New England Interstate
Water Pollution Control
Commission
www.neiwpcc.org/lustline
116 John Street
Lowell, Massachusetts
01852-1124
LU.S.T.L
A Report On Federal & State Programs To Control Leaking Underground Storage Tanks
Bulletin 66
December
2O1O
er d^&rses f
USEPA's Partial El 5 Waiver
Still Has Some Its, Ands, or Buts
by Patricia Ellis
Prologue
One of the goals of the Energy Policy Act of 2005 (EPAct 2005)
was to expand the use of renewable fuels in the transportation
sector. This legislation required the establishment of a Renew-
able Fuels Standard (RFS). In December 2007, Congress passed
the Energy Independence and Security Act of 2007 (EISA), which
revised the RFS, and, in effect, greatly increased the volumes of
renewable fuels required. EISA required that 15.2 billion gallons
of renewable fuel be used in the transportation sector in 2012,
and at least 36 billion gallons per year by 2022. (See page 6.)
Current USEPA regulations allow a maximum of 10 percent
ethanol, by volume, to be blended into gasoline. The total quan-
tity of ethanol being blended into gasoline today is nearing 10
percent of the volume of gasoline consumption, which means
that ethanol is about to hit its upper limit, or "blend wall." There
are two ways we can use ethanol to meet the renewable fuel tar-
gets set by EISA: either we have to use more E85 (which can
only legally be used in flex-fuel vehicles), or we need to be using
more than 10 percent, by volume, of ethanol in conventional and
reformulated fuels.
On October 13,2010, USEPA granted a partial waiver for the
use of gasoline containing up to 15 percent by volume ethanol
(Federal Register: Nov. 4, 2010, Vol. 75, No. 213). The waiver
applies only to model year 2007 and newer light-duty motor
vehicles, which includes passenger cars, light-duty trucks, and
medium-duty passenger vehicles. A decision on the use of E15
in vehicle model years 2001 through 2006 will be made after
USEPA reviews the results of additional testing by the Depart-
ment of Energy, which was recently completed. (See "NREL's
Study on Testing Mid-Level Ethanol/Gasoline in Dispensing
Equipment" on page 7.)
No waiver is being granted for the use ofE15 in model year
2000 and older cars and light trucks or in any motorcycles,
heavy-duty vehicles, or non-road engines, because currently
there is no testing data to support such a waiver. You can find
all documents relating to the Waiver Request at http://www.epa.
gov/otaq/regs/fuels/additive/e157. During the comment period on
the waiver request about 78,000 comments were submitted to
the USEPA docket. Only a handful of these comments mentioned
UST-system infrastructure issues.
I continued on page 2
Inside
NREL Study—Mid-Level Ethanol in Dispensing Equipment
It's the Compatibility Thing—Iowa
Ferreting Out the Identity of Gasoline Additives
Predicting Impact of Biofuels on BTEX Plumes
Vapor Intrusion: Petroleum Hydrocarbon Issues
In Situ Chemical Oxidation
National LUST Cleanup Backlog
New ASTM Release Investigation Standard
Class C Operator Saves the Day
RP100 UST Installation Document
FAQs: Unsupported Leak Detection Methods
-------
LUSTLine Bulletin 66 • December 2010
• Partial E15 Waiver from page 1
Because of the confusing nature of
all of this, USEPA is taking several steps
to help consumers easily identify the
correct fuel for their vehicles and equip-
ment. First, the agency is proposing
pump-labeling requirements, including a
requirement that the fuel industry specify
the ethanol content of gasoline sold to
retailers. There would also be a quarterly
survey of retail stations in most areas
across the country. The proposed rule is a
"Regulation to Mitigate the Misfueling of
Vehicles and Engines with Gasoline Con-
taining Greater than Ten Percent Ethanol
and Modifications to the Reformulated
and Conventional Gasoline Programs,"
which has a comment period that ends on
January 3,2011.
The API Report
With the granting of the partial
waiver request, many changes will
have to be made in rules and regula-
tions before E15 can be sold legally.
An August 2010 report, Identification
and Review of State/Federal Legislative
and Regulatory Changes Required for
the Introduction of New Transporta-
L.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.
New Transportation Fuel Identified
Infrastructure/ Dispenser
Testing Development
EPA Waiver/Substantially
Similar Determination
Modify ASTM/NIST Specs
Modify State Fuel
Requirements
Modify Codes/
Develop
Infrastructure
Finalize Distribution
Implementation
FIGURE 1. Generic schematic of the process for introduction of new transportation fuels.
tion Fuels, prepared for the Ameri-
can Petroleum Institute by Sierra
Research, Inc., details what needs
to be done before E15 can be intro-
duced into the marketplace (http://
www.api.org/aboutoilgas/otherfuels/
upload/Sierra_Final_Alt_Trans_Fuel_
Report_0804W.pdf).
The introduction of a new trans-
portation fuel into the marketplace
is not simple or straightforward; it
requires numerous changes to fed-
eral and state laws, regulations, and
standards. The time required to make
all of the required changes listed by
Sierra is estimated to be as much
as several years. Figure 1 shows a
generic schematic of the required
process, along with estimated time
frames needed to complete the vari-
ous tasks. At the time that the partial
waiver was announced, some news
articles claimed that E15 would be
available for sale as soon as a few
months from now. Evidently a few
states plan on skipping a few steps in
the process!
The API report includes an
appendix summarizing the antici-
pated changes that will be required
for each state in order to introduce
ethanol blends greater than 10 per-
cent into commerce. In this article,
I will attempt to provide some
essential hurdles discussed in this
report—federal requirements, state
requirements, warranties, fuel stor-
age, marketing and distribution, and
liabilities.
Federal Fuels Requirements
• New Transportation Fuels Must
be "Substantially Similar" to Existing
Fuels Since E15 contains more than
2.7 percent oxygen, by weight, it
does not qualify to be "substantially
similar" to existing fuels; therefore a
waiver must be issued before it can
be used as a transportation fuel.
• Fuel Registration and Health
Effects Part 79 of the Title 40 Code
of Federal Regulations requires that
any manufacturer of a motor-vehicle
gasoline or diesel fuel or an additive
used in either, must register with
USEPA prior to introduction of the
fuel or additive into commerce. A
rule was later added requiring health
effects information and additional
air-related research. In addition to
basic registration information about
product composition, concentration,
and production volume, information
must be provided about combus-
tion emissions, evaporative emis-
sions, and potential adverse health
effects related to inhalation of these
emissions. The health-effects testing
usually involves exposing labora-
tory test animals to the emissions.
USEPA evaluates the results of these
-------
December 2010 • LUSTLine Bulletin 66
submissions and makes a determina-
tion as to whether additional testing
is required. Only when all testing has
been submitted and evaluated by
USEPA can the fuel or fuel additive
be registered and introduced into
commerce.
• Fuel Rating and Labeling Since
USEPA issued a "partial waiver,"
allowing blends with ethanol greater
than 10 percent only in vehicles
newer than a specific model year,
additional labeling requirements
may be necessary, either by the FTC
or USEPA. If more aggressive means
than pump labeling are required
to prevent misfueling with higher-
level ethanol blends, implementation
could take several years and could
be quite costly. The announcement of
proposed rulemaking was issued the
same day that the partial waiver was
granted.
The Federal Trade Commission
(FTC) administers requirements for
gasoline and diesel-fuel ratings and
labeling. Existing regulations cover
ethanol blends up to E10 and fuels
with at least 70 percent ethanol, but
blends between E10 and E70 are not
currently covered. The FTC has initi-
ated a rulemaking for blends greater
than E10, which would require either
identification of the precise concen-
tration of ethanol in the blend or
disclosure of the range of ethanol in
the blend. In addition, the proposal
would change labeling requirements
for all gasoline-ethanol blends to
warn that blends with more than 10
percent ethanol may harm some con-
ventional vehicles. Since both agen-
cies are simultaneously proposing
rules for the same thing, let's hope
their efforts will be collaborative.
• Gasoline Detergent Certifica-
tion The Clean Air Act mandated
that USEPA adopt regulations requir-
ing the use of additives in gasoline
to prevent the buildup of deposits
in engines or fuel-supply systems.
Since existing certifications were
made using fuels containing no more
than 10 percent ethanol, changes to
USEPA gasoline detergency regula-
tions with ethanol blends greater
than 10 percent will need to be made
to assure that additives are effective
in preventing buildup in engines
using blends with more than 10 per-
cent ethanol.
• Volatility Exemption for Ethanol
Blends Greater Than 10 Percent The
addition of ethanol to a gasoline
blendstock increases the volatility
of the blend relative to neat gaso-
line; therefore, USEPA created a one-
psi exemption for gasoline-ethanol
blends sold in the summer months
in non-reformulated gas (RFG) areas.
The exemption does not apply to
gasoline with greater than 10 per-
cent ethanol. Without an exemption,
a lower-volatility blendstock would
need to be used. A USEPA rulemak-
ing to extend the exemption to higher
ethanol concentrations could take six
to twelve months. The federal Reid
vapor pressure (RVP) exemption is
not an issue in RFG areas, because
the same VOC requirements would
apply for blends with more than
10 percent ethanol as for other RFG
blends, including E10.
The USEPA partial waiver deci-
sion document includes a discus-
sion by USEPA that it is believed
that E15 blends with higher vola-
tility would cause vehicles to vio-
late their evaporative emissions
standards. Therefore, the partial
waiver is for E15 blends that meet
the summertime gasoline volatility
standards for conventional gasoline
without any 1.0 psi RVP waiver. In
order to introduce a fuel that both
meets the federal summertime RVP
standards and contains between 10
and 15 percent ethanol, fuel refiners
would have to create a fuel or blend-
stock that has approximately 1.0 psi
lower RVP than a fuel or blendstock
intended for E10 due to the interac-
tion between gasoline volatility and
ethanol when blended.
• RFG Federal RFG requirements
are still in effect along most of the
northern Atlantic seaboard, most
of California, and in a number of
other major urban areas. A Complex
Model is used to determine where
RFG is required. The Model esti-
mates the impacts of changes in eight
specific gasoline properties relative
to a 1990 baseline. The proposed
rule includes changing the Complex
Model for ethanol blends greater
than E10, because the limit for oxy-
gen content in the Model was 4.0
percent by weight (approximately
Ell.5). The length of time required to
revise these regulations will depend
on whether sufficient emissions
data exists for vehicles representa-
tive of 2007 vehicle fleets. EPAct 2005
required some of this testing.
State Fuels Requirements
In addition to the federal fuel
requirements, most states and some
regions have enacted their own
requirements for transportation
fuels.
• ASTM and NIST Specifications
Many states have adopted Ameri-
can Society for Testing and Mate-
rials (ASTM) specifications for
gasoline (ASTM D4814) or specifica-
tions established by National Con-
ference on Weights and Measures
(NCWM) under the National Insti-
tute of Standards and Technology
(NIST). While the scope of the ASTM
standard applies to ethanol blends
greater than E10, it is unlikely that
ethanol blends greater than 10 per-
cent could meet the T50 limits of the
current version of the standard with-
out modification (the T50 limit is
the temperature at which 50% of the
gasoline would evaporate). The cur-
rent lower T50 limit applies only to
ethanol blends from 1 to 10 percent
by volume. Most states have adopted
some version of the ASTM standard,
but some adopt the most recent ver-
sion and others adopted the version
of a specific year. Some states have
adopted the NIST volatility limits for
ethanol blends, and similar problems
will exist for those states.
• Blending Restrictions and Blending
Caps Various states have specified
a blending cap of 10 percent ethanol,
by volume, in state fuel specifica-
tions, state biofuels mandates, and
tax incentives for renewable fuels.
Other states have adopted the most
recent version of NIST Handbook
130, which specifies a blending cap
of 10 percent. These states would
require either a change in state leg-
islation or regulations to permit
ethanol concentrations greater than
10 percent, or a modification by
National Conference on Weights and
Measures to the NIST handbook to
raise the blending cap.
• Waivers from Gasoline Vapor-Pres-
sure Requirements In addition to
the federal RVP exemption for E10,
many states have adopted gasoline
• continued on page 4
-------
LUSTLine Bulletin 66 • December 2010
• Partial E15 Waiver from page 3
volatility limits, either by adopting
ASTM D4814 or NIST Handbook
130, or by establishing state vapor-
pressure limits. A large number of
states would have to make changes
to expand RVP waivers to ethanol
blends greater than 10 percent.
• T50 Minimum Offsets and Vapor-
Lock Protection (T@V/L=20) Many
states have adopted their own allow-
ances for offsets for T50 minimum
distillation temperatures and vapor-
lock protection either by adopting
ASTM D4814 or NIST Handbook 130,
or by independently establishing lim-
its through legislation and/or regu-
lation. Where their allowances are
limited to E10 blends, changes would
have to be made to apply them to eth-
anol blends greater than 10 percent.
• California To introduce any
new fuel in California, a multimedia
assessment must first be conducted.
The second step involves the estab-
lishment of fuel specifications by
the California Air Resources Board
to ensure that the new fuel does
not result in increases in air pollut-
ant emissions. In addition, all fuel
must comply with the California Air
Resources Board's (CARB's) Phase
3 RFC regulations, which currently
include a blend cap of 10 percent etha-
nol. The California Predictive Model
(similar in concept to the USEPA Com-
plex Model) must be used to analyze
data from an extensive vehicle-testing
program. The predictive Model indi-
cates increases in NOx emissions with
higher levels of ethanol, therefore
other changes would have to be made
to the RFG 3 requirements to mitigate
this increase, such as further restric-
tions on sulfur content.
• State Implementation Plans For
states that are ozone non-attainment
areas, introducing ethanol blends
greater than 10 percent may require
changes to state implementation
plans under the Clean Air Act. If
changes are necessary, they require
USEPA approval.
Vehicle and Engine
Warranties
• Light-Duty Gasoline Vehicles Use
of ethanol blends greater than 10 per-
cent in light-duty gasoline vehicles
may void vehicle warranties, creat-
ing potential liabilities for vehicle
owners. A review of owner's manu-
als for ethanol usage in non-flex-fuel
vehicles for model years 1999, 2000,
2003, 2006, 2009, and 2010 shows that
10 percent ethanol is the maximum
concentration allowed by any manu-
facturer. Manufacturers may take the
position that they are not required
to address adverse impacts caused
by the use of higher blends of etha-
nol in existing vehicles that are in the
model years covered by the waiver.
• Other Gasoline-Fueled Equipment
Non-road products with gasoline
engines include lawn mowers, chain-
saws, forklifts, boats, personal water-
craft, and all-terrain vehicles. USEPA
did not approve the Growth Energy
waiver request for non-road engines,
vehicles, and equipment for two pri-
mary reasons: (1) Growth Energy did
not provide enough information to
assess the potential impacts of E15 on
the compliance of non-road engines
with applicable emission standards,
and (2) concerns expressed by non-
automotive engine manufacturers
such as ALLSAFE (Alliance for a Safe
Fuels Environment). These concerns
include the following: (1) engine
operability problems, including loss
of power, stalling, and overheating;
(2) substantially shortened engine life
due to enleanment of air-fuel ratios;
(3) catastrophic engine failures; (4)
incompatibility with fuel-system
materials; and (5) increases in exhaust
and evaporative emission levels.
Fuel Storage, Marketing, and
Distribution
It is possible that many extensive,
time-consuming, and costly changes
may also be needed in the areas of
storing, marketing, and distribut-
ing ethanol blends greater than 10
percent. Numerous standards exist
regarding the installation and opera-
tion of the fueling infrastructure.
Most of these standards require that
the equipment be "compatible" with
the product being stored and dis-
pensed and that the equipment be
"listed" by independent organiza-
tions such as Underwriters Laborato-
ries (UL).
Organizations and regulatory
agencies with jurisdiction over or
standards that apply to fuel-dis-
pensing facilities include the follow-
ing: Occupational Safety and Health
Administration (OSHA), National
Fire Protection Association (NFPA),
International Code Council (ICC),
UL, USEPA, and American National
Standards Institute. Many states also
have regulatory agencies with juris-
diction over fueling facilities and
fuel-dispenser and product labeling.
• Pipelines and Terminals If E10
and ethanol blends greater than 10
percent use the same blendstocks,
minimal changes are expected with
regard to transportation and storage
infrastructure. With a partial waiver,
the amount of change that may be
required will depend on whether dif-
ferent blendstocks are required. Dif-
ferent blendstocks would need to be
transported separately and stored
separately at terminals. Currently,
most ethanol is transported by barge,
rail, and truck, separately from gaso-
line. As larger and larger volumes
of ethanol are transported, pipelines
will become more attractive for etha-
nol and gasoline-ethanol blend trans-
port. This generates concerns over
water entrainment and phase separa-
tion of gasoline and ethanol; degra-
dation of materials used in pipelines
and storage tanks by ethanol and
gasoline-ethanol blends; and stress
corrosion cracking of pipelines.
• Retail Fuel Outlets The main
concerns with respect to increasing
ethanol concentrations in gasoline
are similar to those for existing vehi-
cles—materials compatibility with
components of the fuel storage and
dispensing systems. These concerns
raise liability issues for fueling out-
lets, and the marketing of ethanol
blends greater than 10 percent could
be a violation of some local building
or fire codes. As the API report men-
tions, the following equipment may
need to be replaced or modified to
accommodate ethanol blends greater
than 10 percent:
• Handling hardware (nozzles,
hoses, breakaways, and swivels)
• Dispensers
• Product pumps
• Underground storage tanks
• Leak detection systems
• Vapor-recovery systems
• All associated piping
-------
December 2010 • LUSTLine Bulletin 66
Research is currently under-
way on E15 retail infrastructure.
