response personnel with site characterization techniques and enough
information on the site to establish the framework for assessing
alternative corrective technologies.
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UST Corrective Action Technologies
UST co rrective action technologies are classified into three separate
subsections: immediate, long-term, and jEree_prodiuc:L removal. The
immediate corrective action subsection focuses on the removal and
replacement or repair of the tanks/piping, treatment and disposal of
backfill material, and any unconventional/innovative approaches that were
taken. The subsection on long-term corrective actions focuses on
identification and implementation of cleanup objectives and the overall
effectiveness of the action upon its completion. The free product removal
subsection requests information on collection and removal methods,
disposition of recovered product, alternatives that were considered, and
lessons learned. By having this information, OSCs who respond to future
UST releases will have insight into the various methods and techniques
employed to carry out corrective actions.
Implementation and Cost
Implementation and cost information is contained in the subsections on
the effectiveness of the corrective action, operational considerations, and
termination of response. The effec.tLveness-subsec.tlon was tailored to
specific in^orjBatlQn-J3n_cleanup requirements, termination criteria, and
post-monitori ng_act iv.i.t ies. In view of the complexities that may be
encountered during cleanup at an UST site, the operational considerations
subsection was modified to address technical expertise or support that may
have been obtained from outside sources such as federal, state, and local
personnel, and responsible party consultants or contractors, in addition,
the cost information in this subsection has been restructured to identify
both capital and operational costs for each phase of the corrective action:
immediate action, long-term actions for soil, long-term actions for
groundwater, and free product removal.
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Table 4 is a summary of the salient information requested in the
narrative subsections. It also identifies the subsection headings that
would be seen when accessing the system and the UST-related information in
parentheses. It should be noted that the Case History File is undergoing
additional reviews and modifications and may not be in the same format
described in this report.
TABLE 4. CONTENTS OF THE CASE HISTORY DATABASE NARRATIVE SECTION
HEADING and CONTENT of SUBSECTIONS
General Information:
Contact information, tank information, leak detection, verification
methods, and extent of leak
Chemical Information:
Primary substance involved in the leak, initial concentration, Sampling
location, test method, and hazards encountered
Effects of the Incident:
Effects on public health and the environment, anticipated impact if no
action was taken
Site Characteristics:
Land use, hydrogeologic study, geology of site, data quality
objectives, site characterization techniques used, indicator compounds,
and risk assessments
Containment Actions: (Immediate corrective action)
Selection rationale, effectiveness, duration, tank/piping removal,
protocols, problems, innovative approaches, and disposal methods
(continued)
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TABLE 4 (continued)
Cleanup/Removal Actions: (Long-term corrective action)
Selection rationale, effectiveness, duration, cleanup level
requirements, and problems encountered
Treatment Actions: (Free product removal)
Selection rationale, effectiveness, duration, fate of recovered
product, fate of contaminated water and any problems encountered
Disposal Actions: (Effectiveness of corrective actions)
End point concentrations, termination criteria, post-monitoring period
Operational Considerations:
Required permits, contacts providing technical advice/support, public
involvement, administration problems, and cost information
Termination of Response:
Cleanup assessment and any additional comments
The after-action report was field-tested and critiqued by several OSCs
for UST corrective actions to ensure that the requested information would
be available and beneficial to response personnel. The OSCs reviewed each
element of the database and narrative sections for their potential
relevance and use by other OSCs. In a few cases, they recommended
including information that was not already specified in the after-action
report, as either additional fields or field descriptors. The modifications
that resulted from field visits with the state OSCs provided valuable insight in
responding to releases from leaking USTs. The after-action report used to
collect case history information is provided in Appendix B.
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SECTION 5
ANALYSIS OF DATA
This section presents an analysis of the data collected during the
initial project activities. The information is organized under the
subsection headings in the Narrative Section of the Case History File as it
was collected for UST corrective actions as described in Table 4. The data
is presented as reported in the after-action reports. Attempts were not
made to interpret the data or make assumptions on behalf of the
respondents. Case History Files were developed for 50 incidents. The
objectives of the project were to focus on petroleum USTs and or completed
or ongoing corrective actions. The data presented for the_jQ_incidents
should not be construed to be representative_Qf JAe.jov,ejal_l_lJST_p.r.o.gram..
GENERAL INFORMATION
This section provides insight into the background of the release rather
than the actual corrective actions that were implemented. Because some
general information categories are used for search criteria and others
require more detailed responses, general information is recorded in both
the database and narrative sections of the after-action report.
The database section solicits brief information on:
o Site location including the EPA Region and state
o Origin of the incident
o Leak detection
o Land use
The narrative section incorporates detailed information on the
individual sites into the case history file in the following categories:
o Contacts for further information
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o Controls for the corrective action
o History of the tank and tank characteristics
o History of previous releases at the site
o Initial and confirmatory leak detection methods
o Initial measures taken to stop the leak and mitigate hazards
An overview of the general information responses are presented below
according to the respective sections.
Database Section
Site Location—
Based on information provided in the database section, the 50 sites
addressed in this report represent eight EPA Regions covering 16 states and
the District of Columbia. Only six After-Action Reports included latitude
and longitude coordinates as part of the site location.
For most of the fields in the database section, respondents are
instructed to indicate all of the descriptors that apply to their
particular incident. Therefore, the number of responses for particular data
fields will be greater than the total number of incidents, as evidenced by
the results presented below.
Origin of the Incident—
Tanks accounted for 27 of the releases and UST piping accounted for 22.
UST corrosion and installation error was indicated at 16 and 7 sites,
respectively. At 19 of the 50 sites, the release was attributed to several
factors rather than a single source.
Leak Detection—
Most of the leaks were detected by smell (22) and/or inventory records
(21). Leaks detected by sight and tank tightness testing were reported at
16 and 11 sites, respectively. In a few cases, leaks were detected using
external detectors or miscellaneous methods.
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Land Use—
The majority ofJbhe_si.tfis__(45) were locate.cLin.-comme-r-eia-l—areas,
followed by residentiaJL_ar.eas_(.2.4J.. Twenty sites were in areas that were
designated both commercial and residential. Additional sites were in
rural, industrial, parkland, or agricultural settings.
Narrative Section
Contacts—
All 50 after-action reports provided contacts for the response actions,
but only 10 indicated where the information was logged.
History of the Tank—
The amount of information on the history of tanks varied. Well over
half the respondents identified the number of tanks at the facility (44
sites), the source of the leak (35 sites), and the percentage of tank below
grade (31 sites). There were 4, 14, and 15 nonresponses in each category,
respectively. Twenty-two respondents identified the age of the tank (or
tanks) which ranged from 8 days to greater than 30 years. Of the 22, 2
were over 30 years old; 6 were 20-30 years old; 8 were 10-20 years old; 2
were 5-10 years old; and 4 were less than 5 years old. There were 14
nonresponses. Corrosion protection and release detection systems were
rarely installed on the tanks. Of the 32 responses only 5 reported having
corrosion protection. There were 13 nonresponses and 9 sites for which
information was unavailable or unknown.
Similarly, only 3 tanks had a release detection system. The type of
release detection system employed was not indicated. There were 19
nonresponses.
