New England Interstate
Water Pollution Control
Commission
www.neiwpcc.org/lustline
116 John Street
Lowell, Massachusetts
01852-1124
Bulletin 69
December 2O11
LUS.T.UNE
A Report On Federal & State Programs To Control Leaking: Underground Storage Tanks
N
REME
A "before" picture of a Kum & Go station in Joplin (left). (St. John's Hospital, discussed under the Postmortem section of this article, is shown in the
background.) The same Kum & Go station after the F5 tornado (right). The store was destroyed and a concrete dispenser island was blown away, dam-
aging the piping beneath.
by Heather Peters
n May 22, 2011, Joplin, Missouri was hit with an F5
tornado, the most extreme tornado category. In the
aftermath, a host of emergency response agencies were
on the scene, including the Missouri Department of Natural
Resources (MDNR) Environmental Emergency Response team.
The responders immediately visited many different kinds of
facilities to provide assistance on uncontrolled emergencies and
offer additional help with any disaster-related environmental
concerns. These visits included each of the underground stor-
age tank (UST) facilities in the path of the tornado. In addition,
staff from the Missouri Department of Agriculture's Weights
and Measures checked these LIST sites for leaks and tripped any
shear valves that were not already closed.
• continued on page 2
Inside
4U Weathering High-Octane Disasters?
5 (J Irene Takes Vermont by a Storm
7 Q Arizona Wildfires Test UST Owners, Operators
Q(] Tanks in the 2008 Iowa Floods
11 (J It's Been Quite an Autumn 2011
14() Someday My Facts Will Come, Part 2
19Q Lead Scavengers Still Persist in Old Product
21 (J The "Twofer" Economic Theory
23 () Field Notes
25 Q FAQs: Secondary- and Spill-Containment Test Methods
'6 (J Exxon Hit with $1.5 Billion in Damages
-------
LUSTLine Bulletin 69 • December 2011
I Joplin, MO from page 1
With the initial concerns of mas-
sive gasoline or diesel releases abated,
environmental emergency responders
turned their attention to other pressing
concerns. Meanwhile, the department's
tank inspectors began getting questions
from tank owner I operators: What now?
What do I need to worry about at my gas
station? What does the department want
me to do before reopening my station?
The problem, though, was our answer—
"We have no idea."
We started with a visit to every reg-
istered UST site in Joplin. Of the approx-
imately fifty UST sites, eight had serious
damage that immediately raised concerns
about potential releases. Fortunately, the
power was knocked out before the tor-
nado actually hit, so the pumps were all
off by the time any damage would have
occurred. Ironically, the power failure
helped to prevent releases. With most of
the UST equipment below ground, or at
least below the shear valve, we hoped for
the best, and maybe we were even naive
enough to expect no problems at all. But
you live and learn.
L.U.S.T.Lme
Ellen Frye, Editor
Ricki Pappo, Layout
Marcel Moreau, Technical Adviser
Patricia EUis, PhD, Technical Adviser
Ronald Poltak, NEIWPCC Executive Director
Erin Knighton, USEPA Project Officer
LUSTLine is a product of the New England
Interstate Water Pollution Control Commis-
sion (NEIWPCC). It is produced through
cooperative agreements (US-83384301 and
US-83384401) between NEIWPCC and the
U.S. Environmental Protection Agency.
LUSTLine is issued as a communication
service for the Subtitle I RCRA
Hazardous & Solid Waste Amendments
rule promulgation process.
LUSTLine is produced to promote
information exchange on UST/ LUST issues.
The opinions and information stated herein
are those of the authors and do not neces-
sarily reflect the opinions of NEIWPCC.
This publication may be copied.
Please give credit to NEIWPCC.
NEIWPCC was established by an Act of
Congress in 1947 and remains the old-
est agency in the Northeast United States
concerned with coordination of the multi-
media environmental activities
of the states of Connecticut, Maine,
Massachusetts, New Hampshire,
New York, Rhode Island, and Vermont.
NEIWPCC
116 John Street
Lowell, MA 01852-1124
Telephone: (978) 323-7929
Fax: (978) 323-7919
lustline@neiwpcc.org
te) LUSTLine is printed on recycled paper.
The Postmortem
The key to the damage at three of the
UST sites was the shear valve. At a
few of the sites, we found nothing
standing but a few vent pipes. After
seeing the tornado's devastation first-
hand, we were surprised to see these
vent pipes. But when we looked at
what was left of the dispenser islands,
we found closed shear valves that
had accomplished exactly what they
were designed to do—the shear
valve closed; the piping sheared; the
underground portion was protected.
Success! We hoped to issue the fol-
lowing such report at every site: "No
indications of a leak or damage to the
underground storage tank system."
As it turns out, we were only able to
issue that report for three of the eight
UST sites.
For the remaining five sites,
Mother Nature beat out human engi-
neering. A shear valve's strength
lies in its anchoring. At one site, The
Store (see photo below), anchored
with only bolts, the shear valve
broke when the dispenser was blown
off. The piping, unfortunately, went
with the dispenser. The fiberglass
line was broken approximately one
foot below the flexible connector.
One station down.
Shear valves and their anchor-
ing were designed for a side impact.
Unfortunately, at the next facility,
the evidence of the straight upward
force of the tornado was obvious.
What was left of the dispenser,
anchor, shear valve, and piping, was
pulled up approximately one foot.
Fiberglass lines do not stretch. Two
stations down.
At the Kum & Go facility
(see photos on page 1), the shear
valve may have remained securely
anchored in the concrete foun-
dation of the dispenser island.
Unfortunately, after the storm, the
whereabouts of that entire concrete
foundation was unknown. The pip-
ing broke off just below the ground
surface. Three stations down.
Then there was that lovely new,
double-walled system installation
at a spanking new Macadoodles
facility that the department staff
had inspected in 2008 (see photos
on page 3). During our post-tor-
nado visit to that site, we found an
unimaginable amount of debris,
even in the dispenser containment
sumps. The dispensers were long
gone. The store, the canopy, the steel
beams were all gone or bent like
spaghetti. We found debris blown
up into the interstice of the double-
walled piping. We also found prod-
uct in the sumps—never a good sign.
While we do not believe there was a
"The Store" sustained only minor tornado damage, but the fiberglass piping was broken when the
dispensers were blown over.
-------
December 2011 • LUSTLine Bulletin 69
Macadoodles in Joplin as it looked shortly after
opening less than three years ago (left). Note
the store standing in the background. This same
facility as it looked shortly after the F5 tornado
(below). Note the steel canopy beams folded on
the ground.
significant release, as of the deadline
for this article, the manufacturer, the
department, the owner, and the con-
tractor are still trying to determine if
there is a good way to evaluate the
integrity of this piping. Four stations
down.
Last, but by no means least, was
St. John's Hospital, which lost all
power, including the backup gen-
erators. Why? The emergency gen-
erators were located outside of the
building in a concrete block building
near their associated underground
fuel storage tanks. The protective
brick building was blown away like
cardboard.
Large debris (an air handler
from the hospital rooftop) crashed
down on top of an exposed emer-
gency generator. Even if the genera-
tor itself had not been destroyed, its
use would have been short-lived.
The piping connecting the UST to the
generator went through the wall of
the concrete building, the same wall
that was blown away by the violent
winds. The piping, once an inner
steel pipe run through an outer, non-
corrosive pipe, was nothing more
than mangled steel rising out of the
ground, marking the former location
of the protective wall. Four stations
and one hospital down!
Never Underestimate the Power
of Mother Nature
Human engineering on USTs has
certainly come a long way. The
landscape was leveled—not a tree
or building in sight. But, the UST
systems were protected, most of the
time, by their subsurface location
and the undervalued (at least by this
inspector) shear valve. No serious
leaks occurred because the power
went down, the pumps were off, and
unfortunately for most sites, there
was nothing left to "re-power" later.
At the five sites, Mother Nature
demonstrated the astonishing power
of an F5 tornado. She can pull pip-
ing right up out of the ground. She
can blow debris into an interstice in
ways that seem to defy physics. She
can level everything in sight. In this
battle between human engineering
and Mother Nature, Mom may have
won. But as the stations are coming
back to life, brighter and better than
before, the most valuable lesson
learned for this inspector is that with
all the unimaginable chaos, the spirit
of the people of Joplin was truly a
profound source of inspiration to us
all. •
Heather Peters is with the Missouri
Department of Natural Resource's
Hazardous Waste Program, working on
UST inspections and other operational
compliance issues. She can be reached
at: heather.peters@dnr.mo.gov.
Note: If you are interested in pro-
viding support for the victims of
this tornado, please visit the Mis-
souri state website at www.mo.gov/
05222011joplintornadoes/.
-------
LUSTLine Bulletin 69 • December 2011
EXTREME
Cai Talk Systran aid Talk Imare
Waitttr Ilih-fetaia Disasters?
Commentary by Ellen Frye, LUSTLine editor
This November, the Nobel Prize-
winning Intergovernmental
Panel on Climate Change
(IPCC) issued a special report, Man-
aging the Risks of Extreme Events and
Disasters to Advance Climate Change
Adaptation (www.ipcc.chl), on global
warming and extreme weather. The
panel warned that the world needs
to get ready for more dangerous and
"unprecedented extreme weather"
caused by global warming. The
report confirms what climate scien-
tists have long been telling us: that
the occurrence of climate-related
extremes such as increasing heat
waves, heavier rainfall, more floods,
stronger cyclones, landslides, and
intense droughts are highly likely
across the globe this century.
Think of it: This summer, Ari-
zona, New Mexico, and Texas had
record-breaking wild fires fueled by
extreme drought situations. In recent
years, severe floods have submerged
thousands of acres of farmlands,
ranchlands, and urban areas in the
Ohio River, Mississippi River, and
Missouri River valleys. This sum-
mer, hurricane Irene clobbered the
Eastern seaboard, dumping up to 11
inches of rain in some areas of Ver-
mont, the most destructive event
to hit that state in almost a century.
On June 1, 2011, sections of the city
of Springfield, Massachusetts, and its
surrounding region were devastated
by tornadoes, rare events in that
region of the country. The National
Weather Service reports that the
dozen billion-dollar disasters in the
U.S. in 2011 alone add up to $52 bil-
lion...and counting.
So what does this have to do
with USTs (and ASTs, for that mat-
ter)? This issue of LUSTLine consid-
ers just this question by means of
disaster reports from UST regulators
on extreme events involving USTs in
their states, beginning with Heather
Peter's cover article on the F5 tor-
nado in Joplin, Missouri.
Of course extreme events may
not necessarily be the result of some
climate-related phenomenon (e.g.,
the six large outbreaks of tornadoes
this year cannot be attributed to
global warming). But whatever the
cause, the real question is, should
UST programs be thinking in terms
of emergency preparedness for tank
systems? Are UST programs pre-
pared to advise a panicked tank
owner/operator on proactive steps
to take in the event of an approach-
ing wildfire or hurricane? Are they
prepared to assist tank owners in the
face of disaster-related environmen-
tal threats?
As Peters says in her Joplin tor-
nado article (page 1): After the tor-
nado had passed, "the department's
tank inspectors began getting ques-
tions from tank owner/operators:
What now? What do I need to worry
about at my gas station? What does
the department want me to do before
reopening my station? The problem,
though, was our answer—'We have
no idea.'"