(See NREL study on page 7.) Three
million dollars is being spent on
infrastructure compatibility testing,
including work underway by:
• U.S. Department of Energy
- National Renewable Energy
Laboratory: Dispensers, piping,
Stage II equipment, STPs
- Oak Ridge National Labora-
tory: Component materials,
UST coupons
• USEPA Office of Underground
Storage Tanks and Office of
Research and Development
- Leak detection systems
• American Petroleum Institute
- Misfueling mitigation measures
- Flame arresters
- Stage I Recovery Equipment
All national fire codes specify
that gasoline dispensers and associ-
ated dispensing equipment must be
"listed" by a nationally recognized
third-party testing laboratory, the
most well known being Underwrit-
ers Laboratories. In terms of current
UL dispenser and hanging hardware
listings, UL says "dispensing sys-
tems and hanging hardware have
been certified by UL for use with E15
and higher blends of ethanol. Leg-
acy dispensers, the type presently
installed in most stations, have been
tested and certified for a maximum
blend of E10 only."
The problem for tank owners
who want to dispense E15 is that
they may have to replace perfectly
good legacy (E10) equipment for dis-
pensers that UL approves for E15.
So the larger problem lies with
existing equipment, which has not
been evaluated with respect to E15,
and UL does not list equipment
without required testing. UL says it
is up to the authority having juris-
diction to determine how to proceed.
In February 2009, UL announced its
support for authorities having juris-
diction (AHJ) who may chose to per-
mit legacy systems with UL approval
for E10 to be used to dispense fuel
blends up to a maximum of 15 per-
cent ethanol.
They stated that there didn't
seem to be any significant increase in
risk between E10 and E15 blends but
recommended that the AHJs consult
1910
1920
with the equip-
ment manufac-
turers to confirm
that the equip-
ment is compat-
ible with the fuel
to be stored. UL
recommended
that the dispens-
ers be subject to
regular inspec-
tion and main-
tenance because
the potential for
degradation of
the metals and
other materi-
als increases with increasing ethanol
concentrations. (What, no increased
risk, but increased chance of equip-
ment degradation?)
Some states have issued work-
arounds that allow the use of legacy
and newer dispensers, mostly by
requiring periodic inspection and
replacement of the unlisted equip-
ment with listed equipment as soon
it becomes available. These work-
arounds do not, however, exempt
retailers from federal OSHA require-
ments for listed dispenser equip-
ment. Also, it is unclear whether the
UL announcement applied only to
the dispenser itself or to all above-
ground dispensing equipment,
including hanging hardware, break-
aways, and so on. The UL announce-
ment and the state workarounds do
not address the liability issues.
• Changes in Pump Labeling State
advertising and labeling require-
ments may require modification to
accommodate ethanol blends greater
than 10 percent, although many state
regulations only require the posting
of labels alerting consumers to the
fact that the fuel contains ethanol.
Other state labels include the per-
centage, or maximum percentage,
of ethanol in the fuel. In those cases,
the introduction of ethanol blends
greater than 10 percent will require
replacement or multiple replace-
ments of pump labels, depending
on how new transportation fuels are
introduced.
As discussed above, USEPA has
issued a Notice of Proposed Rule-
making to minimize the chances of
misfueling vehicles. One of the parts
of this rule would address dispenser
labeling. Such a label consists of four
Evolution of Fuel Additives
petrofg
1970
2000
2030
components. The information com-
ponent of the label would inform
the consumer of the maximum etha-
nol content that the fuel may con-
tain. The legal approval component
of the label would inform consum-
ers of which vehicles and engines
are approved to use E15. The techni-
cal warning component of the label
would alert consumers that the use
of E15 in other vehicles, engines,
and equipment might cause damage
to these products. The legal warn-
ing component of the label would
inform consumers that using E15 in
a vehicle or engine not approved for
E15 use violates federal law.
If USEPA extends the waiver to
include vehicles made between 2001
and 2006, the label would change
accordingly. The 2007 and later vehi-
cles represent about 20 percent of the
current fleet of passenger cars and
light-duty trucks, or about 42 million
vehicles.
Scott Merritt, executive direc-
tor of the Nebraska Corn Growers
Association, cautioned that a warn-
ing label for E15 would be the wrong
approach. "It will not be positive to
retail sales. We have had discussions
with retailers, and they are reluctant
to put warning labels on pumps.
From a consumer standpoint, it
sends a bad message. Consumer
confidence is high on ethanol (in
Nebraska). Consumers can't be very
positive about a warning label—it
sets us back 15 years." (DTN Progres-
sive Farmer, Oct. 15, 2010.)
A Real Predicament for Tank
Owners!
You have to wonder how many
retail UST facility owners are going
• continued on page 6
-------
LUSTLine Bulletin 66 • December 2010
• Partial E15 Waiver from page 5
to want to mess with ethanol blends
greater than 10 percent. Chevron
has already informed their mar-
keters that they are forbidden to
market E15, unless expressly autho-
rized. The National Association of
Convenience Stores, in a release
issued shortly after the USEPA par-
tial waiver announcement, urged
its members to use extreme caution
when considering selling E15, stating
that the USEPA approval does noth-
ing to remove retailers' legal obliga-
tions regarding storage and sale of
the fuel. "Further, limiting E15 use
to only vehicles manufactured since
2007 could expose retailers to signifi-
cant liability risk if a consumer were
to fill a non-approved engine with
E15," stated John Eichberger, NACS
vice president of government rela-
tions (http://iviviv.ethanolproducer.com,
October 19, 2010).
USEPA stated in its proposed
E15 label rule that it would not typi-
cally hold a fuel retailer liable for
consumer misfueling into a non-
approved engine, provided that
a station's pumps were properly
labeled. NACS claims that the Clean
Air Act includes a provision that
allows for citizens to sue retailers
for misfuelings, and that the labels
do not provide them with enough
litigation protection. Valero Energy
Corporation is expanding E85 avail-
ability at many of its retail stations,
but Bill Day, corporate communi-
cations director, indicated that the
company will not be as supportive
of E15. "Valero is one of the nation's
leading ethanol producers, and gen-
erally supports pro-ethanol poli-
cies," he said. "But in this case, it's
hard to imagine any retailer, includ-
ing Valero, selling the E15 blend at
its sites without liability or warranty
protection."
Representative Ross from Arkan-
sas and Representative Shimkus
from Illinois introduced H.R. 5778,
the Renewable Fuels Marketing
Act of 2010 in July 2010. One of the
provisions of this legislation would
require the USEPA Administrator,
within one year of passage of the
bill, to issue guidelines for determin-
ing whether USTs and associated
dispensing equipment are compat-
ible with any fuel or fuel additive
authorized by the Administrator or
by statute for use in a motor vehicle,
non-road vehicle, or engine.
An additional provision of
the legislation attempts to allevi-
ate liability issues stemming from
the introduction of higher ethanol
blends. It requires that the USEPA
Administrator issue regulations for
labeling within one year that prevent
the introduction and transportation
of fuel into an engine that is not com-
patible with the fuel, and if the seller
complies with the labeling require-
ments, they will not be liable under
the provisions of this act or any other
provision of federal or state law for
"(1) a self-service purchaser's intro-
duction of such a transportation fuel
into a motor vehicle, non-road vehi-
cle, or engine that is not compatible
with such transportation fuel; or (2)
the voiding of the manufacturer's
warranty of such vehicle or engine
from the introduction of such a trans-
portation fuel."
On October 21, Secretary of Agri-
culture Tom Vilsack announced that
the U.S. Department of Agriculture
would use existing funds to assist
in the installation of 10,000 blender
pumps across the U.S. within the
next five years (less than 5 percent
of gas stations in the country). He
sees USEPA's approval for E15 use
in vehicle models 2007 and newer as
a "momentum builder" for the etha-
nol industry, and it should help boost
demand for ethanol. He urged USEPA
to approve E15 for vehicle model
years 2001 to 2006 as soon as possible.
"It's already convinced NASCAR
to use E15, and if it's good enough
for Jimmie Johnson, I remain hopeful
that it will also be good enough for
earlier model vehicles," Vilsack said.
In response to the reluctance of retail
station owners to invest in additional
dispensers and storage tanks for E15,
Vilsack has instructed rural devel-
opment officials to provide match-
ing funds for installing the blender
pumps. He was unable to provide an
exact cost for the initiative, but said
the agency has estimated that a com-
plete blender-pump system ranges in
price from $25,000 to $50,000, and that
work on the blender-pump program
will commence "immediately" (http://
www.ethanolproducer.com. October 21,
2010).
Hmmmmmm.... So which UL-
approved blender pumps will be
installed? And testing hasn't begun
yet on the functionality of leak detec-
tion systems for use with ethanol
blends. I continue to hope that we
have learned from our past experi-
ence with MtBE that changes in our
fuel composition have to be done
carefully and our decisions need
to include evaluation of all of the
potential pitfalls, including compat-
ibility with our existing fuel distribu-
tion system. •
Pat Ellis, Ph.D., is a hydrologist with
the Delaware Department of Natural
Resources and Environmental Control,
Tank Management Branch. She writes
the LUSTLine column "Wander-
LUST," and can be reached at
Patricia.Ellis@state. de.us.
USEPA Finalizes 2011 Renewable Fuel Standards
USEPA has finalized the 2011 percentage standards for the four categories of fuel
under the agency's renewable fuel standard program, known as RFS2. The Energy
Independence and Security Act (EISA) amended the Clean Air Act to greatly increase
the total required volume of renewable fuels each year, reaching a level of 36 billion
gallons in 2022. To achieve these volumes, USEPA calculates percentage-based stan-
dards for the following year. Based on the standards, each producer and importer of
gasoline and diesel determines the minimum volume of renewable fuel that it must
ensure is used in its transportation fuel.
The final 2011 overall volume and standards are:
• Cellulosic biofuel: 6.6 million gallons; 0.003 percent
• Biomass-based diesel: 800 million gallons; 0.69 percent
• Advanced biofuel: 1.35 billion gallons; 0.78 percent
• Renewable fuel: 13.95 billion gallons; 8.01 percent
Based on an analysis of expected market availability, USEPA is finalizing a lower 2011
cellulosic volume than the statutory target. Overall, USEPA remains optimistic that the
commercial availability of cellulosic biofuel will continue to grow in the years ahead.
For more information, go to: http://www.epa.gov/otaq/fuels/renewablefuels/regula-
tions.htm, •
-------
December 2010 • LUSTLine Bulletin 66
USEPA Proposed Guidance on Compatibility of UST Systems
with Biofuel Blends Is Now Available
In the November 17, 2010 Federal Register (http://www.gpo.gov/fdsys/pkg/FR-2010-11-17/pdf/2010-28968.pdf), USEPA
published proposed guidance that will clarify how underground storage tank owners and operators can comply with the
Agency's compatibility requirement (in 40 CFR §280.32) when storing certain biofuels, such as ethanol-blended fuels greater
than 10 percent ethanol and biodiesel-blended fuels containing an amount of biodiesel to be determined.
USEPA solicited comments (due on December 17, 2010) on the proposed guidance, which will provide underground storage
tank owners and operators with greater clarity in demonstrating compatibility of their tank systems with these fuels.
Contact Andrea Barbery (barbery.andrea@epa.gov) of USEPAs Office of Underground Storage Tanks for more information.
NREL's Study on Testing Mid-Level Ethanol/
Gasoline in Dispensing Equipment Now Online
The National Renewable Energy
Laboratory's (NREL) Non-
petroleum-Based Fuel Task
is responsible for addressing the
hurdles to commercializing fuels
and fuel blends such as ethanol that
are derived from biomass. One such
hurdle is the unknown compatibility
of new fuels with legacy infrastruc-
ture components at fuel-dispensing
facilities. The U.S. Department of
Energy's (DOE) Vehicle Technology
Program and the NREL biomass pro-
gram engaged in a joint project to
evaluate the potential for blending
ethanol into gasoline at levels higher
than El 0.
The project, carried out by
Underwriters Laboratories Inc.
(UL), was initiated to help DOE and
NREL [and, by the way, UST regula-
tors] better understand potentially
adverse impacts caused by any
dispensing equipment incompat-
ibility with ethanol blends higher
than equipment design specs. UL's
November 2010 report, Dispens-
ing Equipment Testing with Mid-Level
Ethanol/Gasoline Test Fluid, provides
data on the impact of introducing
gasoline with a higher volumetric
ethanol content into dispensing
equipment from both a safety and a
performance perspective. Safety of
the equipment focuses on "loss of
fuel containment and other safety-
critical performance such as loss of
ability to stop fuel flow or failure of
breakaway couplings to separate at
appropriate forces."
As detailed in the report, the
project consisted of testing new and
used dispensers harvested from the
field (all equipment UL-listed for
up to E10). Testing was performed
according to requirements in the
UL's Outline of Investigation for Power-
Operated Dispensing Devices for Gaso-
line and Gasoline/Ethanol Blends with
Nominal Ethanol Concentrations up
to 85 Percent (EO-E85), Subject 87A,
except using a CE17a test fluid based
on the scope of this program.
As reported in the UL's execu-
tive summary, "the overall results of
the project were inconclusive insofar
as no clear trends in the overall per-
formance of all equipment could be
established. New and used equip-
ment such as shear valves, flow lim-
iters, submersible turbine pumps,
and hoses generally performed well.
Some new and used equipment dem-
onstrated reduced levels of safety or
performance, or both, during either
long-term exposure or performance
tests. Dispenser meter/manifold/
valve assemblies in particular dem-
onstrated largely noncompliant
results. Nozzles, breakaways, and
swivels, both new and used, expe-
rienced noncompliant results dur-
ing performance testing. Responses
of nonmetals, primarily gaskets and
seals, were involved with these non-
compliances."
The report summarizes the per-
formance of different types of equip-
ment in the testing program (Table
1). The report is available at: http://
www.nrel.gov/docs/fyllosti/49187.pdf.
Note: This report documents the
noncompliance (i.e., failure) of cer-
tain nonmetallic materials that may
be found in UST equipment. •
TABLE 1. SUMMARY OF TEST RESULTS ON DIFFERENT
TYPES OF EQUIPMENT
Compliant Test Compliant Test Overall
Results on New Results on Used Compliant Test
Equipment Samples3 Samples3 Results3
Breakaways
Flow Limiters
Hoses/Hose Assemblies
Meter/Manifold/Valve
Assemblies
Nozzles
Shear Valves
Submersible Turbine
Pumps
Swivelsb
2 of 5
1 Of1
8 of 9
Oof 2
3 of 6
3 of 3
1of1
3 of 4
1of4
-
4 of 6
Oof 4
1of4
-
_
3 of 5
3 of 9
1 Of1
12 of 15
Oof 6
4 of 10
3 of 3
1of1
6 of 9
a. In the context this table, "compliant results" is used to include fully compliant test results and inconclu-
sive test results that did not directly manifest a hazard, such as leakage, during the testing that was able to
be performed as a part of this research program.
b. Includes swivels integral to hose assemblies.
-------
LUSTLine Eullek
mber 2010
It's the Compatibility Thing
How Two UST Regulators in the Land of Ethanol
Addressed Ethanol Compatibility
by Ellen Frye
From the very beginning,
we made sure we talked
about compatibility, about
what we are regulating, and why,"
said Paul Nelson, Senior Environ-
mental Specialist with the Iowa
Department of Natural Resources
(DNR), in a recent interview with
Marcel Moreau (author of the
LUSTLine column "Tank-nically
Speaking"). "We stayed away from
expressing opinions for or against
ethanol to avoid alienating some-
body," Paul explained. "The regula-
tory issue is very straightforward.
It's about compatibility and prevent-
ing a release into the environment.
The federal rules, which Iowa has
adopted, say the UST-system compo-
nents have to be compatible with the
fuel being stored."
But compatibility is not only
a fuels issue. As Marcel is quick
to point out, both Paul and his co-
worker Tom Collins, Senior Environ-
mental Specialist, have a personal
style that is instinctively compatible
with their various stakeholders—
tank owners and operators, install-
ers, equipment manufacturers and
distributors, fuel associations, and
the state legislature. The two of them
are a team and have been an effec-
tive force in piloting the state's UST
program since the program began 20
years ago. Their strategy is decep-
tively simple: identify the issues,
research them, and present them to
stakeholders along with a reasonable
plan. A key component of the strat-
egy is to involve the stakeholders
each step of the way.
Iowa is the number one etha-
nol-producing state in the nation.
According to the Iowa Renewable
Fuels Association (IRFA), the state
has the ability to produce 3.3 billion
gallons of ethanol per year. Wiki-
pedia states that in 2008, the 92,600
farms in Iowa produced 19 percent
of the nation's corn and 17 percent
of the soybeans. Living in the heart
of corn country, it was a given that
8
f
motor fuel would con-
tain ethanol. One of
Tom and Paul's big
challenges was to find a
way to ensure that fuels
containing ethanol and
soy-based diesel fuels
are compatible with the
UST systems in which
they are stored.
