New England Interstate
Water Pollution Control
Commission 01852-1124
www.neiwpcc.org/lustline.htm
116 John Street
Lowell, Massachusetts
Bulletin 53
September
2OO6
LUS.T.UN
A Report On Federal & State Programs To Control Leaking Underground Storage Tanks
what Goes Around Comes Around...
ARIZONA'S ROUTE 66 INITIATIVE TACKLES FORGOTT
GAS STATIONS ON A HIGHWAY OF HISTORY
4CKMBBST
by Maggie Witt
Throughout United States history, transportation and
transportation corridors haVe played a central role in the
country's development. Tortns and cities emerged along rtaterrtays,
railways, and roadulays, deriving, income from transportation activities and industry. Over time,
these tou/ns became bustling economic centers, illustrative of the American Bream and the possibilities for success in
an ever-changing environment. But ulhile these transportation hubs derived benefits from transport activities, they
also experienced unique challenges and problems—
especially related to the environment.
Transportation Corridors
and the Environment
Many of these environmental challenges stemmed from
contamination generated by USTs. When considering
some of the country's most famous highways and byways
and the number of gas stations that line these routes, the
prevalence of LUST contamination is not surprising. This
contamination or potential contamination has resulted in
protracted cleanups and brownfields—defined by U.S.
• continued on page 2
Inside
5U Colorado's Historic Byways Revitalization Initiative
6[) National Park Service Restoring Abandoned Gas Stations
8() Update on Energy Policy Act Implementation
10(J Los Angeles—New Expedited Agency Oversight Program
12(J Tanks on Tribal Lands—Using GIS
14[J Updates on Soil Gas Collection/Analytical Procedures
20() Are We to Become "Children of the Corn"?
26(J Portable Electric Pumps for UST Systems
28 [J What About Those Temporarily Closed Tanks?
30() Beware the Unintended Consequences of Manifolding
() FAQs from the NWGLDE—MLLDs
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LUSTLine Bulletin 53 • September 2006
i Route 66 from page 1
EPA as "real property, the expansion,
redevelopment, or reuse of which
may be complicated by the presence
or potential presence of a hazardous
substance, pollutant, or contami-
nant."
Recently, U.S. EPA, states, and
local governments have initiated new
programs to address LUST contami-
nation and petroleum brownfields.
These programs have helped many
communities along major transporta-
tion corridors assess and cleanup
contaminated properties. Addition-
ally, many of these programs are
now looking at ways to propel the
effort to the next level—exploring
opportunities for brownfields rede-
velopment at cleaned-up properties.
Take, for example, Route 66...
Remember Route 66?
Route 66 is one of the most famous
and recognizable historic transporta-
tion corridors in the United States.
Coverphoto courtesy of Maggie Win
sion (NEIWPCC). It is produced through;
cooperative agreement (#1-830380-01)
L.U.S.T.Line
Ellen Frye, Editor
Ricki Pappo, Layout
Marcel Moreau, Technical Adviser
Patricia Ellis, Ph.D., Technical Adviser
Ronald Poltak, NEIWPCC Executive Director
Lynn DePont, EPA Project Officer
LUSTLine is a product of the New England
Interstate Water Pollution Control Commis-
sion (
cooperative <
between NEIWPCC and the U.S.
Environmental Protection Agency.
LUSTLine is issued as a communication
service for the Subtitle I RCRA
Hazardous & Solid Waste Amendments
rule promulgation process.
LUSTLine is produced to promote
information exchange on UST/LUST issues.
The opinions and information stated herein
are those of the authors and do not neces-
sarily reflect the opinions of NEIWPCC.
This publication may be copied.
Please give credit to NEIWPCC.
NEIWPCC was established by an Act of
Congress in 1947 and remains the oldest
agency in the Northeast United States
concerned with coordination of the multi-
media environmental activities
of the states of Connecticut, Maine,
Massachusetts, New Hampshire,
New York, Rhode Island, and Vermont.
NEIWPCC
116 John Street
Lowell, MA 01852-1124
Telephone: (978) 323-7929
Fax: (978) 323-7919
lustline@neiwpcc.org
LUSTLine is printed on Recycled Paper
For over four decades, Route 66 oper-
ated as the country's main east-west
artery, connecting Chicago and Los
Angeles and everything in between
with over 2,400 miles of continuously
paved roadway. Like other commu-
nities along major waterways, rail-
ways, and highways, cities and
towns along Route 66 reaped the
benefits of the highway and thrived.
Motels and diners sprang up to cater
to travelers. Gas stations became the
new icon for America's transition to
an increasingly mobile society. With
the growing number of cars and
trucks on the road, some Route 66
towns sported gas stations and fuel
pumps on virtually every corner.
But by the 1950s, rapidly chang-
ing transportation needs in the coun-
try foreshadowed the demise of
Route 66. Influenced by the speed
and safety of four-lane highways in
Europe, President Eisenhower's
administration promoted federal
sponsorship of a nationwide inter-
state system. Congress responded
with the Federal Highway Act in
1956. Within 14 years, nearly all seg-
ments of Route 66 were bypassed by
modern, divided highways. In 1986,
Route 66 was officially decommis-
sioned. Though parts of it are no
longer drivable, 85 percent of the
highway is still used by tourists and
local traffic. The downtowns of many
small cities and towns are still
located on the historic route.
As traffic moved to new and
neighboring interstates, communities
along Route 66 experienced eco-
nomic and environmental hardships.
With fewer travelers, many busi-
nesses closed down, leaving behind
neglected, abandoned properties.
Abandoned gas stations were espe-
cially problematic, largely due to the
buried bare-steel tanks and the fuel
that remained in them. In many
cases, these tanks corroded and
leaked their contents into the soil and
groundwater.
Today, LUSTs left over from
Route 66's heyday continue to cause
problems. The bypassed communi-
ties are struggling as it is and do not
have the necessary funds to cover the
cost of environmental assessment
and cleanup. The result? Brownfields
and abandoned properties that blight
communities and pose potential
environmental and health hazards.
Arizona's Route 66 Initiative
Arizona contains over 200 miles of
original Route 66 roadway. Along
this stretch of highway, approxi-
mately 350 LUST sites have been
reported. To address contamination
in small and economically challenged
Route 66 communities, some states
have developed programs and
assembled applicable state resources.
In Arizona, the Department of Envi-
ronmental Quality (ADEQ) has allo-
cated resources for a program called
the Route 66 Initiative.
ADEQ launched the program in
2004 to help with assessment and
cleanup efforts at LUST sites located
along the historic highway. Since the
inception of the Initiative, ADEQ has
assisted UST owners, operators, and
property owners in completing site
investigations, initiating cleanup
efforts when necessary, and closing
LUST sites. ADEQ has also per-
formed LUST assessments and
cleanups through the State Lead Pro-
gram, which addresses situations in
which UST owners or operators are
unknown or unable to perform the
necessary cleanup activities. Through
its Brownfields State Response Grant
(SRG) Program, ADEQ has also high-
lighted the availability of SRG fund-
ing to assist with the economic
development and revitalization of
eligible sites along the Route 66 corri-
dor.
Prior to ADEQ's Route 66 Initia-
tive, 250, or 70 percent, of these LUST
sites had been successfully closed,
with cleanup either completed or not
needed. After two years of the imple-
mentation of the Route 66 Initiative,
77 sites currently remain open—22
fewer than when the Initiative was
launched. Many of these remaining
sites pose unique challenges due to
site-specific issues, including hydro-
geologic conditions.
About half of these sites are
located in three small towns in north-
eastern Arizona—Winslow, Hoi-
brook, and Joseph City, all of which
reside in Navajo County. Through
the Route 66 Initiative, ADEQ has
been focusing special attention on
these three towns and working
closely with LUST site owners, con-
sultants, and the communities to
move LUST sites into the cleanup
phase and eventual closure. To facili-
tate close working relationships,
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September 2006 • LUSTLine Bulletin 53
ADEQ assigns project case managers
to each of these towns, and ADEQ's
rural representative, based in St.
Johns, Arizona, frequently meets
with stakeholders, local officials, and
other interested parties.
Opportunities and Barriers to
Cleanup and Redevelopment
in Arizona
While over three decades have
passed since Interstate 40 bypassed
Route 66 in Arizona, the towns of
Winslow, Holbrook, and Joseph City
continue to face economic challenges
initiated by the shift from the high-
way to the interstate. Based on 2000
Census data, Winslow, Holbrook,
and Navajo County (which includes
Joseph City) exhibit lower median
household incomes, lower per capita
incomes, and higher rates of unem-
ployment and poverty than the
national average.
ADEQ's Route 66 Initiative has
helped to relieve the burden of
addressing and improving environ-
mental conditions in these communi-
ties. Because ADEQ's Route 66
Initiative provides assistance for
assessments and cleanup at LUST
sites, property owners and munici-
palities are no longer left with the full
responsibility for expensive cleanups.
However, due to unfavorable eco-
nomic circumstances, barriers to
redevelopment at closed LUST sites
and abandoned tank sites remain.
The Route 66 Partnership
Images of idle and unproductive gas
stations in Winslow, Holbrook, and
Joseph City have spurred questions
about the barriers to redevelopment
and ways to overcome these barriers.
In October 2005, ADEQ and U.S. EPA
partnered to explore the answers to
these questions and examine redevel-
opment opportunities at former LUST
and abandoned tank sites.
The collaboration—called the
Route 66 Partnership—also aims to
link ADEQ's work to U.S. EPA's past
efforts to revitalize petroleum-conta-
minated sites. In 2000, EPA's Office
of Underground Storage Tanks cre-
ated the USTfields Initiative to pro-
mote revitalization at LUST sites and
gas stations. The success of the UST-
fields Initiative contributed to provi-
sions in the 2002 Brownfields Law
that designated EPA Brownfields
grant money for petroleum-contami-
nated sites. The USTfields pilots also
generated examples of successful gas
station redevelopment projects that
petroleum brownfields grant projects
have since emulated.
The goal of the Route 66 Partner-
ship is to combine the success of
ADEQ's ongoing Route 66 Initiative
with lessons learned from the UST-
fields Initiative and subsequent
petroleum brownfields projects to
identify solutions that can be imple-
mented in Arizona and elsewhere. To
achieve its objective, the Route 66
Partnership combines research, stake-
holder interaction, and partnerships
to explore viable opportunities for
community revitalization. For this
initial project partnership, ADEQ and
U.S. EPA chose to focus on the same
communities on ADEQ's Route 66
Initiative agenda—Winslow, Hol-
brook, and Joseph City.
The goal of the Route 66 Partnership
is to combine the success of ADEQ's
ongoing Route 66 Initiative with
lessons learned from the USTfields
Initiative and subsequent petroleum
brownfields projects to identify
solutions that can be implemented
in Arizona and elsewhere.
LUST sites and abandoned gas
stations located on this portion of
Route 66 come in a variety of shapes,
sizes, ages, and conditions. Realizing
this, ADEQ and U.S. EPA have
acknowledged that plans for commu-
nity revitalization must take Route
66's heritage and historic significance
into consideration. For this reason,
the Partnership also includes local
and national historic preservation
programs, ensuring that historic sites
and gas stations will be preserved
whenever possible. Additionally, the
National Park Service Route 66 Corri-
dor Preservation Program—a pro-
gram dedicated to preserving and
protecting the things that make
Route 66 special—has been a key
player in the Partnership since Octo-
ber 2005.
Since the beginning of the Part-
nership, ADEQ and U.S. EPA have
also acknowledged the importance of
local buy-in and involvement. For the
effort to be successful, action and exe-
cution must occur at the level of gov-
ernment that encompasses each site.
To make sure that the goals of the
project align with local goals and
interests, ADEQ and U.S. EPA have
also formed partnerships with
Winslow, Holbrook, and Navajo
County. Fortunately, local govern-
ment agendas include plans to priori-
tize redevelopment as a means to
achieve community beautification
and economic development.
Recent projects in both Holbrook
and Winslow reflect redevelopment
plans and goals. The City of Hol-
brook recently launched a project to
restore and preserve its historic
downtown district with money from
the State Heritage Fund Grant. This
grant is made possible by $20 million
in Arizona Lottery revenues set aside
annually for parks, trails, and natural
areas, historic preservation, and a full
range of wildlife conservation activi-
ties.
Winslow also recently initiated
the Renaissance Downtown Redevel-
opment. Mayor Allan Affeldt, elected
in 2005, has used his past experience
in historical renovation and redevel-
opment to propel the project. Prior to
his mayoral run, Allan purchased
and renovated the historic La Posada
Hotel, originally constructed in 1929
as one of Fred Harvey's famous Har-
vey Houses.
Resources and Partnership
Opportunities
In spite of these local projects and
initiatives, however, the economic
atmosphere in Winslow, Holbrook,
and Joseph City continues to gener-
ate obstacles to redevelopment. How
will these communities fund revital-
ization and make redevelopment
projects at LUST sites and abandoned
gas stations attractive to redevelopers
and investors? Furthermore, with
few resources in terms of both money
and manpower at the local level, how
will these governments track down
assistance from outside sources?
Partnerships—like the Route 66
Partnership—can provide viable
solutions. By working with other
• continued on page 4
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LUSTLine Bulletin 53 • September 2006
Route 66 from page 3
organizations and agencies, these
communities can take advantage of a
wide array of available resources—
both technical and financial. In the
first few months of the Route 66
Partnership, ADEQ, U.S. EPA, and
local governments worked together
to identify potential partners for the
cleanup and redevelopment effort.
Initial research revealed that a wide
spectrum of state, federal, and local
agencies and organizations imple-
ment programs and offer tools and
resources that can be utilized for
redevelopment projects.
To bring these potential partners
together to discuss applicable pro-
grams and to "kick off" the Route 66
Partnership, ADEQ, U.S. EPA's
Pacific Southwest Regional Office,
and local government agencies held a
two-day meeting on January 26 and
27, 2006, in Winslow and Holbrook.
More than 60 people attended the
meeting, including representatives
from approximately 20 agencies and
organizations, local press, private
industry, business owners, bankers,
community members, and UST and
LUST site owners.
At the meeting, participants
learned about various programs,
agencies, and organizations that offer
financial and/or technical assistance
for potential redevelopment projects.
Additionally, speakers from Wash-
ington, D.C., Texas, and Washington
State discussed success stories from
other parts of the country. Overall,
presentations, breakout discussions,
and Q &As helped the group grasp a
better understanding of their respec-
tive challenges, options, and possible
next steps for cleanup and redevelop-
ment. By assembling the various
stakeholders at the outset of the Part-
nership, key players were able to
meet face-to-face and establish allies
that they can comfortably turn to in
the future.
Next Steps
Since the Route 66 kick-off meeting,
ADEQ, U.S. EPA, local governments,
and Route 66 Partners have collabo-
rated to take the next steps on the
road to successful redevelopment.
Armed with the information pre-
sented at the meeting and with new
networks in the state agencies,
Vestiges of the good old days on Route 66, Arizona
Winslow and Holbrook have taken
the initiative to explore available
tools and resources. In March, the
City of Holbrook secured a grant
from the Arizona Department of
Commerce to conduct a business
inventory along Route 66. The inven-
tory is intended to attract new busi-
ness and incorporates a list of sites
available for reuse, including cleaned-
up LUST sites.
In June, ADEQ announced the
award of $96,000 in State Response
Grant funds to help pay for cleanup
at the "Standin' on the Corner" mon-
ument in Winslow. Access to the
monument has been restricted since a
fire destroyed the adjacent building
in October 2004. Concerns about
asbestos and other hazardous sub-
stances in the debris have compli-
cated cleanup and led to the
implementation of access restrictions.
These SRG funds will allow Winslow
to proceed with the cleanup so that
the site can be restored and tourists
and visitors can once again visit the
famous Route 66 landmark.
In the future, key players in the
Route 66 Partnership will continue to
lay the foundation for redevelopment
at LUST sites and abandoned gas sta-
tions along the historic highway.
Tools like EPA Brownfields Grants
and others resources highlighted at
the Route 66 kick-off meeting present
clear opportunities to utilize federal
and state funding. Additionally, sto-
ries of successful redevelopment at
abandoned gas stations and LUST
sites around the country provide
examples and lessons learned that
can be applied in Arizona and
beyond.
Since the Route 66 Partnership's
inception, several states and other
U.S. EPA Regions have considered
opportunities for similar projects to
address petroleum contamination at
LUST sites and abandoned gas sta-
tions. Even non-Route 66 states have
begun to craft initiatives to help com-
munities located along transportation
corridors—whether they are high-
ways or railways—identify environ-
mental challenges and develop
solutions. Those involved in the
Route 66 Partnership hope to both
provide lessons learned and draw
from lessons learned elsewhere to
facilitate successful redevelopment
projects. •
Maggie Witt is the Co-Lead for the
Route 66 Partnership at U.S. EPA's
Pacific Southwest Regional Office and
a participant in the EIP Internship
Program. She can be reached at
wiii. maggie@epa.gov.
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September 2006 • LUSTLine Bulletin 53
Colorado Embarks on a Brownfields Historic
Byways Revitalization Initiative
by Marilyn Hajicek
The Colorado Division of Oil
and Public Safety (OPS) Petro-
leum Storage Tank Program is
partnering with the Colorado Depart-
ment of Public Health & Environ-
ment (CDPHE) Voluntary Cleanup
Program and the Colorado Brown-
fields Foundation (CBF) on the Col-
orado Brownfields Historic Byways
Revitalization Initiative. The Initia-
tive is a statewide partnership
intended to provide recreational,
educational, and economic benefits to
Coloradans and visitors.
Heritage travelers make up a
healthy share of Colorado's visitors
and represent some of the most
important tourist traffic. By spending
money in localities off the beaten
track, heritage travelers help spread
economic benefits throughout rural
areas.
Heritage-area development ini-
tiatives not only build an atmosphere
of creativity and cooperation, they
promote the evolution of major eco-
nomic development assets, especially
in smaller towns. In many communi-
ties, the historic areas and byways
contain abandoned and underuti-
lized properties with real or per-
ceived contamination. These
brownfields properties often include
abandoned gas stations or other com-
mercial or industrial properties with
petroleum contamination.
For years OPS and CDPHE have
worked somewhat independently on
a few petroleum brownfields efforts.
The difficulty has been to establish a
mechanism to leverage the available
funding and resources from both
agencies to identify and implement a
focused approach for assessing and
cleaning up brownfields-eligible
petroleum-contaminated properties.
The Initiative has provided the
opportunity for OPS and CDPHE to
explore their common objectives and
brainstorm ways to more effectively
assist in revitalizing Colorado com-
munities by working together.
One goal of the Initiative is to
improve coordination among Col-
orado's state agencies,
nonprofits, and communi-
ties working on brown-
fields revitalization efforts.
The various sources of
available funding have
become one of the main
issues delaying or imped-
ing these efforts. CDPHE
receives the annual Section
128(a) Brownfields grant,
while OPS oversees
cleanup of contamination
from regulated petroleum
UST sites. To date, OPS
brownfields funding has
consisted of a $100,000 USTfields
grant in 2002 and a competitive
$200,000 Brownfields Assess-
ment grant currently being
administered.
