New England Interstate
Water Pollution Control
Commission
www.neiwpcc.org/lustline
116 John Street
Lowell, Massachusetts
01852-1124
LUS.T.UNE
A Report On Federal & State Programs To Control Leaking Underground Storage Tanks
Bulletin 65
June
2O1O
Operator Training Has Left the Station...
So Where Are State Programs Headed?
by Marcel Moreau and Ben Thomas
UST OPERATOR TRAINING: Will it radically improve our UST compliance rates, or will it be another add-
on regulation that regulators and UST owners must endure? The crystal ball is still fuzzy and we're not making any
predictions, but we thought it might be useful to review some of the diverse approaches that states are taking toward
implementing the operator training requirements of the 2005 Energy Act.
As we write, the deadline for training UST operators
in Oregon and California passed some five years
ago, and Colorado has had a training requirement
in place for a few months. New Mexico is beginning to
implement its operator-training requirement this year. A
few states like Louisiana have a deadline of 90 days after
the next upcoming compliance inspection, and Minnesota
deadlines will be driven by area code (novel but painful
for large operators). Most other states, as far as we can
determine, are aiming for a training deadline of August
8, 2012, the deadline set in the Energy Policy Act of 2005
(EPAct). A number of states have training mechanisms or
at least training plans already in place in anticipation of
the 2012 deadline; however, it looks like a few states may
not meet the deadline.
• continued on page 2
Inside
22 (
9ft I
Transition—Part 2
Release, Remediate, Repeat
Not for the Squeamish!
Plugging the Rest of the Leaks
From Our Readers
What's New at USEPA?
Short List of Potential UST Reg Changes
FAQs: Continuous Leak Detection Methods
ULSD, ULSD, ULSD...
-------
LUSTLine Bulletin 65 • June 2010
m Operator Training Programs
from page 1
The focus of state programs is
to establish training mechanisms for
what the EPAct defines as Class A and
Class B operators. Class A operators
can be loosely defined as "owners"
and Class B operators can be loosely
defined as "facility managers." The
EPAct also establishes a Class C
operator that can be loosely defined
as "clerk." (See USEPA's guidance
document on operator training for the
official definitions of these operator
classifications at www.epa.gov/oust/fed-
laws/otggjinal080807.pdf.)
Because of the large overlap in
Class A and Class B operator knowl-
edge and the relatively small number
of people who are strictly Class A
operators, a number of states are pro-
viding for a combination Class A/B
operator. Class C operators can be
trained by Class A and B operators,
so states are not focusing on estab-
lishing programs to directly train this
class of operator, but several private-
sector training providers are promot-
JL.U.S.T.Line
EUen 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
<££) LUSTLine is printed on recycled paper.
Links to State Internet-Based Training Programs
MONTANA
TankHelper2 - https://app. mt.gov/tank2/
OKLAHOMA
Operator Training - http://www.occeweb.com/operatortraining
MAINE
Ta n kS m art - http://www. maine.go v/dep/rwm/ust/tanksmartonlineservice. htm
SOUTH CAROLINA
UST Training System -
http://www. scdhec. go v/en vironment/lwm/UST_ Training/Default, aspx
ing training specifically for Class C
personnel.
In this article we will focus spe-
cifically on the approaches that states
are taking toward setting up Class A
and Class B (or combined Class A/B)
training programs.
At present we have identified
four kinds of approaches to accom-
plishing Class A and B operator
training:
• State-funded internet-based
• State-funded classroom
• Free-market, operator-funded
• Examination only, operator-
funded.
State-Funded, Internet-
Based Training
MONTANA
In 2005, the Montana Department
of Environmental Quality (MDEQ)
unveiled a state-sponsored UST
operator-training program that was
100 percent web-based and interac-
tive. The Montana program, known
as TankHelper, is being replicated
in various ways in several states,
including Idaho, Maine, and Ken-
tucky.
Prominent features of the Mon-
tana TankHelper program include:
• The TankHelper program links
to the Montana UST database
so the training information pre-
sented to the operator is facility-
specific. For example, if a facility
is all fiberglass, uses an ATG for
tank leak detection, and has safe-
suction piping, then these topics
are presented and all other meth-
ods of corrosion protection and
leak detection are ignored. This
approach to training requires an
accurate database but has huge
advantages in that it presents only
information that the UST operator
needs to know. This suits the great
majority of UST operators who
just want to meet the regulations
and are not interested in becom-
ing all-around experts in UST
management. It also eliminates
the problem faced by many oper-
ators who do not know what kind
of tanks, pumps, or leak-detection
method they have and emerge
overwhelmed and confused from
a training course that covers all
the possible variations of UST sys-
tems.
• At the end of the training, the
operator is presented with a facil-
ity-specific compliance plan. The
plan describes the operational and
leak-detection requirements for
each facility in a concise format so
operators have a complete listing
of exactly what they must do to be
in compliance at their facility.
• The program is funded entirely
by the state and is available free to
the operator.
• The MDEQ maintains complete
control over the program.
The original version of TankHel-
per was silent. Users would log onto
the website, select a facility, read a
series of screens, and then take a
quiz to evaluate their understand-
ing of their UST site. In 2009, MDEQ
unveiled Version 2 of TankHelper,
which provides the operator with a
video and audio presentation of the
training material and requires very
little reading. For those who pass the
final exam with an 80 percent score or
higher, the State of Montana issues a
Class A/B certificate of completion.
-------
June 2010 • LUSTLine Bulletin 65
MAINE
Maine has developed a program
very similar to the original version of
Montana's TankHelper; it goes by the
name of TankSmart. The Maine pro-
gram also links to the UST database
so that facility-specific information
can be presented. The student reads
screens and then takes an exam. In
addition to the web-based program,
the Maine program includes a down-
loadable manual that can be printed
for future reference by the UST opera-
tor or provided upon request by the
DEP via mail to operators who do
not have convenient computer access.
While the Maine training is facility
specific, the TankSmart program does
not produce a facility-specific com-
pliance plan. TankSmart provides a
combined Class A/B certificate to
UST operators who successfully pass
the exam. TankSmart is funded by the
State of Maine and is provided free of
charge to UST operators.
SOUTH CAROLINA
South Carolina has a hybrid web-
based training program that provides
a library of downloadable PDF docu-
ments on the various aspects of UST
systems. The student selects, down-
loads, and reviews the lessons, then
returns to the web to take an online
exam. The program allows the user to
download only the lessons they need;
the state assumes you know which
lessons apply (a big assumption).
South Carolina has also combined
the A/B training. South Carolina,
like California, expects operators to
know their stuff afterward and now
requires a monthly inspection form
be completed. The program is free
but must be completed by August
11, 2011. (We assume the site will
remain in business after the deadline
for new and replacement operators.)
Users who successfully complete the
program are issued a certificate.
OKLAHOMA
Oklahoma has developed an online
PowerPoint-like show as its UST
operator-training mechanism. The
program is self-guided, generic (i.e.,
not site-specific), and silent and
includes a short quiz after each train-
ing category. The trainee is prompted
to print a certificate after each cat-
egory is reviewed and each category
exam is passed.
IDAHO
Idaho has developed a program
similar in format to the Montana
TankHelper program in that it links
to the UST database and provides
facility-specific information and a
facility-specific management plan.
The Idaho approach has a unique
teaching method. Instead of having
the UST operator go to the web to
learn the information, an Idaho UST
inspector delivers the training on a
laptop computer as part of the facil-
ity inspection process. The inspec-
tor also prints out the management
plan and provides a binder in which
to store the plan and the required
recordkeeping paperwork. A cer-
tificate is printed for operators who
pass the associated quiz.
The goal is to raise the bar on UST-
operator knowledge. A training
program that does little more than
review material that UST operators
already know will only serve
to bless the status quo and not
produce the desired improvements
in UST management.
KENTUCKY
The Kentucky Division of Waste
Management is creating an online
operator-training program, modeled
closely on the Montana TankHelper
program, called TOOLS (Tank Oper-
ator Online Learning System.) This
program is still under development,
but the plan is to include a series of
PowerPoint-based lessons with audio
narration. The program will provide
facility-specific training based on
information contained in the state
UST database and a facility-specific
compliance management plan. Oper-
ators who successfully complete the
exam will receive a combination
Class A/B certificate that includes a
listing of the lessons taken.
The TOOLS program will pro-
vide the names of certified operators
and the UST facility(ies) with which
they are associated to the Kentucky
UST database so that compliance
with the UST-operator requirements
can be easily tracked. UST owners
will also be able to go online and
assign or remove UST operators from
UST facilities as personnel change
over time.
State-Funded
Classroom Training
KANSAS
Since 2007, the Kansas Department
of Health and Environment has con-
tracted with the Petroleum Marketers
& Convenience Store Association of
Kansas to provide live UST-operator
classes at various locations across the
state. The classes are presented free
of charge to the UST operators. The
association promotes the classes, reg-
isters UST operators, and provides
instructors for the classes. Class A/B
certificates are provided to attend-
ees. Kansas plans to continue to fund
these live classes for at least the next
few years. In order to obtain an UST
operating permit in 2012, operators
will need to prove that they have
attended an UST-operator class.
LOUISIANA
The Louisiana Department of Envi-
ronmental Quality has adopted an
operator training approach that is
nearly identical to the Kansas model.
U.S. VIRGIN ISLANDS
The Virgin Islands (VI) Department
of Planning and Natural Resources,
using federal funding, decided to
act quickly and offer free classroom
training to the island's UST-facil-
ity owners (about 60). Training was
completed in early May 2010, before
the UST-training rules were final-
ized. With such a small population of
owners, VI should be able to reach all
operators with not too much effort. It
remains unclear what VI will do after
the presumed 2012 deadline.
Free Market, Operator-
Funded Training
In our classification system, "free
market" states are ones where the
state agency is approving or autho-
rizing private-sector training ven-
dors to provide training for a fee to
• continued on page 4
-------
LUSTLine Bulletin 65 • June 2010
m Operator Training Programs
from page 3
UST operators. Usually, training can
be provided through a variety of
venues, including traditional class-
room, webinars (where an instructor
is present at specific times to teach
the class via the Internet), and online
(where a course is available anytime
the student wishes to take it). Many
states appear to be pursuing this
type of operator-training approach.
Only a few representative examples
are described here.
OREGON
With a deadline of March 2004, Ore-
gon was the first state to require UST
operator training. (See LL #58, "Oper-
ator Training—The Oregon Experi-
ence;" LL #47, "Mandatory Training
for UST Operators.") Oregon took the
approach of having the private sector
run the operator-training program.
The state merely authorizes trainers to
provide the training. Operators have
a number of private training provid-
ers from which to choose. To date,
only live classes have been offered.
The number, location, and cost of the
classes offered is entirely up to the
training providers, who provide a
certificate to the attendees. The state
provides little oversight to monitor
the quality of the training.