The use of ethanol
in fuels is complicated
and can be downright
frustrating for UST reg-
ulators, the automobile
industry, tank owners,
installers, and equip-
ment manufacturers
alike. The Iowa tanks
program epitomizes the
tangled web of com-
peting economic and
environmental interests
surrounding growing,
marketing, and retailing
corn and soybean motor
fuels.
Yet in all of this,
UST systems seem to be
the forgotten step chil-
dren—children that can play havoc
with our groundwater resources if
they are not up to the task of stor-
ing and dispensing the fuel put into
them without leaking their contents
into the environment. It is the com-
patibility thing. With lower ethanol
percentage levels (e.g., E10), gaskets
and seals tend to be the primary
problems. At the other end of the
spectrum (e.g., E85), soft metals such
as brass and aluminum are affected.
The mid ranges (e.g., 25-30 per-
cent ethanol) are the most difficult
because they can experience both
sets of problems.
Tom and Paul have become the
"Who ya gonna call?" guys if you
have questions about ethanol-blend
motor fuels. As Marcel noted, "When
I first started looking into ethanol on
the Web several years ago, I ended
up pretty quickly at the Iowa web-
Pat// Nelson (left) and Tom Collins with the Iowa DNR Tank
Program.
site." For regulators like Tom and
Paul, the big question is, "Is UST
equipment ready for ethanol blends
beyond E10?" The solution they
landed on tries to answer the ques-
tions that need to be asked for stor-
ing ethanol fuels—from E10 to E85.
As I heard their names repeat-
edly invoked, I knew it was high
time to tell their story in LUSTLine.
So when Marcel offered to interview
Tom and Paul while doing some
training in Iowa, I gave him a hearty
thumbs-up. So here's the skinny.
Well, We've Got Trouble-
It was 2003, Paul and Tom had been
pulling together information on E85
for a year or so in anticipation of
undertaking some kind of compat-
ibility initiative for the introduction
of E85. But when a just-filled 6,000
gallon stiP3® UST, 1988 vintage,
emptied out overnight, their inter-
-------
December 2010 • LUSTLine Bulletin 66
est in ethanol compatibility with
tank systems reached new heights,
particularly when they learned that
the owner had just filled the tank
with E85. "That's when we decided
we should be doing some serious
research and talking to people who
knew," said Tom.
Around that time, Paul had occa-
sion to talk to a fuel marketer who
called him about some other issues.
Paul took the opportunity to inquire
about ethanol. "He had C stores, and
he also delivered fuel. He told me
about the first time he was going to
deliver E85. He was going to make
the delivery early in the morning, so
he filled the truck the night before.
When he went out the next morning
to deliver the load, he knew some-
thing was wrong because he could
smell fuel. There were little puddles
under his truck. The rubber gaskets
were just dripping with fuel. He
ruined a delivery hose too. So that's
when he discovered that E85 was not
normal gasoline," said Paul. "It was
a whole learning process for him,
and we figured we had some learn-
ing to do too."
"We knew there were UST issues
with E85," said Tom, "but we hadn't
even thought about trucks and vehi-
cles. From talking with our market-
ers and service techs we realized that
we didn't have to convince these
people that there were issues. But
there were other stakeholders who
didn't know much about UST issues
that we had to address as well."
E10 has been in Iowa's gaso-
line since the late 1970s, back when
ethanol and UST-system compat-
ibility weren't on anyone's radar.
But there had been issues back then,
too. "We were talking to one tank
owner," recalled Paul, "and he said
'well yeah, back when we switched
to E10 we had a lot of dispenser
leaks.' And they usually happened
within the first 24 hours.. .didn't take
too long. All of sudden they started
leaking, because it was all just a little
bit different, it wasn't compatible.
When we talked with the dispenser
manufacturers while researching
compatibility, their concern was the
gaskets shrinking or growing due to
a change in fuel with different char-
acteristics."
The Road to the Big Meeting
Predictably, there was considerable
industry interest when the DNR
invited the ethanol stakeholders
to attend some preliminary meet-
ings addressing E85 compatibility
with UST systems. "Some legislators
heard about this initiative and sat in
on some of our early meetings with
the renewable fuels people, even
though we weren't planning any
additional rulemaking," said Paul.
Tom and Paul have become the
"Who ya gonna call?" guys if
you have questions about ethanol-
blend motor fuels.
"We didn't want anybody to be
surprised by what we were doing,
so we explained the reasons why we
had to do something about compat-
ibility. As we were doing our pre-
sentation, I noticed some legislators
were nodding their heads up and
down," recalled Paul. "And when
we went over to the statehouse and
met more legislators, they seemed
to understand. Some of them were
fairly receptive right from the start."
There was a big reason why the
legislature was receptive: they'd
already gone through one round of
discovering and cleaning up leaking
underground storage tanks, and they
didn't want to go through it again.
In the late 1980s, at the start-up of
the state's cleanup fund, there was
a decision to identify pre-existing
conditions at UST facilities through
invasive sampling, in an attempt to
get all facilities back to a clean slate.
It was a real eye-opener. There was a
lot of contamination.
But the legislature was just
part of the work that Tom and Paul
needed to do. "The ethanol interests
did not want to see us restricting
the use of ethanol," explained Tom.
"The national Renewable Fuels Asso-
ciation (RFA) was pretty emphatic
about that."
When they first determined that
they needed to do something about
compatibility, Paul and Tom con-
tacted the tank installers association
for help in researching the issues.
They called around the states to see
what they were doing. They talked
to equipment manufacturers, includ-
ing everyone from the tank manufac-
turers to the people that make pipe
dope.
"I mean we contacted every-
body," said Paul. "We tried to get a
timeline on when various ethanol-
compatible components were being
manufactured and installed."
With the information they had
amassed in hand, they drafted a plan
for what they thought needed to
happen. "Underlying our proposal
was our own recognition that we are
not the experts," said Tom, "and we
don't have time to review all the tank
systems in the state...there's only
two of us. So we thought the best
route to go was to have the installers
check over the UST systems.
"At first, when we ran that idea
by the installers," continued Tom,
"they kind of went 'ehhh,' because
they didn't really want to do it. They
didn't want the liability of declaring
a storage system compatible. So we
explained that all they'd be doing
was determining whether the equip-
ment at a facility was or was not on
the manufacturer's list of compat-
ible models and serial numbers. That
was a lot easier for them to swallow.
Once we were at the point where we
finally had our proposal, we were
ready for the big meeting."
The Big Meeting
At the time (2005), the DNR had an
energy section (now its own Office
of Energy Independence) that was
actively promoting renewable fuels.
Tom and Paul asked them to iden-
tify and invite key players to the big
meeting. Energy made the contacts
and set up the meeting for them. It
would be held at the Farm Bureau's
executive meeting room in West Des
Moines. "It was a very fancy meet-
ing room, a little intimidating rela-
tive to what we were used to, but we
thought it would be a good idea to
hold the meeting on their home turf
rather than at our offices," said Tom.
"We had a huge representa-
tion," said Paul. "The major state
UST insurance company (PMMIC)
and other insurance reps, petroleum
marketers, weights and measures,
the national and state renewable
fuels people, the state fire marshal,
the corn growers association, the
soybean association, ethanol refin-
ery people, the co-ops—the ones that
• continued on page 10
-------
LUSTLine Bulletin 66 • December 2010
• Ethanol Compatibility
from page 9
store the corn and are most inter-
ested in selling the fuel—were there,
and more. We presented our infor-
mation and what we thought we
needed to do.
"We figured there'd be push
back from renewable fuels and other
concerns, which there was," said
Paul. "So we were just trying to get
everyone together and let them
know what direction we were going.
We told the soy people we couldn't
find any problem with B2, which is
what they were concerned about. So
that was easy.
"The national RFA guy kept
insisting there wasn't a compatibility
problem. He made a strong pitch for
ethanol, saying how our information
was not researched or not proven,"
Paul said. "Well many of the people
in the room knew that we had done
our research because we had talked
to them directly. We knew we were
on solid ground because we'd got-
ten our information from the manu-
facturers and the people who made
the equipment and the people who
installed and operated it.
"We weren't about to sit there
and say, 'oh, let's just ignore the
people who know their equip-
ment.' So we listened politely, but
we weren't about to back off," Paul
asserted. "And we knew the mar-
keters and installers were behind
us because they were the ones who
were going to be liable for the leaks,
not the farmers, refiners, or the RFA.
We were regulators doing our job
to protect the environment, but this
was one time when we were protect-
ing the marketers and installers too.
They didn't want leaks either."
"Paul and Tom made sure they
talked to the people who had the
real-world experience and could give
them real-world information," said
Marcel. "They already had a remark-
able level of trust with the industry
and the regulated community and
saw each other as allies in the quest
to store ethanol safely."
Connecting, and More
Connecting
So that was the first meeting and
soon Paul and Tom were being asked
to speak at other places around the
state about what ethanol might mean
10
for owners, operators, and install-
ers. "The marketers don't like being
pushed to do anything," said Tom.
"In this case, they figured they had
everything to lose and not much to
gain by storing E85 in incompatible
storage systems. And so they were
supportive of making sure that what
was going to happen made sense for
them and not just for the farmers.
"Same thing with the people
installing the equipment," he added.
"They had the most skin in the game.
Even though they were initially a
little leery of our proposal to have
"Our drumbeat was, 'Look, we have
some 8,000 tanks at2,800 sites, and
we don't want the public put at risk.
We don't know for sure what could
happen with E85, so we're looking at
a worst-case scenario.'And one thing
good too, we already had federal
rules that said the fuel has to he
compatible."
—Tom Collins
them be the ones to go out there and
inspect to see what needed to be
done to make the UST systems com-
patible, we eventually ended up get-
ting to a win-win solution."
Tom and Paul had other meet-
ings at their office and at legislative
offices. Eventually, Tom gave a pre-
sentation to the Environment Com-
mittee.
"That was kind of a turning
point," said Tom. "After that they
kind of let us alone. They said, okay,
it looks like you guys know what you
are doing, so we'll let you go ahead.
We met with a few other legislators
afterwards, but their concern was
mostly that they don't want to have
leaks anymore. Our drumbeat was,
'Look, we have some 8,000 tanks at
2,800 sites, and we don't want the
public put at risk. We don't know for
sure what could happen with E85,
so we're looking at a worst-case sce-
nario.' And one thing good too, we
already had federal rules that said
the fuel has to be compatible."
The Pre-Ethanol System
Check
Because the rules already required
compatibility, Paul and Tom figured
they didn't need to do any rulemak-
ing. Their task was to figure out a
way to establish whether a storage
facility was compatible or not. The
centerpiece of the guidance that they
developed was a storage system
ethanol-compatibility checklist. The
checklist is a meticulously honed
mechanism for ensuring that all UST-
system components are compatible
with the product being stored—in
this case, any fuel containing ethanol
blends higher than E10. It is a check-
list that must be filled out and signed
by a licensed Iowa installer. (All of
this information and more can be
found at iviviv.ioivadnr.gov/land/ust/
technicalresourceslethanol.html.)
"The beauty of this list,"
explained Marcel, "is that all the
installer needs to do is check serial
numbers and model numbers for the
UST-system components to make
sure they are compatible. They aren't
saying this equipment is fine, they're
saying, this equipment is on the
manufacturer's list as being accept-
able. Parts that aren't compatible
need to be replaced before ethanol
can be stored."
Tom and Paul enlisted the
experts to help them define compat-
ibility. Installers Al Hilgren with Sen-
eca Petroleum and Terry Cooper with
Acterra Group got very involved in
developing the list, essentially taking
the lead in researching equipment.
Once they had the checklist and all
that went with it, many in the indus-
try, including the state renewable
fuels people, were given the oppor-
tunity to comment.
"We didn't do anything in secret
or private," said Tom. "Everything
was out there from the very begin-
ning. Tom Vilsack was governor at
the time and was very supportive.
He just wanted us to solve the prob-
lem. He wanted to make sure that if
he was asked questions about it he
knew what to say. We gave him talk-
ing points. He did his homework
and became knowledgeable about
the requirements."
An Iowa Renewable Fuels
Board was created, and they set up
a Renewable Fuels Infrastructure
Program. They could see that replac-
ing certain equipment was going to
be costly and lobbied the legislature
for funding mechanisms (reimburse-
ments, grants, incentives) to help
convert existing systems.
-------
December 2010 • LUSTLine Bulletin 66
Tom and Paul sent a letter to
the regulated community, letting
them know about the ethanol guid-
ance document and the checklist.
The Iowa Renewable Fuels Board
got behind the checklist and became
very supportive. Tom and Paul
pulled in installers and other stake-
holders to figure out ways to help
the Board spend the money the leg-
islature put aside to upgrade E85
equipment infrastructure. "We could
help identify the equipment that
needed replacement, and the Board
had the money to help pay for the
new equipment, so it was a great
combination," said Tom.
The fire marshal's office was
concerned with dispensers and
crash valves, some of which might
still have brass components. The
DNR had jurisdiction over the dis-
pensers from the ground down; the
fire marshal's office ruled from the
ground up. There were no dispens-
ers listed by UL for E85 service, so
the fire marshal liked the idea of the
checklist as a backup measure. For
their part, the DNR required E85
dispensers to have under-dispenser
containment that was to be checked
daily until such time as the dispenser
was UL-listed. Tom and Paul were
uncomfortable with the fact that they
were allowing this and that it could
have been a public safety issue.
"You try to come up with some-
thing that works for everybody—
and the environment," said Paul.
"We hashed out issues, like, what if
you don't know what kind of pip-
ing dope and glue was used when
the system was installed? So how are
we supposed to determine that? We
covered these things in the checklist,
but sometimes with cautionary notes
rather than hard and fast answers."
Moving Forward with What
You Know
Right now, there are about 135 facili-
ties in Iowa that sell E85. You would
think that Tom and Paul went to an
awful lot of trouble to pave the way
for a relatively few facilities, but, in
fact, their running the gauntlet pro-
vided the legwork and a jumping off
point for many other states and the
USEPA.
Tom and Paul worked hard to
create a mechanism to prevent UST-
system releases brought about by
vulnerable UST-system components.
In the end, they laid out what they
knew in black and white, with a few
gray areas still remaining. "You can
only go with the information you
have," says Paul, and he and Tom
remain cautious.
"We read a lot of Society of Auto-
motive Engineers (SAE) reports,"
noted Tom. "Man the stuff they
found. No wonder they are cautious
with E15. There are a lot more things
to look for in an engine than we look
at in underground storage systems."
Tom and Paul are not aware of
any major releases in the state due
to ethanol, but they are aware that
ethanol is having an effect on some
equipment. (See Paul's note in From
Our Readers below.) "Things we
didn't anticipate," said Tom, "like
the surface corrosion that we're see-
ing on a lot of components. We still
have our ear to the ground in case
something pops up, but so far, things
seem to be okay. "
The E15 Question
"Now that E15 looks like it will be
playing a role in our fuel future, do
you have any thoughts on E15 com-
patibility?" asked Marcel.
"Well, a great deal of the equip-
ment in the ground is only listed
for E10," says Tom, "so our thought
right now is to tweak the checklist a
bit so it can be applied to any storage
system that is to be used for E15 or
any other blend above E10."
"We still would rather be safe
than sorry," adds Paul.
Postscript
"Last question," said Marcel as he
wrapped up the interview, "are you
pleased with the results?"
"I think it worked out," said
Paul.
"It seems to have worked out
well," echoed Tom.
"At first blush, I would have
thought that attempting to regu-
late ethanol in a corn state like Iowa
was a recipe for disaster. I think that
things have worked out well because
of who these guys are," said Marcel.
"They not only understand the tech-
nical issues, they have a deep under-
standing and respect for their fuel
marketers and tank workers. This
shows in the ease with which Tom
and Paul, and the people they regu-
late, communicate with each other.
Tom and Paul listen and come across
as very non-threatening. They are
not know-it-alls, but they do their
homework, they know what they are
talking about, and they seek com-
mon-sense solutions. The industry
people respect that. And that mutual
respect creates an environment
where things can get done." •
Reminder:
If you are seeing unusual corrosion in E10 orE85 sumps, please contact Andrea
Barbery at OUST (tiarbery.andrea@epa.govj and she will coordinate with you
and USEPA's Office of Research and Development to arrange for a sump sam-
pling kit to be sent to you. Data from these sampling kits will be collected and
analyzed to understand what is causing this corrosion.
I found the article in LUSTLine ("Not for the Squeamish," LUSTLine
#65) interesting since we noted the corrosion problem in the sumps
with ethanol several years ago at the National Tanks Conference. Our
hypothesis at the time was that it was caused by vapors, though we did
not pursue an explanation. We had been seeing it for years with the most
severe having huge flakes coming off. No releases can be attributed to
the corrosion though. Evidently no one was listening or paying attention
at the time. The discussion was mainly about E85 and most people had
yet to see the problem in E10.
Paul Nelson
Underground Storage Tank Section
Iowa Department of Natural Resources
11
-------
LUSTLine Bulletin 66 • December 2010
Ferreting Out the Identity of Gasoline
Additives
by Jim Weaver and David Spidle
Chemical dispersing agents for
oil spills, hydraulic fractur-
ing fluids for natural-gas pro-
duction, and chemicals serving as
gasoline additives share a common
characteristic—for the most part,
they are proprietary compounds.