None of the tanks had overfill/spill protection equipment. There were
25 after-action reports with no response. For 8 sites, the information on
overfill/spill protection was unknown or unavailable.
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Previous Releases—
Prior releases were noted for 6 sites. For 21 sites, there was no
response. For 5 sites, this information was reported unknown or
unavailable for 9 sites.
History of the Release—
For the most part, information on the history of the release was rather
limited. The responses typically indicated the date the leak was detected,
the quantity of product involved, and whether or not the contamination
problem was due to a current or past release. Past releases are releases
that occurred prior to the most recently detected leak. Current
contamination problems may result from past releases where the leaking tank
was never repaired/replaced or from a previous release where no corrective
actions or inadequate corrective actions were implemented. The
contamination problem was due to the current releases at 41 sites and from
past releases at the remaining 9 sites. Very few responses reported when
the leak actually occurred.
Only 6 after action reports contained information on the rate of the
leak, and even fewer reported on the extent of the leak. Typically, the
question on the time, rate, and extent of the leak was unanswered. The
duration of the leak was identified for 13 sites. This information was
reported as unknown or unavailable for 16 sites.
Leak Detection—
Of the 50 releases, at least half (26) were initially detected by odor
or by inventory records. Suspected releases were confirmed using tank
tightness testing or line testing at 21 sites, while miscellaneous
confirmation methods were used for 15 sites. Information was not provided
for the remaining 14 sites.
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Initial Measures—
Thirty-two after-action reports identified initial measures taken to
stop a release and to mitigate health and safety hazards. Of this
number, six shut down the system; four removed the tank; and, four vented
buildings or soil. At two sites, either the health department or fire
department was notified as part of the initial action. In general, a
variety of initial measures were implemented, and no single action was
observed more frequently than the other initial measures.
CHEMICAL INFORMATION
The chemical information section of the Case Histories Files identifies
which petroleum product is released to the environment. Information
regarding quantification of the problem including estimated quantity and
results initial of contaminant sampling and test methods is provided. In
addition, the impact of the contaminant on response personnel and public
health as well as the actions taken to mitigate the impacts is collected.
Response
The 50 UST case histories consisted of _4.3_sites involving gasoline and
7 involving diesel or heating__fuej.s. Equipment which was used to
characterize the leaking UST included, in most cases, the use of an
explosimeter to determine the threat of a fire or explosion. Other field
equipment mentioned were the HNu vapor analyzer and draeger tube for
measuring concentrations and an electronic tape to measure free product
floating on the ground water. The immediate actions to protect response
personnel and the public included evacuation of the areas, ceasing
operation of the service station, and in a few sites, the use of
respirators until vapor concentrations were reduced.
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Quantification
Spill estimates were provided for _28js.iteg.. __At~8~si.tes.,._the_spills
were reported to be over 5_0_0_CL_qalLo.PS. Analyses of the contaminated soil
and ground water were not uniformly reported; however, res.uLts_ f or total
petroleum hydrocarbons (TPH) and/or benzene ,_tp_lue.ne.,.-e.thylbenzene«.and
xylene (BTEX) were contaminants typically reported. All reported test
locations were within 200 feet of the source. Test methods typically
reported were EPA Methods 8020 and 8015 for soil samples and EPA Methods
601, 602, and 624 for groundwater samples. These methods are GC or GC/MS
procedures that produce the TPH (Total Petroleum Hydrocarbons) or BTEX
(Benzene, Toluene, Ethylbenzene and Xylene) results. EPA Method 5030 to
purge and trap organics from soil samples was also used.
EFFECTS OF THE INCIDENT
The purpose of the section on effects was to identify the impacts of
the leaking UST. An obvious effect is the contamination of soil
surrounding the UST system and the potential contamination of ground water.
In every case, this problem would have been compounded by the failure to
take the action reported in the case history. The after-action reports
indicate that the long-term impacts of no mitigation would have been
aquifer contamination, drinking water contamination, surface water
contamination, and fire or explosion hazards.
Fire/Explosion
The major reported effect was that of a fire or explosion from vapors
in those 43 sites involving gasoline. The liquid and vapors were reported
in sewers, storm drains, and other utility trenches. Vapors in nearby
basements were reported as a problem in a couple of cases. Involvement by
the fire department was also reported. This involvement included
evacuation of the area, closing the service station, checking vapor
concentrations, and oversight of tank removal operations. Flushing of
liquids from sewers and storm drains and ventilating these lines and
basements were also reported. An interceptor trench that prevents the
spread of contamination was built at a couple of sites.
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Drinking Water
At-26-of—the-50_si.tes_wher.e-dr.inking_wate.r— supplies_wer.e_oj_c_Q.uldJbLave
been impacted, the inaes.ti.on-of-the-car.cinoqeni.c_c.onsti.tuents_o.f_gasoline
^ueh_as_benzene—we-ce—Eepotted_as_a_public-hea-l-feh-Gonce-rn. Public health
officials were typically notified in these situations and sampled drinking
water supplies. Where drinking water supplies were found to be contaminated,
alternate supplies were provided and public health advisories were reported.
Surface Water
_ At 7 of the 50 sites, the impact on surface-wa.texs_w3s_r.epar.ted_as—an
area of concern. This occurred at sites where the fuels entered storm
. •
drains or flowed over the surface, or where the source was located close to
a stream or surface water. Sorbents were used to mitigate these effects.
Sewage Treatment Plants
At a couple of sites, concern was expressed on the possible adverse
impacts to the sewage treatment plant where there were leaks into the sewer
lines.
SITE CHARACTERISTICS
This section is extremely important in identifying the site conditions
and the site characterization studies that had to be undertaken to understand
the subsurface conditions and to define the extent of contamination. The site
characteristics are critical to the corrective action selection process.
The information is intended to enable the user to review the various field
techniques employed to evaluate similar or differing site conditions. Some of
the key results include:
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o There is a heavy reliance on installing numerous monitoring wells
to define the extent of contamination.
o The use of soil gas surveys to assist with well placement is an
emerging field technique that has been implemented at several
sites.
o Indicator comrx3und^/_p.r-e.domina.tely-BTX,--BTEX--and-to.ta]^-pe-trQleum
hydrocarbons (TPH) are used__exj:,ejisiy.e,ly_tQ _djete.naine_ the .extent^of
contamination .
o For 4 of the 50 projects, the respondents indicted that they would
have done something differently such as additional sampling on
certain parts of the projects and the use of a soil gas survey.
o A risk assessment was completed for only one site.
The results of the study regarding site characteristics are presented
in the categories of hydrogeological studies, description of the aquifer
and subsurface geology, field techniques, and sampling and analysis.
Hydrogeological Studies
varying complexity have been performed at 40
of the_50. At the 10 sites where a hydrogeological study was not performed,
the case histories are for immediate corrective actions, such as product
removal, and follow-up projects for the long-term actions were underway. The
primary objectives of the hydrogeological studies were to obtain information
on groundwater depth, direction of flow, and rate of flow. Most of the
respondents identified the depth to ground water and annual precipitation.
While the reports that were completed by referring to project files contained
information on the depth of ground water, they did not contain annual
precipitation data. Specific methods used to conduct the hydrogeological
studies were identified under site characterization techniques.
