New England Interstate
Water Pollution Control
Commission
www.neiwpcc.org/lustline
116 John Street
Lowell, Massachusetts
01852-1124
L.U.S.T.UNE
A Report On Federal & State Programs To Control Leaking: Underground Storage Tanks
Bulletin 64
March
2O1O
IIISH 1011
What's in Store for Tanks and Tank Programs
Over the Next Decade—Part 1
by Ellen Frye
Change happens...all the
time...every which way
you turn...but these
days, things seem to change at
lightning speed. Communica-
tions technologies are passe
almost before they get started.
MP3? Facebook? Twitter?
Enjoy your fifteen minutes of
fame! Cell phones? It's only a
matter of time before they're
implanted in our brains so
all we'll need to do is think a
conversation. Even the climate
can't be depended on. Change
happens, and we all need to get
with the program or be washed out
to sea by that "gotcha" wave. And that
means tank programs too.
So as we enter the second decade of this millen-
nium, it seems as good a time as any to take a peek into ye olde
crystal ball in an attempt to fathom what is clearly a transition
into that great unknown looming on the fuel storage tank hori-
zon, so that we, like the Boy Scouts, can be prepared to be pre-
pared.
This exercise has taken the form of a series of questions
formulated by a small group of industry and regulatory aficio-
nados, including Patricia Ellis, Delaware NREC; Kevin Hen-
derson, Mississippi DEQ; Robert Renkes, PEl; Marcel Moreau;
Anne Hines, Arkansas Marketers
Assoc., Inc.; Andrea Barbery and Hal
White, USEPA OUST; Carol Eigh-
mey, Missouri PSTIF; and Wayne
Geyer, STI/SPFA. We have asked
the questions and provided rea-
sons for the questions, but we
have not necessarily attempted
to provide answers.. .maybe just
some speculation. We have com-
piled so many questions that it
has become necessary to split
them between this issue o/LUS-
TLine and the next. The next set
of questions will look more into
UST/LUST program specifics. We
welcome your thoughts and questions.
• continued on page 2
Inside
6(J LUST Recovery Act: One Year Later
7() Cleanups That Are Making a Difference
9() Top Ten LNAPL Myths
12(J Achieving UST Operational Compliance
14() Observations on CP Operation and Testing
16U Concerns Over Ultra-Low-Sulfur Diesel Fuel
:-H) Evaluating ATGs for 0.1 GPH Leak Rate
-------
LUSTLine Bulletin 64 • March 2010
I Transition from page 1
Just Wondering...
E? UJhot will retail-fueling opera-
tions look like bu the end of this
decade?
When we talk about transitioning,
the big question is: Transitioning to
what? For gasoline-type vehicles,
alternative fuels include alcohol,
biobutanol, biodiesel, methanol, liq-
uefied petroleum gas, compressed
natural gas, hydrogen... What will
retail-fueling facilities be selling?
How will they accommodate the
many potential choices, or will just
one or two choices bubble up to the
top? Today's fuel retailer is caught in
the middle of this transition, needing
to be competitive in order to be via-
ble but having precious little control
over how things play out.
Will fuel stations need to be
mega-sized in order to handle all the
available fuel types? Where, as you
drive in, you are directed to an area
L.U.S.T.Line
Ellen Frye, Editor
Ricki Pappo, Layout
Marcel Moreau, Technical Adviser
Patricia Ellis, PhD, Technical Adviser
Ronald Poltak, NEIWPCC Executive Director
Deb Steckley, USEPA Project Officer
LUSTLine is a product of the New England
Interstate Water Pollution Control Commis-
sion (NEIWPCC). It is produced through
cooperative agreements (US-83384301 and
US-83384401) 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 old-
est agency in the Northeast United States
concerned with coordination of the multi-
media environmental activities
of the states of Connecticut, Maine,
Massachusetts, New Hampshire,
New York, Rhode Island, and Vermont.
NEIWPCC
116 John Street
LoweU, MA 01852-1124
Telephone: (978) 323-7929
Fax: (978) 323-7919
lustline@neiwpcc.org
v^& LUSTLine is printed on recycled paper.
for liquid fuels for cars (e.g., gaso-
line, ethanol-blends), an area for die-
sel-like fuels (e.g., diesel, biodiesel,
blends), electric-vehicle recharging
areas, and areas where there are fuels
that are gaseous in nature (e.g., LPG,
CNG, hydrogen)?
Then again, it seems very likely
that we are transitioning to electric
cars or solar fuel cells. Will these
technologies even need a service
station? Electric cars appear to be
very much on the horizon, and it
appears likely that charging sta-
tions will be located at places like
garages and restaurants, where
vehicles will be able to stay put for
the 30 minutes or so needed for a
charge.
tf What is the fastest growing
fuel-storage-tank sector?
The fastest-growing type of fuel
storage tank being installed in the
U.S. is the nonretail aboveground
tank, and especially the generator-
base diesel standby, or emergency
generator, tank. Banks, credit card
companies, phone companies,
hospitals, governments, gas sta-
tions, and other entities that require
continuous power are installing these
systems by leaps and bounds nation-
wide. An industry source estimates
there are over one million commer-
cial diesel standby generator sets in
the U.S.
While there doesn't appear to be
a central source for tracking the size
of this standby generator tank popu-
lation, a rough guess from our indus-
try source is that over 60 percent of
I
The new "green"
design Element
Hotel in Lexing-
ton, Massachu-
setts includes a
charging station
for electric vehicles. The station is equipped with
a universal plug-in for all kinds of electric vehicles
including cars, buses, Segway scooters and bikes.
Drivers can simply swipe a card, plug in, and charge
up their electric vehicles at the station.
them are fueled from standard cylin-
drical tanks (both above and below-
ground) and about 30 to 35 percent
of them are fueled from rectangular
tanks, usually installed as a base for
the generator set. The average tank
ranges from 300 to 500 gallons in
size.
Under the federal rule, under-
ground generator fuel tanks are sub-
ject to all requirements except leak
detection. The aboveground tanks are
essentially unregulated, unless by a
state. So the ques-
tion here is: Are
we comfortable
with the fact that
there are many
aboveground
storage tanks
out there that are
fully capable of
leaking into the
environment and
yet fall between
the regulatory
cracks?
Emergency generator
system.
-------
March 2010 • LUSTLine Bulletin 64
0* Now that the major oil com-
panies are all but gone from the
retail end of the business (fewer
than 5 percent of retail facilities
are still owned bu flPI members),
who owns these facilities these
days (mom and pops, jobbers,
foreign oil companies, new non-
Cnglish-speaking Americans)?
What will the future ownership
trends be, and what should tank
regulators be doing now to pre-
pare for those changes?
We have seen a variety of trends in
tank ownership over the years, with
implications for UST program imple-
mentation. For example, there was a
major consolidation in the first half
of the program, with many retail-
ers leaving the business, replaced by
fewer but higher throughput facili-
ties. We also saw a major exodus of
nonmarketers, choosing to forsake
the convenience of having their own
fuel supply in order to avoid the cost
and liability of proper tank manage-
ment. More recently, we've seen an
exodus by major oil companies, with
an influx of small, often single-sta-
tion owners.
The good news is that as of Sep-
tember 2009, there are only about
611,000 active federally regulated
USTs (at approximately 223,000
sites), in contrast with the more than
1.7 million substandard USTs back
in 1984. But mind you, average tank
size being manufactured has grown
from about 8,000 gallons back in 1985
to a whopping 15,000 to 20,000 gal-
lons today—fewer retail facilities,
bigger storage capacity.
So regulators are dealing with
about one-third of the pre-regula-
tion tank universe. In terms of com-
pliance with the UST requirements,
as of September 2009, 66.4 percent
of UST facilities were in "significant
operational compliance" with both
the release-prevention and leak-
detection requirements.
But today's UST owners/opera-
tors have the increasingly daunting
job of keeping up with the many
responsibilities that go with own-
ing these facilities. (See "If I Had to
Choose Just One Way of Achieving
UST Operational Compliance..." on
p. 12). The majors were pretty good
at keeping up because they typically
had corporate management systems
"We are already seeing the number of petroleum suppliers, wholesalers, and
retailers shrinking. It started back in 1998 and has been getting progressively
worse. At one time we had 258 petroleum wholesale members in Arkansas.
For the ones who are actually based in Arkansas, our membership is close to
160 now. And the number of retailers has also been shrinking. I have areas in
South Arkansas (the Delta) where it is routinely 15 to 20 miles between retail
locations. Now, that may not be much in Wyoming but in a populated area, it is
a long distance.
And, I think more and more of them will sell to a competitor or, what I
am also seeing, just close their doors before they lose any more money. While I
think gasoline will be a viable fuel for a number of years, we have been trying to
position our members to where they can sell whatever fuel a customer wants."
ANN HINES
EXECUTIVE VICE PRESIDENT,
ARKANSAS MARKETERS ASSOCIATION, INC.
in place. Jobbers who have been
in the business for years may be in
good shape, but what about those
who are new to the regulated and
environmental liability-laden world
of USTs?
Many of the new owners have
retail backgrounds, but not necessar-
ily backgrounds that include man-
aging an underground storage tank
system. The National Association of
Convenience Stores (NACS) is the
industry's leading advocate on motor
fuels policy and represents 80 percent
of the country's retail fuel sales. The
majority of its members are small,
independent operators. More than
70 percent of its total membership is
comprised of companies that operate
ten stores or less. Of the 145,000 con-
venience stores in the United States,
62 percent are owned and operated
by someone who only has one store.
There is a good reason why retail
gasoline marketing has become so
often tied to the convenience store
(C-store): The marriage has evolved
as both necessary and symbiotic.
With highly volatile net profits on
fuel (lately in the vicinity of 2 cents
a gallon on a good day) for gasoline
retailers, business profit margins are
well enhanced by sundry sales inside
the store, but the fuel needed for our
vehicles is the bait.
