New England Interstate
Water Pollution Control
116 John Street
Lowell, Massachusetts
A Report On Federal & State Programs To Control Leaking Underground Storage Tanks
                   Bulletin 65
Operator Training Has Left the Station...
So Where Are State Programs Headed?
by Marcel Moreau and Ben Thomas
UST OPERATOR TRAINING: Will it radically improve our UST compliance rates, or will it be another add-
on regulation that regulators and UST owners must endure? The crystal ball is still fuzzy and we're not making any
predictions, but we thought it might be useful to review some of the diverse approaches that states are taking toward
implementing the operator training requirements of the 2005 Energy Act.
    As we write, the deadline for training UST operators
    in Oregon and California passed some five years
    ago, and Colorado has had a training requirement
in place for a few months. New Mexico is beginning to
implement its operator-training requirement this year. A
few states like Louisiana have a deadline of 90 days after
the next upcoming compliance inspection, and Minnesota
deadlines will be driven by area code (novel but painful
for large operators). Most other states, as far as we can
determine, are aiming for a training deadline of August
8, 2012, the deadline set in the Energy Policy Act of 2005
(EPAct). A number of states have training mechanisms or
at least training plans already in place in anticipation of
the 2012 deadline; however, it looks like a few states may
not meet the deadline.

                    • continued on page 2
                22 (

                9ft I
Transition—Part 2

Release, Remediate, Repeat

Not for the Squeamish!

Plugging the Rest of the Leaks

From Our Readers

What's New at USEPA?

Short List of Potential UST Reg Changes

FAQs: Continuous Leak Detection Methods


LUSTLine Bulletin 65 • June 2010
m Operator Training Programs
from page 1

    The focus of state programs is
to establish training mechanisms for
what the EPAct defines as Class A and
Class B operators. Class A operators
can be loosely defined as "owners"
and Class B operators can be loosely
defined as "facility managers." The
EPAct  also establishes  a Class C
operator that  can be loosely defined
as "clerk."  (See USEPA's guidance
document on operator training for the
official  definitions  of these operator
classifications  at
    Because of the large  overlap in
Class A and Class B operator knowl-
edge and  the relatively small number
of people who are strictly Class A
operators, a number of states are pro-
viding for a combination Class A/B
operator. Class C operators can be
trained by Class A and B operators,
so states  are not  focusing on estab-
lishing programs to directly train this
class of operator, but several private-
sector training providers are promot-

           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.

            116 John Street
         LoweU, MA 01852-1124
        Telephone: (978) 323-7929
          Fax: (978) 323-7919
    <££) LUSTLine is printed on recycled paper.
   Links to State Internet-Based Training Programs
    TankHelper2 - https://app.
    Operator Training -
    Ta n kS m art - http://www. maine.go v/dep/rwm/ust/tanksmartonlineservice. htm
    UST Training System -
    http://www. scdhec. go v/en vironment/lwm/UST_ Training/Default, aspx
ing training specifically for Class C
    In this article we will focus spe-
cifically on the approaches that states
are taking toward setting up Class A
and Class B (or combined Class A/B)
training programs.
    At present we have identified
four kinds of approaches to accom-
plishing Class  A and B operator
•  State-funded internet-based
•  State-funded classroom
•  Free-market, operator-funded
•  Examination only, operator-
State-Funded, Internet-
Based Training	

In 2005, the Montana Department
of Environmental Quality (MDEQ)
unveiled a  state-sponsored UST
operator-training program that was
100 percent web-based and interac-
tive. The Montana program, known
as TankHelper, is being replicated
in various ways in several states,
including Idaho, Maine, and Ken-
    Prominent features of the Mon-
tana TankHelper program include:
•  The TankHelper program  links
   to the Montana UST database
   so the training information pre-
   sented to the operator is facility-
   specific. For example, if a facility
   is all fiberglass, uses an ATG  for
   tank leak detection, and has safe-
   suction piping, then these topics
   are presented and all other meth-
   ods of corrosion protection and
   leak detection are ignored. This
   approach to training requires an
   accurate database but has huge
   advantages in that it presents only
   information that the UST operator
   needs to know. This suits the great
   majority of  UST operators who
   just want to  meet the regulations
   and are not interested in becom-
   ing all-around experts  in UST
   management. It also eliminates
   the problem faced by many oper-
   ators who do not know what kind
   of tanks, pumps, or leak-detection
   method they  have and  emerge
   overwhelmed and confused from
   a training course that covers all
   the possible variations of UST sys-
•  At the end  of the training, the
   operator is presented with a facil-
   ity-specific compliance plan. The
   plan describes the operational and
   leak-detection requirements for
   each facility in a concise format so
   operators have a complete listing
   of exactly what they must do to be
   in compliance at their facility.
•  The program is funded  entirely
   by the state and is available free to
   the operator.
•  The MDEQ  maintains complete
   control over the program.
   The original version of TankHel-
per was silent. Users would log onto
the website, select a facility, read a
series of  screens, and then take a
quiz to evaluate their understand-
ing of their UST site. In 2009, MDEQ
unveiled  Version 2 of TankHelper,
which provides the operator with a
video and audio presentation of the
training material and requires very
little reading. For those who pass the
final exam with an 80 percent score or
higher, the State of Montana issues a
Class A/B certificate of completion.

                                                                                 June 2010 • LUSTLine Bulletin 65
Maine has developed a program
very similar to the original version of
Montana's TankHelper; it goes by the
name of TankSmart. The Maine pro-
gram also links to the UST database
so that facility-specific information
can be presented. The student reads
screens and then takes an exam. In
addition to the web-based program,
the Maine program includes a down-
loadable manual that can be printed
for future reference by the UST opera-
tor or provided upon request by the
DEP via mail to operators who do
not have convenient computer access.
While the Maine training is facility
specific, the TankSmart program does
not produce a facility-specific com-
pliance plan.  TankSmart provides a
combined Class A/B  certificate to
UST operators who successfully pass
the exam. TankSmart is funded by the
State of Maine and is provided free of
charge to UST operators.

South Carolina has a hybrid web-
based training program that provides
a library of downloadable PDF docu-
ments on the various aspects of UST
systems. The  student selects, down-
loads, and reviews the lessons, then
returns to the web to take an online
exam. The program allows the user to
download only the lessons they need;
the state assumes you know which
lessons apply (a big assumption).
South Carolina has also combined
the A/B  training. South Carolina,
like California, expects operators to
know their stuff afterward and now
requires a monthly inspection form
be completed. The program is free
but must be  completed by August
11, 2011. (We assume the site will
remain in business after the deadline
for new and replacement operators.)
Users who successfully complete the
program are issued a certificate.

Oklahoma has developed an online
PowerPoint-like show as its UST
operator-training mechanism. The
program is self-guided, generic (i.e.,
not site-specific), and silent and
includes a short quiz after each train-
ing category. The trainee is prompted
to print a certificate after each cat-
egory is reviewed and each category
exam is passed.
Idaho has developed a program
similar  in format to the Montana
TankHelper program in that it links
to the UST database and provides
facility-specific information  and a
facility-specific management plan.
The Idaho approach has a unique
teaching method. Instead of having
the UST operator go to the web to
learn the information, an Idaho UST
inspector delivers the training on a
laptop computer as part of the facil-
ity inspection process. The inspec-
tor also prints out the management
plan and provides a binder in which
to store the  plan and the required
recordkeeping paperwork. A cer-
tificate is printed for operators who
pass the associated quiz.
   The goal is to raise the bar on UST-

    operator knowledge. A training

   program that does little more than

   review material that UST operators

     already know will only serve

    to bless the status quo and not

   produce the desired improvements

        in UST management.

The Kentucky Division of Waste
Management is creating an online
operator-training program, modeled
closely on the Montana TankHelper
program, called TOOLS (Tank Oper-
ator Online Learning System.) This
program is still under development,
but the plan is to include a series of
PowerPoint-based lessons with audio
narration. The program will provide
facility-specific training based  on
information contained in the state
UST database and a facility-specific
compliance management plan. Oper-
ators who successfully complete the
exam will  receive a  combination
Class A/B certificate that includes a
listing of the lessons taken.
    The TOOLS program will pro-
vide the names of certified operators
and the UST facility(ies) with which
they are associated to the Kentucky
UST database  so that compliance
with the UST-operator requirements
can be easily tracked. UST owners
will also be able to go online and
assign or remove UST operators from
UST facilities as personnel change
over time.
Classroom Training	

Since 2007, the Kansas Department
of Health and Environment has con-
tracted with the Petroleum Marketers
& Convenience Store Association of
Kansas to provide live UST-operator
classes at various locations across the
state. The classes are presented free
of charge to the UST operators. The
association promotes the classes, reg-
isters UST operators, and provides
instructors for the classes. Class A/B
certificates are provided to attend-
ees. Kansas plans to continue to fund
these live classes for at least the next
few years. In order to obtain an UST
operating permit in 2012, operators
will need to prove that they have
attended an UST-operator class.

The Louisiana Department of Envi-
ronmental Quality has adopted an
operator training approach  that is
nearly identical to the Kansas model.

The Virgin Islands (VI) Department
of Planning and Natural Resources,
using federal  funding, decided to
act quickly  and offer free classroom
training to the island's UST-facil-
ity owners (about 60). Training was
completed in early May 2010, before
the UST-training rules were final-
ized. With such a small population of
owners, VI should be able to reach all
operators with not too much effort. It
remains unclear what VI will do after
the presumed 2012 deadline.

Free Market, Operator-
Funded Training	
In our classification system, "free
market" states are ones where the
state agency is approving or  autho-
rizing private-sector training ven-
dors to provide training for a fee to

                • continued on page 4

LUSTLine Bulletin 65 • June 2010
m Operator Training Programs
from page 3

UST operators. Usually, training can
be provided through a variety of
venues, including traditional class-
room, webinars (where an instructor
is present at specific times to teach
the class via the Internet), and online
(where a course is available anytime
the student wishes to take it). Many
states appear to be pursuing this
type of  operator-training approach.
Only a few representative  examples
are described here.

With a deadline of March 2004, Ore-
gon was the first state to require UST
operator training. (See LL #58, "Oper-
ator Training—The Oregon Experi-
ence;" LL #47, "Mandatory Training
for UST Operators.") Oregon took the
approach of having the private sector
run the operator-training  program.
The state merely authorizes trainers to
provide the training. Operators have
a number of private training provid-
ers from which to choose. To date,
only live classes have been offered.
The number, location, and cost of the
classes offered is entirely  up to the
training providers, who provide a
certificate to the attendees. The state
provides little oversight to monitor
the quality of the training.
   Oregon also allows operators
to use the International Code Coun-
cil (ICC) UST operator exam to meet
the state requirements. The ICC pro-
vides a  list of reference documents
to prepare for the exam but does not
provide any actual training. As far as
we can tell, live training classes have
proven  to be much more popular
among UST operators than the ICC

Colorado's operator-training dead-
line was January  1, 2010.  The
state encouraged the free-market
approach and approved a variety of
classroom, internet-based, and exam-
ination options. Several vendors
were approved to provide classroom
training, concluding with an exami-
nation; one vendor was approved to
provide training in a webinar format
with an online exam. Colorado is
also accepting the ICC UST operator
exam. As might be expected, most
of the training activity took place in
the two months immediately prior to
the regulatory deadline. A number of
UST consulting firms started a Colo-
rado market for third-party Class
A/B operators, where the owner on
record outsources the training and
monthly/annual inspections.