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Aquifer and Subsurface Geology
Qnly_2.6_jaf_the_5.Q_re.spondents_.i.deiitIfied the aquife_r__classif i ca t i on. 0f
the 50 sites, 25 involved unconfined aquifers.,.,5_iriKo.lve.d_confined aquifers
and 6 impacted aqujfeE_r,e£harfle—areas..- In addition to the fields specified
in the database section of the after-action report, several respondents
reported alluvial deposits or limestone as other categories.
Out of the 50 respondents, 34 identified soil types, and only 19
identified soil permeability which was usually classified as high, medium, or
low rather than an actual value.
Field Techniques and Sampling and Analysis
Where field studies were completed, the most common technique used to
define the extent of contamination consisted of soil borings and the
installation and use of monitoring wells. MpdeliSS-J*35 used at only j|_srtes
^to_assist with plume identiflca.ti.Qa. Soiljgas surveys or other field
screening techniques wejre_^sgdjitJ7 sites as parjt_of_jthe_gverail study,.__^Theo
compl-exnl-fey-of—the_field-s.tudie.s._r.anqedJ_frgm_havinq 6 shallow^ soil borings J:o
installing 100 monitoring well s. ^A£_the_lafete r_jslte_,_ the_rep_Qr te r_JLndi cated
that_the,v_would have used soil ga_sjanalv.s.is_ea.rljer in the project. A
4 sites, the .reporters established Data__Quali.tv..Objectives_jto_tar.qe.t-the-
sampling and analv_sjLs_l.e.v.elS-and-to-de.tej:mine the extent of £on taminajt i on.
Indicator compounds were used at 38 sites, and most of the sites used more
than one indicator compound. The indicator compounds used Jji_despending
order of extent^of-use were BTX/BTEX (26 sites), TPH (10 sitejsh^JTHC (4
sites)_,_JirBE_(.3_si.tes-)-and-iead--t3 sites).
IMMEDIATE CORRECTIVE ACTIONS
The section on immediate corrective actions contains information on
initial corrective actions to mitigate the impact of a sudden or recently
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detected release. Such actions are usually initiated within a few hours to a
few days from the time the release is discovered, but may take from a few
hours to several months to complete. Immediate corrective actions focus on
source control and on the collection and containment of the released product
to minimize immediate risks to human health and the environment.
This section solicits detailed information for the following pertinent
aspects of immediate corrective actions:
o immediate actions taken before and after the agency's involvement
o selection criteria, effects of the weather, and duration of the
actions
o removal and replacement protocols for tanks/pipes
o alternative methods that were considered
o special problems that were encountered and their effects on the
actions
o unconventional or innovative approaches
o disposal methods and the rationale for their selection
o new or different methods to be used if confronted with a similar
situation in the future
A statistical overview of the information contained in the Immediate
Corrective Actions section of the after-action report is presented below.
Immediate Corrective Action Technologies
Ipnedia te_r.esponse-ac.t ions_werfi_rfipoxted._at_M_out_ oJL_5Q_sit ? jtr_
predominant technologies r_epo_rted_wer.e^sml-r.emoyaLJ_at 17 sitesj^and
^SEfeXi&g—thg_tgnk (at ll.jsites). Removal of free product, replacing the
piping, and removing the tank were implemented at 9 sites. Additional
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technologies observed at several sites were tank testing, tank excavation,
installation of monitoring wells, pipe repair, explosivity technologies
monitoring, and tank replacement. Immediate
in only 2 actions included, booming off the area ,_soil venting, interceptor
trenches, abandonment,
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Selection Criteria /Effects of the Weather/Duration of Actions
Prior to the regulatory agencies involvement, immediate corrective
actions were initiated at 19 sites. Twenty-two sites did not have prior
immediate actions. There were 9 after-action reports without a response to
the questions.
The majority of the after-action reports provided a reasonable amount
of detail on the immediate actions taken. Minimal information- was- supplied
regarding the selection ja^qnale_for._the..linmedi_ajte .corrective..act.ioij.
There were only three responses regarding the effectiveness of the actions
and ^alljbhe^ actions were repgrted^as being effective.
Comments on the weather were reported at 11 sites; all said that
weather was not a factor. The length of time to complete the actions was
provided for only 7 sites and ranged from as little as 1 day to as long as
5 months.
Removal/Replacement Protocol
Removal and replacement protocols were provided in 18 of the 46
after-action reports. At least 10 of the protocols adhered to state and
local fire codes, API (American Petroleum Institute) standards, NFPA
(National Fire Prevention Association), or state UST regulations. There
were only 5 sites where the protocol was unknown. No information was
supplied for 8 sites. This question was reported as nonapplicable for 11
sites.
Alternative Methods
Of the 46 immediate corrective actions, alternative methods were not
considered or there was no information for 22 and 19 sites, respectively.
Alternative methods were identified for only 4 sites while 5 were
nonapplicable.
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Special Problems
Although 21 of the 46 immediate actions did not involve any special
problems, there were 15 reported actions that had a variety of problems.
Technical problems were encountered most frequently (11 out of 15), but
also mentioned were problems dealing with litigation and insurance
coverage. The problems resulted either in delays in cleanup, additional
precautions being taken, or alternative methods being implemented.
Unconventional/Innovative Approaches
Only a few sites (5 out of 46) reported the use of any unconventional
or innovative approaches taken as part of the response action. Among the
approaches mentioned was the use of a television camera to scan a sewer
line to locate a hole. The unconventional or innovative approaches were
reported to be effective at 4 of the 5 sites. No information was provided
for the remaining site.
Disposal Methods
Because the question on disposal methods in the Immediate Corrective
Action section pertains to disposal of soil, water, tanks, and pipes as
well as free product, a variety of disposal methods were identified from
the 2.4 responses to this question. A landfi 11 was used for_disposal_in_ 9
sites, followed bv_r^ej^cIiriq_a.t—8._andJa_sanitary_.sewfi.r_at-5..- Additional
methods mentioned included, storm drains, landfarming, storage,
incineration, and aquifer recharge.
New or Different Methods
Ten reports elaborated on new and different methods that would be tried
if faced with a similar situation again, and 6 reports stated that the same
procedures would be used again. Fifteen responses indicated "none", and 18
of the 46 after-action reports had no comment.
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LONG-TERM CORRECTIVE ACTION
Long-term corrective actions are those actions undertaken to mitigate
the more extensive effects of contamination on public health and the
environment. They are not clearly separable from the immediate actions
taken or the actions taken to recover free product that has been lost.
Long-term corrective actions are applied to both the groundwater and the
soil. In both cases, the action can be presented as an in-situ treatment
or a unit operation.
Ground Water
Long-term corrective actions for ground water vary greatly in
complexity. The alternative to unit operations is in-situ treatment. The
only clear-cutjnethod of in-situ treatment was biological. flierobial
a£Jtloja_was_utilized_at_Qnly_2^of_the 50 sites^ In these incidents, it is
not clear from the report what application or nutrient methodologies were
employed.
At two of the sites, the groundwater contained an indicator chemical in
concentrations above the established standards for groundwater, but below
the local standard for discharge to the sewage systems. In these cases,
the groundwater was pumped directly into the sewage system without prior
treatment.