Will states need to go back to
square one, or at least square two,
to connect with new tank owners/
operators and educate them about
regulations and proper operation
and maintenance? Which bring us to
the next question...
tf Will the operator training
requirements of the 2005 Cnergu
Policy flct (CPflct) have the desired
effect?
It stands to reason that operator
training and certification will afford
operators a better understanding of
what they must do to operate and
maintain their UST systems and
comply with UST regulations...but
to what degree? It still all depends
on enforcement. States have to be
willing to provide frequent, consis-
tent, slap-on-the wrist enforcement
if owners and operators are to learn
what they need to learn and then DO
what they are supposed to do. There
is still something to be said for the
old "fear of getting caught" mindset.
Without effective enforcement, the
results of the operator training initia-
tive are likely to be disappointing.
We must also take into account
certain barriers that may well come
into play with regard to the success
of operator training:
• Language - Many single own-
ers/operators may not speak
and understand English well
enough to engage effectively in
state training programs.
• Complexity - Rules have become
even more complex as a result
of the 2005 EPAct requirements.
• Cconomic - Hard times dictate
that many owner/operators
must make choices. What will
win out, paying the beer ven-
dor or testing the automatic line
leak detectors?
• continued on page 4
-------
LUSTLine Bulletin 64 • March 2010
I Transition from page 3
Culture/attitude - Regulations
are often not easily understood
by some recent immigrants and
are not viewed favorably by
some longtime U.S. residents.
Can regulators mitigate these
barriers?
b* Will the goals of the federal
Renewable Fuel Standard (RFS)
be achievable if we continue in
the direction(s) we are heading
(i.e., mainly €10 and little €85,
biodiesel, or cellulosic ethanol in
production)?
The RFS program was created under
the EPAct, requiring the volume of
renewable fuel blended into gaso-
line to reach 7.5 billion gallons by
2012 (RFS1). Under the Energy Inde-
pendence and Security Act (EISA)
of 2007, the Renewable Fuel Stan-
dard program increased the volume
of renewable fuel required to be
blended into transportation fuel to
36 billion gallons by 2022 (RFS2). Of
these modifications, several are nota-
ble. First, the required renewable fuel
volume continues to increase under
RFS2, reaching 36 billion gallons by
2022. The chart below shows the vol-
ume requirements from EISA.
In a February 16th speech at the
Renewable Fuels Association confer-
ence, General Motors Vice Chairman
Tom Stevens said that half of the com-
pany's vehicle line-up will be able to
run on E85 by the 2012 model year.
He noted that 12,000 or more ethanol
stations are needed "to have ethanol
fuel available for every one of our
customers within about two miles of
where they live." So it appears that at
least automobile manufacturers are
taking RFS2 requirements seriously.
0* What impact will €15 have on
existing UST systems and gasoline
retailers?
Chances are that USEPA will give
the green light to 15 percent etha-
nol (E15) in gasoline (a decision is
expected by late summer 2010) for at
least a portion of the existing vehicle
fleet. Compatibility of most UST sys-
tems with E10 may not be much of
an issue, although we can't be cer-
tain. On the other hand, UST systems
storing E85 often need to be built
from scratch with alcohol-compatible
materials. At what point between 10
percent ethanol and 85 percent etha-
nol should the UST regulatory com-
munity be concerned?
And what about older cars and
small engines (e.g., boats, lawnmow-
ers, weed whackers) that are not
compatible with higher ethanol per-
centages? It seems unlikely that very
many marketers will give up E10 and
sell only E15. But how many market-
ers have an extra tank lying around
that they can use for E15? How
many will want to invest the tens of
thousands of dollars it will take to
dispense E15? And how many cus-
tomers will want to buy E15 when
they see their mileage per gallon
decreasing as the percentage of alco-
hol increases?
Storage system compatibility
issues aside, what's a marketer to do if
he wants to store, meter, and dispense
E10 and E15 fuels? Chances are it will
cost him more money but only yield
the already slim profit margin. Will
tank owners continue to fall by the
wayside if they feel the investment
will just put them deeper in a hole?
J^^^^l jlsn -HE JEM
Year
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022
2023+
Cellulosic biofuel
requirement
n/a
n/a
0.1
0.25
0.5
1.0
1.75
3.0
4.25
5.5
7.0
8.5
10.5
13.5
16.0
b
Biomass-based diesel
requirement
n/a
0.5
0.65
0.80
1.0
a
a
a
a
a
a
a
a
a
a
b
Advanced biofuel
requirement
n/a
0.6
0.95
1.35
2.0
2.75
3.75
5.5
7.25
9.0
11.0
13.0
15.0
18.0
21.0
b
Total renewable
fuel requirement
9.0
11.1
12.95
13.95
15.2
16.55
18.15
20.5
22.25
24.0
26.0
28.0
30.0
33.0
36.0
b
a To be determined by EPA through a Mure rulemaking, but no less than 1. 0 billion gallons.
b To be determined by EPA through a future rulemaking.
-------
March 2010 • LUSTLine Bulletin 64
0* Assuming that the fuel blend
will change, what should tank
regulators do to position them-
selves to accommodate the new
fuels on the horizon without risking
new releases or more challenging
cleanups, and how can we antici-
pate and manage the unintended
consequences of increased use of
biofuels?
On the leak prevention end, regula-
tors want to know that UST owners
and operators are using equipment
that is compatible with the fuel being
stored. A number of states (including
IA, NC, and WI) require UL-listed
equipment or manufacturer's certi-
fication for use with ethanol blends
greater than 10 percent. A good way
for owner /operators to do this is ver-
ify the UL listing or contact the man-
ufacturer. However, in cases where
the owner/ operator cannot show a
UL listing or documentation from
the equipment manufacturer that the
entire UST system is compatible with
mid-level blends (E15, E20, E30), are
states willing to prohibit the storage
of higher-level blends?
With regard to leaking under-
ground storage systems, consider the
fact that currently 80 percent of gaso-
line sold in the U.S. is E10, and yet
we haven't really turned over all the
stones with regard to ethanol's behav-
ior in the environment. As we have
seen time and again, a "fix" for one
environmental problem can often cre-
ate yet another environmental prob-
lem — unintended consequences — if
the life cycle of the fix isn't examined
adequately (e.g., MtBE).
Such new fuel consequences
might include potential for vapor
intrusion due to production of meth-
ane, changes in redox chemistry
in plumes to mobilize arsenic and
manganese, or solubilization of met-
als from water intakes. What minor
components of biofuels, such as anti-
oxidants, denaturants, and other
additives, are of particular concern?
It would be nice to know what is
going to be in our fuel supply before
it is added, not ten years later.
0* Will those of us in the ground-
water protection sector ever be
able to have a sou on what is
stored in petroleum storage tanks
in order to ward off the chance of
a release into the environment?
Right now, fuel content seems to be
dictated by air programs and Con-
gress. Wasn't that how we ended up
with a multibillion dollar MtBE prob-
lem? The press happily covers issues
concerning compatibility of auto-
mobiles with higher ethanol blends,
but we never see any discussion of
compatibility with tank systems and
higher ethanol blends. There is a seri-
ous lack of consideration for how
long it will take to implement storage
and dispensing infrastructure retro-
fits or extreme makeovers, the costs,
and who pays.
We need more coordination
between air, water, and waste pro-
grams, as well as vehicle and other
engine manufacturers, fuel dispens-
ing equipment suppliers, transpor-
tation people, agricultural interests,
health officials, and so on. And we
certainly need more lead time to
make changes in the fuel systems to
avoid creating another generation of
leaking tank systems.
acquisitions had to be AFVs. Law
enforcement, emergency, and mili-
tary tactical vehicles were exempt.
A subsequent amendment permit-
ted federal agencies to use biodiesel
to meet a portion of their alterna-
tive fueled vehicle (AFV) acquisition
requirements.
Biodiesel, a cleaner burning alter-
native fuel produced from domestic
renewable feedstock such as veg-
etable oils, is typically used as B20
(a blend of 20% biodiesel and 80%
petroleum diesel). The use of 2,250
gallons of B20 equates to one AFV
credit under EPAct.
ASTM D 6751, "Standard Specifi-
cation for Biodiesel Fuel Blend Stock
(B100) for Middle Distillate Fuels" is
the spec used for blending biodiesel
with petrodiesel in levels up to 20
percent by volume. Since there is cur-
rently no ASTM standard for higher
percent petrodiesel blends, it is likely
the military is using B20. However,
biodiesel is not approved for use in
tactical vehicles because of concerns
regarding its long-term stability.
"In early 1999, during the EPA Blue Ribbon Panel hearings on fuel
oxygenates, one of the committee members (who happened to be a VPfor one
of the largestMtBE producers) stated thatifthe tank people would just finish
getting all the bare steel tanks out of the ground, there would be no MtBE
problem, because gasoline (and MtBE) wouldn't leak from a 1998-compliant
tank. I believe that we have discovered that that wasn't true. "
PATRICIA ELLIS
DELAWARE DEPARTMENT of NATURAL RESOURCES &
ENVIRONMENTAL CONSERVATION
If What impact will ultra-low-sul-
fur diesel fuel have on fuel stor-
age systems?
There are instances of excessive cor-
rosion being observed, which would
have in impact on our fuel-storage
systems. How serious is this threat?
(See more on ULSD on page 16.)
tf In what fuel/technology direc-
tion is the military going?
The U.S. military is collectively the
biggest tank owner in the country.
