New England Interstate
Water Pollution Control
Commission
www.neiwpcc.org/lustline
116 John Street
Lowell, Massachusetts
01852-1124
Bulletin 67
March 2O11
LUS.T.UNE
A Report On Federal & State Programs To Control Leaking Underground Storage Tanks
The Growing Vulnerability of Groundwater
by Fran Kremer, John Wilson, and Jim Weaver
T A ~jTater supply has long been a concern in the western
I /\ I states. More recently, however, water supply is also
V a growing concern and at times a contentious issue
in southeastern states. Increasing water demands in this region
have led to some severe water restrictions, and in some cases,
this has necessitated the use of the judicial system to resolve
water allocation disputes.
So how does this pertain to underground storage tanks
(USTs)? Those who have been engaged in UST issues over the
past two decades can readily recall some high-profile instances
in which UST sites have impacted drinking water supply wells.
This vulnerability is of particular concern when water supply
wells are being pumped at higher rates in order to deliver water
to meet the demand of communities. Can we expect this vulner-
ability to change?
• continued on page 2
Illustration courtesy the Ground Water Protection Council's Ground Water Report to the Nation: A Call to Action
Inside
4(J Alas, Poor Groundwater
"U Sources and Causes of Releases
8() TQM and USTs
1 "I U Fuel Quality/Tank Design
14() Biofuels Happenings
16(J ARRA- Lessons Learned in Maine
19Q Tanks on Tribal Lands
21 Q Field Notes
S2() FAQs: Adding Biodiesel Blends to NWGDLE Listings
-------
LUSTLine Bulletin 67 • March 2011
m Growing Vulnerability of
Groundwater yrom page 1
Co-location of Population
and USTs
There are several factors that may
contribute to potential impacts
of leaking underground storage
tanks (LUSTs) on water supplies,
including locations of USTs, cli-
mate change, types of fuels stored
in USTs, and growing demand.
First is the co-location of the popu-
lation and gas stations which is,
of course, driven by ready access
to the stations. However, if we put
co-location in the context of avail-
able shallow groundwater used by
communities for drinking water
and in proximity to gas stations, we
find, not surprisingly, that these are
similarly co-located. This proxim-
ity has the potential to increase the
vulnerability of that water supply.
Two national data sets on service
stations and drinking water from
shallow groundwater illustrate this.
Figure 1 depicts the distribution of
service stations nationally. Figure 2
L.U.S.T.Line
Ellen Frye, Editor
Ricki Pappo, Layout
Marcel Moreau, Technical Adviser
Patricia Ellis, PhD, Technical Adviser
Ronald Poltak, NEIWPCC Executive Director
Deb Steckley, USEPA Project Officer
LUSTLine is a product of the New England
Interstate Water Pollution Control Commis-
sion (NEIWPCC). It is produced through
cooperative agreements (US-83384301 and
US-83384401) between NEIWPCC and the
U.S. Environmental Protection Agency.
LUSTLine is issued as a communication
service for the Subtitle I RCRA
Hazardous & Solid Waste Amendments
rule promulgation process.
LUSTLine is produced to promote
information exchange on UST/ LUST issues.
The opinions and information stated herein
are those of the authors and do not neces-
sarily reflect the opinions of NEIWPCC.
This publication may be copied.
Please give credit to NEIWPCC.
NEIWPCC was established by an Act of
Congress in 1947 and remains the old-
est agency in the Northeast United States
concerned with coordination of the multi-
media environmental activities
of the states of Connecticut, Maine,
Massachusetts, New Hampshire,
New York, Rhode Island, and Vermont.
NEIWPCC
116 John Street
LoweU, MA 01852-1124
Telephone: (978) 323-7929
Fax: (978) 323-7919
lustline@neiwpcc.org
*® LUSTLine is printed on recycled paper.
FIGURE 1.
DISTRIBUTION OF SERVICE STATIONS
FIGURE 2. DISTRIBUTION OF PEOPLE
DRINKING SHALLOW GROUNDWATER
(1990 census data, each dot is 1,000 people.)
identifies the distribution of people
reliant on shallow groundwater for
their drinking water supply.
Vulnerability Index
The data on service stations and
on populations utilizing shallow
groundwater for drinking water was
integrated by using a vulnerabil-
ity index. The index was calculated
for each census district in the 1990
census. The density of people using
shallow groundwater in each census
district was calculated by dividing
the number of shallow groundwater
drinkers by the surface area of the
district. The density of service sta-
tions in each census district was cal-
culated by dividing the number of
service stations by the surface area
of the district. An index of potential
vulnerability in each census district
was calculated by multiplying the
density of people drinking shallow
groundwater by the density of ser-
vice stations.
The distribution of potential
vulnerability is shown in Figure 3.
If the potential vulnerability of a
census district falls with the highest
-------
March 2011 • LUSTLine Bulletin 67
30 percent of all districts, the district
is colored in the figure. This shows
potentially greater vulnerabilities in
the midwestern, southeastern, and
eastern regions, particularly in urban
areas.
Potential Impact of
Climate Change
A second factor that could contrib-
ute to the impact of LUSTs on water
supplies is the potential impact of
climate change. The U.S. has been
experiencing drought conditions
and extreme precipitation events,
both of which contribute to changes
in hydrology. Under drought con-
ditions, municipalities that rely on
shallow groundwater may need
to pump at higher rates to deliver
adequate water supplies. These
increased pumping rates can create
conditions for contaminated plumes
to move farther or faster than they
would under normal conditions.
Alternatively, with extreme precipi-
tation events, groundwater recharge
from surface runoff can alter the
direction and flow rate of plumes.
Both of these extreme weather events
can change the vulnerability of water
supplies.
Type of Fuel
A third factor that may change
groundwater vulnerability is the
type of fuel being stored in USTs.
Laboratory and field studies in
recent years have indicated the
potential for ethanol to extend LUST
contaminant plumes. These longer
plumes increase potential impacts to
shallow groundwater drinking water
supplies.
Population Growth and Shifts
Fourth, population growth and
shifts, especially toward coastal
areas, will place additional bur-
dens on water demands. Outside of
Alaska, 53 percent of the U.S. popu-
lation lives in coastal counties that
account for only 17 percent of the
nation's land mass (Population Trends
Along the Coastal US, 1980 - 2008, U.S.
Department of Commerce). Conse-
quently, we need to have better tools
to provide information on water sup-
ply demands for communities with
longer temporal scales that are inte-
grated with the tools to assess where
USTs may create greater vulner-
Why Use 1990 Census Data
on Water Supply Sources?
WHY? Because no such questions were asked in the census questionnaires for either
2000 or 2010. The 1990 census was the last one that asked questions related to drinking
water sources:
Do you get water from:
D A public system such as a city water department or private company?
D An individual drilled well?
D An individual dug well?
D Some other source such as a spring, creek, river cistern, etc.?
So why, when water availability has become so increasingly problematic, have source water
questions been eliminated from the census? Why, when this information could have been
so useful and easy to obtain, was the subject deleted from the census? We don't know, but
it was.
FIGURE 3.
POTENTIAL VULNERABILITY
Density of people drinking shallow groundwater multiplied by the density of service stations.
ability and may require more timely
efforts to control contamination.
So How Are We Addressing
This?
The USEPA, U.S. Geological Survey,
and the Association of State and Ter-
ritorial Solid Waste Management
Officials are collaborating to develop
the needed data and decision sup-
port tools to assist communities in
managing impacts to groundwater
to protect drinking water supplies.
In evaluating the nation's shal-
low groundwater supplies, we as a
nation must be vigilant in identifying
and assessing the factors that con-
tribute to the vulnerability of these
supplies. We not only need to antici-
pate future water demands over the
next 5,10, and 20 years, we also need
to anticipate these demands in the
context of these vulnerabilities. •
Fran Kremer, Ph.D., is a Senior Science
Advisor and can be reached at kremer.
fran@epa.gov. John Wilson, Ph.D., is a
Senior Research Microbiologist and can
be reached at Wilson.johnt@epa.gov.
Jim Weaver, Ph.D. is a hydrologist and
can be reached at weaver.jim@epa.gov
All the authors are with U.S. Environ-
mental Protection Agency's Office of
Research and Development.
-------
LUSTLine Bulletin 67 • March 2011
A MESSAGE FROM CAROLYN HOSKINSON
Director, USEPA's Office of Underground Storage Tanks
Alas, Poor Groundwater
Those of us in the UST program have known for
years the importance of our work in relation to
groundwater. Considering that UST system leaks
are one of the leading sources of groundwater contami-
nation, the need to do all we can to protect this valuable
resource cannot be overstated. According to the Ground
Water Protection Council's Ground Water Report to the
Nation: A Call to Action (October 2007),
"Human activities have altered many landscapes,
changing the water balance and the physical,
chemical, and biological processes that control
water quality. Harmful substances have entered
groundwater by way of leaks, spills, seepage,
disposal, and burial. In the process, groundwater
has been degraded, placing an added strain
on limited water supplies."
And yes, groundwater has the
misfortune of having to share its
domain with things like tanks
that contain toxic substances.
This is significant, consider-
ing that groundwater is the
source of drinking water
for approximately half of all
Americans and 99 percent of
Americans in rural areas.
Ah, water! Our very exis-
tence depends on it. It is the
quintessential antique, when you
consider that the water available
to us here on planet Earth is the very
same water that has always been avail-
able to us and is the only water that will
ever be available to us. The water we drink could
contain the very same molecules that dinosaurs drank!
As they tell us in Water 101, water occurs on the
Earth's surface as liquid, ice, and gas. It covers three quar-
ters of Earth's surface. Water in the form of clouds masks
approximately one-half of Earth's surface at any time. Vol-
canic eruptions continually extract water and gases from
rocks deep within Earth's interior. That Earth is known as
the "water planet" is no fanciful notion.
Yet, only a very small portion of all this water is avail-
able to us for our daily water supply needs. And although
you've probably heard the following bits of water trivia many
times, they are worth repeating. Over 97 percent of Earth's
water is in oceans as salt water. Two percent of Earth's fresh
water is stored in glaciers, ice caps, and snowy mountain
ranges. Only the remaining 1 percent of Earth's fresh water
Oceans 97%
Glaciers 2%
is available to us for our
daily water supply needs.
It is stored in all kinds
of soils, cracks, and fis-
sures as groundwater, or
as surf ace water.
We use that 1 percent of fresh water for a variety of
purposes. Nationally, agricultural uses represent the larg-
est consumer of fresh water, about 42 percent. Approxi-
mately 39 percent of fresh water is used for producing
electricity; 11 percent is used in urban and rural homes,
offices, and hotels; and the remaining 8 percent is used in
manufacturing and mining activities.
In the United States, water has been for the most part
__ readily accessible (as simple as turning a fau-
cet) and inexpensive, so we assume our
water will always be available, plenti-
ful, and clean. But...people with
contaminated water understand
that is not necessarily so.
Lately we are hearing a
lot about "the water crisis."
Water is being referred to
as the twenty-first century's
"blue gold,"the resource that
will "determine the wealth of
nations." The lack of available
water is being felt in many
parts of the world, including
areas of our own country. Our
UST program's core priorities—
preventing releases and cleaning up
releases—are essential to protecting
groundwater, in this case, from UST system
releases. We have a responsibility to be part of the
water solution.
Prevention Is Fundamental
We know that preventing releases and ensuring that petro-
leum does not contaminate soil and groundwater in the
first place costs much less than cleaning up leaks after
they have polluted the environment. I'm pleased with the
UST program's confirmed releases trend over the last
20 years. We've seen a steady reduction in confirmed
releases from almost 67,000 in fiscal year 1990 to 6,328 in
fiscal year 2010. Inspecting UST facilities routinely, oper-
ating and maintaining existing equipment, and installing
required equipment has contributed greatly to this contin-
ued decline in the number of new UST releases reported
each year.