At the other end of the unit operation spectrum, the groundwater was
extensively treated with a well-planned series of steps. Preliminary
separation was accomplished either in-situ with a dual pump system, or
immediately after the recovery with an oil/water separator. The effluent
water was then treated with air stripping followed by carbon adsorption,
and eventually discharged to the sewer system.
There are two pumping systems commonly employed to remove groundwater
from established wells. The first system is the single pump system. This
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uses one pump to transfer all liquid in the well to the surface. Both
water and any product present will be transferred. The single pump systems
were used when no free product was encountered. If floating product was
present, single-pump systems discharged product to gravity separators.
The second type of pump used is the dual pump system. In this
application, two pumps are placed in the well. The lower pump is fixed and
transfers water to the surface for treatment and maintains a cone of
depression to induce floating product to flow by gravity down the core of
depression to the well. The upper pump (which often floats on the water
surface) removes the accumulated product. The upper pump often uses an
interface locating probe to detect the accumulation of product on the water
and minimize the probability of transferring water. The upper pump may
also be timer controlled.
Air strippers used dual pump systems nearly three-quarters of the time.
Activated carbon systems used single-pump systems nearly 50 percent of the
time.
Groundwate.r—tr.ea.tment_was-r.epo.r.te.d-at-41-si.tes-and~invol.ved. 4 pjrimary
techpigufi.s. Each technology and the occurrence of that technology is
outlined in Table 6. The applications did not, as a general rule, utilize
a single technique but a combination of techniques. This results in the
total number of incidents being greater than the number of sites; involved
(41). A discussion of the various techniques is presented in the following
sections.
Air Strippers—
Air stripping is a method of removing dissolved volatile organics, such
as BTEX compounds, from the water. Air is forced over thin layers of water
within a column packed with material to encourage the volatilization of
contaminants from the water into the air transference. Air strippers are
very commonly utilized. Nearly half (23) of the unit operations used air
stripping. Usually, the air stripper is fed from a dual pump.
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TABLE 6. GROUNEWATER TREATMENT TECHNOLOGIES
Technology Incidents Reported
Air Stripping Column 23
Activated Carbon 19
Interceptor Trench 11
Gravity Separator 8
Activated Carbon Treatment—
Activated carbon treatment is a water treatment that traps the organics
dissolved in the water in a stationary carbon bed. The carbon will
eventually become saturated with organics and stop adsorbing any additional
contaminants. The carbon is then replaced. The used carbon is either
regenerated or treated as waste.
Activated carbon units were used at 19 sites. At 8 of these sites,
activated carbon treatment followed air stripping as a polishing step to
achieve maximum clean-up levels.
Interceptor Trenches—
Interceptor trenches are used primarily for free product recovery.
They may also be used as the sole means of groundwater treatment. The
trench provides access to the ground water and free product in lieu of
pumping from wells for recovery. The use of interceptor trenches is
limited, however, by ground water depth. The 11 sites that used an
interceptor trench also used a single pump system (6) or a dual pump (4) as
part of the recovery system. At 2 sites the pumps were installed on vacuum
trucks. The specific recovery method used was not indicated for one site.
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For those sites where the depth to groundwater was identified, the
water table was within 15 feet of the ground surface.
Gravity Separators—
A gravity separator is a coarse method of separating free product from
groundwater. The lighter free product phase floats on the water and can be
removed for independent disposal. The water phase is either further
treated or discharged, depending on the amount of product in the recovered
water. In every case, the separator is fed by a single pump . This
strongly indicates that the gravity separator is used as a substitute for
dual pump systems. The rationale for the substitution may be due to
economic or hydrogeologic considerations, however, this is not indicated in
the data. In general, the effluent water was further treated before
discharge and usually involved activated carbon.
Gravity separators were used with single pump systems at eight sites.
At five sites the water was further treated with activated carbon. Gravity
separators were the final treatment at three sites.
The ultimate disposition of the water treated with the unit operations
depends on the various standards for acceptance and on the availability of
the treated water receptacle. For example, if the treated groundwater
meets the standards for storm sewer acceptance, but only sanitary sewers
are available, then sanitary sewer discharge is more probable. In general,
the higher-technology treatments are more likely to discharge treated water
back into the aquifer when the destination was specified. Treated ground-
water was usually reinfiltrated (10 sites), discharged to a sanitary sewer
(7 sites), or discharged to a storm sewer (7 sites).
Soil
Like groundwater treatment, soil treatment technologies vary in
complexity. The major difference appears in the relative number of
techniques employed for the corrective action. Overall, 29 o^the 50 sites
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had spme_sor-t-of—Gor-recfeive-actign, listed for soil-.. ^All but 2 of these
ttsed^excavation of contaminated soil_as either the primary or secondajry
remediation_tool. Other corrective actions utilized in the soil treatment
were aeration (both in-situ and ex-situ), biological treatment, and
incineration. Many of the respondents reported more than one technology
for a given site. The number of sites using the various technologies are
listed in Table 7.
TABLE 7. SOIL TREATMENT/DISPOSAL TECHNOLOGIES
Technology Incidents Reported
Excavation 25
Aeration 10
Biological 3
Incineration 2
When aeration was used, the numberjDf applications were ,e,venly split
between in-sltu. aeration -and- batch-treatment .of excavated soil . _Eyen when
in-situ .treatment was_app.l Led ,_ the^jovejrall^ process- -Uti l.i zed soi .'[...excavation^
in^two j)f_the— five-cases^. Clearly, unit aeration operations on the soil
required excavation of the soil in every case.
degradation ..of -contaminants
was used in three of the cases_._ Injbhejsje_applications, the spiljwas^
excavated , seeded^ JEe rti 1 i zed , and aerated. This use of aeration of the
excavated soil is not included in the excavation and aeration techniques
listed in Table 7. The difference in the application of air to the soil
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warrants a differentiation between these technologies. At one site,
however, both aeration in the earlier sense and microbial attack were used.
In most of the cases, the ultimate treatment of the excavated soil is
not specified. ,Indications are limited to vague responsessuch as "hauled
to approved disposal facility" or something similar. In these cases, the
response was limited to simple excavation. The uncertainty of any
treatment applied at the receiving facility probably accounts, in part,
for the fact that only two after-action reports listed incineration as the
soil treatment. In both of these cases, the incineration was specifically
designated as on site.
FREE PRODUCT REMOVAL
Free product removal generally refers to the recovery of product that
is located in various subsurface settings in large enough quantities that
it can be removed by mechanical methods. Although usually initiated as
part of the immediate response, free product removal may be of extended
duration. In either case, free product must first be pumped to the surface
where it can then be recycled or treated.
Topics of significant interest addressed in the free product removal
section are:
o free product removal methods, their effectiveness and duration
o fate of the recovered product and contaminated water
o alternative methods that were considered
Observations of the results obtained from this section of the
after-action reports are discussed below.
Free Product Removal Technologies
F.r.ee_product remoyal-was_r^poJrjt^d_^t^2-jaf—the 50 sijtes. The methods
identified for the 42 sites represent the technologies commonly employed to
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remove free product and are summarized in Table 8. At 18 sites, free
product removal consisted of several technologies (2-3) used in
combination. This results in the number of incidences reported in Table 8
being greater than the total number of sites involved (42). Pump systems
were utilized at 26 sites. The dual pump, used at 10 sites was
predominate, followed by the scavenger pump at 8 sites. The pump systems
at the remaining 8 sites were not specifically identified. Recovery
systems were reported at 14 sites, while trenches were reported at 5.