As Matt Garcia notes in his article
on Arizona wildfires, the ADEQ UST
Section was in a similar predicament
when tank owners called for advice
as fires advanced closer to their UST
facilities: "Since the magnitude of
these fires was something the state
hadn't encountered, we needed to get
up to speed. It was kind of like hav-
ing a family member asking you for
help, and you don't have an immedi-
ate answer."
Admittedly, some climate events
are so extreme and disruptive that
concerns about leaking USTs are
moot in light of the surrounding
chaos. In New Orleans, for exam-
ple, the affected areas were awash
in a chemical soup, some tank sys-
tems were submerged in water for
months—it was beyond the beyond.
In Joplin, everything in the torna-
do's path was torn and tattered. But,
as Heather Peters reports, at a few
facilities inspectors found "closed
shear valves that had accomplished
exactly what they were designed to
do—the shear valve closed," pre-
venting the release of product.
The IPCC report assesses a wide
range of complementary adapta-
tion and disaster risk management
approaches that can reduce the risks
of climate extremes and disasters
and increase resilience to remaining
risks as they change over time.
The final October 2011 report
of the Defense Science Board Task
Force on Trends and Implications of
Climate Change on National and Inter-
national Security (www.fas.org/irp/
agencyldodldsblclitnate.pdf) offers the
Department of Defense important
considerations related to this sub-
ject. This report also focuses on the
need to manage consequences of
climate change. And as tank pro-
grams might note, the report states:
"the single greatest direct driver
of impact on the human habitat is
water—too much or too little. Water
and water management are key fac-
tors to food, energy, and economic
development."
So what do our tank programs
say to an owner/operator who has
just gone through or may be about
to go through a disaster? Does the
tank program in your state provide
owner/operator guidance for dif-
ferent kinds of disaster scenarios? If
your state has prepared suggested
emergency procedures, let us know.
The nation's tank programs
exist out of concern for protect-
ing our water resources from con-
tamination associated with releases
from tank systems. We depend
on the owner/operator to comply
with applicable regulations. In an
extreme weather or wildfire event,
tank systems, owner/operators, and
water resources all stand to lose.
So my question is this: Shouldn't
tank owner/operators be provided
with effective best management
practices that they can refer to in
the event of such circumstances?
USEPA's Underground Storage Tank
Flood Guide is a great template (see
page 5). •
-------
December 2011 • LUSTLine Bulletin 69
USEPA's Underground Storage Tank Flood Guide
In November 2010, USEPA's Office of Underground Storage Tanks (OUST) released its Underground Storage Tank Flood
Guide (EPA 510-R-10-002), which is available at www.epa.gov/oust/pubs/ustfloodguide.htm. This 22-page guide is designed
to help state UST regulators and tank owners prepare for any catastrophic effects and environmental harm that could occur
as a result of flooded UST systems and help return these UST systems to service as soon as possible. It provides simple
guidelines and useful information for state, local, and tribal authorities in the event of a threatened or actual flood; informa-
tion about preparing for a flood, important actions after the disaster strikes, and information on financial assistance. This
material was gathered from various federal, state, nongovernmental, and UST industry sources. •
X7
Iraia Tilts Vmnt fey • Storm
by Ted Unkles
On August 28, 2011, Tropical
Storm Irene hit Vermont. Hurri-
cane Irene had already caused a
wide swath of damage and destruc-
tion along much of the East Coast
of the United States, but many peo-
ple believed that since it had weak-
ened to a tropical storm, it would
pose only minor problems when it
reached the Green Mountain State.
Those people were very wrong.
Although wind speeds had dimin-
ished slightly, Vermont was deluged
by copious amounts of rain, which
caused many rivers and streams to
flood and rush through valley floors
with unimaginable force.
The damage to Vermont's
transportation infrastructure was
astounding: Hundreds of miles of
state highways and town roads were
completely washed away. Hun-
dreds of homes were flooded, and
a hundred more home heating oil
tanks spilled their contents into their
basements, resulting in oily sludgy
messes. Because Vermont's Petro-
leum Cleanup Fund covers home
heating oil tanks, this one-day event
generated claims that added up to
what the fund normally expends in a
year on home heating oil spills.
Gas stations, mini marts, and
other facilities with USTs were also
hit very hard. Several UST systems
were damaged, and in two cases, the
tank systems were utterly destroyed.
Vermont has a zero-interest loan
program for tank owners to replace
and upgrade their tank systems, but
as of this writing (November) the
two store owners whose USTs were
destroyed had not decided whether
to replace their UST systems or to
simply get out of the gasoline busi-
ness.
Some Vermont Irene Stories
Upper Valley Grill and
General Store
The Upper Valley Grill and Gen-
eral Store in Groton, Vermont, sits
beside the Wells River, which is nor-
mally a pleasant trout stream. The
store had picnic tables on the grassy
lawn beside the river, and during the
warmer months patrons would regu-
larly sit beside the river and enjoy
their lunch. But Irene turned the
normally placid Wells River into a
raging torrent that jumped its banks
and completely destroyed the store's
parking lot and gasoline fueling area
(see photo below).
As the raging water scoured the
parking area, the concrete slabs over
both tanks were washed away. Ironi-
cally, the concrete slab over one tank
ended up atop the second tank, while
the first tank was completely lifted
onto the ground surface. Most of
the gasoline was apparently washed
out of the USTs; when the storm
was over the tanks were found to
be filled mostly with water, and just
a few inches of free gasoline floated
on several feet of water in both tanks.
The UST systems were completely
destroyed, but remarkably, the store
itself suffered only modest interior
damage. .
• continued on page 6
Upper Valley Grill and General Store.
-------
LUSTLine Bulletin 69 • December 2011
I Vermont Storm from page 5
Blackie's Store.
Blackie's Store
Blackie's General Store in West
Bridgewater, Vermont sits beside
the Ottaquechee River. Irene turned
this river into another raging torrent,
which very heavily damaged the
store building, the parking lot, and
the underground piping to the dis-
pensers (see photo above). The tanks
themselves suffered
no damage (or at least
none that could be seen
by looking down any
of the risers). About 10
miles from this location,
the Ottaquechee River
destroyed the covered
bridge in Quechee Vil-
lage, the video of which
was seen in news broad-
casts nationwide, and
went viral on the inter-
net.
Orphan Tanks
After the flood had
receded, an UST was
found in the Otter Creek
in Proctor. This was a
2,000-gallon, compart-
mented gasoline tank
that contained 75-100
gallons of a water/
fuel mix. The Depart-
ment of Environmen-
tal Conservation (DEC)
was unable to locate an
owner for this tank. We suspect it
was a farm fuel tank, but to date no
one has come forward. DEC paid for
the proper cleaning, removal, and
disposal of the tank.
A second tank was found in the
Ottaquechee River in Bridgewa-
ter. This tank was a heating oil UST
that also contained a fuel/water
mix. Approximately 70 gallons were
removed for proper disposal.
Even USTs that had been prop-
erly closed were subjected to Irene's
fury. The tank seen in the photo
below had been pulled and cleaned
and was sitting on the ground in a
salvage yard beside the Winooski
River. When the river flooded, the
tank and dozens of old tires were
carried several miles downstream,
ending up stranded on an island in
the middle of the river. Large pieces
of the tank's fiberglass outer wall
were found scattered about on the
island.
P.S.: Hurricane Irene flooded us out
of our offices, and we are now in a
"temporary" office in Barre, Ver-
mont. Agency managers assure us
that our location is truly temporary,
but they also say it may be two,
perhaps even three years before we
go to a permanent location. As yet,
no decision has been made about
whether or not to renovate our old
offices, which are (obviously) in a
flood plain. •
Ted Unkles is UST Program Coordina-
tor with the Vermont Department of
Environmental Conservation, Agency
ofNatural Resources. He can be
reached at: ted.unkles@state.vt.us.
Orphaned tank.
-------
December 2011 • LUSTLine Bulletin 69
EXTREME
Mztia WUflits lost 1ST Omars, Iparatars, aid
•aiilitara
By Matthew Garcia
The year 2011 has been very
trying for Arizona residents
because of several major wild-
fires that burned nearly one million
acres, the most for any year in the
state's recorded history. More than
50 residences burned during the
Wallow and Monument fires and
many other dwellings throughout
the state were threatened, creating
tremendous stress on residents in the
path of the fires. There were numer-
ous evacuations in populated areas,
including several businesses with
underground storage tanks (USTs).
Once the evacuations were
ordered, I received frantic calls from
UST owners, operators, and contrac-
tors asking what they needed to do
to protect their systems in the evacu-
ation zone.
The ADEQ UST Section of
the Waste Programs Division has
worked for decades building trust
and communication channels with
owners, operators, and contractors,
and now it was time to build on that
relationship. But since the magni-
tude of these fires was something the
state hadn't encountered, we needed
to get up to speed. It was kind of
like having a family member asking
you for help, and you don't have an
immediate answer.
We quickly called the State Fire
Marshal's office. They didn't have a
set plan either, so we contacted sev-
eral contractors and industry people
with knowledge in wildfires and
USTs and came up with several items
owners and contractors could do
(see below). These suggestions were
not official and were broken down
according to sites that had time
before the evacuation and a contrac-
tor would be able to shut down the
site safely and sites that had to be
evacuated immediately with no time
to call in a contractor.
We are in the process of estab-
lishing our official processes so
they will be in place before the next
fire season. ADEQ's goal, which
was completed successfully, was to
reduce the impact of any environ-
mental damage and provide for the
protection of UST systems as well
as the safety of residents and fire-
fighters.
/ received frantic calls from UST
owners, operators, and contractors
asking what they needed to do to
protect their systems.
Although the fires were devas-
tating, no USTs were damaged. Our
rapid response, sound advice, and
care did help build on our existing
relationships with owners, contrac-
tors, and other agencies. While we
hope Arizona does not have to go
through another wildfire season
like 2011, if we do, ADEQ is ready
to again help the citizens of Arizona
and the environment.
Suggested Actions for UST Sys-
tem Owners/Operators
The following are the suggestions
ADEQ gave to owners/operators
and contractors during the 2011
wildfires. This list is not an official
recommended practice from any
state agency or contractor. The sug-
gestions were broken up into three
categories: Scenario 1: facilities that
had a week or more notice of evacu-
ation; Scenario 2: facilities that had
hours or less to evacuate; and Sce-
nario 3: facilities that were in the
evacuation area, but had to stay open
to provide fuel for evacuees and/or
fire/support personnel.
Scenario 1:
• Empty the tanks
• Inert tanks by triple rinse process
• Remove all waste out of the
evacuation area
• Trip all fire valves and check
emergency vents
• Disconnect all electrical supply
to the tank and system
• Close all ball valves and shear
valves
• 24 hours prior to fire arrival:
- Add dry ice
- Remove all equipment
- Notify local fire command of
the tank status
- Notify tank insurance provider
of tank status and situation
Scenario 2:
• Close all shear valves and ball
valves
• Disconnect all electrical supply
to the tank and system
• Check all vents for proper func-
tion
• Notify local fire command of the
tank status
• Notify tank insurance provider
of tank status and situation
Scenario 3:
• Contact local fire command for
status
• Have back-up/emergency elec-
trical set-up on site
• Notify local fire command
of tank status and determine
proper emergency action if
needed
• Notify tank insurance provider
of tank status and situation. •
Matthew Garcia is an inspector for the
UST section of the Arizona Depart-
ment of Environmental Quality.
He can be reached at
garcia.matthew@azdecj.gov.
-------
LUSTLine Bulletin 69 • December 2011
XT M
inks li ttt 2118 inn Flttis
by Paul Nelson
The 2008 Iowa floods were dev-
astating and unimaginable for
thousands of people in the state.