EARTH'S WATER
Fresh Water 1%
-------
March 2011 • LUSTLine Bulletin 67
MESSAGE FROM CAROLYN HOSKINSON continued from page 4
As of September 2010, there were approximately
597,000 federally regulated active USTs at approximately
215,000 sites across the United States. Inspections are
a good way to determine whether these USTs are being
operated and maintained properly and in compliance
with release prevention and leak detection requirements.
The 2005 Energy Policy Act provided us with a mandate
requiring on-site inspections every three years for all
active USTs. States and territories exerted considerable
effort to meet the initial three-year inspection requirement
of August 2010. And almost all successfully completed
the requirement by the deadline or soon thereafter, while
USEPA and our tribal partners conducted inspections at
nearly all UST sites in Indian country.
Looking ahead, the federal UST program is committed
to continuing improvements in preventing UST releases.
For example, in summer 2011 we intend to issue proposed
federal UST regulation revisions aimed at further reducing
UST releases. By August 2012, state and territorial UST
programs will need to ensure UST facility operators are
trained according to state-specific training requirements,
resulting in properly trained operators possessing the
knowledge to better operate and maintain their UST sys-
tems.
As the UST program continues to mature, we will
look to our UST partners for help in identifying future UST
release prevention opportunities that protect our ground-
water resources.
Cleanup Is Our Duty
Over the past 25 years, more than 401,000 cleanups have
been completed, approximately 12,000 of which were
completed in fiscal year 2010. Yet the annual number of
cleanups completed nationally has declined steadily since
fiscal year 2000.
Although the cleanup backlog—currently at 93,000—
is at its lowest level since 1992, we still need to aggres-
sively tackle the backlog and each year do our best to
achieve our cleanup goals. I realize some of the remaining
cleanups are those that are more complex and may require
lengthier cleanup processes because of complications.
To better understand the makeup of the backlog of
releases and why the pace of cleanups is slowing, USEPA
has been analyzing the backlog. In summer 2011, we
plan to issue results of our analysis and use them as the
groundwork for discussions with states and tribes and
other stakeholders to develop targeted backlog reduction
strategies.
The American Recovery and Reinvestment Act of
2009 gave our cleanup efforts a welcome one-time infu-
sion of money, which is helping to increase the number of
cleanups beyond those traditionally accomplished through
our annual appropriation. Recovery Act money has
funded site assessment and cleanup work at over 4,900
sites nationwide. To date, thanks to Recovery Act money,
approximately 830 assessments have been completed,
and nearly 800 sites have been cleaned to health-based
cleanup levels. Cleaning up these sites protects groundwa-
ter and restores contaminated land to conditions suitable
for future use.
We Will Continue to Be Part of the Solution
Together, we—states, tribes, local governments, industry,
and USEPA—have done a great job of protecting Ameri-
ca's precious groundwater resource. I thank each of you
for your dedication to the job, despite recurring struggles.
Going forward, we will need to identify new opportuni-
ties for protecting Earth's limited groundwater resources.
It's our responsibility to help ensure future generations of
Americans have ready access to clean, useable water. •
USEPA's FY2010
Annual Report Available
he FY 2010 Annual Report on the
I Underground Storage Tank Program
(EPA-510-R-11-001, March 2011)
provides a snapshot of national UST pro-
gram activities during fiscal year 2010.
This 8-page report contains information
regarding tank program highlights in
2010; advances in preventing releases;
progress in cleaning up leaks; an update
on the LUST Recovery Act; and a look
ahead for future years. The 2010 annual
report is available on USEPA's website at
www. epa.gooust/pubs/2010annrpt. htm
We Need to Hear Your Story
Here at LUSTLine, we try to keep our readers informed on what
is being done throughout the U.S. to protect groundwater from
LUST contamination. Of course we have a lot to say about UST
prevention and LUST cleanup, but what other measures are
being taken to keep USTs away from vulnerable water supplies?
We need to hear from you about any such efforts. For example,
one such effort was reported by Maine DEP's David McCaskill in
LUSTLine #41 (June 2002), "When It's Hard to Take 'No' for an
Answer—Maine's UST Siting Law Revisited." If you have a story,
we want to share it.
-------
LUSTLine Bulletin 67 • March 2011
Come on, Really...Can't We Do Better with the
Sources and Causes of Releases?
by Carol Eighmey
Six years have passed since Congress enacted new UST legislation as part of a larger bill called the "Energy
Policy Act" (EPAct). Oddly, the law did not impose any new requirements on owners or operators of USTs;
instead, it imposed several new requirements on the state agencies that implement our nation's UST program.
One of those requirements says, 'The [EPA].. .shall require each State that receives Federal funds... to maintain,
update at least annually, and make available to the public...a record... [T]he public record...shall include, for each
year.. .the number, sources and causes of underground storage tank releases in the State..." [italics added].
After this new federal law was passed, USEPA's Office of Underground Storage Tanks issued guidance to help
states understand what Congress wanted, and most state regulators dutifully began following that guidance. Spe-
cifically, USEPA's guidance on the "Public Record" requirement provides a sample chart that states can use to report
on the sources and causes of UST releases. USEPA required states to provide their first "Source and Cause" reports
no later than December 31, 2008, and annually thereafter.
What Is Leaking and Why?
Last year, I assembled the most
recent Source and Cause reports
from 47 states. (One state admit-
ted it had forgotten to prepare such
a report in 2009; two others did
not respond to requests for their
reports.) I then attempted to compile
the data from the 47 states to get a
national picture of what is leaking,
and why. The compiled data appear
in Table 1.
The results of this effort were less
informative than I had hoped. In fact,
readers may recall Tom Schruben
quoted me in the last issue of LUST-
Line (#66 - "Investigating Petroleum
UST-Equipment Problems...") say-
ing the data "present a largely mean-
ingless picture..."
This article will explain why I
reached that conclusion, and will
offer ideas on how we, as a commu-
nity of regulators, might improve
our data collection and reporting
procedures so that the annual reports
required by Congress are more infor-
mative. But first, please note a few
things about the data.
It would appear that 31 percent
of UST releases are from the tank
itself. But we all know that's not true.
When I queried some state regula-
tors who reported relatively high
numbers of "tank leaks," several
said that's the "catch-all" category
they use, for example, when an UST
system is removed and petroleum
is found in the soils of the tank pit.
This is borne out by the Cause data—
more than half of the supposed tank
leaks had an unknown cause.
In fact, of the 5,168 releases
reported on the states' Source and
Cause reports, less than one-third
had an identified source and cause.
In other words, two-thirds of the
time, we have incomplete informa-
tion on what leaked and why. Can
we do better? Here is some food for
thought.
Clarify What We Are
Reporting
In my conversations with other state
UST/LUST regulators, it quickly
became apparent that some state
annual reports on sources and causes
of releases contain only data on
"actual leaks" from federally regu-
lated USTs, which are (presumably)
operating with corrosion protection
and spill/overfill prevention equip-
ment. Other states include every
newly reported "release" in their
reports, even if the release is discov-
ered during a site assessment on a
property where no USTs have been
operated for 30 years or more.
This clearly means the states'
reports are a mixture of "apples and
oranges." Obviously this under-
mines any effort to analyze the com-
piled data.
USEPA's guidelines for Source
and Cause reports specify that states
must report on all releases that
"occurred" during the reporting
period. However, the guidelines also
specify that the number of releases
reported on the Source and Cause
report is to be the same as reported in
states' semi-annual activity reports.
Experienced bean counters will know
that the semi-annual activity reports
include releases that are "confirmed"
during the reporting period.
TABLE 1. COMPILED STATE SOURCE AND CAUSE DATA (2009)
CAUSE
SOURCE
Tank
Piping
Dispenser
STP
Delivery Problem
Other
Unknown
Totals
Total
#
1616
720
655
76
342
564
1195
5168
%
31.27%
13.93%
12.67%
1 .47%
6.62%
10.91%
23.12%
Spill
#
37
9
38
4
92
14
1
195
%
2.29%
1.25%
5.80%
5.26%
26.90%
2.48%
0.08%
3.77%
Overfill
#
59
6
31
2
121
6
21
246
%
3.65%
0.83%
4.73%
2.63%
35.38%
1.06%
1 .76%
4.76%
Phys/Mech
Damage
#
179
190
160
36
100
97
8
770
%
11.08%
26.39%
24.43%
47.37%
29.24%
17.20%
0.67%
14.90%
Corrosion
#
321
48
8
1
0
6
2
386
%
19.86%
6.67%
1.22%
1.32%
0.00%
1.06%
0.17%
7.47%
Install
Problem
#
9
25
9
5
1
4
1
54
%
0.56%
3.47%
1 .37%
6.58%
0.29%
0.71%
0.08%
1.04%
Other
#
157
43
49
9
14
171
23
466
%
9.72%
5.97%
7.48%
1 1 .84%
4.09%
30.32%
1.92%
9.02%
Unknown
#
854
399
360
19
14
266
1139
3051
%
52.85%
55.42%
54.96%
25.00%
4.09%
47.16%
95.31%
59.04%
-------
March 2011 • LUSTLine Bulletin 67
It is a well-known fact that when
a release "occurred" and when it was
"confirmed" may be two very dif-
ferent dates—years or even decades
apart. Clarification is needed on
exactly which releases are to be
included in state Source and Cause
reports. Perhaps the rules USEPA is
drafting to codify the EPAct's require-
ments will provide this clarification.
Decide Who Is Responsible
for Investigating the Source
and Cause of Leaks
It was also apparent from my proj-
ect that preparing the annual Source
and Cause report is viewed by many
state agencies as something they
have to do to keep USEPA happy,
not a task that has much relevance
to their daily responsibilities. At first
this was puzzling, since I personally
know many UST/LUST regulators
and find them to be a diligent and
thoughtful group of folks.
After reflection, it seems one rea-
son the Source and Cause report is
not viewed as a more important task
is that it falls into the crack between
UST and LUST responsibilities. In
the numerous states where UST
and LUST regulators are in different
agencies, this problem is particularly
acute.
UST regulators are focused on
compliance with UST technical and
operational requirements, so any-
thing that has to do with "releases"
seems outside their bailiwick. On the
other hand, LUST regulators view
their primary responsibility as ensur-
ing that someone properly cleans up
a release after it occurs—why it hap-
pened is of little interest.
I contend the Source and Cause
reports should be of primary inter-
est to UST regulators and whoever
is paying for cleanups. Both of those
parties have a vested interest in
knowing what is leaking so they can
a) focus their inspection, compliance,
and operator training efforts accord-
ingly, and b) reduce the number of
leaks that occur in the future, thereby
reducing costs.
Improve Our Investigative
Protocols
Another improvement we should
consider is how we might do a bet-
ter job investigating the source and
cause when an UST leak is reported
to us. The majority of states rely on
owners/operators, equipment com-
panies, or environmental consultants
to identify and report the source and
cause of releases. None of the three,
however, have any real incentive to
do any real investigation.
When he suspects he may be
losing fuel, the owner/operator
typically calls the same equipment
company that installed or recently
performed maintenance on the UST
system. If that company's personnel
were the ones who overtightened
something or installed a piece of
equipment poorly, how likely is it the
equipment company will volunteer
any meaningful information about
what leaked and why it leaked?
Similarly, the owner's primary
interest is getting the leak fixed
and getting back into operation as
quickly as possible. He has little
incentive to investigate or care why
his system sprang a leak.
The environmental consultant is
focused on the cleanup, and rightly
so. Who will pay for his or her time
to investigate the source and cause of
the leak?