Additional devices utilized for free product removal include the vacuum
truck, skimmer, gravity separation tank, sorbents and incineration.
TABLE 8. FREE PRODUCT REMOVAL METHODS
Technology Incidence Reported
Pump System 26
Recovery System 14
Hand Bailing 6
Trench 5
Vacuum Truck 5
Skimmer 3
Separation Tank 3
Other 3
There was only 1 site where the method used for free product removal was
hot provided. ErjieJpjjaduc.t-removal-ac.ti.ons-_yffiLre_c.onsidered very effective
or je.fffi.c.ti.v.e_a.t. 18 ofJbhe_42_sltes.,_while-only_2_we.r.e-r.epor-ted-as
ineffective Information-on-the-ef-feet-i-veness-of—the-actions-at-the
remaining 22 sites was not provided.
39
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Twenty-five of the 42 after-action reports did not contain information
regarding the duration of the free product removal actions. For the 12
sites that did address the duration, the length of time required to
complete the actions ranged from as little as 6 hours to as long as 3
years. At 5 sites, the free product removal actions were incomplete.
Disposal
Information was generally available on the fate of the recovered
product as well as the contaminated water. In 16 of the 42 responses, the
product was recycled. There were 7 sites where the product was stored in
tanks and 3 sites where the product was disposed of at a hazardous waste
facility. Twelve responses were unsure of the fate of the product or did
not provide any information.
Contaminated water was typically discharged into a sanitary sewer, a
storm drain or recharged to the aquifer. In a few actions, the water was
discharged to surface water. At two sites, the respondent reported the
treatment of the water with an air stripper but failed to provide
information on its final disposition. Three respondents were unsure of the
fate of the contaminated water, while 16 did not report the disposal
method.
Alternative Methods
There were only 6 after-action reports that elaborated on alternative
methods that were considered but discarded. Alternative methods were not
considered at 20 of the 42 sites, and 14 respondents did not provide any
information.
EFFECTIVENESS OF CORRECTIVE ACTIONS
Each of the corrective actions was evaluated in terms of the effectiveness
in meeting their intended objectives. Pollutant concentration reductions, free
product recovery, and plume control were considered in these evaluations.
40
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Terminated corrective actions were evaluated by the OSC upon completion of the
actions. The OSC did not always assess ongoing cases. When it was sometimes
obvious that the process was achieving the intended treatment goal, the
treatment was classified as effective. For other sites, insufficient
information was available to make a clear decision. Vague references were
interpreted by the case reviewer. For example, it is not clear if "Quite
Effective" is superior to, the same as, or inferior to simply effective.
Corrective actions were classified as very effective, effective, or ineffective,
where information was provided. The number of corrective actions associated
with each of these categories is listed in Table 9.
TABLE 9. EFFECTIVENESS OF CORRECTIVE ACTIONS
Evaluation Incidents Reported
Completed Corrective Actions 11
Very Effective 5
Effective 5
Ineffective 1
Ongoing Corrective Actions 39
Very Effective 7
Effective 21
Ineffective 3
Not Specified 8
Of the 50 corrective actions assessed, 39 are ongoing as of the writing
of this report. The ongoing cases were evaluated based on performance to
date, and do not imply a final evaluation of the corrective action used.
41
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The categories created for these evaluations are intentionally very
broad. Each case should be assessed separately to gain a proper
understanding of the actual effectiveness. For example, ongoing cases
where certain objectives have been met but others have not been met were
classified as effective. It is assumed that the treatment will ultimately
be successful in the currently deficient areas, or that a higher degree of
effectiveness will be achieved in time.
The performance of certain treatments changed over time. Actions that
were initially ineffective but improved with time, or originally quite
effective but deteriorated with time, have also been classified as
effective. At one site, the corrective action program was very successful,
but excessively low groundwater levels eventually forced the termination of
the project; the corrective action was also listed as effective. Another
experienced occasional physical problems with pumping wells at times, and
had no difficulty at other times; the corrective action was also
categorized as effective. As a general rule, the treatment system was
given the benefit of the doubt.
It is worth emphasizing that the data for the sites with the ongoing
corrective actions show a definite shift toward the effective category.
This is a result of, among other things, (1) the benefit of doubt discussed
above, (2) incomplete treatment processes difficult to list as extremely
efficient, and (3) overall evaluations not being assessed by the OSC.
Overall, there are very few ineffective classifications, less than 10%.
Presumably, treatments that were ineffective failed to become the treatment
techniques. They were abandoned in lieu of an alternative technology.
This will tend to skew the results to a more positive result.
The effectiveness is a measure of the ability of the treatment system
to remove the contaminants from the environment. It is an overall
assessment of both the ability to remove the contaminant and the rate of
removal. The treatment is progressing to some end point. That is, the
treatment is not expected to operate for time etetnal. The definition of
that end point varies from site to site. The end point criteria are listed
in Table 10.
42
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TABLE 10. END POINT CRITERIA
Response Incidents Reported
Not reported 20
OSC/agency-determined; variable 16
Established standards 7
Benzene concentration standard 3
Original condition 1
Drinking water standard 1
No-treat condition 1
No add gains 1
The classification of OSC- or agency-established standards implies that
the standards are established for each specific site in the state using the
expertise available. The standard is established based on the standards
implied by the items listed below. For example, the standard may place
added weight on the drinking water standards when wells are in the area and
lower when the water in not potable. An evaluation is made for termination
of treatment, but the standards vary from site to site.
The final or most-recent concentration of contaminant in the ground
water was requested depending on whether the treatment was completed or on
going. None of the after-action reports indicated the actual concentration
levels or the contaminants used to make the decision. When there was a
response, coupled with the above information, the determining factor was
generally BTEX (collectively or individually) or TPH. Overall, there was a
response in roughly 60% of the cases.
Contaminant levels may increase after the termination of treatment.
This could be caused by the recontamination of groundwater from soil that
43
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had not been sufficiently decontaminated, influx from other groundwater
that had been isolated, and so on. When this is a concern, a
post-treatment monitoring period may be required. The number of sites
identifying the total duration of post-treatment monitoring is listed in
Table 11.
TABLE 11. POST-TREATMENT MONITORING DURATIONS
Response
Incidents Reported
No response
Not yet determined
No monitoring
2-year monitoring
1-year monitoring
6-month monitoring
3-month monitoring
20
9
9
2
8
1
1
To differentiate from the post-treatment monitoring period, the
frequency of sampling during that period, when reported, was typically
quarterly. There were a few cases where the frequency tapers from weekly
to monthly to quarterly over the time frame. There was also a general
provision that three consecutive samples meet the final specifications for
the cleanup. Cases with responses such as "until standards are maintained
for three quarters" are included in the "Not Yet Determined" category.
This category also includes responses with very wide ranges such as "3
months to 2 years".
OPERATIONAL CONSIDERATIONS
This section of the report discusses operational considerations such as
permits, public involvement, administrative issues, and cost information.