Oregon also allows operators
to use the International Code Coun-
cil (ICC) UST operator exam to meet
the state requirements. The ICC pro-
vides a list of reference documents
to prepare for the exam but does not
provide any actual training. As far as
we can tell, live training classes have
proven to be much more popular
among UST operators than the ICC
exam.
COLORADO
Colorado's operator-training dead-
line was January 1, 2010. The
state encouraged the free-market
approach and approved a variety of
classroom, internet-based, and exam-
ination options. Several vendors
were approved to provide classroom
training, concluding with an exami-
nation; one vendor was approved to
provide training in a webinar format
with an online exam. Colorado is
also accepting the ICC UST operator
exam. As might be expected, most
of the training activity took place in
the two months immediately prior to
the regulatory deadline. A number of
UST consulting firms started a Colo-
rado market for third-party Class
A/B operators, where the owner on
record outsources the training and
monthly/annual inspections.
NEW MEXICO
Like Colorado, New Mexico is
approving private sector vendors to
provide training in a variety of for-
mats. The state has chosen to stagger
the training deadlines between now
and 2012. Owners of 12 or more UST
facilities must have their operators
trained this year. Owners of between
three and eleven facilities must meet
a 2011 deadline. Operators of one or
two facilities have until 2012. New
Mexico is also requiring training for
aboveground storage tank operators.
Examination-Only, Operator-
Funded Training
In our classification system, "Exam-
only" states are ones where the
emphasis is placed on passing a
required exam, and the prospective
UST operator is left to fend for him-
self in terms of learning the infor-
mation needed to pass the exam. To
date, states adopting this approach
are using the UST-operator exam
developed by the ICC.
CALIFORNIA
California's UST-operator certifica-
tion deadline was January 1, 2005,
which became effective prior to the
passage of the Energy Policy Act.
The California strategy requires that
each UST facility have a designated
operator (DO). The DO must con-
duct a monthly inspection of the UST
facility(ies) for which they are respon-
sible, and provide basic leak-detection
and alarm response training to onsite
personnel. Private-sector vendors are
providing live classes to assist pro-
spective DOs in preparing for the ICC
examination. These classes are not
subject to any state-approval process.
A substantial number of California
UST owners have outsourced their
DO responsibilities to third-party ser-
vice providers.
WYOMING
Wyoming also limits operator-certi-
fication mechanisms to the national-
and state-specific ICC UST operator
examinations. The Wyoming DEQ ini-
tially provided a number of free semi-
nars to prepare prospective operators
for the exams. Future exam prepara-
tion will be handled, for the most part,
by private-sector providers.
How Will We Measure
Success?
So as most states (and hopefully
UST owners and operators) begin
to ramp up activities for the 2012
operator-training deadline, we think
this is a good time to ask, "How will
the success of operator training be
measured?" All too often, regulators
measure success by the mere fact that
a required program exists. While the
existence of a program is no doubt
a significant achievement, the pur-
pose of the EPAct was not to increase
bureaucracy.
So how will the states measure
the success of their UST operator-
training programs? Will it be mea-
sured by the number of certificates
issued? By the number of people
who take the various courses? By
the increase in reports of suspected
or confirmed releases? By increases
in the rates of significant operational
compliance? While any of these mea-
sures is feasible, it seems to us that
the goal of UST operator training is
to increase compliance with UST reg-
ulatory requirements. If this is cor-
rect, then the success of a program
might be measured by increases in
the percentage of facilities found to
be in compliance with UST require-
ments.
OUST has been tracking rates of
regulatory compliance as reported
by states since 2002. To satisfy our
curiosity, we plotted the percentage
of UST facilities in compliance with
release-detection and release-preven-
tion requirements for several states:
Oregon, California, Kansas, and Col-
orado (see Figures la, Ib).
Oregon's UST operator train-
ing requirements went into effect on
March of 2004. California's program
took effect on January 1, 2005. Kansas
has been doing some training since
2008, but this is in advance of the
Kansas deadline, so it is not clear how
-------
June 2010 • LUSTLine Bulletin 65
FIGURE 1a
Percent Compliance with Release-Detection Requirements
20022 20031 20032 20041 20042 20051 20052 20061 20062 20071 20072 20081 20082 20091 20092
FIGURE 1b
Percent Compliance with Release-Prevention Requirement
2002 2 20031 2003 2 20041 2004 2 20051 2005 2 20061 2006 2 20071 2007 2 20081 2008 2 20091 2009 2
large a portion of the Kansas UST
operator population has been trained
to date. Colorado's program went
into effect on January 1 of this year, so
it is clearly too early to see any effects
of this training in the data.
From the Figure la and Ib graphs,
it would appear that Oregon's rate of
compliance with both release-detec-
tion and release-prevention mea-
sures has been increasing since the
operator-training requirements went
into effect, with a substantial jump
in compliance coincident with the
implementation of the program in
March of 2004. The California trend
is not so rosy; the compliance rates
appear to have held steady or even
declined slightly since 2005. The Kan-
sas and Colorado compliance rates
seem more or less the same over the
years presented in the graphs.
There is considerable variability
in most of the state data, so we need
to be careful when reaching con-
clusions, but the Oregon data indi-
cate that there may be some hope
that operator training can result in
improved compliance. The Califor-
nia data point out that the success
of operator training may be elusive,
or that measuring success may be
more complex than just monitoring
reported compliance rates.
Operative Words-
Enforcement! Training!
The premise for including UST
operator-training requirements in
the EPAct was that compliance with
UST requirements was lagging. The
remedies prescribed for this problem
were increased inspection frequency
(hopefully accompanied by increased
enforcement via red-tag authority)
and increased operator knowledge of
the regulations via training. There is
no question in our minds that with-
out effective enforcement, the opera-
tor-training requirements will not
bear the desired fruit.
It is also clear to us that the pur-
pose of training is to increase knowl-
edge. The goal is to raise the bar on
UST-operator knowledge. A training
program that does little more than
review material that UST opera-
tors already know will only serve
to bless the status quo and not pro-
duce the desired improvements in
UST management. As state agencies
that are adopting the "free market"
approach review the course materi-
als presented to them by vendors for
approval, they would do well to keep
this in mind. Examinations should be
structured so that if UST operators
were to simply take the exam with-
out any preparation, a large percent-
age of them would fail. If the training
is effective, then most UST operators
will pass the exam only after they
have taken the training. •
NOTE: If your state is doing something
you think is special with regards to oper-
ator training, let LUSTLine Editor Ellen
Frye know, and maybe it can be covered
in a future issue.
Marcel Moreau is a nationally
recognized petroleum-storage specialist
whose column Tank-nicalhj Speaking is
a regular feature o/LUSTLine.
He can be reached at marcel.moreau®
juno.com. Ben Thomas was one of the
first UST-operator trainers in Oregon
and continues to provide operator-
training services across the U.S. He can
be reached at bthomas@whidbey.com.
Marcel and Ben are partners in
Petroleum Training Solutions,
developing online operator-training
courses for all levels of UST operators.
-------
LUSTLine Bulletin 65 • June 2010
III hot's in Store for Tanks and Tank Programs
Over the Next Decade?—Part 2"
by Ellen Frye
n
I s we enter the second decade of this
millennium, it seems as good a time as
any to take a peek into ye aide crystal
ball in an attempt to fathom what is
clearly a transition into that great
unknown looming on the fuel-stor-
age-tank horizon, so that we can be
prepared to be prepared.
Part 1 of this exercise appeared
in LUSTLine #64, March 2010. As
with Part 1, Part 2 has taken the form
of a series of questions formulated by a
Just Wondering
0* Will regulators ever have a
standardized terminology and
protocol for evaluating UST sus-
tems test-data?
Regulators continue to face many,
many challenges but one of the
things they can't lose focus on is the
need to make sure that the progress
made over the past 20 years isn't
tossed out the window. A big part of
the UST regulator's job is to review
facility records for various required
tests (e.g., cathodic protection, line
leak detectors, tank tightness) to
ensure that various operational sys-
tems are functioning as required.
As we look ahead at the next
decade, we must ask ourselves: Is it
the role of the regulator to control the
quality of this testing? Or, is the role
of the regulator simply to ensure that
the testing gets done? If a test is not
done correctly, is it of any value?
More frequent inspections and
stronger enforcement tools will help
ensure that more of the testing and
monitoring required in the rules
actually gets done. But this does not
necessarily mean that testing is being
small group of industry and regulatory afi-
cionados, including Patricia Ellis, Delaware
NREC; Kevin Henderson, Mississippi
DEQ; Richard Speise, Vermont DEC; Hal
White, USEPA OUST; Carol Eighmey,
Missouri PSTIF; Marcel Moreau, and
Curt Johnson, Alabama DEM. We have
asked the questions and provided reasons
for the questions, but we have not neces-
sarily attempted to provide answers...
maybe just some speculation. We welcome
your thoughts and questions.
performed correctly. Unfortunately,
it seems as though testing, in general,
is actually becoming worse as eco-
nomic pressures drive things to be
done quicker and cheaper.
Regulators can't, nor should
they, rely on the owner/operator to
ensure that the testing is performed
correctly. Even with Class A or B cer-
tification, operators typically don't
know an automatic line-leak-detec-
tor test that has been done correctly
from one that has not. Unfortunately,
they often pay the same amount of
money in either case.
Regulators have tradition-
ally relied on a simple "pass/fail"
approach to reviewing testing
records. If the person who conducted
the test indicates that it passed, the
regulators have accepted this as gos-
pel. This approach has serious draw-
backs—regulators need to be able to
review the test records and determine
for themselves whether or not the
test was done correctly (the trust-but-
verify doctrine of the Cold War). The
only way to be able to do this is to
mandate that test records document
certain information. Standardized
forms accomplish this, and training
the inspectors is the first step.
tf fls interstitial monitoring be-
comes the norm instead of the
exception, will there be enough
new leak-detection technologies
to generate sufficient leak-detec-
tion evaluations and protocols to
justify the continued existence of
the National Work Group on Leak
Detection evaluations (NWGID€)?
Since pressure/vacuum systems
came out five or six years ago, there
has not really been anything new in
interstitial monitoring to hit the mar-
ket. The methods seem to be too sim-
ple to justify any new technologies.
All the issues currently being
addressed by the NWGLDE have to
do with whether or not traditional
systems are working with alternative
fuels. Also, there seems to be little
incentive to come up with new leak-
detection technologies for single-
walled tank systems, since this tank
population will continue to decline
in the next decade.
-------
June 2010 • LUSTLine Bulletin 65
"The people who review the facility compliance records must be able to
recognize suspect test documents. These can then be referred to the person or
persons within the regulatory organization who have the expertise to effectively
critique the test data. Not necessarily to declare it as bogus but to at least raise
the right questions so that the person conducting the test understands that there is
someone who is scrutinizing their work. If they understand that there is someone
with authority looking with a critical eye, they are much more likely to perform
the testing correctly.