In the name of competitive advan-
tage, companies carefully guard the
chemical recipes of these products
and are allowed by the federal gov-
ernment to claim "confidential busi-
ness information" (CBI) status for
them. As a consequence, there could
be additives in released fuels that
cause future heartburn for the LUST
program.
The word "could" must be
emphasized because, for a compound
to cause a problem, it would have
to be present in sufficient concen-
tration in a fuel, have high enough
water solubility to enter an aquifer,
have low enough degradation to per-
sist, and be toxic at the concentration
where a receptor would encounter it.
Although these criteria present a high
bar to pass, we can look to the lead
scavenger ethylene dibromide (EDB)
as a past example of an additive that
is indeed a continuing problem (see
LUSTLine #47).
The complexity of additives can
be seen in USEPA's additive registra-
tion form, which lists 50 purposes
for gasoline additives (http://iviviv.
epa.gov/oms/regs/fuels/forms/3520-13.
pdf). These include detergents, anti-
oxidants, metal deactivators, corro-
sion inhibitors, and anti-icing agents,
among many others. The concentra-
tions of these additives in gasolines
can range from low parts per million
(ppm) to low percent levels. For com-
parison, benzene in reformulated
gasoline is currently limited to less
than 1 percent or 7,500 ppm, much
higher than the majority of additives.
The chemical classes of additives
include petroleum fractions, low
molecular-weight alcohols, complex
binders, organometallic compounds,
surfactants, and polymers (VFJ,
2006). "Classic" additives, as defined
by VFJ, are those with known chemi-
12
cal, toxicological, and environmen-
tal risk properties, which tend to be
compounds that have been used in
gasolines over a long period of time.
Newer compounds tend to be surfac-
tants, polymers, and organometallics
(VFJ, 2006).
Chemical Analysis
Some additives have been identi-
fied in fuel handbooks, automotive
industry conference proceedings,
and journal papers, but many are
publicly unknown. Lack of chemi-
cal identification coupled with the
variety and complexity of these com-
pounds, makes chemical analysis a
daunting task. Despite the difficul-
ties, two approaches have been tried.
The first approach is to equili-
brate gasoline with water and
analyze the extracts by liquid chro-
matography/mass spectroscopy.
This was done for a set of Swiss gas-
olines by Torsten Schmidt and col-
leagues at the Swiss Federal Institute
of Technology in Zurich (Schmidt et
al., 2002). The work resulted in a list
of 17 polar compounds that have a
high tendency to partition to ground-
water. Assessment of the partition-
ing behavior of these compounds
led to an approximate approach for
estimating their concentrations in
groundwater. The results showed
that many of these chemicals have
high water solubility and would be
released from their source gasolines
relatively rapidly. Thus, they may
not persist in the gasoline itself.
In a roughly similar hunt for
compounds, Weaver et al. (2009) ana-
lyzed fuel-grade ethanol and looked
for impurities. A number of higher
molecular-weight alcohols were
found and are listed in Table 1, along
with Schmidt's set of compounds
and a number of additives identi-
fied in other literature. Notably for
both of these projects, the focus was
on identifying constituents, but not
their toxicity.
A second approach looks from
the top down. In Denmark, five
major petroleum companies revealed
the identity of additives they were
using to a consulting firm, which
agreed to keep the identities of the
compounds confidential unless a
simplified screening determined
that they might cause ill effects (VFJ,
2006). The companies identified
around 100 compounds and of these,
eight were identified as potentially
harmful. These compounds are listed
in Table 1 alongside the chemicals
identified from the "bottom up."
Questions from LUSTIand
In the United States, all gasoline and
diesel motor-vehicle fuel additives
are required to be registered in accor-
dance with the regulations in 40 CFR
79. USEPA requires that the producer
provide information on the chemical
composition and methods of analy-
sis for determining the presence of
each compound and impurities. The
manufacturer is also asked to submit
any information it has on "the effects
of this fuel additive on all emissions;
the toxicity and any other public
health or welfare effects of the emis-
sion products of this fuel additive."
In a few cases, USEPA has required
that these fuels and fuel additives
be tested for possible health effects,
notably ethanol, ethers, MMT, and
cerium-based additives for diesel
fuel.
However, the manufacturer can
assert that the product information
is CBI, and, presumably, many do. So
although USEPA holds composition
information on registered additives,
CBI information cannot be disclosed
to the public, including LUST pro-
gram managers, and besides that, the
health effects from ingestion of water
are likely to be unknown unless well-
studied chemicals are involved.
USEPA and/or outside groups
have questioned the need for CBI
claims for oil spill dispersants,
hydrofracking fluids, and chemicals
in commerce (Hogue, 2010). These
increased concerns might indicate
a future move toward more disclo-
sure of proprietary chemicals. In the
meantime, research is needed on pos-
-------
December 2010 • LUSTLine Bulletin 66
sible impacts of additives in
suggest a program of research
on these chemicals that would
begin to identify additives in
U.S. gasolines. Publicly identi-
fied additives as in Table 1 form
a starting point for a study
of impacts to groundwater.
If these chemicals are found,
then attention can be focused
on their health effects. Both of
these factors — the exposure
and the effects — need to figure
into decisions concerning site
management, and we are only
at the beginning stage of inves-
tigating these chemicals. •
Jim Weaver is a Hydrologist
with USEPA and can be reached
at weaver.jim@epa.gov. David
Spidle is a Research Chemist
and can be reached at
spidle.david@epa.gov .
Disclaimer
This paper has been reviewed in
accordance with the U.S. Environ-
mental Protection Agency's peer and
administrative review policies and
approved for publication.
References
Hogue, C., 2010, Naming names, Chemical
and Engineering News, Volume 88, Number
16,28-31.
Landells, R. G. In Motor Gasoline; Marshall,
E. L., Owen, K., Eds.; RSC: Cambridge,
UK, 1995; pp 170-200.
Owen, K., 1989, Gasoline and Diesel Fuel Addi-
tives, Wiley.
Quimby, B.D., Giarrocco, V., Sullivan, J.J.,
gen and sulfur compounds in gasoline,
/. High Resolution Cheromatography, 15,
705-709.
gel, Kai-Uew Goss and Stefan B. Hader-
lein. Polar fuel constituents: compound
identification and equilibrium partitioning
between nonaqueous phase liquids and
water, 2002, Environmental Science and Tech-
nology, 36, 4074-4080.
Videncenter for Jordforurening (VFJ), 2006,
Fuel additives: A risk screening of addi-
tives to gasoline and diesel, Teknik og
Administration Nr. 3. 2006. http://zozozo.
avjinfo.dk/filerludgivelserlrapporterl37l
Teknik og Administration Nr. 3 2006.pdf.
pdf.
Weaver, J.W., S. A. Skaggs, D. L. Spidle, G. C.
Stone, 2009, Composition and Behavior of
Fuel Ethanol, EPA/600/R-09/037.
http://u7wio.epa.gov/athens/publications/reports/
Weaver_EPA600R09037_Composition_Fuel_
Ethanol.pdf.
TABLE 1. SOME PUBLICLY IDENTIFIED GASOLINE ADDITIVES
1 Class 1 Chemical 1 CAS* No 1 Note 1 Source
Aromatic
Amines
Aliphatic
Amines
Phenols
Benzotri-
azoles
Poly phenol
(sch iff base)
Thiophenes
Alcohols
Ester
Ester-Acid
Neutral
orgamcs
Undesignated
aniline
p-toluidine
o-toluidine
3,4-dimethylaniline
2,6-dimethylanaline
diethanolamine
triethanolamine
phenol
p-cresol
o-cresol
3,4-dimethylphenol
2,6-dimethylphenol
3,4,5-trimethylphenol
2,6-di-tert-butylphenol
benzotriazole
1 -methyl benzotriazole
N,l\l-disalicylidene-
1,2-diaminopropane
thiophene
benzothiophene
methanol
ethanol
1-propanol
2-propanol
isobutyl alcohol
2-methyl 1-butanol
3-methyl 1-butanol
2-ethyl 1-hexanol
2-butoxy ethanol
ethyl acetate
1,2-bis(2-ethylhexyloxy-
carbonyl) ethanesulpho-
nate potassium salt
1,1-diethoxyethane
2-ethylhexyl nitrate
tetrapropylenebutanedioic
acid
di-sec-butyl-p-phenylene-
diamine
1-propene, 2-methyl-
homopolymer, hydro-
formylation products,
reaction products with
ammonia
(Z)-4-oxo-4-
(tridecylamino)-2-butenoic
acid
polyolefin mannich base
62-53-3
106-49-0
95-53-4
95-64-7
87-62-7
111-42-2
102-71-6
108-95-2
106-44-5
95-48-7
95-65-8
576-26-1
527-54-8
128-39-2
95-14-7
13351-73-0
94-91-7
110-02-1
95-15-8
67-56-1
64-17-5
71-23-8
67-63-0
78-83-1
137-32-6
123-41-3
104-76-7
111-76-2
141-78-6
7491-09-0
105-57-7
27247-96-7
27859-58-1
101-96-2
68891-84-9
84583-68-6
-
Water equilibrated with gasoline
Water equilibrated with gasoline
Water equilibrated with gasoline
Water equilibrated with gasoline
Water equilibrated with gasoline
Potential environmental impact
Potential environmental impact
Water equilibrated with gasoline
Water equilibrated with gasoline
Water equilibrated with gasoline
Water equilibrated with gasoline
Water equilibrated with gasoline
Water equilibrated with gasoline
Identified additive
Water equilibrated with gasoline
Water equilibrated with gasoline
Water equilibrated with gasoline
Identified additive
Water equilibrated with gasoline
Identified additive
Fuel ethanol analysis
Fuel ethanol analysis
Fuel ethanol analysis
Potential environmental impact
Fuel ethanol analysis
Fuel ethanol analysis
Fuel ethanol analysis
Potential environmental impact
Potential environmental impact
Fuel ethanol analysis
Potential environmental impact
Fuel ethanol analysis
Potential environmental impact
Potential environmental impact
Identified additive
Potential environmental impact
Potential environmental impact
Potential environmental impact
Schmidt etal, 2002
Schmidt etal, 2002
Schmidt etal. ,2002
Schmidt etal. ,2002
Schmidt etal. ,2002
VFJ, 2006
VFJ, 2006
Schmidt etal. ,2002
Schmidt etal. ,2002
Schmidt etal. ,2002
Schmidt etal. ,2002
Schmidt etal. ,2002
Schmidt etal. ,2002
Landels, 1995
Schmidt etal. ,2002
Schmidt etal. ,2002
Schmidt etal. ,2002
Quimby etal, 1992
Quimby etal, 1992,
Schmidt etal. ,2002
Weaver etal., 2009
Weaver etal., 2009
Weaver etal., 2009
VFJ, 2006
Weaver etal., 2009
Weaver etal., 2009
Weaver etal., 2009
VFJ, 2006
VFJ, 2006
Weaver etal., 2009
VFJ, 2006
Weaver etal., 2009
VFJ, 2006
VFJ, 2006
Owen, 1989
VFJ, 2006
VFJ, 2006
VFJ, 2006
* CAS = Chemical Abstracts Service.
13
-------
LUSTLine Bulletin 66 • December 2010
FOOTPRINT
A New Tool to Predict the Potential Impact of
Biofuels on BTEX Plumes
by John Wilson
Most of us know that BTEX compounds can biodegrade in groundwater, and many of us incorporate this natural biodegra-
dation into our strategy to manage risk at sites where there has been a gasoline release. In the absence of natural biodeg-
radation, many BTEX plumes would be much larger than they are. Unfortunately, biofuels can interact with BTEX and
inhibit this natural biodegradation, further complicating an already complex picture.
A Bit of History
More than a decade ago, ground-
water scientists and engineers
raised the possibility that ethanol
could inhibit natural biodegrada-
tion of benzene, toluene, ethylben-
zene, xylenes (BTEX) compounds
(Corseuil et al., 1996, Powers et al.,
2001). If this is true, a spill of E10
should have a longer BTEX plume
than a spill of conventional petro-
leum gasoline. To see if this really
happened at gasoline station sites,
Ruiz et al. (2003) compared the
lengths of benzene plumes at 217
sites in Iowa, where gasoline releases
did not have ethanol, to the length of
benzene plumes at 29 sites in Kan-
sas, where the releases had E10. On
average, the benzene plumes were 39
percent longer at the E10 sites.
To further evaluate this poten-
tial impact of ethanol on the size of
BTEX plumes, Mackay et al. (2006)
did a side-by-side experiment to
compare the effects of ethanol at the
same release site. They constructed
artificial plumes of BT and X. Both
had approximately 1 to 3 mg/L of
benzene, toluene and o-xylene. One
plume had 500 mg/L ethanol, while
the other had none. After the plumes
reached a steady state, the BTX
plume in the presence of ethanol was
four times longer than the plume
without ethanol.
A Conceptual Model to
Predict the Impact of Ethanol
Deeb et al. (2002) developed a con-
ceptual model that can be used to
make quantitative predictions of
the effect of ethanol on the length of
the BTEX plume. In contaminated
groundwater there is very little oxy-
gen available, and anaerobic bacteria
14
carry out almost all of the natural
biodegradation. After all the soluble
electron acceptors such as nitrate or
sulfate are exhausted, the only pro-
cesses assumed to attenuate BTEX
concentrations are physical, such as
dispersion and sorption, and anaero-
bic biodegradation, which proceeds
through a fermentation reaction
that produces acetate and molecu-
lar hydrogen. If the concentration of
hydrogen builds up to a critical level,
the thermodynamics of the BTEX
degradation becomes unfavorable,
and the degradation stops. Ethanol
in groundwater is also fermented to
acetate and hydrogen.
When the concentrations of
ethanol are above 3 mg/L, natural
degradation of ethanol can produce
enough molecular hydrogen to stop
the natural anaerobic biodegradation
of BTEX compounds. In the Deeb et
al. conceptual model, whenever the
concentration of ethanol is above
a critical threshold (3 mg/L), the
natural biodegradation of BTEX is
prohibited. In the region of an aqui-
fer where concentrations of ethanol
are above the threshold, the only
processes that attenuate the concen-
trations of BTEX are dispersion and
sorption. However, ethanol degrades
in the groundwater, and eventually
to a concentration below the thresh-
old. At that point along the flowpath
in the aquifer, the model assumes
that natural biodegradation of BTEX
proceeds at the same rate that would
prevail in the aquifer if ethanol had
not been released.
FOOTPRINT
Ahsanuzzaman et al. (2008) used
the Deeb et al. (2002) conceptual
model to construct a simple screen-
ing model to estimate the area of a
plume of benzene produced from a
release of gasoline containing etha-
nol. The screening model estimates
the plume area, or footprint of the
plume, in addition to the plume
length, because the chance that a
plume will impact a monitoring well
is proportional to its surface area,
not its length. FOOTPRINT is built
around the Dominico analytical solu-
tions to the advection dispersion
transport equation (Dominico, 1987;
Martin-Hayden and Robbins, 1997).
This is the same mathematics that is
used in BIOSCREEN, a widely used
fate-and-transport model.
Applying FOOTPRINT to a
Vulnerable Site
Every plume is different. The ques-
tion is: What will ethanol do to
plume lengths at sites in your case
load? To illustrate the potential
impacts of a biofuel spill, FOOT-
PRINT was calibrated to a large
BTEX and MtBE plume at Naval
Base Ventura County, in Port Huen-
eme, California.
• In the first step, FOOTPRINT
was calibrated without any effect
of ethanol. (Note the check box
labeled COC Only [No Ethanol]
in the lower right of Figure 1.)
If FOOTPRINT is appropriately
calibrated, the simulated output
should adequately mirror the real
benzene plume at the site.
• In the second step, the poten-
tial impact of a new biofuel spill
was simulated by assuming a
relatively high concentration of
ethanol and an average rate of
biodegradation for ethanol.
• In the third step, a potential worst
case was simulated by assuming
-------
December 2010 • LUSTLine Bulletin 66
a slow rate of biodegradation for
ethanol.
This site was chosen because
it is representative of sites where
groundwater is highly vulnerable
to contamination from gasoline. In
the mid-1980s there was a release
of approximately 10,000 gallons
of motor gasoline from the Navy
ethanol extends deep into the water-
table aquifer.
The input menu window for
FOOTPRINT accounts for these fac-
tors (Figure 1). The site has been
particularly well studied, and it was
possible to calibrate FOOTPRINT
using input values that were exter-
nally derived. The only assumed val-
ues in the calibrations are the vertical
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FIGURE 1. Input screen for FOOTPRINT, simulating the potential effect of ethanol on an exist-
ing BTEX plume at a gasoline spill site in California. In this simulation the rate of degradation of
ethanol was set at 2 mg/L per day or 730 mg/L per year.
dispersivity (which was set at a low
number) and the effective porosity.
A pumping test and a variety of
slug tests in monitoring wells indi-
cate that the hydraulic conductivity
at the site is near 100 feet per day.
The hydraulic gradient over nearly a
mile of the flow path was 0.0028 foot
per foot. A tracer study using deuter-
ated MtBE (Amerson and Johnson,
2003) determined that the average
longitudinal dispersivity was 8.8
feet and the average transverse dis-
persivity was 0.82 foot.