Like Colorado, New Mexico is
approving private sector vendors to
provide training in a variety of for-
mats. The state has chosen to stagger
the training deadlines between now
and 2012. Owners of 12 or more UST
facilities  must have their operators
trained this year. Owners of between
three and eleven facilities must meet
a 2011 deadline. Operators of one or
two  facilities have until 2012. New
Mexico is also requiring training for
aboveground storage tank operators.

Examination-Only, Operator-
Funded Training	
In our classification system, "Exam-
only"  states are ones where  the
emphasis is placed on passing  a
required  exam, and the prospective
UST operator is left to fend for him-
self in terms of  learning the infor-
mation needed to pass the exam. To
date, states adopting this approach
are using the UST-operator exam
developed by the ICC.

California's UST-operator certifica-
tion  deadline was January 1, 2005,
which became effective prior to the
passage  of the Energy Policy Act.
The California strategy requires that
each UST facility have a designated
operator (DO). The DO must con-
duct a monthly inspection of the UST
facility(ies) for which they are respon-
sible, and provide basic leak-detection
and alarm response training to onsite
personnel. Private-sector vendors are
providing live classes to assist pro-
spective DOs in preparing for the ICC
examination. These classes are not
subject to any state-approval process.
A substantial number of California
UST owners have  outsourced their
DO responsibilities to third-party ser-
vice providers.
Wyoming also limits operator-certi-
fication mechanisms to the national-
and state-specific ICC UST operator
examinations. The Wyoming DEQ ini-
tially provided a number of free semi-
nars to prepare prospective operators
for the exams. Future exam prepara-
tion will be handled, for the most part,
by private-sector providers.
How Will We Measure
So as most  states (and  hopefully
UST owners and operators) begin
to ramp up activities for the  2012
operator-training deadline, we think
this is a good time to ask,  "How will
the success of operator training be
measured?" All too often, regulators
measure success by the mere fact that
a required program exists. While the
existence of a program is no doubt
a significant achievement, the pur-
pose of the EPAct was not  to increase
    So how will the states measure
the success of their UST operator-
training programs? Will  it be mea-
sured by the number of certificates
issued? By the number  of  people
who take the various courses?  By
the increase in reports of suspected
or confirmed releases? By increases
in the rates of significant operational
compliance? While any of  these  mea-
sures is feasible, it seems to us that
the goal of UST operator  training is
to increase compliance with UST reg-
ulatory  requirements. If this is cor-
rect, then the  success of a program
might be measured by increases in
the percentage of facilities found to
be in compliance with UST require-
    OUST has been tracking rates of
regulatory compliance as reported
by states since 2002. To satisfy our
curiosity, we plotted the percentage
of UST facilities in compliance  with
release-detection and release-preven-
tion requirements for several states:
Oregon, California, Kansas, and Col-
orado (see Figures la, Ib).
    Oregon's  UST operator train-
ing requirements went into effect on
March of 2004. California's program
took effect on January 1, 2005. Kansas
has been doing some training since
2008, but this is in advance of the
Kansas deadline, so it is not clear how

                                                                                    June 2010 • LUSTLine Bulletin 65
            Percent Compliance with Release-Detection Requirements
     20022 20031  20032 20041  20042  20051 20052  20061 20062  20071 20072  20081 20082  20091 20092
            Percent Compliance with Release-Prevention Requirement
     2002 2 20031  2003 2  20041  2004 2  20051 2005 2  20061 2006 2  20071 2007 2  20081 2008 2  20091  2009 2
large a portion of the Kansas UST
operator population has been trained
to date. Colorado's program went
into effect on January 1 of this year, so
it is clearly too early to see any effects
of this training in the data.
    From the Figure la and Ib graphs,
it would appear that Oregon's rate of
compliance with both release-detec-
tion and release-prevention mea-
sures has been increasing since the
operator-training requirements went
into effect, with a substantial jump
in compliance coincident with the
implementation of the program in
March of 2004. The California trend
is not so rosy; the compliance rates
appear to have held steady or even
declined slightly since 2005. The Kan-
sas and Colorado compliance rates
seem more or less the same over the
years presented in the graphs.
    There is considerable variability
in most of the state data, so we need
to be careful  when reaching con-
clusions, but the  Oregon data indi-
cate that there may be some hope
that operator training  can result in
improved compliance. The Califor-
nia data point out that the success
of operator training may be elusive,
or that  measuring success may be
more complex than just monitoring
reported compliance rates.

Operative Words-
Enforcement! Training!
The premise for including UST
operator-training requirements in
the EPAct was that compliance with
UST requirements was lagging. The
remedies prescribed for this problem
were increased inspection frequency
(hopefully accompanied by increased
enforcement via red-tag authority)
and increased operator knowledge of
the regulations via training. There is
no question in our minds that with-
out effective enforcement, the opera-
tor-training  requirements will  not
bear the desired fruit.
    It is also clear to us that the pur-
pose of training is to increase knowl-
edge. The goal is to raise the bar on
UST-operator knowledge. A training
program that does little more than
review material that UST opera-
tors already know will  only serve
to bless the status quo and not pro-
duce the  desired improvements in
UST management. As state agencies
that are adopting the "free market"
approach review the course materi-
als presented to them by vendors for
approval, they would do well to keep
this in mind. Examinations should be
structured so that if UST operators
were to simply take the exam with-
out any preparation, a large percent-
age of them would fail. If the training
is effective, then most UST operators
will pass the exam only after they
have taken the training. •

NOTE: If your state is doing something
you think is special with regards to oper-
ator training, let LUSTLine Editor Ellen
Frye know, and maybe it can be covered
in a future issue.

     Marcel Moreau is a nationally
 recognized petroleum-storage specialist
 whose column Tank-nicalhj Speaking is
    a regular feature o/LUSTLine.
  He can be reached at marcel.moreau® Ben Thomas was one of the
 first UST-operator trainers in Oregon
   and continues to provide operator-
 training services across the U.S. He can
  be reached at
    Marcel and Ben are partners in
     Petroleum Training Solutions,
  developing online operator-training
  courses for all levels of UST operators.

LUSTLine Bulletin 65 • June 2010
                                       IIISII  1011
   What's  in  Store  for  Tanks  and  Tank  Programs
                Over  the Next  Decade?—Part 2"
 by Ellen Frye
  I s we enter the second decade of this
millennium, it seems as good a time as
any to take a peek into ye aide crystal
ball in an attempt to fathom what is
clearly a transition into that great
unknown looming on the fuel-stor-
age-tank horizon, so that we can be
prepared to be prepared.
    Part 1 of this exercise appeared
in LUSTLine #64, March 2010. As
with Part 1, Part 2 has taken the form
of a series of questions formulated by a
Just Wondering	
If Will  regulators ever have a
standardized terminology and
protocol for evaluating UST sus-
tems test-data?

Regulators continue to face  many,
many challenges but one of the
things they can't lose focus on is the
need to make sure that the progress
made over the past 20 years isn't
tossed out the window. A big part of
the UST regulator's job is to review
facility records for various required
tests (e.g., cathodic protection, line
leak detectors, tank tightness) to
ensure that various operational sys-
tems are functioning as required.
   As we look ahead at the next
decade, we must ask ourselves: Is it
the role of the regulator to control the
quality of this testing?  Or, is the role
of the regulator simply  to ensure that
the testing gets done? If a test is not
done correctly, is it of any value?
   More frequent inspections and
stronger enforcement tools will help
ensure that more  of the testing and
monitoring required  in the rules
actually  gets done. But this does not
necessarily mean that testing is being
small group of industry and regulatory afi-
 cionados, including Patricia Ellis, Delaware
  NREC; Kevin Henderson, Mississippi
  DEQ; Richard Speise, Vermont DEC; Hal
   White, USEPA OUST; Carol Eighmey,
   Missouri PSTIF; Marcel Moreau, and
   Curt Johnson, Alabama DEM.  We have
   asked the questions and provided reasons
  for the questions, but we have not neces-
  sarily attempted to provide answers...
  maybe just some speculation. We welcome
 your thoughts and questions.
                                  performed correctly. Unfortunately,
                                  it seems as though testing, in general,
                                  is actually becoming worse as eco-
                                  nomic pressures drive things to be
                                  done quicker and cheaper.
                                     Regulators can't, nor should
                                  they, rely on the owner/operator to
                                  ensure that the testing is performed
                                  correctly. Even with Class A or B cer-
                                  tification,  operators typically don't
                                  know an automatic line-leak-detec-
                                  tor test that has been done correctly
                                  from one that has not. Unfortunately,
                                  they often pay the same amount of
                                  money in either case.
                                     Regulators  have  tradition-
                                  ally relied on a simple "pass/fail"
                                  approach  to  reviewing  testing
                                  records. If the person who conducted
                                  the test indicates that it passed, the
                                  regulators have accepted this as gos-
                                  pel. This approach has serious draw-
                                  backs—regulators need to be able to
                                  review the test records and determine
                                  for themselves whether or not the
                                  test was done correctly (the trust-but-
                                  verify doctrine of the Cold War). The
                                  only way to be able to do this is to
                                  mandate that test records document
                                  certain information. Standardized
  forms accomplish this, and training
  the inspectors is the first step.
  o fls interstitial monitoring be-
  comes  the norm instead of the
  exception, will there be enough
  new leak-detection technologies
  to generate sufficient leak-detec-
  tion evaluations and protocols to
  justify the continued existence of
  the  National Work Group on Leak
  Detection evaluations (NWGLD€)?
  Since pressure/vacuum systems
  came out five or six years ago, there
  has not really been anything new in
  interstitial monitoring to hit the mar-
  ket. The methods seem to be too sim-
  ple to justify any new technologies.
  All  the issues currently being
  addressed by the NWGLDE have to
  do with whether or not traditional
  systems are working with alternative
  fuels. Also, there seems to be little
  incentive to come up with new leak-
  detection technologies for single-
  walled tank systems, since this tank
  population will continue to decline
  in the next decade.

                                                                                   June 2010 • LUSTLine Bulletin 65
     "The people who review the facility compliance records must be able to
 recognize suspect test documents. These can then be referred to the person or
 persons within the regulatory organization who have the expertise to effectively
 critique the test data. Not necessarily to declare it as bogus but to at least raise
 the right questions so that the person conducting the test understands that there is
 someone who is scrutinizing their work. If they understand that there is someone
 with authority looking with a critical eye, they are much more likely to perform
 the testing correctly.
     "In my experience, most people want to do the right thing, for various
 reasons, they just don't know what that is. If there is not someone who knows
 what is really going on, then they have no impetus to learn themselves."
                                                       KEVIN HENDERSON
                                                 MISSISSIPPI DEPARTMENT OF
                                                   ENVIRONMENTAL QUALITY
b* Now  that we  have red-tag
authority to lock out  tanks that
are not in compliance, will compli-
ance rates go up for UST systems?
Fewer  leaks? find  how many
leaks are occurring from  compli-
ant USTs?