The major subtopics of interest that will be discussed under operational
considerations are:
44
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o types of federal, state, or local permits required for the
action
o amount of and type of technical support requested
o community relations including the effect of public pressure in
the cleanup action
o administrative problems encountered during the project
o available cost information and the parties and percentage
sharing of the costs
Each subtopic will be discussed individually, pointing out the
important statistical data obtained from a review of the 50 individual
after-action reports.
Permits
The 50 after-action reports were reviewed to determine the number and
type of permits required. Six after-action reports provided no information
on permitting. Eight reports stipulated that no permits were required
while the remainder (26) indicated that some type of permit was required.
The majority of required permits were National Pollutant Discharge
Elimination System (NPDES) or groundwater permits. At 6 sites, air quality
permits were required. This occurs in situations where air stripping is
used or where soils are spread over the ground to volatize gasoline
constituents. At certain sites, construction permits are required for
construction wells or remedial action equipment such as as air strippers.
Five different permits were required for one site; well drilling, well
operation, land disposal, and so forth. Based on the after-action reports,
permitting is necessary in most instances, and no significant permitting
problems were reported. There were no reported project slippages due to
the inability to obtain the required permit.
45
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Technical Advice/Support
This subsection of the operational considerations section queried the
users on what organizations were solicited for technical support. A review
of the after-action reports revealed that at 4 sites, no technical advice
was sought, and that at 3 sites, no information was provided. In the
remaining 43 cases, technical support was sought from various organiza-
tions. At 4 sites, state and local agencies alone served as consultants.
At 26 sites, contractors alone served as consultants. At the remaining 13
sites, both contractors and regulatory agencies provided technical advice
to the OSC. At one site, advice was sought from 2 regulatory agencies, 2
oil companies, and 2 private consulting firms. At most_sites_,__the
regulatory jgenciesprovided_J.nput on the_standards or cleanup goals and
the technology to be used during site cleanup^ Consultants-were--used-;in
the^ area of hydrology/ground water and_to a lesser extentremediation
technology evaluation, with the hydrology category predominating.
Public Communication
This subsection inquires about the involvement of the media in the site
problem, the effect of public pressure on the cleanup and unusual problems
associated with the project. At 17 sites the respondents reported that
they communicated with the public. Vehicles used to communicate were TV,
newspapers, and public hearings. Out of 17 responses where public
communication existed, 6 sites were reported to have generated enough
pressure to have a positive effect on the cleanup project. At one site,
public awareness forced off-site disposal of contaminated soils.
Administrative problems were reported to have occurred in some
instances. The issues causing the problems were:
o too many parties being involved in the project slowed progress
o selection of best available technology issues with the EPA
46
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o state had no mechanism for scheduling the remediation
o state agency could not immediately hire a contractor to assist
in the cleanup
o meeting the cleanup goals set by the regulatory agency was
very difficult
o overly stringent standards near a public well
o problems associated in requiring a site owner's insurance
company to assume financial responsibility for the cleanup
The after-action reports did not explain how some of these unique
situations were handled or resolved.
Availability Cost Information
Of 50 after-action reports, only 19 provided any information on site
remediation costs. Only a few of the reports provided the detailed
breakout required by the after-action report showing federal or state
monies and person/hour splits between immediate action, long-term soil,
long-term groundwater action and free product removal. The most expensive
cleanup cost was $1.2 million, and involved the installation of 14 wells in
overlapping capture zones where water was withdrawn and treated by an air
stripper to remove volatile organic compounds.
The lowest costjassociated with a cleanup was $4,500 for a pump test at
one site. Those reports which documented costs usually break the cost down
into planning, capital cost (stripper, well installation, tank removal),
and operation and maintenance costs in those instances where long-term
remediation was planned. In certain instances, multiple technology costs
were reported at the same site. At the other end of the spectrum, total
47
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cost to date was reported in several instances with no breakout of costs at
all. The payment of cleanup cost was predominantly borne by the site owner
(38 out of 39 reported instances). At one site, it was reported that the
site cleanup cost was borne by the federal and state governments. At
numerous sites, the reports stipulated it was "believed" that the site
owner paid the cleanup costs, indicating those filling out the report were
not sure of exactly who was liable for clean up.
TERMINATION OF RESPONSE
This section of the after-action report discusses site cleanup
termination. There are two subtopics under the termination heading:
o percentage of site cleaned up
o remarks on various aspects of the overall cleanup project
Each subtopic will be discussed individually, addressing the important
information gleaned from a review of the 50 after-action reports.
Percentage of Site Cleanup
The response to this subjective question was revealing. Twelve reports
stated 100% cleanup was achieved, 3 reported the cleanup as satisfactory,
15 reported the cleanup was ongoing, and 3 reported cleanup percentages
below 100% (i.e., 95%, 80%, and 42%). The 42% figure was the ratio of the
volume of free product recovered over the volume of the original amount of
product lost. The remainder of the after-action reports (17) did not
provide any details on the percentage of cleanup.
Remarks
Only 10 of the 50 reports (20%) provided comments pertaining to
personal experience with the cleanup. Three of the remarks indicated the
technology used during the cleanup worked well (free product removal,
48
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off-site soil incineration, and activated carbon). Two respondents
criticized a city for not having adequate response capabilities, one
respondent expressed concerns over cleanup costs, one respondent provided
a detailed chronology of the project's significant milestones and another
expressed concern over operating an air stripper. Two after-action reports
provided a detailed critique of problems associated with the cleanup.
The first detailed critique raised concerns over the lack of any firm
schedules for the cleanup and suggested that the state develop a regulation
establishing cleanup time schedules and allowing for the state to veto the
cleanup technology proposed by the site owners. This site selected
bio-remediation, and the OSC would have utilized soil venting in lieu of
bio-remediation if the project were repeated. The after-action report also
recommended a brochure be developed to provide site owners with immediate
access to information on corrective action technologies, protocols,
emergency cleanup procedures, and so on.
The final after-action report recommendation is that it is best to take
quick immediate action; for example, simple soil excavation, without
waiting for detailed studies.. Detailed groundwater evaluations could be
conducted after the immediate action. This approach should minimize total
cleanup cost at the site. The same report also recommended that if
monitoring is not required prior to the leak, it should be mandatory after
the corrective action is completed.
49
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APPENDIX A
The Case History File Check List used to collect information to screen
sites.
50
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Contact N'a.ne:
Agency:
UNDERGROUND STORAGE TANK (UST) CORRECTIVE ACTIONS
Case History File Screening Check List:
Date Contacted: / /
Telephone No.:
Address:
UST site name:
Is this a petroleum product UST? Yes
Vhat leaked? Tank Pipe
No
When vas leak detected?
Hov long was leak occurring?
/ (mo/yr)
(mo or yr)
Uhen vas the corrective action initiated? /
Is it complete? Yes No
Vhen vas the corrective action completed? /
_(mo/yr)
(mo/yr)
Geographic/Site information:
EPA Region
State
Se 11 i ng
Annual precipitation
Depth to groundvater
Size of facility
_inches
feet
acres
UST information:
Tank size (gal)
Number of tanks
Type of petroleum product_
Quantity of leak
Soil type
Tank material
Pipe material
Aquifer classification
Immediate corrective action taken? Yes No
Method of immediate corrective action? Is it complete? Yes
Removed Tank Repaired Piping/Fittings
Repaired Tank Pumped Free Product
Removed Pipings/Fittings Excavated Backfill Area Other_
No
Vas there free product removal from groundvater/soil? Yes No
Method of free product removal? Is it complete? Yes No_
Long term corrective action taken? Yes No
Vas site characterization done? Yes No
Vas groundwater contaminated? Yes No
Method of soil treatment? Is it complete? Yes
Method of groundvater treatment? Is it complete? Yes No
Give criteria used to determine when corrective action is/vas completed7
Are photos available?