The EPAct of 1992 set requirements
for the acquisition of alternative fuel
vehicles (AFVs) by federal agen-
cies. Starting in fiscal year 2000,
75 percent of light-duty vehicle (LDV)
The bigger question for federal
and state tank programs contin-
ues to center on the degree to which
these entities are able to regulate and
enforce military tanks. And an even
more exciting futuristic question:
Does the military have a secret under-
ground cave where they are develop-
ing petroleum-free, pollutant-free,
Star-Trek-like vehicles that will move
us all into a new realm of transpor-
tation and put UST regulators out of
business? •
.. the next issu.
f of LUSTLine we '
will address more
questions on the
k future of tank
programs.
-------
LUSTLine Bulletin 64 • March 2010
A MESSAGE FROM CAROLYN HOSKINSON
Director, USEPA's Office of Underground Storage Tanks
The LUST Recovery Act:
One Year Later
In autumn 2008, I listened to the U.S. presidential candi-
dates discuss the need for change in many aspects of our
nation's modus operand!—economic, security, involve-
ment in world matters, energy use, and more. I'm certain you
heard many of those discussions and promises, too. At the
time, I thought that some aspects of my life might be affected
by those promised changes. But I certainly did not anticipate
the magnitude of change that roared into USEPA as part of
the American Recovery and Reinvestment Act (Recovery Act)
of 2009. The Act included significant provisions for the leak-
ing underground storage tank (LUST) program; provisions
we refer to as the LUST Recovery Act.
Since February 2009, states, territories, tribes, and
USEPA regions and headquarters have put much thought and
effort into LUST Recovery Act issues. If asked to describe
the last year, intense and exhausting are two adjectives that
quickly jump to mind. And given a moment, I would add
rewarding and exciting to my description. Although sig-
nificant work is still ahead of us in implementing the LUST
Recovery Act program, I would also like to raise a glass to
the impressive progress that USEPA and our LUST Recovery
Act partners have made over the last year.
LUST Recovery Act Basics
For those of you who aren't familiar with the LUST Recov-
ery Act, here's a quick recap of what it is, how much money
USEPA received, and how the money is being spent.
The Recovery Act provided USEPA with $200 million from
the LUST Trust Fund to assess and clean up contamination
from federally regulated underground storage tanks (USTs).
As one of only six USEPA programs to receive Recovery Act
money, this investment illustrates the importance of protect-
ing our nation's groundwater—the source of drinking water
for approximately 50 percent of Americans and 99 percent of
Americans in rural areas. This also shows an awareness that
USTs are a leading source of groundwater contamination in
our country.
USEPA allocated over $190 million in LUST Recovery
Act money to states and territories, as well as over $6 million
to assess and clean up eligible tank releases in Indian coun-
try. This infusion of more than three times the typical annual
LUST allocation will help reduce the backlog of 100,000
releases that still need to be cleaned up. While this money
is providing environmental benefits to our country, it is also
helping to retain jobs and improve our nation's economy. Yet,
this money brings with it requirements for unprecedented
accountability and visibility, as well as additional implementa-
tion tasks.
See a sampling of
"Cleanups That Are Making a Difference" on page 7
LUST Recovery Act
Money = More Work
I acknowledge that the LUST
Recovery Act money was a
great boost to our cleanup program; but I also recognize that
the additional money brought with it many requirements. I
appreciate the significant contributions states and territories
made and continue to make—providing input to the LUST
Recovery Act program guidance; identifying candidate proj-
ects; undertaking ongoing assessment and cleanup work on
projects; providing reports to USEPA on LUST Recovery Act
performance measures, as well as ongoing recipient reports
to www.FederalReporting.gov, among others.
Realistically, I know states and territories are juggling the
LUST Recovery Act work along with other ongoing efforts,
such as Energy Policy Act requirements, traditional assess-
ments and cleanups, and compliance and inspections. I
fully appreciate the added workload the LUST Recovery Act
requirements are presenting for states and territories, given
that USEPA headquarters and regions are also dealing with
increased workloads as a result of the LUST Recovery Act
money.
Accomplishments
But now, at the one-year mark, I am buoyed as I recount the
LUST Recovery Act accomplishments and successes I see
from states, territories, and USEPA regions and headquar-
ters. As of December 31, 2009, on a program-wide level, the
following was accomplished:
• Ninety-eight percent of $197 million allocated for states
and territories and for LUST-eligible work in Indian coun-
try has been obligated—this means the money is avail-
able for field work to begin.
• One hundred percent of recipients completed the neces-
sary jobs and performance measures reporting for the
first two quarters.
• Cumulative LUST Recovery Act performance measures
results were as follows:
• Site assessments - 323 initiated; 112 completed
• Cleanups -166 initiated; 46 completed
• LUST Recovery Act money has also contributed to
ongoing assessments and cleanups at a total of 554
sites that did not begin as Recovery Act projects and
are not represented in the numbers above.
• More than 45 jobs were created or retained in the first
quarter (July to September 2009) and over 150 jobs
were created or retained in the second quarter (October
to December 2009—in other words, LUST Recovery
Act money is providing economic and environmental
benefits. •
-------
March 2010 • LUSTLine Bulletin 64
LUST Recovery Act
Cleanups That Are Making a Difference
by Carolyn Hoskinson
States, territories, and tribal partners—along with USEPA support—are making significant progress in putting LUST
Recovery Act funds to good use. I've been hearing about cleanups at LUST sites in communities across the U.S., thanks to
help from LUST Recovery Act money. I want to share with you three examples from Alabama- on the Cheyenne River Indian
Reservation in South Dakota; and in Pennsylvania.
ALABAMA: SELMA TO MONTGOMERY
NATIONAL HISTORIC VOTING RIGHTS TRAIL
Alabama's Department of Environmental Manage-
ment (DEM) and USEPA are working closely with
local communities and citizens living along and in
the vicinity of the Selma-to-Montgomery National Historic
Voting Rights Trail to realize a local community vision for
revitalization that is consistent with national historic site
goals. The Trail runs through Dallas, Lowndes, and Mont-
gomery Counties and is a pivotal civil rights location. It
begins in Selma and continues along U.S. Highway 80 to
West Montgomery. Unfortunately, today the route is a 54-
mile corridor of high unemployment, health issues, lower
educational and economic achievements, and severe rural
isolation.
Alabama DEM and USEPA, along with a number of
state and federal agencies (e.g., the Army Corps of Engi-
neers, National Park Service, Department of Agriculture,
and Federal Highway Administration), are collaborating
with local communities to apply Recovery Act resources
along the Trail. State and federal partners are support-
ing the local vision of enhancing the preservation of his-
toric assets, while realizing the area revitalization goal of
improving the economic situation of the area. The Trail
communities of Hayneville, White Hall, Lowndesboro,
Selma, and Montgomery have recommended a variety
of reuses for abandoned UST properties, including local
craft and gift shops that support National Historic Trail
visitors, restaurants, and vegetable stands.
In addition to LUST Recovery Act-funded efforts,
DEM and USEPA are devoting contract and in-house
efforts to conduct site assessment activities for other
petroleum and hazardous waste properties along the cor-
ridor. Sampling activities were conducted in 2009 and
additional sampling efforts are ongoing in 2010. Combin-
ing targeted involvement and leveraging other federal
and state resources, DEM and USEPA can facilitate com-
munity-based revitalization, environmental benefits, and
economic development activities along the corridor.
There are many active and former gasoline stations
along the Trail that have the potential to cause contami-
nation from petroleum leaks. For example, the DEM and
USEPA are addressing contamination at a former Gulf ser-
vice station in Montgomery in an area bordered by mixed
light commercial and residential properties. The site was
formerly a retail gas station and is currently used as a car
detail shop.
This site has petroleum contamination that dates back
to at least 1986 or earlier, and in 1986 four 3,000-gallon
gasoline tanks were removed. There are concerns about
soil, groundwater, and possibly petroleum vapor con-
tamination in surrounding residential neighborhoods.
Site investigation activities are in progress. Groundwater
monitoring and risk assessment activities are next, and
cleanup activities are scheduled to be completed in late
2011. DEM estimates it will cost $350,000 to address con-
tamination at this site and intends to clean up the site to a
• continued on page 8
Drilling activities at a former Gulf station located along the Selma to
Montgomery National Historic Voting Rights Trail route.
Local community visioning at one of the sites along the Trail.
-------
LUSTLine Bulletin 64 • March 2010
m Cleanups That Are Making a Difference from page 7
level protective of human health and the environment,
which will allow for a greater range of property uses.
USEPA provided the DEM with $4 million to assess
and clean up contamination released from federally regu-
lated underground storage tanks. The DEM identified a
list of 28 sites for initial assessment evaluation, and will
identify additional sites for investigation and cleanup
over the next two to three years.
SOUTH DAKOTA: CHEYENNE RIVER INDIAN
RESERVATION
On the Cheyenne River Indian Reservation in South
Dakota, USEPA Region 8's UST program is work-
ing in partnership with the Cheyenne River Sioux
Tribe to use LUST Recovery Act money to clean up the
Lantry Oil site. Work includes operating and maintaining
an air sparge/soil-vapor-extraction (SVE) system, con-
ducting two injection events of in-situ chemical oxidation,
and reducing the dissolved groundwater plume by more
than 60 percent. Originally a mixed-use property that
Remediation work on the Cheyenne River Indian Reservation, South
Dakota.
once housed a gas station, auto repair facility, and plumb-
ing business, the Lantry Oil site was abandoned approxi-
mately six years ago. The remediation activities, paid for
by LUST Recovery Act money, have been instrumental in
facilitating a property transfer of this site, which in turn
will foster productive reuse of the property. In addition,
the cleanup is creating several jobs in Lantry, a small com-
munity on the reservation.