Another goal of the Initia-
tive is to improve coordination
of services. CBF will take the
lead on the public outreach
efforts by helping to prioritize
sites using the economic and
community development goals
set by the communities them-
selves. An innovation of the Ini-
tiative will be to develop a set of
reporting criteria to highlight com-
munity progress toward redevelop-
ment and environmental cleanup
success.
The development of this Initiative
is the culmination of years of effort to
coordinate agency resources on petro-
leum brownfields projects. Steven
McNeely with the the U.S. EPA
Office of Underground Storage Tanks,
Tracy Eagle with the U.S. EPA Region
8 Groundwater Program, Karen Reed
with the U.S. EPA Region 8 Brown-
fields Program, and Jesse Silverstein
with the Colorado Brownfields Foun-
dation have all been instrumental in
providing the support and resources
to OPS and CDPHE in the develop-
ment of this project.
Where do we go from here? OPS
and CDPHE are developing an intera-
gency agreement (IA) to formalize
roles and procedures for future
brownfields coordination. The key
element of the IA will be the process
by which OPS will utilize funding
from the CDPHE Section 128(a)
The not-so-scenic places along Colorado's highways
and byways.
Brownfields grant for petroleum-
contaminated sites. This IA will be
comprehensive for petroleum brown-
fields projects, as part of this Initiative
and beyond.
An immediate goal of the Initia-
tive was to identify two geographi-
cally oriented pilot sites along a
scenic byway or in a historic district
to assess for environmental concerns
and remediate if necessary to help
position the properties for defined or
potential reuse. Two former gas sta-
tions, located on the "Highway of
Legends Scenic Byway" in Walsen-
burg, are being targeted as the first
pilot sites. The model for future pro-
jects will be based on the successes
and lessons learned from these pilot
projects. •
Marilyn Hajicek, P.G., is Remediation
Section Manager with the Division of
Oil and Public Safety, Colorado
Department of Labor and Employment.
She can be reached at
marilyn.hajicek@state. co.us.
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LUSTLine Bulletin 53 • September 2006
RECONNECTING WITH THOSE
WAYSIDE GEMS OF YESTERYEAR
The National Park Service Sees Opportunity in
Reusing Many AbanAomA Gas Stations
by Chad Randl
Gas stations are icons of the
twentieth century—the prod-
ucts of the transportation rev-
olution and America's affection for
the automobile. They illustrate both
the romance of the open road and the
drive toward corporate standardiza-
tion. Over the one hundred-year-long
history of the gas station, every archi-
tectural phase and fancy seems to
have made its way into the design of
these facilities. English Cottage and
Colonial Revival stations from the
1920s, streamlined "ice-box" forms of
the 1930s, and postwar Space Age
themes reflect once-popular trends
and cultural priorities. Some stations
were one-of-a-kind whimsies shaped
like icebergs, teakettles, and tepees;
others were stock units, mass pro-
duced by oil companies promoting
uniform branding and seeking cus-
tomer loyalty.
Today many of these stations sit
empty, abandoned when new high-
ways siphoned off customers, when
the stations were declared outmoded
by the petroleum industry and its
customers, or when environmental
cleanup costs exceeded an owner's
resources. In response, historic
preservationists have organized local
rehabilitation projects, listed gas sta-
tions in the National Register of His-
toric Places, and raised awareness
about the gas station's importance to
the sense of place in many local com-
munities. In 2004, the Alabama
Preservation Alliance and the Ala-
bama Historical Commission even
included that state's historic gas sta-
tions on their annual list of "places in
peril."
Abandoned historic gas stations
represent not only a lost connection
to the past, they can also represent a
found opportunity for the future.
Abandoned, they are a significant
hindrance to community redevelop-
ment, generate no local taxes or
Former Magnolia Mobil gas station in Little Rock, Arkansas, now restored as the Central High
School Museum and Visitors Center.
employment opportunities, and in
some cases are accompanied by
ongoing environmental contamina-
tion. But as federal, state, and local
cleanup programs continue to
mature and develop holistic
approaches that incorporate both site
reclamation and economic develop-
ment, these sites have the potential to
reemerge as unique and functioning
historic landmarks. As Edward Chu
noted in the December 2005 LUST-
Line bulletin, "we are shifting our
focus from cleanup only to cleanup
and reuse."
Reusing the Building
Often, reuse refers specifically to the
land alone, while the surviving gas
station structure is slated for demoli-
tion. However, a growing list of reha-
bilitation projects has shown that
many aging gas station buildings still
have life in them and that their reuse
can benefit both investors and the
community. The National Park Ser-
vice's Technical Preservation Services
branch has recently published a
Preservation Brief (http://www.cr.
nps.gov/hps/tps/briefs/presbhom. htm)
entitled "The Preservation and Reuse
of Historic Gas Stations" that
describes successful approaches to
rehabilitating these properties for
continued use as service stations or
adapting the buildings for new uses.
It shows how stations can be reused
as a distinctive setting for a new
business while retaining a sense of
historical continuity and limiting
disruption to the existing built envi-
ronment.
Guidance in the NFS Brief is
based on the Secretary of the Inte-
rior's Standards for Rehabilitation.
These ten general principles call for a
conservative approach to work on
historic buildings, including an
emphasis on reuse over demolition,
repair rather than replacement, hon-
esty in interpreting the building's
past, and sensitivity to significant his-
toric features.
A historic gas station usually has
a number of "character-defining fea-
tures" starting with the overall form
and scale of the building, often
including exterior material, the inte-
rior layout, distinctive windows and
doors, canopies, signage, and the
organization of structures, pump
islands, landscape features, and light-
ing fixtures on the site. Deciding
whether these features are important
to the building's history and, when
significant, planning how they will
be retained are crucial first steps in
any rehabilitation project.
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September 2006 • LUSTLine Bulletin 53
Before: 1200 Wealthy
Street, Grand Rapids,
Michigan
This cycle of
abandonment and
reuse is typical of
gas station his-
tory. Frequently
they were con-
verted to other
automobile-relat-
ed purposes such
as repair shops or
used car dealer-
ships, changes
that required lit-
tle more than
switching signs
and removing the
pumps.
While the best
use for a historic gas station is its
historic use—regular maintenance
and well-considered repairs help
ensure that existing historic gas sta-
tions continue to survive while
retaining those elements that help
give them historic integrity—more
often, landowners or municipal
governments are dealing with
vacant gas stations.
When new functions are found,
gas station buildings have proven
remarkably adaptable. As Ben &
Jerry's Homemade Ice Cream
showed when they opened their first
store in a converted gas station in
Burlington, Vermont, these buildings
are often ideal for new start-up com-
panies with limited resources. New
owners have also reused stations as
art galleries, like the Station 66
gallery in Providence, Rhode Island,
and The Station Pure Art in McMinn-
ville, Tennessee, as well as bakeries,
pet stores, medical supply shops, and
numerous other functions.
Restaurants and
Coffee Shops
While the introduction of a kitchen,
freezer, and other restaurant facilities
always requires some change to a his-
toric structure, the basic configura-
tion of many historic gas stations has
been shown to be well suited for
reuse as an eatery. In modest cafes
and coffee shops, the former sales
area is reworked into counter, prep,
and limited seating space. The ser-
vice bays in larger stations are easily
converted to open seating areas.
Where more space is required for the
kitchen or storage, service bays are
reorganized for this use or an unob-
After: 1200 Wealthy Street, now Sandmann's Restaurant
trusive addition is constructed at the
rear of the building.
The gas station at 1200 Wealthy
Street in Grand Rapids, Michigan,
was constructed in 1929 and enlarged
and refaced with steel panels during a
1950s remodeling. It served as an auto
repair shop for a number of years
before being abandoned in the 1990s.
In 2004, a new owner rehabilitated the
boarded-up station for use as a neigh-
borhood carry out restaurant called
Sandmann's.
The old sales area was reused for
customer ordering, pick up, and a
small seating area, while the service
bays were converted to food prepara-
tion, storage, and office spaces. To
meet current ADA and building code
requirements, the two historic
restrooms were merged into one
accessible unisex restroom. To
accommodate a new barbecue grill
while retaining the historic size and
shape of the original structure, the
new owners placed an inconspicuous
masonry addition onto the rear.
Other restaurant examples in-
clude Sherman Perk in Milwaukee,
Wisconsin; The Coffee Station in
Minerva, Ohio (which features coffee
beans in the vintage glass pumps out
front); the Fuel Pizza Cafe in
Charlotte, North Carolina; and
Cruiser's Cafe in Mount Pleasant
Mills, Pennsylvania.
Offices and
Community Centers
Former gas stations can also be con-
verted to offices and community
centers. The West Broadway Neigh-
borhood Association in Providence,
Rhode Island, rehabilitated a classic
1930s porcelain enamel station for
their office and
meeting space. An-
other example is
the Spruce Street
Standard gas sta-
tion in Ogallala,
Nebraska, which
was restored in
2003 for use as
the Main Street
program office and
community meet-
ing space. In
1997 the statewide
group Preser-
vation North Car-
olina finished re-
storing a Shell gas station in Winston-
Salem for use as its regional office.
Constructed in 1930 with a concrete
finish over a bentwood frame, it was
one of eight shell-shaped stations
built by a local gasoline distributor to
lure curious customers from the road-
side.
Museums and
Visitors Centers
In recent years, a number of historic
gas stations have been converted to
museums and visitors centers. The
structures are often fully restored to
replicate their appearance during a
formative period of local history. Sur-
viving remnants of historic roads like
Route 66 include a number of gas sta-
tions that were bypassed by the inter-
state system and are now restored
and patronized by tourists and locals.
As public interest in heritage tourism
continues to grow, projects like the
Reed/Niland Corner Filling Station
along the former Lincoln Highway in
Colo, Iowa, are proving to be a viable
way of preserving historic gas
stations while increasing tourism rev-
enue and enhancing the visitors'
experience.
• continued on page 9
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LUSTLine Bulletin 53 • September 2006
A MESSAGE FROM CLIFF ROTHENSTEIN
Director, U.S. EPA Office of Underground Storage Tanks
Update on Energy Policy Act
Implementation
E
'xhilarating, intense,
exhausting—those
i words come to mind
as I think of the past 12
months. Since August
2005, when Congress
enacted and President Bush signed the Energy Policy Act of
2005, we've all been working at a fast pace to implement the
underground storage tank provisions in the act. I know
states, tribes, and other UST partners have worked tirelessly
to share their input, expertise, and advice as we developed
grant guidelines and the tribal strategy. Together we've
achieved major milestones. Yet over the next few years, we
still have much more to accomplish.
We Met Statutory Deadlines
Sections 1527 and 1529 of the Energy Policy Act provide
requirements regarding a prohibition on product delivery and
a strategy for implementing the UST program in Indian Coun-
try, respectively. Both of these requirements have the statu-
tory deadline of August 8, 2006. With significant effort from
state and tribal representatives on the work groups, as well
as input from other UST partners, EPA met the deadline and
issued the delivery prohibition grant guidelines and tribal
strategy. States now have the important job to implement the
guidelines.
Delivery Prohibition - The delivery prohibition grant
guidelines describe the process and procedures that
states must use for prohibiting fuel delivery to under-
ground storage tanks that are ineligible to receive prod-
uct. They include definitions, criteria, examples, options,
and requirements for states implementing the delivery
prohibition provision. States receiving federal funds
under Subtitle I of the Solid Waste Disposal Act must
implement the delivery prohibition requirements
described in the guidelines by August 8, 2007. EPA con-
sulted with states and representatives from the UST and
fuel delivery industries to develop the guidelines.
To ensure that the guidelines are implemented with mini-
mal disruption, EPA is giving states considerable flexibility
to establish their own delivery prohibition programs. At the
same time, the guidelines establish several important safe-
guards to ensure that states have a process for notifying
deliverers when an UST is not eligible to receive product.
To ensure the delivery prohibition guidelines are effectively
implemented, EPA will continue to work with states and the
delivery industry to share information on delivery prohibi-
tion programs developed and used by states.
See: http://www.epa.gov/oust/fedlaws/finaLdp.htm to
view the delivery prohibition grant guidelines, which are
posted on EPA's website.
Tribal Strategy - The strategy for implementing the UST
program in Indian Country identifies key issues and
actions to: strengthen the relationships between EPA
and tribes; improve information sharing; enhance tribal
capacity; and further the cleanup and compliance of
USTs in Indian Country. The tribal strategy is the foun-
dation for future UST work and collaboration between
EPA and tribes. Over the next year, we will work with our
tribal partners to implement the strategy. EPA developed
the strategy with considerable input from tribal repre-
sentatives, as well as EPA regional and headquarters
staff. EPA is required to report to Congress by August 8,
2007, on our progress in implementing the strategy.
See: http://www.epa.gov/oust/iedlaws/1inaLtsMm to
view the tribal strategy, which is posted on EPA's web-
site.
All federal agencies are required to report directly to
Congress and EPA's Administrator by August 8, 2006, on the
compliance status of federally owned USTs. OUST, along with
EPA's Federal Facilities Enforcement Office staff, is compiling
a checklist of federal agencies' progress in submitting their
compliance reports to Congress and determining how best to
share that information with tank partners and stakeholders.
Additionally, this reporting requirement applies to tanks EPA
owns or operates. EPA's Office of Administration and
Resources Management developed the Agency's compliance
report, in which the Agency states that its USTs have been
inspected and are in compliance with applicable regulations.
EPA provided its report to Congress on August 9.
We Resolved All or
Nothing and Issued Drafts
All or Nothing - On August 10, we shared with EPA
regions and the ASTSWMO tank subcommittee an
opinion from EPA's Office of General Counsel clarifying
the issue of EPA's enforcement remedies when a state
does not comply with one or more of the requirements
for receiving Subtitle I funding specified in the under-
ground storage tank provisions of the Energy Policy
Act. We commonly refer to this as all ornothing. Our
Office of General Counsel advised us that EPA may
consider a wide range of remedies for noncompliance
under its grant regulations, and that the Agency is not
• continued on page 9
8
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September 2006 • LUSTLine Bulletin 53
Energy Policy Act from
under a legal obligation to automatically terminate or
withhold future funding when a state does not comply
with one or more Energy Policy Act requirements.
Issued Drafts in Spring - As a result of the hard work
by states and EPA staff, we developed and issued for
public comment draft guidelines in spring 2006.
Those drafts covered requirements for secondary
containment, financial responsibility and certification,
and public records.
There's More to Come
This summer, we've been reviewing public comments on
the draft guidelines. In autumn 2006, we plan to issue final
grant guidelines for secondary containment, financial
responsibility and certification, and public records. All the
while, work groups responsible for other Energy Policy Act
provisions are busy analyzing and evaluating many issues
so we can continue our progress. Also this fall, keep a look-
out for EPA to issue draft grant guidelines on provisions
such as inspections and government-owned tanks in states.
States Have a Big Job Ahead
I acknowledge that, while this past year has been an excit-
ing time, states are now (and will continue to be) faced with
a huge workload and some difficult challenges ahead to
implement the grant guidelines just issued, as well as those
that will be issued in the coming months and years. I realize
states have genuine concerns regarding the need to balance
meeting the new requirements with very real resource con-
straints in today's climate of tightening budgets and limited
resources. And I understand that the meeting schedule of
states' legislatures may be obstacles to states' progress in
implementing new requirements.
We hear your concerns, and they are legitimate. We're
identifying ways—such as flexibility in the delivery prohibi-
tion grant guidelines, the all-or-nothing issue, and addi-
tional funding to meet the two-year inspection
requirement—to help states as they work to implement the
new requirements. And I pledge that we will continue to
work with states to find opportunities to help.
With Great Appreciation
I sincerely appreciate the hard work and dedication of state
and tribal work-group representatives who've helped us
achieve so much in implementing the UST provisions of the
Energy Policy Act. And I also thank state and tribal tank
managers and staff—our partners—for your work to imple-
ment the new requirements as well as your ongoing work to
keep our environment safe from the threat of UST releases.
I respect your commitment to our tank work, and I value
your support of our partnership. •
NPS Reusing Abandoned Gas Stations from page 7
Restored gas stations can also
help tell other stories. In the 1950s, a
Magnolia Mobil gas station was
located down the street from the Little
Rock Central High School, scene of the
1957-1958 battle over school desegre-
gation. Decades later, the disused sta-
tion was purchased and restored it to
its appearance during those historic
events. Mobil's Corporate Archives
provided original specifications for
the vintage signage, the paint scheme,
and the restored gas pumps. Renamed
the Central High School Museum and
Visitors Center, the station today pro-
vides exhibit and interpretation spaces
serving the many tourists and school
groups that visit the area. (See photo
on page 6.)
Funding Rehabilitation
Gas station rehabilitation projects
often rely on financing assembled
from numerous sources. Owners con-
verting historic stations for use as
restaurants, leasable offices, and other
income-producing functions may be
eligible for grants or no-interest loans
sponsored by local business develop-
ment agencies and chambers of com-
merce. In some states, project costs
may be eligible for state historic reha-
bilitation credits.
If a property is listed or eligible
for listing in the National Register,
rehabilitation may be an eligible
option for Federal Historic Tax Incen-
tives, a tax credit program adminis-
tered by State Historic Preservation
Offices (SHPO) and the National Park
Service. Some gas station rehabilita-
tion projects have received grants
through the federal transportation
enhancement (TEA-21) program.
Parties interested in rehabilitating
or restoring a historic gas station have
formed new ad hoc organizations or
worked with an existing nonprofit
organization. In either case, such
groups can sponsor fundraisers, write
grant proposals, seek private and
institutional donations, and serve as
leaseholders or even owners of the
building.
Where Are Your Gems?
Abandoned gas station site cleanup,
economic revitalization, and building
rehabilitation go hand in hand. To fur-
ther their overlapping goals, preserva-
tionists, developers, local officials, and
LUST program administrators should
more closely coordinate their efforts.
As the projects highlighted in the
Preservation Brief show, it is feasible to
retain and return to service former gas
stations in ways that benefit the com-
munity's economic stability and sense
of place, while providing a return for
money spent cleaning up contami-
nated sites. Gas station rehabilitations
reflect an inclusive understanding of
conservation—one that embraces the
varied appearance, dynamism, and
complexity of the American land-
scape, one that recognizes the stored
energy contained in existing construc-
tion, and one that sees the reuse of
buildings as recycling. •
Chad Randl is an architectural historian
with the National Park Service's Techni-
cal Preservation Services branch. He can
be reached at chad_randl@nps.gov.
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LUSTLine Bulletin 53 • September 2006
Los Angeles Adopts New Expedited
Agency Oversight Program
Completes Multisite Agreement with Five Oil Companies
by Yue Rang and Matthew Small
There are currently about 117,000 ongoing leaking underground storage tank (LUST) cleanups nationwide (EPA, 2006a). U.S.
EPA has placed a strong emphasis on cleaning up these sites to reduce the national caseload and return the contaminated
properties to productive use. To achieve this objective, U.S. EPA's Government Performance and Results Act (OMB, 1993)
cleanup goals for fiscal year 2006 include completing 13,600 cleanups and decreasing newly reported confirmed releases to fewer than
10,000. To meet these goals, it is important to enhance cleanup rates in the states with the largest caseloads.