"In my experience, most people want to do the right thing, for various
reasons, they just don't know what that is. If there is not someone who knows
what is really going on, then they have no impetus to learn themselves."
KEVIN HENDERSON
MISSISSIPPI DEPARTMENT OF
ENVIRONMENTAL QUALITY
b* Now that we have red-tag
authority to lock out tanks that
are not in compliance, will compli-
ance rates go up for UST systems?
Fewer leaks? find how many
leaks are occurring from compli-
ant USTs?
In the past, the enforcement process
could take months, or even years.
Now, thanks to our red-tag authority,
we can stop owners and operators
from making money from continued
use of out-of-compliance tanks. (See
Figure 1.) It would be nice if we had
some sort of equivalent for LUST
non-compliance, but often, tanks
are gone and there isn't anything
to tag, so we have to go through
the old enforcement process with
warning letters, Notice of Violation,
Secretary's Order, penalty orders,
and threats to take over investigation
and cleanup and then cost-recover.
Maybe we just need big signs to post
on out-of-compliance LUST prop-
erties, stating that violations are
threatening public health, safety, and
the environment (and a big fine for
removing the signs).
FIGURE 1. Red tag on fill pipe in Delaware.
If What is a "green" gas station,
and will we ever get there?
There is a lot that gas stations can
do to improve their impact on the
environment and serve as public
showcases for all kinds of best man-
agement practices, such as control-
ling storm water and roof runoff,
recycling water from car washes,
reducing air-pollutant emissions,
using electricity generated by power
sources like solar panels and wind
turbines, where feasible, and using
building components made of recy-
cled materials. They can become
"transportation service centers,"
where they not only pump gaso-
line/biofuels into auto fuel tanks,
they also service electric cars, bikes,
and motorcycles and other transport
modes such as bicycles, pedal cars,
and even weary walkers.
But wait. If "green" means some-
thing that's environmentally friendly,
what's the greenest imperative at any
gas station? Wouldn't that be pre-
venting any and all vapor emissions,
fuel and oil spills and overfills, and
UST system releases? Wouldn't that
mean a zero tolerance for releases?
A release is an expensive proposition
and it's bad for the environment.
Since gas stations are primarily
owned by smaller entities, is green
just too expensive to hope for? Larger
companies might do this, but might
it be too expensive for the little mom-
and-pops? In ten years will we finally
realize that spilling bad stuff into the
environment is too expensive?
tf Will we be conducting "greener"
cleanups, using "sustainable"
remediation techniques?
The SURF "Sustainable Remedia-
tion White Paper" (see box on page
8) broadly defines sustainable reme-
diation as "a remedy or combination
of remedies whose net benefit on
human health and the environment
is maximized through the judicious
use of limited resources."
Remediation decisions often
have a triple bottom line—environ-
mental, economic, and social inter-
ests. The rush to remediation is often
encouraged by regulatory policy, reg-
ulatory culture, statutes, public pres-
sure, and often the unwillingness of
all parties to recognize the limitations
of their own approaches. As a result,
repeated attempts at source remedia-
tion are not uncommon—each requir-
ing additional resources and energy
and each having additional negative
environmental consequences without
achieving the treatment objectives.
For more information about
green remediation, go to http:llwww.
epa.gov/oswer/greencleanups/index.html,
a USEPA resource for learning about
greening cleanups. The goal for the
site is to communicate with stakehold-
ers about initiatives related to greener
cleanups, lessons learned, success sto-
ries and updates on current develop-
ments and upcoming events.
F Will we ever agree on how much
INflPl we can leave behind?
Regarding light nonaqueous-phase
liquid (LNAPL), federal rule 40
CFR 280.64 (1988) states "remove
free product to the maximum extent
practicable as determined by the
implementing agency...." Federal
statute, state statutes/regulations,
policies, and guidance documents
range from:
• Remove all detectable levels of
LNAPL at all sites.
• A defined measurable amount
(0.01 ft.-l/8 in.) may remain.
• Guidelines are risk-based/site-
specific.
• Less stringent cleanups are
allowed, based on an evolving
understanding of LNAPL behav-
ior (in many cases without for-
mally adopting related rule or
policy changes).
• continued on page 8
-------
LUSTLine Bulletin 65 • June 2010
I Transition from page 7
Many of these rules were devel-
oped prior to the current state of
knowledge. Regulations generally
don't consider the fact that LNAPL
is potentially mobile only if the satu-
ration exceeds residual saturation.
After LNAPL releases are abated,
LNAPL bodies reach a stable con-
figuration, generally within a short
period of time. Regulators and
cleanup consultants need to assess
the stability of dissolved plumes to
establish whether they are stable.
At some point, LNAPL ceases
to be mobile and is just a residual.
Depending on composition, it may or
may not be contributing to a plume of
ground water contamination. Oppos-
ing philosophies maintain that since
we have many new technologies that
we didn't have early on, we should
be able to get more of the LNAPL out
of the ground than we could before.
But the question remains that if there
is no risk-based reason to remove it,
why go to the expense of doing it?
See LUSTLine #64, "The Top 10
LNAPL Myths," and also go to:
• http://www.api.org/ehs/groundTvater/
Inapl/index.cfm
• http:llwww. itrcweb.orglteampublic_
LNAPLs.asp
(/ Will longer dissolved plumes
associated with ethanol/gasoline
fuel releases cause additional
problems, or have we done better
or enough to reduce release rates
to offset additional risk?
Only time will tell if we have done
enough to offset any additional risk
posed by ethanol due to our progress
in reducing overall leak rates from
tank systems. There are concerns
that UST system compatibility issues
associated with ethanol may cause
more, but perhaps smaller, releases.
In fuel releases that contain etha-
nol, microorganisms seem to prefer
to feast on the alcohol first, allow-
ing the BTEX plume to move farther
along than it would if there were no
alcohol.
With regard to fuel releases from
LUST sites, private water supplies
and small groundwater systems tend
to be more impacted by contaminants
than public water supplies because
there is little dilution. A study of
8
SURF's "Sustainable Remediation White Paper" Is a Must-
Read for LUST Program Personnel and Consultants
The Sustainable Remediation Forum (SURF) authored a groundbreaking white
paper titled "Sustainable Remediation White Paper—Integrating Sustainable
Principles, Practices, and Metrics into Remediation Projects" (edited by David E.
Ellis and Paul W. Hadley). The paper was published in a special edition of the Summer
2009 Remediation Journal, and is currently available at http://www.sustainablereme-
diation.org/.
SURF's primary objective is to provide a forum for various stakeholders in reme-
diation—industry, government agencies, environmental groups, consultants, and aca-
demia—to collaborate, educate, advance, and develop consensus on the application
of sustainability concepts throughout the lifecycle of remediation projects, from site
investigation to closure.
The paper communicates SURF members' thoughts on incorporating sustain-
ability principles into environmental remediation. It promotes the use of sustainable
practices during implementation of remedial action activities with the objective of bal-
ancing economic viability, conservation of natural resources and biodiversity, and the
enhancement of the quality of life in surrounding communities. •
MtBE releases in New Hampshire
found that standards were exceeded
more often in private water sup-
ply wells. Contamination may be
especially problematic in areas with
sole-source aquifers or where water-
table levels are dropping due to pro-
longed drought.
According to the USEPA, approx-
imately 15 percent of Americans
rely on their own private drinking
water supplies, and these supplies
are not subject to USEPA standards,
although some state and local gov-
ernments do set rules to protect users
of these wells (www.epa.govi'safewa-
ter/privateTvells/index2.html). Unlike
public drinking water systems
serving many people, they do not
have experts regularly checking the
water's source and its quality before
it is sent to the tap.
$ Will institutional controls be
effective long-term environmental
stewardship mechanisms at LUST
sites?
Should we be leaving sites with con-
tamination so that future uses of
the land must be restricted in some
manner? Even if (a big if) there are
effective tracking mechanisms and
notification systems for sites that
have some sort of institutional con-
trol on land-use and there is good
coordination among agencies at dif-
ferent levels of government, where
does all of this get us long term? Do
we end up with a lot of "groundwa-
ter management zones" so that even-
tually you can't use the groundwater
for much of anything?
Groundwater should be consid-
ered one of the most precious com-
modities on earth, but that's not how
it's treated. What do we pass down
to our children and grandchildren?
Again, how much do we clean up,
and how much do we leave behind?
tf Will there be increased poten-
tial for vapor intrusion due to pro-
duction of methane associated
with new gasohol releases?
Gasoline leaks and spills at UST sites
happen, and with the advent of E10
(and the potential for E15), these
releases will contain a significant
amount of ethanol. Gasohol releases
may cause greater risks to indoor air
than traditional petroleum releases
due to the production of methane.
(See Figure 2.)
At traditional release sites petro-
leum vapors migrating upward
toward a basement in the vadose zone
are quickly biodegraded by microbes
in the soil matrix. This occurs, primar-
ily, due to the prevalence of oxygen
in the pore space of the soil. At sites
where releases occur that have etha-
nol in the fuel, the ethanol is biologi-
cally broken down into acetic acid.
Once all of the ethanol is degraded,
the acetic acid is broken down into
methane. The biodegradation of the
ethanol consumes available oxygen
and the methane, as it moves upward
into the soil matrix, displaces the oxy-
gen in the soil pore space.
Without oxygen to promote bio-
logical breakdown of the benzene,
-------
June 2010 • LUSTLine Bulletin 65
ContaiTwnanl
Oilfution
Through tt*
4 VKtoMZone
FIGURE 2. Vapor intrusion cross-section.
as well as other components of the
petroleum vapors, these compounds
have greater potential to migrate
through the soil profile and into con-
fined spaces like basements, thereby
increasing the risk of violation of
indoor-air health criteria.
F Is indoor vapor inhalation ex-
posure a real threat? Or is the
"vapor intruder" a bogeyman?
As all good LUST managers know,
benzene and the "indoor inhalation
pathway" drive the majority of LUST
cleanups. States have used a vari-
ety of methods to analyze this risk,
and most have relied heavily on the
Johnson-Ettinger model, developed
in 1991. It's 2010, and we've been
addressing this risk for 20-plus years.
What have we learned?
In recent years, USEPA and state
regulators have collaborated with
industry experts to review available
research and the knowledge gained
collectively from tens of thousands
of tank-site cleanups. What conclu-
sions have we reached? Is it time for
a new model? In an era when finan-
cial resources and economic develop-
ment are evermore precious, are we
reaching reasonable conclusions that
achieve the right balance between
protecting the public from undue
risk and site remediation?
E? Given the bleak financial state
of state budgets, will state tank
funds continue to be the primary
Financial Responsibility (FR) pro-
viders for UST owners/operators?