In 1993, state inspectors documented petroleum
odors and found soil contamination at the bottom of the
pit when underground storage tanks were removed. Site
soil samples indicated contamination of benzene, tolu-
ene, ethylbenzene, xylenes (BTEX); naphthalene; and total
petroleum hydrocarbon (TPH). Beginning in 1997 when
the site was eligible for federal LUST money, monitoring
wells were used to determine the extent of contamina-
tion, exposure pathways, and risk receptors. After evalu-
ating remediation options, USEPA chose an SVE system
8
as the most viable option because it specifically targets
residual hydrocarbons from the vadose zone. With the
help of LUST Recovery Act funds, contaminant impacts
to groundwater will be mitigated over time as the contrib-
uting source of hydrocarbons in the soil is reduced.
The more than 4,200 square mile Cheyenne River
Indian Reservation is the fourth largest reservation in
land area in the U.S. Approximately 14,000 people live
on this reservation. The Reservation is just one example
of how USEPA is investing a portion of the $6.3 million
LUST Recovery Act money to assess and clean up eligible
tank releases in Indian country.
PENNSYLVANIA: WARRINGTON TOWNSHIP IN
BUCKS COUNTY
Pennsylvania's Department of Environmental Pro-
tection (DEP) is using LUST Recovery Act money
in Warrington Township, Bucks County, to clean up
petroleum contamination at an abandoned property. Mal-
colm's Gas Station and Auto Repair shop, an abandoned
two-acre property, was a small family-owned facility that
closed after petroleum releases and soil contamination
were discovered in 2002. The property owner is deceased
and the estate lacks the financial resources to remediate
the site, which is located on Easton Road (Route 611), a
busy corridor in Central Bucks County. It is on a neglected
commercial strip that the township targeted for future
improvement.
Petroleum releases and soil contamination discovered at Malcolm's ser-
vice station in Pennsylvania.
In January 2010, Ferrick Construction, a local, women-
owned business certified by the DEP to conduct UST clo-
sures, began work. Seven USTs, along with dispensers and
associated piping, were cleaned and removed in order to
assess the extent of the contamination. Significant petro-
leum contamination was observed in some of the excava-
tions, and approximately 300 tons of visibly contaminated
soil were subsequently removed for off-site disposal. The
DEP will review soil and groundwater sampling results to
learn the extent and migration patterns of any additional
-------
March 2010 • LUSTLine Bulletin 64
Cleanup work at Malcolm's service station in Pennsylvania.
contamination and determine if further assessment of soil
and groundwater is needed to complete the cleanup. The
initial assessment is expected to provide two to five tem-
porary jobs.
Approximately 25,000 people live in the 13.8 square
mile Warrington Township. Designated as the gateway
to historic Bucks County, the Township is nestled amidst
both agricultural and preserved lands. Cleaning up the
former Malcolm's Gas Station and Auto Repair Shop site
is an important first step that will allow the property to be
returned to a useful purpose. Local residents and town-
ship officials are ecstatic that this community eyesore is
on the road to redevelopment.
EPA provided the DEP with $6.163 million to assess
and clean up contamination released from federally regu-
lated USTs. Pennsylvania identified 71 eligible abandoned
sites where USTs may have leaked, impacting soils and
groundwater.
More Stories Abound
These three stories are but a few examples of the impor-
tant role of LUST Recovery Act money in assessing and
cleaning up UST releases across the country. I know there
are other, untold stories similar to these throughout our
nation. I am personally very proud to be a part of our
work to implement the LUST provision of the American
Recovery and Reinvestment Act of 2009. And I am pleased
that together states, territories, tribes, USEPA, and other
UST partners are making a real difference—for human
health, our environment, and our economy. •
THE TOP TEN LNAPL MYTHS
by San joy Garg
Typically, when liquid petro-
leum hydrocarbon, also known
as light nonaqueous-phase
liquid (LNAPL), is inadvertently
released onto or into the ground, it
migrates vertically downward, and,
if sufficient in volume, it eventually
reaches the water table. Depend-
ing on its saturation, the LNAPL
may flow into observation wells.
The terms "free product," "sepa-
rate-phase hydrocarbon (SPH),"
or "phase-separated hydrocarbon
(PSH)" are also used to indicate the
presence of LNAPL in observation
wells. Irrespective of its occurrence
in observation wells, LNAPL can
act as a source of contamination for
groundwater or vapor.
Existing technical and regulatory
frameworks are robust in addressing
groundwater and vapor pathways
if there is no LNAPL in observa-
tion wells. However, when LNAPL
appears in observation wells, the
state of practice is generally lag-
ging behind the state of knowledge,
which has undergone significant
development in recent years. This
gap can result in suboptimal deci-
sion-making and the misdirection of
effort and resources (e.g., perform-
ing hydraulic recovery of LNAPL,
regardless of its recoverability, to
reach an unrealistic thickness; infer-
ring that LNAPL is absent simply
because it is not observed in wells;
pumping LNAPL to address dis-
solved-phase contamination or
vapor issues).
Given that we have gained
some very useful information about
LNAPL, I'd like to point out the
ten most common myths related
to LNAPL and then set the facts
straight.
MYTH 1: There is no LNAPL
at a site because it has not been
observed in observation wells.
Fact: If the site has persistent
dissolved-phase or vapor issues,
chances are there is LNAPL in the
ground (exception being small
vapor releases). If LNAPL does not
show up in an observation well,
there may be some perfectly good
reasons why—it is below residual
saturation; it is limited to the vadose
zone; the observation wells are not in
an area of high enough LNAPL satu-
ration; the wells are not screened in
the appropriate zone.
MYTH 2: LNAPL thickness in
observation wells is exaggerated by
a certain factor (e.g., 4 to 10) when
compared to the actual thickness in
the ground.
Fact: LNAPL thickness in a well
is usually not an exaggeration of
the LNAPL-impacted thickness in
the ground. For unconfined condi-
tions and in areas that are not greatly
affected by water-table fluctuations,
the thickness in the well is similar
to (actually somewhat greater than)
that in the ground (Huntley, 2000).
In some specific cases, LNAPL thick-
ness in wells can be exaggerated
(e.g., when LNAPL appears under
perched or confined conditions).
MYTH 3: The presence of LNAPL
in observation wells means that all
pores in the formation are filled
with LNAPL (i.e., the LNAPL is
present at 100 percent saturation).
Fact: We know that when a moni-
toring well contains groundwater,
• continued on page 10
-------
LUSTLine Bulletin 64 • March 2010
• LNAPL Myths from page 9
the formation pores are practically
100 percent filled with water, so we
tend to believe that LNAPL must
be analogous. In reality, LNAPL is
never at 100 percent saturation in
the pores. Average LNAPL satura-
tion can vary from less than 10 per-
cent in fine-grained soils to greater
than 50 percent in very coarse soils.
For example, the API LNAPL param-
eters database contains LNAPL satu-
rations ranging from 0.01% to 56%
for 100 samples from varied soil
types (API, 2006). LNAPL saturation
depends on the observed thickness
in the well and the soil type. For a
given soil type, the LNAPL satura-
tion is higher for a greater observed
LNAPL thickness (e.g., a sand with
3 feet of observed LNAPL thickness
will have a higher LNAPL satura-
tion than that with a 6-inch thick-
ness). For a given observed LNAPL
thickness, a coarser-grained soil will
have a higher saturation (e.g., a sand
will have a higher saturation than a
silt with the same thickness). This
misconception often results in a sig-
nificant overestimation of in-place
volume, which is frequently calcu-
lated from measured LNAPL thick-
ness in observation wells.
MYTH 4: Observed thickness of
LNAPL in wells is a good metric for
LNAPL recoverability.
Fact: We know that the presence of
groundwater in a well does not neces-
sarily indicate recoverable groundwa-
ter and that its transmissivity, which
is a measure of permeability and satu-
rated thickness, is the true indicator
of its recoverability. Similarly, LNAPL
thickness in an observation well is
also not a comprehensive indicator of
LNAPL recoverability. LNAPL recov-
erability depends on the soil type,
the thickness of the mobile LNAPL
zone, and LNAPL saturation and
viscosity. LNAPL transmissivity is a
lumped parameter that accounts for
all of these variables (Huntley, 2000;
API, 2004a). LNAPL transmissivity is
being increasingly utilized as a metric
for LNAPL recoverability.
MYTH 5: LNAPL can be fully
recovered from the subsurface by
hydraulic methods (e.g., pump and
treat, dual-phase extraction, skim-
ming).
Fact: The theoretical limit for
recovery of any fluid from a porous
media is its residual saturation (Mer-
cer and Cohen , 1990). For example,
once squeezed, a kitchen sponge is
at the residual saturation of water.
Further, transmissivity of a fluid
decreases with decrease in its satu-
ration and is ultimately zero at
residual saturation. For these rea-
sons, it is easier to initially remove
water from a wet sponge but it gets
progressively harder as the water
content decreases. LNAPL too can-
not be pumped effectively once it
approaches its residual saturation;
at this point LNAPL transmissivity
is greatly reduced. The remaining
LNAPL can continue to be a source
for dissolved or vapor phases (Mer-
cer and Cohen, 1990; Huntley and
Beckett, 2002). Typically, the fraction
of LNAPL recovered is greater in the
case of new releases (a few days to
a few months after the release) and
significantly less for older releases.
Early recovery efforts also prevent
the LNAPL from expanding, which
in turn reduces the LNAPL footprint
to be managed or remediated in the
long term.
MYTH 6: Risk-based frameworks
are not applicable until LNAPL is
recovered from wells.
Fact: LNAPL is present in the for-
mation before and after the hydrau-
Before Hydraulic Recovery of LNAPL
r
M
CL
z
1
o
J
c
o
CO
CD
LJJ
(
ig ^ Potential source for aw
and/or vapor impacts
< > Potentially Mobile
or recoverable LNAPL
I/
y
f
/ Residual Saturation
D LNAPL saturation 100
(% of pores filled with LNAPL)
After Hydraulic Recovery of LNAPL
Q_
z
_l
W
o
\l
o
§
CD
LJJ
^_^^ Potential s^iir^p fnr gw
and/or vapor impacts
^^^^
r
3 LNAPL saturation 100
(% of pores filled with LNAPL)
LNAPL, at best, can be removed to residual saturation range via hydraulic recovery. LNAPL can be a source of groundwater or vapor
impacts even after it is removed from monitoring wells. When LNAPL is observed in monitoring wells (as SPH) additional consider-
ation is the evaluation of its migration potential.