With more than 14,000 LUST sites, California has the second-highest caseload in the country. The Los Angeles Regional Water
Quality Control Board (LARWQCB) is responsible for regulating more than 4,000 of these sites. So, with a staff of only 20 environ-
mental scientists, geologists, and engineers, LARWQCB was looking for ways to improve the efficiency of their cleanup process. The
program landed the idea of leveraging private-sector expertise and resources by allowing major oil companies to conduct self-directed
cleanups at their lower-priority flower-risk sites within a specified time frame using a modified regulatory oversight approach. Thus
the Expedited Agency Oversight Program (EAOP) was born.
Program Structure
The LARWQCB program staff have
prioritized all cases and classified
them into four categories (A, B, C, D),
based on the presence of MtBE and
proximity to drinking water wells.
Category A and B sites have priority
for regulatory oversight. Given the
reality of limited staff and resources,
lower-priority cases often receive less
attention and cleanups may slow
down or stall.
The EAOP was created to help
move lower-priority cases (D cases)
through the cleanup process more
efficiently. The EAOP allows major
oil companies, as responsible parties,
to conduct self-directed site assess-
ment, monitoring, and cleanup with
expedited regulatory oversight.
Expedited oversight consists of quar-
terly face-to-face meetings with LAR-
WQCB staff to review cleanup
progress for each company's portfo-
lio of low-risk sites, deferring review
of a formal written report until
cleanup is complete and site closure
is requested. The responsible parties
are also required to provide an esti-
mated time line for implementing site
assessment and completing cleanup.
EAOP eligibility criteria include:
• Low-risk/low-priority sites
• Agreed-upon time frame for
cleanup (usually two to three
years)
• Major oil company sites
(proven cleanup expertise
allows self-directed cleanup)
10
• Regularly scheduled verbal
portfolio and progress reviews
with LARWQCB
• Sites listed with the state fund
to allow reimbursement of
costs without work plan
preapproval from regulatory
agency
• Final report when requesting
closure must describe site
work and data collected.
The EAOP was made possible
due to a number of supporting fac-
tors, including cooperation of the
State Cleanup Fund; site tracking
through the statewide Geotracker
database; nonnumerical, or perfor-
mance-based, closure criteria for low-
risk sites; and the experience and
expertise of major oil company
cleanup consultants working closely
with LARWQCB staff. (Note: the self-
directed cleanup approach requires a
responsible party with proven
cleanup expertise, such as a major oil
company).
Program Benefits
and Limitations
The EAOP multisite cleanup agree-
ment groups sites by ownership (i.e.,
major oil companies) and by geo-
graphic area (i.e., LARWQCB) (U.S.
EPA, 2006b). This grouping is an
effort to achieve greater results by
addressing sites that have common
characteristics or issues. The EAOP
takes advantage of economies of
scale to save time and resources.
Table 1 outlines some potential addi-
tional benefits of the EAOP.
There are some possible limita-
tions to this approach. For example,
the self-directed cleanup process
requires experienced, capable re-
sponsible parties as well as trust
between the regulatory agency and
the responsible parties. Waiver of
preapproval for work plans could
potentially create problems with state
fund approval of expenditures. How-
ever, the benefits currently appear to
outweigh the limitations.
Program Status
Since inauguration of the EAOP in
February 2005, about 250 LUST sites
have been included in the program.
LARWQCB has also established a
process to add new cases that meet
the EAOP criteria described above.
Currently, LARWQCB meets
with responsible parties and their
consultants on a quarterly basis. Dur-
ing these meetings, staff and respon-
sible parties review cleanup progress
of EAOP portfolio sites with the oil
company. These meetings provide a
forum to discuss any issues encoun-
tered during site assessment or reme-
diation and to check the progress for
each site. Again, the meetings are an
expedited verbal review process—no
written reports, preapproval, or work
plans are required prior to perform-
ing work at EAOP sites.
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September 2006 • LUSTLine Bulletin 53
Agency Oversight Progr
mg, 2006, EPA, 2004,200
Stakeholder Benefits
Move low-priority sites through the cleanup process and increase closure
rates
Reduce staff time on low-risk sites and provide more time for higher-risk
sites
Leverage private-sector resources and cleanup expertise
REGULATORY
AGENCIES
Reduced report review time by eliminating work plan preapproval require-
ments and reducing reporting frequency
Focused, regularly scheduled portfolio review with regulated community
Provides an incentive for responsible parties to review their low-priority case
portfolio and make a plan for managing these sites in a timely manner
Clear communication of cleanup time frame expectations and closure criteria
Increased communication with regulated community streamlines cleanup
Remediated sites can be reused or resold
Remediated sites reduce liability
REGULATED
COMMUNITY
Reduced reporting requirements, no work plan preapproval required, which
can result in cost reductions as well as faster site assessment and cleanup
Increased communication with regulators improves understanding of
regulatory closure process, expectations, and criteria
Input and agreement on cleanup time frames
Focused, regularly scheduled portfolio review with regulators
More efficient regulatory interface for multiple sites
lems and issues that may be common
to a number of sites, allowing regula-
tors and oil companies to make
appropriate programmatic changes
to streamline the cleanup process.
Equally important, these discussions
have helped the regulated commu-
nity to gain a better understanding of
the criteria and requirements for site
cleanup and closure. This allows
responsible parties to focus on the
important issues at each site, poten-
tially saving a tremendous amount of
time and resources.
Negotiated cleanup time frames
are a key to the success of this pro-
gram. The LARWQCB reviews each
company's portfolio of category D
sites and assigns an estimated
cleanup time frame for each site. The
company can propose a modification,
but must supply a realistic estimated
time to achieve cleanup. The pro-
gram has already resulted in closure
for 17 sites and, based based on esti-
mated cleanup time frames, over 200
additional sites are in the "pipeline"
for closure in the near future. These
low-priority cases are starting to
In addition, these discussions
create an opportunity for the oil com-
panies to better understand LAR-
WQCB cleanup criteria. The EAOP
gives major oil companies an incen-
tive to review their low-priority case
portfolio and make a plan for manag-
ing these sites in a timely manner.
Table 2 summarizes portfolio review
and cleanup progress to date for each
major oil company.
The numbers in Table 2 indicate
that 59 percent of the major oil com-
pany low-priority cases are in the
remediation stage—an advanced
stage toward case closure. This indi-
cates that the majority of the low-
priority case portfolio is in a relatively
"mature" stage. As of June 30, 2006, a
total of 17 cases under the EAOP have
been granted case closure. Also, about
123 EAOP cases are projected for clo-
sure during the next three years (2006,
2007, and 2008). Although not all
cases can be closed in the three-year
period from the start of the EAOP, it
is a big success to have each major oil
company working on its low-priority
cases and estimating a closure time
frame for each site.
Though the number of cases
closed under this program is small in
comparison with the total caseload
for LARWQB, it is important to
TABLE 2 EAOP Case Status and Progress Summary
MAJOR OIL
COMPANY
Company 1
Company 2
Company 3
Company 4
Company 5
TOTAL
NO. OF TOTAL
EAOP CASES
32
53
34
67
65
251
NO. OF CASES
IN REMEDIATION STAGE
30 (94%)
32(61%)
6(18%)
31 (46%)
48 (74%)
147 (59%)
CLOSURE PROJECTIONS
2006 2007 2008
8
5
4
7
2
26
6
12
5
6
10
39
10
12
8
11
17
58
TOTAL
24
29
17
24
29
123
remember that this is a pilot effort. In
addition, progress is now being made
on low-priority cases that otherwise
would be given much less attention
and would probably move much
more slowly through the cleanup
process. This approach is being eval-
uated for potential expansion to other
areas in California.
Thumbs Up!
Increased face-to-face communica-
tion between regulators and the regu-
lated community is probably the
largest single benefit that has come
out of the EAOP. The program pro-
vides a forum for discussing prob-
move more quickly through the
cleanup process.
Expedited regulatory oversight
helps us address limited regulatory
resources by reducing the staff time
needed to manage low-risk, lower-
priority cases, allowing more time to
be spent on higher-priority sites. To
make this approach work, the EAOP
leverages existing industry cleanup
expertise combined with self-directed
cleanup of low-priority, low-risk
sites. Cleanup progress is still
monitored regularly, but preap-
proval and reporting requirements
are dramatically reduced. •
• continued on page 35
11
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LUSTLine Bulletin 53 • September 2006
Rims an riD
Prioritizing and Targeting UST
Systems at Risk Using GIS
by Frank Harjo
The Inter-Tribal Environmental Council (ITEC) is a tribal consortium consisting of 40 member tribes from Oklahoma, New
Mexico, and Texas. The ITEC staff is committed to providing technical assistance and support to ITEC member tribes
through programs funded by EPA Region 6. The ITEC Underground Storage Tank Program works with member tribes that
currently have or are proposing to have an UST system installed on tribal land. The goal of the ITEC UST Program is to assist
member tribes in complying with federal regulations and remediating leaking underground storage tanks.
While all tribes strive to achieve these goals, various factors contribute to the release of product or deterioration of an UST sys-
tem. As each UST system is unique, the potential for a release is determined on a case-by-case basis. As our UST population
increases, the need for UST inspections grows. In order to prioritize our inspections, it is important that we identify the UST sys-
tems that are prone to failure and could have a negative impact on our natural resources. Currently, ITEC assists 19 member tribes
at 31 different locations and over 90 USTs in three states.
Using Geographic Information System (GIS) technology, ITEC has developed a screening tool, the Cumulative Risk for Under-
ground Storage Tank (CRUST) model, to assess the risk of a given UST, based on criteria used to model the UST and surrounding
environment. It is the goal of the ITEC UST program to use this information to prioritize sites that have a high potential to leak and
impact the environment.
The CRUST Model
The CRUST model is based on an
EPA Region 6 model developed by
Dr. Gerald Carney and others. To
assess risk, the model uses a scoring
system whereby criteria from five
sets of data categories are ranked and
then combined to yield an overall
score from 1-5.
The five categories are:
• Community
• Topography/geology/
• Physical UST characteristics
• Compliance
• Facility
So, for example, when consider-
ing the age of an UST, under the
physical UST characteristics cate-
gory, a newly installed UST would
score much lower than an UST that
has been in service for ten years. A
score of 1 indicates a low risk, or min-
imal concern. As the score increases,
the risk factor for a particular crite-
rion increases as well, with a maxi-
mum score of 5. More than 70 items
are currently factored into the overall
analysis.
The community category consists
of a compilation of all the criteria that
best fit the makeup of a particular
12
community—census data, health,
land use, and other quality-of-life cri-
teria. The topography/geology cate-
gory includes data that best describe
the natural resources (including
water resources) and geology of the
environment around a particular
UST. The UST criteria are divided
into three categories that best describe
the UST system—physical UST char-
acteristics, compliance, and facility.
These sets of criteria give us the infor-
mation we need to describe the UST
system with regard to potential risk.
The GIS Tool
GIS technology has become readily
available to the tribal community. In
fact, the affordability of and access to
GIS technology and global position-
ing systems (GPS) have made the two
applications an essential tool to man-
age our natural resources As tribal
expertise and use has grown, more
GIS applications are becoming appar-
ent. Tribes are becoming accustomed
to managing their natural resources
in a way that was not possible just a
few years ago. GIS provides the foun-
dation for the organization of spatial
data and placing this data onto a flat
surface, such as a map or computer
screen.
GIS features are represented by
point, line, and polygon feature
classes. Layering features on top of
each other allows spatial relation-
ships to be formed and an analysis of
the data to be constructed. Within
any given feature class there is an
attribute table that contains informa-
tion about that feature. For example,
the location of a building can be rep-
resented as a polygon feature class
and have specific attributes or infor-
mation related to that building, such
as type, color, and other information
pertaining to that particular feature.
It is the combination of the spa-
tial and tabular data of a feature class
that makes GIS analysis possible.
With two or more features, relation-
ships such as proximity and areas of
interest can be established. Using the
location of an UST as the point fea-
ture of concern, other features can be
overlaid with the UST, and the level
of risk associated with other features
can be analyzed.
GIS is not just a map-making
tool, it is also a powerful data pro-
cessing and analysis tool that can be
used to do complex work. Manual
GIS computation with individual
USTs and features could take hours.
The CRUST application does this
work by automating the GIS analysis
and processing more than 70 sets of
criteria for a single UST location. The
processing of data by automation is
what separates this GIS application
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September 2006 • LUSTLine Bulletin 53
from any other GIS analysis. This tool
gives the user immediate results and
allows high-risk UST facilities to be
prioritized as quickly as data is
received for a particular site.
The GIS analysis is made possi-
ble by having our predetermined cri-
teria gathered as scripts or small
programs in the GIS. The scripts
score the data based on the values
obtained from the location of the site
or the data collected in the field. The
scripts are the 1-5 criteria ranking
and as data is evaluated for each set
of criteria, a score of 1-5 is returned
for that particular piece of criteria.
After all of the criteria are scored
on a 1-5 ranking, they are grouped
into one of the five categories, and a
cumulative score is calculated. The
cumulative score indicates the overall
priority for an UST facility. However,
the CRUST model is flexible to allow
weighing of either a specific category
of criteria or a single piece of criteria to
standout in the overall GIS analysis.
The model consists of three GIS
applications or tools that combine to
facilitate a system of collecting, ana-
lyzing, and viewing data. These
applications enable the ITEC UST
program to maximize resources in a
number of ways in order to focus our
resources on troubled or high-risk
UST facilities.
In the Field
We collect our site-specific data in the
field during routine UST inspections
at the tribal UST facilities. The data
are collected using a customized GIS
ArcPad application that allows us to
have all of the UST criteria built into
the software. Currently, ITEC has
developed 25 sets of criteria that per-
tain to an UST system and facility
that make up three of the five overall
categories. The information gathered
in the field during the actual UST
inspections makes up three-fifths of
the overall risk analysis. The infor-
mation collected during the inspec-
tion is also used in the GIS analysis.
To ensure quality control of the
data collected by the UST inspector
and consistency with the GIS analy-
sis, it was necessary to create an
application that matched the infor-
mation that the UST inspector would
collect in the field. With the field
application and office GIS applica-
tion in sync, the UST inspector could
Custom ITEC UST inspection form—
criteria are built into the form.
use a customized inspection form
that had the values loaded into it
that matched the criteria ranking
used back in the office for the GIS
analysis.
The UST inspector can easily
choose from a dropdown list and
collect the data on site in a GIS
format using the ArcPad soft-
ware and, at the same time, cap-
ture spatial information from
each of the USTs on site. This
ensures that the data collected
is consistent and that there is
no transfer from paper to the
database.
This is done by capturing
the location of the fill tubes.
Since compartmentalized USTs are
counted as individual USTs, the fill
tube location gives us the most accu-
rate information about a particular
UST and the layout of an UST facility.
The ITEC UST inspection form
allows us to have the same consistent
form available for all UST site inspec-
tions and provides an easier mecha-
nism to download the data back into
the GIS desktop for analysis.
One advantage to having the
spatial information of an UST facility
is that the data can be entered into
the GIS program and constructed
into a three-dimensional model of the
actual facility. Having the spatial
data associated with a site allows
ITEC to track active and nonactive
USTs at that site. The big advantage
of using the ArcPad software is that
GPS can be utilized, and the form is
customizable to any changes that
may be needed.
Back in the Office
Back in the office, data are down-
loaded from the field unit into the
desktop GIS for analysis. Using the
predetermined criterion that is
already in our system, a radius of a
quarter-mile is set to determine the
extent of our analysis. The GIS pro-
gram reads the spatial location of the
UST fill tubes and begins to analyze
data collected in the field, scoring
each set of criteria. After all of the
UST data are read, the community
and topography/geology categories
are analyzed, based on UST location
and using the same quarter-mile
buffer. After all of the data are read
and scored, a table showing the 1-5
scoring results is displayed.
Displayed Results
The tabular results are converted and
submitted to an ArcIMS data viewer
where the data is mapped and
viewed internally through an ArcIMS
data viewer. An ArcIMS data viewer
gives non-GIS users the ability to
view spatial relationships between
different objects. Different layers of
data can be applied to the ArcIMS
data viewer to distinguish features
that an UST facility may impact if a
leak does occur.
It is this type of GIS program, in
which results can be added after a
GIS analysis or update of data, that
makes this tool valuable to the tribal
community. Access can be granted to
anyone who may wish to utilize these
data to protect human health and the
environment surrounding an UST
facility.
Thus far, the highest scoring
facility was a 3.62 and the lowest
scoring facility was a 1.75. However,
the full potential in this program is
not the cumulative score but more
important, the ability to see the high
scores of 4 and 5 for each set of crite-
ria where risk or concern is elevated.
This can be easily seen in the ArcIMS
data viewer for each of the five cate-
gories. For instance, if a user would
like to know which criteria are
• continued on page 32
13
-------
LUSTLine Bulletin 53 • September 2006
How to Collect Reliable Soil-Gas Data for Risk-Based
Applications—Specifically Vapor Intrusion
Part 4 - Updates on Soil-Gas Collection
and Analytical Procedures
by Blayne Hartman
Since I wrote Part 3 of this "Collecting Reliable Soil-Gas Data" series in LUSTLine #48, Nov 2004, the subject of vapor intru-
sion has continued to be a "box-office blockbuster" throughout the environmental community. The EPA-OSWER draft vapor-
intrusion guidance is currently being rewritten and is expected to be released in the first half of 2007. The Interstate Technology
and Regulatory Council (ITRC) has written a vapor-intrusion guideline document that is currently out for review and is due to be
released in early 2007. ASTM International has entered into the fray and has convened a workgroup to amend the Phase I guidance to
include assessment of the vapor-intrusion pathway and to write a standard on how to do it. Individual states continue to release their
own policy/guidance on this pathway (e.g., CA, NY, NJ, MO). Many others are working on their own guidance. The concern about
vapor intrusion extends to the United Kingdom (U.K.) and Australia. Since soil-gas data are preferred by the majority of agencies in
evaluating the pathway, much debate has surfaced over some of the collection and analytical procedures. In this article, I present some
of the results from recent studies that address some of the pertinent issues. I refer you to Parts 1 (LUSTLine #42) and 3 in this series
for a good introduction to this article and for more information on some of the topics covered herein.
The Two Most
Common Errors
Vapors and vapor intrusion are
unfamiliar territories for many prac-
titioners in this field (regulators,
stakeholders, consultants, subcon-
tractors, attorneys). Here are two of
the most common errors that people
make with soil-gas programs or data.
• Confusion with Units
One common error that people
make with soil-gas programs or
data is thinking a ppbv is equiva-
lent to a ug/L or a ug/m3. The
units are not equivalent, and the
conversion depends on the mole-
cular weight of the compound.
Converting between units (e.g.,
ug/L to ug/m3, percent to
ppmv) is also causing headaches.
As I advised in Part 3, make your
life simpler by:
- Instructing your lab in what
units and detection levels you
want the data reported.
- Going to www.handpmg.com
for a handy-dandy and easy-
to-use unit conversion spread-
sheet.
• Required Soil-Gas Target Levels
The other error I see too often is
the regulator or consultant using
incorrect soil-gas target levels.