Or will USEPA and state regulators
have to require owners/operators to
use other FR mechanisms?
tf Where's the peak in peak oil?
Oil seems a finite resource, so peak
oil is in our future somewhere. But
will it be the next decade or the next
century? What happens to petroleum
(and thus the tank world) is largely
dependent on the price we pay at the
pump. The spike in 2008 prices made
a big impression on a lot of fuel users.
So what does the future hold? Here
are some of the competing factors:
• Gasoline consumption in China
and India is going to go UP!
• Speculation in the markets
(responsible for the 2008 price
spike?) may or may not be con-
trolled by new rules.
• Natural gas production in the U.S.
is likely to increase dramatically
because of shale gas production.
• Oil production in Iraq is likely
to increase dramatically as new
fields are found and foreign oil
development comes to fruition
(unless unrest or politics puts the
kibosh on this). China is the lead-
ing developer of Iraqi oil.
• How will Iraq fit in with OPEC?
Having a new large-volume player
in the oil market will upset the
current equilibrium on the supply
side. What will happen then?
• Assuming increased supplies of
energy in both native natural gas
and imported oil, will the supply
be ahead of, keep up with, or fall
behind the expected increase in
demand? •
Related reading: The Party's Over: Oil,
War and the Fate of Industrial Societ-
ies by Richard Heinberg.
USEPA Provides Recommendations on Lead
Scavengers at LUST Sites
In May, OUST Director Carolyn Hoskinson signed a memorandum recommending
the investigation and cleanup of lead scavengers at LUST Sites. Lead scavengers,
common additives in leaded gasoline, pose risks to drinking water sources. The
memorandum encourages states, tribes, and the USEPA Regions to:
•When appropriate, monitor and report the presence of lead scavengers in
groundwater at LUST sites;
•Analyze EDB and 1,2-DCA using EPA Methods with the appropriate detection
limits;
• Remediate lead scavengers when such constituents could threaten a source of
drinking water; and
• Share information on the presence and remediation of these constituents.
Not all LUST sites are potential candidates for lead scavenger investigation. Only
sites at which leaded motor fuels were or are currently stored are appropriate
candidates. Both off-road racing fuel and aviation gasoline (Avgas) are leaded
fuels. LUST sites where these fuels have been or are still stored should generally
be investigated for EDB and 1.2 DCA. (See Table 1.)
The complete memo-
randum is available at
http://www.epa.gov/oust/
cat/leadscav. Go to "lead
scavengers" and click on
"Phase 3: Recommenda-
tion for States, Tribes, and
EPA Regions to Investi-
gate and Clean Up Lead
Scavengers When Present
at Leaking Underground
Storage Tank (LUST) Sites
-May 2010." •
TABLE I
Summary of Recommendations
forOn-Road Gasoline Sites
Recommendation
to sample and
analyze for EDB
and 1,2-DCA.
Recommendation
to sample and ana-
lyze for EDB and
1,2-DCA depen-
dent upon:
•UST's storage
history
•Threat to drinking
water sources.
Recommendation
to sample and ana-
lyze for EDB and
1,2-DCA only at
sites where USTs
continue to store
leaded fuels (off-
road racing fuel,
aviation gasoline).
1986-* M996
Years of Storage
-------
LUSTLine Bulletin 65 • June 2010
_
US'*
Release, Remediate, Repeat
Just when one of our LUST sites
had come within spitting distance
of meeting its cleanup goal. ..after
22 years as an active LUST project...oh
no, a new release! Up to five feet of free
product has been discovered in the moni-
toring wells! ARRRRGH
The site has been a LUST site since
1988, when a leak occurred around
a fill neck. Historically, up to several
feet of free product existed in the area
of the tank field, and by 2004, fol-
lowing several years of operation of
a pump-and-treat system, followed
by operation of product-only skim-
mers, the free product was no longer
observed.
A post-remedial monitoring
phase followed to evaluate the con-
tinued natural attenuation at the site.
By 2007, we were down to one well
that slightly exceeded our Risk-Based
Screening Levels (RBSLs) for clos-
ing the site, and if we had entered
site-specific parameters, I'm sure we
would have met Site-Specific Target
Levels (SSTLs) in all of the wells (the
site is in the Piedmont, with finer-
grained soils than were used to gen-
erate our generic RBSLs).
But site closure was evidently
not meant to be. When the remedia-
tion consultant for the site was on
site performing the regular quarterly
gauging and sampling event, he/she
encountered up to five feet of free
product in the monitoring wells.
To add further complications, the
site had been sold in 2001, so we had
the former owner who was still on the
10
-Source of 2007
Gasohol Release
FIGURE 1. "T" fitting under the dispenser where 2007 release occurred.
hook for the 1988 release, and the new
owner with a new release. We also
had two sets of consultants for the
site.
What's Going On?
The consultant for the current owner
mobilized to the site and began con-
ducting vacuum-truck events in
wells with free product to minimize
the spread. The source of the release
was identified as a failure of a "T"
fitting under the dispenser closest to
the tank field (Figure 1). It appears
that the ethanol in the gasoline may
have dissolved the adhesive used to
secure the "T" fitting; however, the
cause of the failure was not verified
by laboratory analysis. A portion of
the release followed a preferential
pathway along
the piping
run back to
the tank field,
which is where
the 1988 release
occurred, while
the other por-
tion mobilized
into the soil
beneath the
dispensers and
associated UST
Piping-
Examina-
tion of inven-
tory records for
the site did not
show a discern-
able release
and the line
leak detectors did not alarm. Initially,
it was thought that the 2007 release
was less than 100 gallons. The release
could have been going on for as long
as three months, because that is the
time period between groundwater
monitoring events. If monitoring
had not already been underway at
the site, the release could have gone
undetected for a much longer period
of time. (See figures 2a, 2b, 2c.)
The Shades of Time
Two distinct types of free product
have been found at the site since the
new release. In the tank-field moni-
toring wells, the LNAPL column had
a gradual color change from dark-col-
ored LNAPL (1988 release) to light-
colored LNAPL (2007 release) (those
-------
June 2010 • LUSTLine Bulletin 65
Isotontenli dliun (cmdJiii
May 21. 2007
August 9, 2007
November 30,2009
FIGURES 2A, 2B, 2C. Site diagrams show plume
size prior to 2007 release, shortly after discovery of 2007
release, and more than two years after 2007 release. Note
increasing size of plume and area of separate-phase hydro-
carbons.
bailers must have looked
stunning!). In source-
zone monitoring wells,
the LNAPL column was
dark, indicating that the
NAPL was weathered
and likely from the 1988
release (Figure 3).
Graphs plotting
contaminant concentra-
tions and free product
thickness through time
show that benzene and
BTEX levels have begun
to increase in downgra-
dient wells (Figures 4a
and 4b). Free product
observed in the wells
downgradientofthe2007
release is dark-colored
and highly weathered.
It is not known whether
the increase in dissolved
concentrations is primar-
ily due to migration of
the 2007 release to these
wells, or whether the
dissolved component
found in these wells is
resulting partially from the dissolu-
tion of residual product. The concen-
tration of ethanol in the 2007 release
(E10) would not be expected to cause
co-solvency.
Pilot testing conducted in
November 2009 showed that air
sparging coupled with soil-vapor
extraction should be an effective
remedial technology for the site. The
sparge well radius of influence was
nearly 75 feet, and the soil-vapor
extraction radius of influence was 50
feet. Ten paired air sparge/SVE wells
are planned. Due to the location of
a car wash on-site (not shown on
the maps in Figures 2a,2b, and 2c.),
it will be necessary to obtain county
approval to locate the remediation
building or trailer along the property
boundary.
Remobilizing?
A majority of the releases that we've
identified lately have been at facilities
that have previously experienced a
release, so we're superimposing new
contamination on residual hydrocar-
• continued on page 12
MW-09
RW-03 RW-04
FIGURE 3. Top: Light-colored LNAPL from tank field wells (2007 release);
Bottom: Dark, weathered product from source zone wells (1988 release).
11
-------
LUSTLine Bulletin 65 • June 2010
i Release, Remediate, Repeat from page 11
140000
0.012
0.01
0.008
Benzene (mg/L]
BTEX (ug/U
MTBE (ug/L)
TBA(ugA)
TAME (ug/L)
SPH(feet)
200000
180000
160000
140000
120000
100000
Benzene (ug/L)
BTEX (ug/L)
___. MTBE (ug/L)
••TBA(ug/L)
- TAME (ug/L)
SPH (feet)
80000
60000
FIGURES 4A and 4B. MW-5 and MW-6 are located 30-50 feet downgradient of the
2007 release. Weathered LNAPL was observed in MW-6 approximately one year after the
release. Increases in dissolved concentrations of benzene and BTEX were also observed
about one year after the release.
bon plumes that had become stable
or were shrinking. The presence of
ethanol in these new releases may
cause remobilization of the preex-
isting contamination, and the new
plumes can be expected to travel far-
ther because the aquifer is already
anaerobic and electron acceptors are
already depleted.
What FOOTPRINT Tells Us
USEPA contractors recently used the
FOOTPRINT decision-support soft-
ware tool (available at http://www.
epa.gov/ada/csmos/models/footprint.
html) to estimate the possible impact
12
of higher concentrations of biofu-
els on the size of plumes that are
produced by releases from UST
systems. Forty Coastal Plain sites
from Sussex County, Delaware
were modeled.
Depending on the decay rate
used (ranging from 20 mg/L/day
to 2 mg/L/day), the plume area
for an E10 release increased from
13 to 189 percent over the plume
area for a release with no ethanol
in the gasoline. Increasing ethanol
content (up to E85) caused large
increases in plume area (up to
2,377% over a plume area with no
ethanol and a decay rate of 2 mg/L/
day).
Research has shown that etha-
nol can inhibit natural anaerobic
biodegradation in benzene, toluene,
ethylbenzene, and xylenes (BTEX)
in groundwater, making for longer
BTEX-compound plumes. Ethanol
can also produce potentially explo-
sive concentrations of hydrogen and
methane gas at gasoline spill sites.
As we see more and more sites
where E10 (or higher ethanol concen-
trations) is released in areas of preex-
isting contamination, we can expect
to see larger plumes, consequently
putting downgradient receptors at
higher risk. These effects may be
multiplied by the fact that we have
equipment in the ground as compo-
nents of our UST systems that we
can't be sure is compatible with E10
gasoline, much less higher concen-
trations of ethanol. •
I would like to acknowledge Environ-
mental Alliance ofHockessin, Delaware
for providing the photographs in this
article.
Two E85 Dispensers
Now Have UL Listings
On June 25, the Underwriters Labora-
tory (UL) officially issued certification
for two dispensers for use with pre-
blended E85: Gilbarco Veeder-Root's
Encore E85 and Dresser Wayne's
Ovation Eco Fuel.