The release produced a pool of
floating product that was at least
280 feet wide. The water-table aqui-
fer is approximately 10 feet thick. It
is confined by a lower layer of silt
and clay. The maximum concen-
tration of benzene at the site is 5.4
mg/L. The first-order rate of bio-
degradation was extracted from
data on the attenuation of concen-
trations of benzene with distance
along the flow path, using the
approach of Buscheck and Alcantar
(1995). The release was assumed to
have occurred in 1985, making the
plume 15 years old at the time of
calibration.
• continued on page 16
Exchange (NEX) service station. The
groundwater seepage velocity at the
site is high, nearly one foot per day.
By 2000, the MtBE plume extended
at least 4,600 feet down-gradient of
the release. In August 2000, the Navy
installed an aerobic biobarrier to
treat both MtBE and BTEX contami-
nation in the plume. FOOTPRINT
was calibrated to conditions in the
plume just prior to installation of the
treatment system.
Calibration Details
The impact of ethanol on the foot-
print of a benzene plume will be
greater under the following condi-
tions: (1) the concentration of ben-
zene in the source is high, (2) the
concentration of ethanol is high, (3)
the seepage velocity of groundwa-
ter is high, (4) the natural degrada-
tion rate of benzene is slow, (5) the
natural biodegradation rate of etha-
nol is slow, (6) the source of ethanol
to groundwater is wide in cross sec-
tion to groundwater flow, and (7) the
Coneemraoon along m* Cmurtne « Ihe Plume
o
\
j;
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O
\
\
\
\
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FIGURE 2. Benzene concentration vs. distance along the centerline of the plume for the
FOOTPRINT simulation described in Figure 1. The simulated length where ethanol was pres-
ent above the threshold and degradation of benzene was not allowed was 2,100 feet. The
overall length of the benzene plume was almost 3,200 feet.
15
-------
LUSTLine Bulletin 66 • December 2010
• FOOTPRINTyrom page 15
Simulations for a hypotheti-
cal release of motor fuel assumed
that the fuel was 10 percent etha-
nol. Following Deeb et al. (2002), the
calibration assumed that the initial
concentration of ethanol in impacted
ground water was 4,000 mg/L, and
the threshold concentration was set
to 3 mg/L ethanol. Based on experi-
mental work conducted by USEPA
staff at the Kerr Center in Ada, Okla-
homa, ethanol degradation was
assumed to be a zero-order process.
FOOTPRINT was calibrated with the
rate of ethanol degradation set at 20
mg/L per day and again with the
rate at 2 mg/L per day. These rates
reflect average rates and slow rates
of ethanol degradation under anaer-
obic conditions respectively.
Results of the Simulations
In FOOTPRINT, the results of the
simulation can be presented in two
different ways. Figure 2 presents
concentrations of benzene along the
centerline of the plume. Figure 3
maps the surface area of the benzene
plume 15 years after the release of
ethanol.
Unfortunately, FOOTPRINT
does not allow the user to scale the
axes in the Figure 3 graphic. As a
result, all the "footprints" look the
same. What changes from one simu-
lation to the next is the values plot-
ted on the x and y axes. Figure 4
presents the actual distribution of
MtBE and benzene in the aquifer in
2000, and compares that distribution
to the distribution of benzene if there
was no ethanol and the distribu-
tion in the presence of ethanol. The
charts in Figure 3 were modified and
rescaled to make the axes in the out-
put consistent with the scale marker
in Figure 4.
Notice in Figure 4 that there is
reasonable agreement between the
disposition and surface area of the
real plume and the simulated plume
without ethanol. This indicates that,
for the purposes of this illustrative
exercise, FOOTPRINT is sufficiently
calibrated to conditions at the site.
If the rate of ethanol biodegradation
is 20 mg/L per day, the presence of
even 4,000 mg/L of ethanol will have
little effect on the size of the benzene
plume. The ethanol only becomes
16
important if the rate of ethanol deg-
radation is slow.
Table 1 makes the same com-
parisons as Figure 4 using num-
bers instead of shapes. If the ethanol
degrades at an average rate, the sim-
ulated benzene plume is 27 percent
larger with ethanol than without
ethanol. The simulated effect is well
within the uncertainty in the model
calibration. If the ethanol degrada-
tion is slow, the benzene plume can
be up to four times larger. The MtBE
plume was seven times larger than
the benzene plume. If the rate of etha-
nol degradation is slow, the size of
the benzene plume from a new spill
of E10 might approach the size of the
Pfume Area Exceeding Taget Concentration
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FIGURE 3. Output benzene plume area for the FOOTPRINT simulation in Figure 1. The simulated
area of the benzene plume was 37 acres.
Real Plume
FOOTPRINT Simulation
Benzene,
Plume
Benzene FOOTPRINT
4,OOOmgJLElhanol
degrading at 2 mg/L per
day
Benzene FOOTPRINT
4,000 mg/L Ethanol
degrading at 20 mg/L
per day
Benzene
FOOTPRINT
no Ethanol
FIGURE 4. A comparison of the distribution of BTEXand MtBE in the plume at Port Hueneme,
California, to the projected distribution of benzene from three separate calibrations of FOOTPRINT.
-------
December 2010 • LUSTLine Bulletin 66
Actual Plume FOOTPRINT Simulation Surface Area (acres)
Benzene Plume
MtBE Plume
Benzene Plume, no Ethanol
Benzene Plume, 4,000 mg/L Ethanol degrad-
ing at 20 mg/Lperday
Benzene Plume, 4,000 mg/L Ethanol degrad-
ing at 2 mg/Lperday
6.6
8.9
11.3
37
46
TABLE 1. Comparison of the actual surface area of MtBE and benzene plumes in an aquifer to the
predicted surface areas of the benzene plume as simulated by FOOTPRINT.
MtBE plume that developed at this
site.
Developments in the R&D
Pipeline
Remember that FOOTPRINT is only
a screening model. It is based on
analytical solutions to the transport
equation. As a result, it must assume
uniform flow of groundwater. Notice
in Figure 4 that the real plume takes
a curved path through the aquifer,
probably following local variations
in hydraulic conductivity. FOOT-
PRINT cannot handle variations in
aquifer properties, and in particu-
lar FOOTPRINT cannot handle the
effects of a pumped well that might
tend to draw in a plume.
To overcome these limitations,
the groundwater flow model must
be able to accommodate point-to-
point variation in groundwater
velocity. It will be necessary to move
up to a numerical model to describe
the transport of the contaminants in
groundwater and their impact on
water supply wells. USEPA/ORD is
developing just such a model based
on flow from LUST sites to water
supply wells. This model builds
the characteristics of LUST-site
releases—gasoline volume, composi-
tion, smear zone thickness—into the
aquifer-transport model and then
accounts for mixing of clean and
contaminated water in the well bore.
Example results from the model were
shown at the 2010 National Tanks
conference and are due for publica-
tion in April 2011. •
NOTE: A Problem with FOOTPRINT
in Excel 2007 and higher. FOOTPRINT
will run in later versions of Excel, but it
runs slowly. ORD is working to bring
out a new version of FOOTPRINT that
will not have this problem.
John Wilson is a Research Microbiolo-
gist at the USEPA Office of Research
and Development in Ada, Oklahoma.
He can be reached at
wilson.johnt@epa.gov for advice on
anaerobic biodegradation ofbiofuels.
For technical support for FOOTPRINT
contact csmos.ada@epa.gov. Contact
Jim Weaver at weaver.jim@epa.gov for
details of the numerical model he has
under development.
Disclaimer
The U.S. Environmental Protection
Agency through its Office of Research
and Development funded and managed
the research described here through in-
house efforts. It has been subjected to the
Agency's peer and administrative review
and has been approved for publication as
an EPA document.
References
Ahsanuzzaman, A. N. M., J. T. Wilson, M. Wang,
and R. C. Earle. FOOTPRINT (a screening model
for estimating the area of a plume produced
from gasoline containing ethanol) Version 1.0. A.
EPA/600/R-08/058 (2008).
Amerson, I., and R. L. Johnson. Natural gradient
tracer test to evaluate natural attenuation of MTBE
under anaerobic conditions. Ground Water Monitor-
ing & Remediation 23(1): 54-61 (2003).
Buscheck, T.E., and C.M. Alcantar. Regression tech-
niques and analytical solutions to demonstrate
intrinsic bioremediation, in Proceeding of the 1995
Battelle International Symposium on In Situ and
On-Site, April 1995 (1995).
Corseuil, H. X. and P. J. J. Alvarez. Natural bioreme-
diation perspective for BTX-contaminated ground-
water in Brazil: effect of ethanol. Water Science and
Technology 34 (7-8), 311-318 (1996).
Deeb, R. A., J. O. Sharp, A. Stocking, S. McDonald, K.
A. West, M. Laugier, P. J. Alvarez, M. C. Kavana-
ugh, and L. Alvarez-Cohen. Impact of ethanol on
benzene plume lengths: microbial and modeling
studies. Journal of Environmental Engineering 128 (9),
868-875 (2002).
Domenico, P. A. An analytical method for multidi-
mensional transport of a decaying contaminant
species. Journal of Hydrology 91: 49-58 (1987).
Mackay, D. M., N. R. de Sieyes, M. D. Emarson, K. P.
Feris, A. A. Pappas, I. A. Wood, L. Jacobson, L. G.
Justice, M. N. Noske, K. M. Scow, and J. T. Wilson.
Impact of ethanol on the natural attenuation of ben-
zene, toluene, and o-xylene in a normally sulfate-
reducing aquifer. Environmental Science & Technology
40 (19), 6123-6130 (2006).
Martin-Hayden, J., and G. A. Robbins. Plume distor-
tion and apparent attenuation due to concentration
averaging in monitoring wells. Ground Water 35 (2):
339-346(1997).
Miller, K. D., P. C. Johnson, and C. L. Bruce. Full-scale
in-situ biobarrier demonstration for containment
and treatment of MTBE. Remediation Journal 12(1):
25-36 (2001).
Powers, S. E., C. S. Hunt, S. E. Heermann, H. X.
Corseuil, D. Rice, and P. J. J. Alvarez. The transport
and fate of ethanol and BTEX in groundwater con-
taminated by gasohol. Critical Reviews in Environ-
mental Science and Technology 31(1): 79-123. (2001).
Ruiz-Aguilar, G. M. L., K. O'Reilly, and P. J. J. Alva-
rez. A comparison of benzene and toluene plume
lengths for sites contaminated with regular vs. eth-
anol-amended gasoline. Ground Water Monitoring &
Remediation 23 (1): 48-53 (2003).
Tank Bit
From PEl's Safety Letter 10/15/10
Failure to Communicate Can Be Dangerous
A service technician reported a near miss when he went to a job to fix a dispenser
filter housing. Prior to the visit by the service technician, another employee had
visited the site and had written "bad" on the front of the housing. The employee,
however, failed to note the bad filter housing in the Dispatch Log. When the ser-
vice technician was working on the dispenser, he engaged the shear valve with-
out noticing the sign. When the shear valve was engaged, product was released.
The spill was minor and no injuries incurred. However, the submitting company
noted that the incident could have been prevented if the service technician and
employee had engaged in better communication. The employee should have
added notes to the job's Dispatch Log and thoroughly explained the situation.
The dispenser should have also been properly tagged on both sides. The com-
pany noted that a red "out of order" wire tag on the Impact Valve would have
saved the technician working on the site from an incident. The establishment of a
lockout/tagout procedure for this scenario is also advisable. •
17
-------
LUSTLine Bulletin 66 • December 2010
The Vapor-Intrusion Pathway: Petroleum
Hydrocarbon Issues
by Blayne Hartman
Jt has been four years since my last article in LUSTline on vapor intrusion (LL#53, September 2006). Since then, the vapor-
intrusion pathway has continued to be a "box-office blockbuster" throughout the environmental community. Guidance doc-
uments have been released by the Interstate Technology and Regulatory Council (ITRC), ASTM, and more than 25 states.
USEPA is preparing to update its guidance. However, these documents do not have sufficient distinctions between assessing the
vapor-intrusion pathway for chlorinated hydrocarbons (e.g., CHCs, solvents such as TCE, PCE) versus petroleum-related hydrocar-
bons (e.g., PHCs). As a result, vapor-intrusion assessments are being conducted at many PHC sites when recent evidence suggests
they may not be necessary or they are being conducted in a manner that is inappropriate for PHCs. State reimbursement fund man-
agers are concerned that the costs for unnecessary or improperly conducted vapor-intrusion assessments could drain the coffers of
already cash-poor funds. So what to do?
In this article, I begin with a brief regulatory update on the vapor-intrusion pathway and then address issues specifically related
to PHCs to underscore the distinction between PHCs and CHCs. I refer you to my previous articles written in LUSTline #48 and
#53 for more information on some of the topics covered herein.
Regulatory Updates
• EPA-OSWER
As of this writing, the draft 2002
EPA-OSWER vapor-intrusion guid-
ance has yet to be updated. In 2009,
the Office of Inspector General rec-
ommended that OSWER identify
the portions of the 2002 guidance
that need to be updated. A report
released by OSWER in August 2010
summarizes the areas they feel need
to be updated, including:
• Emphasis on a multiple lines of
evidence approach
• Generic attenuation factors for soil
gas data
• Collection time period for indoor
air samples (days or longer)
(See http://www.epa.gov/oswer/vaporin-
trusion/documents/review_of_2002_
draft_vi_guidancejmal.pdf.)
In a footnote, this document
states that: "The generalized state-
ments in this document may not per-
tain to the more readily degradable
petroleum compounds." OSWER
will be releasing a draft version of
the revised guidance in late 2011, and
has committed to releasing a final
version by November 2012.
Go to OSWER's vapor-intrusion
website for more information: http://
www.epa.gov/oswer/vaporintrusion.
18
• EPA-OUST
Recognizing the need for vapor-
intrusion guidance specific to PHCs,
OUST convened a technical work-
group to prepare guidance spe-
cifically for PHCs. The workgroup
consists of EPA-OUST staff, regula-
tors from several states, and repre-
sentatives from industry. The group
plans to assist with the development
of a series of issue papers on various
topics throughout 2011, draft guid-
ance by November 2011, and a final
version by November 2012 at the
same time as the revised OSWER
guidance.
Fundamental Differences
Between CHCs and PHCs in
the Vadose Zone
PHCs behave differently than CHCs
in the vadose zone for two primary
reasons. First, volatile petroleum
compounds biodegrade readily
in the presence of oxygen and soil
moisture, whereas chlorinated com-
pounds are typically more resistant
to biodegradation. The biodegrad-
ability of volatile petroleum com-
pounds provides an effective,
naturally occurring contaminant-
removal mechanism that inherently
limits the migration of subsurface
petroleum vapors in most cases.
Second, petroleum-hydrocarbon
free product is lighter than water,
while chlorinated-hydrocarbon free
product is denser. These two key
properties (i.e., biodegradability and
density) lead to significantly differ-
ent subsurface source and transport
behaviors that greatly influence
whether vapors reach the near sur-
face and intrude into structures.
One final difference to keep in
mind is that PHC fuel products are
mixtures of many hundreds of com-
pounds, many of which are also
present in common consumer prod-
ucts other than fuel. Chlorinated sol-
vents are typically only one primary
compound with perhaps some deg-
radation compounds.
Biovapor: A New Predictive
Model Incorporating
Bioattenuation
The most common predictive model
currently used for vapor-intrusion
applications is the one-dimensional
Johnson-Ettinger (J-E) model that
USEPA and some states have formu-
lated into Excel spreadsheets (http://
www.epa.gov/oswer/riskassessment/
airmodel/johnson_ettinger.htm). How-
ever, for PHCs this model tends to
significantly overpredict the vapor-
intrusion risk, primarily because
there is no allowance for bioattenu-
ation. Recently, the American Petro-
leum Institute (API) funded the
creation of a new Excel version of the
J-E model that incorporates bioatten-
uation, named Biovapor. Dr. George
DeVaull of the Shell Development
Company developed the original for-
-------
December 2010 • LUSTLine Bulletin 66
mulation of this spreadsheet and the
new Excel version was developed by
GSI Environmental Inc.
Biovapor is a user-friendly
spreadsheet that allows prediction of
indoor air concentrations and asso-
ciated risk from soil-gas or ground-
water data (a version for soil-phase
data is being contemplated). It also
performs the back calculation of
calculating allowable soil-gas and
groundwater concentrations from
indoor-air screening levels.
The model does the calculations
for the individual aromatic com-
pounds (i.e., BTEX, naphthalene), as
well as for aliphatic hydrocarbons.
The model applies bioattenuation
only when sufficient oxygen is pres-
ent in the vadose zone (i.e., aerobic
bioattenuation). It uses a mass-bal-
ance approach to ensure that the
amount of bioattenuation does not
exceed the amount of available oxy-
gen.
Shaw Environmental reviewed
the model formulations in January
2010 under contract to USEPA ORD.
The formulations were found to be
correct. EPA-ORD is planning to
do its own evaluation of the model.
Meanwhile, Robin Davis of the Utah
Department of Environmental Qual-
ity has compared the model's predic-
tions to actual field data at a number
of sites and found the model's results
to be slightly on the conservative
side (in other words, the model often
underpredicts the amount of attenu-
ation and hence overpredicts the
risk). (See Robin Davis's presentation
at http:llwww. neiwpcc. orgllustlinelsup-
plements.asp.)
The model is currently available
on the API website (www.api.org).
Instructional classes/webinars are
being planned and will be listed on
the website.