Residential values are erro-
14
neously applied at commercial
sites, incorrect attenuation factors
are being used to determine tar-
get values, or values determined
from predictive models are incor-
rect. The soil-gas target level ulti-
mately determines the required
analytical method and the need
for additional assessment. Deter-
mining the proper value is often
an unfamiliar exercise for both
regulator and consultant. So, con-
sultants need to ensure that regu-
lators are asking for the proper
values, and regulators need to
ensure that consultants are
proposing the proper value.
Sample-Collection Issues
Probe Installation Method
I have not seen a significant differ-
ence in results among samples col-
lected either through the probe rod
while the rod is still in place or
through tubes that are buried in the
ground after the rod is removed. This
observation is based on data from
hundreds of sites where we have
made repeated measurements using
different methods. While I have
never compiled these data, a recent
report by U.S. EPA (DiGiulio et al.
2006a) provides data that addresses
this very topic. Although small dif-
ferences were detected, the study
showed that data collected using
hand-driven probes, direct-push
rods, and buried tubes show good
agreement, generally about the same
as analytical precision.
The bottom line is that the probe
installation technique does not mat-
ter so long as you do it right. So, the
choice of which method to use
should depend upon the site, access,
and project goals. Typically, sam-
pling through the probe rod is faster
and less likely to disturb the insitu
soil gas. For limited-access areas, a
hand probe may be all that is applica-
ble. For deeper depths, direct-push
probes are more convenient. For
repeated sampling, burial of small-
diameter tubes offers advantages. If
the probe-rod methods are used,
samples should be collected through
small-diameter inert tubing that runs
down the probe rod so the sample
does not contact the inside of the
probe rod.
Extraction Volume
Three published studies are now out
that compare soil-gas concentrations
collected from volumes ranging from
0.5L to 100L (DiGiulio et al. 2006a;
McAlary and Creamer, 2006; DiGiulio
et al. 2006b). The results of these stud-
ies, done in relatively coarse-grained
soils, show no significant difference in
concentrations. (See Figure 1.) I have
reviewed data from countless sites
comparing on-site analysis from 50cc
-------
September 2006 • LUSTLine Bulletin 53
FIGURE 1 Soil Gas Concentration vs. Volume Extracted
ft
T60D
1400
1200
taoo
300
600
400
300
0
0 20 40 •=,: BO im 12
CummulMive Pre-Sample Exlriclion Veukjnrt |L|
No significant effect is seen on volumes from 500 c (0.5L) to over 100L. Study
conducted by EPA-ORD at an EPA test site. (DiGiulio etal. 2006a.)
syringe samples to off-site analysis
done on samples collected in canisters
(1L to 6L). I rarely see differences
greater than 20 percent.
However, in finer-grained soils,
large volumes are often not possible
or difficult to collect. If larger sample
volumes are attempted, the potential
for leaks around fittings increases. I
also have witnessed higher concen-
trations where large volumes are
"forced" from tight soils, presumably
due to contaminant desorption off
the soils.
Finally, the larger the volume
extracted, the greater the uncertainty
of where the sample is located. The
more complex the sampling system,
the greater the chance of drawing air
from the surface and the longer it
takes to collect a sample. These fac-
tors increase the potential for sam-
pling errors, nonrepresentative
values, and increased costs. It is best
to collect a sample volume that is no
larger than that required by your lab
and no larger than 1L.
Sample Flow Rate
Many state agencies have put a limit
on sample flow rate (typically
<200ml/min) because they are con-
cerned that excessive flow might cre-
ate turbulent flow at the probe tip
and influence the soil-gas concentra-
tions. DiGiulio et al. (2006b)
addressed this topic using airflow
modeling and concluded that this
general limit was reasonable. How-
ever, McAlary and Creamer (2006)
actually measured soil-gas concentra-
tions over different flow rates rang-
ing from 100ml/min to lOOL/min at
a hydrocarbon contamination site.
They saw no significant difference in
measured concentration. This sug-
gests that for relatively coarse-
grained soils, flow rate does not
appear to be an important variable on
soil-gas concentrations. Allowing
faster flow rates increases sample
throughput and eliminates the cost
and potential blanks of additional
hardware (e.g., flow restrictors).
Tubing Type
Two studies have been done to eval-
uate different types of tubing. Air
Toxics (Hayes et al. 2006) conducted
tests of three tubing types (Teflon,
nylon, PEEK) that showed little dif-
ference in the tubing type. Low-level
blanks were detected in nylon, but
the values were far below required
soil-gas risk-based screening levels.
An earlier study presented at a con-
ference in 2004 (Ouellette, 2004)
compared the adsorption of a hydro-
carbon standard by five tubing types
(Teflon, nylon, polyethylene, vinyl,
and flexible tygon). Nylon and Teflon
showed insignificant losses (<10%),
but the others showed higher losses,
especially the flexible tubing, where
losses were up to 80 percent.
Flexible tubing should be
avoided. For rigid-wall tubing, in
practice, the type of tubing is not
nearly as important as where the tub-
ing is stored and how it is handled.
Any type of tubing will become con-
taminated and contribute to false
positives if it is stored in the back of a
truck unsealed or near the truck
exhaust. My preference is 1/8" nylon
tubing, which is easier to work with
than the 1/4" tubing if soil-gas sam-
pling is your only need. It has a
smaller dead volume and is much
less expensive than Teflon.
Tracer/Leak Compound
Most agencies are now requiring that
a tracer compound be used to ensure
there are no leaks around the
installed probe and/or the soil-gas
sampling train. There are methods
using gases (e.g., helium, propane,
SF6, freon) or liquids (e.g., freon, iso-
propanol, butane in shaving cream).
Both types of tracers have pros and
cons.
Gaseous tracers offer some
advantages, but they are more of a
pain logistically, especially if you are
trying to cover leakage in the sam-
pling train as well. Plus you need
tanks, regulators, and other hard-
ware. The entire process becomes
much more cumbersome and time-
consuming, resulting in higher sam-
ple-collection costs.
Helium offers a nice advantage
in that it is readily measured on-site
with a field meter, but due to its
small molecular size, helium more
readily permeates sampling materi-
als than larger molecules typical of
VOCs, so it may indicate a leak when
there really isn't one.
Volatile liquid tracers offer logis-
tical simplicity and accomplish the
primary goal: detecting any leaks in
the probe or sample train. The tracers
are easily and quickly supplied at
multiple locations (probe, sampling
rod, and sampling train) simultane-
ously using paper towels or clean
rags. This method is particularly bet-
ter suited for sampling through the
probe rod since it can be applied at
the base and top of the rod.
This method is also qualitative
since the concentration at the point of
• continued on page 16
-------
LUSTLine Bulletin 53 • September 2006
• Soil Collection and Analytical
Procedures from page 15
application is typically not measured
(although it can be). One disadvan-
tage is that small leaks (as low as
lOOug/L) can cause a lab to raise its
their detection levels depending on
the tracer compound, especially if the
toxic organic (TO) methods are being
used. When on-site analysis is used,
leaks can be found in real time and
samples can be recollected as neces-
sary.
With deeper soil-gas samples (>3
feet bgs), the likelihood of surface air
being drawn down the length of the
probe and into the sample is small,
especially if small (<1L) volumes are
collected. I suspect that most detected
leaks are from poor sample collection
procedures and poor tracer applica-
tion procedures. To minimize these
issues, collection personnel should
keep sample volumes small and col-
lection assemblies and protocols as
simple as possible.
Finally, it is important to recog-
nize that a small amount of tracer in a
sample does not indicate a significant
leak. If the concentration of the tracer
indicates a leak of less than 10 per-
cent, then the leak should be consid-
ered insignificant and the sample
should be considered valid. For liq-
uid tracers such as isopropanol, a 10
percent leak would give a value in
the sample of ~10,OOOug/L, assum-
ing a starting concentration equiva-
lent to the vapor pressure of
isopropanol.
It is best not to limit your options
to any one method. Let the choice be
made by the soil-gas collector for a
given site, based on his or her
comfort with either method, the
availability of on-site analysis, and
the compounds of concern.
Equilibration Time
In the process of burying sampling
tubes in the ground, in situ soil gas is
displaced and the tip is buried in a
sand pack that contains atmospheric
air. How long does it take for the
sand pack to equilibrate with the sur-
rounding soil gas? DiGiulio et al.
(2006b) calculated and plotted equili-
bration times for different distances
and soil water contents. For a 2"
outer diameter borehole, the plot
shows a required time of a few min-
utes to less than a few hours. A recent
16
test performed at a U.S. EPA test site
in Indianapolis showed that the sand
pack equilibrated within three hours
for a 1.5" borehole. In practice, I
advise clients to include the volume
of the sand pack in their purging if
samples are collected the same day as
installation, but not to include the
volume of the sand pack if samples
are collected on a different day.
Temporal Effects
This is a big issue for regulators and
stakeholders. Do we need repeated
sampling events, similar to monitor-
ing wells? There have been a number
of studies on this issue, and more are
currently under way or planned. Dr.
Thomas McHugh of Groundwater
Services recently conducted a
research program for the Department
of Defense and saw variations of
chlorinated hydrocarbon concentra-
tions in shallow soil-gas samples of
less than 30 percent over a 48-hour
period (McHugh 2005).
Todd McAlary of Geosyntec has
shown results from a site in the U.K.
with hexachlorobenzene variations
over seasons less than 40 percent
(McAlary, 2002). Data from a site in
Endicott, New York, presented by Dr.
William Wertz of the New York
Department of Environmental Con-
servation, show maximum variations
of chlorinated hydrocarbon concen-
trations in shallow soil gas (~5 feet
bgs) over a period of 16 months (8/04
to 12/05) of a factor of four, but typi-
cally less than a factor of two. The
variation from the average or mean
concentration is far lower.
At a site in Casper, Wyoming,
Dr. Paul Johnson and others have
monitored soil-gas concentrations of
hydrocarbons using an auto-analyzer
(Luo et. al. 2006). Variations in soil
gas at four feet or deeper were less
than a factor of two over a period of
70 days from September to Decem-
ber. Variations in sub-slab samples
were on the same order except near
cracks. This study is still on going,
and a companion study is planned
for a hydrocarbon site in Ohio. I have
seen little temporal variation in
southern California based on
repeated sampling at thousands of
houses with methane in the shallow
soils. Unfortunately, there is no com-
piled database.
U.S. EPA just awarded a contract
to TetraTech to study temporal varia-
tions at a chlorinated hydrocarbon
site. The testing is to be conducted
this fall/winter and the results will
be reported in 2007.
Looking at the big picture, the
soil-gas concentration variations in
these datasets, even for northern cli-
mates, are insignificant compared
with the overprotectiveness of the
risk-based screening levels. I suggest
that if soil-gas values are a factor of
five to ten times below the risk-based
screening levels, there is no need to
do repeated sampling unless a major
change in conditions occurs at the
site (e.g., elevated water table).
Sub-slab vs. Exterior
Soil-Gas Samples
In another hotly debated issue, some
agencies are concerned that exterior
soil-gas samples may not be reflec-
tive of soil-gas concentrations under
the slab, and they are struggling to
decide what to allow in their guid-
ances. Going inside structures, espe-
cially personal residences, can be a
Prozac moment, so there is strong
incentive to try to use exterior soil-
gas concentrations to assess the
vapor-intrusion risk. U.S. EPA-
OSWER, based on limited data and
some recent 3-D modeling, is feeling
that deeper, exterior soil-gas data (10'
to 15' below the receptor) may be
more representative of concentra-
tions under a slab than shallower
soil-gas data. Currently, there is no
comprehensive database to reach a
definitive conclusion.
For petroleum hydrocarbons, a
significant amount of bioattenuation
can occur in the upper 10' (see Davis,
2006, LUSTLine #52 for a good sum-
mary), so collecting only deeper sam-
ples would not give an accurate
picture of the vapor-intrusion risk.
For chlorinated hydrocarbons, bioat-
tenuation is not as prevalent, so col-
lecting deeper samples may be
justified if the contamination source
is directly below. If the source is spa-
tially away from the receptor, exte-
rior soil-gas concentrations on the
side of the receptor will likely be
higher than concentrations below the
receptor.
I recommend that for hydrocar-
bons, shallow (3' to 5' bgs) exterior
soil-gas samples around the receptor
should be representative of sub-slab
samples if oxygen levels are high
(>6%) and the contamination source
-------
September 2006 • LUSTLine Bulletin 53
FIGURE 2 A Comparison of On-Site Analysis of TCE by
8021 out of a Tedlar Bag vs. Off-site Analysis by TO-15 Out of a
6 Liter Summa Canister Collected by EPA-ORD at a Test Site
mnn
100
10
1 .
w
sf-
• . ,i?"
•• 'X
**>'i*
. *sm •
. ^
//'
1 10 100 1000
Summa Canister - TO-1 5
The correlation is excellent down to values as low as 2 ppbv. Units for both axes
areppbv. (DiGiulio etal. 2006a.)
is not too high (<50,OOOug/L in the
soil vapor, based on 3-D modeling
results by Lilian Abreau, 2006). For
chlorinated compounds, if the source
is below the structure, collect sam-
ples around the receptor as close to
the source as possible. The sub-slab
concentration can be no higher than
the source concentration (e.g., imme-
diately above the saturated zone if
groundwater is the source). If the
source is so deep that samples can
not be readily or inexpensively col-
lected, collect vertical profiles to at
least the mid-depth as discussed in
Part 3 of this series. If a consistent
pattern is obtained around the struc-
ture you can likely safely extrapolate
the data to below the structure. If not,
it will be time to go inside.
Sample Analysis Issues
Use of Tedlar Bags for
Soil-Gas Samples
A number of published studies (e.g.,
Denly & Wang, 1995) have been done
over the years on the stability of com-
pounds in tedlar bags. All of the
studies I've seen, and some tests
we've done, show the bags are reli-
able for the common VOCs for stor-
age times of 24 to 36 hours (less than
15% over 24 hours), but the fall-off
gets greater after 48 hours (30% to
40%). The other primary concern is
blanks from the new bags. New ted-
lar bags can have low levels of VOCs
in them. However, they are typically
less than 10ug/m3, which is also
below most soil-gas risk-based
screening levels (Hayes et al. 2006).
Sample collection in tedlars
offers some sampling advantages.
They are easier to handle and less
expensive, spares are readily avail-
able, they eliminate the potential of
blanks from dirty canisters, and there
are a variety of simple ways to fill
them. In tight soils or soils with high
water contents, I prefer that samples
be collected in tedlar bags to avoid
the potential for leaks at fittings and
water being sucked into the sampling
system or canisters. If the samples
cannot be analyzed within 24 or 48
hours, the sample can easily be trans-
ferred into a canister either in the
field or when received by the labora-
tory.
I suggest that you consider using
tedlar bags when collecting soil gas
samples. Depending on the allowed
storage time, either ship samples to
the lab overnight for them to transfer
or analyze, or transfer them into can-
isters in the field. For high-profile
projects or projects in later stages,
stick to the 24- to 36-hour storage
time. For initial assessments or pro-
jects where a potential 40 percent
error is not of concern, use the 48-
hour storage time.
TO-14/15 Analysis Method: The
Gold or Plastic Standard?
If you're a regulator who believes the
TO-15 method is the gold standard of
VOC analytical methods, you're in for
a shock when you read this section.
Before I begin, it is important that you
understand that my firm conducts
both 8260 and TO-15 analyses, so I am
not writing this because I have a con-
flict of interest or a bias toward either
method. My purpose in writing this is
to inform you of a number of QA/QC
deficiencies in the standard method
so you can ensure that the TO-15 data
you are getting are of sufficient qual-
ity. This is of growing concern as the
number of laboratories offering TO-
15 is rapidly increasing to meet the
vapor-intrusion market.
In truth, QA/QC criteria in the
standard TO-14 and TO-15 methods
are below the requirements of U.S.
EPA SW-846 VOC methods (e.g., 8021
and 8260). A few states have realized
this (e.g., NJ, NY), and their laboratory
certification groups have stipulated
additional QA/QC requirements for
the TO methods (some EPA regions
have done the same although they do
not certify labs). Following are four of
the most pertinent issues.
• Lack of a Second-Source Stan-
dard. The TO-15 method does
not require a second-source stan-
dard. Second-source standards
are required by the SW846 VOC
methods and by most state stan-
dards (e.g., Cal-EPA/DTSC soil
gas advisory) to be analyzed
after the initial calibration to vali-
date the calibration curve, and in
some instances, daily with each
batch as a laboratory control
sample (LCS). Without a second-
source standard there is no
validation or check that the cali-
bration standard is accurate.
The lack of this requirement for
the TO method becomes even
more shocking when you realize
that the method allows use of the
same standard for up to a year!
• continued on page 18
-------
LUSTLine Bulletin 53 • September 2006
• Soil Collection and Analytical
Procedures from page 17
Further, there are no criteria on
the canister type for the stan-
dard. In other words, a lab is
fully method compliant if it uses
only one calibration standard
stored in an aluminum cylinder
for up to a year.
In contrast, most states only
allow samples to be held in pol-
ished or glass-lined canisters for
up to 14 days (Cal-EPA/DTSC
only allows 3 days). You can see
the obvious contradiction that
the same hold-time criterion for
samples is not applied to the sin-
gle-calibration standard. So, how
do you know your standard is
still good after six months if you
are not checking it?
I suggest that states require a sec-
ond-source standard analysis
with the initial calibration and
each analytical batch and require
this analysis to be part of their
data report. Further, if states are
interested in naphthalene, they
should require labs to have naph-
thalene standards, since they are
not part of the standard TO-14 or
TO-15 calibration mix (some labs
report naphthalene based on the
calibration of a similar com-
pound).
• Lack of Surrogates. The stan-
dard TO-15 method does not
require surrogates. The SW-846
VOC methods require surrogates
within lab-derived recovery
ranges. Surrogates are used to
give an indication if a sample ran
"properly." If the surrogates
aren't measured within an
acceptable range, say +/-30 per-
cent, then the results for the other
compounds are considered sus-
pect. Without surrogates, you
have no information as to
whether sample recovery was 10,
50, 100, or 200 percent. Quality
labs reanalyze samples if the sur-
rogates do not report within the
acceptable range.
It is best to require surrogates (at
least three) in all samples.
Require that surrogate recoveries
be reported on each analysis with
recovery acceptance limits simi-
lar to SW-846 methods.
FIGURE 3 TAGA vs. 8021 TCE Concentrations
tVi'n'i
_Ui5JJ
A.
w -40DQQ
•J
C
w -3UUUU
rn
9
inau
o •
1
^^
^-^
^^"
^^-^
_*•*" +
•,"
A comparison of on-site analysis of TCE by method 8021 from 60cc syringe sam-
ples to on-site analysis by the EPA TAGA mobile laboratory fromIL tedlar bag sam-
ples collected at an EPA test site in Indianapolis in August 2006, The correlation is
excellent (R2 = 0,998) and the values agree within analytical precision.
Calibration Acceptance Win-
dows. The standard TO-15
method calibration standard
recovery windows for some com-
pounds are larger than the
SW846 VOC methods and do not
meet some state soil-gas guide-
lines (e.g., Cal-EPA/DTSC). The
solution to this problem is to
ensure that the laboratory's cali-
brations fulfill any state require-
ments and require that the
continuing calibration analysis
be included in the lab report.