The issue of certifying E85 dis-
pensers was first raised in 2006 after
it became evident that no safety stan-
dard existed to test and certify high
ethanol fuel blends. At that time, UL
launched an extensive research ini-
tiative in collaboration with federal,
industry, and international experts and
advisory groups to better understand
the corrosive properties of ethanol/
gasoline fuel blends and to develop
test methodologies that address
potential fire, explosion, and shock
hazards while addressing degradation
issues for products that distribute the
fuel blends up to E85.
Those certification requirements
were published in 2007, and the Gil-
barco and Dresser Wayne dispensers
were the first complete systems to
have met all of those requirements. For
more information, contact Claire Kam-
mer at Claire.A.Kammer@us.ul.com.
-------
June 2010 • LUSTLine Bulletin 65
TUH
Those Alcohol-Loving Acetobacters at Work... or What?
fey E/kn Frye
SENT: Wednesday-, December 17-, EDDfl-, ^4:30 PN
SUBJECT: Some odd corrosion and reactions
FROM: Steve Pollock
I ran across this mess in a sump today- I've seen similar messes-, but this was
just a little different- The environmental consultant I was with had never
seen anything like it either- Kind of mounded-, with recently act ive-looking
bubbles (hydrogen gas?) on top- Sort of like the sulfur-reducing bacteria crud
we sometimes find-, but somehow a little more pillowy- The consultant knocked it
around a little (with his neatly designed lid lifter which he described as the
best tool they've ever purchased)-, and I was waiting for the whoosh of rotten-
egg smell- Instead-, it was a vinegar smell-acetic acid- Maybe in the presence
of E1D-, our native soil/water bacteria now prefer to chomp on the ethanol first
as Acetobacters or just as opportunistic bacteria loving an easier chain (the
alcohol) to digest-, creating acetic acid—you know-, like wine going bad- Or
perhaps-, in the presence of E1D-, these are the first bacteria to feast at the
buffet-, then the vultures-, and then the oil metabolizers
Anyway-, the acetic acid-, bacteria-, and some funky mold (or yeast?) is tearing up
the steel-, too- Also note that the line leak detector was supposedly replaced
this past February with a Red Jacket FX-1V series part- Maybe•••though it sort of
looked like the older-, bigger XL's- But if it's new as of Feb 'Dfl-, it has had a
hurting put on it- Oddly-, the next-door STP sump was also full of water-, but not
this mess- And it was clear that the LLD had been replaced-
Eew!
The facility that Virginia DEQ Petro-
leum Program Compliance Inspector
Steve Pollock described in his e-mail
above to co-workers had been sell-
ing E10 since its introduction to the
non-attainment areas of Virginia in
2006. "I was accompanied by a local
environmental consultant contracted
by the tank owner," says Pollock.
'The owner had also submitted a few
records prior to the day of inspection.
The inspection was fairly typical until
the consultant removed the Submers-
ible Turbine Pump (STP) containment
sump lid for one of the USTs.
"The containment sump con-
tained a good deal of liquid, nearly
covering the STP's motor head. This
condition is not unknown to UST
inspectors. The surface of the liquid
was also covered in what appeared
to be a biological mat. I've run into
this condition before, where there are
iron-reducing bacteria; it seems to
occur in shallow groundwater areas,
particularly near swampy areas or
former swamps covered by suburban
sprawl."
"But," notes Pollock, "this mat
appeared slightly different from
others I've encountered—it
had a lighter color and
what appeared to be larger,
recently formed gas bub-
bles."
The consultant investi-
gated the situation by dis-
turbing the mat and liquid
with a pry bar. "I didn't stop
him quickly enough, so I
stepped back to avoid the
predictable rotten egg smell
of the sulfurous metabolic
products of the bacteria,"
says Pollack. "But, instead
of sulfur, the odor was vin-
egary—acetic acid. The con-
sultant removed the STP
sump lid from the adjacent
UST. It was also full of liq-
uid, but seemed to be just
clear water."
Having received some of the
testing data ahead of the inspec-
tion, Pollock was aware that the line
leak detectors for these UST systems
had been replaced in February 2008
with new Red Jacket FX-lVs. This
certainly seemed believable for the
equipment in the sump with the clear
water, but he had trouble believing
STP sump showing biological mat from a 2008 inspection
at an E10 facility.
that the leak detector in the other
sump was only eight months old.
That leak detector appeared to be
very old and corroded. But strangely,
the STP head and even the visible
electrical conduit appeared covered
by an aggressive, almost mounding
layer of corrosion, not typical of the
corrosion Pollack had seen during
previous inspections.
• continued on page 14
13
-------
LUSTLine Bulletin 65 • June 2010
m Not for the Squeamish
from page 13
Could Ethanol Be Involved?
"I began to think the recent testing
and button-up work for the USTs (the
facility was in the midst of a property
transfer) allowed for a small amount
of E10 to have been deposited in the
containment sump," says Pollock.
But he wondered if it might also be
possible, despite passing UST and
vapor-recovery testing, that small
weeps or vapor releases allowed for
the continuous input of a miniscule
amount of E10 to the containment-
sump environment from the one UST
but not the other. John Wilson, at
USEPA's National Risk Management
Research Lab in Ada, Oklahoma,
found it quite plausible that "etha-
nol is probably finding its way to the
water in the sump through a vapor
release pathway."
Spill bucket from a 2010 inspection at an E10
facility. Note the stalactite-type corrosion under
the lid.
USEPA did a study of two sites
in Northern Virginia that had MtBE
plumes in groundwater, even though
the tanks were tight. They estab-
lished that the MtBE in groundwa-
ter was coming from MtBE that had
escaped the USTs as vapors. Ethanol
and MtBE are similar in some of their
physical properties in that both have
a high vapor pressure from gasoline
(i.e., the proportion of ethanol or
MtBE in the vapors is greater than
the proportion of ethanol or MTBE
in the liquid gasoline), and both are
very soluble in water. So if MtBE
vapors can escape an UST system
and dissolve in water, it is plausible
14
that ethanol can do the
same thing.
Recalling recent
ethanol research and
its degradation prod-
ucts, Pollock formed a
hypothesis, or at least a
guess. In the presence
of E10, were different
native bacteria selected
to degrade the product?
Are Acetobacter or other
opportunistic bacteria
favored to digest the
alcohol, creating acetic
acid as a waste product?
At the time this con-
dition was observed,
John Wilson theorized
that the vinegar smell
could, indeed, come from aerobic
degradation of ethanol to produce
acetic acid by Acetobacter. He noted
that it could also be produced by
anaerobic bacteria that ferment etha-
nol to acetic acid and hydrogen gas.
"The hydrogen gas might be the
bubbles. Other bacteria can ferment
acetic acid to carbon dioxide and
methane, and the carbon dioxide and
methane might also be in the bub-
bles," he said.
The resulting problem for our
UST equipment seems to be that a
more-corrosive-than-expected envi-
ronment develops, attacking steel
and other metals. "The brew can
attack metals by a variety of meth-
ods," says Wilson. "Probably the
most important is that the acetic acid
is a good electrolyte, making the
water more conductive of electricity.
The acetic acid also obviously makes
the water more acid."
Once the liquid in both UST
sumps at the facility was pumped
out, and the fouled equipment was
cleaned, both Pollock and the owner
asked for confirmation that the leak
detector was only eight months old.
The serial number was compared to
the invoice, confirming that a techni-
cian had installed a new leak detec-
tor earlier in the year.
Following that inspection, Pol-
lock and his co-workers have kept an
eye out for similar conditions. They
have continued to encounter similar
scenarios and acetic acid odor at sites
in the Richmond area and near the
North Carolina border. The condition
has been noted in STP sumps, spill
buckets, and around ATG probe ris-
An ATG probe area from a 2010 inspection at an E10 facility.
Notice the extreme corrosion throughout.
ers. Some UST service providers have
told Pollock of similar observations.
What Are You Seeing?
Clearly, more information is needed
to determine exact causes and effects
surrounding these and other phe-
nomena taking place in UST systems.
For those of you out there in the field
doing facility inspections: Are you
seeing anything like this? We'd like
to help USEPA's Office of Under-
ground Storage Tanks (OUST) gain
a better understanding of potential
impacts to UST systems caused by
ethanol and other biofuels. So if
you have observed corrosion and
that telltale vinegar odor similar
to that described by Steve Pollock
and inspectors in a few other states
(New Hampshire is currently study-
ing similar findings), please contact
Andrea Barberry at OUST (Barbery.
Andrea@epamail.epa.gov) to let her
know what you have seen.
The more OUST learns about
what you are seeing in the field the
better chance we have of understand-
ing the physical and chemical chal-
lenges UST systems face from new
fuels. John Wilson has agreed to offer
a test kit to the first ten people that
send an e-mail to wilson.johnt@epa.
gov. His lab will provide materials,
including test strips to allow them
to measure the pH of the water in
the sumps in the field at the time the
samples were collected, for 10 sam-
ples in each kit. They will attempt
to determine the concentration of
ethanol (it may well be degraded)
and the concentration of acetate and
butyrate. •
-------
June 2010 • LUSTLine Bulletin 65
Plugging the Rest of the Leaks
New Hampshire Aims for Comprehensive
Secondary Containment for New UST Systems
by Mike Juranty
Secondary containment and leak
monitoring have been required
for all new UST installations in
New Hampshire since 1985; in 1997
that requirement was extended to
new product piping installations as
well. In spite of the secondary con-
tainment requirement, however,
these "modern" UST systems still
have releases. Leaks from modern
tank systems were recognized and
brought to the forefront through the
work of Gary Lynn, New Hamp-
shire Department of Environmental
Services (NHDES), and others who
demonstrated that methyl tertiary-
butyl ether (MtBE) was escaping in
the form of "vapor releases" from the
UST systems.
Further forensic leak investi-
gation by Jason Domke at NHDES
has shown that other events, such
as UST overfills and "topping off"
motor-vehicle gas tanks at facilities
with Stage II vapor-recovery sys-
tems, can go unnoticed but result in
liquid-product releases from tank-
system components that "don't
routinely contain product," are not
double-walled, and have no release
detection. These releases enter the
relatively porous pea-stone or sand-
bedding/backfill layer surrounding
the UST system. This layer acts as an
infiltration gallery of sorts that routes
any contamination into the ground-
water.
Mechanisms for Releases at
"Modern" Facilities
NHDES, as well as most other state
tank programs, identified the fol-
lowing mechanisms for releases that
have not been adequately addressed
in both its own rules and in the fed-
eral rules:
• Stage II vapor recovery systems
and "topping off" at the pump.
Many gas station patrons like to
get a little bit of extra fuel in the
tank or round off
their gasoline pur-
chase by repeat-
edly activating the
gas nozzle after it
has automatically
shut itself off. This
behavior can cause
liquid gasoline to
be drawn into the
vapor path of the
nozzle and then
into the Stage II
vapor piping that
leads back to the
underground tank.