In the past, the enforcement process
could take months,  or  even years.
Now, thanks to our red-tag authority,
we can stop owners and operators
from making money from continued
use of out-of-compliance tanks. (See
Figure 1.) It would be nice if we had
some sort of equivalent for  LUST
non-compliance, but often,  tanks
are gone and there  isn't anything
to tag, so we have to go through
the old enforcement process with
warning  letters, Notice of Violation,
Secretary's Order, penalty orders,
and threats to take over investigation
and  cleanup and then cost-recover.
Maybe we just need big signs to post
on out-of-compliance  LUST  prop-
erties, stating  that violations are
threatening public health, safety, and
the environment (and a big fine for
removing the signs).
FIGURE 1. Red tag on fill pipe in Delaware.
tr What is a "green" gas station,
and will we ever get there?

There is a lot that gas stations can
do to improve their impact on the
environment and serve as public
showcases for all kinds of best man-
agement practices, such as control-
ling storm water and roof runoff,
recycling water from car washes,
reducing air-pollutant emissions,
using electricity generated by power
sources like solar panels and wind
turbines, where feasible, and using
building components made of recy-
cled materials. They can become
"transportation service  centers,"
where they not only pump gaso-
line/biofuels into auto fuel tanks,
they also service electric cars, bikes,
and motorcycles and other transport
modes such as bicycles, pedal cars,
and even weary walkers.
    But wait. If "green" means some-
thing that's environmentally friendly,
what's the greenest imperative at any
gas station? Wouldn't that be pre-
venting any and all vapor emissions,
fuel and oil spills and overfills, and
UST system releases? Wouldn't that
mean a zero tolerance for releases?
A release is an expensive proposition
and it's bad for the environment.
    Since gas stations are primarily
owned by smaller entities, is green
just too expensive to hope for? Larger
companies might do this, but might
it be too expensive for the little mom-
and-pops? In ten years will we finally
realize that spilling bad stuff into the
environment is too expensive?

tr Will we be conducting "greener"
cleanups,  using "sustainable"
remediation techniques?
The SURF "Sustainable Remedia-
tion White Paper" (see box on page
8) broadly defines sustainable reme-
diation as "a remedy or combination
of remedies whose net benefit on
human health and the environment
is maximized through the judicious
use of limited resources."
    Remediation decisions often
have a triple bottom line—environ-
mental, economic, and social inter-
ests. The rush to remediation is often
encouraged by regulatory policy, reg-
ulatory culture, statutes, public pres-
sure, and often the unwillingness of
all parties to recognize the limitations
of their own approaches. As a result,
repeated attempts at source remedia-
tion are not uncommon—each requir-
ing additional resources and energy
and each having additional negative
environmental consequences without
achieving the treatment objectives.
    For more  information about
green remediation, go to http:llwww.,
a USEPA resource for learning about
greening cleanups. The goal for the
site is to communicate with stakehold-
ers about initiatives related to greener
cleanups, lessons learned, success sto-
ries and updates on current develop-
ments and upcoming events.

t? Will we ever agree on how  much
INflPl we  can leave  behind?

Regarding light nonaqueous-phase
liquid (LNAPL), federal rule 40
CFR 280.64 (1988) states "remove
free product to the maximum extent
practicable as determined by the
implementing agency...." Federal
statute, state statutes/regulations,
policies, and guidance documents
range from:
• Remove all  detectable levels of
  LNAPL at all sites.
• A defined  measurable amount
  (0.01 ft.-l/8 in.) may remain.
• Guidelines are risk-based/site-
• Less stringent cleanups are
  allowed, based  on an  evolving
  understanding of LNAPL behav-
  ior (in many cases without for-
  mally adopting related rule or
  policy changes).

                 • continued on page 8

LUSTLine Bulletin 65 • June 2010
 I Transition from page 7
    Many of these rules were devel-
oped prior to the current state of
knowledge. Regulations generally
don't consider the fact that LNAPL
is potentially mobile only if the satu-
ration exceeds residual saturation.
After LNAPL releases are abated,
LNAPL bodies reach a stable con-
figuration, generally within a short
period  of time. Regulators and
cleanup consultants need to assess
the stability of dissolved plumes to
establish whether they are stable.
    At some  point, LNAPL ceases
to be mobile  and is just a residual.
Depending on composition, it may or
may not be contributing to a plume of
ground water contamination. Oppos-
ing philosophies maintain that since
we have many new technologies that
we didn't have early on, we should
be able to get more of the LNAPL out
of the ground than we could before.
But the question remains that if there
is no risk-based reason to remove it,
why go to the expense of doing it?
    See LUSTLine #64, "The Top 10
LNAPL Myths," and also go to:
•  http:llwww. itrcweb.orglteampublic_

t? Will  longer dissolved plumes
associated with ethanol/gasoline
fuel releases cause additional
problems, or have we done better
or enough to reduce release rates
to offset additional risk?

Only time will tell if we have  done
enough to offset any additional risk
posed by ethanol due to our progress
in reducing overall leak rates  from
tank systems. There are  concerns
that UST system compatibility issues
associated with  ethanol may cause
more, but perhaps smaller, releases.
In fuel releases  that contain etha-
nol, microorganisms seem to prefer
to feast on the alcohol first, allow-
ing the BTEX plume to move farther
along than it would if there were no
    With regard to fuel releases from
LUST sites, private water supplies
and small groundwater systems tend
to be more impacted by contaminants
than public water supplies because
there is little dilution. A study of
 SURF's "Sustainable Remediation White Paper" Is a Must-
 Read for LUST Program Personnel and Consultants
     The Sustainable Remediation Forum (SURF) authored a groundbreaking white
     paper titled "Sustainable Remediation White  Paper—Integrating Sustainable
     Principles, Practices, and Metrics into Remediation Projects" (edited by David E.
 Ellis and Paul W. Hadley). The paper was published in a special edition of the Summer
 2009 Remediation Journal, and is currently available at http://www.sustainablereme-
    SURF's primary objective is to provide a forum for various stakeholders in reme-
 diation—industry, government agencies, environmental groups, consultants, and aca-
 demia—to collaborate, educate, advance, and develop consensus on the application
 of sustainability concepts throughout the lifecycle of remediation projects, from site
 investigation to closure.
    The paper communicates SURF members' thoughts on incorporating sustain-
 ability principles into environmental remediation. It  promotes the use of sustainable
 practices during implementation of remedial action activities with the objective of bal-
 ancing economic viability, conservation of natural resources and biodiversity,  and the
 enhancement of the quality of life in surrounding communities. •
MtBE releases in New Hampshire
found that standards were exceeded
more often in private water sup-
ply wells. Contamination may be
especially problematic in areas with
sole-source aquifers or where water-
table levels are dropping due to pro-
longed drought.
    According to the USEPA, approx-
imately  15  percent of Americans
rely on their own private drinking
water supplies, and these  supplies
are not subject to USEPA standards,
although some state and local gov-
ernments do set rules to protect users
of these  wells (www.epa.govi'safewa-
ter/privateTvells/index2.html). Unlike
public  drinking water systems
serving many people, they do not
have experts regularly checking the
water's source and its quality before
it is sent to the tap.

$ Will institutional controls be
effective long-term environmental
stewardship mechanisms at LUST

Should we be leaving sites with con-
tamination so that future uses of
the land  must be restricted in some
manner? Even if (a big if) there are
effective tracking mechanisms and
notification  systems for sites that
have some sort of institutional con-
trol on land-use and there is good
coordination among agencies at dif-
ferent levels of government, where
does all of this get us long term? Do
we end up with a lot of "groundwa-
ter management zones" so that even-
tually you can't use the groundwater
for much of anything?
    Groundwater should be consid-
ered one of the most precious com-
modities on earth, but that's not how
it's  treated. What do we pass down
to our children and grandchildren?
Again, how much do we clean up,
and how much do we leave behind?

tf Will there be increased poten-
tial for vapor intrusion due to pro-
duction  of  methane associated
with new gasohol releases?

Gasoline leaks and spills at UST sites
happen, and with the advent of E10
(and the potential for E15), these
releases will contain a significant
amount of ethanol. Gasohol releases
may cause greater risks to indoor air
than traditional petroleum releases
due to the production of methane.
(See Figure 2.)
    At traditional release sites petro-
leum vapors migrating upward
toward a basement in the vadose zone
are quickly biodegraded by microbes
in the soil matrix. This occurs, primar-
ily, due to the prevalence of oxygen
in the pore space of the soil. At sites
where releases occur that have etha-
nol in the fuel, the ethanol is biologi-
cally broken  down into acetic acid.
Once all of the ethanol is degraded,
the  acetic acid is broken down into
methane. The biodegradation of the
ethanol consumes  available oxygen
and the methane, as it moves upward
into the soil matrix, displaces the oxy-
gen in the soil pore space.
    Without oxygen to promote bio-
logical breakdown of the benzene,

                                                                                   June 2010 • LUSTLine Bulletin 65
  •  	•'
FIGURE 2. Vapor intrusion cross-section.

as well as other components of the
petroleum vapors, these compounds
have greater potential to migrate
through the soil profile and into con-
fined spaces like basements, thereby
increasing the risk of violation of
indoor-air health criteria.
F Is indoor vapor inhalation ex-
posure a real threat? Or is the
"vapor intruder" a bogeyman?

As all good LUST managers know,
benzene and the "indoor inhalation
pathway" drive the majority of LUST
cleanups. States have used a vari-
ety of methods to analyze  this risk,
and most have relied heavily on the
Johnson-Ettinger model, developed
in 1991. It's 2010, and we've been
addressing this risk for 20-plus years.
What have we learned?
    In recent years, USEPA  and state
regulators have collaborated with
industry experts to review  available
research and the knowledge gained
collectively from tens of thousands
of tank-site cleanups. What conclu-
sions have we reached? Is it time for
a new model? In an era when finan-
cial resources and economic develop-
ment are evermore precious, are we
reaching reasonable conclusions that
achieve the right balance  between
protecting the public from undue
risk and site remediation?

I? Given the bleak  financial state
of state budgets, will state tank
funds continue to be the  primary
Financial Responsibility (FR) pro-
viders for UST owners/operators?

Or will USEPA and state regulators
have to require owners/operators to
use other FR mechanisms?

t? Where's the peak in peak oil?