Exclusion (Screen-Out Sites)
Criteria
A primary problem we are facing
with petroleum hydrocarbon sites is
what criteria to use to decide if a site
needs a vapor-intrusion assessment
if there is not an obvious situation
(e.g., fuel in a basement, petroleum
odor in a structure). If existing
OSWER Tier 1 screening distances
of 100 feet are applied both verti-
cally and spatially, combined with
extremely low Tier 2 screening con-
centration, then the vast majority of
sites will be screened in for further
investigation, and few sites will be
screened out. While these criteria
may be appropriate for recalcitrant
compounds, they are not appropriate
for PHCs in most scenarios.
Robin Davis has analyzed a
database of about 170 sites from the
United States, Canada, and Australia
in an effort to determine screening
criteria for PHCs sites (see LUSTLine
# 61). Her primary goal was to deter-
mine what thickness of clean soil is
necessary for various source concen-
trations to decrease to levels below
LNAPL on groundwater are also
completely attenuated with as little
as eight feet of clean soil between
the source and the receptor, based on
a more limited data set of 76 vapor
samples collected at 16 different sites
(Figure 2).
For soil vapor concentrations,
Robin has previously written in two
prior PHCs articles (LUSTLine #49
and #52) that if three to five feet of
clean, aerobic soil (oxygen > 5%)
exist, vapors are completely attenu-
ated and the vapor-intrusion path-
way will not be complete.
Results for Dissolved
Benzene & TPH
Benzene: 194 exterior/near-slab *•
35 sub-slab = 229 total
* VAftef A QHMtrttf P«rt« UfeMWIIflM
TPH: 68 exterior/near-slab +
22 sub-slab = 90 total
• t»M: t*» Yif* t
I.OM.MO
5 ft clean overlying soil attenuates vapors associated with
dissolved Benzene < 1,000 ug/L, TPH 10,000 ugtL
FIGURE 1. Thickness of clean soil required to attenuate benzene vapors from dissolved benzene
in groundwater and to attenuate TPH vapors from dissolved TPH in groundwater (Robin Davis,
2010).
accepted risk thresholds due to bio-
attenuation.
She concluded that five feet
of clean soil is all that is required
between source and receptor to fully
attenuate benzene vapors for dis-
solved concentrations of benzene up
to 1,000 fig/L and TPH vapors for
dissolved TPH concentrations of up
to 10,000 fig/L (Figure 1), although
the latter value is based on a smaller
number of data points. Compare her
benzene screening value of 1,000
jUg/L to the value that you would
get from the current USEPA Tier 2
screening value of 1.5 fig/L: the dif-
ference is a factor of nearly 700 times!
Robin's database also shows that
benzene vapors volatilizing from
These exclusion criteria for dis-
solved groundwater concentrations,
free product, and soil-vapor con-
centrations are being discussed to
screen out PHC sites from further
vapor-intrusion assessment. Califor-
nia recently included some of them
as screening criteria in their new
draft Leaking Underground Fuel Tanks
(LUFT) Manual.
Sampling Issues for PHC
Sites
• Indoor Air Sampling
The August 2010 OSWER review
document mentioned previously dis-
cusses possibly collecting indoor air
samples at the beginning of a vapor-
• continued on page 20
19
-------
LUSTLine Bulletin 66 • December 2010
I Vapor-Intrusion Pathway from page 19
Results for LNAPL/Contaminated Soil
Vapor umpte event* »tot<*ird wnh LNAPL * euYMnmued »fti meuf CM
tl CLEAN «!•%•• Ui
npon «McM*d wUi LNAFl en GW ind
tell iwrcti
FIGURE 2. Thickness of clean soil required to attenuate benzene vapors from sites with LNAPL
(Robin Davis, 2010).
intrusion investigation. Indoor air
sampling for PHCs will likely be
problematic and confuse, not clarify,
the vapor-intrusion pathway for two
primary reasons:
• Ambient (outdoor air) levels of
benzene exceed the screening lev-
els in most urban areas and can
exceed the one in one million resi-
dential risk levels in many non-
urban areas. Try explaining to the
resident why his or her indoor
air exceeds the allowable cancer
risk value by 10 times, but that it
is okay because the air is coming
from the outside.
• The indoor sources for benzene
and other PHC compounds are
ubiquitous and nearly impos-
sible to identify. My favorite
recent example that demonstrates
this point is Bloonie®, a balloon-
making toy for kids. It contains
obscene amounts of acetone, etha-
nol, benzene, and other goodies,
and you would never think to
remove it from a house if it was
lying on the counter. (Read on for
another example of a ubiquitous
source of benzene in homes.)
In recent presentations at vapor-
intrusion-related conferences,
USEPA-OSWER is recommending
longer indoor air sample-collection
20
periods, for periods as long as 7 to
30 days, based on lessons-learned
from the radon literature. This is not
a good idea for PHC sites because
of the many potential indoor air
sources. The procedure will result
in numerous false positives, which
will require a lot of time and expense
to decipher the actual source of the
detections.
For the above reasons, I rarely
recommend collecting indoor air
samples for PHCs at residences.
For commercial/industrial recep-
tors, collection of indoor air samples
might be more suitable depend-
ing on the allowable indoor levels
(allowable indoor levels can be 10 to
50 times higher than residential lev-
els in some states).
• Groundwater Sampling
Since the existing models and default
attenuation factors do not account
for bioattenuation, you can expect
groundwater data to overpredict
the risk for PHC compounds if there
are no sources in the vadose zone.
Hence, I rarely recommend that
groundwater samples be collected
for PHC vapor-intrusion assess-
ment if soil-gas data can be collected
(sometimes a shallow water table
precludes the collection of soil-gas
data). However, if groundwater data
already exist and indicate there is no
risk, then it is probably a safe bet that
the pathway is not of concern, and
no further assessment is needed.
• Soil-Gas Sampling
Sample Depth
PHC soil-gas sampling locations
differ from those for CHCs owing
to their different fate and transport
behavior. For PHCs, if samples at
deeper depths (>5ft bgs) exceed
allowable values, shallower sam-
ples (<5ft bgs) should be collected
for slab-on-grade structures, since
bioattenuation may be active in the
upper few feet and reduce values
below acceptable levels. If on-site
analysis is available, this decision
can be made in real time. However,
if on-site analysis is not available, I
recommend that my clients collect a
sample shallower than five feet bgs
in the event that the deeper sample
exceeds allowable levels.
The incremental cost of collect-
ing the additional samples is negli-
gible. You can withhold analyzing
the shallower sample to see if results
from the deeper sample indicate
there is a need to analyze it. As far
as the representativeness of shallow
soil-gas concentrations, EPA-ORD
has finished two studies document-
ing that the temporal variation of
soil-gas concentrations as shallow as
two feet bgs are less than 50 percent
(Figure 3). (See http://www.epa.gov/
nerlesdllcmblpdfl270cmb07.pdf.)
Oxygen data should always be
collected to document the presence
of the aerobic zone. Carbon dioxide
and methane are also useful to con-
firm the presence of bioattenuation.
Soil-phase data may also be needed
to document the presence of clean
soil.
Sub-slab vs. Near-slab Samples
For CHCs, the current thinking is
that shallow soil-gas data (5 to 10 ft
bgs) collected outside the building
slab may not adequately represent
sub-slab soil-gas concentrations in
many situations. This thinking is
based on modeling simulations as
well as data from many CHC sites.
But for PHCs, field data currently
being presented by Robin Davis and
Todd Ririe (BP-Arco) at many confer-
ences (http://www.neiwpcc.org/tanks-
conference/pre-workshops.asp) and from
-------
December 2010 • LUSTLine Bulletin 66
Soil Gas Temporal Study
TCE - Probe A3
o
"to
O
O
O
-D
0>
N
lo
2
1.8
1.6
1.4
1.2
1
0.8
0.6
0.4
0.2
0
17'(Port 5)
[ 3' (Port 9)
Time (3/16/07 to 4/10/07)
FIGURE 3. TCE concentrations in soil gas fora period of four weeks for three probes at 3' bgs, 7'
bgs, and 17' bgs (EPA 2007).
Effect of
Source
Concentration
Results suggest that
there may be source
vapor concentrations
that .11 v oflittle
concern if soil gas
beneath the
foundation is well-
oxygenated (e.g.,
•ji I'liini'is :iu i plume
sources)
'
"•
FIGURE 4. 3-D modeling of hydrocarbon vapors showing the effects of bioattenuation (Abreu &
Johnson, 2006).
modeling simulations suggest that
exterior shallow soil-gas samples are
representative, so long as sufficient
oxygen is present (> 4%) and three
to five feet of clean soil exist under
the receptor (Figure 4). So, near-slab
sampling for PHCs should be a via-
ble approach at most sites, unless
contaminated soils or low oxygen is
suspected under the structure.
Including Petroleum
Aliphatics as a Compound of
Concern?
Some states (e.g., MA, CA, WA, HI)
have published indoor air screen-
ing levels for the petroleum ali-
phatic range and require that they be
included as a compound of concern
(COC) for the vapor-intrusion path-
way at PHC sites. There is currently
considerable debate as to whether
this compound group does represent
a potential health threat. I am not a
regulator making policy, but I will
caution those that do—if aliphatics
are included as a COC, it is likely
that many more sites will require
a vapor-intrusion assessment. The
reason for this is that the aliphatics
have much higher Henry's constants
and higher vapor pressures than the
aromatics, resulting in much higher
concentrations in the soil gas (by lOx
to 50x) over free product, near dirty
soil, and even near dissolved con-
tamination.
The fundamental problem is that
petroleum is made up of many dif-
ferent aliphatic compounds, but the
toxicity data exist for very few of
them. Hence, applying the limited
existing toxicity data to the total ali-
phatic fraction is an extrapolation.
To better understand the true risk
of these compounds, it is necessary
that the toxicity of the individual ali-
phatics be reviewed so that the risk-
driving compounds, or compound
groups, are identified and appropri-
ate chemical-specific screening levels
(meaning not too conservative) are
determined.
If you are going to measure the
aliphatics, be sure that the laboratory
does the appropriate compound-
group speciation and that it uses
calibration standards for those com-
pounds. Some labs are quantifying
all the aliphatics using one or two
compounds, such as hexane, rather
than purchasing the expensive ali-
phatic mixture standards.
Beware Natural Gas
Earlier this year, while on a vapor-
intrusion investigation, we dis-
covered 90 percent methane and
benzene in the thousands of ]Ug/
m3 under a garage at a home far
removed from the suspected ser-
vice station source. Using real-time
analysis, we collected additional soil-
gas samples and honed in toward
the culprit—a built-in barbeque in
the adjoining courtyard plumbed
directly to the public natural gas. We
next collected and analyzed a sample
of the natural gas itself and were
astonished to find benzene concen-
trations exceeding 1,000 jUg/m3!
All of the houses in the com-
munity had natural gas fireplaces in
the living rooms, gas furnaces, and
• continued on page 22
21
-------
LUSTLine Bulletin 66 • December 2010
• Vapor-Intrusion Pathway
from page 21
many had gas ovens/stoves. It turns
out that most natural gas supplied
by gas companies across the coun-
try has 0.1 to 1 percent "impurities,"
meaning hydrocarbons other than
methane. Take-home lesson: if the
receptor has natural gas, analyze a
sample of the natural gas for the tar-
get compounds. This should be done
if indoor-air, sub-slab soil-gas, or
exterior soil-gas data are being col-
lected, since underground gas lines
can also leak.
Parting Thoughts
• The Two Most Common Errors in
Vapor Intrusion
Vapors and vapor intrusion are an
unfamiliar territory for many prac-
titioners in this field (i.e., regulators,
stakeholders, consultants, subcon-
tractors, attorneys). Here are two of
the most common errors that I see
being made in this subject area:
• Confusion with Units
One common error that people
make with soil-gas data is think-
ing a ppbv is equivalent to a |Ug/L
or a jUg/m3. The units are not
equivalent, and the conversion
depends on the molecular weight
of the compound. Converting
between units (e.g., |Ug/L to ]Ug/
m3, percent to ppmv) is also caus-
ing headaches. Make your life
simpler by:
- Instructing your lab in which
units and detection levels you
want the data reported.
- Going to www.handpmg.com for
a handy-dandy and easy-to-use
unit conversion spreadsheet.
• Required Soil-Gas Target Levels
The other error I see too often is
the regulator or consultant using
incorrect soil-gas target levels.
Residential values are erroneously
applied at commercial sites, incor-
rect attenuation factors are being
used to determine target values,
or values determined from pre-
dictive models are incorrect. The
soil-gas target level ultimately
determines the required analyti-
cal method and the need for addi-
tional assessment. Determining
the proper value is often an unfa-
22
miliar exercise for both regulator
and consultant. So, consultants
need to ensure that regulators are
asking for the proper values, and
regulators need to ensure that
consultants are proposing the
proper values.
Vapor-intrusion assessments are
being conducted at many PHC sites
when recent evidence suggests they
may not be necessary or they are
being conducted in a manner that
is inappropriate forPHCs. State
reimbursement fund managers
are concerned that the costs for
unnecessary or improperly conducted
vapor-intrusion assessments could
drain the coffers of already
cash-poor funds.
Experience: The Key Ingredient for
Vapor-Intrusion Solutions
The most important ingredient
needed for cost effective, and cost-
efficient vapor-intrusion inves-
tigations is the experience of the
consultant and the subcontractors
(e.g., sampling firm, laboratory). This
is a growing problem as many practi-
tioners are jumping into vapor intru-
sion due to the opportunities that
exist.
Sampling errors include such
basics as not opening containers,
incorrect seals, over-tightening
swage lock fittings, wrong tubing,
using contaminated parts and seal-
ants, and more. Laboratory issues
consist of sending out incorrect or
faulty hardware, using the wrong
method for the required detection
levels (typically at higher cost), and
more. These mistakes result in bad
data that only further confound the
interpretation.
I advise responsible parties to
use consultants experienced with
this pathway. In turn, I advise con-
sultants to use firms experienced in
soil-gas collection and use labs expe-
rienced in indoor-air/soil-gas analy-
sis. The stakes are simply too high
with vapor intrusion to do anything
else.
Want to Know More?
• The Nielsen Field School will be
giving a course on "Soil Gas Sam-
pling for Vapor Intrusion Appli-
cations" in January 2011 in San
Diego. Go to: http:llwww.envirofi-
eldconference.com.
• API is offering free training enti-
tled "Assessing Vapor Intrusion
at Petroleum Hydrocarbon Sites"
covering the topics discussed in
this article and more at the AEHS
conference in San Diego in March
2011.
• As mentioned previously, API
will be offering training on the
Biovapor model throughout 2010
and 2011. Go to www.api.org to
find dates or e-mail me if you are
interested in such training.
• ITRC continues to offer a two-day
vapor intrusion course. San Anto-
nio in January 2011, and three
other locations (TEA) in 2011. Go
to www.itrcweb.org for details.
• EPA-OSWER will be holding a
1-day workshop on vapor intru-
sion at the AEHS conference in
San Diego in March 2011. Go to:
http:llwww. aehsfoundation. org. •
References
Abreau & Johnson (2006). Simulating the effect of
aerobic bioattenuation on soil vapor intrusion into
buildings: Influence of degradation rate, source
concentration, and depth. Env.Sci.Tech., 40, 2304-
2315
LUSTLine articles referenced in this article can be
found atwww.nenvpcc.org/lustline.
Robin Davis (2010). Slides from her most recent pre-
sentations at API's "Assessing Vapor Intrusion at
Petroleum Hydrocarbon Sites" training course.
USEPA (2007). Final project report for investigation
of the influence of temporal variation on active soil
gas/vapor sampling. EPA/600/R-07/141, Decem-
ber 2007.
I wish to thank the following reviewers of
this article for their constructive comments:
Robin Davis, George DeVaull, Larry Froebe,
Tom McHugh, and Todd Ririe.
Blayne Hartman, Ph.D., is an indepen-
dent consultant offering vapor-intru-
sion, soil-gas, and analytical support
services. He has provided training on
soil-gas methods and vapor intrusion
to over 30 state agencies, several U.S.
EPA regions, ASTSWMO, the DOD,
and numerous consultants and stake-
holders. He is a trainer in vapor intru-
sion courses offered by EPA-OUST,
ITRC, API, and previously ASTM. For
more information, contact Blayne at
Blayne@hartmaneg.com.
-------
December 2010 • LUSTLine Bulletin 66
Using In-Situ Chemical Oxidation to
Clean Up Contamination at a Shallow
Groundwater/Fine-Grained Soils Site
by Samar J. Bhuyan and Michael R. Latin
The Arizona Department of Environmental Quality
(ADEQ) developed and implemented a successful reme-
diation approach to address a challenging set of site-
contamination conditions at a leaking underground storage tank
(LUST) site in Somerton, Arizona. The challenges at the site
involved shallow groundwater, fine-grained soils, and gasoline
contamination in the groundwater, smear zone, and in free-prod-
uct phase. The remediation approach combined in-situ chemical
oxidation (ozone injection) with soil-vapor-extraction (SVE)
technology. The cleanup was implemented through the ADEQ's
State Eead Unit (SLU), Corrective Action Section, Waste Pro-
grams Division. The project was initially funded by state funding
and was completed and closed utilizing federal stimulus money
provided under the American Recovery and Reinvestment Act
(ARRA). Timely completion of this project prevented the spread
of contamination to nearby residential properties and a school.