Can ve have copies?
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APPENDIX B
The Case History File After-Action Report used to collect case history
information.
52
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CASE HISTORY FILE AFTER-ACTION REPORT
This After-Action Report provides data that will become part of the EPA's Case
History File. The Case History File After-Action Report has two sections: a
database section and a narrative section.
The information required in the database section is brief, so that computerized
searches can be made. Not every block of the data base will apply to your
response action, i.e., spill, removal action, remedial action, or underground
storage tank corrective action, but please complete all applicable sections.
More detailed information is required in the narrative section which is tailored
to your specific response action. Please complete all questions with as much
detail as possible.
There are no length limitations to the narrative section of the report. If you
are preparing a paper copy, feel free to add additional sheets or use both sides
of these sheets. If you are using a word processor, feel free to insert
additional lines wherever necessary. The narrative section may be the most
useful part of the Case History File system to personnel responding to a similar
incident. It's important to pass along the benefits of your experience.
Return this form to:
Technical Information Exchange
Releases Control Branch
Hazardous Waste Engineering Research Laboratory
U.S. Environmental Protection Agency
Edison, New Jersey 08837
To access the on-line Case History File, you must have a microcomputer or
terminal, a modem, and a telephone. Dial FTS 340-6612 or 201-321-6612 to access
the computer. The system operates using 2400 baud, 8 data bits, 1 stop bit, no
parity. For operator assistance, call FTS 340-6675 or 201-321-6675.
Name of Preparer:
Signature :
Date :
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CASE HISTORY FILE AFTER-ACTION REPORT
DATABASE SECTION
Type of Incident: (circle one) spill removal action remedial action
underground storage tank corrective action
Date of Incident:
EPA Region :
Latitude :
Name of Site :
Date of Report:
State :
Long!tude :
NPL Number :
Type of Materials Released
Primary hazardous substance involved in this incident:
Name: Quantity Released:
(Kilograms,
gal., liters, etc.)
CAS No.:
DOT Number:
List other hazardous substances released:
1. CAS No.:
2. CAS No.:
3. CAS No.:
4. CAS No.:
5. CAS No.:
Quantity_
Quantity_
Quantity
Quantity
Quantity
(Kilograms, gal., liters, etc.)
(Kilograms, gal., liters, etc.)
_(Kilograms, gal., liters, etc.)
^(Kilograms, gal., liters, etc.)
(Kilograms, gal., liters, etc.)
Affected Area:
plume or contaminated soil)
Affected Population:
Route(s) of exposure:
(specify acres, square meters, etc. of
(number of people)
Depth to groundvater:
feet
Annual precipitation:
inches
-1-
-------
Origin of the Incident: (circle all that apply)
facility vehicle vessel railway airway
pipeline tank pond dump sewer
landfill storage containers UST corrosion
UST Installation Error UST overfill UST piping other
Weather (during initial response): (circle all that apply)
high winds rain snow ice
very hot very cold other fog
Time of Incident (during initial response): (circle one)
day night not applicable
Major Effects/Impacts of the Incident: (circle all that apply)
water contamination lake human health
groundwater intercoastal area plant life
drinking aquifer coastal area wildlife killed
unused aquifer marine (open ocean) fish killed
stream wetlands fire/explosion
river soil contamination property damage
pond air pollution other
How was the leak detected: (circle all that apply)
Sight Smell Taste Internal Leak Detector
External Leak Inventory Reconciliation Tank Tightness Other
Detector
-2-
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UST Construction (original tank that leaked): (Circle all that apply)
steel sand backfill liners
concrete gravel backfill internal cathodic protection
fiberglass reinforced traps external cathodic protection
plastic
tank support anchors coatings
soil backfill double vailed vaults unknown
Geography of the Site: (circle all that apply)
open land valley hilly ocean port marine
forest mountainous river port beach other
Hydrology of the Site: (circle all that apply)
stream valley estuary unconfined aquifer other
watercourse flood plain confined aquifer
lake/pond flood channel karst zone
marsh aquifer recharge fractured bedrock
Ground Materials at the Site (geologic media and surface conditions): (circle
all that apply)
clay
silt
sand
gravel shale
rock bedrock
fill sandstone
asphalt surface
concrete surfaced
other
Land Use at the Site: (circle all that apply)
residential industrial agricultural indian reservation
commercial rural parkland military
-3-
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Containment Technologies Taken: (circle all that apply)
dike trench plug groundwater control
subsurface barriers excavation boom other
leachate collection sump cap
gas collection containers liner
Cleanup/Removal Technologies Taken: (circle all that apply)
removed product from tank excavated other soils containerizing
repaired tank treatment on site leachate collection
replaced tank free product recovery other
repaired pipings/fittings pump/vac truck
removed pipings/fittings hauling avay
excavated backfill area flushing avay
Treatment Technologies Taken: (circle all that apply)
Volatilization/Ventilation Passive Remediation
Biodegradation Granular Media Filtration
Thermal Destruction Ion Exchange/Resin Adsorption
Soil Vashing Reverse Osmosis
Solidification/Stabilization Chemical Extraction
Vitrification Precipitation/Flocculation/
Sedimentation
Groundvater Extraction/Treatment
Neutralization
Carbon Adsorption
Leachate Collection
Air Stripping
Other
Steam Stripping
Disposal Methods Used: (circle all that apply)
landfill evaporation injection veil storage
incineration land farming encapsulation ocean dumping
treatment soil vashing recycling other
__
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UNDERGROUND STORAGE TANK (UST) CORRECTIVE ACTIONS
CASE HISTORY FILE AFTER-ACTION REPORT
NARRATIVE SECTION
1. GENERAL
Please give the name, address, and telephone number of the On-Scene
Coordinator (OSC) or Remedial Project Manager (RPM) and other key response
personnel, such as state or local government personnel or contractors.
Identify where this information is being logged. This will enable a future
OSC/RPM to obtain more information.
How many tanks are at the facility? How many leaked? What was the size of
the tank(s)? What percent of the tank(s) vas/vere below grade? How old was
the svstem?
the system?
Please expand on the history of the tank(s). Vas corrosion protection
installed? Vere release detection systems installed? Vas spill/overfill
protection equipment installed? How long was the leak(s) occurring? Vere
there any prior leaks associated with the tank(s) and/or the site?
-1-
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Is the current contamination problem due to the current release or a past
release? If past release, please explain.
Please expand on the history of the most recent leak incident associated
with the tank(s). Provide information on the time, rate and extent of leak.
Please describe the procedures that were followed that led you to believe
that a leak vas suspected and what activities were taken to confirm that the
tank was leaking. What initial measures were taken to stop the leak and to
mitigate any fire and/or safety hazards?