Oil seems a finite resource, so peak
oil is in our future somewhere. But
will it be the next decade or the next
century? What happens to petroleum
(and thus the tank world) is largely
dependent on the price we pay at the
pump. The spike in 2008 prices made
a big impression on a lot of fuel users.
So what does the future hold? Here
are some of the competing factors:
• Gasoline consumption in China
  and India is going to go UP!
• Speculation in the markets
  (responsible  for the 2008 price
  spike?) may or may not be con-
  trolled by new rules.
           • Natural gas production in the U.S.
             is likely to increase dramatically
             because of shale gas production.
           • Oil production in Iraq is likely
             to increase dramatically as new
             fields are found and foreign oil
             development comes to fruition
             (unless unrest or politics puts the
             kibosh on this). China is the lead-
             ing developer of Iraqi oil.
           • How will Iraq fit in  with OPEC?
             Having a new large-volume player
             in the oil market will upset the
             current equilibrium on the supply
             side. What will happen then?
           • Assuming increased supplies of
             energy in both native natural gas
             and imported  oil, will the supply
             be ahead of, keep up with, or fall
             behind  the expected increase in
             demand? •
           Related reading: The Party's Over: Oil,
           War and the Fate  of Industrial Societ-
           ies by Richard Heinberg.
 USEPA Provides Recommendations on Lead
 Scavengers at LUST Sites
 In May, OUST Director Carolyn Hoskinson signed a memorandum recommending
 the investigation and cleanup of lead scavengers at LUST Sites. Lead scavengers,
 common additives in  leaded gasoline, pose risks to drinking water sources. The
 memorandum encourages states, tribes, and the USEPA Regions to:
 •When appropriate,  monitor and report the presence of lead scavengers in
   groundwater at LUST sites;
 •Analyze EDB and 1,2-DCA using EPA Methods with the appropriate detection
 • Remediate lead scavengers when such constituents could threaten a source of
   drinking water; and
 • Share information on the presence and remediation of these constituents.

 Not all LUST sites are potential candidates for lead scavenger investigation. Only
 sites at which leaded motor fuels were or are  currently stored are appropriate
 candidates. Both  off-road racing fuel and aviation gasoline (Avgas) are leaded
 fuels. LUST sites where these fuels have been or are still stored should generally
 be investigated for EDB and 1.2 DCA.  (See Table 1.)
 The  complete memo-
 randum is available at
 cat/leadscav. Go to "lead
 scavengers" and click on
 "Phase 3: Recommenda-
 tion for States, Tribes, and
 EPA  Regions  to Investi-
 gate and Clean Up Lead
 Scavengers When Present
 at Leaking Underground
 Storage Tank (LUST) Sites
 -May 2010." •
TABLE I   Summary of Recommendations
            forOn-Road Gasoline Sites
to sample and
analyze for EDB
and 1,2-DCA.
to sample and ana-
lyze for EDB and
1,2-DCA depen-
dent upon:
•UST's storage
•Threat to drinking
 water sources.
to sample and ana-
lyze for EDB and
1,2-DCA only at
sites where USTs
continue to store
leaded fuels (off-
road racing fuel,
aviation gasoline).
           1986-*	M996
              Years of Storage

LUSTLine Bulletin 65 • June 2010
Release, Remediate,  Repeat
     Just when one of our LUST sites
     had come within spitting distance
     of meeting its cleanup goal. ..after
22 years as an active LUST project...oh
no, a new release! Up to five feet of free
product has been discovered in the moni-
toring wells! ARRRRGH	

The site has been a LUST site since
1988, when a leak occurred around
a fill neck. Historically, up to several
feet of free product existed in the area
of the tank field, and by 2004, fol-
lowing several years of operation of
a pump-and-treat system, followed
by operation of product-only skim-
mers, the free product was no longer
    A  post-remedial  monitoring
phase followed to evaluate the con-
tinued natural attenuation at the site.
By 2007, we were down to one well
that slightly exceeded our Risk-Based
Screening Levels (RBSLs) for clos-
ing the site, and if we had entered
site-specific parameters, I'm sure we
would have met Site-Specific Target
Levels (SSTLs) in all of the wells (the
site is in the Piedmont, with finer-
grained soils than were used to gen-
erate our generic RBSLs).
    But  site closure was evidently
not meant to be. When the remedia-
tion consultant for the  site was on
site performing the regular quarterly
gauging and sampling event, he/she
encountered up to five feet of free
product in the monitoring wells.
    To add further complications, the
site had been sold in 2001, so we had
the former owner who was still on the
                       -Source of 2007
                        Gasoriol Release
FIGURE 1. "T" fitting under the dispenser where 2007 release occurred.
 hook for the 1988 release, and the new
 owner with a new release. We also
 had two sets of consultants for the

 What's Going On?
 The consultant for the current owner
 mobilized to the site and began con-
 ducting vacuum-truck events in
 wells with free product to minimize
 the spread. The source of the release
 was identified as a failure of a "T"
 fitting under the dispenser closest to
 the tank field (Figure  1). It appears
 that the ethanol in the gasoline may
 have dissolved the adhesive used to
 secure the "T" fitting; however, the
 cause of the failure was not verified
 by laboratory analysis. A portion of
 the release followed a preferential
                  pathway along
                  the  piping
                  run back to
                  the tank field,
                  which is where
                  the 1988 release
                  occurred, while
                  the other por-
                  tion mobilized
                  into the soil
                  beneath the
                  dispensers and
                  associated UST
                  tion of  inven-
                  tory records for
                  the site did not
                  show a discern-
                  able release
                  and the  line
leak detectors did not alarm. Initially,
it was thought that the 2007  release
was less than 100 gallons. The release
could have been going on for  as long
as three months, because that is the
time period between groundwater
monitoring events. If monitoring
had not already been underway at
the site, the release could have gone
undetected for a much longer period
of time. (See figures 2a, 2b, 2c.)

The Shades of Time
Two distinct types of free product
have been found at the site since the
new release. In the tank-field moni-
toring wells, the LNAPL column had
a gradual color change from dark-col-
ored LNAPL (1988 release) to light-
colored LNAPL (2007 release) (those

                                                                                  June 2010 • LUSTLine Bulletin 65
                                 May 21. 2007
  l«>(oiK«iti ATion (ontow
                                August 9, 2007
  Kocoritenli .111011 Cofitour
  1bl.ll BTEX IllgA)
                              November 30,2009
FIGURES 2A, 2B, 2C. Site diagrams show plume
size prior to 2007 release, shortly after discovery of 2007
release, and more than two years after 2007 release. Note
increasing size of plume and area of separate-phase hydro-
bailers must have looked
stunning!). In source-
zone monitoring wells,
the LNAPL column was
dark, indicating that the
NAPL was weathered
and likely from the 1988
release (Figure 3).
    Graphs  plotting
contaminant  concentra-
tions  and free  product
thickness through time
show that benzene and
BTEX levels have begun
to increase in downgra-
dient wells (Figures 4a
and 4b).  Free  product
observed in the wells
release is dark-colored
and highly weathered.
It is not known whether
the increase in dissolved
concentrations is primar-
ily due to migration of
the 2007 release to these
wells, or whether the
dissolved component
found in these wells is
resulting partially from the dissolu-
tion of residual product. The concen-
tration of ethanol in the 2007 release
(E10) would not be expected to cause
   Pilot  testing  conducted  in
November 2009 showed  that air
sparging coupled with soil-vapor
extraction  should be an  effective
remedial technology for the site. The
sparge well radius of influence was
nearly 75 feet, and the soil-vapor
extraction radius of influence was 50
feet. Ten paired air sparge/SVE wells
are planned. Due to the location of
a car  wash on-site (not shown on
the maps in Figures 2a,2b, and 2c.),
it will be necessary to obtain county
approval to locate the remediation
building or trailer along the property

A majority of the releases that we've
identified lately have been at facilities
that have previously experienced a
release, so we're superimposing new
contamination on residual hydrocar-
                • continued on page 12

                                                               RW-03      RW-04
FIGURE 3.  Top: Light-colored LNAPL from tank field wells (2007 release);
Bottom: Dark, weathered product from source zone wells (1988 release).

LUSTLine Bulletin 65 • June 2010
 i Release, Remediate, Repeat from page 11


— Benzene (mg/L)
	 BTEX (ug/L)
— • TBA(ugA)
» SPH(feet)

1 1
1 1
.\ i




    o 120000
    £ 100000
   - Benzene (ug/L)
	BTEX (ug/L)
   — TAMEIug/L)
    SPH (feet)
  FIGURES 4A and 4B.  MW-5 and MW-6 are located 30-50 feet downgradient of the
  2007 release. Weathered LNAPL was observed in MW-6 approximately one year after the
  release. Increases in dissolved concentrations of benzene and BTEX were also observed
  about one year after the release.
bon plumes that had become stable
or were shrinking. The presence of
ethanol in these new releases may
cause remobilization of the preex-
isting contamination, and the new
plumes can be expected to travel far-
ther because the aquifer is already
anaerobic and electron acceptors are
already depleted.

USEPA contractors recently used the
FOOTPRINT decision-support soft-
ware tool (available at http://www.
html) to estimate the possible impact

of higher concentrations of biofu-
els on the size of plumes that are
produced by releases from UST
systems. Forty Coastal Plain sites
from Sussex County, Delaware
were modeled.
   Depending on the decay rate
used (ranging from 20 mg/L/day
to 2  mg/L/day), the plume  area
for an E10 release increased from
13 to 189 percent over the plume
area for a release with no ethanol
in the gasoline. Increasing ethanol
content (up to E85) caused large
increases in plume area (up to
2,377% over a plume area with no
                                     ethanol and a decay rate of 2 mg/L/
                                         Research has shown that etha-
                                     nol can inhibit natural anaerobic
                                     biodegradation in benzene, toluene,
                                     ethylbenzene, and xylenes (BTEX)
                                     in groundwater, making for longer
                                     BTEX-compound plumes. Ethanol
                                     can also produce potentially explo-
                                     sive concentrations of hydrogen and
                                     methane gas at gasoline spill sites.
                                         As we see more and more sites
                                     where E10 (or higher ethanol concen-
                                     trations) is released in areas of preex-
                                     isting contamination, we can expect
                                     to see larger plumes, consequently
                                     putting downgradient receptors at
                                     higher  risk. These effects may be
                                     multiplied by the fact that we have
                                     equipment in the ground as compo-
                                     nents of our UST systems that we
                                     can't be sure is compatible with E10
                                     gasoline, much less higher concen-
                                     trations of ethanol. •

                                     I would like to acknowledge Environ-
                                     mental Alliance ofHockessin, Delaware
                                     for providing the photographs in this
                                                           Two E85 Dispensers
                                                           Now Have UL Listings
                                                           On June 25, the Underwriters Labora-
                                                           tory (UL) officially issued certification
                                                           for two dispensers for use with pre-
                                                           blended E85: Gilbarco Veeder-Root's
                                                           Encore  E85 and Dresser  Wayne's
                                                           Ovation Eco Fuel.
                                                               The issue of certifying E85 dis-
                                                           pensers was first raised in 2006 after
                                                           it became evident that no safety stan-
                                                           dard existed to test and certify high
                                                           ethanol fuel blends. At that time, UL
                                                           launched an extensive research ini-
                                                           tiative in collaboration with federal,
                                                           industry, and international experts and
                                                           advisory groups to better understand
                                                           the  corrosive  properties of ethanol/
                                                           gasoline fuel blends and to  develop
                                                           test  methodologies that  address
                                                           potential fire,  explosion,  and shock
                                                           hazards while addressing degradation
                                                           issues for products that distribute the
                                                           fuel blends up to E85.
                                                               Those certification requirements
                                                           were published in 2007, and the Gil-
                                                           barco and  Dresser Wayne dispensers
                                                           were the first complete systems to
                                                           have met all of those requirements. For
                                                           more information, contact Claire Kam-
                                                           mer at