Dealing with cleanup and recovery
was even worse. Many UST owner/
operators in eastern Iowa saw their
sites completely flooded, and in
some cases, their tanks floated out of
the ground.
To ensure sites in the flood zone
safely returned to operation, the
Department of Natural Resources
(DNR) UST Section developed an
emergency flood policy that included
an UST system checklist, which was
to be completed by an Iowa licensed
installer/installation inspector or
compliance inspector. Seventy-two
sites were identified from FEMA
flood maps as affected by the flood.
Each site identified was sent a letter
and a checklist.
Field office personnel assisted by
visiting the flood plain sites to con-
firm which sites were submerged.
Forty-two sites were identified as
having been submerged by floodwa-
ters and were required to complete
the UST Emergency Flood Policy
checklist (at least those that wanted
to remain in business). Twenty of
the 72 sites were not submerged by
floodwaters. Seven sites reported
water in their tanks, requiring tank
cleaning. Nine tanks from three
different sites were displaced and
floated.
Several of the affected sites had
filled their tanks with product to
counter the buoyancy forces only
to find that their tanks were still in
place but water had filled the tanks
where there once was product. The
capped openings on the tanks were
not tight and in one case (on Mays
Island) the vent pipes on two tanks
were damaged by floating debris
allowing floodwaters to enter. •
Paul Nelson is an Environmental
Specialist Senior with the Iowa Depart-
ment of Natural Resources. He can be
reached at paul.nelson@dnr.iowa.gov.
8
View of downtown Cedar Rapids. Mays Island lies in the center of the river housing City Hall,
Veteran's Memorial Auditorium, Linn County Courthouse, a correctional facility, and two USTs.
Clark station tank that floated out of the tank pit. The site was covered by seven feet of water.
-------
December 2011 • LUSTLine Bulletin 69
More scenes of tanks and floods from Iowa
•^ Clark station tank that made it to this neighbor's yard.
The tanks were not anchored and empty.
T Clark station tank that made it to the interstate. It cast
a shadowy figure as it floated down an unlit street at
night, past emergency responders in a Jon boat.
T A day care facility found this new playground equip
ment in their front yard after the flood.
T Unanchored, empty tanks float out in Oakville.
-------
LUSTLine Bulletin 69 • December 2011
t about three o'clock on a Friday morning in September, residents near Sunny's convenience store and gas station in
Newport, Nebraska, were awoken by the sound of a loud boom. Sunny's 10,000-gallon fiberglass underground diesel
tank (photo A) had exploded due to a lightning strike at the facility during a fierce storm. The force of the explosion
hurled large chunks of concrete several feet, leaving a gaping hole and the skeletal remains of the tank (photo B).
A close up view of the diesel tank. On the right side just
under the concrete is the hole in the super unleaded gaso-
line tank caused by the explosion of the diesel tank. The
water level is about lour feet below the top of the concrete.
Besides the diesel tank, the facility had an 8,000-gallon
super unleaded tank and an 8,000-gallon unleaded tank. All
product lines were single-walled fiberglass, and vent lines
were fiberglass. An ATG monitor probe was located at the
center of each tank. The dispensers had card readers on them
that hadn't been used for two or three years. All three tanks
had metal spill buckets with metal covers, and all of the riser
pipes for the fill and ATG were steel with brass rings at the
top.
The Newport Fire Department found that the unleaded
tank was still intact; the super unleaded tank had a hole in it,
likely caused by the explosion of the adjacent diesel tank. That
tank and the diesel tank lost a total of 625 to 700 gallons of
product, which was pooled on the water table. All three tanks
were removed, and product and vent lines were capped off.
Investigators hypothesized that the lightning came into
the building on the telephone line going to the fax and credit
card machines (neither the building nor the canopy showed
evidence of having been hit by the lightning). Both lines had
black soot on the walls where junction boxes were mounted.
A black mark on the diesel tank's ATG probe (photo C), likely
due to a spark discharge, indicates the probable source of
ignition that resulted as the current from the lightning strike
moved through the ATG wiring. •
Two large concrete slabs from the top of the diesel tank
were blown up ana landed upside down on top of each
other.
Area of arcing on the diesel ATG probe tube (by the small
hole in the center of the picture).
Photos courtesy of the office of the Nebraska State Fire Marshal.
10
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December 2011 • LUSTLine Bulletin 69
A Message From Carolyn Hoskinson
Director, USEPA's Office of Underground Storage Tanks
It's Been Quite an Autumn 2011
Autumn brings us changes: decreasing daylight, cool-
ing temperatures, and falling leaves. Autumn also sig-
nals the end of the federal government's fiscal year.
For the national underground storage tank (UST) program,
autumn is the time of year to report performance about our
core priorities—preventing releases and cleaning up leaks.
For a quick overview of the national UST program's 2011 per-
formance measures, see the box below. You can learn more
about the UST program's 2011 performance at www.epa.gov/
oust/cat/camarchv. htm.
National UST Program By The Numbers
(as of September 30,2011)
• 590,104 active USTs
• 1.77 million USTs closed
• 70.9 percent of UST systems in significant
operational compliance with release prevention
and leak detection
• 501,723 releases confirmed
• 413,740 cleanups completed
For more 2011 UST performance measures:
www.epa.gov/oust/cat/camarchv.htm.
But there's more good stuff to add to your UST/LUST
quivers. I want to make sure you know about our preven-
tion work (biofuels and proposed UST regulations) and our
cleanup activities (national LUST cleanup backlog study and
petroleum brownfields).
PREVENTING UST RELEASES
Biofuels
With the United States moving toward a greater reliance on
alternative fuels, the national UST program has been focus-
ing on the compatibility of UST systems and biofuel blends.
Several months ago, USEPA issued compatibility guidance
that provided information on how UST owners and operators
can demonstrate the compatibility of their UST systems with
stored fuels containing certain percentages of biofuels.
The guidance indicates that one of the options for dem-
onstrating compatibility is a manufacturer's approval that
UST components are compatible with the fuel stored. To help
UST owners and operators who choose this option, two of
our industry partners—Petroleum Equipment Institute (PEI)
and Steel Tank Institute (STI)—are making manufacturers'
compatibility statements available on their websites. Thank
you to PEI and STI for
sharing this information
widely on your websites;
this is another example
of how UST partners
work together to protect our country's groundwater from UST
releases. (See also Field Notes on page 23)
UST Compatibility Resources
EPA's June 2011 Compatibility Guidance:
www.epa.gov/oust/altfuels/biofuelsguidance.htm
PEI's UST Component Compatibility Library:
www.pei.org/PublicationsResources/
RegulatoryCompliance/USTComponent
CompatibilityLibrary/tabid/882/Default.aspx
STI's Tank Manufacturer Statements
of Compatibility: www.steeltank.com/
Publications/E85BioDieselandAlternativeFuels/
ManufacturerStatementsofCompatibility/tabid/413/
Default.aspx
Also, in the 2011 federal budget, USEPA's UST program
received 2.5 positions (known as full-time equivalents or
FTEs) to help the nation's continued migration toward alterna-
tive fuels. USEPA headquarters and regions agreed that these
additional positions will serve as a National Biofuels Team,
supporting our national effort and collectively serving as a
resource about UST issues associated with biofuels and other
alternative fuels. The team is currently developing a work
plan. Please contact Andrea Barbery at barbery.andrea@epa.
gov or 703-603-7137 if you have biofuels issues you want the
team to consider including in the work plan.
USEPA's Office of Research and Development (in par-
ticular, the Environmental Technology Verification program)
developed a quality assurance plan that evaluates automatic
tank gauging systems in USTs storing ethanol-blended fuels
and tested two vendors' technologies. When completed in a
few months, we will share the results of this effort, which will
increase our technical knowledge of the effectiveness of leak
detection technology in biofuels service.
Proposed UST Regulations
On November 18, USEPA published in the Federal Register
a proposal that strengthens the 1988 UST regulations by
increasing emphasis on properly operating and maintaining
UST equipment. While we considered environmental needs in
developing the proposal, we were also very sensitive of future
• continued on page 12
11
-------
LUSTLine Bulletin 69 • December 2011
Message From Carolyn Hoskinson continued from page 11
costs to UST owners and operators and, consequently, mini-
mized UST system retrofits. Briefly, the proposed revisions:
• Ensure all USTs in the United States, including those in
Indian country, meet the same minimum standards
• Close regulatory gaps and accommodate new technolo-
gies
• Improve prevention and detection of UST releases, which
are a leading source of groundwater contamination.
In developing these proposed revisions, USEPA reached
out to a wide variety of interested and affected UST stakehold-
ers, resulting in valuable input, which significantly helped us
identify the scope of our proposed changes. I am extremely
appreciative of the efforts of all who shared their input with us.
The proposal's public comment period is open for 90 days
from when the proposal was published in the Federal Regis-
ter, which means we can accept comments until February 16,
2012. I hope you will provide us with your comments, per
instructions in the Federal Register notice. See www.epa.gov/
oust/fedlaws/proposedregs.htmlto access the proposed regu-
lations, Federal Register notice, and additional resources.
CLEANING UP UST RELEASES
National LUST Cleanup Backlog Study
At the end of September, we issued The National LUST
Cleanup Backlog: A Study Of Opportunities (see www.epa.gov/
oust/cat/backlog.html), which provides state regulators and
other interested stakeholders with:
•A detailed understanding of the LUST releases backlog
and why the pace of cleanups is slowing
• Data compiled from 14 state LUST cleanup programs
• Key findings derived from analyzing the data
• Opportunities to help reduce the backlog in the 14 states
studied, as well as more widely across all state cleanup
programs.
The study confirmed some hypotheses related to the
existing LUST backlog (e.g., that the remaining backlog
is dominated by groundwater-contaminated sites). It also
questioned others (e.g., that all high-priority sites have been
assessed and that all soil-only sites, which are often referred
to as low-hanging fruit, have been addressed). The study also
revealed that many state UST programs are already applying
backlog reductions strategies, such as:
• Reviewing data and files
• Employing temporary staff to close more releases
• Using multi-site agreements to encourage responsible
party activity
• Using pay-for-performance and other incentives for con-
tractors to reach closure
• Referring low-priority releases to brownfields programs
or others, such as voluntary cleanup programs.
USEPA is supportive of these ongoing strategies, as well
as other potential efforts, such as exchanging best practices
and continuing to build on states' successes.
Now that the study is completed, we will be develop-
ing targeted backlog reduction strategies in cooperation with
states, tribes, and other stakeholders. We will work with
USEPA regional and state UST partners to identify next steps,
gather additional promising backlog reduction strategies, and
implement the strategies.
Petroleum Brownfields
In September, we also issued Opportunities for Petroleum
Brownfields (see www.epa.gov/oust/pubs/pbfopportunities.
htm), a document that gives readers:
• Information about the types of petroleum brownfields
properties
•Opportunities and challenges petroleum brownfields
present
•Ways these sites can be successfully addressed and
reused.