-2-
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2. CHEMICAL INFORMATION
List a common name of the primary hazardous substance and any other
hazardous substances involved in this leak. Give the respective
concentrations in (mg/kg) for soils and (mg/1) for groundwater. Identify
and describe sampling location(s) and test methods. (Refer to section 4 for
details on methods.)
*Vhen initially sampled.
**Provide distance in feet from focal point of leak incident to where
maximum concentration vas measured.
Soil
Contaminant *Avg. Cone. *Max. Cone. **Sampling Location Test Method
(primary)
Groundvater
Contaminant *Avg. Cone. *Max. Cone. **Sampling Location Test Method
(primary)
-3-
-------
What chemical reaction/interaction hazards were you avare of? Did serious
problems develop?
What hazards did these substances pose to the response personnel? What
steps did you take to minimize exposure and to minimize the hazards?
What hazards did these substances pose to the general public? What
immediate steps did you take to minimize the hazard?
-4-
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3. EFFECTS
What has been the immediate major effect of this leak since its initial
detection?
Was there a threat of fire/explosion? Vhat role did the local fire marshal
or emergency service organization play?
Vhat hazards to public health did you anticipate during the immediate
response? Vhat was done about immediate hazards? Vere state and/or local
health officials involved and, if so, what was their role?
-5-
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If the situation was allowed to continue, vhat would have been the
predicted long-term effect on public health?
Vhat hazards to the environment did you anticipate during the immediate
response? Vhat was done about them?
If the situation was allowed to continue, what would have been the
predicted long-term effect on the environment?
-6-
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4. SITE CHARACTERISTICS
Please describe the site in more detail such as land use, ground cover,
proximity to residential areas, utilities. How did these affect your
response?
Was a hydrogeologic study performed? If so, describe the hydrogeologic
characteristics addressed (groundvater direction, soil conductivity, etc.)
and give the results.
-7-
-------
How deep are the aquifers? Are there any confining layers? What is the
aquifer classification (sole source, current potable, future potable or
non-potable)? How did groundvater use affect your actions?
Describe the subsurface geologic characteristics, i.e., soil permeability,
soil type. How did the ground materials affect your response?
-8-
-------
Describe the site characterization techniques employed to define the extent
of soil and groundvater contamination, i.e., types of sampling and
analytical methods used such as soil gas analysis, installation and number
of groundvater monitoring veils, number of soil borings taken, depth of
soil borings taken. Was groundvater modeling used to assist in plume
identification? What other types of field techniques vere employed?
(These questions may be answered by attaching relevant reports.)
-9-
-------
Based upon the site characterization conducted initially and what you now
know about the site, what would you have done differently with regards to
site characterization?
Describe any data quality objectives that were established for soil and
groundwater. Vere these objectives met? Please describe the sampling and
analytical techniques used in the field and/or in laboratories. Also,
describe the QA/QC procedures that were followed.
-10-
-------
Please identify any indicator compounds you used such as methyl tertiary
butyl ether (MTBE) or total petroleum hydrocarbons.
Was a risk assessment conducted for the site? If so, briefly summarize the
guidelines followed and the results obtained.
-11-
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5. IMMEDIATE CORRECTIVE ACTION (CONTAINMENT)
Describe any immediate actions taken prior to your arrival. Hov effective
were they? (Address free product removal under section 7.)
Please elaborate on the immediate actions you used. What led you to
choose those methods? Hov effective were they? Hov long did it take to
complete the actions?
If the tank(s)/piping vere removed, please describe the removal and
replacement protocols?
-12-
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What alternative methods did you consider and discard? Why?
What special problems arose during the response? What was their affect on
your immediate actions?
Please describe any unconventional/innovative approaches taken as part of
your response action. Hov effective vere they?
-13-
-------
Describe any disposal methods that were used and why that method was
selected.
If you were faced with a similar situation again, what nev or different
methods would you try?
-14-
-------
6. LONG-TERM CORRECTIVE ACTIONS (CLEANUP/REMOVAL)
Describe any long-term corrective actions taken prior to your involvement.
How effective were they?
What corrective action alternatives did you consider? What were their
estimated cost?
Were cleanup requirements for soils and groundwater established for the
corrective action? If so, list the cleanup levels established for each
hazardous substance for soil and groundwater and Identify the source of the
standard, i.e., federal, state, MCL, MCLG, risk based levels, etc.
-15-
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Please elaborate on the corrective actions that were selected for responding
to contamination above the water table and below the water table, if
applicable. What led you to choosing those methods? How effective were
they? How long did it take to complete the actions?
What special problems arose during the corrective action? What was their
affect on your actions?
If you were faced with a similar situation again, what new or different
methods would you try?
-16-
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7. FREE PRODUCT REMOVAL (TREATMENT)
Describe actions taken to remove free product. Hov effective were they?
How long did it take to complete the actions?
Describe the fate of the recovered product, i.e, was it reused or disposed
of? Hov was it disposed of? Hov vas the contaminated vater
treated/disposed of?
What alternative methods did you consider and discard? Why?
What special problems arose during free product removal? What vas their
affect on your removal methods?
If you vere faced vith a similar situation again, what nev or different
methods vould you try?
-17-
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8. EFFECTIVENESS OF CORRECTIVE ACTIONS (DISPOSAL)
How effective was the corrective action(s) in meeting their intended
objectives?
For each substance identified in part 6 (long-term corrective action) that
had cleanup requirements established, identify the end-point
concentrations, if applicable. What were your criteria for terminating the
action, i.e., risk, standards, background, technology limitations? How were
these end point concentration(s) measured?
-18-
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For each substance where the cleanup requirement was not: achieved, explain
why and who was involved in the decision to terminate the corrective action.
If the corrective action is ongoing, please provide the concentration(s)
obtained from the most recent sampling round for each hazardous substance
identified in section 2. Please give sampling date.
Is/was there a post monitoring period? If so, give duration and parameters
used for termination.
-19-
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9. OPERATIONAL CONSIDERATIONS
What federal, state, or local permits were required? Please give their
numbers and the names of the issuing agencies.
Vas technical advice/support obtained from federal, state or local
personnel, responsible party consultant, or contractor? If so, give name
and phone number of source and explain the nature of the technical
advice/support obtained.
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Did you communicate with the public? Hov? With whom? Vhat problems did
you have with public communication/public relations? Did your
communications help? Vhat vould you do differently if you were to face a
similar situation in the future?
Vhat effect did public pressure and awareness have on the action?
Vhat unusual administrative problems did you encounter?
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Please give the following cost information if available:
Long-Term Long-Term Free
Immediate Actions Actions Product
Action Soil Groundvater Removal
Federal Labor $ :
Federal Labor Hours:
State Labor $ :
State Labor Hours :
Capital :
Disposal Costs :
Material Costs :
O&M Costs :
*0ther :
TOTAL
*Specify:
Hov was the burden of payment divided among the parties involved (federal,
state, local, spiller/site ovner, etc.)?
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10. TERMINATION
What percent of the site was cleaned up to your satisfaction?
Please use the remaining space or additional sheets to add further comments
that you feel would be helpful to response personnel who may fact similar
incidents. What improvements vould you make the next time? What nev
technology is needed, etc.?
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