Lack of Certification (Beware
the "Wal-Mart" TO-15). As the
vapor-intrusion market in-
creases, so too do laboratories
offering TO-15, especially since
the analyses command three to
four times the price of soil and
water VOC methods. The TO-15
QA/QC criteria are less strin-
gent, and most states don't have
a certification for the method, so
it is very easy for a lab to quickly
set up and offer TO-15 analyses.
In other words, a lab can be
running the method with no reg-
ulatory oversight/checks on
whether the lab ever could or is
currently running the method
properly. I recently reviewed a
lab report in which a lab posted
its state certification number on
its TO-15 lab report even though
the state didn't certify the
method!
Strong Recommendation: To ensure
that you are getting a quality analysis
that can withstand both the regula-
tory and legal challenge, use only a
lab that can show it has upgraded the
method QA/QC as described above
and has a certification for the method
from either NELAC or a state agency.
Most high-quality laboratories have
upgraded the published TO-15
method to correct the issues raised
above.
The Ongoing Debate on VOC
Analysis by TO-14/15 vs.
Methods 8260 vs. 8021
This debate has been going on for
many years now and much confusion
and controversy still exist. There
have been two recent presentations
and published papers comparing
method TO-15 to method 8260, one
by Air Toxics (Hayes et al. 2005) and
one by my company (Picker, 2005).
Both studies reached the same con-
clusion: the methods match up quite
well for the common VOCs. How-
ever, the jury is still out regarding
naphthalene.
Figure 2 shows a comparison of
on-site analysis of TCE by method
802 lout of a tedlar bag to off-site
analysis by TO-15 out of a 6L Summa
canister from a U.S. EPA test site
(DiGiulio et al. 2006b). The correla-
tion is excellent down to values as
low as 2 ppbv.
Another comparison study was
done this August at a U.S. EPA test
-------
September 2006 • LUSTLine Bulletin 53
site. The values I measured on-site by
method 8021 from 60cc syringe sam-
ples matched analysis by EPA's
mobile Trace Atmospheric Gas Ana-
lyzer system from tedlar bags within
analytical error. (See Figure 3.) We
see similar agreement between on-
site analysis using method 8260 from
60cc syringes and samples collected
in 6L canisters and analyzed off-site
by TO-15.
These studies prove that the soil
and water VOC methods and the TO
methods give equivalent results
down to levels as low as 10ug/m3.
The decision on what analytical
method to use should be based pri-
marily on the required detection
level, expected contaminant level,
project scope, and cost.. .in this order.
The TO methods and hardware
(e.g., canisters, flow chokes, adsor-
bents) are designed for measuring
low levels in ambient air. They are
not designed for the high concentra-
tions we commonly see in soil gas.
Typical soil-gas concentrations at
LUST, dry cleaner, and industrial-
solvent sites are in the 100,000s to
1,000,000s of ug/m3. High concentra-
tion samples can lead to system car-
ryover, large dilutions, and
contaminated canisters, increasing
the potential for false positives,
raised reporting levels, and other
logistical problems, such as canister
management. Due to these potential
problems, programs using off-site
analysis should include canister trip-
blank samples and sampling equip-
ment blank samples.
In practice, a combination of
these methods is the best approach.
Most soil-gas risk-based screening
levels can be reached with all of these
methods. If expected values are high,
then the 8021 and 8260 methods are
more advantageous to use than the
ultra sensitive TO methods. If ex-
pected values and risk-based screen-
ing levels are low, then the TO
methods offer advantages. Further,
the 8021 and 8260 methods can be run
in the field, allowing real-time infor-
mation. Refer to Part 3 for a summary
table of the available methods.
The Need for TO-15 SIM for
Soil-Gas Samples
Too frequently, we get asked for TO-
15 SIM analysis for soil-gas samples.
TO-15 SIM (selected ion mode) is
used to get to lower detection levels
(< Iug/m3) than the typical TO-15
SCAN analysis (1 to 5ug/m3). But for
almost all compounds at any collec-
tion depth, including sub-slab, soil-
gas risk-based screening levels are
higher than 5ug/m3. So TO-15 SIM is
not necessary. Save your client (or the
state reimbursement fund) the extra
expense.
Experience Goes a Long Way
A final topic of concern among the
regulatory community is the spatial
variability of soil gas, both around
structures and under structures. In
many cases, soil gas, like soil, is not
homogenous. We have accepted this
fact about soil data and have adjusted
our site investigation methods, sam-
pling plans, and interpretation
accordingly. But for some reason, we
are not yet comfortable with soil gas
variability. Many of the interpreta-
tion problems I see people dealing
with come from a lack of data. It's
simply not possible to sort out the
variations with a handful of analyses
collected on a couple of occasions.
Since some variability is to be
expected, you need enough data to
give decent coverage near, around,
and under the receptor. I encourage
simpler collection systems that
enable higher production per day
(>20 samples per day) and the use of
less expensive analytical methods
(e.g., 8015, 8021, 8260) enabling more
analyses for the same cost. I also
encourage field analysis, when possi-
ble, as it allows for real-time deci-
sions on additional sampling needed
to sort out variations and recognition
of inconsistent data and tracer leaks
while you are still in the field.
The last important ingredient
needed for high-quality, cost-effec-
tive, and efficient vapor-intrusion
investigations is the experience of the
consultant and the subcontractors. I
advise consultants to use firms expe-
rienced in soil-gas collection and use
labs experienced in soil-gas analysis.
The stakes are simply too high with
vapor intrusion to do anything else. •
Blayne Hartman, Ph.D., is a partner of
H&P Mobile Geochemistry, a firm
offering on-site sampling and analysis,
soil-gas surveys, and vapor intrusion
services. He has provided training on
soil-gas methods and vapor intrusion to
over 23 state agencies, U.S. EPA
regions, ASTSWMO, the DOD, Dry
Cleaner Coalition, and numerous
consultants and stakeholders. This arti-
cle is excerpted from his vapor-intru-
sion training course.
For more information, contact Blayne
at bhartman® handpmg.com, or check
out his website at
www.handpmg.com.
Thanks to the following reviewers of
this article for their constructive com-
ments: Dom DiGiulio, Tamara Davis,
David Folkes, Larry Froebe, Ross Hart-
man, Tom McHugh, Bill Morris, James
Picker, Bob Sweeney, Rod Thompson,
and Janis Villareal.
References
Abreau, L. (2006). 3D Model Simulations and Impli-
cations to Near Building Sampling, Presentation.
EPA Vapor Intrusion Guidance Workshop. AEHS
conference, San Diego, CA, March 2006.
Davis, R. (2006). Vapor attenuation in the subsurface
from petroleum hydrocarbon sources, LUSTLine
#52, May 2006.
Denly, E., and H. Wang (circa 1995). Preparation of
Tedlar whole air standard with a Summa canister
for field VOC analysis. Conference details
unknown.
DiGiulio, D., C. Paul, R. Cody, R. Willey, S. Clifford,
R. Mosley, A. Lee, K. Christensen (2006a). Compari-
son of Geoprobe PRT and AMS GVP soil-gas sam-
pling systems with dedicated vapor probes in
sandy soils at the Raymark superfund site. USEPA-
ORD draft report, 6/5/06.
DiGiulio, D., C. Paul, R. Cody, R. Willey, S.Clifford, P.
Kahn, R. Mosley, A. Lee, K. Christensen (2006b).
Assessment of vapor intrusion in homes near the
Raymark superfund site using basement and sub-
slab air samples. EPA/600/R-05/147, March 20061
Hayes, H., D. Benton, S. Grewal, N. Khan (2005). A
comparison between EPA compendium method
TO-15 and EPA method 8260 for VOC determina-
tion in soil gas. Paper #46. AWMA symposium, San
Francisco, CA, April 2005.
Hayes, H., D. Benton, N. Khan (2006). Impact of sam-
pling media on soil gas measurements. Presenta-
tion, Vapor intrusion, the next great environmental
challenge, AWMA symposium, Philadelphia, PA,
January 2006.
Luo, H., P. Dahlen, P. Johnson, T. Creamer, T. Pear-
gin, P. Lundegard, B. Hartman, L. Abreau, T.
McAlary (2006). Spatial and temporal variability in
hydrocarbon and oxygen concentrations beneath a
building above a shallow NAPL source. Presenta-
tion, Remediation of Chlorinated and Recalcitrant
Compounds, Monterey, CA, May 2006.
McAlary, T., and T. Creamer (2006). The effects of
purge rate and volume on sub-slab soil gas sam-
ples. Presentation, Remediation of Chlorinated and
Recalcitrant Compounds, Monterey, CA, May 2006
McAlary, T. A., P. Dollar, P. de Haven, R. Moss, G.
Wilkinson, J. Llewellyn, and D. Crump, 2002. Char-
acterization of Vapour Transport in Fractured Rock.
Platform Presentation, Remediation of Chlorinated
and Recalcitrant Compounds, Monterey, CA, May
20-23, 2002.
McHugh, T. (2005). Results and Lessons Learned
Interim Report: Altus AFB Site, Environmental
Security Technology Certification Program
(ESTCP) Project ER-0423.
Ouellette, G. (2004). Soil vapor sampling and analysis
- lessons learned. Presented at DOE/PERF work-
shop, Brea, CA, January 2004.
Picker, J. (2005). A comparison of EPA methods 8260B
and TO14/15 for the analysis of VOCs in soil gas:
application to upward vapor intrusion studies.
Paper #41, AWMA symposium, San Francisco, CA,
April 2005.
-------
LUSTLine Bulletin 53 • September 2006
Are We to Become "CMWren of the Corn"?
The great civilizations of Mesoamerica - the Maya, Aztec, Toltec, Zapotec, Mixtec, Olmec, and others - could not have existed
without corn. It was basic in their diet and a revered crop. According to the Popol Vuh, the sacred book of the Maya,
humankind itself was made of corn. Some say that the god of corn was defenseless—a victim of birds, insects, and rodents—
who depended on the help of the god of rain for survival. Man, too, was an ally, making rituals and offerings to attract rain, weeding
out other plants that might crowd corn, scaring off predators, and giving life to the god by planting him. The Mayans were Children
of the Corn. They believed that they were created by gods who added their own blood to flour made from corn, and they worshipped the
tall grass that fed them. (1) Should we also be worshiping the corn from which we produce the ethanol that will keep our mighty steel
beasts running?
Popcorn, corn on the cob, corn
flakes, corn oil, corn chips, corn frit-
ters, corn tortillas, corndogs, corn-
bread - by golly, it's one of our staple
foods! Cows eat corn, pigs eat corn,
chickens eat corn—as a matter of fact,
we raise somewhere around 350 mil-
lion chickens per year in Delaware,
so that's a lot of chicken feed! And
ethanol is to be our great savior in
terms of reducing our dependence on
foreign oil. Food, feed, or fuel, that's
the dilemma. According to Lester
Brown, president of the environmen-
tal research group Earth Policy Insti-
tute, "This is shaping up as a
competition between the 800 million
people in the world that own auto-
mobiles and the two billion low-
income people in the world, many of
whom are already spending over half
their income on food." (2)
For the last 15 years, I've wanted
to see MtBE eliminated from gasoline
because of the impact that it can have
on groundwater. We've spent a small
fortune drilling replacement wells,
installing and maintaining carbon fil-
ters, and extending water lines to
provide safe drinking water for
Delaware residents. That's in addi-
20~
tion to the extra costs for more
complex, detailed groundwater
investigations, and extra expenses for
remediation.
The chemical and physical prop-
erties of MtBE make it something that
just doesn't belong in gasoline, pri-
marily because we seem to be unable
to keep the gasoline in the tanks
where it belongs. At times, MtBE has
confounded us because of its ability to
escape from seemingly tight tank sys-
tems and because it could race along
underground and manage to find its
way into the only well in the area.
Goodbye MtBE, Hello Ethanol
Finally, with MtBE bans passed in
more than 25 states, and with no
defective product lawsuit protection
in the 2005 Energy Policy Act
(EPAct), MtBE seems to have disap-
peared or is disappearing from gaso-
line in the United States. For the
states that were still using MtBE, the
transition to ethanol earlier this year
got off to a little bit of a rocky start.
When Delaware was notified about
the changeover date, we had a short
three or four months to educate our-
selves, our station owners and opera-
tors, and the public. Some station
owners heeded our advice about tank
cleaning, filters, and eliminating
water from their tanks, while others
chose to blow off our recommenda-
tions and take their chances.
Luckily, in Delaware we had no
reports of cars coughing to a halt
right after getting a tank full of E10,
although lately I've gotten a few "My
boat engine sputters and stalls," and
"My lawnmower hasn't run right all
summer." Right at the time of the
transition, we did have some short-
ages, with stations temporarily run-
ning out of certain grades of gasoline,
and there were long lines at the ter-
minals for a few days because USTs
were pumped lower than normal to
make the switch.
But, other than what has hap-
pened to the price of gas over the
past few months, we weathered the
changeover storm relatively well.
Lately, we've had all sorts of com-
plaints come in about the price of
gasoline, particularly when Delaware
residents notice that conventional gas
on Maryland's Eastern Shore, just a
stone's throw away, is running about
40 cents less per gallon!
-------
September 2006 • LUSTLine Bulletin 53
Mileage has also gone down,
with one resident claiming that his
vehicle has lost between 5 and 7
miles per gallon, although that num-
ber seems unlikely. I just calculated a
9.7 percent decrease in the gas
mileage for my car since ethanol-
blended gas was introduced to the
state, but that also corresponded to
the time that I started turning on the
air conditioner in the car more fre-
quently. I'll see if my mileage
improves in the fall when I'm not
using the AC. On the other hand, the
Valero refinery in Delaware tells us
that it is adding between 6 and 9 per-
cent ethanol, and is asking to drop
that to 5.6 percent. I'm kind of glad
that we're not using 10 percent!
Next, we'll see whether
our tank systems do a bet-
ter job of keeping the
ethanol in the tank any
better than they did for
MtBE. Ah yes, those mys-
terious leaks from suppos-
edly tight tank systems.
Will those funky "MtBE
only" hits start disappear-
ing from our monitoring
wells? At least in most
environments, any re-
leased ethanol should
degrade fairly rapidly.
In fact, in controlled
releases, researchers had to
sample quickly to find it at
all. However, the rapid
degradation of ethanol
may reduce the oxygen
levels in the soil and
groundwater and may also
deplete other electron recep-
tors necessary for biodegrada-
tion of other components in the
gasoline. The result may be longer
plumes of other gasoline con-
stituents, such as benzene.
It will be time soon to make the
decision as to which sites we need to
add ethanol to for the list of analytes
and whether our area labs are
equipped to do it. Maybe it will be
time to take a look at other analytical
parameters to see if more plumes are
developing larger anaerobic shadows
due to degradation of ethanol.
Corn: Food, Feed, or Fuel?
So, since the lion's share of ethanol in
the United States is made from corn,
let's talk about corn. Department of
Agriculture studies of ethanol pro-
duction from corn find that an acre of
corn yields about 139 bushels. One
bushel of corn will produce about 2.5
gallons of ethanol—about 350 gallons
of ethanol per acre. (3) The fuel value
of ethanol is lower than that of gaso-
line—1.4 gallons of ethanol in the
tank equals about 1 gallon of gasoline
in terms of energy output.
It also takes energy to pro-
duce ethanol (e.g., fertilizer,
harvesting, corn process-
ing). Some researchers
claim that the net
energy input of
ethanol is
ethanol creates more than 67 percent
more energy than it takes to make it.
(7) And other studies have come to
similar conclusions. The American
Coalition for Ethanol says that it
takes 35,000 BTUs of energy to turn a
bushel of corn into a gallon of
ethanol, and that a gallon of ethanol
contains at least 70,000 BTUs. (8)
Researchers at the Univer-
sity of Minnesota published a
study in the July 11, 2006
"Proceedings of the
National Academy of
Sciences" showed
that soybean
biodiesel
actually negative when all inputs are
included—ethanol takes more energy
to produce than it yields. According
to Ted Patzek, a University of Cali-
fornia, Berkeley, engineering profes-
sor, it takes six units of energy in
farming, distillation, and transporta-
tion to yield one unit of energy pro-
duced by ethanol in a car. (4,5) Patzek
and Cornell University's David
Pimentel calculated that about 70
percent more energy is required to
produce ethanol than the energy that
is actually in ethanol. (6)
Other studies have shown a pos-
itive net energy from the production
of ethanol. According to a 2004
USDA study, the production of
Ofe
returns 93 percent more energy than
is used to produce it, while corn grain
ethanol currently provides only 25
percent more energy. Their study
showed that dedicating all current
U.S. corn and soybean production to
biofuels would meet only 12 percent
of gasoline demand and 6 percent of
diesel demand. (9) There's no way
I'm going to try to analyze these
studies, but at least most recent stud-
ies indicate that you get more energy
out of the ethanol than you have to
put into its production.
The 55 million tons of U.S. corn
going into ethanol this year represent
nearly one-sixth of the country's
grain harvest but will supply only
• continued on page 22
21
-------
LUSTLine Bulletin 53 • September 2006
• Children of the Corn?
from page 21
3 percent of its automotive fuel. (10)
The U.S. has 73 million acres of corn
cropland. The entire U.S. corn crop
would make 25.5 billion gallons of
ethanol. We consume about 130 bil-
lion gallons of gasoline per year;
therefore using the entire U.S. crop of
corn to produce ethanol would still
meet only a small percentage of our
fuel needs. Some farmers are already
switching from other crops, such as
soybeans, to corn to meet the grow-
ing demand.
But wait - we must have been
growing those soybeans for some
purpose! What shortages will be cre-
ated by switching the crops? Say
goodbye to popcorn, corn on the cob,
and all those other favorites? We can
produce a little more ethanol using
agricultural wastes, such as the corn
stover, which is normally
plowed back into the land
and helps the soil fertility.
According to the U.S.
Energy Information
Agency, using the crop
residues from corn pro-
duction could produce
about 10 billion gallons of
ethanol —ethanol equiva-
lent to another 5 billion
gallons of gasoline.
what we get from corn stover, ethanol
from 300 million acres of switchgrass
could still not supply our current
gasoline and diesel consumption,
which is projected to double by 2025.
Energy Secretary Samuel Bod-
man has a goal of displacing 30 per-
cent of 2004 transportation fuel
consumption with biofuels by 2030.
To meet this goal, annual U.S. pro-
duction will need to increase from
about 4 billion gallons of corn-based
ethanol per year to about 60 billion
gallons per year from a variety of
plant materials. (12)
logen, one of the companies that
is working on the process has esti-
mated that a commercial-sized plant
capable of producing 40 million gal-
lons of ethanol per year would cost
$320 to $350 million to build, which is
roughly six times the cost of a corn-
based ethanol plant of the same
capacity. Obviously the economics
"// the national policy construct remains as it was through
the MTBE crisis—and if policy on a state level continues to
he reactive, inconsistent, and based on outdated
information or unsound science—a repeat environmental
policy performance is almost certain to occur."
conduct basin research on how to
release energy from plant fibers, or
cellulose. (14)
Tariffs and Credits
MTBE: Effects on Soil and Groundwater Resources
edited by James Jacobs, Jacques Guertin, and Christy Herron
Lewis Publishers, 2001, ISBN: 1-56670-553-3
The Great
Cellulosic Hope?