This document presents examples of reusing petroleum
brownfields properties in the commercial, industrial, transpor-
tation, residential, and open land categories. It discusses les-
sons learned through historic case studies and provides a list
of resources about funding, technical issues, and partnership
opportunities. The document provides technical assistance
for revitalizing petroleum brownfields, particularly reuse of
abandoned gas stations. It is the third in our series of petro-
leum brownfields documents. You can access our petroleum
brownfields documents, plus our petroleum brownfields web
pages, on USEPA's website (see www.epa.gov/oust/petro-
leumbrownfields/index.htm).
r
EPA's Petroleum Brownfields Documents
Opportunities For Petroleum Brownfields
www. epa. go v/oust/pubs/pbfopportunities. htm
Petroleum Brownfields: Developing Inventories
www. epa.gov/swerust1/pubs/
pbfde velopin ventories. htm
Petroleum Brownfields: Selecting A Reuse Option
www.epa.gov/oust/pubs/pbfreuseoption.htm
We believe that identifying reuse opportunities and pro-
viding assistance to transform petroleum brownfields proper-
ties will help inspire additional cleanup of the backlog of open
LUST release sites.
Our National UST Program Protects Groundwater
USEPA's UST program efforts—as well as those of our state,
territorial, tribal, local government, and industry partners—
culminate in one overarching goal: protecting our ground-
water. It is a goal that is essential for our country and will
continue to guide our work for future years. •
12
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December 2011 • LUSTLine Bulletin 69
\ OUST UPDATE
Topics Covered in USEPA's
Proposed Rules
USEPA's proposal revises the UST
technical regulation in 40 CFR part
280 by:
• Adding secondary contain-
ment requirements for new
and replaced tanks and piping
• Adding operator training
requirements for UST system
owners and operators
• Adding periodic operation
and maintenance require-
ments for UST systems
• Removing certain deferrals
• Adding new release preven-
tion and detection technolo-
gies
• Updating codes of practice
• Making editorial and techni-
cal corrections
USEPA is also proposing
to update the state program
approval (SPA) requirements in
40 CFR part 281 to incorporate the
proposed changes to the UST tech-
nical regulation listed above.
USEPA developed resources
to help interested and affected
stakeholders review the proposed
revisions to the 1988 UST regula-
tions. For details, go to: www.epa.
govloustlfedlawslproposedregs.html.
Check Out OUST's New Petro-
leum Vapor Intrusion (PVI)
Compendium
The PVI compendium is now
available at www.epa.gov/oust/cat/
pvi/index.htm. It provides infor-
mation about OUST's efforts to
develop policy guidance on PVI
and provides links to supplemen-
tal technical materials as well as
state guidance documents. Tabs
at the top of the pages help you
to navigate through the compen-
dium. You can also access intro-
ductory information, such as an
overview of PVI, work products
(e.g., information papers, webi-
nars), and additional vapor intru-
sion resources.
Vapor intrusion occurs
when vapor-phase contaminants
migrate from subsurface sources
into buildings. One type of vapor
intrusion is PVI, in which vapors
from petroleum hydrocarbons
such as gasoline, diesel, or jet fuel
enter a building. The intrusion of
contaminant vapors into indoor
spaces is of concern due to poten-
tial threats to safety (e.g., explo-
sive concentrations of petroleum
vapors or methane) and possible
adverse health effects from inhala-
tion exposure to toxic chemicals.
For questions or more informa-
tion about the PVI compendium,
contact Hal White at white.hal@epa.
gov.M
USEPA Region 9 Video
Highlight's ARRA-
Funded LUST Cleanup
Work in Navajo Nation
Check out USEPA Region 9's YouTube video
on LUST projects funded by the American
Recovery & Reinvestment Act (ARRA) in
the Navajo Nation at www.youtube.com/
watch?v=2KYg4jnHdk8. The video features
benefits to the local tribal firm conducting
the cleanup work, the Navajo community,
and the environment made possible with
the ARRA funds.
Tribal lands have some of the highest
unemployment rates in the nation; many
areas lack adequate access to electricity
and clean drinking water. By cleaning up
contaminated lands and protecting ground-
water resources, tribal communities can
be assured that petroleum releases from
LUST-impacted soil and groundwater will
not continue to cause negative impacts to
their communities.
USEPA allocated roughly $6.3 million
from ARRA funding for cleaning up LUSTs
on tribal lands across the country. The
funding was provided to expand agency
efforts to clean up eligible sites on tribal
lands, in an effort to restore property for
future use opportunities.
Region 9 received roughly half of
the funding to assess eligible tribal LUST
sites in California, Nevada, and Arizona.
The national contractor for this work is a
100 percent American Indian-owned firm.
The funding provided USEPA with an
incredible opportunity to clean up the most
contaminated sites on tribal lands. •
SNAPSHOTS FROM TH€ FI€ID
Kevin Henderson, a consultant, formerly with the Mississippi DEQ,
sent this shot ofE85 corrosion in a STP sump. "I think that the
bright bluish-green mineral crystallized on the automatic line leak
detector vent tubing is copper acetate," says Henderson. "This
mineral precipitates out of solution on the surface of copper under
the right conditions. The right conditions are high humidity, acetic
acid, and a copper surface. Obviously, the conditions are right
within this sump. The mineral could be any one of various copper
salts (e.g. copper sulfate) but I believe it is most likely copper
acetate." (See this photo in color in the online version of LUSTLine
sfwww.nelwpcc.org
13
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LUSTLine Bulletin 69 • December 2011
nically Speaking
by Marcel Moreau
Marcel Moreau is a nationally
recognized petroleum storage specialist
whose column, Tank-nically Speaking,
is a regular feature o/LUSTLine.
As always, we welcome your comments
and questions. If there are technical
issues that you would like to have
Marcel discuss, let him know at
marcel.moreau@juno.com.
Someday My
As promised in my March 2011, LUSTLine article, this follow-up article will take a closer look at what some of the testing statistics
generated by Crompco, a leading UST testing company headquartered in Pennsylvania, can tell us about the current state of our
UST systems. To provide different viewpoints on the data, I've also enlisted Tom Schruben, an independent environmental risk-
management and UST-equipment-failure investigator, and Ed Kubinsky of Crompco, to contribute to this article as well.
About Our Data
Crompco has been in business for
30 years and operates up and down
the East Coast from Florida to Maine,
with a strong presence in the Mid-
Atlantic states. Unless otherwise
stated, the data presented here are
a compilation of the testing done
by Crompco in Maryland, Pennsyl-
vania, New Jersey, New York, and
Massachusetts from January 2004
through August of 2011.
Crompco is primarily in the UST
testing business, performing tra-
ditional tank and piping tightness
testing, sump and spill bucket leak
testing, and line leak detector opera-
tional testing, and providing annual
certification of automatic tank
gauges (ATGs) and the various sen-
sors that are plugged into them.
Crompco primarily uses the fol-
lowing equipment and test methods:
• Tanks: Estabrook Ezy-3 Locator
Plus (a non-volumetric, underfill
tank testing methodology)
• Lines: Petro-Tite line tester
• Under-dispenser and tank-top
sumps: hydrostatic testing
• Spill buckets: both hydrostatic
and vacuum-based methodolo-
gies.
• ATG and associated sensors:
per manufacturer's instructions
and regulatory guidance.
Crompco has been using the
same testing technologies for a num-
ber of years, so this variable is con-
stant. Crompco also has a seasoned
team of testers, most with many
years of experience, so most of the
test data we will be looking at were
gathered by a relatively small group
of people.
14
In the interest of preserving
some of Crompco's proprietary data,
all of the numbers here are presented
as percentages. But in all cases, the
percentages are based on hundreds
to thousands of individual tests, so
we can be reasonably confident that
the percentages presented here rep-
resent accurate trends and are not
flukes due to a small sample size.
The Facts
Here are some graphs and a brief dis-
cussion of what we think might be
going on.
Piping
Overall, the piping tightness-testing
data (Figure 1) show that all types of
piping are performing pretty well.
There does not appear to be a sig-
nificant difference among single- or
double-walled fiberglass piping or
the flexible piping systems that are
in service today. Ed says they still
test some of the older yellow Total
Containment piping systems, but we
made no attempt to sort these out
from the flex-pipe category. Remem-
ber, these statistics are for passing
tests—there was no evaluation of
the condition of the pipe. There are,
however, some pretty scary looking
old flex-pipe systems that still man-
age to get passing test results. Steel
piping systems have a slightly lower
passing rate than FRP or flexible
pipe, but steel is still doing reason-
ably well. The dramatic improve-
ment in steel pipe performance in
-------
December 2011 • LUSTLine Bulletin 69
•ERCENT PIPING TESTS PASSE
2011 may not be a reliable trend as
there have been relatively few tests
of steel piping systems conducted in
2011.
Given the prevailing wisdom
that leaks today are mostly in piping,
the near perfect performance of these
piping systems may seem a bit per-
plexing. Where are the piping leaks?
When reviewing these data, keep
the following in mind:
• These piping tightness test
results do not include the dis-
penser components or the sub-
mersible pump. This is because
most tests are conducted with
the ball valve at the submersible
pump closed, so any leaks in the
submersible pump head will not
be "seen" by the test. Likewise,
Crompco testers typically run
the initial line test with the crash
valve open so the dispenser com-
ponents are tested, but if a leak
is found in a dispenser compo-
nent, the test is re-run with the
crash valve closed so the dis-
penser is no longer included
in the test. If the test with the
crash valve closed passes, the
result is recorded as a pass and
would appear as a pass in our
data. Crompco reports the leak
in the dispenser separately to the
owner or operator of the facil-
ity. So the leaks that are part of
our database are leaks that were
found between the ball valve
and the crash valve. This would
include flexible connectors in
fiberglass piping systems and
end fittings on flexible piping
systems, but not leaks in the sub-
mersible pump head or inside
the dispenser cabinet.
Liquid leaks in dispensers and
submersible pumps are very
often visible when a cover or lid
is removed. Most service techni-
cians who observe a leaking fil-
ter, meter, flexible connector, or
functional element are not going
to call in a tightness tester to con-
firm the leak. As a result, your
typical service technician will
likely discover a lot more liquid
leaks (as opposed to vapor leaks)
in the course of a year than your
typical tightness tester. The
service technician will simply
replace the leaking component
and there will be no tightness-
test results to document the
leak—only perhaps a test con-
ducted after the repair to docu-
ment that the piping is tight. The
point here is that we need to look
beyond tightness-test data to get
a handle on the universe of UST
releases. While dispensers and
submersible pumps have been
largely overlooked by the UST
regulations, they are clearly sig-
nificant contributors to the LUST
side of the program.
Tanks
Overall, the tank-testing data (Fig-
ure 2) show that all types of tanks are
performing pretty well, though not
quite as well at the piping. Fiberglass
tanks are performing a bit better than
steel tanks. Somewhat disturbing is
the sudden decrease in the passing
rate of double-walled steel tanks,
and to a lesser extent the fiberglass
tanks. This is true only for 2011 and
although we have only partial data
for 2011, the number of tanks tested
in each category is still significant.
These are trends worth keeping an
eye on.
• continued on page 16
FIGURE 2.
PERCENT TANK TESTS PASSED
Year
15
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LUSTLine Bulletin 69 • December 2011
• Facts, Part 2 from page 15
When reviewing these data, keep
the following in mind:
• The data we currently have do
not indicate whether the tank
failed to pass because of either
a liquid leak in the bottom of
the tank or a vapor leak from a
tank-top fitting. This information
could likely be gleaned from the
data sheets for the tests, but we
have not conducted that analysis
yet.
• The double-walled tank failures
may be underestimated. I know
that in Maine, for example, a ser-
vice technician who finds that
the interstitial space of a tank is
full of fuel will typically pump
out the fuel from the intersti-
tial space and return a week
or so later to see if the fuel has
returned. If the interstitial space
is again full of fuel the tank is
generally considered to have
failed and a tightness test is not
conducted. Maine has docu-
mented more than 50 failures of
jacketed and double-walled steel
tanks over the last five years.