Product also enters
the Stage II piping
during the periodic
liquid-blockage
testing of the vapor-
recovery system
and by condensa-
tion of fuel vapors
in the below-grade
portion of the pip-
ing. Releases then
occur through leaks
in the single-walled
vapor-recovery
piping.
UST overfills.
Despite the wide-
spread use of over-
fill-prevention
devices such as ball-
floats, drop-tube
shutoff valves (a.k.a.
"flapper-valves"),
and electronic
alarms, overfills still
occur. Lack of routine maintenance,
incorrect overfill-device installa-
tion, use of inappropriate over-
fill devices for the type of tank fill
method, and old-fashioned human
"ingenuity" can and do result in
UST overfills. Many of these over-
fills can be detected by the distinc-
tive spray patterns surrounding
Top: Typical ATG riser installation surrounded by the tank backfill.
Overfill events can leak from such unprotected risers and spill directly
into the tank backfill. Such releases can be prevented by locating all
risers within a collared sump.
Bottom: Typical ATG riser installation surrounded by the tank back-
fill. An overfill event popped the cap off the riser, and product leaked
into the tank backfill. The release would have been prevented if the
riser was located within a collared sump.
the tank vents but many more go
unnoticed until inspection time or
until a groundwater-contamina-
tion spike is evidenced. Overfill
releases occur through tank-top
fittings such as fill risers that have
corroded or loosened up over
time, automatic tank gauge (ATG)
• continued on page 16
15
-------
LUSTLine Bulletin 65 • June 2010
• NH and Secondary Contain-
ment from page 15
risers and fittings (ATG caps can
be blown off by the overfill event),
and leaking single-walled vent pip-
ing and vapor-recovery piping.
*•* 55**B> mSS^Si*i
mSSmmSSnSMEl ESS
S59*Hn3K. S5iS5
Product was released from the vent cap dur-
ing an overfill event. A leak in the single-walled
vent line resulting from improper installation,
corrosion, or movement of the vent riser would
result in a product release into the backfill dur-
ing such an overfill event. Gasoline vapors and
vapor condensates can also be released from
these leaking vent lines
• Leaking spill buckets. Spill bucket
covers are a tank's "front line of
defense" against vehicular traffic.
Repeated hits from snow plows
and car and truck tires passing
over the spill buckets can cause
degradation of the surround-
ing concrete, damage to the spill
bucket/concrete support ring, as
well as the spill bucket and riser.
Leaks from spill buckets and spills
around the spill buckets then have
a direct route into the tank bed-
ding.
A tank equipped with a collar for attaching a full-depth sump. Such collared sumps provide sec-
ondary containment and can be used to isolate tank risers and spill buckets from the tank backfill
material.
How Can These Types of
Releases Be Prevented?
One method for preventing these
releases is to rely on the facility own-
ers, contractors, fuel suppliers, and
patrons to "do the right thing" once
they have been educated on the
proper procedures and requirements
for constructing, maintaining, oper-
ating, and servicing the facility, and
in the case of patrons, pumping gas.
But history has shown that it is pru-
dent to employ the complementary
approach of building a system that
will capture or at least minimize the
adverse effects of equipment failure
or human error.
This approach has been partially
implemented in New Hampshire
and much of the country with rules
requiring secondary containment
and leak detection for new
tanks and product piping,
low-point piping sumps,
dispenser sumps, and spill
buckets. NHDES now plans
to complete that contain-
ment system by requiring
secondary containment and
Damage to a spill-bucket support ring.
Such damage allows surface spills to
enter the tank backfill.
release detection for vent and vapor-
recovery piping, as well as sumps
connected to tank collars (a "collared
sump") wherever a tank-top penetra-
tion is made, at all new UST installa-
tions. Tank-top penetrations include
submersible pumps/product piping,
ATGs, vents, vapor-recovery connec-
tions, interstitial risers, and fill risers
with spill buckets.
The additional overall cost of
installing double-walled (versus sin-
gle-walled) vent and vapor piping
and collared sumps (versus manway-
connected sumps, sumps mounted
at the top of a tank riser, or risers
without any sump at all) at new
UST installations is negligible com-
pared with the costs associated with
groundwater cleanup and business
down time that would result from a
product release. Collared sumps may
even provide an operational cost sav-
ings as they allow repairs of system
components such as spill buckets
and tank risers to be made without
the need to break concrete and exca-
vate to the tank top. •
Mike Juranty is supervisor of the Oil
Compliance Section of the New Hamp-
shire Department of Environmental
Services. He can be reached at michael.
juranty@des.nh.gov.
16
-------
June 2010 • LUSTLine Bulletin 65
Observations from an UST Compliance Service Provider
I read Marcel Moreau's article, "If I Had to Choose
Just One Method of Achieving UST Operational
Compliance...," in the March 2010 issue of LUST-
Line with great interest. I have, for the last 18 years,
operated a company providing UST compliance ser-
vices to tank owners.
Mr. Moreau advocates an annual, thorough check
of the entire fueling system from top to bottom, includ-
ing operability checks of the various components. Not
bad, but is it good enough? I think not, based on my
experience in the field.
I have the oil changed in my company vehicles
every 3,000 miles. While the mechanic changes the oil
he checks the belts, hoses, brakes, along with various
fluid levels—transmission, coolant, brake...even wind-
shield washer fluid—and alerts me to any potential
problems. I've found it is easier and cheaper to address
problems early rather than when I'm broken down on
the side of the road. Like the TV ad says: "You can pay
me now or you can pay me later...."
Just as most of us get our oil changed every 3,000
miles, I advocate a monthly visual check of all the com-
ponents of an UST system. This will allow you to iden-
tify small problems early enough to keep them from
becoming major issues. Let me give you some examples
based on my experience in the field.
I probably check and clean around 500 spill-con-
tainment manholes every month. Not one of them is
clean and dry from one monthly visit to the next. I reg-
ularly find cracks or holes in those plastic spill buckets,
caused by movement and rough handling of the equip-
ment by transport drivers, I suspect. Another problem
area is where the spill-containment "boot" is clamped
to the riser—these clamps break or come loose. If you
catch these problems early you can prevent ongoing
leakage into the surrounding backfill and, in North
Carolina at least, use an approved method to repair
the spill bucket, rather than face a minimum $6,000
expense to replace it with a monitored double-walled
spill-containment manhole. I cannot count the number
of gauge sticks I've removed from overfill-prevention
valves; occasionally I've even found these valves miss-
ing entirely from one monthly inspection to the next.
At one site I visit there's an old mechanical line leak
detector in the submersible turbine pump (STP) sump
and a filter in the under-dispenser containment (UDC)
sump. On one inspection I see that these contain a bit of
product, and if the sump fills with water, the fuel could
leak out. Fuel is dripping from the new filter, or meter.
Smells like gas around that STP, and I notice some soil
staining I didn't see last month. Inside, the ATG shows
a probe is out. One of the ELLDs is no longer perform-
ing a 0.1 or 0.2 gph test because the STP is running con-
stantly. The impressed current rectifier box is reading 0
volts and amps because someone flipped the breaker,
or a fuse blew after a thunderstorm. Jane is supposed
to call the office about these problems, but she got busy
with paperwork, and forgot. And so it goes...
So I choose a hybrid monthly visual inspection by
a qualified third party for UST compliance. Just as you
can prevent a lot of expensive auto repairs with regu-
lar scheduled preventive maintenance, you can avoid
expensive repairs and UST compliance issues with a
monthly scheduled visual check of your UST system. I
simply do not think that an annual inspection/opera-
tion check is often enough.
Do you have the discipline, or the staff with
enough time to do the monthly check? Probably not.
Are you worried about your UST operator filling out
his checklist in the office instead of actually looking
under the manhole covers and inside the dispensers?
You should be. It's cold outside, those manhole cov-
ers are awfully heavy, and last month he couldn't get
the regular cover off at all! He broke the key off in the
door to dispenser 1-2, and he doesn't have another one.
After the monthly check he smells of gas and just wants
to go home and take a shower and change. He works
9-10 hours a day as it is, without this added burden.
Get a qualified third party to do it. Get someone who
knows about petroleum-handling equipment as well as
the UST regulations. He needs to "think" like a regula-
tor while performing the monthly inspection. •
Charles Broadf oot
Charles Broadf oot & Associates, Inc.
Fayetteville, NC
UST Operational Compliance? Keep It Simple!
In his article, "If I Had to Choose Just One Way of
Achieving UST Operational Compliance," LUST-
Line #64, Marcel Moreau claims that by having an
annual operational inspection by a qualified service
technician, "one phone call does it all." He says the UST
operator doesn't need to remember all the things he is
responsible for—like line leak detector testing, ATG
maintenance, crash-valve checks, etc., etc. Well what is
operator training for? Who is ultimately responsible for
compliance? The service provider? No, it's the operator.
I agree with what Marcel is promoting, but opera-
tors need to know their system to ask the right ques-
tions and not get snowed by the low-cost service
provider. Of course I know Marcel knows that. The
problem is in most states operator training is the law,
• continued on page 18
17
-------
LUSTLine Bulletin 65 • June 2010
et-a continue!
UST Operational Compliance? Keep It Simple!
not annual inspections by qualified technicians. Also,
if most operator training will simply be a test, I expect
that Marcel's suggestion would be a good one.
However, we are dealing with mostly mom and
pops and they need to understand what is necessary.
I see too many sites where the method of leak detec-
tion could be less costly, but the owner is talked into
purchasing, for whatever reason, a more expensive
method. Now that, in most cases, we require secondary
containment for new tanks and piping, why would you
need to do any tank leak detection outside of monitor-
ing the interstice?
I think that the best way to address this and other
issues is to design systems that require little oversight.
Use suction systems on piping, use double-walled
tanks, install piping and tanks that do not require any
cathodic protection, and use spill buckets with second-
ary containment. If these features were in place, you
would need service providers primarily for fixing card
readers and the like.
Most mom and pops don't have the resources to
respond to water alarms in sumps and other nuisance
issues associated with more complicated monitoring
systems. In some of our rural areas it costs $600 just
to get to the location before any work is done. In fact,
with many systems, even if inspectors identify prob-
lems such as compatibility issues, cracks in piping, or
that yellow piping that is falling apart, our regulatory
hands are tied to get them replaced because they are
not leaking.
So why require annual inspections by service
providers when we do not have the staff to see if the
work that is done will help the owner meet the regula-
tions? We only visit the sites every three years, and by
the time we get back, 30 percent of the operators will
be someone else, and they need to be trained so they
understand that they are responsible for the day-to-day
operations of that facility.