So...what to do? As already
mentioned, someone first has to take
responsibility for the Source and
Cause investigation. Then that per-
son—and it will have to be a UST or
LUST regulator or Tank Fund Man-
ager—must figure out how, in today's
world of declining resources, to get a
sound investigation accomplished.
Recognizing the need for some
uniform procedures, ASTM has pub-
lished a new standard, E2733-10,
which was discussed in Tom Schru-
ben's article. One approach sug-
gested by Mr. Schruben is to require,
as part of installer or inspector train-
ing, that state-licensed UST install-
ers or inspectors be trained, then be
required to follow the procedures
outlined in E27330-10 when they
respond to a suspected release.
Another option might be for
state personnel who respond to envi-
ronmental emergencies to be simi-
larly trained and enlisted to report
Source and Cause information to the
UST regulator or tank fund manager.
Or, in some states, the tank fund may
have resources with which to engage
a trained investigator to go to the
UST site immediately after a release
is reported and conduct the investi-
gation.
Combine or Replace Activity
Reports with Source and
Cause Reports
I offer one final suggestion: USEPA
should consider how states' report-
ing responsibilities can be consoli-
dated so that the reporting burden
is minimized and the validity of the
data is improved.
When the data assembled from
47 state Source and Cause reports
was compared with the number of
confirmed releases, those same states
reported in their semiannual activ-
ity reports that a significant discrep-
ancy was apparent. There were 5,168
releases reported on the Source and
Cause reports; compared with 6,839
in the semiannual activity reports.
Even taking into consideration some
variation in the timing of the reports,
this seems too large a discrepancy.
Perhaps USEPA should consider
consolidating these two reporting
responsibilities, which should save
time for state regulators and improve
the accuracy and quality of the data.
Let's Do Better!
Congress clearly expressed its desire
to know whether our collective
regulatory efforts are reducing the
frequency of leaks, and what weak-
nesses in the regulatory system need
to be addressed to further reduce the
incidence of UST releases. We're now
into our fourth reporting cycle. If
you're the person who is required to
fill out this report annually, consider
how you can make it a more useful
endeavor. Have you talked to the
equipment companies in your state
to see whether they have records
that might shed some light on what
parts are "failing" most frequently?
(See Tank-nically Speaking on page
8.) Are there other personnel in
your agency, or in other state agen-
cies, who can share photographs or
field notes with you? Can the new
ASTM Standard be incorporated into
inspector or installer training?
In most states, the number of
actual leaks from operating UST
systems is not that large, so improv-
ing our investigations and reporting
shouldn't be an overwhelming chal-
lenge. Let's do it! •
Carol Eighmey is Executive Director of
the Missouri Petroleum Storage Tank
Insurance Fund. She can be reached at
pstif@sprintmail.com.
-------
LUSTLine Bulletin 67 • March 2011
-jnically Speaking
by Marcel Moreau
Marcel Moreau is a nationally
recognized petroleum storage specialist
whose column, Tank-nically Speaking,
is a regular feature o/LUSTLine.
As always, we welcome your comments
and questions. If there are technical
issues that you would like to have
Marcel discuss, let him know at
marcel.moreau@j uno.com.
Someday My
TQM £ USTs—A Marriage Made in Heaven
If you can remember acronyms
like "TQM," phrases like "con-
tinuous improvement," and
terms like "Deming management
method" and "franchise" in the
context of USTs and LUSTs, then
you qualify as an old-timer in
the world of tank regulation.
For all of you more youth-
ful LUSTLine readers, these
were all catchwords of
Ron Brand, the first direc-
tor of USEPA's Office of
Underground Storage
Tanks (OUST) and vision-
ary founder of the UST
regulatory program.
"TQM" stands for Total
Quality Management,
an approach taught by
W. Edwards Deming for
improving manufactur-
ing processes through
repetition of a series of
steps:
• Measurement of the status quo
• Implementation of small changes
• Comparing measurements from
before and after the change
to determine what has been
achieved
For example, if I were making
widgets, I would carefully measure
a sampling of my finished widgets
to see how closely they matched
the "perfect" widget I had set out to
make. I would measure dimensions
and weights, and do tests to see how
long my widgets would last. I would
also measure how long it took to
make my widgets, how much raw
material went into them, and how
many widgets I had to reject because
they didn't do whatever they were
8
supposed to do. Once I had my base-
line measurements, I would then
make changes. Ideally these changes
would come from ideas generated
by the workers who made the wid-
gets, because they were the ones who
knew best where the mistakes were
being made and how to improve the
process.
After implementing a change,
I would compare my pre-change
measurements to the post-change
measurements to see how much
the quality of the widgets had been
improved, or the time required to
make them had been reduced, or
how many fewer widgets were
rejected because of quality problems.
This is a process of endless measure-
ment of the entire widget-making
process, continually tweaking the
process in order to make improve-
ments, and tracking the resulting
effect on the finished widgets and/or
the widget-making process—always
with a goal of making better widgets
and making them faster and cheaper.
Nearly a quarter century has
passed since the tank rules were
finalized, and there is no question
that our UST systems are of a higher
quality (less prone to leak) than they
have ever been. That said, if I were to
try to quantify this "quality" of our
UST system population I would be
hard-pressed to come up with many
meaningful numbers. I can say with
some level of certainty that there were
597,333 tanks in active service last
year and that 1,748,204 tanks have
been closed since the USEPA regula-
tory program began. I can look up
-------
March 2011 • LUSTLine Bulletin 67
how many confirmed releases have
occurred each year over the last 22
years. I can count how many ongoing
cleanup operations we have (93,123)
and how many have been completed
(401,874). These numbers certainly
tell a story that tank owners and tank
regulators alike can be proud of. (Fig-
ures from USEPA's Semiannual Report
of UST Performance Measures End of
Fiscal year 2010; iviviv.epa.gov/oust/cat/
ca_10_12.pdf.)
But there is another statistic that
has a crimping effect on this happy
news: Last year, 6,328 new releases
were reported. And keep in mind,
this is only the number of releases
reported—we don't know about the
unreported releases. In the inter-
est of continuous improvement, the
ultimate goal of the tank program
should be to whittle down the num-
ber of new releases to zero. While I
can imagine a lot of heads nodding
affirmatively as they read this, there
is one big problem—we haven't got
a clue how to do this!
Doctor Doctor!
As Tom Schruben pointed out in his
LUSTLine #66 article "Investigating
Petroleum UST-Equipment Prob-
lems...," and Carol Eighmey has
been preaching from her soapbox
for quite a while now (see her article
on page 6), we don't know what's
wrong with our UST systems, and if
we don't know what's wrong, how
are we ever going to fix them?
The fundamental tenet of TQM
is that you measure your product or
your process continually so you can
see where you are and plot a course
to where you want to be. It seems to
me that to establish where we are in
the UST-release world, we should
have a firm grip on statistics like:
• How many new releases did
we actually have last year? As
Eighmey points out in her arti-
cle, we don't know whether the
"new" releases reported last year
are in fact releases from new
storage systems or whether they
are newly discovered releases
from old storage systems.
• How many leaks did each
method of leak detection actu-
ally detect last year? For exam-
ple, how many tank leaks were
discovered by ATG monthly
tests? How many piping leaks
were discovered by line-leak
detectors? How many leaks were
discovered using secondary con-
tainment? And just as important,
how many leaks were missed by
each of these methods of leak
detection?
• How many delivery spills hap-
pened last year, and how many
spill buckets are leaking? Are
our methods of preventing and
containing delivery spills actu-
ally working?
• What UST components are fail-
ing, how often do they fail, and
why do they fail? Although the
generally accepted wisdom
today is that most leaks are asso-
ciated with the piping, that is not
what the current national statis-
tics say (see Eighmey's article).
So where does the truth lie?
While I'd wager that any group
of UST owners or installers or regu-
lators could sit around a table with
a pitcher or two of beer and have a
very lively discussion on any of these
issues, none of us could pull out a
chart or a table with hard numbers
to answer any of these questions. In
an era of limited resources, how do
you know which problem to tackle
when you don't know which problem
causes the most frequent and/ or most
severe leaks? And how do you know
whether whatever it is you change is
working if you don't continuously
measure the effect of the change?
We've Been Here Before
Back in the 1980s, when Ron Brand
and a team of OUST folks and state
regulators were structuring the regu-
latory program we have today, they
faced a similar problem. They knew
there were lots of things wrong
with UST systems, but they wanted
to know what the biggest problems
were and how best to tackle them.
Back then, there were very few UST
regulators, so the idea of gathering
national statistics using regulatory
personnel was not feasible.
But the OUST program did have
a budget, so they commissioned var-
ious studies. They sent consultants
out to review state leak files. They
interviewed Petroleum Equipment
Institute (PEI) contractors. They got
statistics from testing companies that
had conducted thousands of tight-
ness tests. Eventually, all of these
data were consolidated into a "Cause
of Release" study. Though nearly a
quarter century old, the findings of
this study are still worth reviewing.
Among the major points made:
• While the historical problem had
largely been caused by corro-
sion of bare steel tanks, the study
recognized that this particular
problem (except for internal cor-
rosion of steel tanks) had largely
been solved.
• The big remaining problem was
the piping, because although
piping materials had been
improved (fiberglass had largely
replaced galvanized steel) there
was still an issue of quality con-
trol (good workmanship) in
installing the piping under field
conditions.
• Pressurized pumping systems
were particularly prone to large
releases.
• Delivery releases were very com-
mon.
• "Nonoperational" leaks (e.g.,
loose tank-top bungs, loosely
screwed-together vent lines)
were very common. (In later
years these would come to be
known as "vapor leaks," and
they came to have great signifi-
cance while MtBE was present in
our gasoline.
In short, back in the 1980s we
got a pretty good qualitative (and
sometimes quantitative) handle on
the problems by consulting with the
people out in the field actually doing
the work!
Who Is in Touch with the
Cold, Hard Facts?
It is my belief that in trying to get
regulators to gather UST system fail-
ure statistics, we are trying to pound
square pegs into round holes. As a
group, regulators lack the funding,
the time, the motivation, and the
knowledge to conduct tank autop-
sies. I would note that it can be done,
as shown by the statistics gathered
in Florida during Marshall Mott-
Smith's tenure as administrator of
the Florida UST program, but this
effort required a substantial com-
mitment of resources and a regula-
tory structure and discipline that is
lacking in most states.
• continued on page 10
-------
LUSTLine Bulletin 67 • March 2011
m TQM and USTs/rom page 9
If we really want to understand
what's going wrong with our UST
systems, we should look at history.
We need to look back to the late
1970s, when, under the auspices of
the American Petroleum Institute
(API), storage system failure data
were gathered (primarily by PEI
members). While the data were not
perfect, they did show conclusively
that corrosion was the biggest issue
with steel tanks. Likewise USEPA's
Cause of Release study gave us infor-
mation that helped put the national
UST program on sound footing. In
short, we should look to the people
doing the work in the field—the
installers, testers, and maintenance
folks who are out there every day,
responding to alarms, discover-
ing, and repairing leaks—for the
answers.
We can get some tantalizing
clues about what is going on in the
UST world because, in this com-
puter age, we have huge databases
that can be mined for information.
These include those of large-scale
tightness-testing companies like
Crompco that maintain databases of
their test results, and remote moni-
toring services like Gilbarco's Fuel
Management Service that record tens
of thousands of alarms.
Just to see if this approach is
worthwhile, I've been working with
Ed Kubinsky of Crompco to get a
peek at what their testing statistics
can tell us. Just looking at some of the
"big picture" numbers that Ed was
able to generate quite rapidly gives
us some interesting information. For
example, a ranking of what types of
equipment fail the most frequently
(Figure 1) tells us that our secondary
containment systems are in trouble
because they have, by far, the high-
est failure rates of any storage system
component that Crompco tests.