                                                                        June 2010 • LUSTLine Bulletin 65
Those Alcohol-Loving Acetobacters at Work... or What?
fey Ellen Frye
 SENT:           Wednesday-, December 17-, EDDfl-, ^4:30  PN
 SUBJECT:       Some  odd corrosion and reactions
 FROM:           Steve Pollock
 I ran  across  this mess  in  a  sump today-  I've seen similar  messes-,  but this  was
 just  a little  different-  The environmental  consultant  I  was with  had never
 seen  anything  like  it  either- Kind  of mounded-,  with recently act ive-looking
 bubbles (hydrogen gas?)  on top-  Sort of like the sulfur-reducing  bacteria crud
 we  sometimes  find-, but  somehow a  little more pillowy-  The  consultant knocked it
 around a little  (with  his  neatly designed lid  lifter which he described as  the
 best  tool they've ever  purchased)-,  and I was waiting for the whoosh  of rotten-
 egg smell- Instead-,  it  was a vinegar smell-acetic acid-  Maybe in  the presence
 of  E1D-, our native soil/water bacteria now  prefer to chomp on the  ethanol first
 as  Acetobacters  or  just  as opportunistic bacteria loving an easier chain  (the
 alcohol) to digest-,  creating acetic acid—you  know-, like wine going  bad-  Or
 perhaps-, in the  presence  of  E1D-, these are  the  first bacteria to  feast at the
 buffet-, then  the vultures-, and then the oil metabolizers
 Anyway-, the acetic acid-,  bacteria-,  and some funky mold (or yeast?)  is tearing up
 the steel-, too-  Also note  that the  line leak detector  was  supposedly replaced
 this  past February with  a  Red Jacket FX-1V  series part-  Maybe•••though it sort  of
 looked like the  older-,  bigger XL's-  But if  it's new as of  Feb 'Dfl-,  it has had a
 hurting put on it- Oddly-,  the next-door STP sump was also  full of  water-, but not
 this  mess- And it was  clear  that the LLD had been replaced-
The facility that Virginia DEQ Petro-
leum Program Compliance Inspector
Steve Pollock described in his e-mail
above to co-workers had been sell-
ing E10 since its introduction to the
non-attainment areas of Virginia in
2006. "I was accompanied by a local
environmental consultant contracted
by the tank owner," says Pollock.
'The owner had also submitted a few
records prior to the day of inspection.
The inspection was fairly typical until
the consultant removed the Submers-
ible Turbine Pump (STP) containment
sump lid for one of the USTs.
   "The containment sump con-
tained a good deal of liquid, nearly
covering the STP's motor head. This
condition is not unknown to UST
inspectors. The surface of the liquid
was also covered in what appeared
to be a biological mat. I've run into
this condition before, where there are
iron-reducing bacteria; it seems to
occur in shallow groundwater areas,
particularly near swampy areas or
former swamps covered by suburban
   "But," notes Pollock, "this mat
appeared slightly  different from
others I've encountered—it
had a lighter  color and
what appeared to be larger,
recently formed gas bub-
   The consultant investi-
gated the situation by dis-
turbing the mat and liquid
with a pry bar. "I didn't stop
him quickly enough, so I
stepped back to avoid the
predictable rotten egg smell
of the  sulfurous metabolic
products  of the bacteria,"
says Pollack. "But, instead
of sulfur, the odor was vin-
egary—acetic acid. The con-
sultant removed the STP
sump lid from the adjacent
UST. It was also full of liq-
uid, but seemed to be just
clear water."
   Having received some of the
testing data ahead of the inspec-
tion, Pollock was aware that the line
leak detectors for these UST systems
had been replaced in February 2008
with new Red Jacket FX-lVs. This
certainly seemed believable for the
equipment in the sump with the clear
water,  but he had trouble believing

STP sump showing biological mat from a 2008 inspection
at an E10 facility.
       that the leak detector in the other
       sump was only eight months old.
       That leak detector appeared to be
       very old and corroded. But strangely,
       the STP head and even the visible
       electrical conduit appeared covered
       by an aggressive, almost mounding
       layer of corrosion, not typical of the
       corrosion Pollack had seen during
       previous inspections.
                     • continued on page 14


LUSTLine Bulletin 65 • June 2010
m Not for the Squeamish
from page 13

Could  Ethanol Be Involved?
"I began to think the recent testing
and button-up work for the USTs (the
facility was in the midst of a property
transfer) allowed for a small amount
of E10 to have been deposited in the
containment sump," says Pollock.
But he wondered if it might also be
possible, despite passing UST and
vapor-recovery testing, that small
weeps or vapor releases allowed for
the continuous  input of a miniscule
amount of E10  to the  containment-
sump environment from the one UST
but not the other. John Wilson, at
USEPA's National Risk Management
Research Lab in Ada, Oklahoma,
found it quite plausible that "etha-
nol is probably finding its way to the
water in the sump through a vapor
release pathway."
 Spill bucket from a 2010 inspection at an E10
 facility. Note the stalactite-type corrosion under
 the lid.
    USEPA did a study of two sites
in Northern Virginia that had MtBE
plumes in groundwater, even though
the tanks were tight. They estab-
lished that the MtBE in groundwa-
ter was coming from MtBE that had
escaped the USTs as vapors. Ethanol
and MtBE are similar in some of their
physical properties in that both have
a high vapor pressure from gasoline
(i.e., the proportion of ethanol or
MtBE in the vapors is greater than
the proportion of ethanol or MTBE
in the liquid gasoline), and both are
very soluble in water. So if  MtBE
vapors can escape an UST system
and dissolve in water, it is plausible

that ethanol can do the
same thing.
    Recalling  recent
ethanol research  and
its  degradation prod-
ucts, Pollock formed a
hypothesis, or at least a
guess. In the presence
of E10, were different
native bacteria selected
to degrade the product?
Are Acetobocter or other
opportunistic bacteria
favored to digest the
alcohol, creating acetic
acid as a waste product?
    At the time this con-
dition was observed,
John Wilson theorized   	
that the vinegar smell
could, indeed,  come from aerobic
degradation of ethanol to produce
acetic acid by Acetobacter. He noted
that it could also  be produced by
anaerobic bacteria that ferment etha-
nol to acetic acid and hydrogen gas.
"The  hydrogen gas might  be the
bubbles. Other bacteria can ferment
acetic  acid to carbon dioxide and
methane, and the carbon dioxide and
methane might also be in the bub-
bles," he said.
    The resulting problem for our
UST equipment seems to be that a
more-corrosive-than-expected envi-
ronment develops, attacking steel
and other  metals. "The  brew can
attack metals by a variety of meth-
ods," says Wilson. "Probably the
most important is that the  acetic acid
is a good electrolyte, making the
water more conductive of electricity.
The acetic acid also obviously makes
the water more acid."
    Once the liquid in both UST
sumps at the facility was pumped
out, and the fouled equipment was
cleaned, both Pollock and  the owner
asked for confirmation that the leak
detector was only eight months old.
The serial number was compared to
the invoice, confirming that a techni-
cian had installed a new leak detec-
tor earlier in the year.
    Following that inspection, Pol-
lock and his co-workers have kept an
eye out for similar  conditions. They
have continued  to encounter similar
scenarios and acetic acid odor at sites
in the Richmond area and near the
North Carolina border. The condition
has been noted  in STP sumps, spill
buckets, and around ATG probe ris-
An ATG probe area from a 2010 inspection at an E10 facility.
Notice the extreme corrosion throughout.
             ers. Some UST service providers have
             told Pollock of similar observations.

             What Are You Seeing?
             Clearly, more information is needed
             to determine exact causes and effects
             surrounding these and other phe-
             nomena taking place in UST systems.
             For those of you out there in the field
             doing facility inspections: Are you
             seeing anything like this? We'd like
             to help USEPA's Office of Under-
             ground Storage Tanks (OUST) gain
             a better understanding of potential
             impacts  to UST systems caused  by
             ethanol  and other biofuels. So if
             you have observed corrosion and
             that telltale  vinegar odor similar
             to that described by Steve Pollock
             and inspectors in a few  other states
             (New Hampshire is currently study-
             ing similar findings), please contact
             Andrea Barberry at OUST (Barbery.
    to let her
             know what you have seen.
                The  more OUST learns about
             what you are seeing in the field the
             better chance we have of understand-
             ing the physical and chemical chal-
             lenges UST systems face from new
             fuels. John Wilson has agreed to offer
             a test kit to the first ten people that
             send an e-mail to wilson.johnt@epa.
             gov. His lab will provide materials,
             including test strips to  allow them
             to measure the pH of the water in
             the sumps in the field at  the time the
             samples were collected, for 10 sam-
             ples in each kit. They will attempt
             to determine the concentration of
             ethanol (it may well be degraded)
             and the concentration of acetate and
             butyrate. •

                                                                             June 2010 • LUSTLine Bulletin 65
                    Plugging the  Rest  of the  Leaks
                    New Hampshire Aims for Comprehensive
                    Secondary Containment for New UST Systems
by Mike Juranty
    Secondary containment and leak
    monitoring have been required
    for all new UST installations in
New Hampshire since 1985; in 1997
that requirement was extended to
new product piping installations as
well. In spite of the secondary con-
tainment requirement, however,
these "modern" UST systems still
have releases. Leaks from modern
tank  systems were recognized and
brought to the forefront through the
work of Gary Lynn, New  Hamp-
shire Department of Environmental
Services (NHDES), and others who
demonstrated that methyl tertiary-
butyl ether (MtBE) was escaping in
the form of "vapor releases" from the
UST systems.
   Further forensic leak investi-
gation by Jason Domke at NHDES
has shown that other events, such
as UST overfills and "topping off"
motor-vehicle gas tanks at facilities
with Stage II vapor-recovery sys-
tems, can go unnoticed but result in
liquid-product releases from tank-
system components that  "don't
routinely contain product," are not
double-walled, and have no release
detection. These releases enter the
relatively porous pea-stone or sand-
bedding/backfill layer surrounding
the UST system. This layer acts as an
infiltration gallery of sorts that routes
any contamination into the ground-

Mechanisms for Releases at
"Modern" Facilities
NHDES, as well as most other state
tank  programs, identified the fol-
lowing  mechanisms for releases that
have  not been adequately addressed
in both its own rules and in the fed-
eral rules:
• Stage II vapor recovery systems
  and  "topping off" at the pump.
  Many gas station patrons like to
  get a little bit of extra fuel in the
tank or round off
their gasoline pur-
chase by  repeat-
edly activating the
gas nozzle after it
has automatically
shut itself  off. This
behavior can cause
liquid gasoline to
be drawn  into the
vapor path of the
nozzle and then
into the Stage II
vapor piping that
leads back to the
underground tank.
Product also enters
the Stage II piping
during the  periodic
testing of the vapor-
recovery  system
and by condensa-
tion of fuel vapors
in the below-grade
portion of  the pip-
ing. Releases then
occur through leaks
in the single-walled
UST  overfills.
Despite the wide-
spread use of over-
devices such as ball-
floats, drop-tube
shutoff valves (a.k.a.
and  electronic  	
alarms, overfills still
occur. Lack of routine maintenance,
incorrect overfill-device installa-
tion, use of inappropriate over-
fill devices for the type of tank fill
method, and old-fashioned human
"ingenuity" can and do result in
UST overfills. Many of these over-
fills can be  detected by the distinc-
tive spray  patterns  surrounding
Top: Typical ATG riser installation surrounded by the tank backfill.
Overfill events can leak from such unprotected risers and spill directly
into the tank backfill. Such releases can be prevented by locating all
risers within a collared sump.