So, if I had to choose just one way of achieving
UST operational compliance, it would be to Keep It
Simple! •
Rickjarvis, Idaho DEQ UST/LUST Program Coordinator
Verification Testing of ATG Performance for
Ethanol-Blended Fuels
The USEPA Office of Research
and Development's Environ-
mental Technology Verifica-
tion Program (ETV), Advanced
Monitoring Systems (AMS) Center,
operated by Battelle, is developing
a test plan to assess automatic tank
gauging (ATG) systems for detect-
ing leaks from USTs using various
ethanol blends. The intent is to col-
lect unbiased data concerning the
performance of leak-detection tech-
nologies with ethanol blends. It is
important to understand the per-
formance of ATGs when used with
ethanol-blended fuels because of the
differences in chemical and physical
properties between petroleum and
ethanol, specifically the difference in
their miscibility with water. The test
plan is being developed in collabora-
tion with the National Work Group
on Leak Detection Evaluations
(NWGLDE), USEPA Office of Under-
ground Storage Tanks (OUST), and
other stakeholders. ATGs are the first
in a series of planned leak-detection
technology assessments. ATGs will
be tested first since they are the most
18
widely used leak-detection method
in the United States.
Over the past six months, the
AMS Center has formed a techni-
cal stakeholder panel and a vendor
panel to provide input to the test
plan. These panels consist of repre-
sentatives from industry associations,
state and federal governments, and
users. Panel constituents include the
Underwriters Laboratories, Renew-
able Fuels Association, Petroleum
Marketers Association of America,
Oak Ridge National Laboratories,
NWGLDE, USEPA Regions 4 and
10, 12 states (WI, NY, TN, MA, CA,
MS, AL, NH, UT, CT, DE, MI), and
the U.S. Army Environmental Com-
mand.
Panel discussions have been
held, and a draft test plan has been
written. The plan is currently going
through a peer review process to
establish an unbiased evaluation
of the performance of this particu-
lar technology category. During the
coming months, the AMS Center
will solicit collaborators and vendors
to participate in technology testing
through this third-party testing pro-
cess. Depending on the scope of the
test plan and vend or/collaborator
interest, testing is expected to start
in late 2010. For more information on
the ETV AMS Center, visit the web-
site at http://TVWTV.epa.gov/nrmrl/std/
etv/center-ams.html. For specific inqui-
ries about this verification test, con-
tact Anne Gregg at Battelle (gregga®
battelle.org or 614-424-7419). •
August 1985/Bulletin #1 -
June 2010/Bulletin #65
The LUSTLine Index
is ONLY available online.
To download the
LUSTLine Index, go to
http://www.neiwpcc.org/lustline/
and then click on LUSTLine.
-------
June 2010 • LUSTLine Bulletin 65
A MESSAGE FROM CAROLYN HOSKINSON
Director, USEPA's Office of Underground Storage Tanks
What's New at USEPA?
It's been over a year since Administrator Lisa Jackson
took on the job of leading the USEPA under the Obama
Administration. So what's new and different under this
leadership? And how is it playing out in our tanks pro-
gram?
Earlier this year, Administrator Jackson announced
seven priorities for USEPA, underscored by three core val-
ues for how we are to go about our work (see text boxes
and http://blog.epa.gov/administrator/2010/01/12/seven-
priorities-for-epas-future/}. She also said that she expected
each of us at USEPA to consider ourselves not just within
the scope of our individual programs, but as one united
USEPA committed to working together to achieve our
mutual goals.
USEPA's Priorities
• Taking action on climate change
• Improving air quality
• Assuring the safety of chemicals
• Cleaning up our communities
• Protecting America's waters
• Expanding the conversation on environmentalism
and working for environmental justice
• Building strong state and tribal partnerships
USEPA's Core Values
• Science
• Transparency
• The rule of law
Each of us has been asked personally to consider how
the work we do and the work of our programs serve to fur-
ther the agency's mission.
It's obvious that the national underground storage tank
(UST) program's ongoing work to prevent and clean up
UST releases supports three of these Agency priorities—
cleaning up our communities, protecting America's waters,
and expanding the conversation on environmentalism and
working for environmental justice.
The last, and arguably the greatest, priority—building
strong state and tribal partnerships—is one that is inter-
woven into the fabric of all we do. Since the beginning of
the UST program, we have embraced our relationship with
state, territorial, and tribal UST partners, and indeed with all
our program stakeholders—from regulated tank owners,
to equipment manu-
facturers, to service
providers, to affected
communities. For me
personally, these relationships are truly the most rewarding
part of being in the UST program.
To Further USEPA's Priorities, OUST Is
Involved in Specific Initiatives
Within USEPA's Office of Solid Waste and Emergency
Response (where OUST resides along with such sister pro-
grams as Superfund, Brownfields, Hazardous and Solid
Waste, and Emergency Response), OUST has embraced
and become a part of several cross-OSWER and cross-
Agency initiatives. Below are five examples of where we're
doing our part to overcome the individual, narrow stove-
pipes, or spheres of interest, within which we often oper-
ate. I don't know if our stovepipes are built out of straw,
sticks, or bricks, but we're huffing and puffing at them and
maybe someday we'll blow them all down.
• COMMUNITY ENGAGEMENT- In December 2009,
USEPA's Office of Solid Waste and Emergency Response
(OSWER) issued its community engagement initiative,
released a proposed action plan—which presents prin-
ciples, goals, and objectives for community engagement
—and solicited feedback from community stakeholders
and the general public. On May 20, 2010, OSWER released
a detailed implementation plan, listing specific actions to
enhance community engagement (see www.epa.gov/oswer/
engagementinitiative). OSWER is committed to reaching out
to all stakeholders so they can meaningfully participate in
government decisions regarding land cleanup, emergency
preparedness and response, and hazardous substances
and waste management.
How is OUST involved? While we recognize that states
and territories implementing the UST program often engage
with communities above and beyond that required in the
federal UST regulations, OUST is examining current prac-
tices, identifying best practices, and evaluating ways the
UST program currently engages with communities. Over
the coming months, we will be developing materials about
community engagement in the context of the UST program,
discussing it in September at the National Tanks Conference
in Boston. We ask that you share with us your thoughts and
comments. For more about OUST's work on community
engagement, contact Barbara Grimm-Crawford at grimm-
crawford.barbara@epa.gov or 703-603-7138.
• continued on page 20
19
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LUSTLine Bulletin 65 • June 2010
MESSAGE FROM CAROLYN HOSKINSON continued from page 19
• INTEGRATED CLEANUP - OSWER's integrated
cleanup initiative is a strategy to integrate and leverage
land cleanup authorities to address a greater number of
contaminated sites, accelerate cleanups, and put these
sites back into productive use while protecting human
health and the environment. (See www.epa.gov/oswer/
integratedcleanup.htm for more information.) OSWER is
currently working on an implementation plan for the inte-
grated cleanup initiative.
OUST's backlog characterization study and petro-
leum brownfields projects clearly fit within the integrated
cleanup initiative's objectives of working to advance clean-
ups; enhance partnerships between cleanup programs,
other agencies, states, tribes, and local governments;
and link cleanup and revitalization efforts. For more about
OUST's work on the integrated cleanup initiative, contact
Sue Burnell at burnell.susan@epa.gov or 703-603-9231.
• RE-POWERING AMERICA'S LAND - OSWER
launched the RE-Powering America's Land initiative to
explore opportunities for siting renewable energy on
potentially contaminated land and mining sites (see www.
epa.gov/oswercpa/). USEPA and the Department of Ener-
gy's National Renewable Energy Laboratory (NREL) are
collaborating on projects to evaluate potential opportuni-
ties.
NREL's investigation for the UST program is exploring
opportunities to site or otherwise support the infrastruc-
ture for alternative-fuel vehicles. Because former gas sta-
tions are often small in size, energy-supply facilities may
be difficult to site there; but because they are located near
traffic intersections and other heavily trafficked routes, an
alternative-fuel-vehicle infrastructure may present unique
ways for petroleum brownfields sites to contribute to the
nation's use of alternative fuels and renewable energy.
USEPA expects to release a report summarizing the inves-
tigation in winter 2011. For more about OUST's work on
RE-Powering America's Land, contact Deb Steckley at
steckley.deb@epa.gov or 703-603-7181.
• URBAN WATERS - USEPA recently launched an
urban water initiative, a component of Administrator Jack-
son's priority to protect America's waters. The goal of this
initiative is to restore and protect urban water bodies by
engaging communities in activities that foster increased
connection, understanding, and ownership of their waters
and surrounding land. Urban environments, particularly
in disadvantaged communities, are often dominated by
impervious surfaces, industrial facilities, and abandoned
or vacant, often contaminated, lands.
OUST is participating in a cross-agency workgroup on
this initiative. We plan to involve state and tribal UST part-
ners in activities that support leaking UST-system cleanup
and petroleum brownfields reuse and that focus on the
restoration and protection of urban waters. USEPA intends
to make a draft strategy available for stakeholder review
in late spring. The agency also plans to hold a forum for
stakeholder comment and input. For more about OUST's
work on the urban waters initiative, contact Deb Steckley
at steckley.deb@epa.gov or 703-603-7181.
• AREA-WIDE PLANNING - USEPA's Office of Brown-
fields and Land Revitalization is piloting a program that
will provide communities with grants to develop area-wide
plans, which will help in assessing, cleaning up, and reus-
ing brownfields. The goal of the area-wide planning pro-
gram is to work in partnership with local communities to
help create a shared vision for brownfields-impacted areas
—neighborhoods, districts, city blocks, or corridors—and
to ensure that brownfields assessment and cleanup deci-
sions include planned reuse for the sites and support area-
wide revitalization strategies. USEPA will share information
about lessons learned with stakeholders nationally. See
text box for information about the request for proposals.
Area-Wide Planning For Brownfields
• Approximately $3.5 million available ($175,000 per
project) to provide money and technical assistance
for 20 pilot projects in brownfields-impacted areas,
such as neighborhoods, districts, city blocks, or
corridors
• Assistance will enhance area-wide planning and
revitalization
• Request for proposals issued March 30
• Proposals were due June 1, 2010
• Awards anticipated in August 2010
• Proposal available on EPA's Web site: www.epa.
gov/oswer/docs/grants/epa-oswer-oblr-10-05.pdf
OUST is supporting this effort inasmuch as many
brownfields are impacted by petroleum, much of it from
leaking USTs at old gas stations. In addition, many states
and others have already been pursuing area-wide efforts,
such as Route 66 in the Southwest, Colorado Historic
Revitalization Initiative, Tamiami Trail in Florida, National
Historic Voting Rights Trail from Selma to Montgomery in
Alabama, Route 99 in California, I-5 in Oregon and Wash-
ington, and many more. For more about OUST's work on
area-wide planning, contact Steve McNeely at mcneely.
steven@epa.gov or 703-603-7164. •
20
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June 2010 • LUSTLine Bulletin 65
OUST Issues a Revised "Short List" of Potential
Changes to UST Regulations
Two years ago the USEPA Office of Underground Storage Tanks (OUST) started the process to consider changes to the
UST regulations to better protect the environment and to improve implementation of the program. After considering
input from a wide variety of stakeholders, in June 2009 OUST shared a "short list" of issues it planned to evaluate
further. After considering the costs, benefits, and technical feasibility of the possible changes, OUST has now revised the short
list. Below is the current list of issues OUST plans to continue to move through the USEPA regulatory process. This list may
change further as OUST navigates the regulatory process. OUST hopes to publish a proposed rule in the federal register for
public comment this coming winter.