10
-------
March 2010 • LUSTLine Bulletin 64
lie recovery of LNAPL. Thus, there
should be little change in how the
risk pathways (dissolved phase,
vapor, or soil pathways) are evalu-
ated. When LNAPL is observed in
a well, the additional concern that
should be evaluated is its potential to
migrate. If LNAPL is migrating, then
future receptors also need to be eval-
uated for risk (API, 2004b).
MYTH 7: Hydraulic recovery of
LNAPL substantially reduces vapor-
or groundwater-related risks.
Fact: These risks are primar-
ily a function of LNAPL composi-
tion and not its saturation (e.g., the
mole fraction of benzene in gaso-
line determines its concentration in
groundwater and not the amount or
saturation of gasoline). Saturation
generally affects the longevity of risk
(Huntley and Beckett, 2002). A suit-
able way to alter LNAPL composi-
tion (e.g., soil vapor extraction and
air sparging) may be more appro-
priate to reduce risk than hydraulic
recovery of LNAPL.
MYTH 8: If LNAPL is present in
a well, then the LNAPL plume is
migrating.
Fact: If LNAPL appears in a well,
the LNAPL is locally mobile near
the well, but additional analyses are
required to determine whether the
overall LNAPL body is migrating.
Most LNAPL bodies come close to a
stable state within a few years after
a release. For LNAPL to move, a cer-
tain minimum amount of LNAPL
pressure is required to displace the
preexisting groundwater—known as
the pore entry pressure. This means
that LNAPL may be present in
observation wells at the edge of the
LNAPL plume, but the plume may
not be able to migrate into pristine
downgradient pores if the pore entry
pressure is not overcome. Pore entry
pressure is lower for coarser-grained
soils. There is no pore entry pres-
sure when LNAPL flows into pores
that previously contained LNAPL
(e.g., LNAPL flow to a recovery well
located in the middle of a LNAPL
plume). Charbeneau (2007) presents
the development of a critical LNAPL
thickness in a well, below which
there can be no lateral migration into
pristine medium.
MYTH 9: Like groundwater,
LNAPL plumes move indefinitely
until they reach a natural boundary
such as a river.
Fact: While this is true for ground-
water, which is essentially infinite,
it is not the case for finite LNAPL
releases. In this case, as LNAPL
migrates, progressively less and less
LNAPL is present at each subsequent
downgradient location (i.e., LNAPL
conductivity continuously decreases
as the plume migrates). Eventually
the LNAPL in the leading edge of the
plume is insufficient to migrate, and
the plume stops.
MYTH 1O: Sophisticated site
characterization is always necessary
for sound decision-making at sites
with free LNAPL (e.g., petrophysi-
cal data, CPT/LIF).
Fact: Many different data-collec-
tion techniques are available, includ-
ing standard soil- and well-sampling
techniques, and newer coring and
petrophysical techniques. Selecting
the right tools depends on what is
needed to fill a knowledge gap, the
magnitude of risk, and the complex-
ity of the site. For the most part, espe-
cially for smaller sites, conventional
data (soil, groundwater, soil-gas data)
are adequate for decision-making. In
some cases, where there is a need for
additional information or for larger,
complicated sites, advanced data col-
lection techniques can be applied.
For example additional data may
be required if the following types of
information are necessary for deci-
sion-making: total LNAPL volume in
the subsurface; recoverable volume
of LNAPL; migration potential of
LNAPL; high spatial density charac-
terization of the area; and mathemat-
ical modeling.
LNAPL Scenarios
In summary, LNAPL presence at sites
can be classified into three scenarios:
A. LNAPL is present in the subsur-
face but not in observation wells (i.e.,
it is below residual saturation).
B. LNAPL is present in observation
wells but the LNAPL plume is stable.
C. LNAPL is present in observa-
tion wells and the LNAPL plume is
migrating.
In all three cases, the LNAPL can
result in the generation of dissolved-
phase and vapor-phase contamina-
tion. In all cases, these risks can be
evaluated using the well-established
risk-based procedures. From a risk
and remediation perspective, Sce-
nario B is usually more similar to
Scenario A than it is to Scenario C.
Yet, significant resources are spent
to hydraulically recover LNAPL
from Scenario B. Scenario C can pose
additional risks due to the expan-
sion of the LNAPL plume that need
to be identified and addressed. Dis-
tinguishing between the three sce-
narios (especially between B and C),
and making appropriate remedial
decisions, can significantly improve
resource and risk management at
LUST sites. •
Sanjay Garg, Ph.D., is a consultant
with Shell Global Solutions. He can be
reached at sanjay.garg@shell.com.
References
API, 2004a. API Interactive LNAPL Guide. Path:
Educational Information/Mobility, Stability, and
Recoverability LNAPL Mobility and Conductiv-
ity (http:/ /www.api.org/ehs/groundwater/
Inapl/lnapl-guide.cfm).
API, 2004b. API Interactive LANPL Guide. Path:
Assessment Tools/LNAPL Risks/LNAPL Risk
— Conceptual Overview (http://www.api.org/
ehs / groundwater / Irtapl / Inapl-guide.cfm).
API, 2006. LNAPL Parameters Database (http://
www.api.org/ ehs / groundwater / Inapl /
Irtapl-params-db.cfm).
Charbeneau, R. 2007. LNAPL Distribution and
Recovery Model (LDRM) Vol 1. Distribution
and Recovery of Petroleum Hydrocarbon Liquids
in Porous Media, Section 3.3. API Publication
Number 4760.
Huntley, D. 2000. Analytic Determination of
Hydrocarbon Transmissivity from Baildown
Tests. Groundwater, Vol 38, No.l pp 46-52.
Huntley D. and Beckett, G.D., 2002. Evaluating
Hydrocarbon Removal from Source Zones and its
Effect on Dissolved Plume Longevity and Magni-
tude, API Publication Number 4715.
Mercer, J.W., Cohen, R.M., 1990. A Review of
Immiscible Huids in the Subsurface: Proper-
ties, Models, Characterization and Remedia-
tion. Journal of Contaminant Hydrology, 6:pp.
107-163.
Selected Resources
• ITRC: http://www.itrcweb.org/teampublic_
LNAPLs.asp; Training and Documents.
• API Website: www.api.org/lnapl.
• NAPL Cleanup Alliance: www.rtdf.org/public/
napl.
• ASTM: http://www.astm.org/; ASTM LNAPL
Decision Guide (E50.04 July 2005).
• SABCS British Columbia http://www.sabcs.
chem.uvic.ca/docs.html.
11
-------
LUSTLine Bulletin 64 • March 2010
- Jit/ca/fy Speaking
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 cjuestions. If there are technical
issues that you would like to have
Marcel discuss, let him know at
marcel.moreau@juno.com.
If I Had to Choose Just One Way of A
UST Operational Compliance.
Sometimes, because we work
with tank issues on a daily
basis, we forget the simple
truth—operating a tank in today's
world is a complex task. I was
reminded of this recently when an
associate, who is a professional engi-
neer but not a tank professional,
reviewed an UST-operators man-
ual I've been working on and pro-
claimed, "Wow, there sure is a lot to
operating a tank!" Indeed. There is
leak detection for tanks and piping,
spill containment, overfill preven-
tion, corrosion protection, financial
responsibility, spill reporting and
cleanup, investigating suspected
releases, and a lot of regulatory
paperwork. Besides that, UST opera-
tors have to be concerned with prod-
uct compatibility and quality issues
(ethanol), minding fuel inventory,
pricing fuel, keeping the appropriate
amount of inventory on hand, cus-
tomer drive-offs...and, oh yeah, how
about being sure the fire extinguish-
ers have been serviced?
UST operators in the C-store
business have a much longer list of
concerns, everything from whether
the cash register person has shown
up for work, to liquor and cigarette
sales to minors, expiration time of
the food, temperature of the beer
cooler, and cleanliness of the public
bathroom. It is no wonder that issues
near and dear to an UST regulator's
heart, such as appropriate response
to a leak alarm, might get buried
among the day-to-day tasks of most
UST operators.
Would I Choose Operator
Training?
And while bathroom cleanliness
and even alcohol sales to minors
12
tend to be concerns that the average
person is at least somewhat famil-
iar with, understanding the signifi-
cance of an "LI Fuel Alarm" is not
something that parents commonly
teach their children. It makes sense,
therefore, that there should be some
formal education associated with
operating UST systems. For many
UST operators, however, taking an
UST operator course will have all
the allure of a course in intermediate
algebra, and the retention of infor-
mation will be commensurate with
the interest.
Would I Choose an Operator
Checklist?
A number of states are instituting the
use of periodic checklists to help UST
operators remember what it is they
should be doing. The checklists serve
to document that UST equipment
has been visually checked and found
to be in operating condition. The
Petroleum Equipment Institute (PEI)
Recommended Practices (RP500 for
dispensers, www.pei.org/RP500, and
RP900 for UST systems, www.pei.
org/RP900) provide good models for
those who are interested in adopting
such checklists. (In the interest of full
disclosure, I was the consultant who
worked with PEI committees to pro-
duce both of these Recommended
Practices.) While having UST opera-
tors visually check on the condi-
tion of their facilities on a daily and
monthly basis is a great idea, I also
see the potential for rampant "pencil
whipping" of checklist forms, where
a checklist that is supposed to be
completed at a dispenser or tank pad
in 10 or 15 minutes is completed in
seconds back in the office.