This is somewhat disconcerting
because as a result of the 2005 Energy
Act, we as a nation are headed in the
direction of adopting secondary con-
tainment. The clear message is that if
we do not address the liquid-tight-
ness of secondary containment, our
chosen method of leak detection will
turn out to be less than satisfactory
in detecting and preventing releases.
The bottom line is that periodic test-
ing of the integrity of secondary con-
10
FIGURE 1. FAILURE RANKING OF UST COMPONENTS
(Based on 2004 through 2010 Crompco data)
fi
y
y y
FIGURE 2.
SPILL BUCKET FAILURE RATE
(Based on 2004 through 2010 Crompco data)
tainment is going to be key to the
success of secondary containment.
What this graph does not show is
exactly how these containment sys-
tems are failing. That would require
a more labor-intensive review of the
tester's notes for each failed test, but
such a review might be a crucial step
in figuring out how to design more
reliable containment systems for the
future.
Looking at trends over time, we
can see that spill buckets, for exam-
ple, are showing marked improve-
ment (Figure 2). Keep in mind,
however, that this improvement is
being seen only in spill buckets that
are being tested periodically. States
where periodic spill-bucket test-
ing is not the rule should be looking
at the early years of the data in this
graph and realizing that they have a
substantial problem with leaky spill
buckets that will only grow worse
over time.
As with any data set, the limita-
tions of the data have to be under-
stood. For example, Figure 1 tells us
that steel tanks have a higher failure
rate than fiberglass tanks but that
fiberglass tanks, even double-walled
tanks, fail tightness tests as well. We
have to keep in mind that these data
• continued on page 23
-------
March 2011 • LUSTLine Bulletin 67
The Fuel Quality and Tank Design Disconnect
by Paul Nazzaro
Whether buried underground, positioned above ground, or exposed in a basement, fuel-storage tanks have kept millions of
cars and trucks, as well as businesses, industry, aircraft, homes, and the like adequately supplied with gasoline, diesel
fuel, aviation fuel, and home heating oil for as long as distillate fuels have needed some form of bulk storage. Generally,
the consumer rarely notices these tanks, nor does the consumer think about how fuel quality could be impacted by factors such as
fuel quality and tank design.
Over the past few years, a great deal of attention has been given to what appears to be an increase in premature filter plugging
and corrosion activity in the underground storage tank (UST) systems across the country, which can affect every type of distillate
fuel. Given my 30 years of experience storing, blending, and shipping fuel, not much surprises me when the phone rings and a
concerned fleet manager begins to share his story of an early-morning filter-plugging problem that's causing him to experience his
worst nightmare—costly downtime.
The Petroleum Supply Chain
To appreciate what could be happen-
ing to these fuel-storage systems we
need to understand how the petro-
leum supply chain functions and
how quality standards are used to
maintain fuel quality while the fuel
type is "in commerce" from the point
of manufacture to the point of sale.
It is interesting to contrast
fuel-quality management practices
between the aviation industry and
the pleasure-craft industry. In the
case of the former, the airline indus-
try worldwide has invested millions
of dollars and hundreds of thou-
sands of hours to develop a fuel-
management program that ensures
that jet fuel maintains stringent fuel-
quality standards by filtering and
dewatering it every step along the
distribution network. From produc-
tion, transport, and storage to fueling
the aircraft, industry practices ensure
and maintain optimum fuel quality,
resulting in reliable aircraft operation
and, in turn, passenger safety during
flight.
In stark contrast to the aviation
industry is the marine retail market,
selling diesel fuel, gasoline, and E10.
These fuel-storage tanks are typi-
cally near a body of water, subjected
to diurnal temperature fluctuation,
and in humid conditions. Over time,
these elements lead to the formation
of sediment and bottom water that
remain with the stored fuel until the
tank is physically cleaned and dewa-
tered.
The situation with middle-
distillate fuel used in home heating
oil lies between these two extremes.
Even though the industry is com-
mitted to maintaining fuel within
specification while in commerce,
fuel-handling, storage, and mainte-
nance practices may be much less
rigorous before the fuel reaches the
consumer.
Fuel Quality—the Big Picture
For decades the world energy mar-
kets have been chaotic, to say the
least. With recent downturns in the
world economy and uncertainty
about how it will all play out, the
demand for energy and the near-
term future of that market have been
significantly impacted.
Projections provided in the U.S.
Energy Information Administra-
tion's Annual Energy Outlook 2009
look beyond current economic and
financial woes and focus on factors
that drive the U.S. energy markets
and their impact on energy invest-
ment decisions in the long term.
These factors include the growing
and uncertain global crude oil prices,
improving domestic air quality and
reducing greenhouse gases (GHG),
the need to increase renewable fuels
inventories, the increasing produc-
tion of unconventional natural gas,
the move from inefficient to more
efficient engines, and improved effi-
ciency in end-use appliances.
If anything is different in 2011,
it is that the 2009 report is on track
for advancing the original agenda—
today's fuels need to be cleaner,
more efficient, and sustainable to
survive in the energy marketplace of
the twenty-first century.
What Contributes to Fuel-
Quality Degradation?
The road to fuel-quality degrada-
tion begins with the process in which
crude oil is transformed into the fin-
ished petroleum products. Refiners
are driven to maximize each barrel
of crude oil. Their objective is to opti-
mize technology in order to produce
as much high-value product per bar-
rel of crude that enters the refinery as
they can.
Through several distinct pro-
cesses—distillation, cracking,
reforming, blending, and treating—
refiners convert barrels of crude oil
into higher-value products such as
gasoline, diesel fuel, jet fuel, and
home heating oil. Once the products
exit the refinery, they are transported
through a network of pipelines,
barges, ships, and rail cars to their
final destination.
During the various transfers, the
fuels are subjected to the ravages of
time, temperatures, and organic and
inorganic contaminants, all of which
can potentially compromise their
future performance and the storage
systems in which they will be held
until they are sold to the general
public. From the time the fuels are
produced to the time they reach the
downstream marketplace, they are in
the process of degrading (the initial
point of recognized fuel instability).
When a fuel product arrives at a
regional petroleum deep-water pipe-
line or a break-out terminal strategi-
cally located in the United States, it
is then redistributed to a local dis-
tribution zone and placed in a large
storage tank with other products,
all of which must coexist by way of
"like" fuels (i.e., fuels that meet their
respective American Society for Test-
ing and Materials (ASTM) specifica-
tions).
• continued on page 12
11
-------
LUSTLine Bulletin 67 • March 2011
m Fuel Quality/Tank Design
from page 11
For example, ASTM D975 bench-
marks standards for diesel fuels,
ASTM D396 benchmarks standards
for home heating oil, and ASTM
D6751 benchmarks standards for
B100 biodiesel. Subsequent desig-
nations for biodiesel blends (i.e.,
B6-B20), must conform to their
respective benchmark specifications.
Biodiesel blends of up to 5 percent
biodiesel (B5) in either diesel or heat-
ing oil fall under core diesel and
heating oil specifications—D975 and
D396, respectively. Biodiesel blends
that range between B6 and B20 per-
cent are governed under ASTM
D7467.
During the period of time before
a product is sold to the consumer for
use as a transportation fuel or heat-
ing fuel, the custodian of these fuels
may blend other products into the
fuel stream to optimize both supply
and economics. These blend stocks
may be light-cycle oil (LCO), Russian
Gas Oil (RGO), or even various types
of biodiesel; all of these blends must
continue to meet their respective
specifications.
In the end, millions of gallons of
fuel products produced at home or
abroad are transported daily through
thousands of miles of a "fungible"
product network in order to arrive
to the end user (Figure 1). Imagine,
in the absence of a minimum fuel-
quality standard throughout the stor-
age and distribution network, these
fuels could initiate and contribute
to fuel-product degradation during
transport, ultimately affecting the
integrity and performance of the fuel
product and fuel-storage systems.
Can It Get Worse?
In addition to the physical aspects
associated with fuel quality and
fuel storage, fuel dealers must also
address growing negative percep-
tions on the part of consumers
regarding fuels, price fluctuations of
their respective fuel products, and
attacks from market competition
anxious to take their rightful place in
the twenty-first-century energy mar-
ket by offering an alternative energy
solution to the long-term traditional
fuel market. The very issues that
bulk-storage-system professionals
are trying to grapple with and under-
12
FIGURE 1. DOWNSTREAM PETROLEUM SECTOR REVIEW
M
Down* Era-inn
P*!ral»um 5*
~ ill!
t
Courtesy Measurement Canada (http://www.ic.gc.ca/eic/site/mc-mc.nsf/eng/lm00252.html)
stand—unexplained increases in dis-
penser filter plugging, premature
tank failure, corrosion, and microbial
events—can also be reflected in the
local home heating oil dealers who
are fighting for their economic sur-
vival in the face of the natural gas
industry's effort to devour every last
oil heat customer.
The reason home heating oil
dealers are looking at a mind-
numbing market contraction is
primarily due to their inability to
control what is happening inside
the homeowner's 275-gallon home
heating oil tank. For example, large
aboveground storage tanks (1,000
- 20,000 in capacity) typically have
built-in man ways on the side of the
tank that allow access to the tank
interior for inspection and cleaning.
Contrast this to the typical home
heating oil tank, which is sealed and
virtually inaccessible to the removal
of any degraded fuel product, water,
or microbial contamination that has
accumulated inside. After decades
of accumulation, fuel-degradation
product, water, and microbes at
the bottom of these home heating
oil tanks are roiled each time fuel is
delivered, which ultimately leads to
plugged fuel lines, filters, strainers,
and worse, degraded burner nozzle
performance.
Taking on the Challenges
So what can we do to make a bet-
ter product? Many industry observ-
ers understand that to compete
with cleaner-burning technologies,
government intervention is needed
to help reduce the environmental
impacts of available fuels by way of
establishing legislation/mandates/
incentives to use low-sulfur fuel
and/or renewable fuel. The liquid-
fuel industry will have to transition
to selling lower-sulfur fuels, consider
blending biodiesel into middle distil-
lates, and, if they wish to truly com-
pete, begin paying attention to what
they are buying and find ways to
protect the fuel prior to sale.
The big question on the minds
of many marketers at the moment is:
How will ultra-low-sulfur heating
oil (ULSHO) impact the industry's
challenges associated with heating
oil systems? For example, the high
levels of hydro treatment required
to make ULSHO will have a signifi-
cant impact on many chemical and
physical properties of the fuel. These
changes can subsequently affect field
performance and result in end-user
problems. Currently there is very lit-
tle true ULSHO in the field; however,
one should be able to anticipate the
impact of potential changes based
on experiences with ultra-low-sulfur
diesel (ULSD) fuel.
-------
March 2011 • LUSTLine Bulletin 67
There have been a great number
of industry discussions regarding
ULSD 's potential role in causing cor-
rosive activity and hardware failure
in fuel dispensers. Industry lead-
ers were quick to address these iso-
lated incidents and formed a task
force to explore the problem. To date,
there have been no findings that
clearly indicate cause and effect of
those reported incidences. But one
question remains: Should the oil-
heat industry be concerned about
ULSHO?
Our team of fuel blenders, man-
ufacturers, and components devel-
opers have had discussions and
pulled together several parameters
that will change the fuel chemistries
and the net effect downstream in
both vehicles and tanks.
Fuel Stability
One of the major contributors to a
customer's fuel-related, "no-heat
call" has been degradation material
derived from unstable fuels. This
situation occurs because the fuel
itself contains material that readily
degrades under the right circum-
stances. These degradation materi-
als form particles and sludge that
can plug filters, lines, and burner
nozzles. Preventing fuel degradation
is key to eliminating fuel-related,
no-heat calls and goes a long way
in extending the life-expectancy of a
fuel storage tank.