Release Prevention
• Operation and maintenance (O&M) - Includes over-
fill-functionality testing, walk-through checks, spill-
bucket testing, and integrity testing for interstitial
areas.
• Ball floats - Eliminate flow restrictors in vent lines as
an overfill device on new systems and when overfill
is replaced.
• Repairs
- Address repairs and secondary containment - If
primary or secondary wall is fixed, must verify
structural integrity of the interstitial space before
returning tank/piping to service.
- Revise repairs section - Include non-release repairs
and requirements/testing. This will also require
re-evaluating repair definition and disassociating
repair from release.
Release Detection
• O&M - Walk-through checks and periodic opera-
tional checks and testing (i.e., automatic tank gauge,
probes, sensors, line leak detectors, and alarms).
• New technologies - Incorporate new technologies
with applicable performance standards (i.e., statisti-
cal inventory reconciliation (SIR), continuous in-tank
leak detection systems (CITLDS)).
• Suspected releases - Address interstitial alarms
with regard to section 280.50 "Reporting of Suspected
Releases."
• Leak-detection methods - Phase out groundwater
and vapor monitoring as leak-detection methods.
Other
• Update Regulations to acknowledge 1998 deadline
has passed.
• Require closure of lined USTs that fail periodic
inspection and cannot be repaired.
• Update tank and piping sections for new technolo-
gies - include clad and jacketed tanks, flexpiping.
• Require revised notification forms when ownership
changes at the facility.
• Make technical corrections (e.g., update standards,
correct typos).
• Address alternative fuels and compatibility.
Deferrals
• Exclude USTs containing radioactive substances.
• Exclude emergency generator USTs at nuclear power
generation facilities regulated by NRC.
• Fully regulate emergency generator USTs.
• Regulate airport hydrant systems with alternate
release-detection requirements.
• Regulate field-constructed USTs with alternate
release-detection requirements.
• Regulate wastewater treatment tanks. •
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21
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LUSTLine Bulletin 65 • June 2010
FAQs from the NWGLDE
...All you ever wanted to know about leak detection, but were afraid to as
Continuous Leak Detection Methods
In this LUSTLine FAQs from the National Work Group on Leak Detection Evaluations (NWGLDE), we discuss the differences
between the types of continuous leak detection methods that are available for detecting leaks from single-walled underground
storage tank (LIST) systems. Note: The views expressed in this column represent those of the work group and not necessarily
those of any implementing agency.
Lj. What are the different types of continuous leak-
detection methods being used to detect leaks in
single-walled USTsystems?
A. The most common type of continuous leak-detection
method being used today is Continuous Automatic
Tank Gauging. This method uses a probe to collect
product-level and temperature data continually and
software designed to identify time intervals when
there is no activity in the tank to ensure that the data
are stable enough for analysis. An algorithm then
combines data from a number of these stable periods
until there is enough evidence to make a determina-
tion about the leak status of the tank. This method
functions like a static automatic tank gauge (ATG)
test, except that it does not require the tank be taken
out of service for a set period of several hours when-
ever a test is to be performed.
The method is designed to meet the USEPA monthly
monitoring performance standard of detecting a leak
of 0.20 gallon per hour with a 95 percent probability
of detection and no more than a 5 percent possibility
of a false alarm. Like the static ATG test, this method
only evaluates the tank vessel itself. It is widely used
in locations where monthly static ATG testing would
be disruptive to business but the tank still has occa-
sional periods of inactivity. Vendors such as Dresser
Wayne Europe (TIG ATG System), EBW (AutoStik
with SCALD), Hectronic GmbH (Optilevel CLTLDS),
OMNTEC (OEL with CITLDS), OPW (EECO and
Galaxy ATG Systems), Simmons (Tank Manager
with CITLDS), Veeder-Root (ProMax and ProPlus
with CSLD), and Franklin Fueling (TS with SCALD)
manufacture Continuous Automatic Tank Gauging
equipment.
Another continuous leak detection method, Con-
tinual Reconciliation, uses an onsite industrial
computer to retrieve data from pump controllers
associated with the point-of-sale system as well as
from the ATG. The method develops an ongoing
record of fuel inventory observations by pulling
together sales data every time a fuel transaction is
completed, and simultaneous tank-level and prod-
uct-temperature observations from the ATG. It uses
algorithms similar to those used for statistical inven-
tory reconciliation (SIR). Data from delivery records
can be recorded, but the actual volumes of deliveries
to the tanks can also be independently calculated.
When the method's algorithms analyze the data, a
very accurate picture emerges of the product activity
in the tank (or tanks), and a loss, if present, becomes
apparent. Operational issues such as theft, miscali-
brated meters, blending problems, and delivery dis-
crepancies can also be determined. In addition, this
method may identify sudden or unexpected losses
of product from the tank vessel, pressurized lines, or
both.
This method is also designed to meet the USEPA
monthly monitoring performance standard of detect-
ing a leak of 0.20 gallons per hour with at least a 95
percent probability of detection and no more than a
5 percent probability of a false alarm. The only exam-
ple of a continual reconciliation method currently
appearing on the NWGLDE list is PetroNetwork S3
from Warren Rogers Associates, Inc. PetroNetwork
S3 allows a combination of monitoring data from
both static and dynamic operations of the tank to be
combined to monitor the tank system for a tank or
line leak. (See LUSTLine Bulletin #56 [August 2007]
article "Continual Reconciliation Applications for
Active Fueling Facilities" for additional information
about this system.) PetroNetwork S3 is used widely
at high-throughput locations where there is no down
time for static ATG testing or where continuous auto-
matic tank gauging does not have sufficient quiet
time to collect sufficient data to determine a monthly
leak detection result.
The Automatic Monthly Inventory Control method
is a third method of continuous leak detection. This
method uses continuous inventory monitoring as a
tank-management tool, both for business and inven-
tory. The Business Inventory Reconciliation (BIR)
system by Veeder Root and Reconciliation System
by Incon are two examples of this type of method.
To date, neither vendor has developed an automatic
monthly inventory control method that meets USEPA
requirements for monthly manual inventory moni-
toring, either alone or combined with another leak
detection method. These two systems are marketed
as business management tools while providing an
automatic way to meet daily inventory records and
monthly inventory reconciliation requirements.
The systems use the concept of inventory control
by adding the variance of 130 gallons to the gallons
pumped after dividing the gallons pumped by 100.
They then compare the overage and shortage of the
month with the leak-check result. These methods are
not third-party certified. Whether to accept the use of
• continued on page 23
22
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June 2010 • LUSTLine Bulletin 65
FAQs... continued from page 22
these systems as part of a release-detection method,
either alone or in combination with other evaluated
release-detection methods, 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 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 determine if each evalu-
ation was performed in accordance with an acceptable leak detection
test method protocol and ensure that the leak detection system meets
EPA and/or other applicable regulatory performance standards.
• Review only draft and final leak detection test method protocols sub-
mitted to the work group by a peer review committee to ensure they
meet equivalency standards stated in the U.S. EPA standard test pro-
cedures.
• Make the results of such reviews available to interested parties.
from Robert N. Renkes, Executive Vice President, Petroleum Equipment Institute (PEI)
ULSD, ULSD, ULSD...THE BEAT 4
In the last issue of LUSTLine (#64), I reported that
PEI held a meeting earlier this year at USEPA
headquarters with various industry and govern-
mental stakeholders seeking input on what seemed
to be an abnormal number of reports of excessive
rust and other damage to equipment in ultra-low-sul-
fur diesel (ULSD) service. The result of that meeting
was to develop a screening survey that would go out
to industry and state UST inspectors in an effort to
understand the extent of the corrosion in ULSD stor-
age and dispensing systems.
The month-long survey was hosted by PEI and sent
to North American tank owners, fuel suppliers, equip-
ment service providers, equipment manufacturers,
tank/ equipment regulators, cargo tank motor-vehicle
owners, and others in March/April of 2010. Nearly
1,200 people responded and some findings from the
survey were quite revealing:
• 496 (42 percent) of respondents reported increased
equipment-related issues of one kind or another
after introduction of ULSD.
• These respondents identified close to 5,000 loca-
tions with apparent ULSD-related problems.
• Reported problems were spread widely across the
United States and Canada, rather than being con-
fined to a particular geographic region.
• Only 124 (12 percent) of survey participants were
service providers. Tank owners (including fuel
suppliers who may also own tanks) accounted for
829 of the responses (69 percent). Six percent of the
respondents were either tank or equipment inspec-
tors/regulators.
Notably, 449 survey participants gave additional
comments about their experiences with ULSD. The
problems mentioned most frequently were:
• Filters clogging/requiring more frequent replace-
ment
• Seal/gasket/O-ring deterioration
• STP replacement/column pipe wear/motor prob-
lems
• Tanks rusting/leaking (includes fuel tanks on vehi-
cles)
• Meter failure
• Line leak detectors damaged or broken
• Automatic nozzle shutoff failure/ shorter lifespan
• Tank probes malfunctioning
• Check valves not seating
• Shear valves not sealing/ failing tests
• Swivels failing/ shorter lifespan
• Dispenser leaks/failure/premature replacement
• Solenoid valves clogged/failing
• Corrosion on the riser pipe
• Pipe failure
On April 8, 2010, the stakeholders gathered again in
Washington, D.C., to discuss the survey results and plan
next steps. At that meeting, the consensus was that while
the preliminary survey uncovered a variety of apparent
ULSD-related issues, the results were inconclusive as to
the potential causes of these issues. The meeting ended
with the Clean Diesel Fuel Alliance (CDFA) agreeing to
head future efforts to understand the nature and deter-
mine the causes of the problem.
The CDFA Steering Committee met May 19 and
agreed to develop a tank-maintenance guidance docu-
ment and post it on the CDFA website (www.clean_diesel.
org). In addition, the committee will seek a consultant to
assist in determining the scope and nature of the issues
associated with the storage and dispensing of ULSD. The
CDFA hopes to have more information on which to act by
the end of the year.
The ULSD problem will be discussed this Septem-
ber at the National Tanks Conference in Boston. A more
detailed report on the survey results is available at wima.
peijournal.org. •
23
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LUST. .INE
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TRNKS CONFERENCE
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