1"T.
r
m
•=/.£
cS
j-
FIGURE 1. Somerton, Arizona, LUST-site map.
The Setting
The previous owner used the prop-
erty as a retail gasoline station dur-
ing the 1980s. In 1987, an unknown
quantity of gasoline escaped from
the UST system into the soil and
groundwater. Of particular concern
was the residential property and the
Desert Sonora Elementary School
located just north and down gradi-
ent of the property. Pump-and-treat
and SVE systems were implemented
by the responsible party in the 1990s
and then terminated without suc-
cessful completion. The responsible
party declared bankruptcy and the
property was sold to the current
property owner.
In 2006, the property owner
requested state-lead program assis-
tance to complete the corrective-
action work. The site lithology
consisted of mostly clay from the
surface to depths ranging between
7 and 11 feet below ground surface
(bgs). Below the clay layer to a depth
of at least 25 feet bgs, a fine-grained,
unconsolidated, and uniform river
sandy layer was observed. The
groundwater level at this site is gen-
erally about 10 or 11 feet bgs.
Due to the shallow nature of
the groundwater, soil contamina-
tion was not the primary remedia-
tion concern. The groundwater had
very high levels of benzene, toluene,
ethylbenzene, and xylene (BTEX).
Arizona's Aquifer Water Quality
Standard (AWQS) for BTEX cleanup
is 5.0, 1,000, 7,000, and 10,000 fig/L
(ADEQ, 2002), respectively.
Groundwater fluctuation, corre-
sponding to nearby irrigation sched-
uling, resulted in a smear zone of
contamination. Nine groundwater-
monitoring wells, as shown in the
site map (Figure 1, extracted from
ADEQ's LUST file), were installed at
the site to delineate the groundwater
plume. This contaminated mass was
estimated to have spread to an area
of approximately 8,200 square feet.
The Methods
The objective of our remediation
approach was to be as effective
and aggressive as possible due to
the presence of the down-gradient
school and residential properties. To
do this, we used, primarily, the in-
situ chemical oxidation technology,
reported to be effective in reducing
contaminants in a short time frame
from both the groundwater and the
smear zone (USEPA, May 2004).
We injected air containing up to 5
percent ozone into the groundwater
for this purpose. Ozone has a very
high chemical oxidation potential of
2.1 V, which is useful for attacking
petroleum contamination aggres-
sively in-situ (ITRC, 2005). The ozone
was injected at a low pressure and
flow so that the contaminated mass
would be less likely to be pushed
underneath the building on the site.
It also helped minimize the potential
for generating volatiles through the
vadose zone and causing groundwa-
ter mounding. The ozone also dis-
solves readily in groundwater, which
can significantly increase dissolved
oxygen (DO) and enhance biodegra-
dation (USEPA, May 2004).
Under this approach, developed
by the SLU in 2007, ten 2-inch-diam-
eter injection wells were installed to
25 feet bgs. They were constructed
with chlorinated poly vinyl chloride
(CPVC) materials and three feet of
stainless-steel screen at the bottom.
The wells were installed in the more
highly contaminated source area.
Injection wells were then connected
through subsurface teflon tubing to
the ozone-injection equipment. Tef-
lon tubings were inserted through
larger diameter (6-inch) PVC pipe
installed in a horizontal trench at
about 4 feet bgs.
• continued on page 24
23
-------
LUSTLine Bulletin 66 • December 2010
• In-Situ Chemical Oxidation
from page 23
Due to the shallow depth to
groundwater, a horizontal SVE sys-
tem was implemented. With this
system, we extracted contaminated
hydrocarbon vapors (using a smaller
blower with a 100 standard cubic feet
per minute [scfm] capacity) from the
vadose and smear zones and treated
it through a catalytic oxidizer.
The horizontal subsurface per-
forated piping consisted of five
different legs, each constructed of
2-inch-diameter PVC perforated
pipe, approximately 40 feet long
(Figure 1). During this period,
groundwater dropped about 3 feet
to approximately 13 feet bgs, result-
ing in the appearance of free product
in three monitoring wells (MW-2,
MW-3, and MW-4; see Figure 2) and
exposure of the smear zone in the
site. These three wells were retrofit-
ted to vapor extraction (VE) wells
and connected to the SVE equip-
ment through subsurface piping,
in order to extract free-product and
smear-zone contamination. The free
product from the wells was also
hand-bailed prior to system start-up.
Start-Up
The SVE system was started on May
31, 2007, utilizing three vertical VE
wells and all five horizontal perfo-
rated legs. The flow rate was initially
Remediation system installation and groundwater-monitoring activity.
98 scfm and later reduced to 40 scfm
due to low hydrocarbon recovery
rate and groundwater mounding
concerns. The ozone injection sys-
tem was then brought into opera-
tion at 2 pounds per day with a flow
rate range of 3.6-4.5 scfm and at a
pressure range of 9-12 pounds per
square inch (psi) through individual
injectors. This ozone injection equip-
ment was programmed to inject a
mixture of ozone and air through
one injection well at a time for one
hour, known as pulsing or cycling.
Each injection well was injecting at
least once per 24-hour cycle. This
pulsing of airflow is reported to be
effective in remediating contamina-
tion (NAVFEC, 2001).
The Outcome
We monitored the progress of this
remediation by periodically sam-
pling the groundwater in nine moni-
toring wells (MW-1 through MW-9)
as well as the influent and effluent
to the catalytic oxidizer. During each
groundwater-sampling event, the
remediation systems were turned off
three days prior to sampling to allow
the groundwater to stabilize and to
collect a homogenized sample. Wells
that showed free product were not
sampled. Atmospheric vapor read-
ings across the site did not show any
unusual readings.
The ozone injection system was
equipped with an ambient ozone
sensor that detects and measures
concentration of ozone emission.
The equipment shuts down auto-
matically if an ozone leak is detected.
Approximately, 670 pounds of ozone
were injected into the groundwater.
Based on the influent vapor sam-
pling, the SVE system was recover-
ing approximately 10 pounds/day of
petroleum hydrocarbons in the ini-
tial four months of operation, which
was reduced to 4 pounds/day, and
then to 0.4 pounds/day toward the
end of the remediation.
The baseline DO measured at
the site prior to the system installa-
tion was in the range of 0.4 through
1.1 parts per million (ppm). DO lev-
els measured during the remediation
period were as high as 8.9 ppm. This
demonstrated a significant increase
in DO as a result of ozone and air
injections. Four boundary moni-
toring wells (MW-5, MW-6, MW-7,
MW-9), which were away from the
24
-------
December 2010 • LUSTLine Bulletin 66
Months
FIGURE 2. Benzene concentration data in a few selected wells. Note: Free product was detected in
MW-2, MW-3, and MW-4 in early 2007.
ozone injection area, also showed
increased DO levels. These wells
were between 40 and 80 feet away
from their nearest ozone injection
well. The location of the boundary
injection wells enhanced bioremedia-
tion in the outer edge of the plume.
Groundwater elevation during
the remediation period remained
at approximately 13 feet bgs, which
helped expedite free-product recov-
ery and smear-zone remediation.
The free product contamination dis-
appeared after three months of oper-
ation. Free product was not analyzed
for contaminants of concern (COC).
Sampling below the free-phase
area would have provided us with
a better understanding of the total
contaminant mass. Therefore, the
concentration data shown in Figure 2
cannot be used to estimate this mass.
Benzene concentrations in most
contaminated wells are shown in
Figure 2. The COCs from most of the
wells dropped significantly within 8
months of system operation. After 18
months of system operation, results
from the December 2008 ground-
water-sampling event showed that
COCs in all wells except one, MW-3,
were below AWQS. Active remedia-
tion on the site was terminated fol-
lowing this sampling event.
Two rounds of post remediation
groundwater sampling were per-
formed approximately one year after
the termination of active remediation
to test for any rebound of contami-
nants. Confirmatory soil sampling
at two locations was also performed
to test for residual soil contamina-
tion across the vadose zone. All
COCs were measured below AWQS
and soil cleanup levels. The site was
closed in February 2010.
It should be noted that bioreme-
diation (natural attenuation) may
have occurred during the post-active
remediation period to address resid-
ual contamination. This remediation
phase helped reduce remediation
costs as a result of system opera-
tion and maintenance, generation of
remediation wastes, and associated
costs for treating residual levels of
contamination. Recently, the remain-
ing infrastructures were abandoned
and the site was restored as close as
possible to its original condition.
The successful results of this
remediation approach, however,
should not be taken as endorsement
for this application in similar site
conditions. Detailed site-specific con-
dition and feasibility tests should be
carefully evaluated before develop-
ing any remediation approach. •
Somar J. Bhuyan, Ph.D., is an Envi-
ronmental Engineer and Michael R.
Latin is the Manager of State Eead Pro-
gram, Corrective Action Section, Waste
Programs Division with the Arizona
Department of Environmental Qual-
ity. Samar J. Bhuyan can be reached at
bhuyan.samar@azdeq.gov.
Acknowledgement: Funding for this project
was provided under Arizona's State Assur-
ance Fund and American Recovery and
Reinvestment Act (ARRA). The remediation
approach was implemented through Ground-
water and Environmental Services, and post-
active remediation activities were performed
through Elaes Environmental Management,
Inc., State Environmental Contractors con-
tracted with State of Arizona. Comments
from Eric Magnan, P.E., Underground Stor-
age Tank Program Office, U.S. EPA Region 9
were much appreciated.
References
Arizona Department of Environmental Quality
(ADEQ), 2002. Release Reporting and Corrective
Action Guidance. Underground Storage Tank Pro-
gram.
The Interstate Technology & Regulatory Council
(ITRC). January 2005. Technical and Regulatory Guid-
ance for In-Situ Chemical Oxidation of Contaminated
Soil and Groundwater. Second Edition, January 2005.
Naval Facilities Engineering Command (NAVFEC).
August 2001. Technical Report. Final Air Sparging
Guidance Document. TR-2193-ENV.
United States Environmental Protection Agency
(USEPA). May 2004. How to Evaluate Alterna-
tive Cleanup Technologies for Underground Stor-
age Tank Sites: A Guide for Corrective Action Plan
Reviewers. EPA510-R-04-002.
• .
Maine DEP Receives National Award for
Online Operator Training
The Maine Department of Envi-
ronmental Protection received an
award for its TankSmart online L
service from the Center for Digi-
tal Government's annual "Best of
the Web" program—Government-
to-business category. The awards
given for online state government
services are chosen for their innova-
tion and effectiveness. TankSmart
(www. Maine, go v/online/tanksmarf)
is a free online service that provides
training and certification for Class A/B operators of underground storage tank
facilities. Congrats to the Maine UST program folks.
25
-------
LUSTLine Bulletin 66 • December 2010
A MESSAGE FROM CAROLYN HOSKINSON
Director, USEPA's Office of Underground Storage Tanks
Move Over Sisyphus, Here's a Real
Challenge: Reducing the National
LUST Cleanup Backlog
/n Greek mythology, Sisyphus was a king who angered the gods so much that they
punished him with a difficult and never-ending task. He was made to roll a huge
rock up a steep hill, but before he could reach the top of the hill, the rock would
always roll back down, forcing him to begin again. At times, cleaning up the nation's LUST cleanup backlog seems like a
Sisyphean task. We continually clean up sites, but the pace of cleanups has slowed, some sites remain open for decades,
some are not addressed, and all the while new releases add to the workload. There doesn't seem to be an end in sight.
A Unique Analysis of the Cleanup Backlog
As of March 2010, more than 491,000 releases from USTs
had occurred nationwide. The states (with a few done by EPA
in Indian Country) have made tremendous progress address-
ing these releases by cleaning up 395,000 (80%) of them.
This achievement represents an enormous amount of work
and resources. However, a national backlog of over 96,000
releases remains, and the annual number of cleanups com-
pleted nationally has declined steadily since FY 2000. To
understand the makeup of the backlog of releases and why
the pace of cleanups is slowing, EPA under-
took a two-phase data-driven analysis of
the backlog. Phase 1 of the study uti-
lized summary data from 45 states
to determine that 60 percent of
the backlog was concentrated
in ten states, that many
releases in the backlog
were old, and that there
were more groundwa-
ter than soil-only sites,
although many soil-only
sites remain in the back-
log.
In Phase 2, EPA
invited 14 states to
participate in a more in-
depth analysis of their
LUST backlogs. We
were interested in iso-
lating several attributes of the sites in the backlog
(e.g., age, media affected, prioritization) and looking closer
at how state cleanup programs functioned. EPA selected
those 14 states because they are responsible for approxi-
mately 67 percent of the national LUST cleanup backlog and
provide participants from all ten EPA Regions. EPA worked
with the states to ensure it used the correct data elements
for analysis, and the states provided EPA with the data from
their LUST cleanup programs.
By the end of FY 2009, the cleanup programs in the
participating states had closed 71 percent of their cumula-
tive releases but had over 71,000 releases remaining in their
cleanup backlogs. EPA was able to identify patterns and
trends within the state backlogs that could provide potential
opportunities to reduce the state and national cleanup back-
logs and improve cleanup progress. The report on Phase 2
will consist of 14 individual state reports and one national
summary report. EPA will use the results of the study to set
the groundwork for discussions with states and tribes and
other stakeholders to develop targeted backlog reduction
strategies.
Some Disconcerting
Findings
Many of the states' open
releases looked at in Phase
2 are very old and still in
the early stages of cleanup.
Over 50,000 of the releases
are ten years old or older,
and over half of the releases
did not have a completed
site assessment.
Many factors affect the
pace of cleaning up releases,
including funding availabil-
ity and mechanisms, statutory
requirements, and program structure.
For example, the current backlog is likely
composed of difficult-to-remediate sites. Data
indicate that the majority of releases in the back-
log contaminate groundwater resources. In general,
remediating groundwater contamination is more techni-
cally complex, longer-term, and more expensive than reme-
diating soil contamination. Therefore, larger numbers of
releases affecting groundwater could be a major reason for
the persistence of the LUST cleanup backlog.
In addition to the prevalence of groundwater contami-
nation, the states lacked the resources to fully address all
of these expensive cleanups in the near term. EPA is aware
that state cleanup programs face obstacles to reducing
their backlogs and that the recent economic downturn has
also had a tremendous impact on the states' ability to make
26
-------
December 2010 • LUSTLine Bulletin 66
MESSAGE FROM CAROLYN HOSKINSON continued from page 26
progress on cleanups. State cleanup funds and staff are
often stretched thin and cleanup costs are increasing. Fur-
thermore, many cleanups have uncertain financing.
Is all the low-hanging fruit already picked? Our data
say, No! But, many of the low-hanging fruit are low-pri-
ority fruit, and we're not picking those. State programs
use various strategies to address limited resources, such
as prioritizing releases to focus on the worst sites first.
These practices have positive benefits: they address the
highest risks to human health and the environment and
protect state environmental resources. However, they also
can contribute to the backlog, especially where statutory
requirements prevent some state programs from complet-
ing easy, lower-priority closures. Consequently, there are
many sites in the backlog that are very old, low priority,
and will likely remain unaddressed for many more years
to come.
Opportunities to Reduce the Backlog
EPA acknowledges that many state programs have initi-
ated their own backlog reduction strategies. Such efforts
have included data and file reviews and the use of tempo-
rary staff (e.g., interns, contractors) to close more releases.
Other strategies being implemented include using multi-site
agreements to encourage responsible party activity, utilizing
pay-for-performance and other incentives for contractors
to reach closure, and referring releases to brownfields pro-
grams or other programs like voluntary cleanup programs.
EPA wants to highlight these efforts, encourage sharing
best practices, and continue to build on states' successes.
The Phase 2 report analyzes and presents additional
factors related to backlog releases. Throughout the national
study, EPA identifies potential opportunities for improved
backlog reduction. The opportunities presented are related
to three main categories: accelerating corrective action,
pursuing targeted initiatives, and improving program imple-
mentation. These opportunities are not intended as spe-
cific recommendations. They are meant to open dialogue
with the states and other stakeholders on all opportunities
to reduce the national cleanup backlog and to serve as the
basis for the backlog reduction strategies that EPA intends
to develop jointly with the states and tribes.
Next steps for EPA include working with the states
and tribes to identify and begin to implement backlog
reduction strategies, explore further questions about the
existing backlog, examine funding issues for LUST clean-
ups, look at cleanup goals and milestones, and support
the states and tribes in improving LUST program manage-
ment. Our role as Sisyphus is more illusion than reality,
and by retooling our approaches we can reach the top of
the hill. Our work is important to the nation's health and
safety, and we must find ways to improve our efforts. •
Investigating Petroleum UST-Equipment
Problems and Releases (ASTM E2733-10)
by Thomas Schruben
Since the 1980s, significant
strides have been made in pre-
venting releases. By all reports,
the frequency of releases is down,
and the size of releases is typically
smaller than the bad old days of
USTs. But releases still happen, even
in systems that are in full compli-
ance with current regulations. In
fact, when viewed as a fraction of the
active tank population, the rate of
release discovery is now only about
half the rate in the 90s (Figure 1).
One can argue that the current
rate of releases is actually much
lower than that indicated by this
graph, because this statistic includes
new discoveries of old releases and
only a fraction of these discoveries
are from new failures. While there
is probably some truth in this argu-
ment, it brings me to the point of
this article—we don't really know
4.5%
enough to make
definitive state-
ments about the
rates of releases
or the sources and
causes of releases.