For example, as a result of the
desulphurization process for making
ULSHO fuels, many of the potential
degradation precursors are trans-
formed to materials that are insensi-
tive to traditional storage (oxidative)
degradation. Thus sludge produc-
tion is expected to be negligible (and
great for the consumer, fuel mer-
chant, and tank environment).
It is rare, however, that changes
in the processing of fuel result in one
simple phenomenon. It is well docu-
mented that heavily hydro-processed
fuels readily generate aggressive free
radicals that can form peroxides in
the fuel. Upon achieving certain min-
imum levels, these peroxides easily
attack and degrade fuel-system elas-
tomeric seals and gaskets.
The same peroxides can initi-
ate the premature degradation of
biodiesel/heating oil blends, result-
ing in fuel instability, high acid con-
tent, and sludge formation. ULSHO,
again by nature of desulphurization,
does not have the natural peroxide
inhibitors that would protect the
consumer and tank from this phe-
nomenon. Fortunately, properly for-
mulated additives focus on this new
problem and can protect against per-
oxide formation.
• Existing Sludge/ULSHO
Solvency
The absence of newly formed deg-
radation material should not imply
that existing sludge will not be prob-
lematic. Both heating oil systems and
diesel-fuel storage systems that have
not been proactively protected may
have years of built-up sludge. This
buildup occurs over a long period of
time and reaches a state of equilib-
rium. Part of this phenomenon is due
to the solvency effect of high-sulfur
fuels. The solvency of ULSHO can be
markedly different from high-sulfur
diesel or low-sulfur diesel, and may
have a negative impact in mobiliz-
ing sludge. Agitation during the fill
process and change in solvency may
cause sludge to be "sloughed off"
and can result in filter and strainer
plugging and negatively impact noz-
zle and injector performance.
A mild dispersant may effec-
tively control the rate and size of
sludge particle removal. Disper-
sants function to gradually mobilize
sludge and to keep sludge particles
at a microscopic and filterable size so
as not to have a detrimental impact
on the fuel-delivery system. Many
premium diesel and heating oil pack-
ages currently marketed by oil com-
panies contain these components to
aid the fuel dealer by way of offering
a higher-quality product.
Corrosion
As mentioned earlier, the petroleum
industry is currently trying to deter-
mine the reasons why corrosion
problems have increased so rapidly
over the past few years. Multiple
technical associations have formed
groups to study the root cause and
determine the appropriate path for-
ward. It is only logical to assume that
ULSHO, being made and handled in
the same manner as ULSD, may have
similar problems.
Some have postulated that it is
the overuse of corrosion inhibitor
additives in the fuel that is poten-
tially causing the corrosion problem.
However, others postulate that it
may not be the presence of the cor-
rosion inhibitor additive that is caus-
ing the corrosion but rather the lack
of the corrosion inhibitor additive in
the bulk fuel.
Specifically, corrosion inhibitors
work by binding to bare metal sur-
faces to protect them from attack by
corrosive contaminants. However,
freely available metal contaminants
in the bulk fuel can preferentially
bind to molecules of the corrosion
inhibitor while it is in the bulk fuel,
forming what is termed as a "soap."
By definition, the process of
forming soaps results in remov-
ing the corrosion inhibitor from the
fuel and, as a result, removes abil-
ity of the corrosion inhibitor to pro-
vide protection to the metal surface.
Keep in mind that the soaps would
not have formed if it were not for
the trace contaminants that some
feel should not be in fuel in the
first place. Regardless, the fuel will
most likely need to be treated (with
a properly formulated additive) to
provide corrosion protection for the
entire fuel-handling system, includ-
ing the storage tanks.
• Microbial Issues
The growth of microorganisms in
middle-distillate fuels is nothing
new. What is new is their potential
new home. ULSHO will, like ULSD,
have numerous changes in chemical
composition due to desulfurization.
The changes in fuel composition may
directly impact chemistries that were
responsible for inhibiting growth of
certain microorganisms. This is not
unlike a weakened immune system
that is vulnerable to infection.
Microbes will consume fuel for
energy and growth while generat-
ing sludge and short-chain acids as
by-products of their metabolic pro-
cesses. These short-chain acids can
cause not only corrosion problems
in the tank (wetted surface) but, due
to their volatility, they can also cause
corrosion on metallic surfaces above
the level of the fuel. ULSHO has
no defense against these corrosion
issues and may offer a more favor-
able environment for this to occur.
In a nutshell, microbial con-
tamination can be minimized if tank
owners establish and implement
a proactive review of their storage
• continued on page 23
13
-------
LUSTLine Bulletin 67 • March 2011
BIOFUELS Happenings
Oak Ridge National Lab Study Weighs in on Compatibility of
Intermediate Ethanol Blends and the Fueling Infrastructure
A key provision of the Energy Independence
and Security Act (EISA) of 2007 is the Renew-
able Fuel Standard (RFS), which requires the
nation to use 36 billion gallons of renewable fuel in
vehicles by 2022. Ethanol is the most widely used
renewable fuel, and a significant portion of the 36-
billion-gallon goal can be achieved by increasing
the ethanol in gasoline to 15 percent. In March 2009,
Growth Energy (a coalition of ethanol producers
and supporters) requested a waiver from USEPA to
allow the use of 15 percent ethanol in gasoline. This
waiver has now been partially granted for car and
light truck model years 2001 to the present.
In anticipation of the E15 waiver being granted,
uncertainties arose as to whether additional fuel
ethanol, such as E15 and E20, would be compatible
with legacy and current materials used in standard
gasoline-fueling hardware. The U.S. Department
of Energy (DOE) recognized the need to assess the
impact of intermediate blends of ethanol on the
automotive fueling infrastructure. This research
effort was led by the Oak Ridge National Laboratory
(ORNL) and the National Renewable Energy Laboratory
(NREL) in collaboration with Underwriters Laboratories.
In LUSTLine #66, we reported on the result of the
NREL study Dispensing Equipment Testing with Mid-Level
Lthanol/Gasoline Test Fluid. At the same time, ORNL was
leading the effort to evaluate the impact of intermediate
blends of ethanol on a large number of materials (i.e.,
metals, elastomers, plastics, sealants) representing those
typically used in dispenser infrastructure. The results of
these studies are now available in the report, Intermediate
Ethanol Blends Infrastructure Materials Compatibility Study:
Elastomers, Metals, and Sealants (http://info.ornl.gov/'sites/
publicationslfileslPub27766.pdf). Additional work is under
way at ORNL, and additional interpretation of the com-
bined data from ORNL, NREL, and UL is expected in the
near future.
What Was Evaluated?
According to the report Executive Summary, material
selection was based on a thorough investigation of dis-
penser materials by the ORNL materials research team.
Team members contacted dispenser component and
elastomer /seal manufacturers and received input from
stakeholders, including UL, the Petroleum Equipment
Institute (PEI), and the API members. The broad mate-
rial classes that were identified for use in gasoline fuel
dispensers include metals, elastomers, plastics, and seal-
ants. ORNL tested for the metals, elastomers, and seal-
ants only. During the time this report was being written,
the plastic specimens were still undergoing compatibil-
ity exposures. A follow-up report discussing the plastic
results will be issued upon completion of that portion of
the study.
14
Flexible connector
(SS. fluorocarbon. N8R)
Emergency Shear Valve
Protector (Iron, steel, brass. SS.
Teflon, polyurothanaj
Flowlimiter |AI, stiN.-l|
Breakaway ralvff (nylon.
HOPE, fluorocarbon, NBR.
fluorotilieone)
Nozi to (Nylon. Al,
fluorocarbon, Silieono rubbar,
NBR, (luorosilicuni.-, HDPE|
Swivel (SS. fluorocarbon.
NBR)
Ho»e (N8R)
Piping (nylon, PVOF, PPS,
PK|
Emrric'or fining (Iron,
, Zn alloy)
Ball float wnl valve
[Me*). SSI
Vapor Line Shear Vulva
(Iron, MuDrocarbon.
polyurethano)
Schematic showing dispenser materials and components from the UST to the
nozzle. (http://info.ornl.gov/sites/publications/files/Pub27766.pdf)
In this study, four test fuels were used to evaluate
material compatibility. These formulations are based on
test fuels described in SAE J1681, Gasoline, Alcohol, and
Diesel Fuel Surrogates for Materials Testing. The fuel types
used were Fuel C, CElOa, CE17a, and CE25a. Fuel C is a
50-50 mixture of toluene and isooctane and is representa-
tive of highly aromatic gasoline (>40% aromatics by vol-
ume). In order to simulate long-term exposure, the other
test fuels contain a slightly soured, or "aggressive" ethanol
solution added to Fuel C. See the study for the details.
Results in a Nutshell
• Metals
The study observed very little corrosion of any of the
metallic coupons from exposure to Fuels C, CElOa,
CE17a, or CE25a. Coupons exposed to the vapor phase
above each solution exhibited slight discoloration in
some cases (particularly the brass and bronze coupons),
but no loss of mass was observed for any of the metals
exposed in the vapor regions. In short, metals did not
appear to be a problem.
• Elastomers
All of the elastomer specimens that were exposed to the
test fuels (including Fuel C) exhibited some level of vol-
ume swell. Ethanol was found to further increase the vol-
ume swell and produce softening. The level of swell is an
indication of solubility, and for most elastomers tested,
the highest level of swell occurred with either the CElOa
or CE17a (not CE25a). This result suggests that the high-
est level of mutual solubility for elastomers occurs at
relatively low levels of added ethanol. After drying for
20 hours at 60°C, all of the samples, except the fluorocar-
bons, exhibited some level of shrinkage and mass loss. The
details for elastomers are further refined in the report.
-------
March 2011 • LUSTLine Bulletin 67
• Sealants
The results show that the standard sealant passed the
ASTM D6396 criteria in Fuel C but did not pass following
exposure to either CElOa or CE25a. However, when stan-
dard sealant was combined with Teflon tape, leaking did
not occur. The results also show that the ethanol-resistant
sealant product passed when tested with both CElOa and
CE25a. Hence the standard sealants may not be compat-
ible without the additional sealing provided by Teflon
tape. The ethanol-resistant sealant product was success-
ful at preventing leakage in CE25a according to the ASTM
standard.
As noted in the report, the results of this study will be
used to assist with the design and selection of materials to
be used in future dispensers, possibly including retrofits.
The experimental analysis of the plastic specimens will
conclude this test series, and a final report summarizing
these conclusions will be forthcoming.
USEPA Grants E15 Fuel
Waiver for Model Year 2001 -
2006 Cars and Light Trucks
In January, USEPA partially waived its limitation on
selling gasoline that contains more than 10 percent
ethanol for model year (MY) 2001 through 2006 pas-
senger vehicles, including cars, SUVs, and light pickup
trucks. The waiver applies to fuel that contains up to 15
percent ethanol—known as E15. The decision was made
following a review of testing performed by the Depart-
ment of Energy and other available data on the effect of
E15 emissions from MY 2001 through 2006 cars and light
trucks. Possible effects of E15 on the fuel storage infra-
structure cannot legally be considered as a part of the
waiver decision.
In October 2010, USEPA approved a waiver allow-
ing the use of E15 for MY 2007 and newer cars and light
trucks. At that time, USEPA denied a request to allow the
use of E15 for MY 2000 and older vehicles and postponed
its decision on the use of E15 in MY 2001 to 2006 cars and
light trucks until DOE completed additional testing for
those model years.
The Agency also announced that no waiver is being
granted this year for E15 use in any motorcycles, heavy-
duty vehicles, or non-road engines because current test-
ing data does not support such a waiver. These waivers
represent one of a number of actions that are needed from
federal, state, and industry to commercialize E15 gasoline
blends.