Would I Choose an Annual
Operational Inspection?
In my book, the most important
inspection checklist in the PEI docu-
ments from an operational compli-
ance standpoint is the annual one. A
qualified technician who has all the
required tools and training to perform
any typical service-related operation
pertinent to USTs, as defined by PEI
RP500 and RP900, conducts the annual
inspection. The qualified techni-
cian, in other words, is a professional
UST service person, not your typical
UST owner or operator. The annual
inspection, besides checking on all the
things that the UST operator should
be routinely checking, also goes into
much greater depth (e.g., operation
of line leak detectors, crash valves,
nozzles, cathodic-protection systems,
overfill-prevention equipment, emer-
-------
March 2010 • LUSTLine Bulletin 64
gency shut-off switches). In short, the
annual inspection is comparable to an
annual automobile inspection, mak-
ing sure that all the essential systems
are in good operating condition.
The annual inspection has many
things to recommend it, including:
• A knowledgeable person
reviews the entire system. UST
systems today are beyond the
ken of all but a few UST opera-
tors. Routine visual inspections
are good, but how many opera-
tors really have a clue about what
they are looking at and what they
should be looking for? Qualified
technicians look at this hardware
day in and day out. They know the
weak points and the strong points
of most common equipment and
can tell when something is not
"right." Qualified technicians also
have the skills and equipment to
actually put important equipment
through its paces and verify that it
actually works the way it should.
• One phone call does it all. An
UST operator doesn't have to
remember to have line leak detec-
tors tested, lines tested, cathodic
protection tested, ATGs main-
tained, interstitial sensors tested,
crash valves checked, spill buck-
ets looked at, overfill prevention
checked, etc., etc., etc. All he or she
has to do is make one call and say,
"I need an annual inspection," and
the qualified technician does the
rest. The checklist of what must
be done should be specified by the
state, so if the operator wants to
get several quotes, all technicians
are bidding on the same work, and
the bids should be directly compa-
rable to one another.
• The UST system gets "exer-
cised." Folks who operate emer-
gency generators typically run
them for a short time once a month
or so to "exercise" them. Mechani-
cal things with moving parts need
to move on a regular basis so
they don't freeze up. Many of the
critical parts of UST systems like
crash valves, overfill valves, inter-
stitial sensors, and emergency
shutoff switches may sit idly by
for long periods of time, but it is
critical that they operate properly
when they are needed. Like emer-
gency generators, they need to be
The annual UST inspection is an in-depth look at the condition of all the peripheral components of
an UST system to verify that they are operational and in good condition.
Qualified, conscientious UST technicians are an essential component of an annual inspection
program.
exercised once in a while so they
don't freeze up.
• A third party takes an objec-
tive view of the system. While a
facility operator may be complet-
ing a facility checklist and mark-
ing everything as being in good
condition, a qualified technician
inspecting the same facility might
notice a deep cut on a dispenser
hose, a leaking breakaway, or a
spill bucket that has corroded
through. These are all things that
the UST operator should have
noticed but didn't see for reasons
ranging from near-sightedness to
over-sightedness to carelessness.
A conscientious owner of this facil-
ity who is comparing the operator
checklist to the technician check-
list might decide that the operator
needs a little "refresher" train-
ing in what to look for during an
inspection. A not-so-conscientious
facility owner might be thinking
that he's glad the UST operator
is not wasting time completing a
checklist that the darn fool regula-
tors want him to complete.
Either way, the problems are iden-
tified and will hopefully be fixed.
Of course next year the not-so-con-
scientious UST owner might hire a
not-so-conscientious UST inspec-
tor in hopes of finding fewer prob-
lems, so keeping a close watch on
the quality of the work done by
• continued on page 14
13
-------
LUSTLine Bulletin 64 • March 2010
m Achieving UST Operational
Compliance from page 13
inspectors is important as well.
• Problems can get fixed. Maine
initiated an annual inspection pro-
gram a good many years ago. In
2000, I conducted a study for the
State of Maine to review the effec-
tiveness of the program (the report
is available at: http://iviviv.mame.
gov/dep/rivm/publications/ussinspec-
tionreports.pdf). Among the findings
were that about 30 percent of facili-
ties had problems discovered dur-
ing annual inspections, indicating
that problems routinely occur with
UST equipment. A more disturbing
finding was that some 39 percent
of the problems discovered had not
been addressed by the following
year. For an inspection program
to be most effective, there has to
be enforcement. Since 2000, Maine
has beefed up enforcement of the
annual inspection requirement
by requiring that annual inspec-
tions be submitted to the state.
The Department of Environmental
Protection also has the authority to
prohibit deliveries if annual inspec-
tions are not completed or prob-
lems discovered are not corrected.
So What Would I Choose?
I do believe that operator training is
a step in the right direction, but it is
only a step. Routine checklists com-
pleted by UST operators are another
good step, but UST operators are lim-
ited in what they can evaluate. If I had
to choose just one approach to assur-
ing proper UST operation, I would
pick annual inspections by qualified
technicians. I believe annual inspec-
tions have great value because they
simplify the UST operator's life and
standardize what constitutes "proper"
operation of a UST system. In addi-
tion, annual inspections verify that all
the equipment that is just "standing
by," such as interstitial sensors and
line leak detectors and overfill-pre-
vention equipment, is really ready for
action. And isn't that what properly
operating an UST is all about?
What Would You Choose?
Send your choices and reasoning to:
marcel.moreau@juno.com. •
14
Observations on Cathodic-
Protection Operation and
Testing
by Chris Prokop
/work in USEPA Region 9's Underground Storage Tanks Program, and one of
my duties is inspecting UST facilities in Indian Country. So far in my career
with the agency, I have conducted some 150 UST-system inspections. I would
estimate that roughly 25 percent of these systems employ some type ofcathodic protec-
tion (CP) for the tanks, piping, and/or metal connector elements associated with pip-
ing. My purpose in writing this article is to share three examples associated with my
experiences with CP system operation and testing in Region 9 Indian Country. The
examples illustrate a larger problem that has to do with determining how well the CP
tester is doing his job. I hope that what I have learned will be of benefit to all of us who
inspect tank systems.
[Editor's note: For more detailed information on CP operation and
testing, see the LUSTLine Index, which lists several articles we have
published on CP. Among these titles are "Effective Corrosion Con-
trol—Qualified Personnel" (LL #23), "Combating CP-Test Heartburn"
(LL #32), and "Evaluating CP Data" (LL#44). A particularly good
article relating to the subject of this article is "Testing Cathodic-Protec-
tion Systems" (LL #25) by Marcel Moreau. We have freshened up this
article and put it on the NEIWPCC website (www.neiwpcc.org). Click
on LUSTLine and then "online-only supplements."
CP Regulation
Pursuant to the federal regulations
(and, by extension, state and local
regulations), UST systems must be
protected from corrosion in order to
minimize the potential for petroleum
releases. This can be achieved by
using non-metallic components such
as fiberglass, by coating the metal to
isolate it from the electrolyte, or by
using cathodic protection. For older
UST systems, where metallic USTs,
piping, and/or connector elements
are in contact with soil, some form of
CP must be used.
The two types of CP used to
meet federal regulations are: (a) gal-
vanic systems (utilizing sacrificial
anodes), and (b) impressed current
(1C) systems (utilizing rectifiers).
Both galvanic and 1C systems must
be designed by a corrosion engineer
(though galvanic systems may be
"pre-engineered" by the manufac-
turer), and both systems must be
tested at least every three years by
a person with knowledge and/or
training in CP testing (a "CP tester").
For 1C systems, voltage and amper-
age readings (e.g., voltage, amper-
age, hour meter readings) from the
rectifier must be recorded on a writ-
ten log at least every 60 days.
The basic rule for compliance
during the testing of both types of
CP systems is that the polarized volt-
age potentials at all surveyed points
of the UST system must be at least
as negative as -0.85 volts or demon-
stration that 100 mV of polarization
has been achieved. See the NACE
International (formerly known as
the National Association of Corro-
sion Engineers) Standard RP0285
for information on the design of gal-
vanic and impressed current systems.
NACE Standard RP0285 also pro-
vides good background on the basic
CP test criteria, and NACE Standard
TM0101 addresses the testing tech-
niques for CP systems.
Example: Failure to Consider
Voltage Drops During the
Testing of 1C Systems
Until a few years ago, I was not
-------
March 2010 • LUSTLine Bulletin 64
aware of the significance of obtaining
"instant-off" voltage potentials dur-
ing structure-to-soil CP "surveys" of
1C systems. At that time, the poten-
tial data from CP surveys provided
by most VST facilities in Region 9
Indian Country did not, for the most
part, contain instant-off-potential
data or consider voltage (a.k.a. IR)
drops. Instead, the potential mea-
surements were only obtained with
the rectifiers "on."
Obtaining instant-off potentials
is important because accurate polar-
ization potentials cannot be obtained
on 1C systems when the rectifier is
on. Turning off the rectifier results in
more accurate measurements of the
true "polarized" conditions of the
UST systems being protected. Test
Method 1 under NACE Standard
TM0101 allows CP system "on" mea-
surements as long as voltage drops
are "considered," and the standard
lists five methods for considering
voltage drops.
However, none of these five
methods are particularly applicable
to storage tank systems, and all are
beyond the expertise of most CP tes-
ters. As a result, I have begun requir-
ing CP testers to obtain instant-off
potentials because this is the only
practical way for considering voltage
drop in 1C systems. These instant-off
potentials are typically obtained after
the current from the rectifier is inter-
rupted, either manually (by a second
technician) or by means of a device
designed for that purpose.