Cellulosic ethanol production is what
President Bush was referring to in his
State of the Union address when he
mentioned "cutting-edge methods of
producing ethanol, not just from corn
but from wood chips, stalks, or
switch grass. Our goal is to make this
new kind of ethanol practical and
competitive within six years."
Cellulosic ethanol production is
in the demonstration stage. It uses
enzymes to break down plants or
other raw materials, making it easier
to distill ethanol from them. This
process generates far more energy
with less energy input. So far, how-
ever, it is not economically feasible to
produce ethanol from cellulose (e.g.,
wheat stalks, wood chips, straw, saw-
grass). (11)
If we guesstimate that switch-
grass could produce 1,000 gallons of
ethanol per acre, more than twice
22~
need to change to make this a viable
process. logen's demonstration plant
produces about 1 million gallons of
cellulosic ethanol from wheat straw,
corn stalks, and switchgrass. (13)
The Department of Energy just
released a "research roadmap" for
developing new technologies into an
economically viable, carbon-neutral
transportation fuel. This report is
available at http://www.doegenom.es
tolife.org/biofuels/b2bworkshop.shtml.
On August 2, 2006, DOE
announced a plan to invest up to
$250 million, subject to Congressional
approval, over five years to spur U.S.
private industry and universities to
find new ways of creating motor fuel
from renewable sources such as soy-
beans, wood chips, and agricultural
cast-offs. The plan would set aside
$25 million a year for two separate
biofuel research facilities that would
Currently, the U.S. provides the
domestic ethanol industry with a 51
cent tax credit per gallon blended.
This credit lasts until 2010, unless it is
extended again, as it has been four
times previously. At the same time, it
slaps imported ethanol with a 54-
cent-a-gallon tariff. This prevents
refineries from buying it wherever
it's cheapest on the global market.
During the ethanol crunch that
we experienced around May this
year, when the petroleum companies
were coping with their voluntary
removal of MtBE and the EPAct
requirements to start using their
required amounts of renewable fuels,
there was talk in Congress of tem-
porarily lifting the tariff on
imported ethanol, so we
could import some cheaper
ethanol from Brazil.
Protests came largely
from the corn states, which
didn't want to lose the cap-
tive market for ethanol sales
just when they were in the
middle of a large expansion
in capacity. On the other
hand, many blame ethanol
shortages and high prices for
the increased gas prices that
we are experiencing. U.S.
distillers count on the tariff
to shield them from cheaper Brazilian
prices. Refiners imported 21,750 bar-
rels of ethanol in February 2006, or
enough to meet 6.7 percent of U.S.
demand (DOE).
Energy Policy Act of
2005 Requirements
EPAct took away the oxygenate man-
date for reformulated gasoline, while
at the same time, it gave us a Renew-
able Fuels Program, which is essen-
tially an ethanol mandate. The
Renewable Fuels Program mandated
the use of an increasing amount of
renewable fuel between now and
2012. (See Table 1.) Bonus points are
awarded for the use of cellulosic
ethanol - one gallon of cellulosic
ethanol or waste-derived ethanol is
considered to be the equivalent of 2.5
gallons of renewable fuel!
-------
September 2006 • LUSTLine Bulletin 53
TABLE 1
Renewable Fuel Requirements of
EPACT 2005 by Year
CALENDAR
YEAR
2006
2007
2008
2009
2010
2011
2012
APPLICABLE VOLUME
OF RENEWABLE FUEL
(in billions of gallons)
4.0
4.7
5.2
6.1
6.8
7.4
7.5
There are market guarantees for
ethanol for a while. Under EPAct, we
must increase the use of ethanol by
an average of 11 percent each year
through 2012. Today we use about
4.4 billion gallons of ethanol (3% of
all gasoline used). By 2012, we must
increase consumption to almost 5
percent. After 2012, the law no longer
mandates an 11 percent or better
boost in demand. Starting in 2013,
biofuel demand growth will need to
match that of gasoline, which DOE
forecasts will be about 1.1 percent a
year through 2020.
For distillers to expand rapidly
after 2012, the price will have to be
competitive with gasoline. And if the
tax credit isn't extended, ethanol will
lose that big advantage. According to
Bloomberg, for the past eight years,
ethanol has cost an average of 49
cents a gallon more than gasoline.
Last year, the federal tax break
brought the price of ethanol down to
32 cents a gallon less than gasoline
(Bloomberg.com, May 25,2006).
Chevron is investing in distil-
leries to guarantee steady supplies of
ethanol. Exxon Mobil Chairman, Rex
Tillerson, says "Pull the subsidies off
and see how much ethanol gets made
or used." Eric Holthusen, a Royal
Dutch Shell executive, considers
using food crops to make biofuels
"morally inappropriate" as long as
there are people in the world who are
starving. (15)
Ethanol should be produced
from renewable resources such as
wood chips and plant waste, rather
than the food crops that are typically
used to make the fuels. For now,
however, economics and legislation
drives the decisions.
Use and Prices
According to the Renewable Fuels
Association, between 85 and 95 per-
cent of ethanol in the U.S. is sold
under long-term contracts (6-12
months) negotiated between the
ethanol producer and the oil refiner
or gasoline blender. (16) Most of
these contracts are "fixed price."
Some contracts may be pegged to the
price of gasoline (usually at a dis-
count to gasoline), meaning the price
of ethanol will change as the gas
price changes, but the percentage
impact will remain constant. (17)
According to the JJ&A Fuel-Blend-
stock Report (6/16/06) most of the
long-term contracts were established
"well before the current short-term
spot price insanity developed."
According to JJ&A, contracted
ethanol is selling between $1.80 and
$2.40 per gallon, once the tax incen-
tive is figured in. Spot market prices
were as high as $5.75 near the end of
May. Many of the spot market pur-
chases have been between refiners,
when a particular refiner/blender
has been caught short and will pay
almost anything to cover a require-
ment. (See Table 2.)
tion, including the Maryland Grain
Producers Association. (19) One or
two plants are proposed for
Delaware. New Jersey has at least
one plant proposed—Garden State
Ethanol in Cumberland County. The
New Jersey Legislature has qualified
the plant to receive a $1 million fed-
eral grant. (20) Pennsylvania has a
couple of plants proposed in the
southeastern part of the state, but I've
been reading a lot of NIMBY stories
about proposed locations.
One article that I read about the
New Jersey plant is that they will use
corn from New Jersey growers, and
imports from Maryland and Dela-
ware. Maryland proposes imports
from nearby states, as does Delaware.
We can't all produce ethanol from the
same bushels of corn!
The American Coalition for
Ethanol recently produced the "ACE
Ethanol Handbook," a state-by-state
reference guide that provides infor-
mation about U.S. ethanol produc-
tion, marketing, and use, public
policies, and regulations that states
have adopted affecting ethanol pro-
duction and use, and state laws
requiring ethanol use (available at
TABLE 2
U.S. Fuel Ethanol Production/Demand for April 2006
(mg = million gallons; b/d = barrels
Fuel Ethanol Production
Fuel Ethanol Use
Fuel Ethanol Stocks
Fuel Ethanol Exports
Fuel Ethanol Imports
per day)
363.5 mg
396.2 mg
381. 7 mg
Omg**
32.6 mg*
289,000 b/d
302,000 b/d
31 .4 days of reserve
n/a
n/a
* Source: U.S. International Trade Commission.
**Jim Jordan and Associates.
http://www.ethanolrfa.org/industry/statistics/ttB
New Ethanol Plants are
Springing Up Everywhere
Lots more ethanol plants are coming
on-line. Currently, there are 101 oper-
ating ethanol biorefineries nation-
wide, producing 4.8 billion gallons
annually. There are 34 ethanol
refineries and 7 expansions under
construction with a combined annual
capacity of more than 2.2 billion gal-
lons. (18) There are even plans in the
works for ethanol plants in the
Northeast, where much of the
ethanol demand currently is located.
In Maryland, at least three differ-
ent groups are looking at construc-
http://www.ethanol.org/). The Hand-
book provides figures about the corn
production for each state, the gaso-
line consumption based on 2004 fig-
ures, and the potential ethanol use if
all gasoline sold in the state con-
tained 10 percent ethanol.
I've calculated the ethanol pro-
duction in millions of gallons per
year that could be produced if all
corn grown in the state was used to
make ethanol. We're coming up a lit-
tle short, and now we're also sup-
posed to be adding E85 stations as
well. I don't know how the volume of
distillers mash that is a by-product of
• continued on page 24
~23
-------
LUSTLine Bulletin 53 • September 2006
• Children of the Corn?
from page 23
the ethanol production compares
with the volume of chicken feed
available if the corn is not used to
produce ethanol, but I think we may
have a few chickens going hungry.
One of the proposals for an
ethanol plant in Delaware is for a
plant with an annual ethanol produc-
tion of 100 million gallons. To make
that amount of ethanol would require
an input of corn of about 36 million
bushels or 1.5 times Delaware's cur-
rent corn production (their estimate
for gallons per bushel is higher than
USDA estimates). I guess we'll have
to buy some from our neighbors. Oh,
but wait—they were going to buy
some corn from Delaware to feed
their proposed new ethanol plants! If
we can find enough corn to feed the
plants, at least we'll have plenty of
chicken feed from the distillers mash
that is a co-product of making
ethanol, and enough CO2—, also a
byproduct, to carbonate lots of drinks.
If we take all of the corn grown in
the states (287,977,000 million
bushels—see Table 3), we should be
able to produce about 800 million
gallons of ethanol. The ethanol
demand for these states, if all the
gasoline used is E10, means that we
need about 1,800 million gallons of
ethanol. And we're starting to pro-
duce all those flex-fuel vehicles that
can run on E85! I guess we're still
going to be buying from the Mid-
west. New Jersey will help. They
have plans for a waste-to-ethanol
plant that will produce about 55 mil-
lion gallons of ethanol per year from
old tires. (21) I'm sure we'd have
some scrap tires to sell them.
It's becoming more economical
to produce ethanol—distillers now
recycle the heat and steam used in
fermentation and distillation for pro-
duction of more fuel. The overall cost
of production is less than half of what
is was in 1986. Newer plants also use
hardier yeasts, boosting the amount
of ethanol that can be produced from
each bushel of corn. One refiner in
California says West Coast demand
is now so high that it is cheaper to
bring in trainloads of corn from the
Midwest than trying to find spare
tankers to haul finished ethanol from
the same region. It's logical that the
most viable ethanol industry is where
24~
TABLE 3
Corn Production, Gasoline Consumption, and Potential Ethanol Use and
Production for EPA Region III States Plus New Jersey
STATE
Delaware
Maryland
New Jersey
Pennsylvania
Virginia
West Virginia
District of
Columbia
TOTAL
Estimated
Total Corn
Production
in bushels
(2004)
23,256.000
65,025,000
10,296,000
137,200,000
52,200,000
0
0
287,977,000
Gasoline
Consump-
tion
(2004)
0. 431 bgy
2.7 bgy
4.4 bgy
5.3 bgy
4 bgy
0.86 bgy
0.1 6 bgy
17.851 bgy
Ethanol
Production
Incentives
No
Yes
No
Yes
No
No
No
Ethanol Use
Volume
Potential
(based on 10%
ethanol blend in
2004 gasoline
consumption)
43 mgy
286 mgy
439 mgy
530 mgy
402 mgy
85 mgy
16 mgy
1801 mgy
Ethanol
Production
in gallons
(based on 1
bushel of corn
producing 2.5
gallons of
ethanol)
58 myg
163 mgy
25 mgy
343 mgy
131 mgy
0
0
720 mgy
http://www.ethanol.org/EthanolHandbook2006.pdf.pdf
you've got the greatest supply of raw
materials and demand for the prod-
uct, which keeps prices down.
"Poop to Pump" Ethanol
Panda Ethanol just announced plans
to build an ethanol plant in Hereford,
Texas that will be fired by mountains
of manure. Panda's CEO said "We've
located a project in what I would call
the Saudi Arabia of manure." The
plant will gasify 1 billion pounds of
manure a year to make 100 million
gallons of ethanol. The plant will also
fuel more than 90 percent of its own
energy needs by heating up manure
until it releases methane, which it
will then burn to make steam to fuel
the plant. Ash from the process can
be used to make cow bedding and
cement. They also hope to build a
plant using the same technology in
Kansas. The CEO did warn, however,
that when it comes to harvesting
manure, timing is important. "It can't
be too fresh and it can't be too old."
(22)
E85, Flex-Fuel Vehicles,
and CAFE Standards
One drawback of ethanol is that a
gallon of ethanol generates only
about 75 percent as much power as a
gallon of gasoline. It takes about 1.4
gallons of E85 to get as far as one gal-
lon of gasoline. That means that E85
would have to be about 25 percent
cheaper per gallon than gasoline to
be a bargain for consumers.
Federal tax subsidies are avail-
able to service stations that install E85
pumps, and some states are also sub-
sidizing installation. Rules recently
published by the IRS allow for a 30
percent federal income tax credit, up
to $30,000 per property, for the instal-
lation of fuel pumps that dispense
alternative fuels. Some states are also
subsidizing E85 prices. GM has its
advertising campaign "Live Green,
Go Yellow" to push the sale of E85-
compatible vehicles. (23)
Ever wonder why the big
automakers are starting to churn out
flex-fuel vehicles, even though most
of the E85 pumps are still clustered in
the Midwest? The answer is the
mandatory Corporate Average Fuel
Economy (CAFE) standards. Federal
law requires that the cars an auto-
maker offers for sale average 27.5
mpg; light trucks must achieve 22.2
mpg. Failure to do so can result in
substantial fines. Relief, however, is
available to manufacturers that build
E85-compatible, or flex-fuel vehicles.
-------
September 2006 • LUSTLine Bulletin 53
For CAFE calculations, the
government only counts the 15
percent of E85 that is gasoline. By
not counting the ethanol, which is
the other 85 percent, you get a sev-
enfold increase in the rating. The
calculations assume that you
would fill up with E85 half of the
time and gasoline the other half.
The EPA window sticker mileage
rating for a Chevy Tahoe flex-fuel
vehicle is 20.1 mpg. Using the cal-
culations allowed for flex-fuel
vehicles, the CAFE mileage rating
is 33.3 mpg. (24) Running on E85,
the Tahoe should actually get
between 14 and 15 miles per gallon.
Ever wonder why we don't
see smaller, fuel-efficient vehicles
available as flex-fuel vehicles? It's
the larger vehicles with lower
mileage ratings that are more readily
available as flex-fuel vehicles. There
are approximately five million flex-
fuel vehicles on the road today in the
U.S. It's estimated that only about 1
percent of them have ever had E85 in
their gas tanks.
Almost all new vehicles in Brazil
can run on E85. The figures that I've
seen show that it costs about $100 to
$200 more per vehicle to make a car
compatible with E85. Why don't we
require it, instead of giving out all
these credits? In Brazil, stations carry
gasoline, gasohol (E10), E24, and E85.
If you have a flex-fuel vehicle, you
can fuel your vehicle with whatever
makes sense economically.
Earlier this year, the Big Three
U.S. automakers said they plan to
more than double annual production
of vehicles capable of running on
renewable fuels to two million cars
and trucks by 2010. In a letter to
members of Congress, the chief exec-
utives of the Big Three stated "Our
hope is that with this commitment,
fuel providers will have even more
incentive to produce ethanol and
other biofuels and install pumps to
distribute them." The majority of the
vehicles available now as flex-fuel
versions are the gas-guzzling SUVs
and trucks, not the gas-sipping
smaller vehicles. (25) Will there be
any flex-fuel compacts or subcom-
pacts available by 2010?
And Back to LUST...
Section 1505 of the EPAct concerns
the public health and environmental
ALCOHOL
6AMMJM£
•*•
impacts of fuels and fuel additives.
Within two years of signing of the
Act, studies are to be conducted to
determine possible effects on public
health, air quality, and water
resources of the increased use of
MtBE substitutes such as ETBE,
TAME, DIPE, TEA, other ethers and
heavy alcohols, ethanol, iso-octane,
and alkylates. So, we'll have two
years, at a minimum, to wait for
One drawback of ethanol is that a
gallon of ethanol generates only
about 75 percent as much power as
a gallon of gasoline. It takes about
1.4 gallons of E85 to get as far as
one gallon of gasoline. That means
that E85 would have to be about
25 percent cheaper per gallon than
gasoline to be a bargain
for consumers.
information from which we can gen-
erate action levels and cleanup num-
bers for these chemicals.
Notice, this list doesn't include
information for MtBE, which, while
disappearing from most gasoline, has
yet to disappear from the soil and
groundwater at release sites. We still
haven't seen the U.S. EPA risk assess-
ment that cites MtBE as a "likely"
human carcinogen, linking MtBE to
cancers such as leukemia and lym-
phoma that have toxicological
endpoints similar to known car-
cinogens, such as benzene and
butadiene. The document was
evidently completed some time
in 2004, circulated through EPA
for review, and approved by the
Office of Research and Develop-
ment's National Center for Envi-
£ ronmental Assessment. It still
needs signoffs by other EPA
• divisions and external review.
(26)
I know people are busy. So
the document's been sitting in
someone's in-box for the last
two years and is not a priority. I
do know that during last year's
EPAct hearings, some members
of Congress asked to see the
report. News reports at the time
said that they didn't get to see it. So
the states have each had to generate
some sort of action levels and
cleanup numbers for a chemical for
which we are lacking health data.
Are we erring on the conservative
side, costing money for cleanups that
are unnecessary, or are we erring in a
manner that may be impacting peo-
ple's health?
I'm sitting on a few sites where I
have sky-high levels of TEA in moni-
toring wells and levels in potable
wells that I don't know whether or
not should be of concern. What about
the TAME? I have a few sites where
the TAME concentrations rival those
of the MtBE concentrations. How
much cleanup is necessary?
So, sometime around two years
from now, we may have some num-
bers for ethanol, and for the other
chemicals that we've been dealing
with for years. Thank you for that,
Congress. Now, if you could only
appropriate a little more of the
money you authorized in the Energy
Bill...
As today's oil prices soar and
ethanol becomes liquid gold, ethanol
will soon consume more than 40 per-
cent of Minnesota's corn crop. If the
plants currently on the drawing
board are built, that will rise to 50
percent or more. In Iowa, there are 55
ethanol plants open or proposed,
and, according to Iowa State Univer-
sity economist Bob Wisner, if all
those plants are built,".. .it would use
virtually all of the Iowa corn crop."
(27)
• continued on page 27
~25
-------
LUSTLine Bulletin 53 • September 2006
New Hope for Hurricane Fuel-Availability
Problems...Portable Electric Pumps for
UST Systems
by Marshall Mott-Smith
In summer 2004, Hurricane Ivan
gave Florida a reality check on
how major storm damage can
adversely affect fuel availability to
consumers, government, and com-
merce. Ivan destroyed and damaged
bridges, large AST storage and distri-
bution facilities, and UST facility
infrastructure. Electric power was
out for several weeks in some areas.
The day after the storm, it became
painfully clear to residents in storm-
damaged areas of northwest Florida
that the only fuel they would have
for the near future would come from
the product remaining in their vehi-
cle gas tanks or portable gasoline
containers.