• Maryland requires heating oil
and emergency generator tanks
to be tested at 15 years of age and
every 5 years thereafter. A fair
number of these tanks are pres-
ent in the Maryland data, and our
statistics may be skewed a bit by
the inclusion of these tanks in our
tank-testing statistics.
• The results of these tank tests
are encouraging when viewed
through a historical lens. Back
in the late 1970s, when one of
the first regulatory-driven tank-
testing programs was conducted
in Prince Georges County, Mary-
land, passing rates for tank tests
were 50 percent. When USEPA
conducted their tank-testing sur-
vey in the mid-1980s, the passing
rate was 65 percent. That we are
achieving tank-test passing rates
generally above 95 percent in
recent years is a measure of how
far we have come in our quest
to improve the integrity of our
storage systems. Still, we should
keep an eye on these numbers
and maybe dig a little deeper to
see how today's tanks are failing
16
FIGURE 3.
PERCENT SUMP TESTS PASSED
Figure 3: Percent Sump Tests Passed
2009 2010 2011 2012
Year
to be sure that our passing rate
isn't slipping as our tank popula-
tion ages.
Sumps
Keep in mind that a technician may
make simple repairs to sump com-
ponents (e.g., tightening a loose hose
clamp) before conducting a test or
after a failed test. Some of these pass-
ing results (Figure 3) may have ini-
tially been "fails" that were repaired
and passed when retested. In other
words, sumps in the "as found" con-
dition might have a lower passing
rate than what is reflected here.
The sump testing trend is
encouraging in that it shows that
greater numbers of sumps are pass-
ing tests over time, an indication
that once sumps are made tight, a
good many of them will stay tight
for a while. The data show little
difference in the performance of
fiberglass versus high-density poly-
ethylene (HDPE) plastic sumps.
This is perhaps an indication that
the major issues with sump leaks are
associated with the penetration fit-
tings that seal around the piping and
-------
December 2011 • LUSTLine Bulletin 69
electrical conduit that go through the
side of the sump walls.
The pronounced decline in pass-
ing tests in 2005 is most likely due to
a new sump-testing requirement that
went into effect in Maryland in that
year. Because a large number of the
Maryland sumps were being tested
for the first time, a large percent-
age of them failed. The sump-testing
data for Maryland only (Figure 4)
demonstrate that once the initial leak
problems are addressed, sump per-
formance increases substantially over
time and levels off to about a 95 per-
cent passing rate after a few years.
Spill Buckets
The trend in spill buckets is similar
to the sump trend (Figure 5). There
is a high failure rate initially that
improves with time as leaky spill
buckets are replaced. As this new
generation of spill buckets ages,
they may begin to fail as well and
we should see a decreasing trend in
the passing rate over time. If such a
trend comes to pass, it would give us
an indication of the real-world life
expectancy of spill buckets.
Line Leak Detectors
Figure 6 shows the percent of elec-
tronic and mechanical line leak detec-
tors (LLDs) that were successfully
able to detect a three-gallon per hour
leak each year. Overall, the electronic
line leak detectors are performing bet-
ter than the mechanicals, although
the performance of the mechanical
LLDs is steadily improving. We're
not sure what is responsible for the
improvement in the passing rate of
the mechanical LLDs, but it may be
the result of either better procedures
for testing LLDs or improvements in
the manufacturing of LLDs that have
made them more reliable.
The dip in the performance of
the electronic LLDs in 2005 and 2006
is likely due to a large increase in the
number of electronic LLDs that were
tested in MD and NJ in those years.
These were presumably electronic
LLDs that had not been tested pre-
viously. The substantial increase in
failure rate for the "first time" tests
points to the importance (despite
some manufacturer's claims) of
evaluating the performance of
these devices. Failure of electronic
LLDs to detect leaks can be due to
improper programming, air pockets
in the piping, or failure of the hard-
SPILL BUCKET TESTS PASSE
Figure 5: Spill Bucket Tests Passed
Year
FIGURES.
PERCENT LLD TESTS PASSED
Sfn
-•-Electronic HO
Year
ware itself. Review of the actual test
records would be required to deter-
mine which of these factors might be
responsible for the failed tests.
Monitor Certification
Monitor certification typically
involves checking the functional-
ity of the different components of
a tank gauge, including everything
from the alarm and indicator lights to
the sump and interstitial space sen-
sors. The data (Figure 7) show a pro-
nounced dip in 2006 and 2007. This
dip is associated with large increases
in the number of tank gauges that
were tested in these years in Mas-
sachusetts and New York, and likely
indicates that when checked for the
first time, the performance of UST
equipment is substantially less than
the performance when equipment is
routinely tested. Even when routinely
tested, however, the passing rate for
ATGs seems to level off at about 85
percent. Just looking at the raw data,
it is not possible to tell whether the
failures are due to programming
errors, burned-out light bulbs, or
• continued on page 18
17
-------
LUSTLine Bulletin 69 • December 2011
• Facts, Part 2 from page 17
failing sump sensors. A closer look
at the individual records would be
required to answer these questions.
Compliance Inspections
A number of states have third-party
inspection programs, and Crompco
personnel are certified as inspectors
in a number of states. The data for
Maryland, Massachusetts, and Penn-
sylvania (Figure 8) strongly point
to some consistency issues among
the state programs. While nearly all
inspections conducted in Massachu-
setts have a passing result, in recent
years less than 20 percent of the inspec-
tions conducted in Maryland have had
a passing result. Pennsylvania fits in
the middle, where generally between
40 and 60 percent of inspections have
a passing result. These dramatic dif-
ferences in results are likely due to
substantial differences in the compli-
ance criteria in each of these states.
Ed says the low passing rate in
Maryland may be because the state's
inspection criteria include not only
the usual UST issues but also Stage II
vapor recovery equipment, mainte-
MONITOR CERTIFICATION TESTS PASSED
200$ 2010 3011 2012
Year
OMPLIANCE INSPECTIONS PASSE
2003 2004
nance records, and testing documen-
tation.
A representative of a very con-
scientious tank owner who has tanks
in several states and saw a presenta-
tion that included these compliance
inspection statistics commented to
Ed that, "It's funny, in Pennsylva-
nia I never have a facility operations
inspection that fails, yet in Maryland
I never have a third-party inspection
that passes." A conscientious tank
owner who has a uniform standard
of UST operation for all of his storage
systems and who operates in these
three states would have good cause
to be frustrated.
So What Have We Learned?
Here are our observations:
• While we have not applied any
formal statistics to these data,
the test numbers are fairly large
and the trends fairly consistent
among different states, so we feel
that these data are reasonably
reliable. Overall, it looks like
UST system integrity is generally
good and improving in the states
that we evaluated.
• Tanks and piping are perform-
ing quite well, but there are
some trends worth watching
and it may be worthwhile to
dig deeper into the data to try
to understand the causes behind
some of the observed trends. Are
failures related to the type of fuel
or some other factor? Where are
the failures happening in dou-
ble-walled steel tanks—vapor
leaks at the top or liquid leaks at
the bottom?
• Take this analysis with a large
grain of salt. Storage systems
that pass tightness tests are not
necessarily free of releases. Some
components are not included
in routine tests and repairs are
often made before test results
are reported. Testing data will
underestimate release events
because components that fre-
quently leak (i.e., dispensers
and submersible pumps) are not
reported as part of piping tight-
ness tests, and service techni-
cians who observe leaks repair
them without conducting a tight-
ness test. We need to consult
with service technicians to get
a more complete picture of how
18
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December 2011 • LUSTLine Bulletin 69
USTs are performing. It might
also be instructive to gather data
on the "as found" condition of
containment sumps and spill
buckets so we can have a better
idea of whether these compo-
nents are tight when the tester
first comes to a site.
• Sump and spill bucket integ-
rity testing appears to improve
the reliability of these systems.
Sump and spill bucket integrity
is typically low during a first
round of testing but improves
over time. Reliability of sumps
and spill buckets is critical for
secondary containment to be a
viable leak-detection (and, even
more importantly, leak-preven-
tion) method.
• We should study why ATG sys-
tems are failing certification
procedures so we can figure out
how to improve their reliability.
Ed says that this may be pos-
sible by delving further into the
records.
A big question is: Will compli-
ance inspection procedures and
compliance criteria ever be standard-
ized enough to compare compli-
ance inspection results from state to
state? At the moment the differences
between state evaluation procedures
and passing criteria make such com-
parisons and data aggregation impos-
sible. Eventually, we may arrive at a
"just right" consensus on compliance
inspections, but for now comparing
data across states only tells us that
states are wildly different in their
approaches, much to the consterna-
tion of multi-state tank owners. •
Postscript
As we dig into the data, we keep finding
new questions to ask and new ways to
slice and dice the numbers. We're think-
ing there are likely at least a few more
LUSTLine articles in these numbers.
Are you interested? Let us know:
-Tom Schruben:
tschruben@ustcostrecovery.com
-Ed Kubinsky:
ed.kubinsky@crompco.com
-Marcel Moreau:
marcel.moreau@juno.com
Also, we'll be presenting and dis-
cussing testing data at a session at
next year's National Tanks Conference
not only from Crompco, but also from
Tanknology and Protanic. See you there!
Those Lead Scavengers Still
Persist in Old Product
by Jim Weaver and David Spidle
Thomas Midgley, Jr. patented
the use of tetraethyllead (TEL)
as a gasoline additive in 1926
(Midgley, 1926) to eliminate the
newly found problem of engine
knock. TEL was not a benign addi-
tive as it tended to precipitate on
engine components. So Midgley
soon found compounds, now known
as "lead scavengers," that would
prevent this problem by combining
with lead during combustion. Early
on, lead and lead scavengers were
sold as a package to be added to gas-
oline at refineries.
One prominent "scavenger," eth-
ylene dibromide (EDB), proved to be
an effective solution to this problem.
However, when the law of unin-
tended consequences was applied,
EDB proved to have lower volatility,
higher water solubility, and more tox-
icity than benzene. EDB has a maxi-
mum concentration level (MCL) 100
times lower than benzene (0.05 |Ug/L
EDB vs. 5 |Ug/L benzene) and has
been found to persist in groundwater.
EDB has been discussed in
LUSTLine several times. Ron Falta
and Nimeesha Bulsara of Clemson
University described many of the
issues associated with lead scaven-
gers in LL #47 (Falta and Busara,
2004). Based on their study of South
Carolina data, they found that EDB
was detected above its MCL at 25
percent of sites and at concentrations
of 0.5 fig/L to more than 50,000 fig/L.
In LL #50, Read Miner of South Car-
olina reported on a study of 104 EDB
confirmed sites to better understand
the lead scavenger problem. The
results showed plume lengths from
100 to 2,800 feet and concentrations
up to 40,000 fig/L (Miner, 2005). The
prospects for various remedial tech-
nologies were assessed from experi-
ence at these sites.
In subsequent LUSTLine issues
Steve Burton from USEPA Region 4
pointed out that leaded aviation gas-
oline and racing fuel were still sold,
but that manufacturers' material
safety data sheets didn't always indi-
cate the presence of the lead scaven-
gers (Burton, 2005). MarkToso (Toso,
2007) reminded us that 1,2-dichloro-
ethane (DCA) was also a lead scav-
enger and that in Minnesota, EDB
detections were rare in comparison
to DCA detections. That fewer EDB
detections were seen in Minnesota's
groundwater than in South Caro-
lina's could be attributed to various
causes, including differences in geo-
chemistry and temperature.