USEPA is also developing requirements to ensure that
E15 is properly labeled at the gas pump. The label will be
designed to prevent refueling into vehicles, engines, and
equipment not currently approved for the higher ethanol
blend. The Agency continues to review public comments
for an E15 pump label to help ensure consumers use the
correct fuel
Ethanol is an alcohol that can be mixed with gasoline
to result in a cleaner-burning fuel. E15 is a blend of 15 per-
cent ethanol and 85 percent gasoline. The primary source
of ethanol is corn, but other grains or biomass sources,
such as corncobs, cornstalks, and switchgrass, may be
used. The Energy Independence and Security Act of 2007
mandated an increase in the overall volume of renewable
fuels into the marketplace, reaching a 36-billion-gallon
total in 2022.
Ethanol is considered a renewable fuel because it is
produced from plant products or wastes and not from
fossil fuels. Ethanol is blended with gasoline for use
in most areas across the country. USEPA granted the
waiver after considering the March 2009 E15 petition sub-
mitted by Growth Energy and 54 ethanol manufacturers.
In April 2009, the Agency sought public comment on the
petition and received about 78,000 comments.
The petition was submitted under a Clean Air Act
provision that allows USEPA to waive the act's prohi-
bition against the sale of a significantly altered fuel if
the petitioner shows that the new fuel will not cause or
contribute to the failure of engine and other emission-
related parts that ensure compliance with emission stan-
dards. For more information, go to: http://iviviv.epa.gov/
otaq/regs/fuels/additive/el5/
UL Retracts Position on E15
Dispensers
In February 2009, Underwriters Laboratories (UL)
issued a statement which said "[UL]...announced
today that it supports Authorities Having Jurisdiction
(AHJs) who decide to permit legacy system dispensers,
listed to UL 87 and currently installed in the market, to
be used with fuel blends containing a maximum ethanol
content of 15 percent." In December 2010, however, UL
went back to its earlier position on E15 dispensers, saying
that "in light of recent research published by the Depart-
ment of Energy (DOE) and the National Renewable
Energy Laboratory (NREL)," UL is confirming its previ-
ous position regarding the use of existing dispensing sys-
tems with greater than E10 ethanol blends.
UL now reasserts, "fuel dispensers certified under UL
Standard 87 are certified for use with gasoline and etha-
nol blends up to El 0 at a maximum. Research has shown
that there are some issues with legacy equipment exposed
to higher ethanol fuel blends. Of particular concern is
the degradation of gaskets, seals, and hoses, which can
occur when these elastomers are exposed to greater than
E10 ethanol blends. Breakdown of these components can
cause leaks."
In short, UL says, "In situations where E15 is to be
dispensed, UL recommends the use of new, listed equip-
ment designed and identified for use with mid-level
blends. There are currently dispensing units on the mar-
ket listed for use with blends up to E25 under UL Stan-
dard UL 87A-E25.
It notes that "determinations of fuel compatibility
and warranty are made only by the manufacturer and
users with questions about the compatibility of their
pump should contact the manufacturer." http://iviviv.ul.
com/global/eng/pages/offerings/industries/energy/alternative/
flammableandcombustiblefluids/updates •
15
-------
LUSTLine Bulletin 67 • March 2011
by W. David McCaskill
David McCaskill is a Senior Environmental Engineer with the Maine
Department of Environmental Protection (MEDEP). "Tanks Down East"
is an irregular feature ofLUSTLme. David can be reached at
David.Mccaskill@maine.gov. As always, we welcome your comments.
Kittery to Fort Kent
fin fifififi Pilgrimage Across Maine and the Lessons Learned
The State of Maine is big enough to swallow up the five other New England states. (I know that doesn't mean much to many other
states, especially those big western ones, but in New England, it's something to crow about.) So when given $1.4 million of Ameri-
can Recovery and Reinvestment Act (ARRA) monies to spend on UST/EUST work, those of us at the Maine Department of Envi-
ronmental Protection (MEDEP) had to give careful thought to how we would best use this money throughout our vast state.
When we describe the length of our state we often use the phrase "Kittery to Fort Kent" (hence the title of this article). Kittery is
one of our two big retail "outlet" towns. You'll find it at the southernmost end of the state, just after you cross the Piscataqua River,
which separates Maine from its only U.S. neighbor, New Hampshire. Fort Kent is up in the northernmost Aroostook County, a small
farming and community college town a stone's throw across the St. John River from the Canadian province of New Brunswick.
The truth is, we ended up selecting ARRA LIST/LUST sites that covered the length and breadth of the state, except that we
started in Elliot, which is just across 1-95 from Kittery, and up north in the Crown of Maine we worked in the town of Grande Isle,
just east and slightly up from Fort Kent. To stretch the projects out sideways we worked in the logging town of Patten on the western
flank of the mile-high Mount Katahdin and across 'til our feet got wet in the lobster fishing port ofjonesport on the ragged edge of
the sunrise County of Washington.
In this edition of "Tanks Downeast" I'm going to tell the tale oftheMEDEP's ARRA pilgrimage up, down, and over Maine, the
problems encountered, and the lessons learned.
The Strategy
Our site selection strategy was
simple (or so we thought) and in
keeping with our grand plan for
this endeavor—spend the funds as
locally as possible to clean up some
knotty LUST/UST sites. We decided
to focus on three areas of concern:
a) out-of-service UST systems in
groundwater-sensitive areas where
the owners could no longer afford
to operate or maintain their facil-
ity; b) the need for after-the-fact site
closure assessments where USTs
had already been removed; and c)
removal of contaminated soil at three
backlogged LUST remediation sites
where the tanks were long gone but
contamination remained.
Many of the ARRA tanks were
at active facilities (or in the case of
Grande Isle, a gas station turned resi-
dence) where the owners could no
longer afford to operate the tanks, let
alone remove them. These were clas-
sic cases of "if we don't remove them
then no one will." In this article I will
16
focus on just one of the 14 ARRA
projects MEDEP carried out. This
site, in the Town of Patten, had sev-
eral attractive aspects, not to men-
tion the benefits of lessons learned.
The advantage of remediating
sites with out-of-service tanks is if
they are located in a sensitive geo-
logical area and are removed with no
plans to replace them, then our UST
siting law prevents any future USTs
from being installed at that site—
no USTs, then no threat of future
releases. For the purpose of a strict
prohibition for installing a UST, a
sensitive geological area is consid-
ered to be one that is within 300 feet
from a private well, 1,000 feet from
a community water supply well, or
located over a mapped high-yield
sand and gravel aquifer.
The Thickened Plot
The subplot to this tale is that during
the two years the ARRA projects were
under way, MEDEP was beta testing
its new petroleum cleanup standards,
based on Massachusetts DEP Volatile
Petroleum Hydrocarbon (VPH) and
Extractable Petroleum Hydrocarbon
(EPH) Methods. These methods break
down volatile (gasoline) and extract-
able (middle distillates) to a list of
constituents that have an individual
health risk based on specific cleanup
standard scenarios. Prior to this we
used a composite method of Gasoline
Range Organics (GRO) and Diesel
Range Organics (DRO).
We were also retuning our use of
the photo-ionization detector (PID)
bag head-space method for volatile
organic compounds (VOCs), includ-
ing replacing the commonly used
zip-lock plastic bags with aluminized
bags to reduce errors owing to vapor
loss. The PID screening methods
also changed from using set points
to using screening values for specific
PID models, specific sample vol-
umes, and cleanup levels. For diesel
and fuel-oil soil screening we were
trying out an oleophilic dye-shake
field test. All these methods are in
-------
March 2011 • LUSTLine Bulletin 67
use now and waiting to be formally
incorporated into our standards. (See
http://www.maine.gov/dep/nvm/petro-
leuml index, htm.)
All the sites we worked on were
primarily gasoline and in ground-
water-sensitive areas, so we used the
leaching to groundwater scenario
standard. Also, for comparison pur-
poses, we tested for both GRO/DRO
and VPH/EPH and tested for ethyl-
ene di-bromide (EDB).
The Roadblocks
The major roadblock to using the
ARRA funding for UST assessments
and cleanups was cost recovery.
Because these funds came through
existing grants—the LUST grant,
in particular—we were required to
seek reimbursement for any funding
spent. This made it difficult to find
suitable sites for removing tanks and
assessing and cleaning up any con-
taminated soils. This was a concern
in many other states as well when
the LUST ARRA guidance was rolled
out. We limited our search to facili-
ties that were in sensitive groundwa-
ter areas and to owners who could
pass our existing financial test for
nonreimbursement.
The other roadblock was making
sure that our contracts were ARRA
compliant and also acceptable to our
Bureau of Purchases. The upshot to
of all this was that a retainer contract
was developed for UST installation/
removal companies and for compa-
nies with direct-push soil-sampling
rigs. Both contracts included con-
tractors from the south, central, and
northern parts of the state.
The Patten Project
Of all the ARRA work we did during
2009 and 2010, the UST assessment,
tank removal, and contaminated soil
removal at the former Patten Gen-
eral Store was the best tale of all and
was successful because of the fits
and starts and lessons learned from
our previous ARRA projects. Patten,
Maine, was a once thriving logging
and potato-growing town of around
1,100 near the north gate of Baxter
State Park—the Northern Terminus
of the Appalachian Trail. The Pat-
ten General Store was once a mecca
for sportsmen to pick up hunting,
camping, and fishing supplies before
heading off to the park or into the
north woods.
In 2010 the current owner finally
let the property go for taxes, and the
Town of Patten was stuck with a non-
tax-producing environmental liability.
Unlike the other ARRA UST assess-
ments/removal projects involving
failing businesses, the town was sol-
vent. Since financial commitments
were made before the site's eligibility
status was fully clarified, the site was
considered LUST Trust eligible. So
the town did not have to pay for the
assessment and remediation but did
provide us with invaluable service
throughout the project.
The Patten General Store had
We limited our search to facilities
that were in sensitive groundwater
areas and to owners who could
pass our existing financial test for
nonreimbursement.
five abandoned single-walled, cath-
odically protected tanks and associ-
ated single-walled piping located
less than 600 feet from one of the
town's drinking water wells. The
town has another well but it was
not in service because of contamina-
tion concerns resulting from a failed
home-brew biodiesel experiment
carried out in the now burned-down
building next door!
Since this project was basically a
wellhead-protection project, we also
decided to use monies of our own to
replace the aboveground home heat-
ing oil tanks in the town's mapped
wellhead protection zone. This
endeavor involved replacing the
tanks in most of the homes and busi-
nesses in the town. MEDEP responds
to an average of one spill a day from
residential aboveground home heat-
ing oil tanks. Spills from corroded
tanks, leaking oil lines, and overfills
cost the state between $1 million and
$2 million a year.
Twelve years ago, Maine set up
a program, carried out through our
Groundwater Cleanup Fund, to pro-
actively help replace home heating
oil tanks and tanks in wellhead pro-
tection areas for towns and water dis-
tricts. The replacement specifications
that we use include double-walled
tanks and many other requirements
over and above the state require-
ments. We started this process with
the town, working with the superin-
tendent of the Patten Water Depart-
ment, months before the ARRA UST
assessment project started. He not
only walked door to door with us to
talk to folks about the tank replace-
ment project, but was also extremely
helpful during the UST assessment
project, locating utilities, coordinat-
ing with the local Department of
Transportation maintenance garage,
the local electrical utility, and site
security, and more.
Tanks Away!
We used our ground-penetrating
radar unit to locate the USTs and
piping and clear locations for pre-
removal soil sampling. In June 2010
we hired a company that we had
used on other ARRA sites to sam-
ple the site with direct-push soil-
sampling equipment. Findings from
this work indicated that around 1,300
tons of soil needed to be excavated,
primarily in front of the store under
the dispensers. This information was
used to bid the removal project out
to our three prequalified tank instal-
lation/ removal contractors.