Congress
tucked a pro-
vision into the
Energy Policy Act
of 2005 that tasked
USEPA with gath-
ering data on the
sources and causes
of releases, but
by all accounts,
the data gathered
so far does not provide the insight
needed to focus prevention efforts on
the weak links in UST systems in the
ground today.
Carol Eighmey Executive Direc-
tor of the Petroleum Storage Tank
1990
1995
2000
2005
2010
FIGURE 1. New-release reports nationally as a % of number of active
tanks. Data from 1990 through 2010 EPA 0US7"Semiannual Report of
UST Performance Measures.
Insurance Fund, compiled Annual
"Source and Cause Reports" from
47 state UST programs. (For more
information, contact Carol Eighmey
at pstif@sprintmail.com.) Eighmey
has concluded that the data pres-
• continued on page 28
27
-------
LUSTLine Bulletin 66 • December 2010
lASTME2733-10^om
27
ent "a largely meaningless picture in
which the vast majority of releases
are catalogued with 'other' or
'unknown' as the source or cause of
the release, providing little insight
into what equipment is failing or
which regulations need strengthen-
ing or increased enforcement."
And So, a Standard Guide
Gathering data that can be analyzed
for sources and causes of failure
requires investigation and unifor-
mity—some kind of standardized
data-gathering method. Creating this
kind of standard sounded like a job
for the American Society of Testing
Materials (ASTM), so Dennis Rounds,
Director of Risk Management for
South Dakota and Past Chair of the
E50.04 Subcommittee on Environ-
mental Corrective Action, asked me
and the ASTM E50.04 Subcommittee
to develop what has now been pub-
lished as the ASTM E2733-10 Standard
Guide for Investigation of Equipment
Problems and Releases for Petroleum
Underground Storage Tank Systems.
Several years ago Dennis con-
ducted an UST autopsy study for
South Dakota's Petroleum Release
Compensation Fund. The informa-
tion from that study has been very
useful to the UST community in
South Dakota. Dennis would like to
make it easier for states to collect this
type of information routinely during
tank closures. He believes that states
would benefit from greater detail
and uniformity in sources and causes
of release data. Both Dennis and I
believe that this data can be collected
by inspectors, tank removal contrac-
tors, and tank maintenance contrac-
tors with little additional expense.
E2733 is intended to assist in the
development of protocols for the
investigation of a malfunction or fail-
ure of storage tank systems and the
implementation of said protocols.
The guide outlines steps that may be
necessary, including but not limited
to: initial evaluation of the UST sys-
tem to determine the malfunction(s);
preparation of samples of failed
equipment for laboratory analysis;
and documentation of the investiga-
tion.
The guide provides a series of
investigation options the user may
employ to design failure investiga-
28
tion protocols. It describes common
investigation techniques in the order
in which they might be employed
in an investigation. In other words,
it puts some meat on the bones of
collecting data on the sources and
causes of releases.
A user may elect to utilize this
guide for a number of reasons,
including but not limited to:
• Differentiating new releases from
new discovery of old releases
• Establishing malfunction and fail-
ure rates of various storage tank
equipment components
• Determining expected life spans
of various storage tank equipment
components
• Identifying opportunities for
improving the performance and
reliability of storage tank equip-
ment
• Focusing inspection and mainte-
nance efforts on portions of the
tank system most prone to mal-
function and failure
• Identifying components of the
storage tank system that require
more frequent maintenance
• Reducing remediation and equip-
ment replacement costs
• Preventing petroleum releases
• Identifying conditions that may
cause or contribute to the dete-
rioration or cause the malfunction
and failure of various components
of the UST system
• Complying with environmen-
tal regulations that require the
investigation of release-detection
alarms and the source of releases.
The guide may be used to estab-
lish a framework that pulls together
the common approaches to UST sys-
tem investigation and allows users
to establish an investigation protocol
to meet their specific requirements.
Specific user requirements will vary
depending on the purposes of the
data collection and the decisions that
the investigation is intended to sup-
port.
While the guide focuses on iden-
tifying and documenting UST system
equipment problems and preserv-
ing problem equipment and does not
provide guidance on establishing root
causes of equipment malfunction or
failure, it does provide the first, nec-
essary steps in a root-causes inves-
tigation. Identifying the root causes
of equipment malfunction or failure
may require further expert analysis
of the data and equipment collected
during the failure investigation.
The guide includes informa-
tion on methods of investigation,
documentation, taking samples of
problem equipment, preserving
equipment samples, chain of cus-
tody, storage, shipping, working
with equipment manufacturers, and
notifying regulators and listing labo-
ratories. It provides techniques for
documenting problems while the
tank system is operating, while it is
being removed, and after the equip-
ment has been removed.
Working with equipment manu-
facturers is particularly important
because they need to know about
problems in the field if they are to
improve their equipment and pro-
vide effective instructions to the
installers, maintenance contractors,
and owners of tank systems. Simi-
larly, notifying listing laboratories
like UL provides valuable real-life
information they can use to improve
the testing and listing procedures for
the equipment they list.
Implementation Pilot Project?
As wonderful and useful you may
think this guide is, publishing a
guide is only the first step to a better
world. As is oft-repeated in the pages
of LUSTLine, implementation is the
key. To that end, Dennis Rounds
and I would be happy to work with
states where there is interest in doing
a pilot project on incorporating this
guide, first, into their inspector train-
ing program and eventually into
their installer or tank-removal train-
ing programs. We feel that a pilot
project would help refine the guide
and bring in the knowledge needed
to start compiling useful statistics.
If you are interested contact Dennis
Rounds (dennis.rounds@state.sd.us)
or me. If you would like a copy of
the standard, it can be purchased
at ASTM.org or contact Dan Smith
(dsmith@astm.org) for more infor-
mation on obtaining this standard
for regulators. •
Tom Schruben is an independent
environmental risk-management
consultant and UST-equipment failure
investigator. He can be reached at
environmentalguy@aol.com.
-------
December 2010 • LUSTLine Bulletin 66
Class C Operator Saves the Day When Dogs
Drive Van into Dispenser
by Ben Thomas
As a trainer you want to think
all your hard work pays off
and that the folks you train
are actually putting into practice
what they've learned. And some-
times you get a small reward as a
reminder that what you are doing
matters. This story is about such a
reminder.
When we used to do more
classes live and in person, I would
sometimes get an operator who had
to take an emergency call on his or
her cell phone and step out of the
room to respond to an alarm or spill.
And because the operator was in a
classroom and off-site—usually in
some city halfway across the state—
response was limited to delegating
action to an on-site coworker.
With Web training, people can
be attending from anywhere. When
we do Class A/B webinars, people
often take the class in an office and
sometimes even in the back room of
a C-store.
In December 2009, I received
an email at lunch break during an
online Class A/B Operator class I
was conducting:
"Sorry I had to scramble out of
class today. A customer parked his
van while he was having lunch in my
deli, his "dogs" jumped on the steer-
ing wheel/dash board and put it into
gear! [The engine was on.] Rolled
into the pump, smashed it. Fuel
started flowing. THANK GOOD-
NESS for my responsible certified
"C" Operators!!!! They did every-
thing right. One person shut off the
emerg. switch and breakers while the
other one contained the flow of the
spill with the socks, pads, etc. and
the 3rd one called me! WHEW! Fire
dept. wasn't necessary.
I will be in class tomorrow while
all the "certified" workers are trying
to get my business running again."
When I emailed back for details,
the operator told me they had
certified their Class C operators
two months ago, and all the store
employees had attended a safety
Lessons Learned:
Q Even with training, acci-
dents can and do happen,
sometimes where you least
expect it.
Q Training compliance can
be measured by certificates
or response actions. We
like the latter.
Q Training can result in a sig-
nificant savings of time,
money, and petroleum.
Q Using real, live incidents
as case studies can be a
very informative learning
tool.
Q When you're at a C-store,
don't leave the engine on
when you go inside! •
Damaged dispenser.
meeting a couple of weeks
prior. When I asked what hap-
pened at the dispenser she
replied:
"The shear valve did not
shear. The impact of the van
crashing into the dispenser
broke the connection between
the filter housing and the
delivery piping, even break-
ing off the bolts! The electri-
cal conduit got displaced and
opened also. I did take several
pictures. I will try and down-
load and send them to you by
class tomorrow."
The second day of class,
the operator very generously
allowed me to share the pho-
tos. The cool thing about the
webinar as a learning plat-
form is that we were able to
look at the pictures, discuss
what happened, sleuth out the
causes, and have an interactive study
case—all in nearly real time. The
students really appreciated using
the incident as a learning exercise to
make the training material more rel-
evant and meaningful.
The shear that didn't shear.
Ben Thomas is an online trainer for
class A, B, and C operators. A former
LIST regulator in Alaska, he has been
training operators since 2004. He can
be reached at ben@USTtraining.com.
29
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LUSTLine Bulletin 66 • December 2010
from Robert N. Renkes, Executive Vice President, Petroleum Equipment Institute (PEI)
PEI Revises RP100 UST Installation Document
The 2011 edition of the Petroleum Equipment
Institute's (PEIs) Recommended Practices for Instal-
lation of Underground Liquid Storage Systems (PEI/
RP100) is now available. This eighth edition of RP100
supersedes the previous recommended practices of the
same name that were published in 2005. PEI revises
RP100, when warranted, to ensure that users of its doc-
uments receive the latest guidance on the proper meth-
ods and techniques for installing underground storage
tank (UST) systems.
PEI's Tank Installation Committee, which includes
installers and federal and state UST regulators,
reviewed over 70 suggestions submitted by various
individuals and groups to revise the previous edition
of PEI/RP100. The committee accepted more than 50
percent of these comments in some manner. I won't
go through all of the changes here for several reasons.
First, we don't have enough space in LUSTLine to list
them all. And second, I'm afraid it would put all but
the most avid tank installer/regulator to sleep. Having
said that, however, several of the changes are worth
noting and will provide you with a sense of the kinds
of issues the committee addressed and how they dealt
with them.
• Recognizing that ballasting underground tanks with
water may promote problems with microbial con-
tamination that may lead to subsequent fuel-qual-
ity issues, the document now recommends that the
installation of submersible pump motors be post-
poned until after the water ballast has been com-
pletely removed (Section 5.3).
• The committee confirmed that the UST has to be
tight for flapper valves to be used as overfill pre-
vention by requiring that all risers above the flow
shut-off device be properly sealed to prevent prod-
uct from being discharged when the overfill shut-off
device closes (Section 7.3.2).
• The warning that prohibited vent-restriction devices
on emergency-generator or heating-oil supply tanks
has been removed (Section 7.3.3) because it was con-
sidered to be redundant with another warning in
the same section.
• Language reflecting the secondary containment pro-
visions of The Energy Act of 2005 was incorporated
in the secondary-containment chapter (Section 8).
• A new section for transition sumps was added.
New Section 8.6 now states: "Transition sumps may
be required for reasons of extending existing pip-
ing systems, extending from underground piping
to aboveground apparatus, or creating branches in
piping. Transition sumps have similar requirements
as other sumps, but, additionally, should always be
continuously monitored and installed in conjunc-
tion with a raised concrete apron not less than 24
inches all around the grade opening for durability
reasons."
• A new warning was added to the groundwater
monitoring section, admonishing installers never to
use fill caps or similar-appearing covers for observa-
tion-well service (Section 9.2.2).
• The committee noted that many truck stops and
other large facilities have been installed with line
leak detection that does not function properly. A
new warning has been added to the automatic line
leak detection section, explaining that mechanical
line leak detectors may be insufficient to detect leaks
quickly in high-throughput systems or systems with
submersible pumps operating in tandem. The warn-
ing goes on to suggest that additional means of leak
detection may be required (Section 9.3.1).
• If a piping manufacturer permits a shallower piping
installation depth than recommended in RP/100,
the document will now allow those shallower
depths, provided the installation is thoroughly com-
pliant with the manufacturer's specifications for
configuration and quality (Section 10.4).
• RP/100 has long maintained, as a general rule, that
product piping maintain a minimum slope of 1/8
inch per foot toward the tank, a dispenser sump, or
a collection sump. The committee elaborated on that
statement by adding the following language to the
third paragraph of Section 10.4: "In pressure sys-
tems, slope may not be necessary on supply lines.
Rather, communication between the interstitial
space of secondarily contained pressure supply lines
and collection sumps should be maintained so that
released product can enter a sump and be visually
observed or detected by sensors. For safe suction-
piping configurations, the entire piping run must
slope down to the tank, allowing product to drain
safely if air should enter."
The committee also made changes in the sections
of the recommended practices dealing with piping
trenches (tracer tape), threaded joints, flexible con-
nectors, fuel compatibility, and vent piping. New sec-
tions on shear valves and manhole identification were
added. All the drawings were updated.
The 2011 PEI/RP100 is copyrighted and may not
be photocopied or otherwise reproduced. Order copies
online at iviviv.pei.org/rplOO. •
30
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December 2010 • LUSTLine Bulletin 66
FAQs from the NWGLDE
...All you ever wanted to know about leak detection, but were afraid to ask.
Unsupported Leak Detection Methods
In this LUSTLine FAQs from the National Work Group on Leak Detection Evaluations (NWGLDE), we discuss leak detection meth-
ods that are no longer supported by the company that markets them. Note: The views expressed in this column represent those of
the work group and not necessarily those of any implementing agency.
The NWGLDE depends on the company that mar-
kets a leak detection method to notify us of any
changes. As we are made aware of corporate
changes (e.g., companies being acquired by other
companies, ceasing operation), this information is
added to the NWGLDE list. However, this informa-
tion will not always be on the listings, because we
don't always receive this information. Even if we do
receive the information, we may not be able to ver-
ify its accuracy.
Please be aware that even though a NWGLDE leak
detection method listing indicates that a company
is out of business, or that the equipment is no longer
supported by the manufacturer, the method still has
the potential to perform well without further support.
Theoretically these unsupported methods could func-
tion indefinitely. However, as technology advances,
some of these methods may encounter compatibility
issues (new computer operating systems that will not
run certain software, unavailability of replacement
parts). In these scenarios, even though a leak detection
method is still listed by the NWGLDE, the method
will become obsolete, and another leak detection
method will need to be used. •
According to the NWGLDE website, [a certain com-
pany] is out of business. Given this circumstance, is
this method still approved by the NWGLDE?
A. Before answering this question, we need to make it
clear that the NWGLDE list is not a list of "approved"
leak detection methods. Please review the disclaimer
on our website at http://iviviv.nivglde.org/disclaimer.
html. The NWGLDE list is a compilation of meth-
ods that meet the criteria for being listed on our list;
namely, a successfully completed third-party evalua-
tion that is properly performed in accordance with a
protocol that has been found to be acceptable to the
NWGLDE.
Now, the answer to the question: Once a leak detec-
tion method has met the criteria for being listed,
it remains on the list, even if the company is out of
business or the company no longer provides support
for the method. We do this because those who have
purchased the leak detection method may still be
using that method. To remove such a method from
the NWGLDE list could create problems in states
where the method is still in use, and only leak detec-
tion methods that are listed by the NWGLDE are
allowed.
If a state has concerns about tank owners using listed
leak detection methods that may no longer have sup-
port from the manufacturer, we suggest that the state
develop a policy or regulation that would preclude
tank owners from using such methods. (Please note:
the NWGLDE does not get involved with the devel-
opment of implementing agency policy or regula-
tion.)
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.
L«U«S«T«LINIE Subscription Form
Name .
Company/Agency
Mailing Address
E-mail Address
J One-year subscription: $18.00
_l Federal, state, or local government: Exempt from fee. (For home delivery, include request on agency letterhead.)
Please enclose a check or money order (drawn on a U.S. bank) made payable to NEIWPCC.
Send to: New England Interstate Water Pollution Control Commission 116 John Street, Lowell, MA 01852-1124
Phone: (978) 323-7929 • Fax: (978) 323-7919 • lustline@neiwpcc.org • www.neiwpcc.org
31
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New England Interstate Water
Pollution Control Commission
116 John Street
Lowell, MA 01852-1124
Ellis and Frye Receive LUST Poster Session Lifetime Achievement
Awards at the National Tanks Conference
The LUST Poster Session Lifetime
Achievement Award was presented
this year to Pat Ellis of Delaware,
DNREC, and Ellen Frye, Editor of LUSTLine.
Pat was recognized for her many years of
dedication, leadership, and significant con-
tributions to the science of site assessment,
risk evaluation, and cleanup for LUST sites.
Ellen was recognized for her dedication
and tireless efforts to ensure that the lat-
est information on operating and cleaning
up underground storage tank sites is dis-
seminated and documented in LUSTLine,
the "bible" of the UST/LUST program. The
award was presented from their friends
and colleagues with many thanks for years
of dedication and significant contributions.
Previous award recipients include John
Wilson, USEPA Kerr Lab, Bruce Bauman,
American Petroleum Institute, and Robin
Davis, Utah DEQ. •
Pat Ellis and Ellen Frye receive the 2010 LUST Poster Session Lifetime Achievement
Award. From left to right: Pat Ellis, DE, DNREC, John Wilson, USEPA ORD, 2007 award
recipient, Ellen Frye, LUSTLine Editor, Robin Davis, Utah DEQ, 2009 award recipient,
and Bruce Bauman, API, 2008 award recipient.
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