The USEPA Office of Under-
ground Storage Tanks (OUST) and
Office of Research and Development
(ORD) analyzed groundwater sam-
ples submitted by state tanks agen-
cies from sites that were likely to
contain leaded gasoline releases. The
study found that EDB was above its
MCL at 42 percent of sites, and DCA,
as detected, was above its MCL at 15
percent of sites (Wilson et al., 2008).
As a result of all of this work, OUST
issued a recommendation that states
test for the presence of lead scaven-
gers at sites where they are likely to
persist (www.epa.govjoust I'cat I'lead_
scavengers jnemo_05212010.pdf).
Ferreting Out State Data
To address an aspect of lead scaven-
gers that was not previously studied,
we asked states for product samples
from pre-1985 release sites to see
how much of the scavengers were
still in old product (Weaver et al.,
2011). We received gasoline samples
drawn from wells located primarily
in eastern states, which were about
evenly divided between north and
south. With our 76 samples in hand
from 10 states and 41 sites, we ana-
lyzed for TEL, EDB, and DCA.
Some of the results were as
expected: Samples containing TEL
or other forms of lead (tetramethyl-
lead and triethylmethyllead), also
contained EDB and DCA. Some
leaded gasoline samples contained
only EDB, which could be due to
leaching of the more highly water
soluble DCA. And then some leaded
gasoline samples contained no
scavengers, presumably also a result
of leaching.
• continued on page 20
19
-------
LUSTLine Bulletin 69 • December 2011
• Lead Scavengers from page 19
Beginning in 1974, USEPA man-
dated the sale of unleaded gasoline
to meet the needs of 1975 model year
vehicles. For a while, both unleaded
and leaded gasoline were sold at gas
stations, and it's likely that some sta-
tions had leaks of both leaded and
unleaded gasoline. Of our samples,
37 percent met USEPA's definition
of unleaded gasoline (less that 0.05
grams per gallon lead). Some of these
contained no scavengers, as expected.
A fraction, however, contained scav-
engers at concentrations almost as
high as the leaded gasoline, while
some contained EDB-only at low con-
centrations. We explored all possibili-
ties to explain these data. Analytical
error, preferential leaching, incorrect
formulation of the additive package,
as well as others were considered and
discarded in favor of the following
two hypotheses.
First, consider the possibility
that EDB was used as an agricultural
fumigant until its two main uses as a
pesticide were revoked in 1983 and
1984. Could the agricultural use of
EDB in groundwater, in effect, con-
taminate unleaded gasoline from
nearby leaking tanks by partitioning
from the water to the unleaded gas-
oline? Using the properties of EDB
and a transport model, we found that
the agricultural EDB could indeed
explain the existence of unleaded
gasoline samples containing only a
fewmg/LofEDB.
Ten to twenty years are needed
to produce this level of contamina-
tion because with the maximum EDB
in groundwater of 15 |Ug/L, only a
small amount of mass is available at
any given moment to partition into
the unleaded gasoline. Although
this explanation is plausible, sev-
eral of our samples were from urban
areas. These could be the result of
contact with a contaminant plume
that originated from leaded gaso-
line, rather than agricultural use of
EDB. The same mechanism would
be at work—groundwater that con-
tains EDB "contaminates" unleaded
gasoline, resulting in concentrations
of EDB in unleaded gasoline up to
about 20 mg/L.
Second consider the group of
our unleaded gasoline samples that
contained appreciable amounts of
EDB and 1,2-DCA. In a few samples
20
the concentrations were almost as
high as those found in the leaded
gasoline. Again, these are concentra-
tions that shouldn't exist, because
the unleaded gasoline should be free
of lead scavengers. After ruling out
analytical errors, we hypothesize
that these samples are the result
of multiple releases of leaded and
unleaded gasoline.
If sites exist where the leaded
gasoline is not commingled with the
unleaded gasoline, then the scaven-
gers can partition into the ground-
water. The organic leads remain in
the gasoline phase because the solu-
bility of the organic leads is very low.
The groundwater contaminated with
scavengers contacts the unleaded
gasoline, and over time the ground-
water "contaminates" the unleaded
gasoline. Our model results show
that this is a plausible explanation
of these samples and that several
years are required to complete EDB
transport through the leaded and
unleaded gasoline.
Thinking It Through
Looking back at our leaded gasoline
samples, some of these had fairly
low lead content, but the use of lead
in gasoline was more variable than
most people think: During the lead
phase-down, the lead content of gas-
oline was highly variable and con-
centrations could range from 0 g/gal
to a maximum of 4 g/gal in the early
years and up to 1 mg/L in the late
1980s (Weaver et al., 2010, figure 1).
On the other hand, some of the sam-
ples could represent commingled
leaded and unleaded gasoline and
the concentrations would depend
on the ratio of the two as well as the
lead content of the leaded gasoline.
At some sites commingling of prod-
uct may have resulted in samples
with low lead content, while at oth-
ers the two gasoline types might
have been fairly well separated, so
the unleaded gasoline gained scav-
engers.
These scenarios can also explain
the extended persistence of EDB
and DCA contamination in aquifers.
If the releases were such that the
scavengers had to migrate through
the unleaded gasoline zone, a long
time would be required to exceed
the scavenger-holding capacity of
the unleaded gasoline. In effect, the
unleaded gasoline acts like a large
sink for the scavengers. This would
be similar to placing a huge reservoir
of organic carbon into the aquifer;
it would retard the transport of the
contaminants and then return them
to the groundwater over time. In
effect, the source lifetime is increased
and the plume exists for longer peri-
ods in the groundwater.
The various studies of lead scav-
engers—South Carolina (Falta and
Bulsara, 2004; Minor, 2005), U.S.
groundwater (Wilson et al., 2008),
and this 2011 study—show that wide-
spread contamination still exists from
lead scavengers at old release sites.
Because releases of unleaded gasoline
can occur after previous leaded gaso-
line releases, lead scavenger contami-
nation could persist from a time when
scavengers weren't considered in site
assessment. To eliminate exposure to
these contaminants, and as noted in
OUST's recommendation, sampling
and analysis for scavengers is very
much needed at sites where releases
of leaded gasoline are likely to have
occurred. •
Jim Weaver is a Research Hydrologist
at the USEPA, Office of Research and
Development, Groundwater and Eco-
system Restoration Division in Ada,
Oklahoma. He can be reached at weaver.
jim@epamail.epa.gov. David Spidle is
Research Chemist at the USEPA, Office
of Research and Development, Eco-
systems Research Division in Athens,
Georgia. He can be reached at spidle.
david@epa.gov.
This paper has been reviewed in accor-
dance with USEPA's peer and adminis-
trative review policies and approved for
publication. Mention of trade names or
commercial products does not constitute
endorsement or recommendation for use.
References
Burton, S. "Leaded gasoline? Hmm, what's in those
underground storage tanks?" LUSTLine, New Eng-
land Interstate Water Pollution Control Commis-
sion: Lowell, Massachusetts 2005, 50,15-16.
Falta, R.W. and N. Bulsara, "Lead Scavengers: A
Leaded Gasoline Legacy?," LUSTLine, New Eng-
land Interstate Water Pollution Control Commis-
sion: Lowell, Massachusetts, 2004, 6-10.
Midgley Jr, T. Fuel. U.S. Patent 1592954, July 20,1926.
Miner, R., "What South Carolina is learning about
ethylene dibromide (EDB) at LUST sites," LUST-
Line, New England Interstate Water Pollution Con-
trol Commission: Lowell, Massachusetts 2005; 50,
11-14.
• continued on page 26
-------
December 2011 • LUSTLine Bulletin 69
The "Twofer" Economic Theory
How Symbiotic Relationships Can Benefit Multiple
Governmental Organisms
by Gary Lynn
Whenever I need two of anything, I look for a twofer.. .can't beat getting two for the price of one! Certainly there are worse
philosophies to live by, and in our current political and economic climate, this may be one of the few viable ways to obtain
additional resources. So with the twofer economic theory in mind, New Hampshire's leak prevention and petroleum reme-
diation programs have worked out a number of cooperative strategies that help both programs. Achieving simultaneous progress in
multiple programs is a welcome challenge for the hard-core twofer lover.
The Sleuthing Advantage
The ultimate objective of the UST
compliance program is leak preven-
tion. On the release side, the petro-
leum remediation program is tasked
with cleaning up leaks quickly and
cost effectively. If releases are pre-
vented or eliminated faster, both
the remedial program and the reim-
bursement fund benefit, and the tank
program fulfills its mandate. Work-
ing together on leaks is therefore
advantageous to both programs—a
classic twofer—but not always a
modus operandi in tank programs.
In New Hampshire, we are
lucky to have a staff member, Jason
Domke, who worked at an environ-
mental consulting firm, then as a
tank inspector, and now with our
remedial program. Over time, the
tank and remedial programs have
worked out a mutually beneficial
arrangement that takes advantage
of his background. Jason visits each
tank closure so he can direct initial
remedial efforts before the excava-
tion is backfilled, dramatically reduc-
ing long-term remedial costs. During
this same site visit he completes a
tank leak autopsy. His familiarity
with tank hardware and leaks makes
him the perfect candidate for both
activities.
Cooperation among programs
goes beyond this, however. Moni-
toring-well networks are in place at
about one-third of the state's active
gas stations, due to past releases.
These networks have successfully
detected new releases at a number of
sites where leak detection equipment
did not. Whenever the groundwater
monitoring data suggest that a new
leak is present, Jason is sent out to
investigate. He completes a normal
tank inspection that helps the tank
program fulfill its three-year tank-
inspection-cycle mandate, and he
also dissects the tank system until
he identifies and eliminates the leak.
In a number of cases, his trouble-
shooting eliminated leaks that were
impossible to detect via normal site
inspections and standard leak detec-
tion methods.
For example, Jason was sent to
troubleshoot a facility where ground-
water contamination was detected
in a monitoring well near the dis-
pensers. His detective work uncov-
ered serious compliance issues that
led to the release. The owner failed
to report two unusual operating
conditions: 1) one of the dispens-
ers had been hit by a car, and 2) the
line leak detector was in alarm. A
cosmetic dispenser repair failed to
include retightening the crash valve,
and the line-leak-detector alarm was
traced to a leaking flex connector.
Quick detection and elimination of
the leaks minimized the release and
future cleanup costs.
In another case, Jason found a
large subsurface vapor leak resulting
from improperly manifolded vapor
recovery lines—a leak large enough
to cause indoor air and groundwater
problems but small enough to pass
the pressure-decay test. Once again,
the problem was buried under-
ground and missed by ongoing
inspection and leak detection efforts.
Jason even found an intermit-
tent problem at another site caused
by a line-leak-detector diaphragm
failure. It only leaked during the
infrequent periods when the pump
was activated at this low-volume gas
station—lines and tanks tested tight.
Persistence was the key. There are
many other examples; in every case
leak troubleshooting started imme-
diately, thanks to Jason's seasoned
sleuthing prowess, and a leak was
arrested earlier than it would have
been otherwise.
In addition to all these efforts,
Jason participates in all of our opera-
tor training sessions. He is able to
provide graphic examples of the
impacts of inattention on leak pre-
vention, help troubleshoot facility
owner issues, and answer questions
concerning the remedial program.