The contractor selected was from
central Maine and had done a job for
us in 2009 at a Jonesport site. He is
a very savvy and colorful business-
man whom we have known for over
20 years and is a great negotiator for
trucking, soil disposal, and all the
little details that make for a success-
ful cleanup. His bid price included
sending the excavated contaminated
soil to a secure special-waste landfill
about two hours away from the site.
Our other option was to take the
dirty dirt about 45 minutes away to
a licensed asphalt batch plant, but
the tipping fee was much higher.
This, quite frankly, was a relief to us
since our air-quality agency had an
emissions issues history with this
facility, which could have created an
"uncomfortable" situation. In fact,
the writing was on the wall that the
thermodesorption option was on its
way out unless facilities were willing
to invest in advanced emission con-
trols.
In July 2010 the tanks at
the former Patten General Store
came out, along with 1,300 tons of
contaminated soil. We had sent out a
• continued on page 18
17
-------
LUSTLine Bulletin 67 • March 2011
m Tanks Down East^rom page 17
press release to advertise the ARRA
project, and three camera crews from
the local television affiliates actu-
ally showed up. And something else
showed up—three more small circa
1930s USTs and a chunk of contami-
nated soil under the building.
In October 2010 we came back
to Patten for Phase II and, to the
delight of most townspeople, tore
the abandoned 70-year-old build-
ing down and sent the demolition
debris to the same secure special-
waste landfill where the dirty dirt
went. The main section of the store
came down around lunchtime. On
that day, in that small rural town,
everybody who was anybody was
there to watch the biggest news since
the building across the street burned
down two years earlier. Everybody
had a story about the old place, and
it had its own stories to tell.
During the subsequent removal
of an additional 1,500 tons of soil and
the three surprise USTs, we found
two old treasureless safes, a Model-
T wheel with its rubber tire, a truck
axle and wheels, and an intriguing
selection of old liquor bottles.
So Was This a Successful
Project?
Were jobs created and lessons
learned? The site has been cleaned
up, which will facilitate the sale and
redevelopment of the property. This
and three other UST-assessment sites
served as great testing grounds for
our new cleanup standards and pro-
cedures. The general contractor, his
environmental consultant, and the
direct-push contractor got more work
than they normally would, consider-
ing the economy. Most of the sub-
contractors were local, including
the flaggers, truckers, backfill sup-
plier, paving contractor, motel and
inn owners, and the deli next door,
where the whole project team ate
everyday on and off for about two
weeks. Finally, one can't put a price
on protecting a town's drinking water
supply.
Oh, by the way, at the end of
the Patten Project we were the first
state in New England and third in
the nation to spend our LUST ARRA
funds. •
18
Phase 1 soil excavation
at the "dooryard" of
Patten General store.
2. Three surprise tanks are
discovered underneath the
store. This discovery leads
to Phase 2 of the project.
#3. The store is demolished
and Phase 2 soil
removal begins.
-------
March 2011 • LUSTLine Bulletin 67
TRNHS DM TRIBRL LRNDS
USE PA is responsible for implementing the UST program in Indian country (1C). The primary
objective of the 2005 EPA UST Tribal Strategy agreed on by the tribes and USEPA, was to
strengthen relationships, communication, and collaboration—and this has indeed been the
case (http://www.epa.gov/oust/fedlaws/Tribal%20Strategy_080706r.pdf). To increase the
likelihood of successful implementation of the UST program, the tribes and USEPA work
together in a strong partnership. For years, the significant operational compliance and
cleanup completion rates in 1C have lagged behind the national averages. However, this is
changing. In both cases, there has been steady improvement in 1C. In fact, the 1C rates nearly
equaled the national rates the end of FY2010 (September 20, 2010). (See Figures 1 and 2.) This
article explores some of the recent successes in 1C and identifies some of the factors.
FIGURE 1.
Significant Operational Compliance Rates;
National and Indian Country
I ao%
eora,
40% •
30% -
20% •
10% -
66%
«*
63%
66%
6B
68.6*4
87'*
37%
20M 2005 2006 2007 2008 2009 2010
"National
' tn titan Country
FIGURE 2.
Indian Country and National LUST Cleanup Rate
10 Year Comparison: 2DD1-20IO
2001 2D02 2003 2CKM 2«J5 2006 2U07 2Q09 2009 20B
$6.3 Million of Recovery Act Money for
Cleaning Up Tank Releases in Indian Country
Iln 2010, USEPA continued its work to cleanup sites in
Indian country using an additional $6.3 million of 2009
Recovery Act funds (Figure 3). The money was allocated
to existing USEPA cleanup contracts with Alaska Native
and Native American firms. This one-time addition sub-
stantially increased USEPA's ability to assess and clean
Jtm pnttct it (undid by lh« American
Recovery and ft*Mw*»tmw* Act
up LUST sites in Indian country by supporting work at
53 sites, benefiting 23 tribal communities. The following
two stories are examples of projects carried out in Indian
country. •
FIGURE 3.
EPA's Funding For Cleanup Of UST
Releases In Indian Country
(in millions)
53.0
$6.3
(Cleanup
I continued on page 20
19
-------
LUSTLine Bulletin 67 • March 2011
i Tanks on Tribal Lands from page 19
Winnebago Tribe of Nebraska, Former Skelly
Gas Station
USEPA Region 7's UST program worked in partnership
with the Winnebago Tribe of Nebraska to use Recov-
ery Act money to clean up the former Skelly Gas Sta-
tion site. The Skelly Gas Station was abandoned in the
1960s. Work included assessing the site, removing USTs
in conjunction with contaminated soil, and addressing
petroleum vapor exposure that affected the Tribal Court-
house. The remediation activities have reduced the risk
to human health and the environment from petroleum
vapor and soil contamination, and improved the neigh-
borhood environment for the nearby elderly community
center and boys and girls club. This cleanup created sev-
eral jobs on the reservation and will facilitate the reuse of
this site for commercial purposes. •
Navajo Nation, Former Painted Desert Inn
Gas Station
USEPA Region 9's UST program is working in partner-
ship with the Navajo Nation Tribe to use Recovery Act
money to clean up the former Painted Desert Inn Gas
Station. This gas station originally operated two 10,000
gallon and two 2,000 gallon USTs, which were removed
in August 1991. The remediation activities have been
instrumental in helping determine the extent of soil
and ground water contamination. Navajo Nation plans
to improve the drinking and wastewater system for the
residents in the area and revitalize the site for poten-
tial commercial purposes. According to a 2004 survey,
approximately 30 percent of Navajo Nation residents
haul water because they do not have water piped to their
homes. •
Remediation work at Navajo Nation, Arizona.
Status of Significant Operational Compliance
at UST Facilities
Significant operational compliance (SOC) is a key ele-
ment to preventing releases because it means that a
20
facility has the equipment required by regulations and
performs operation and maintenance to prevent and
detect releases. SOC rates in Indian country have varied
considerably from year to year, owing to the relatively
small number of USTs. Between 2006 and 2010, SOC
in Indian country has been on average about 8 percent
below the national rate. However, at the end of FY2010,
the gap was reduced to 1.6 percent, and for the first time,
the SOC rate for Indian country exceeded the national
goal of 66.5 percent. (See Figure 2.) Increased compliance
assistance by USEPA staff and particularly tribal compli-
ance assistance officers, who are often located closer to
regulated facilities, play an invaluable role in educating
owners and operators and thus promoting compliance.
Furthermore, training for tribal environmental staff and
UST owners and operators is important to helping main-
tain and improve SOC. •
Tribal Inspectors Authorized to Conduct
Federal UST Inspections
Designating tribal inspectors as authorized representa-
tives of USEPA to inspect USTs can help increase the geo-
graphic coverage and frequency of inspections in Indian
country. It also helps enhance relationships and increase
the capabilities of tribal inspectors. Since USEPA's com-
mitment in 2006 to issue federal credentials for tribal
inspectors, a total of six inspectors have received cre-
dentials; although only four currently hold credentials,
a result of changes in tribal staff responsibilities and
turnover. However, since the beginning of the new fis-
cal year on October 1, 2010, three additional tribal staff
members have received federal credentials. In FY2010,
these federally credentialed tribal inspectors contributed
significantly to meeting the inspection requirements of
the Energy Policy Act, having completed 63 inspections.
USEPA anticipates that at least two additional tribal staff
will receive federal credentials in FY2011. •
Strengthening Tribal and USEPA
Communications over the Past Five Years
Developed website http://www.epa.gov/oust/tribes/
* Developed website http://iviviv.epa.gov/oust/tribes/
index.htm
* Developed UST Program Directory http://iviviv.epa.
govlaustlpubslustindiancauntrydirectaryll-08.pdf
* Held Annual Tribal-EPA Meetings in Albuquerque,
NM (2007), Rapid City, SD (2008), Miami, FL (2009),
and quarterly conference calls
* Increased tribal role in the National Tanks Confer-
ence
• Developed chat room http://tech.groups.yahoo.com/
group/Tribal_UST/ and http://groups.yahoo.com/group/
Tribal-EPA_UST_Workgroup/
* USEPA Administrator Jackson reaffirmed USEPA's
1984 Indian Policy on July 27, 2009. •
-------
March 2011 • LUSTLine Bulletin 67
from Robert N. Renkes, Executive Vice President, Petroleum Equipment Institute (PEI)
PEI Committee Developing LIST Equipment System Testing Document
Release detection, release prevention, and over-
fill equipment is currently employed at under-
ground storage tank (UST) facilities as required
by local, state, and federal regulations. For this equip-
ment to be operated effectively and safely, it must be
maintained, inspected, and tested for proper opera-
tion on an ongoing basis.
To date, there has not been a document available
to UST owners and/or regulators that provides infor-
mation on the proper procedures related specifically
to the verification and testing of spill, overfill, release
detection, and secondary-containment equipment at
UST facilities. The PEI Board of Directors thought that
a single authoritative source of information would
benefit not only the regulated community but also the
equipment industry and UST regulators, so the board
authorized the appointment of a committee to develop
a recommended practice on the subject.
The committee has hit the ground running, meet-
ing for the first time this January and again in March.
Although the scope of the recommended practice may
change as the committee proceeds with its work, the
document is currently limited to facilities that are
equipped with UST systems used for the storage of
motor fuels, jet fuels, distillate fuel oils, residual fuel
oils, lubricants, petroleum solvents and used oils.
Equipment covered includes USTs, connected under-
ground piping, underground ancillary equipment,
and containment systems.
While it is important to consider the design and
operational characteristics of an UST system when
specifying overfill prevention and release prevention
and detection equipment, the committee clearly will
not provide guidance in the document to address the
design, installation, or day-to-day operation of UST
systems.
The committee intends to cover the testing and
verification of all equipment used to prevent overfills,
and prevent and detect releases to the environment.
Although it's still early in the process and the committee
has not completely finished its initial draft, chapters on
the following subjects have been included:
• Dry and wet methods for testing the integrity of
tank secondary-containment systems
• Testing the interstitial space of fiberglass and flex-
ible/semi-rigid piping systems
• Hydrostatic and vacuum testing of single- and dou-
ble-walled spill buckets
• Testing of sumps and under-dispenser-pan contain-
ment—this would include all containment sumps
including, but not necessarily limited to, submers-
ible sumps, piping sumps, vent riser sumps, and
tank-top sumps
• Verification, inspection, and testing of overfill pre-
vention valves (flapper valves), high-level alarms,
and flow restrictors (ball float valves)
• Inspection and testing of automatic tank gauge
(ATG) systems
• Testing of mechanical and electronic line-leak detec-
tors
• Inspecting and testing of shear valves
Plans now call for the committee to be in a position
to circulate a draft of the yet-to-be-named recommended
practice sometime this fall to all interested parties. If
you want a copy to review, write rrenkes@pei.org and I'll
see that you get one. The committee should be able to
review and act on the comments before the end of the
year and publish a final document early in 2012.