Bottom: Typical ATG riser installation surrounded by the tank back-
fill. An overfill event popped the cap off the riser, and product leaked
into the tank backfill.  The release would have been prevented if the
riser was located within a collared sump.
               the tank vents but many more go
               unnoticed until inspection time or
               until a groundwater-contamina-
               tion spike is evidenced. Overfill
               releases occur through tank-top
               fittings such as fill risers that have
               corroded or loosened up over
               time, automatic tank gauge (ATG)
                            • continued on page 16


LUSTLine Bulletin 65 • June 2010
• NH and Secondary Contain-
ment from page 15

  risers and fittings (ATG caps can
  be blown off by the overfill event),
  and leaking single-walled vent pip-
  ing and vapor-recovery piping.
 Product was released from the vent cap dur-
 ing an overfill event. A leak in the single-walled
 vent line resulting from improper installation,
 corrosion, or movement of the vent riser would
 result in a product release into the backfill dur-
 ing such an overfill event. Gasoline vapors and
 vapor condensates can also be released from
 these leaking vent lines

•  Leaking spill buckets. Spill bucket
   covers are a tank's "front line of
   defense" against vehicular traffic.
   Repeated hits from snow plows
   and car and truck tires passing
   over the spill buckets can cause
   degradation of the  surround-
   ing  concrete, damage  to the spill
   bucket/concrete support ring, as
   well as the spill bucket and riser.
   Leaks from spill buckets and spills
   around the spill buckets then have
   a direct route into the tank bed-
                                     A tank equipped with a collar for attaching a full-depth sump. Such collared sumps provide sec-
                                     ondary containment and can be used to isolate tank risers and spill buckets from the tank backfill
How Can These Types of
Releases Be Prevented?
One method for preventing these
releases is to rely on the facility own-
ers, contractors, fuel suppliers, and
patrons to "do the right thing" once
they  have been educated on  the
proper procedures and requirements
for constructing, maintaining, oper-
ating, and servicing the facility, and
in the case of patrons, pumping gas.
But history has shown that it is pru-
dent to employ the complementary
approach of building a system that
will capture or at least minimize the
adverse effects of equipment failure
or human error.
   This approach has been partially
implemented in New Hampshire
and much of the country with rules
requiring secondary  containment
        and leak detection for new
        tanks and  product piping,
        low-point piping  sumps,
        dispenser sumps, and spill
        buckets. NHDES now plans
        to complete  that  contain-
        ment system by requiring
        secondary containment and
                                            Damage to a spill-bucket support ring.
                                            Such damage allows surface spills to
                                            enter the tank backfill.
release detection for vent and vapor-
recovery piping, as well as sumps
connected to tank collars (a "collared
sump") wherever a tank-top penetra-
tion is made, at all new UST installa-
tions. Tank-top penetrations include
submersible pumps/product piping,
ATGs, vents, vapor-recovery connec-
tions, interstitial risers, and fill risers
with spill buckets.
    The additional overall cost of
installing double-walled (versus sin-
gle-walled) vent and vapor piping
and collared sumps (versus manway-
connected sumps, sumps mounted
at the top of a tank riser, or risers
without any sump at all) at new
UST installations is negligible com-
pared with the costs associated with
groundwater cleanup and business
down time that would result from a
product release. Collared sumps may
even provide an operational cost sav-
ings as they allow repairs of system
components such as spill buckets
and tank risers to be made without
the need to break concrete and exca-
vate to the tank top. •

  Mike Juranty is supervisor of the Oil
 Compliance Section of the New Hamp-
  shire Department of Environmental
 Services. He can be reached at michael.

                                                                               June 2010 • LUSTLine Bulletin 65
Observations from an UST Compliance Service Provider
I    read Marcel Moreau's article, "If I Had to Choose
    Just One Method of Achieving UST Operational
    Compliance...," in the March 2010 issue of LUST-
 Line with great interest. I have, for the last 18 years,
 operated a company providing UST compliance ser-
 vices to tank owners.
    Mr. Moreau advocates an annual, thorough check
 of the entire fueling system from top to bottom, includ-
 ing operability checks of the various components. Not
 bad, but is it good enough? I think not, based on my
 experience in the field.
    I have the oil  changed in my company vehicles
 every 3,000 miles. While the mechanic changes the oil
 he checks the belts, hoses, brakes, along with various
 fluid levels—transmission, coolant, brake...even wind-
 shield washer fluid—and alerts me to any potential
 problems. I've found it is easier and cheaper to address
 problems early rather than when I'm broken down on
 the side of the road. Like the TV  ad says: "You can pay
 me now or you can pay me later...."
    Just as most of us get our oil changed every 3,000
 miles, I advocate a monthly visual check of all the com-
 ponents of an UST  system. This will allow you to iden-
 tify small problems early enough to keep them from
 becoming major issues. Let me give you some examples
 based on my experience in the field.
    I probably check and clean around 500 spill-con-
 tainment manholes every month. Not one of them is
 clean and dry from one monthly visit to the next. I reg-
 ularly find cracks or holes in those plastic spill buckets,
 caused by movement and rough handling of the equip-
 ment by transport drivers, I suspect. Another problem
 area is where the spill-containment "boot" is clamped
 to the riser—these  clamps break or come loose. If you
 catch these problems early you can prevent ongoing
 leakage into the surrounding backfill and, in North
 Carolina at least, use an approved method to repair
 the spill bucket, rather than face a minimum $6,000
 expense to replace it with a monitored double-walled
 spill-containment manhole. I cannot count the number
 of gauge sticks I've removed from overfill-prevention
 valves; occasionally I've even found these valves miss-
 ing entirely from one monthly inspection to the next.
   At one site I visit there's an old mechanical line leak
detector in the submersible turbine pump (STP) sump
and a filter in the under-dispenser containment (UDC)
sump. On one inspection I see that these contain a bit of
product, and if the sump fills with water, the fuel could
leak out. Fuel is dripping from the new filter, or meter.
Smells like gas around that STP, and I notice some soil
staining I didn't see last month. Inside, the ATG shows
a probe is out. One of the ELLDs is no longer perform-
ing a 0.1 or 0.2 gph test because the STP is running con-
stantly. The impressed current rectifier box is reading 0
volts and amps because someone flipped the breaker,
or a fuse blew after a thunderstorm. Jane is supposed
to call the office about these problems, but she got busy
with paperwork, and forgot. And so it goes...
   So I choose a hybrid monthly visual inspection by
a qualified third party for UST compliance. Just as you
can prevent a lot of expensive auto repairs with regu-
lar scheduled preventive maintenance, you can avoid
expensive repairs and UST compliance issues with a
monthly scheduled visual check of your UST system. I
simply do not think that an annual inspection/opera-
tion check is often enough.
   Do you  have the discipline, or the staff with
enough time to do the monthly check?  Probably not.
Are you worried about your UST operator filling out
his checklist in the office instead of actually looking
under the manhole covers and inside the dispensers?
You should be. It's cold outside, those  manhole cov-
ers are awfully heavy, and last month he couldn't get
the regular cover off at all! He broke the key off in the
door to dispenser 1-2, and he doesn't have another one.
After the monthly check he smells of gas and just wants
to go home and take a shower and change. He works
9-10 hours a day as it is, without this added burden.
Get a  qualified third party to do it. Get  someone who
knows about petroleum-handling equipment as well as
the UST regulations. He needs to "think" like a  regula-
tor while performing the monthly inspection. •

                                Charles Broadf oot
                 Charles Broadf oot & Associates, Inc.
                                 Fayetteville, NC
UST Operational Compliance? Keep It Simple!
   In his article, "If I Had to Choose Just One Way of
   Achieving UST Operational Compliance," LUST-
   Line #64, Marcel Moreau claims that by having an
 annual operational inspection by a qualified service
 technician, "one phone call does it all." He says the UST
 operator doesn't need to remember all the things he is
 responsible for—like line leak detector testing, ATG
 maintenance, crash-valve checks, etc., etc. Well what is
operator training for? Who is ultimately responsible for
compliance? The service provider? No, it's the operator.
   I agree with what Marcel is promoting, but opera-
tors need to know their system to ask the right ques-
tions and not get snowed by the low-cost service
provider. Of course I know Marcel knows that. The
problem is in most states operator training is the law,

                               • continued on page 18

LUSTLine Bulletin 65 • June 2010
                   et-a continue!
    UST Operational Compliance? Keep It Simple!
  not annual inspections by qualified technicians. Also,
  if most operator training will simply be a test, I expect
  that Marcel's suggestion would be a good one.
      However, we are dealing  with mostly mom and
  pops and they need to understand what is necessary.
  I see too many sites where the method of leak detec-
  tion could be less costly, but the owner is talked into
  purchasing, for whatever reason, a more expensive
  method. Now that, in most cases, we require secondary
  containment for new tanks and  piping, why would you
  need to do any tank leak detection outside of monitor-
  ing the interstice?
      I think that the best way to address this and other
  issues is to design systems that require little oversight.
  Use suction systems on piping,  use double-walled
  tanks, install piping and tanks  that do not require any
  cathodic protection, and use spill buckets with second-
  ary containment.  If these features were in place, you
  would need service providers primarily for fixing card
  readers and the like.
      Most  mom and pops  don't have the resources to
  respond to water alarms in sumps and other nuisance
                 issues associated with more complicated monitoring
                 systems. In some of our rural areas it costs $600 just
                 to get to the location before any work is done. In fact,
                 with many systems, even if inspectors identify prob-
                 lems such as compatibility issues, cracks in piping, or
                 that yellow piping that is falling apart, our regulatory
                 hands are tied to get them replaced because they are
                 not leaking.
                    So  why require annual  inspections by service
                 providers when we do not have the staff to see if the
                 work that is done will help the owner meet the regula-
                 tions? We only visit the sites every three years, and by
                 the time we get back, 30 percent of the operators will
                 be someone else, and they need to be trained so they
                 understand that they are responsible for the day-to-day
                 operations of that facility.
                    So, if I  had to choose just one way of  achieving
                 UST operational compliance, it would be to Keep It
                 Simple! •