The advantages to each of our
tank programs are obvious. The
remedial program saves money on
cleanup costs by minimizing the size
of releases, removing source areas
early on in the process, and helping
the leak prevention program uncover
weaknesses in their leak preven-
tion efforts. The prevention program
also benefits by having an additional
resource for inspections, operator
training, and leak autopsies.
The Tank Upgrade Deadline,
Foreclosures, and Temporary
Closures
One of the biggest challenges facing
New Hampshire's tank compliance
program is its 2015 deadline for clos-
ing all single-walled tank and piping
systems. The single-walled systems
meet federal regulations but not our
more stringent state rules. In addi-
tion to that looming deadline, there
have been a rash of foreclosures and
"temporary" tank closures brought
on by the harsh economic climate
for gas stations. Here, the petroleum
brownfields and the tank compliance
programs have common interests
and another possible twofer oppor-
tunity.
In New England, petroleum
brownfields programs have indi-
cated that they are finding it difficult
to locate eligible sites. To be eligible
for state grant assistance, the owner
• continued on page 22
21
-------
LUSTLine Bulletin 69 • December 2011
• Twofer Economics from page 21
of a property cannot be both liable
and financially viable, and the owner
must be looking to redevelop or sell
the property. Essentially, the brown-
fields programs are looking for the
same sites that the tank compliance
program needs to address.
Owners that aren't financially
viable tend to have their tanks in tem-
porary closure, are unable to afford to
upgrade or remove their tanks, and
are more likely to be looking to sell or
redevelop their property. Brownfields
programs can remove tanks, when
required as part of the site assess-
ment, as well as complete due-dili-
gence investigations and hazardous
materials surveys of buildings. Tank
compliance programs benefit by the
removal of the tanks, new ownership,
or creating a more financially viable
property.
To take advantage of this oppor-
tunity, the tank program has devel-
oped data-mining computer queries
that provide information on all tank
systems that need upgrades, are in
temporary closure, and are double-
walled tanks that have failed. In
addition to data mining, the tank
inspectors talk to tank owners about
their plans and problems. When the
tank inspectors identify owners that
would like to remove tanks but are
unable to do so, they alert the petro-
leum remediation program, which
passes the information on to the
appropriate local, regional, or state-
wide brownfields program. This
collaborative effort has addressed, to
date, more than 50 tanks and 25 facil-
ities. While this is a little less than
10 percent of the tank upgrade uni-
verse, it will make a significant dent
in the 2015 tank upgrade deadline if
we are able to continue at the current
pace of cooperative assistance.
Lessons Learned
What we've learned over the years is
broadly applicable:
• Information sharing is critical.
Without a good understanding
of an allied program, it is impos-
sible to find efficiencies and suc-
cessfully leverage them.
• Improvements in efficiency and
resource allocations are possible
whenever programs share simi-
lar goals and overlapping site
locations (e.g., combining tank
inspection with the vapor recov-
ery program was very successful
in our state).
• Cooperative strategies typically
result in better overall program
outcomes. Petroleum brown-
fields site identification is signifi-
cantly enhanced in our state by
direct contacts made by our tank
inspectors, mutually benefiting
both programs.
Cooperation and cross-fertil-
ization between programs is likely
to continue. Just the other day, for
example, Mike Juranty, tank com-
pliance program administrator,
announced that his horse stalls
need mucking out. I need a load of
manure to activate my leaf compost
pile. Looks like another twofer is on
its way that would have been impos-
sible to pull off without good com-
munication between programs. •
Gary Lynn is Petroleum Remedia-
tion Program Manager with the New
Hampshire Department of Environ-
mental Services. He can be reached at:
Gary.Lynn@des.nh.gov.
Why New Hampshire UST Operators
Are Choosing Classroom Training
by Suzanne Connelly
New Hampshire's Class A
and B operator training stat-
ute allows various alterna-
tives for compliance—International
Code Council (ICC), online courses,
webinars—but the option of attend-
ing the Department of Environ-
mental Services (NHDES) day-long
classroom training has become the
preferred choice among operators.
Classroom-style training has many
benefits. There is value in the inter-
actions between speakers and opera-
tors, in handling actual equipment,
and in sharing experiences with the
regulated community at large.
Quality presenters are an essen-
tial feature to classroom training.
New Hampshire uses six present-
ers from different areas of their Oil
Compliance section. Engineers offer
expertise on compatibility and how it
applies to the installation and main-
22
tenance of a tank system. Inspectors
explain how to recognize the signs of
failed or faulty tank components and
bring attendees up to date on UST
news and regulations. In addition to
the presenters, the trainees also share
their own experiences during discus-
sions, another advantage to this edu-
cational setting.
Although webinars and online
programs are convenient, they tend
to lack the hands-on benefits of an
interactive classroom. Such partici-
pation allows prospective Class A
and B operators to see and handle
assorted tank components. NHDES
UST staff have collected and cleaned
their display pieces in order to
demonstrate ways in which UST
components can be compromised
in contrast with how functioning
equipment should appear.
For example, broken vent caps
show the kind of damage that can be
caused by hailstorms. Softened pip-
ing demonstrates what can happen
when an incompatible fuel compro-
mises certain tank-system compo-
nents. Damaged dispenser nozzles
due to customer misuse show attend-
ees that it's in their best interest to
check their equipment periodically.
The importance of monthly visual
inspections is driven home for the
operator who has firsthand exposure
to the equipment.
Evaluation forms provide feed-
back to presenters and the overall
operator training program. Their
remarks reinforce NHDES' com-
mitment to training Class A and B
operators through their preferred
classroom setting. Such efforts will
certainly help New Hampshire reach
the U.S. Energy Act August 8, 2012,
operator training deadline. •
Suzanne Connelly supervises the UST
Operator Training Program for the
New Hampshire Dept. of Environ-
mental Services. She can be reached at
Suzanne.Connelly@des.nh.gov.
-------
December 2011 • LUSTLine Bulletin 69
from Robert N. Renkes, Executive Vice President, Petroleum Equipment Institute (PEI)
PEI Lends a Hand on Compatibility and Equipment Testing Issues
USEPA has cleared E15 for use in certain Model
Year 2001 and newer light-duty motor vehicles,
and it won't be long before the new higher-level
blend fuel is registered and legal to market.
Federal law (40 CFR §280.32) requires that under-
ground storage tank systems (USTs) be compatible with
the substance to be stored. If tank owners wish to store
fuels with 15 percent or more ethanol—or diesel with
more than 20 percent biodiesel—the obvious choice for
new facilities is to install equipment listed by Under-
writers Laboratories (UL) as compatible for that fuel.
Equipment manufacturers now have equipment avail-
able that is compatible with these new blends. But what
about the legacy UST systems that were purchased and
installed before this newer equipment was listed and
made available to tank owners?
USEPA guidance says UST system owners also may
demonstrate compatibility and meet the requirements
of 40 CFR §280.32 if the manufacturer of the UST com-
ponent approves it as compatible. USEPA identified 12
types of UST components that must be compatible with
the substance to be stored—again, either listed by UL or
approved by the manufacturer as compatible. The list is
extensive and includes:
• Tank or internal lining
• Piping
• Line leak detectors
• Flexible connectors
• Drop tubes
• Spill and overfill prevention equipment
• Submersible turbine pumps and components
• Sealants (including pipe dope and thread sealants),
fittings, gaskets, o-rings, bushings, coupling, and
boots
• Containment sumps (including submersible turbine
sumps and under-dispenser containment)
• Release detection floats, sensors, and probes
• Fill and riser caps
• Product shear valves
PEI and its members see manufacturer approval as
a reasonable and practical approach to the listing alter-
native. Shortly after USEPA identified the four elements
that UST component manufacturers were required to
include in their compatibility statements, manufacturers
began to draft their letters.
The elements component manufacturers must
include in writing on compatibility are:
• An affirmative statement of compatibility
• Specifying the range of biofuel blends the compo-
nent is compatible with
• Directly from the manufacturer.
The issue then became how to get the letters in the
hands of the UST owners/ operators, regulators, and
equipment vendors who needed them.
It occurred to us at PEI that a single, industry-wide
repository for the affirmations of all manufacturers
would bring a great deal of efficiency to the distribution
process. The UST Component Compatibility Library
was created in late summer of 2011 to do just that.
Residing at http://iviviv.pei.org/PublicationsResources/
ComplianceFunding/USTComponentCompatibilityEibrary.
aspx, the Library contains statements from manufactur-
ers of products in the 12 affected categories identified by
USEPA. As of this writing, it contains statements from
over two dozen manufacturers. Available 24/7, all let-
ters are posted as PDFs that can be easily downloaded
and printed. The letters are on company letterhead and
include a name and contact person should questions
arise.I
PEI's Recommended Practices for the Testing and Verification of Spill, Over-
fill, Leak Detection, and Secondary Containment Equipment at UST Facilities
USEPA has proposed to revise its 1988 UST regu-
lations (see story page 11) by increasing the
emphasis on properly operating and main-
taining equipment. Although the 1988 UST regulation
required that owners and operators have spill, over-
fill, and release detection equipment in place, it did
not require proper operation and maintenance for that
equipment. For example, USEPA required that spill
prevention equipment capture drips and spills when
the delivery hose is disconnected from the fill pipe but
did not require periodic testing of that equipment. The
proposed revision published in the November 18, 2011
Federal Register will require that UST equipment is oper-
ated and maintained properly, which should go a long
way in improving environmental protection.
USEPA is proposing owners and operators test
equipment by using either requirements developed by
the manufacturer of the equipment or a code of prac-
tice developed by a nationally recognized association
or independent testing laboratory. The manufacturer's
requirement is an option only when the owner/opera-
tor knows who made the equipment and that the specific
manufacturer has developed a testing requirement.
In response to the proposed regulation, USEPA
anticipates that nationally recognized associations or
independent laboratories will develop codes of practice
for spill, overfill, leak detection, and secondary contain-
ment equipment tests. The agency also anticipates that
manufacturers will develop testing requirements. In
• continued on page 24
23
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LUSTLine Bulletin 69 • December 2011
, continued from page 23
addition, USEPA is providing implementing agencies
flexibility to allow other methods they determine to
be protective of human health and the environment as
the manufacturer's requirements or a code of practice.
This option allows alternatives in the event that codes
of practice and manufacturer's testing requirements are
not developed.
Those of us in the industry have known for quite
some time that for leak detection, release prevention,
and overfill equipment to be operated effectively and
safely, it must be maintained, inspected, and tested for
proper operation on an ongoing basis. A little over two
years ago, requests from UST system owners and opera-
tors, equipment testers, and regulators encouraged PEI
to embark on a project to produce a single authoritative
source of information—a code of practice—that rep-
resents a synthesis of industry procedures and manu-
facturer's recommendations relating to testing and/or
verifying spill, overfill, leak detection, and secondary
containment equipment. A draft of that document, Rec-
ommended Practices for the Testing and Verification of Spill,
Overfill, Leak Detection and Secondary Containment Equip-
ment at UST Facilities (PEI/ RP1200), is in the final stages
of production and will soon be available for comment at
iviviv.pei.org/rpl200.
The practices described in PEI/RP1200 are the con-
sensus recommendations of the PEI Overfill, Release
Detection, and Release Prevention Equipment Testing
Committee. The committee is made up of represen-
tatives from equipment suppliers, tank owners, leak
detection and release prevention testers, industry-
related associations, and the regulatory community. In
instances where there were differences or omissions in
material available from existing sources, this committee
has included its own consensus recommendations based
on the practical experience of its members. •
NOTE: PEI's procedures provide that anyone can review and
comment on its proposed recommended practices. Because of
its length and technical nature, a 45-day comment period has
been established. You are encouraged to review the draft care-
fully. If you find it acceptable as written, no response is nec-
essary. On the other hand, if you take issue with any of the
language in the recommended practices, please submit com-
ments on the form available at iviviv.pei.org/rpl200 by the
deadline shown.