In addition, the remaining fuel
stored in USTs at retail petroleum
marketing facilities was not available
since there was no electric power to
pump it out. On top of that, no fuel
could be delivered to the hurricane-
ravaged coastal areas because of
damage to bridges and the trans-
portation network. However,
because Florida's Emergency Re-
sponse Program is experienced, well
funded, and well managed, the state
responded quickly and efficiently to
26~
these problems; nevertheless, there
was a period of hardship and incon-
venience for the local residents.
Two months after Hurricane
Ivan, I attended the annual Petroleum
Equipment Institute Trade Show to
keep up with the latest advancements
in technology. While visiting at a
booth with portable electric pumps
designed for ASTs, I had an idea that
the concept could work for USTs as
well. I spoke with the exhibitor, Great
Plains Industries, Inc. (GPI), and they
Test run of GPI's portable electric pump system unit.
agreed that the concept was worth
pursuing. I obtained their product lit-
erature and contact information and
followed up several weeks after-
wards. However, I had to put the
effort on the back burner in the face of
higher priorities with tanks program
management issues.
One Year Later...
Hurricane Wilma hit Florida...right
on the heels of Hurricanes Katrina
and Rita which had crippled one-
third of our nation's fuel-refining
capacity and significantly disrupted
petroleum distribution in Florida.
Wilma was projected to hit Florida as
a Category Three near Naples and
exit the east coast as a Category One.
But the projections were inaccurate—
Wilma retained her Category Three
status all the way across the state to
the Atlantic Ocean. Once again,
Florida faced serious problems with
interruption of electric power and
fuel availability. Although most had
power within one week, some facili-
ties were without power for nearly
two weeks.
-------
September 2006 • LUSTLine Bulletin 53
Components of GPI's portable electric pump system.
Shortly before Wilma hit, I was
asked to help with the State Emer-
gency Response Team's Fuels Desk
(known as ES 12). ES 12 manages the
pre-storm positioning of fuel tankers
for first responders and other emer-
gency response personnel and helps
to match up critical-need facilities
such as nursing homes, assisted-liv-
ing facilities, and hospitals with
petroleum distributors.
As Wilma hit, it became clear that
we needed a way to increase fuel
availability. In addition to the critical-
need facilities, we were swamped
with calls from consumers who
couldn't get fuel for their vehicles
and electric generators. There was an
immediate and pressing need for the
UST-pumping system we had con-
templated the previous year.
Fortunately, Great Plains Indus-
tries had not shelved their plans and
were able to respond quickly to our
urgent requests for a portable electric
pump system that could be used to
pump fuel from USTs into vehicles.
Three days after Wilma made land-
fall, the Florida Department of Envi-
ronmental Protection (DEP) placed
an order for 30 of the prototype units.
Shipping took several days, and com-
munication problems in the affected
area slowed us down. By the time we
got the units operational, the need for
them had diminished.
During the winter, we worked
with GPI to refine the prototype and
make improvements, particularly
with ease of use, cleanup, and safety
considerations. The new units are
portable, relatively lightweight, and
easy to use. The
unit includes a
meter that can
accurately quantify
product dispensed
for inventory needs
and a filter for
ensuring fuel qual-
ity. There is also a
six-inch steel offset
fitting at the bot-
tom of the suction
hose to prevent
sludges and tank
water bottoms
from being
pumped into the
vehicle. The 20-foot
suction hose is
more than sufficient
to reach the bottom
of large-diameter USTs. Power is
supplied through a 15-foot power
cable with battery clips to the 12-volt
battery of a nearby vehicle or the
vehicle receiving fuel.
After conducting several success-
ful field tests, and with a set up time
of less than five minutes, DEP
decided to exchange its 30 prototype
units for the newer improved pump
systems. We now have ten of the
newest model portable electric
pumps. Most likely, the units will be
used for county and local govern-
ment fleet management facilities
where qualified personnel can oper-
ate the systems, but we know of sev-
eral retail facilities that plan to use
the units in a full-serve application.
We plan to deploy six of the units to
the DEP District Offices and retain
four in Tallahassee to be predeployed
before storm landfall for immediate
use in affected areas.
We have notified the County
Emergency Operations Centers to
make them aware of these assets, and
we will coordinate with the districts
on pre-hurricane deployment and
posthurricane return of the pumps.
Next time Florida is affected by a
hurricane like Ivan or Wilma, we will
be better prepared to assist govern-
ment and the public with posthurri-
cane fuel-availability problems. •
Marshall Mott-Smith is Administrator
of the Florida Department of Environ-
mental Protection's Storage Tank Reg-
ulation Section. He can be reached at
Marshall.Mott-Smith@dep.state.fl.us
• Children of the Corn?
from page 25
We need to be thinking on a
more global level. When MtBE was
added to gasoline to help decrease air
pollution, there was little to no
consultation with water programs to
see what the ramifications would be.
The "butterfly effect" is a Chaos The-
ory phrase that explains how small
changes in the initial condition of a
system can cause a chain of events
leading to large-scale phenomena.
Had the butterfly not flapped its
wings when we decided to make
MtBE a major fuel component, the
trajectory of the great global system
might have been vastly different. As
we move toward an ethanol econ-
omy, we need to be looking beyond
the narrow view of just putting fuel
into our vehicles. •
References
1. www.pbs.org/wnet/nature/spirits/ktml/ mayabody-
mayaMmi
2. www.earth-poiicy.org/
3. www.eartli-policy.org/Updates/2006/
Update55_data.htm
4. Patzek, T.W., 2004, Crit. Rev. Plant Sci. V. 23,
519-567
5. http://petroleum.berkele\/.edu/patzek/index.htm
6. Pimentel, D., and T.W. Patzek, 2005, Nat.
Resources Research. V. 14, 65-76.
7. www.usda.gov/oce/reports/energy/net_energy_
balance.pdf
8. www.ethanoi.org/documents/Ethanoif'AOs_OOO.pdf
9. www.pnas.org/cgi/content/short/103/30/11206
10. www.earth-poiicy.org/Updates/2006/ Update55.htm
11. www.ethanoi.org/documents/6-05_
Cellulosic_Efhanol.pdf
12. www.ens-newswire.com/ens/jul2006/
2006-07-07-01.asp
13. www.iogen.ca/news_events/iogen_news/
2006_02_13_Eiorefinery_Ereakthrough.pdf
14. www.planetark.com/dailynewsstory.cfm/
newsid/37504:/newsDate/3-Aug-2006/story.htm
15. www.pianetark.com/avantgo/daiiynewsstory.
cfm?newsid=37152
16. www.grainnel.com/info/arliclesjprinl.
html?lD=351320
17. www.ethanolrfa.org/industry/statistics/ttA
18. www.ethanoirfa.org/industry/iocations/
19. www.baltimoresun.com/news/local/
bal-te.md.ethanol20jun20,l,1057950.story
20. www.newsdesk.org/archives/000591print.php
21. www.world-wire.com/news/0606200001.html
22. www.planetark.com/dailynewsstory.
cfm/newsid/374,77/newsDate/2-Aug-2006/story.'htm
23. www.gm.com/company/oniygm/
24. www.caranddriver.com/features/11174:/tech-stuff-
ethanol-promises.html
25. www.fueleconomy.gov./feg/byfueltype.'htm
26. www.ewg.org/issues/mfbe/20050711/
index.php?print_version=l
27. www.twincities.com/mid/twincities/business/
14916259.htm? template=contentModules/
printstory .jsp
~27
-------
LUSTLine Bulletin 53 • September 2006
What About Those Temporarily Closed Tanks?
Are We Creating a New Generation of
Forgotten Tanks?
by June Reilly
Rscently, a flurry of e-mails cir-
culated among various state
LIST program folks dealing
with the question of what to do with
tanks that meet post-1998 perfor-
mance standards but that have been
placed into temporarily out-of-service
(TOS), or temporary closure, status
for one reason or another. With this
discussion on TOS tanks, comes the
question of how closely we are keep-
ing track of these tanks—whether we
are in effect creating a new generation
of out-of-service tanks.
It's not difficult to see how a state
could lose track of some of these TOS
tanks. Take this not-unusual sce-
nario—a small country store closes,
and the property is on the market for
several years. The owner of a gas sta-
tion dies, and settling the estate takes
on a life of its own. Finally, when the
property eventually changes hands
and reopens for business, the new
business does not sell gasoline, and
the temporarily closed tanks remain
in the ground.
Every program in the country
has gone through the nightmare of
discovering tanks that were aban-
doned prior to the inception of
regulatory/permit programs. One
advantage to today's temporarily
closed tanks is that they have been
taken out of service legally and that
through this process the state UST
programs know where they are
located thanks to the notification
requirements. But that still leaves us
with a crop of these tanks. So what
happens now?
It is worth taking a look at the
federal requirements for temporary
closure (40 CFR Subpart G, § 280.70)
so we can keep in mind what is
expected at the minimum:
(a) When an UST system is tem-
porarily dosed, owners and opera-
tors must continue operation and
maintenance of corrosion protection
in accordance with § 280.31, and
any release detection in accordance
28~
with Subpart D [release detection],
Subparts E [release reporting, inves-
tigation, and confirmation] and F
[release response and corrective
action for UST systems] must be
complied with if a release is sus-
pected or confirmed. However,
release detection is not required as
long as the UST system is empty.
The UST system is empty when all
materials have been removed...so
that no more than one inch of
residue, or 03 percent by weight of
the total capacity of the UST system,
remain in the system.
(b) When an UST system is tem-
porarily closed for 3 months or more,
owners and operators must also
comply with the following require-
ments:
(1) leave vent lines open and func-
tioning; and
(2) cap and secure all other lines,
pumps, manways, and ancillary
equipment.
(c) When an UST system is tem-
porarily closed for more than 12
months, owners and operators must
permanently close the UST system if
it does not meet either performance
standards in § 280.20 for new UST
systems or the upgrading require-
ments in § 280.21, except that the
spill and overfill equipment require-
ments do not have to be met. Owners
and operators must permanently
close the substandard UST systems
at the end of this 12-month period in
accordance with §§ 280.71-280.74,
unless the implementing agency pro-
vides an extension of the 12-month
temporary closure period. Owners
and operators must complete a site
assessment in accordance with
§ 280.72 before such an extension
can be applied for.
Where Do the States Stand
with Temporarily Closed
Tanks?
The e-mail discussion was timely for
states such as Vermont and Oregon,
whose UST programs are dealing
with the question of whether tem-
porarily closed tanks have adequate
financial responsibility mechanisms.
The federal rule releases an owner or
operator from maintaining financial
responsibility "after the tank has
been closed, or, if corrective action is
required, after corrective action has
been completed and the tank prop-
erly closed." So until the tank is
permanently closed, financial respon-
sibility must be maintained. But
many insurance companies will not
continue insurance at all on out-of-
service tanks, or if they do, coverage
is limited to only one year. This
creates a dilemma for owners and
operators
Some states have realized that
most post-1998 TOS tanks are not
coming back into service and need to
be permanently closed, so they are
addressing this requirement in their
next rule change. Louisiana adopted
rules in May 2005 that allow
upgraded tanks to remain in tempo-
rary closure for 24 months; after that
the owner/operator must either per-
manently close them or perform an
environmental site assessment.
Wyoming is considering changing its
rules to require an environmental site
assessment after three years if a tem-
porarily closed tank not removed.
How adequately are states track-
ing the status of TOS tanks with
regard to maintaining performance
standards? For example, Wisconsin
ordered the closure of a number of
tanks when it was discovered that the
power had been shut off by the local
utility, thereby disabling the
impressed current system.
Most states require annual tank
fees to be paid on temporarily closed
tanks if owners want them to remain
in their state fund for financial
responsibility. The requirement to
pay the fee has promoted the
removal of tanks in many cases. Prior
to this year, Vermont did not collect
the annual tank assessment on TOS
-------
September 2006 • LUSTLine Bulletin 53
tanks. However, this year we have
notified temporarily closed tank
owners of their financial responsibil-
ity requirement and will be billing
them the annual tank assessment. So
far, the notice of assessment has
caused three tank owners to remove
their tanks, and one owner, following
certification by a tank contactor as
being compliant with the rules,
brought his tank back into service!
Based on the e-mail responses, it
appears that many state UST pro-
grams are tracking how long tanks
have been in TOS mode. If owners
and operators of out-of-service tanks
are kept aware of their responsibili-
ties, they are likely to make the deci-
sion to either permanently close their
out-of-service tanks or put them back
into service—after a few years, regu-
latory requirements become a cost
burden with no financial return.
Owner/operators are therefore likely
to make the decision to close their
tanks. However, many states are con-
sidering making rule changes to
require the owner to close these tanks
permanently. If a tank has been
closed for more than five years—
maintained or not—chances are that
it won't ever be going back into ser-
vice. And the environment has no
need to have it in the ground.
Vermont, like most other states,
is still dealing with abandoned tanks
that were never notified to the state.
The Vermont Department of Envi-
ronmental Conservation uses San-
born Fire Insurance maps as a
supporting historical source for vali-
dating the suspected location of old
buried tanks discovered during prop-
erty transfers, redevelopment of
property, and installation of sewer or
water lines. To avoid another genera-
tion of abandoned tanks, tracking
TOS tanks until their permanent clo-
sure is a must. And there is no
excuse, because by the notification of
tanks states know where they are. •
June Reilly is assistant UST Coordina-
tor with the Vermont Department of
Environmental Conservation. She can
be reached at 802 241 3871 or e-mail
june.reilly@state.vt.us. Special thanks
to Ted Unkles and Marc Roy.
from Robert N. Renkes, Executive Vice President, Petroleum Equipment Institute
Equipment Compatibility and the New Fuels
We have known for some time that many alter-
native fuels do not have the same compatibil-
ity characteristics as conventional fuels when
they are transported, stored, metered, and dispensed.
We know, for instance, that certain metals are not com-
patible with some ethanol blends. We are also aware
that some nonmetallic materials may degrade when
placed in contact with ethanol.
Biodiesel fuels also require special storage and
handling requirements. While biodiesel is commonly
mixed with ordinary petroleum diesel to make bio
blends like B5 or B20, straight, nonmixed biodiesel
(B100 or "neat" biodiesel) can also be burned as fuel in
diesel engines. Some studies suggest that compatibility
problems increase as the percentage of biodiesel in the
diesel increases.
The problem until now has been finding a reliable
source for which everyone involved with these alterna-
tive fuels (owners/operators, regulators, installers and
equipment providers) can obtain the latest and most
accurate information on equipment compatibility.
The Petroleum Equipment Institute (PEI) has
recently begun an ambitious project to provide an
online database of ethanol- and biodiesel-compatible
equipment. The information, available under the Alter-
native Fuels section of PEI's website, www.pei.org, is
searchable by manufacturer and general item descrip-
tion. Manufacturers are responsible for providing the
list of equipment and the particular fuel(s) with which
the component is compatible (B5, B20, B100, E10, E20,
E85, and E100). The manufacturer also identifies the
verification process used to prove that the equipment
is indeed compatible with those fuels.
We anticipate that, in time, the following equipment,
components and materials will be identified as ethanol
and/or biodiesel compatible:
• Automatic shutoff and overfill valves
• Tanks
• Submersible pumps
• Line-leak detectors
• Leak detection equipment
• Spill containment and sumps
• Piping
• Sealants/adhesives
• O-rings and gaskets
• Flex connectors
• Filters
• Dispensers and internal components
• Hanging hardware
We anticipate that this equipment matrix will be a
dynamic reference document, with changes constantly
being made as manufacturers confirm compatibility and
list their products. Questions and/or comments about
the PEI alternative fuels website in general or the equip-
ment compatibility guide in particular should be
directed to Allison Monroe (amonroe@pei.org) of the
PEI staff at (918) 494-9696. •
29
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LUSTLine Bulletin 53 • September 2006
-)f?fca//y Speaking
by Marcel Moreau
Marcel Moreau is a nationally
recognized petroleum storage specialist
whose column, Tank-nically Speaking,
is a regular feature of LUSTLine. As
always, we welcome your comments and
questions. If there are technical issues
that you would like to have Marcel
discuss, let him know at
marcel.moreau@juno.com
BEWARE THE UNINTENDED CONSEQUENCES OF MANIFOLDING
It used to be that connecting tanks
containing the same product
together to increase storage capac-
ity was a simple matter. A pipe was
run from the bottom of one tank, out
the top of the tank, over to the second
tank, and back down through the top
to the bottom of the second tank. In
the days of suction-pumping sys-
tems, this was the only practical way
to connect two tanks. The piping was
called a siphon, or sometimes a
siphon bar, and the arrangement was
called "tank manifolding."
The advent of submersible
pumps did little to change the basic
siphon arrangement, although other
alternatives also became feasible. For
example, it was now possible to
install submersible pumps in each
tank and connect the product piping
coming out of the pumps together
using a "T" fitting, so two tanks
could be used to feed a single prod-
uct line out to the dispenser islands.
This arrangement is called a "piping
manifold" to distinguish it from a
tank manifold. With a piping mani-
fold, a siphon connection between
the tanks is no longer needed.
With the advent of tank gauges,
we have entered an era when the
electronic intelligence of the tank
gauge can be used to control the
operation of the submersible pump.
The option of having the ATG control
the pump now offers other possibili-
ties for managing product in multiple
tanks. Two pumps can be installed
into two tanks storing the same prod-
uct as before, but now the pumps can
be controlled individually and auto-
matically via the tank gauge. This
offers multiple possibilities.
Instead of having the two pumps
connected to a piping manifold oper-
30~
ating together all the time, the two
pumps can be used in an alternating
fashion. For example, pump #1 might
operate to supply product to a cus-
tomer, and pump #2 can be used for
the next customer, pump #1 for the
third, and so forth. This allows both
tanks to be drawn down more or less
at the same rate.
Another way to use the ATG with
the pipe manifold is to have one
pump be the primary pump and the
second pump the backup. In this
mode, one pump is used continu-
ously until the product level in the
tank is low, then the tank gauge shuts
down the first pump and transfers the
pumping activity to the second
pump. When the first tank is refilled,
the pumping activity switches back to
the first pump. In this type of arrange-
ment, the second tank serves as a
reserve or backup supply of product.
What Effect Has Manifolding
Had on Leak Detection?
The traditional tank siphon connec-
tion increases the difficulty of tank
leak detection because of the greater
fluctuation in liquid level when small
amounts of product flow between
tanks through the siphon during test
periods. This complicates the issue of
determining whether the liquid level
is changing due to a leak. Also, the
leak rate in each tank of a two-tank
manifold is half the actual leak rate,
making it necessary for the leak-
detection system to find smaller
leaks. For example, in a two-tank
manifold, if one tank is leaking at 0.2
gph, the leak rate measured in each
tank is 0.1 gph, requiring an
increased sensitivity on the part of
the leak detection equipment.
Piping manifold systems in
which both pumps operate simulta-
neously cause problems with
mechanical line-leak detectors
because the simultaneous operation
of the two pumps means that the
detectable leak rate is doubled. (See
LUSTLine Bulletin #29, "Of Blabber-
mouths and Tattletales, The Life and
Times of Automatic Line-Leak Detec-
tors," for a description of the opera-
tion of MLLDs and the NWGLDE
article on page 33 of this issue.)