                   Rickjarvis, Idaho DEQ UST/LUST Program Coordinator
Verification Testing of ATG Performance  for
Ethanol-Blended  Fuels
     The USEPA Office of Research
     and Development's Environ-
     mental Technology Verifica-
tion Program (ETV), Advanced
Monitoring Systems (AMS) Center,
operated by Battelle, is developing
a test plan to assess automatic tank
gauging (ATG) systems for detect-
ing leaks from USTs using various
ethanol blends. The intent is to col-
lect unbiased data concerning the
performance of leak-detection tech-
nologies with ethanol blends. It is
important to understand the per-
formance of ATGs when used with
ethanol-blended fuels because of the
differences in chemical and physical
properties between petroleum and
ethanol,  specifically the difference in
their miscibility with water. The test
plan is being developed in collabora-
tion with the National Work Group
on  Leak Detection  Evaluations
(NWGLDE), USEPA Office of Under-
ground Storage Tanks (OUST), and
other stakeholders. ATGs are the first
in a series of planned leak-detection
technology assessments. ATGs will
be tested first since they are the most

widely used leak-detection method
in the United States.
   Over the past six months, the
AMS Center has formed a techni-
cal stakeholder panel and a vendor
panel to provide input to the test
plan. These panels consist of repre-
sentatives from industry associations,
state and federal governments, and
users. Panel constituents include the
Underwriters Laboratories, Renew-
able  Fuels Association, Petroleum
Marketers Association of America,
Oak  Ridge National Laboratories,
NWGLDE, USEPA Regions 4 and
10, 12 states (WI, NY, TN, MA, CA,
MS, AL, NH, UT, CT, DE, MI), and
the U.S. Army Environmental Com-
   Panel  discussions  have been
held, and a draft test plan has been
written. The plan is currently going
through a peer review process to
establish an unbiased  evaluation
of the performance of this particu-
lar technology category. During the
coming months, the AMS Center
will solicit collaborators and vendors
to participate in technology testing
through this third-party testing pro-
cess. Depending on the scope of the
test plan  and vend or/collaborator
interest, testing is expected to start
in late 2010. For more information on
the ETV AMS Center, visit the web-
site at
etv/center-ams.html. For specific inqui-
ries about this verification test, con-
tact Anne Gregg at Battelle (gregga® or 614-424-7419). •
  August 1985/Bulletin #1 -
   June 2010/Bulletin #65

      The LUSTLine Index
     is ONLY available online.

        To download the
      LUSTLine Index, go to
   and then click on LUSTLine.

                                                                                June 2010 • LUSTLine Bulletin 65
Director, USEPA's Office of Underground Storage Tanks

What's New  at USEPA?

   It's been over a year since Administrator Lisa Jackson
   took on the job of leading the USEPA under the Obama
   Administration. So what's new and different under this
leadership? And how is  it playing  out in our tanks pro-
    Earlier this year, Administrator Jackson  announced
seven priorities for USEPA, underscored by three core val-
ues for how we are to go about our work (see text boxes
priorities-for-epas-future/}. She also said that she expected
each of us at USEPA to consider ourselves not just within
the scope of our individual programs,  but as one united
USEPA committed to working together to achieve our
mutual goals.
 USEPA's Priorities
 • Taking action on climate change
 • Improving air quality
 • Assuring the safety of chemicals
 • Cleaning up our communities
 • Protecting America's waters
 • Expanding the conversation on environmentalism
    and working for environmental justice
 • Building strong state and tribal partnerships
                      USEPA's Core Values
                      • Science
                      • Transparency
                      • The rule of law
    Each of us has been asked personally to consider how
the work we do and the work of our programs serve to fur-
ther the agency's mission.
    It's obvious that the national underground storage tank
(UST) program's ongoing work to prevent and clean up
UST releases supports three of these Agency priorities—
cleaning up our communities, protecting America's waters,
and expanding the conversation on environmentalism and
working for environmental justice.
    The last, and arguably the greatest, priority—building
strong state and tribal partnerships—is one that is inter-
woven into the fabric of all we do. Since the beginning of
the UST program, we have embraced our relationship with
state, territorial, and tribal UST partners, and indeed with all
our program stakeholders—from  regulated tank owners,
to equipment  manu-
facturers, to  service
providers, to affected
communities. For me
personally, these relationships are truly the most rewarding
part of being in the UST program.

To Further USEPA's Priorities, OUST Is
Involved in Specific Initiatives
Within  USEPA's Office of  Solid Waste and  Emergency
Response (where OUST resides along with such sister pro-
grams as Superfund, Brownfields, Hazardous and Solid
Waste,  and Emergency Response), OUST has embraced
and become a part of several cross-OSWER and  cross-
Agency initiatives. Below are five examples of where we're
doing our part to overcome the individual, narrow stove-
pipes, or spheres of interest, within which we often oper-
ate. I don't know if our stovepipes are built out of straw,
sticks, or bricks, but we're huffing and puffing  at them and
maybe someday we'll blow them all down.

USEPA's Office of Solid Waste and Emergency Response
(OSWER) issued its community  engagement initiative,
released a proposed action plan—which  presents prin-
ciples, goals, and objectives for community engagement
—and solicited feedback from community stakeholders
and the general public. On May 20, 2010, OSWER released
a detailed implementation plan, listing specific actions to
enhance community engagement (see
engagementinitiative). OSWER is committed to reaching out
to all stakeholders so they can meaningfully participate in
government decisions regarding land cleanup, emergency
preparedness  and response, and hazardous  substances
and waste management.
    How is OUST involved? While we recognize that states
and territories implementing the UST program often engage
with communities above and beyond that  required in the
federal  UST regulations, OUST is examining current prac-
tices, identifying best practices, and evaluating  ways the
UST program currently engages with communities. Over
the coming months, we will be developing materials about
community engagement in the context of the UST program,
discussing it in September at the National Tanks Conference
in Boston. We ask that you share with us your thoughts and
comments. For more about OUST's work on community
engagement, contact Barbara Grimm-Crawford at grimm- or 703-603-7138.
                                 • continued on page 20

LUSTLine Bulletin 65 • June 2010
  MESSAGE FROM CAROLYN HOSKINSON continued from page 19
   • INTEGRATED CLEANUP - OSWER's integrated
   cleanup initiative is a strategy to integrate and leverage
   land cleanup authorities to address a greater number of
   contaminated sites, accelerate cleanups, and put these
   sites back into productive use while protecting  human
   health and the environment.  (See
   integratedcleanup.htm for more information.) OSWER is
   currently working on an implementation plan for the inte-
   grated cleanup initiative.
       OUST's backlog characterization  study and petro-
   leum brownfields projects clearly fit within the integrated
   cleanup initiative's objectives of working to advance clean-
   ups; enhance partnerships between cleanup programs,
   other agencies, states, tribes, and local governments;
   and  link cleanup and revitalization efforts. For more about
   OUST's work on the integrated cleanup initiative, contact
   Sue  Burnell at or 703-603-9231.

   launched  the RE-Powering America's Land initiative to
   explore opportunities for siting  renewable energy on
   potentially contaminated land and mining sites (see www. USEPA and the Department of Ener-
   gy's National Renewable  Energy Laboratory (NREL) are
   collaborating on projects  to evaluate potential opportuni-
       NREL's investigation for the UST program is exploring
   opportunities to site or otherwise support the infrastruc-
   ture for alternative-fuel vehicles. Because former gas sta-
   tions are often small in size, energy-supply facilities may
   be difficult to site there; but because they are located near
   traffic intersections and other heavily trafficked routes, an
   alternative-fuel-vehicle infrastructure may present unique
   ways for petroleum brownfields sites to contribute to the
   nation's use  of alternative fuels and renewable  energy.
   USEPA expects to release  a report summarizing the inves-
   tigation in winter 2011. For more about OUST's work on
   RE-Powering America's  Land, contact Deb Steckley at or 703-603-7181.

   • URBAN WATERS - USEPA recently launched an
   urban water initiative, a component of Administrator Jack-
   son's priority to protect America's waters. The goal of this
   initiative  is to restore  and protect urban water bodies by
   engaging  communities in activities that foster increased
   connection, understanding, and ownership of their waters
   and  surrounding land. Urban  environments, particularly
   in disadvantaged communities, are often dominated by
   impervious surfaces, industrial facilities, and abandoned
   or vacant, often contaminated,  lands.
       OUST is participating  in a cross-agency workgroup on
   this  initiative. We plan  to involve state and tribal UST part-
ners in activities that support leaking UST-system cleanup
and petroleum brownfields reuse and that focus on the
restoration and protection of urban waters. USEPA intends
to make a draft strategy available for stakeholder review
in late spring. The agency also plans to hold a forum for
stakeholder comment and input. For more about OUST's
work on the urban waters initiative, contact Deb Steckley
at or 703-603-7181.

  AREA-WIDE  PLANNING - USEPA's Office of Brown-
fields and Land Revitalization is piloting a program that
will provide communities with grants to develop area-wide
plans, which will help in assessing, cleaning up, and  reus-
ing brownfields. The goal of the area-wide planning pro-
gram is to work in partnership with local communities to
help create a shared vision for brownfields-impacted areas
—neighborhoods, districts, city blocks, or corridors—and
to ensure that brownfields assessment and cleanup  deci-
sions include planned reuse for the sites and support area-
wide revitalization strategies. USEPA will share information
about lessons  learned with stakeholders nationally. See
text box for information  about the request for proposals.
  Area-Wide Planning For Brownfields
  • Approximately $3.5 million available ($175,000 per
    project) to provide money and technical assistance
    for 20 pilot projects in brownfields-impacted areas,
    such as neighborhoods, districts, city blocks, or
  • Assistance will enhance area-wide  planning and
  • Request for proposals issued March 30
    Proposals were due June 1, 2010
  • Awards anticipated in August 2010
    Proposal available on  EPA's Web site: www.epa.

    OUST is supporting this  effort inasmuch as many
brownfields are impacted by petroleum, much of it from
leaking USTs at old gas stations. In addition, many states
and others have already been pursuing area-wide efforts,
such as Route  66 in the Southwest,  Colorado Historic
Revitalization  Initiative, Tamiami Trail in  Florida, National
Historic Voting Rights Trail from Selma to Montgomery in
Alabama, Route 99 in California, I-5 in Oregon  and Wash-
ington, and many more. For more about OUST's work on
area-wide planning, contact Steve McNeely at mcneely. or 703-603-7164. •

                                                                               June 2010 • LUSTLine Bulletin 65
OUST Issues  a Revised  "Short List"  of Potential

Changes to  UST Regulations
      Two years ago the USEPA Office of Underground Storage Tanks (OUST) started the process to consider changes to the
      UST regulations to better protect the environment and to improve implementation of the program. After considering
      input from a wide variety of stakeholders, in June 2009 OUST shared a "short list" of issues it planned to evaluate
further. After considering the costs, benefits, and technical feasibility of the possible changes,  OUST has now revised the short
list. Below is the current list of issues OUST plans to continue to move through the USEPA  regulatory process. This list may
change further as OUST navigates the regulatory process. OUST hopes to publish a proposed rule in the federal register for
public comment this coming winter.
Release Prevention
• Operation and maintenance (O&M) - Includes over-
  fill-functionality testing, walk-through checks, spill-
  bucket testing, and integrity testing for interstitial

• Ball floats - Eliminate flow restrictors in vent lines as
  an overfill device on new systems and when overfill
  is replaced.