In follow-up to my observations
of this problem at one UST facility, I
contacted the CP tester to explain my
concern, and I also explained NACE
International's "100 mV polariza-
tion shift" criterion (see Test Method
3, NACE Standard TM0101). In
response to my phone call, the CP
tester agreed to retest the facility. The
new CP survey data for this facility
yielded 14 of 24 instant-off potential
measurements that were more nega-
tive than the -0.85 volt standard (i.e.,
14 measurements passed the test and
10 measurements failed), while 23 of
the 24 measurements "passed" the
100 mV polarization change criterion
(following a two-hour depolarization
period).
The one failing measurement
under the 100 mV criterion was 89
mV, just 11 mV shy of the standard.
The CP tester's conclusion in his
cover letter was that the UST sys-
tem had adequate CP based on the
100 mV polarization criterion. I sup-
ported the CP tester's conclusion
based on the overall strength of the
CP data and the facility's favorable
history of UST and CP system opera-
tions. In addition, NACE Standard
TM0101 notes that extended polar-
ization-decay time periods (even
days) may be needed to achieve a 100
mV polarization shift.
With regard to galvanic systems,
it is my understanding that conduct-
ing instant-off testing is generally not
practical because, at least in the case
of STI-P3 tanks, the anodes are typi-
cally welded to the USTs. In addi-
tion, galvanic systems are intended
to be used with well-coated UST
structures where the exposed metal
surfaces potentially requiring CP are
relatively small ("holidays"), and
voltage-drop effects are minimal.
After my experience with the
facility described above, I contacted
two other CP testing firms that do
work in Region 9 Indian Country,
and they verbally agreed to modify
their testing procedures.
We need to be able to ensure
that CP tests are performed
properly, according to standards
developed by nationally recognized
associations (such as NACE
International). Otherwise what is
the point of doing the tests?
Example: Taking Voltage
Potential Measurements Over
Asphalt or Concrete
Judging from my discussions with
some CP testers, I have come to
believe that CP surveys incorrectly
conducted over asphalt or con-
crete may be a pervasive problem.
Both NACE Standards RP0285 and
TM0101 state clearly that potential
readings "shall not be taken through
asphalt or concrete." Furthermore,
RP0285 indicates that contact with
soil can be achieved through exist-
ing design openings, or by drilling
through the asphalt or concrete to
access the soil beneath. At least one
CP tester has told me, however, that
he has, on occasion, placed his ref-
erence electrode directly on asphalt.
It should be noted that asphalt is a
petroleum-based compound that is
not a conductor.
I have also heard at least one CP
tester refer to placing the reference
electrode directly on concrete follow-
ing thorough wetting of the surface.
Potential measurements over con-
crete are commonly erroneously ele-
vated (which would be exacerbated
by the presence of rebar). It is worth
repeating: CP readings made with
the reference electrode placed on
asphalt or concrete are NOT valid.
Example: Electrical Continuity
Testing/Surveys
I am briefly mentioning this topic
because continuity/isolation testing
is clearly important to the success-
ful operation of CP systems. NACE
Standard TM0101 provides specific
procedures for demonstrating appro-
priate electrical isolation for galvanic
systems and electrical continuity for
1C systems. The standard also lists
a number of "invalid techniques"
for conducting continuity testing.
However, I rarely see continuity sur-
veys in the CP data sets for my UST
facilities. I think it is important that
inspectors request continuity surveys
as a part of CP testing.
What Testers Need to Know,
What Inspectors Need to
Look For
We need to be able to ensure that CP
tests are performed properly, accord-
ing to standards developed by nation-
ally recognized associations (such
as NACE International). Otherwise
what is the point of doing the tests?
A number of states have developed
CP test protocols and forms that tes-
ters must fill out, sketch survey find-
ing on, and sign. Sloppy CP testing
behavior is not going to change until
inspectors refuse to accept improper
test results. As inspectors, we need
to be out there, understanding what
we are looking at and what it means,
and then make sure the tester knows
we are watching. •
Chris Prokop is a hydrogeologist with
the USEPA Region 9 UST program.
He can be reached at
Prokop.Chris@epa.gov.
15
-------
LUSTLine Bulletin 64 • March 2010
from Robert N. Renkes, Executive Vice President, Petroleum Equipment Institute (PEI)
Concerns Grow Over Ultra-Low-Sulfur
Diesel Fuel
When the American Society for Testing and
Materials (ASTM) reduced the sulfur con-
tent of diesel fuel from 500 parts per million
(ppm) to 15 ppm in response to new USEPA mandates
that took effect in 2006, it was good news for the envi-
ronment. What's not to like about lowered emissions
and cleaner air?
At the time, ASTM knew of one possible side
effect — the process of removing sulfur may also reduce
the fuel's natural lubricity. Recognizing this was a seri-
ous concern, ASTM added a minimum requirement
for diesel fuel to provide protection for certain engine
components. Most fuel suppliers turned to lubricity
additives to meet this new requirement.
In a little over a year since the country made the
switch to the 15 ppm ultra-low-sulfur diesel (ULSD),
another possible side effect began to make itself
known. The first rumblings came late in 2007. A hand-
ful of ULSD users on the Petroleum Equipment Insti-
tute (PEI) Forum posted issues with clogged filters,
seals breaking down, excessive rust, and other damage
to their ULSD storage and dispensing systems. Since
then, the number of reports and questions surround-
ing ULSD has grown. What's causing the deteriora-
tion? How bad is it? And where do we go from here?
In January, PEI convened a meeting of industry
stakeholders (oil marketers, additive manufacturers,
Corrosion on the
inside of the fill
pipe. Corrosion is
visible on the steel
fill riser and the
brass fill adapter.
There was no drop
tube present in this
fill pipe.
Corrosion on the
inside surface of
the submersible
pump manifold
(the part of the
pump that sits
above the tank).
This area would
be exposed
to fuel vapors
but would not
normally be in
contact with any
liquid product.
The joint between the submersible pump motor casing (aluminum on
the left) and the steel piping on the right. This joint area would normally
be submerged in the fuel.
USEPA, equipment groups, trucking industry, and stan-
dards organizations) to discuss this matter. PEI called
the meeting because we have received accounts of this
problem from all regions of the country, in both newer
and older equipment, in high- and low-use situations.
But the corrosion problems don't appear everywhere
and excessive deterioration does not seem to appear at
all facilities in a particular market.
Participants in the meeting stressed that they had
firsthand knowledge of only a few incidents of corro-
sion and by some accounts reports had not increased
over time. Although many at the meeting had not seen
corrosion on a large scale, a fair number of them were
still in an information-gathering mode.
The stakeholders group agreed to take a two-
pronged approach to investigate the problem. The first
step is to determine if the corrosion problem is isolated
or more widespread. A task force of the stakehold-
ers group developed a brief survey for fuel suppliers,
tank owners, equipment manufacturers, ULSD-facility
service providers, and tank and/or equipment inspec-
tors to try to get a handle on how pervasive the prob-
lem is. The online survey takes less than two minutes to
complete and can be found at www.ulsdsurvey.com. The
deadline for completing the survey is Tuesday, April 6
(unfortunately, this issue of LUSTLine will hit the streets
slightly after the deadline).
If the results indicate substantial, widespread
issues, then the second step will be to conduct a system-
atic, integrated evaluation of the problem—with prob-
ably another, more in-depth survey—and suggest a
solution. •
16
-------
March 2010 • LUSTLine Bulletin 64
A Cautionary Note About DEF
The following letter is from a former UST regulator.
It was with some dismay that I read the article titled "DEF, It's as easy
as One, Two Three, as Simple as Do Re Mi" in the latest issue of LUST-
Line. The urea in diesel exhaust fluid (DEF) contains nitrogen. Most of
us are familiar with nitrogen as a plant fertilizer, but nitrogen in ground-
water can cause something known as blue baby syndrome (methemoglo-
binemia)—a nitrogen compound called nitrite interacts with hemoglobin
forming methemoglobin. The methemoglobin cannot carry sufficient oxy-
gen to the body. This condition is most common in infants in areas where
nitrate-contaminated water is used to make up baby formula and other
infant drinks. Bacteria in the human body, in food, and in soils convert
the nitrate to nitrite as part of the nitrogen cycle. USEPA has established
a drinking water standard of 10/mg/L for nitrates because of the human
health hazard. This is an acute standard, and little work has been done on
determining what the physical effects of long-term exposure to lower lev-
els of nitrate might be.
Although nitrate is not a petroleum product, it can have negative
health effects and if stored in an underground tank some sort of leak
detection monitoring of the tank and associated underground piping
would seem to be appropriate, especially at locations near public or pri-
vate drinking water wells.
I worked as a regulator of underground oil tanks for 15 years and now
work as a compliance inspector for wastewater treatment facilities. It is this
work that has made me aware of the health issues associated with nitrates
in drinking water. State regulators should consider this issue when decid-
ing whether and how to regulate tanks storing DEF.
I bring this to your attention simply because my job experience has
made me aware of the hazards associated with nitrates. I am speaking
solely as a private individual whose experience has given me the knowl-
edge to recognize this hazard. •
For those of you that don't know,
the current issue of LUSTLine
is available for download as a
PDF at www.neiwpcc.org/lust-
line. Besides having a full-color
version of the current issue, the
LUSTLine website also features
online-only supplements, archived
issues dating back to November,
2000, and the LUSTLine Index,
which provides a complete list
of every article ever published
in the bulletin, broken down by
category. NEIWPCC would like
to encourage our readers to take
advantage of this electronic,
paper-saving deal.
If you are interested in
accessing LUSTLine online,
rather than receiving a print
copy, please let NEIWPCC know!
We will send you a notification
via email when the new issues
are posted. Simply send your
Name, Organization, and Email
Address to lustline@neiwpcc.org
to remove your name from the
hard-copy mailing list and receive
the electronic notifications.
Thank you!