Piping manifold systems in
which pumps are operated individu-
ally do not have the issue of line-leak
detectors not detecting the required
size leak. However, these systems
have another potential environmen-
tal hazard that must be addressed.
The Potential Hazard
One of the features common to all
submersible pumps is a check valve
that is present in the pump head (also
known as the pump manifold) whose
function is to open when product is
flowing and close when product is
not flowing, thus keeping the piping
full of product between customers.
This is why fuel should start flowing
immediately when you squeeze the
nozzle handle. Otherwise the prod-
uct would drain out of the piping
back to the tank and the piping
would need to be refilled every time
there was a time lag between cus-
tomers.
Because the check valve creates a
length of piping that is closed at both
ends (at the check valve and at the
dispenser), there is the risk of thermal
expansion of the product in the pipe,
producing very high pressures in the
piping. To prevent this, the check-
-------
September 2006 • LUSTLine Bulletin 53
TANK MANIFOLD
STP
PIPING MANIFOLD
valve mechanism also includes a
pressure-relief valve that allows
product to flow back to the tank if the
pressure is too great.
The problem arises when the
operating pressure of the pump is
greater than the closing pressure of
the pressure-relief valve. These days,
pressure-relief valves can have a vari-
ety of settings, but in many cases the
valve will open at pressures in the
range of 10 to 15 pounds. Now a typi-
cal pump operating pressure is in the
range of 25 to 30 pounds.. .and higher
horsepower pumps have even higher
operating pressures than this.
It is obvious from this that if two
submersible pumps are connected in
a piping manifold configuration, but
only one pump operates at a time, the
operating pump will in many cases
have sufficient pressure to open the
pressure-relief valve. This means that
when one pump is operating, prod-
uct will flow not only to the
customer, but also past the pressure-
relief valve of the nonoperating
pump and into the other tank.
This might seem relatively harm-
less as the fuel is still contained in a
storage tank. However, if the facility
is operated so that the master tank is
refilled frequently and the secondary
tank is kept full as a reserve, the con-
tinual addition of product to the sec-
ondary tank could produce an
overfill situation.
Only an overfill alarm type of
system would be able to detect this
condition, as neither drop-tube shut-
off devices nor ball-float valves
would be effective in preventing the
flow of product into the secondary
tank through the pressure-relief
valve. If the overfill alarm is silenced,
it can conveniently be ignored for
quite some time. Of course, inventory
control recordkeeping would also
reveal the unintentional transfer of
product to the second tank—if any-
one were paying attention.
// two submersible pumps are
connected in a piping manifold
configuration, but only one pump
operates at a time, the operating
pump will in many cases have
sufficient pressure to open the
pressure-relief valve. This means
that when one pump is operating,
product will flow not only to the
customer, but also past the pressure
relief valve of the nonoperating
pump and into the other tank.
The situation could be made
even worse if the check valve on the
secondary pump did not seat prop-
erly (not an uncommon problem) and
the amount of fuel that flowed into
the secondary tank increased greatly.
If all the tank-top fittings are liq-
uid tight, this could eventually result
in fuel coming out of the vent pipe.
The more likely scenario, however, is
one where the tank top is not liquid
tight and fuel escapes via the ATG
probe cap, the stage I vapor recovery
fitting, the fill cap, or some other con-
nection that is not liquid tight.
I am aware of one instance where
this scenario unfolded and the cop-
per vent tube of a mechanical leak
detector was not properly connected.
Over a period of several months, a
substantial amount of fuel was
released to the environment via the
vent-tube opening.
The Solution?
To determine whether this type of sit-
uation is present, the installer must
determine the holding pressure of the
pressure-relief valve relative to the
operating pressure of the pump. If
the operating pressure of the pump is
higher than the opening pressure of
the pressure-relief valve, there are
two solutions. One pump manufac-
turer recommends the installation of
a check valve in each leg of the pip-
ing manifold with a pressure-relief
setting that exceeds the operating
pressure of the submersible pumps.
As long as this auxiliary check valve
operates properly, the product will
flow only to the customer and not
into the second tank.
Another pump manufacturer pro-
vides pressure-relief valves with dif-
ferent settings, so the installer need
only purchase and install the appro-
priate pressure-relief valve in the sub-
mersible pump. Not all tank installers,
however, are aware of the need to take
the pressure-relief valve setting into
consideration when installing a piping
manifold where both pumps do not
operate simultaneously.
The Moral?
As technology makes pumping sys-
tems more sophisticated, it is wise to
keep our old friend Murphy in mind
and consider the possibility that our
actions could have unintended con-
sequences. •
31
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LUSTLine Bulletin 53 • September 2006
Thoughts from Louisiana on "Operator
Training: Boon or Bust"
In regard to your article, "Operator Training: Boon or Bust" (LUSTLine
#52, Marcel Moreau), I have some input on the issue. As a regulator in
Louisiana, I can see that the requirement for all owner/operators to be
trained is a goal that will be difficult to meet. At the present time,
Louisiana DEQ has a system in place that gives the option for UST
owner/operator first-time violators to take a training class and pay a
reduced fine for violation(s) of the UST regulations.
The class covers the basics of UST system types, release-detection
methods/requirements, corrosion-protection requirements, recordkeep-
ing, etc. The class is thorough but basic (it is a five-hour class). I think with
a little tweaking here and there, the class could include the other points in
your "short list." The class is offered to whoever wants to come to it (viola-
tors and nonviolators), is free of charge, and the training dates/locations
are posted on the LDEQ public website. We offer resources for the individ-
ual owner/operator after the class for site-specific questions.
My thought is, instead of trying to get everyone trained at once, the
regulatory agency could, as sites are inspected, require the violators to
attend the class, all the while offering it to any one who would like to
attend. A deadline could be set for all owner/operators to have attended
the training by [a certain date]. Presently, we are offering the class
[approximately] 12 times a year. The class is offered in different regions
each time 2-3 times a year. Attendance is typically between 30 and 60 peo-
ple (in the capital region) and is based on the size of the region and the
number of UST facilities in the region.
So far we have received excellent feedback from the attendees; many
of them ask us why we didn't offer the class sooner. I agree with your
solution that one or two people from each facility/company should be
required to attend and be certified as the "professional UST operator" for
that facility/company. Then the certified person(s) would have the
responsibility to train site personnel. We do that already for our stage II
vapor-recovery sites. We require that there be at least one person on site
who is trained to do the daily equipment inspections and that individual
can train others [on site] as the need arises.
Here is the link to the LDEQ UST training calendar for the rest of 2006:
http://www.deq.louisiana.gov/portal/tabid/2501/Default.aspx •
These thoughts come from Terry Dedon, Staff Scientist, Louisiana Department
of Environmental Quality Capital Region
e-mail: terry.dedon@la.gov
• Tribal Lands from page 13
elevated for landscape, then the user
could access the landscape category
and see all the criteria for that partic-
ular category and the scores.
The benefits of this type of sys-
tem of collecting, analyzing, and
viewing data are tremendous. The
ITEC UST staff are able to prioritize
UST facilities for inspection, maxi-
mize the staff time, and inspect high-
risk sites more frequently. Not only
does this tool give us the ability to
determine the impact of a leak to the
environment and natural resources in
the area, it may also give us the abil-
ity to predict where future leaks may
occur based on the data obtained
from an UST inspection.
There is still work to be com-
pleted and improved upon. Another
goal for this project is to develop a
planning tool for siting future UST
installations using only the commu-
nity and topography/geology cate-
gories. This tool is a valuable asset
that could be used by any tribal
department for a number of pro-
grams beyond the UST program.
We hope to make everything
Internet accessible, where the user
can enter a latitude and longitude
and have the results delivered over
the Internet. As work continues, the
CRUST CIS tool will adopt addi-
tional changes to increase the overall
effectiveness of this application to the
UST inspection process. •
Frank Harjo is an Environmental Spe-
cialist with ITEC. He can be reached at
fharjo@cherokee.org. Special thanks to
the EPA Region 6 UST Tribal Program
and U.S. EPA Region 6 staff Dr. Ger-
ald Carney and Jeff Danielson, who
have been instrumental in providing
support and input to our project.
Make tracks
•h.
>
to the
19th Annual National Tanks
Conference and Exposition
March 5-7, 2007
see Expo details on back page
32
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September 2006 • LUSTLine Bulletin 53
FAQs from the NWGLDE
...All you ever wanted to know about leak detection, but were afraid to ask.
Questions about Automatic Mechanical Line Leak
Detectors (MLLDs) — Part II
In this issue's FAQs from the National Work Group on Leak
Detection Evaluations (NWGLDE), we discuss the effects of
the type of piping and the location of the MLLD in the line on
the MLLD itself. This article does NOT apply to electronic
line-leak detectors (ELLD). (Please Note: the views expressed
in this column represent those of the workgroup and not nec-
essarily those of any implementing agency.)
Q Can an MLLD evaluated in a rigid pipeline sys-
tem be used in a flexible pipeline system?
A Due to the difference in bulk modulus (amount
of stretching under pressure) between rigid pip-
ing and flexible piping, MLLDs designed for use
in rigid pipelines may not be satisfactory for use
in flexible-pipeline applications. MLLDs are
likely to see the stretching as a leak and erro-
neously respond by restricting the flow (false
alarm). NWGLDE believes that MLLDs used in
flexible-pipeline systems must be evaluated in
flexible-pipeline systems to ensure that they are
able to detect leaks in accordance with U.S. EPA
performance standards. However, the decision
as to whether or not to restrict MLLD use on spe-
cific pipeline systems is up to each state.
Evaluations of MLLDs tested for use in flexible
pipelines show that the affect of stretch (bulk
modulus) limits the capacity (and therefore the
length) of flexible-pipeline systems that can be
successfully monitored by an MLLD when com-
pared with the capacity (also length) of rigid-
pipeline systems that can be successfully
monitored with the same MLLD. It is also neces-
sary to evaluate MLLDs in a combination of both
rigid and flexible pipelines if they are to be used
in that type of system. Again, the decision on
whether or not to restrict MLLD use on this type
of pipeline system is up to each state.
Qls it important where MLLDs are placed in the
• L ^
system!
A Since MLLDs are designed to detect leaks down-
stream from their installation point (from the
MLLD toward the dispenser), the normal instal-
lation point is in the submersible turbine pump
(STP). In some applications, MLLDs must be
placed in a special pipe fitting adjacent to the
STP. In these cases, the MLLD should be installed
as close to the STP as possible. However, in this
situation, the piping that is between the STP and
the MLLD is not being monitored for leaks.
Installations involving manifolded tank systems
appear to have the most MLLD placement errors.
In cases where two or more STP systems are
piped to one common discharge line, and each
STP has its own MLLD, the leak rate that will be
monitored is equal to the total amount of product
being metered into the line by the MLLDs. For
example, a two-tank system, each with its own
STP and MLLD, will trip when a leak greater
than 6 gph is detected. The leak rate for a three-
tank system would be 9 gph. On the other hand,
if a single MLLD is placed on the common dis-
charge line, that MLLD will check the piping
downstream for a 3 gph leak.
Manufacturers of MLLDs have suggested config-
urations that installers can use to achieve the
required 3 gph leak-detection rate when connect-
ing to one common discharge line. For example,
if the STPs are on a delay relay, when the first
pump comes on, the MLLD associated with that
pump will check all the piping for a 3-gallon-per
hour leak before the other STPs come on. This
information can be found by visiting MLLD
manufacturers' websites. •
About NWGLDE
The NWGLDE is an independent work group compris-
ing 10 members including 9 state and 1 U.S. EPA mem-
bers. This column provides answers to frequently asked
questions (FAQs) the NWGLDE receives from regula-
tors and people in the industry on leak detection. If you
have questions for the group, please contact them at
questions@nwglde.org
NWGLDE's mission:
• Review leak-detection system evaluations to deter-
mine if each evaluation was performed in accor-
dance with an acceptable leak-detection test
method protocol and ensure that the leak-detection
system meets U.S. EPA and/or other applicable
regulatory performance standards
• Review only draft and final leak-detection test
method protocols submitted to the work group by a
peer review committee to ensure they meet equiva-
lency standards stated in the U.S. EPA standard test
procedures
• Make the results of such reviews available to inter-
ested parties
33
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LUSTLine Bulletin 53 • September 2006
SHELTER FROM THE STORM
Mr. J. L. Faircloth of
Pensacola, Florida
constructed this storm
shelter from a sal-
vaged steel UST
anchored to the earth
by log chains, site-
built concrete dead-
men, and partially
bermed. The tank was
originally reported to
the local UST program
as an unregistered
storage tank, the sub-
ject of a complaint
investigation.
The outside is painted
silver, the interior a
pastel green. Internal
stanchions are welded in place, supporting shelves along the
sides, which serve as storage for food, water, candles and
first aid supplies, tools, and as a place to spread sleeping
bags. Ventilation is provided by a port low at one end, and
several four-inch PVC risers from bungs at the top with
return bends at the top of each to exclude rain. A step-
through door at the south end of the tank provides access. A
steel door constructed with a removable sheet metal panel
for emergency egress opens inward.
Photos courtesy of John Stevenson of the Escambia County (Florida) Dept. of Health.
Mr. Faircloth and his dog occupied this shelter during
Hurricane Dennis. He reports it was both quiet and comfort-
able during the stay. Intended for only a few hours tenancy,
at the height of a storm, he says the rain cooled the interior
quickly, and the wind effectively vented it. Also, convection
stratification removed the warmed air at the top. Chocked,
anchored, and bermed, the shelter was very stable while the
wind tore at its surroundings.
A TANK CAR UNEARTHED...WITH PRODUCT!
What appears to be a single-
dome railroad tank car was
unearthed recently near a
roundhouse (a circular
building for housing, repair-
ing, and switching locomo-
tives) in Keene, New
Hampshire. The car, which
had no undercarriage, was
probably used to fuel trains
that approached the round
house. It is riveted, which
means that it was manufac-
tured prior to 1920. The car
contained some product and
a very old broken baseball
bat. There was some conta-
mination around one end of the car and some petroleum in the groundwater.
The area where the car was found is part of Keene's rails-to-trails project,
which will connect two fairly long segments of existing bicycle trails. The New
Hampshire Department of Environmental Services (NHDES) also determined
that two nearby above-ground storage tanks were probably the tanks shown
on the 1924 San born map of the area.
There is a good entry in wikipedia.org on tank cars at http://en.wikipedia.org/wiki/Tank_car.
This story and photos were provided by Gary Lynn, NHDES.
If you have any UST/LUST-related snapshots from the field that you would like to share with our readers, please send them to Ellen Frye c/o NEIWPCC.
34
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September 2006 • LUSTLine Bulletin 53
• L.A. Oversight Program from page 11
Dr. Yue Rang (a.k.a. "Y.R.") is the program manager for the
Underground Storage Tank Program at the California
Regional Water Quality Control Board, Los Angeles Region.
He has worked with cleanup of chlorinated solvents in the
San Fernando Valley and is a senior staff member of the
multidisciplinary MtBE groundwater contamination team.
He can be reached at YRONG@waterboards.ca.gov
Dr. Matthew Small is a hydrogeologistfor U.S. EPA Office
of Underground Storage Tanks - Region 9 in San Francisco,
California, and a licensed professional geologist. He provides
technical support and training to state UST/LUST programs
and direct program implementation on Native American
lands, and is active in creation of national standards and
guidelines. He can be reached at small.matthew@epa.gov
References:
Office of Management and Budget (OMB), 1993, Government Performance Results Act
of 1993 (GPRA), http://www.whttehouse.gov/omb/mgmt-gpra/gplaw2mMml.
http://www.whttehouse.gov/omb/mgmt-gpra/indexMml.
Rong, Y., 2006, Memo: EAOP progress report, From: Yue Rong, Section Chief, Under-
ground Storage Tanks, To: Jonathan S. Bishop, Executive Officer, David Bacharowski,
Assistant Executive Officer, California Regional Water Quality Control Board, Los
Angeles Region, July 17, 2006.
U.S. Environmental Protection Agency (EPA), 2004, Memo: Promoting the Use of Multi-
Site Approaches to Cleanup and Revitalize LUST Sites, From: Cliff Rothenstein, Direc-
tor, Office of Underground Storage Tanks, To: UST/LUST Regional Division
Directors Regions 1-10, March 29, 2004, www.epa.gov/oust/msa_memo_032904.pdf.
U.S. Environmental Protection Agency (EPA), 2006a, Office of Underground Storage
Tanks Web Site, Corrective Action Measures Archive, June 20th, 2006,1st Half FY
2006 (October 1, 2005 through March 31, 2006), http://epa.gov/oust/cat/camarchv.htm.
U.S. Environmental Protection Agency (EPA), 2006b, Office of Underground Storage
Tanks Web Site, Types of Multi-Site Agreements, March 8, 2006,
http://www.epa.gOV/oust/cat/msJ:yfiesMm.
LUSTLine T-Shirts
Short sleeve
L
Back of shirt
TWO WACK¥ designs l
created by LUSTLine cartoonist, Hank Abo
TWO colors... red and black
TWO versions... long and short sleeve
Long sleeve $8.50 Front of shirt
Short sleeve $6.50
Sizes: M, L, X, XXL (men's sizes only)
TO OR^ER! Send check or money order (drawn on U.S. banks only) to:
NEIWPCC
116 John Street
LoweU, MA 01852-1124
Tel: (978) 323-7929 • Fax: (978) 323-7919
How Much Bioenergy Can Europe Produce
Without Harming the Environment?
In its new report, How Much Bioenergy
Can Europe Produce Without Harming
the Environment?, the European Environ-
ment Agency assesses how much bio-
mass could technically be available for
energy production without increasing
pressures on the environment. The
study concludes that "significant
amounts of biomass can technically be
available to support ambitious renew-
able energy targets, even if strict envi-
ronmental constraints are applied."
The report, which did not analyse costs
and logistics, finds that Europe could actually produce 190 Mtoe (million
tons of oil equivalent) of bioenergy in an environmentally viable fashion,
by 2010. This could reach almost 300 Mtoe by 2030. Seems such a study
would be useful here in the United States. Read more at
http-.//reports, eea. europa. eu/eea_report_2006_ 7/en. •
Subscription Form
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Company/Agency.
Mailing Address _
E-mail Address.
Q One-year subscription. $18.00.
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Please enclose a check or money order (drawn on a U.S. bank) made payable to NEIWPCC.
Send to: New England Interstate Water Pollution Control Commission
116 John Street, Lowell, MA 01852-1124
Phone: (978) 323-7929 • Fax: (978) 323-7919 • lustline@neiwpcc.org • www.neiwpcc.org
35
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19tl nniial anks
k March 5-7, 2007
Attention Underground Storage Tanks Manufacturers/Representatives
Do you have a product or service you'd like to showcase?
Make your company known to an estimated
600 conference and show attendees!
You'll be interacting with:
Tanks Managers
Municipal Government Professionals
County and State Government Representatives
Federal Agency Representatives
Engineers
Contractors
Project Managers
Consultants
Distributors
Available October 27, 2006—Our website will provide the exhibition
registration form, including complete pricing information.
www.neiwpcc.org/tanks07
E-mail us at NTCInfo@Neiwpcc.org with any questions.
LUSJ.UNE
New England Interstate Water
Pollution Control Commission
116 John Street
Lowell, MA 01852-1124
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