• Repairs
  - Address repairs and secondary containment - If
    primary or secondary wall is fixed, must verify
    structural integrity of the interstitial space before
    returning tank/piping to service.

  - Revise repairs section - Include non-release repairs
    and requirements/testing. This will also require
    re-evaluating repair definition and disassociating
    repair from release.

Release Detection
• O&M - Walk-through checks and periodic opera-
  tional checks and testing (i.e., automatic tank gauge,
  probes, sensors, line leak detectors, and alarms).

• New technologies - Incorporate  new technologies
  with applicable performance standards (i.e., statisti-
  cal inventory reconciliation (SIR), continuous in-tank
  leak detection systems (CITLDS)).

• Suspected releases - Address interstitial alarms
  with regard to section 280.50 "Reporting of Suspected
• Leak-detection methods - Phase out groundwater
  and vapor monitoring as leak-detection methods.

• Update Regulations to acknowledge 1998 deadline
  has passed.

• Require closure of lined USTs that fail periodic
  inspection and cannot be repaired.

• Update tank and piping sections for new technolo-
  gies - include clad and jacketed tanks, flexpiping.

• Require revised notification forms when ownership
  changes at the facility.

• Make technical corrections (e.g., update standards,
  correct typos).

• Address alternative fuels and compatibility.

• Exclude USTs containing radioactive substances.
• Exclude emergency generator USTs at nuclear power
  generation facilities regulated by NRC.
• Fully regulate emergency generator USTs.
• Regulate airport hydrant systems with alternate
  release-detection requirements.
• Regulate field-constructed USTs  with alternate
  release-detection requirements.
• Regulate wastewater treatment tanks. •
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 Phone: (978) 323-7929 • Fax: (978) 323-7919 • •

LUSTLine Bulletin 65 • June 2010
 FAQs from the NWGLDE
 ...All you ever wanted to know about leak detection, but were afraid to as
  Continuous Leak  Detection  Methods
  In this LUSTLine FAQs from the National Work Group on Leak Detection Evaluations (NWGLDE), we discuss the differences
  between the types of continuous leak detection methods that are available for detecting leaks from single-walled underground
  storage tank (LIST) systems. Note: The views expressed in this column represent those of the work group and not necessarily
  those of any implementing agency.
 Lj. What are the different types of continuous leak-
     detection methods being used to detect leaks in
     single-walled USTsystems?
 A. The most common type of continuous leak-detection
     method being used today is Continuous Automatic
     Tank Gauging. This method uses a probe to collect
     product-level and temperature data continually and
     software designed to identify time intervals when
     there is no activity in the tank to ensure that the data
     are stable enough for analysis. An algorithm then
     combines data from a number of these stable periods
     until there is enough evidence to make a determina-
     tion about the leak status of the tank. This method
     functions like a static automatic tank gauge (ATG)
     test, except that it does not require the tank be taken
     out of service for a set period of several hours when-
     ever a test is to be performed.
     The method  is designed to meet the USEPA monthly
     monitoring performance standard of detecting a leak
     of 0.20 gallon per hour with a 95 percent probability
     of detection and no more than a 5 percent possibility
     of a false alarm. Like the static ATG test, this method
     only evaluates the tank vessel itself. It is widely used
     in locations where monthly static ATG testing would
     be disruptive to business but the tank still has occa-
     sional periods of inactivity. Vendors such as Dresser
     Wayne Europe (TIG ATG System), EBW (AutoStik
     with SCALD), Hectronic GmbH (Optilevel CLTLDS),
     OMNTEC (OEL with CITLDS), OPW (EECO and
     Galaxy ATG Systems), Simmons (Tank Manager
     with CITLDS), Veeder-Root (ProMax and ProPlus
     with CSLD),  and Franklin Fueling  (TS with SCALD)
     manufacture Continuous Automatic Tank Gauging
     Another continuous leak detection method, Con-
     tinual Reconciliation, uses an onsite industrial
     computer to retrieve data from pump controllers
     associated with the point-of-sale system as well as
     from the ATG. The method develops an ongoing
     record of fuel inventory observations by pulling
     together sales data every time a fuel transaction is
     completed, and simultaneous tank-level and prod-
     uct-temperature observations from the ATG. It uses
     algorithms similar to those used for statistical inven-
     tory reconciliation (SIR). Data from delivery records
     can be recorded, but the actual volumes of deliveries
     to the tanks can also be independently calculated.
     When the method's algorithms analyze the data, a
     very accurate picture emerges of the product activity
in the tank (or tanks), and a loss, if present, becomes
apparent. Operational issues such as theft, miscali-
brated meters, blending problems, and delivery dis-
crepancies can also be determined. In addition, this
method may identify sudden or unexpected losses
of product from the tank vessel, pressurized lines, or

This method is also designed  to meet the USEPA
monthly monitoring performance standard of detect-
ing a leak of 0.20 gallons per hour with at least a 95
percent probability of detection and no more than a
5 percent probability of a false alarm. The only exam-
ple of a continual  reconciliation method  currently
appearing on the NWGLDE list is PetroNetwork S3
from Warren Rogers Associates, Inc. PetroNetwork
S3 allows a combination of monitoring data  from
both static and dynamic operations of the tank to be
combined to monitor the tank system for a tank or
line leak. (See LUSTLine Bulletin #56 [August 2007]
article "Continual Reconciliation Applications for
Active Fueling Facilities" for additional information
about this system.) PetroNetwork S3 is used widely
at high-throughput locations where there is no down
time for static ATG testing or where continuous auto-
matic tank gauging does not have sufficient quiet
time to collect sufficient data to determine a monthly
leak detection result.

The Automatic Monthly Inventory Control method
is a third method of continuous leak detection. This
method uses continuous inventory monitoring as a
tank-management tool, both for business and inven-
tory. The Business Inventory Reconciliation (BIR)
system by Veeder  Root and  Reconciliation System
by Incon are two examples of this type of method.
To date, neither vendor has developed an automatic
monthly inventory  control method that meets USEPA
requirements for monthly manual inventory moni-
toring, either alone or combined with another leak
detection method. These two systems are marketed
as business management tools while providing an
automatic way to meet daily inventory records and
monthly inventory reconciliation requirements.

The systems use the concept of inventory control
by adding the variance of 130 gallons to the gallons
pumped after dividing the gallons pumped by 100.
They then compare the overage and shortage of the
month with the leak-check result. These methods are
not third-party certified. Whether to accept the use of
                            • continued on page 23

                                                                                  June 2010 • LUSTLine Bulletin 65
FAQs... continued from page 22
    these systems as part of a release-detection method,
    either alone or in combination with other evaluated
    release-detection methods, is ultimately the decision
    of each implementing agency. •

About the NWGLDE
The NWGLDE is an independent work group comprising ten members,
including nine state and one USEPA member. This column provides
answers to frequently asked questions (FAQs) the NWGLDE receives
from regulators and people in the industry on leak detection. If you have
questions for the group, please contact them at
 NWGLDE's Mission
 • Review leak detection system evaluations to determine if each evalu-
  ation was performed in accordance with an acceptable leak detection
  test method protocol and ensure that the leak detection system meets
  EPA and/or other applicable regulatory performance standards.
 • Review only draft and final leak detection test method protocols sub-
  mitted to the work group by a peer review committee to ensure they
  meet equivalency standards stated in the U.S. EPA standard test pro-
 • Make the results of such reviews available to interested parties.
 from Robert N. Renkes, Executive Vice President, Petroleum Equipment Institute (PEI)

    In the last issue of LUSTLine (#64), I reported that
    PEI held a meeting earlier this year at USEPA
    headquarters with various industry and govern-
 mental stakeholders seeking input on what seemed
 to be an abnormal number of reports of excessive
 rust and other damage to equipment in ultra-low-sul-
 fur diesel (ULSD) service. The result of that meeting
 was to develop a screening survey that would go out
 to industry and state UST inspectors in an effort to
 understand the extent of the corrosion in ULSD stor-
 age and dispensing systems.
     The month-long survey was hosted by PEI and sent
 to North American tank owners, fuel suppliers, equip-
 ment service providers, equipment manufacturers,
 tank/ equipment regulators, cargo tank motor-vehicle
 owners, and others in March/April of 2010. Nearly
 1,200 people responded and some findings from the
 survey were quite revealing:
 •  496 (42 percent) of respondents reported increased
    equipment-related issues of one kind or another
    after introduction of ULSD.
 •  These respondents identified close to 5,000 loca-
    tions with apparent ULSD-related problems.
 •  Reported problems were spread widely across the
    United States and Canada, rather than being con-
    fined to a particular geographic region.
 •  Only 124 (12 percent) of survey participants were
    service providers. Tank owners (including fuel
    suppliers who may also own tanks) accounted for
    829 of the responses (69 percent). Six percent of the
    respondents were either tank or equipment inspec-

     Notably, 449 survey participants gave additional
 comments about  their experiences with ULSD. The
 problems mentioned most frequently were:

 •  Filters clogging/requiring more frequent replace-

 •  Seal/gasket/O-ring deterioration
• STP replacement/column pipe wear/motor prob-
• Tanks rusting/leaking (includes fuel tanks on vehi-
• Meter failure
• Line leak detectors damaged or broken
• Automatic nozzle shutoff failure/ shorter lifespan
• Tank probes malfunctioning
• Check valves not seating
• Shear valves not sealing/ failing tests
• Swivels failing/ shorter lifespan
• Dispenser leaks/failure/premature replacement
• Solenoid valves clogged/failing
• Corrosion on the riser pipe
• Pipe failure

    On April 8, 2010, the stakeholders gathered again in
Washington, D.C., to discuss the survey results and plan
next steps. At that meeting, the consensus was that while
the  preliminary survey uncovered a variety of apparent
ULSD-related issues, the results were inconclusive as to
the  potential causes  of these issues. The meeting ended
with the Clean Diesel Fuel Alliance (CDFA) agreeing to
head future efforts to understand the nature and deter-
mine the causes of the problem.
    The CDFA Steering Committee met May  19 and
agreed to develop a tank-maintenance guidance docu-
ment and post it on the CDFA website (www.clean_diesel.
org). In addition, the  committee will seek a consultant to
assist in determining the scope and nature of the issues
associated with the storage and dispensing of ULSD. The
CDFA hopes to have more information on which to act by
the  end of the year.
    The ULSD problem will be discussed this Septem-
ber  at the National Tanks Conference in Boston. A more
detailed report on the survey results is available at wima. •

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