The committee is made up of representatives from
equipment suppliers, tank owners, release-prevention
testers, industry-related associations, and the regula-
tory community (Paul Miller from USEPA's Office of
Underground Storage tanks and Kevin Henderson from
the Mississippi Department of Environmental Quality).
A complete list of all committee members is available
under the "About PEI" tab at www.pei.org. •
Latest Version of PEI's Recommended Practices for Inspection and Mainte-
nance of Motor Fuel Dispensing Equipment (PEI/RP500) Now Available
The Petroleum Equipment Institute's Recom-
mended Practices for Inspection and Maintenance
of Motor Fuel Dispensing Equipment (PEI/RP500)
has been updated and is now available. This new edi-
tion will be welcomed by regulators who permit petro-
leum marketers to dispense ethanol at blend levels
higher than the dispenser's listing, provided that the
dispensers are inspected on a regular basis. The reac-
tion to the initial version of RP500 was very positive.
This improved and updated edition builds on that fine
document.
PEI's Fuel Dispensing Equipment Inspection and
Maintenance Committee made over 35 changes to the
document. Some of the more important changes address:
• Emergency stop switches
• Inspecting dispenser cabinets
• Procedures for taking nozzles out of service
• Methods for checking the integrity of hose
• Procedures for testing nozzles equipped with a
mechanical interlock
• continued on page 22
21
-------
LUSTLine Bulletin 67 • March 2011
. continued from page 22
Plumbing from the top of the shear valve
Suction-pumping systems
Warning users that the country's move to higher
ethanol blends and lower amounts of sulfur in die-
sel may result in leaks or unusual operating condi-
tions that may necessitate more frequent inspections
than outlined in the document
• Determining that DEF is outside the scope of the
recommended practice.
Recommended Practices for Inspection and Maintenance
of Motor Fuel Dispensing Equipment (PEI/RP500) can be
purchased at iviviv.pei.org/rp500. Price is $40 for mem-
bers; $95 for nonmembers. •
FAQs from the NWGLDE
Adding Biodiesel Blends to NWGLDE Leak-
Detection Equipment Listings
In this LUSTLine FAQs from the National Work Group on Leak Detection Evaluations (NWGLDE), we discuss our policy for the
addition of biodiesel blends to our leak-detection-equipment listings. Note: The views expressed in this column represent those of
the work group and not necessarily those of any implementing agency.
Q. Is the NWGLDE going to allow the addition of tion of B21-B99 is not in accordance with an ASTM
standard. Instead, B21-B99 blends are currently pro-
duced by blending ASTM D975 diesel and ASTM
A, ; " , D6751 B100. Since the report was written, the BIAP
. The Biodiesel Industrial Advisory Panel (BIAP) hag indicated that they are working with ASTM to
Is the NWGLDE going to allow the addition of
biodiesel blends to listings in accordance with the
Biodiesel Industrial Advisory Panel report?
The Biodiesel Industrial Advisory Panel (BIAP)
report Effects of Biodiesel Blends on Leak Detection for
Underground Storage Tanks and Lines dated August
2010 (amended January 2001), prepared by Ken Wil-
cox Associates, Inc. states that the ASTM D975 stan-
dard allows diesel fuel to include up to 5 percent
biodiesel. In response, the work group added the
following definition to the NWGLDE website glos-
sary:
• Diesel or Diesel Fuel: Middle petroleum distil-
late fuel that may contain up to 5 percent biodie-
sel in accordance with ASTM standard D975.
As a result, all work group listings that are appli-
cable for use with diesel are also acceptable for use
with B5 biodiesel.
Based on the BIAP report, the work group imple-
mented a policy that allows a leak-detection-equip-
ment vendor to request that certain biodiesel blends
meeting ASTM standards be added to listings with-
out additional third-party evaluation, as follows:
• ASTM D7647 Biodiesel B6-B20: Acceptable for
all current methods of leak detection, except an
out-of-tank product detector (vapor phase)
• ASTM D975 Biodiesel B100: Acceptable for all
current methods of leak detection, except an
out-of-tank product detector (vapor phase), liq-
uid sensors (dry interstitial space and out-of-
tank), and all tracer methods
The BIAP Report also made a recommendation that
certain leak-detection equipment should not require
third-party evaluation prior to listing the equip-
ment for biodiesel B21-B99. The NWGLDE did not
agree with this recommendation, since the produc-
develop a standard for B21-B99. Until such a stan-
dard is developed and implemented, the NWGLDE
will only add this range of biodiesel to a listing if the
leak-detection equipment was third-party evaluated
using biodiesel blends in the B21-B99 range. Once
the ASTM standard is completed, the NWGLDE will
review the standard and may revise its policy.
The BIAP report discussed only biodiesel fuels
produced using ASTM standards. Leak-detection-
equipment manufacturers who request listing of
a biodiesel fuel not produced in accordance with
ASTM standards must submit a third-party evalu-
ation using this fuel to the Work Group before
consideration will be given to add the fuel to the
NWGLDE listing.
Another recommendation by the BIAP report is that
compatible materials be used in the manufacture
of leak-detection equipment for use with biodiesel
blends. Since protocols used to evaluate leak-detec-
tion equipment do not include material compatibility
testing, the NWGLDE previously developed the fol-
lowing disclaimer to address material compatibility:
• Since long-term material compatibility with the
product stored is not addressed in test proce-
dures and evaluations, the NWGLDE makes no
representations as to the compatibility of leak-
detection equipment with the product stored.
Therefore, since the NWGLDE does not take into
account material compatibility when consider-
ing requests to list leak-detection equipment. No
changes will be made to leak-detection equipment-
listings based upon this aspect of the BIAP report.
22
-------
March 2011 • LUSTLine Bulletin 67
FAQs... continued from page 22
Manufacturers of leak-detection
equipment are encouraged to con-
tact the appropriate members of
the NWGLDE to request the addi-
tion of ASTM standard biodiesel
blends to their current listings.
Contact information can be found
under "Group Members" and "Team
Members" at www.nwglde.org.
A copy of the Biodiesel Industrial
Advisory Panel (BIAP) report
Effects of Biodiesel Blends on Leak
Detection for Underground Storage
Tanks and Lines can be found at
www.nwglde.org under "Down-
loads." •
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 ques-
tions (FAQs) the NWGLDE receives from
regulators and people in the industry on
leak detection. If you have questions for the
group, please contact them at questions®
nwglde.org.
NWGLDE's Mission
• Review leak detection system evalua-
tions to determine if each evaluation was
performed in accordance with an accept-
able leak detection test method protocol
and ensure that the leak detection system
meets EPA and/or other applicable regu-
latory performance standards.
• Review only draft and final leak detection
test method protocols submitted to the
work group by a peer review committee
to ensure they meet equivalency stan-
dards stated in the U.S. EPA standard test
procedures.
• Make the results of such reviews avail-
able to interested parties.
• TQM and VSTsfrom page 10
represent strictly pass/fail statistics.
The data at this point do not indicate
whether the leaks are liquid leaks at
the tank bottom or vapor leaks from
the tank top. Nor do the statistics
indicate whether the failed tests for
double-walled tanks merely resulted
in a release to the interstitial space
or to the environment. Ed tells me
that many of these issues could be
resolved by reviewing the tester's
notes on the test, but that review
would need to be done by a person
familiar with the test protocols and
the often-cryptic language that tes-
ters use to document their findings.
So What's the Point of
this Soapbox?
Simple, a) We need some hard data
on what is wrong with our UST sys-
tems today, if we're ever going to
learn how to make them better (i.e.,
more leakproof) in the future, b) If
we really want the data, we need
to enlist the help of those out there
doing the work—the installers, tes-
ters, and third-party monitors who
are seeing the warts in our UST sys-
tems in real time on a daily basis. I
believe that many of these people
would be happy to help, especially if
there were funds available to pay for
the time it will take to pore through
their data bases and get the informa-
tion that we really need to move our
UST system population to the next
level of integrity.
P.S. I'm planning on spending
some more time with Ed's data to
see what's there and describing my
findings in the next issue of LUST-
Line. •
• Fuel and Tank Disconnect
from page 13
system every quarter. Keeping tanks
water free, incorporating a desiccant
dryer on the vent alarm, and man-
aging the water content by imme-
diately removing it to avoid that
"perfect storm" when water and
temperature combine to manifest
microbial contamination. This is in
fact the one place where tank owners
can lend a helping hand to their fuel
supplier and make a big difference
in both fuel performance and storage
tank longevity.
What Next?
My goal in writing this article was
to help the reader look beyond the
tank system to the entire fuel-supply
chain and understand that no mat-
ter what happens in that fuel tank,
whether good or bad, it is still a
direct result of its entire life cycle. A
short summary would suggest that
all parties involved in the fuel-distri-
bution business work collegially to
establish an easy-to-f ollow road map
for quality fuel preservation from
upstream to downstream. Open
communication will be required
if we are to minimize fuel-quality
issues that have compromised per-
formance both under the hood and
inside the tank system. •
Paul Nazzaro is President of Advanced
Fuel Solutions, Inc. He can be reached
at paulsr@yourfuelsolution.com,
www.yourfuelsolution.com A
special thanks to Ld English at Fuel
Quality Services, Inc. for his much-
appreciated input in preparing
this article.
L«U«S«T«LINIE Subscription Form
Name
Company/Agency
Mailing Address
E-mail Address
_l One-year subscription: $18.00
J 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
23
-------
LU.S.T.UNE
New England Interstate Water
Pollution Control Commission
116 John Street
Lowell, MA 01852-1124
OUST UPDATE
LUST Corrective Action
Compendium Now Available
The USEPA Office of Underground
Storage Tanks (OUST) LUST Cor-
rective Action Compendium is
now available at iviviv.epa.gov/'oust/
lust/intro.html. The Compendium is
a clearinghouse that presents con-
cepts and addresses issues associ-
ated with corrective action at LUST
sites. It provides valuable infor-
mation and links to resources for
all aspects of the LUST remedia-
tion process.
The Compendium is divided
into six sections, beginning with an
overview of the LUST corrective
action process. It then discusses
each of the steps in the process—
release discovery, confirmation,
and initial response; characteriza-
tion of the source and site; physical
site assessment; corrective action;
and site closure.
The information is intended
for the use of federal, state, and
tribal LUST remediation spe-
cialists, but other stakeholders
will find it a valuable resource
as well. A work group made up
of UST stakeholders from states,
tribes, USEPA, and the private sec-
tor developed the Compendium. •
New UST Flood Guide
Available
USEPA's new Underground Storage
Tank Flood Guide, EPA 510-R-10-
002, is available on OUST's website
at TVTVTV.epa.gov/oust/pubs/ustflood-
guide.htm. The guide presents use-
ful information and guidelines for
state, local, and tribal authorities in
the event of a threatened or actual
flood. It will help authorities pre-
pare for, prevent, or lessen the
catastrophic effects and environ-
mental harm that could occur as a
result of flooded UST systems, as
well as aid the return of these UST
systems to service as soon as pos-
sible. It includes information about
preparing for a flood, important
actions after the disaster strikes,
and financial assistance. It con-
solidates information from various
federal, state, nongovernmental,
and UST industry resources. •
Online Insurance Resource
for UST Owner/Operators
Updated
OUST recently updated its List
Of Known Insurance Providers For
Underground Storage Tank Own-
ers And Operators. The publication
is available on OUST's website at
TVTVTV.epa.gov/STverustl/pubs/inslist.
htm. It contains a list of insurance
providers who may be able to help
UST owners and operators com-
ply with financial responsibility
requirements by providing a suit-
able insurance mechanism. •
------- |