NRPSHOTS FROM TH€ FICLD
17
-------
LUSTLine Bulletin 64 • March 2010
FAQs from the NWGLDE
...All you ever wanted to know about leak detection, but were afraid to as/
Evaluating ATGs for a 0.1 gph Leak Rate
In this LUSTLine FAQs from the National Work Group on Leak Detection Evaluations (NWGLDE), we clarify how ATGs are listed
after being third-party evaluated for detecting a 0.1 gph leak. Please Note: The views expressed in this column represent those of
the work group and not necessarily those of any implementing agency.
\J.. If an automatic tank gauge (ATG) is certified to
find 0.1 gph leaks, can it be used as a tank tightness
test?
A. Automatic Tank Gauges (ATGs) that have been cer-
tified to detect leaks of 0.1 gph are evaluated using
the EPA Standard Test Procedures for Evaluating Leak
Detecting Methods: Volumetric Tank Tightness Testing
Methods in addition to the ATG protocol, EPA Stan-
dard Test Procedures for Evaluating Leak Detecting Meth-
ods: Automatic Tank Gauging Systems. The Volumetric
Tank Tightness Testing (VI11) protocol requires the
method to demonstrate that it can detect leaks as
small as 0.1 gph with at least a 95 percent probability
of detection (Pd) and no more than a 5 percent prob-
ability of false alarm (Pfa).
There is an important difference in the third-party
evaluations for ATGs and Volumetric Tank Tight-
ness Testing methods. While the ATG protocol does
not require the determination of groundwater depth
during third-party evaluations, VTTT methods are
required by the protocol to determine the depth to
groundwater in the tank excavation backfill. This
is done to see if groundwater is at or above the bot-
tom of the tank. This is important because ground-
water above the bottom of a tank can result in water
intrusion into a hole in a tank due to high hydro-
static pressure. Any tank that can take on water has
the potential to release fuel if there are fluctuations
in the groundwater level, or if fuel is added to the
tank, causing the hydrostatic pressure relationship
between fuel inside the tank and water outside the
tank to change.
The VI11 protocol also requires these test methods
to have a means to account for and compensate for
the presence of groundwater if it is detected at or
above the bottom of the tank. Methods designed for
compensation due to groundwater adjust the product
level in the tank to create a positive pressure from the
product at the bottom of the tank, thus negating the
effects of a high water table.
There is no such requirement for ATGs in the USEPA
ATG protocol. ATGs are not required to detect the
depth to groundwater in tank excavations and com-
pensate for groundwater if it is at or above the bot-
tom of the tank. In regions where groundwater
levels are typically below the bottom of the tank and
groundwater is not a factor, the use of an ATG to con-
duct a tightness test may be acceptable. In other areas
where groundwater is above the tank bottom, slow
water ingress might go undetected until it reaches
the ATG level where the high-water alarm is acti-
vated. Be aware that a static ATG test only evaluates
the portion of the tank that is holding fuel when the
test is conducted, and most tests are conducted when
the tank is less than full. Therefore, a static ATG test
result would only be representative of a portion of the
tank. Another method, such as an ullage test, would
need to be used in conjunction with an ATG test if
the objective is to test the entire tank. VI11 underfill
tests would also only test the wetted portion of the
tank, but typically these tests are supplemented with
ullage testing that would test the remaining unwet-
ted portion of the tank.
Since ATG test methods do not account for ground-
water levels, they are not listed by NWGLDE as a
VI11 method. Whether to accept the use of a 0.1 gph
ATG test as equivalent to a VTTT and, if so, under
what conditions, is ultimately the decision of each
implementing agency. •
About the NWGLDE
The NWGLDE is an independent work group comprising ten
members, including nine state and one USEPA member. This
column provides answers to frequently asked questions (FAQs)
the NWGLDE receives from regulators and people in the indus-
try on leak detection. If you have questions for the group, please
contact them at questions@nwglde.org.
Oops!
In the last FAQs from the National Work Group on
Leak Detection Evaluations (LUSTLine #63, "More
Questions on Throughput!"), we left out some impor-
tant words at the very end of the answer to the ques-
tion: Why do some listings have throughput limits
while others do not? So, please accept our humble
apology and note the complete text for the end of that
question:
"Unfortunately, the current SIR protocol does
not include a throughput limit like the CLTLDS
protocol. Because of this, the NWGLDE has
included the throughputs from the data sets
used during the third-party evaluation of the
SIR methods. The NWGLDE provides this
information for state agencies that may want
to consider using this monthly throughput as a
throughput limit."
18
-------
March 2010 • LUSTLine Bulletin 64
Kentucky's Compliance
Assistance Calendar for Gas
Stations
^^ ««• « i^^i • ^^
The Kentucky Division of Compliance Assistance
in partnership with the Division of Waste Man-
agement's Underground Storage Tank Branch has
developed a multimedia 2010 Environmental Steward-
ship Calendar for Gasoline Stations, The calendar is the
first step in a series of outreach efforts targeted at this
sector. It is part of a pilot project to evaluate the effec-
tiveness of repeat communication and contact with gas
station owners resulting in increases in compliance and
environmental stewardship behaviors.
The calendar covers topics ranging from compli-
ance with UST, air quality, water, and waste regulations
to encouraging green behaviors such as recycling,
energy efficiency, and resource conservation. In addi-
tion to the calendar, the pilot counties will receive
follow-up materials such as a green scorecard, com-
pliance checklists, and targeted training on new regu-
lations such as the National Emission Standard for
Hazardous Air Pollutants for Gasoline Distribution
Facilities SubpartBC.
A primary goal of the project is to increase com-
pliance rates and at the same time encourage positive
environmental stewardship behaviors and membership
into Kentucky's environmental leadership program, KY
EXCEL. Upon completion, the project outcomes will also
be used to evaluate future environmental stewardship
and compliance outreach and communication materials
for the sector statewide. For more information, contact
Kenya Stump at 502-564-0323. To see the calendar, go
to http://www. small biz-en viro web, org/Compliance/cal-
endarfiles/KYgasstationcalendar20 1 0.pdf, •
2010 Environmental Stewardship
Calendar for Gasoline Stations
frPCA
43
•§•
'•'^HE^6
Im tsBr
.j3LJts
.,
\7
UST Program Pioneer Bill Torrey
Says Goodbye Tanks, Hello
Gardening and Fermenting
l~n November 1984, while
1 working in USEPA Region ^^B ^^
JLl's (New England) RCRA ^^
Subtitle C Hazardous Waste A •
program, Bill Torrey was asked ' •
to help start a new program to
rein in the problem of leaking ~^~^7^
underground storage tanks in
the region. Region 1 had been
working closely with its states
for several years to enhance
awareness of a broad spectrum
of groundwater management
and protection issues. In fact,
since January 1984 the New
England Interstate Water Pollu-
tion Control Commission (NEI-
WPCC) had been providing a
forum for the six New England states and New York State to meet
and share experiences regarding leaking underground storage
tanks and formalize and foster compatible state UST regulatory
programs. Bill Torrey guided the states all along the way.
On November 8, 1984, USEPA's mandate to regulate
underground storage of petroleum products and hazardous
substances (RCRA Subtitle I) was signed into law. USEPA head-
quarters turned to the experiences of the New England states,
which already had initial statutory authorities to regulate tanks,
one had already initiated a notification/ registration process, and
all were set to get busy writing regulation. Bill Torrey helped
make the connections with his states and the new federal pro-
gram. He even wrote a column in the first issue of LUSTLine in
o
August 1985, giving other states a sense of how things were tak-
ing shape in New England.
Bill was a steadfast, guiding presence for the New England
state tank programs for more than 25 years, but in December
2009, he bade his friends in the tanks program farewell. While
he may have retired from tanks, we all know what this brew-
meister/ gardener par excellence is up to. We'll miss you Bill, but
we also know you are having lots of fun doing what you really
love. 1
V|§jl L.U.S.T.LINE Subscription Form
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Mailing Address
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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 1 16 John Street, Lowell, MA 01852-1 124
Phone: (978) 323-7929 • Fax: (978) 323-7919 • lustline@neiwpcc.org • www.neiwpcc.org
19
-------
LUST. .INE
New England Interstate Water
Pollution Control Commission
116 John Street
Lowell, MA 01852-1124
iNElWPCC
ASTSWIHO [fiMassDEP u
22"1 National
TRNKS
The 2010 National Tanks Conference
will be held September 1 9-22, 201 0 at the Westin
Hotel Boston Waterfront in Boston, MA. The National
Tanks Conference Website (www.neiwpcc.org/
tanksconference) contains all conference information
including agendas, registration, exhibitors, hotel,
and destination information, and much more.
Exhibitor registration is currently open and
attendee registration is expected to open in May. Please check the website often for more
information and updates!
September 20-22,2010
www.neiwpcc.org/tanksconference
Exhibiting at the 22nd National Tanks Conference and Expo
As in the past, the 2010 National Tanks Conference and Expo will showcase the latest and
greatest in tanks-related products and services. We invite you to join us in Boston to exhibit
your product or service to the 500+ anticipated attendees. Interested in exhibiting?
Contact Michele Piazza (mpiazza@neiwpcc.org, (978) 323-7929) for more information or visit
the Exhibitors section of our website!
LU.ST.LINE INDEX
August 1985/Bulletin #1
May 2009/Bulletin #61
The LUSTLine Index
is ONLY available online.
To download the
LUSTLine Index, go to
http://www. neiwpcc. org/lustline/
and then click on LUSTLine.
NOTE: If you were fascinated
and/or grossed out by Bob Renkes'
article and photos on ultra-low-sul-
fur diesel fuel, page 16, you might
want to read an excellent article
titled "Microbes and Fuel Systems:
The Overlooked Corrosion Prob-
lem" by Fred Passman in LUSTLine
#39, November 2001. We have put
this article on the NEIWPCC web-
site (www.neiwpcc.org). Click on
LUSTLine and then "online-only
supplements."
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