WARREN ROGERS, FATHER OF SIR
by Marcel Moreau
Dr. Warren Rogers, founder and president of Warren Rogers Associates,
Inc., passed away on October 29. Warren was known in the tank world for
developing a means of predicting the failure of unprotected steel tanks and
for introducing Statistical Inventory Reconciliation (SIR). Until he arrived on the
underground storage tank scene in the late 1970s, that world had never attracted the
interest of statisticians.
"Oil men," as they were known in those days, were baffled by why some steel tanks seemed to last forever and some failed
in a few years. Warren did a little studying of corrosion and figured that with a little data, he could answer that question.
In 1981, his analysis produced a methodology for tank-life prediction that was incorporated into Connecticut's first-
generation regulations and used by some major oil companies to prioritize their tank-upgrading programs.
In the 1990s, corrosion companies used the methodology extensively to evaluate whether or not a storage tank was
suitable for the addition of cathodic protection. Using industry data, Warren famously calculated in 1982 that some 70,000
tanks were leaking at that time and that another 350,000 would be leaking in five years, in 1984 he appeared in the original
60 Minutes piece on the leaking tank problem, a broadcast that helped bring the tank problem to the average American's
awareness.
Inventory control was another field where Warren's unshakable confidence in the value of data and the ability of statistics
to reveal the truth led him to develop SIR. While others would later imitate Warren's lead, none would ever equal the depth
of his analysis or his grasp of what all those inventory measurements could tell you. With the development of computers
and ATGs, Warren saw early on the possibility that these tools could take inventory to levels of accuracy that no one had
ever dreamed possible, and after years of development, a completely automated inventory procedure was born.
Warren has passed on. But he leaves the tank world an awesome legacy of using data and statistics to solve real world
problems. His vision and his talents significantly shaped the tank world we see today. •
24
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December 2011 • LUSTLine Bulletin 69
FAQs from the NWGLDE
...Allvou ever wanted to know about leak detection, but were afraid to ask.
Secondary- and Spill-Containment Test Methods
In this LUSTLine FAQs from the National Work Group on Leak Detection Evaluations (NWGLDE), we will discuss the reasons why
there is an absence of secondary- and spill-containment test-method equipment listings. Note: The views expressed in this col-
umn represent those of the work group and not necessarily those of any implementing agency.
Q
Why are there no secondary- and spill-contain-
ment test methods on the NWGLDE list when the
NWGLDE has a Secondary- and Spill-Contain-
ment Test Methods Team?
A. Before we answer the question, we want to make
sure everyone understands what kinds of test meth-
ods fall under these categories. Secondary-contain-
ment test methods are used to test the integrity of
tank-top and piping transition containment sumps,
and under-dispenser containment sumps, while
spill-containment test methods test the integrity of
spill catchment basins (spill buckets).
If you look at our mission statement at www.nwglde.
org, you will find that the appearance of a method
on the NWGLDE list is dependent on a third-party
evaluation being performed on that method in
accordance with a protocol found to be acceptable
by the work group. Since there are currently no
protocols for evaluating secondary- and spill-con-
tainment test methods that have been found to be
acceptable by the NWGLDE, there can be no third-
party evaluations and thus no equipment listings
for these test methods
Q.
• Why are there no acceptable protocols for evaluat-
ing Secondary- and spill-containment test meth-
ods
Most state, territorial, and local regulatory agencies
do not have regulations that require secondary- and
spill-containment testing. Those that do require the
testing are currently approving or simply allowing
the use of secondary- and spill-containment test
equipment based either on the manufacturer's per-
formance claims or without consideration of per-
formance, rather than waiting for the equipment to
appear on the NWGLDE list. As long as the equip-
ment is allowed to be used without a third-party
evaluation, there would seem to be no incentive to
invest in writing a protocol and performing a third-
party evaluation.
However, for underground storage tank and piping
leak detection equipment there is an advantage to
being listed by the NWGLDE. These manufactur-
ers do not have to pursue approval from each and
every state, territorial, and local regulatory agency,
because most regulatory agencies' underground
storage tank and piping leak detection equipment
approvals are based on whether or not the equip-
ment is listed by the NWGLDE. Since only a few
agencies regulate secondary- and spill-contain-
ment test methods, there is currently no regula-
tory agency approval advantage to being on the
NWGLDE list.
One other thing that could also be discouraging
protocol development is the lack of either national
consensus or regulatory performance standards
for secondary- and spill-containment test meth-
ods. Since there is currently a variety of these test
methods on the market that vary significantly in
performance, manufacturers may be putting off
investing in a protocol and third-party evaluations
now in order to try to avoid having to repeat the
evaluations if a nationally recognized performance
standard is established that is more stringent than
their performance claims.
Lj. What will it take to encourage secondary- and
spill-containment test method protocols to be
written?
A. Protocols will most likely be written and third-
party evaluations performed when most states
require secondary- and spill-containment testing
in accordance with a nationally recognized perfor-
mance standard. The best way this can be accom-
plished is for USEPA to write regulations requiring
this testing and encourage regulatory agencies to
adopt them.
The good news is that USEPA is currently looking at
their first major revision to the federal underground
storage tank rules since the rules came out in 1988,
and the agency has proposed operation and main-
tenance requirements for UST system components,
including requirements to perform secondary- and
spill-containment testing.
USEPA is proposing to require UST-system own-
ers and operators to test tank and piping interstitial
areas used for release detection (and not continu-
ously monitored) at least once every three years
using vacuum, pressure, or liquid testing. Sumps
used as secondary containment must also be tested
under the proposed rule change, unless the sump
is double-walled and the space between the walls
is monitored continuously. Additionally, USEPA
proposes to require spill-containment testing at
installation and at least every 12 months thereafter,
unless the spill containment is double-walled and
the space between the walls is monitored continu-
ously.
• continued on page 26
25
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LUSTLine Bulletin 69 • December 2011
FAQs... continued from page 25
Testing of these areas would need to be in accor-
dance with express requirements developed by the
manufacturer, a performance standard developed
by a nationally recognized association or indepen-
dent testing laboratory, or requirements established
by the implementing agency. The proposed rule can
be viewed at iviviv.epa.gov/OUST/fedlaivs/propose-
dregs.html and includes details about the continuous
monitoring exception.
In the meantime, if a manufacturer wants to try to
get a jump on the evaluation process, the NWGLDE
is willing to review new secondary- and spill-con-
tainment test protocols and third-party evaluations.
Once a third-party evaluation is performed and
submitted to the NWGLDE, if found acceptable, the
equipment could be listed with each test method's
limitations, precision, and accuracy. When nation-
ally recognized performance standards are finally
in place, if the listed equipment is within those stan-
dards, the equipment would be able to remain on
the NWGLDE list. •
• About the NWGLDE
The NWGLDE is an independent work group comprising ten mem-
bers, including nine state and one USEPA member. This col-
umn 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, contact them at
questions@nwglde.org.
NWGLDE's Mission
• Review leak detection system evaluations to determine if each eval-
uation was performed in accordance with an acceptable leak detec-
tion test method protocol and ensure that the leak detection system
meets USEPA and/or other applicable regulatory performance stan-
dards.
• Review only draft and final leak detection test method protocols
submitted to the work group by a peer review committee to ensure
they meet equivalency standards stated in the USEPA standard test
procedures.
• Make the results of such reviews available to interested parties.
Jacksonville, MD: Exxon Hit with
$1.5 Billion in Compensatory and
Punitive Damages
In 2007, Glen Thomas, a resident
of Jacksonville, Maryland, wrote
an article for LUSTLine titled "It
Should Never Have Happened: The
Story of a 26,000-Gallon Gasoline
Release in Jacksonville, Maryland
and Its Aftermath on This Rural
Community." This summer, after a
six-month trial in the Circuit Court
for Baltimore County, Maryland, the
160 households and businesses that
brought suit against ExxonMobil
Corp. had the satisfaction of receiv-
ing a verdict in their favor, amount-
ing to $495 million in compensatory
damages and $1 billion in punitive
damages associated with the 2006
gasoline leak discussed by Thomas.
The jury of six women deliber-
ated for two days on the amount of
punitive damages, which, according
to the law offices of Peter G. Ange-
los PC, the firm that represented
the plaintiffs, covered intentional
misconduct by Exxon, including
misrepresentations in information it
gave county officials and the Mary-
land Department of the Environment
(MDE). Jurors also faulted the com-
pany for not mentioning the release
26
on a sign that was posted for a few
days on the site, which said the sta-
tion was "Temporarily Closed for
Upgrade." The release had been
ongoing for 34 days before it was
reported to the MDE.
The jurors awarded compen-
satory damages for diminution of
property value, past loss of use and
enjoyment, fear of cancer, fear of loss
of property value, and medical moni-
toring, although not all plaintiffs
sought damages in every category.
Plaintiffs received an award for dimi-
nution of some 60 percent of the pre-
release value of their home, $750,000
for emotional distress due to fear of
cancer, $250,000 for emotional dis-
tress or anxiety over diminution in
the value their property, and sub-
stantial awards in varying amounts
for past loss of use and enjoyment.
Medical monitoring awards ranged
from less than $10,000 to more than
$1 million based on individual life
expectancies.
As Glen Thomas noted in his arti-
cle, "It should never have happened."
Exxon has noted an appeal. •
UST Caselaw Digest
Now Available
USEPA's Office of Site Remediation
Enforcement (OSRE) has prepared
an Underground Storage Tank Case-
law Digest to serve as a reference
tool to assist USEPA headquarters
and regional staff, as well as state
agency staff in their enforcement
efforts. The digest is a compre-
hensive compilation of documents
related to the federal UST enforce-
ment and compliance program.
OSRE will continue to periodically
update the digest, which is available
at http://intranet.epa.gov/oeca/osre/
documents/lust/index.html. •
• Lead Scavengers from page 20
Toso, M., "Never Mind EDBB, What About 1,2-DCA?
Minnesota's Curious Little Piece of the Puzzle,
"LUSTLine, New England Interstate Water Pollu-
tion Control Commission: Lowell, Massachusetts,
2007, 57, 5-6.
Wilson, J. T.; Banks, K.; Earle, R. C; He, Y; Kuder, T.;
Adair, C. Natural Attenuation of the Lead Scavengers
1,2-Dibromoethane (EDB) and 1,2-Dichlrorethane (1,2-
DCA) at Motor Fuel Release Sites and Implications for
Risk Management. USEPA, Washington, DC, 2008,
EPA/600/R-04/1790.
Weaver, J.W.; Exum L.R.; Prieto, L.M. Gasoline Com-
position Regulations Affecting LUST Sites, U.S.
EPA, Washington DC, 2010, EPA600/R-10/001.
Weaver, J.W.; Spidle, D.L.; Hassan, S.M. Lead Scaven-
gers in Gasoline from Leaking Underground Stor-
age Tank Sites, submitted to Environmental Science
and Technology, 2011.
-------
December 2011 • LUSTLine Bulletin 69
Visit NEIWPCC's Online Clearinghouse for
UST Inspectors
6NEIWP
The New England Interstate
Water Pollution Control Com-
mission (NEIWPCC) has been
working with USEPA's Office of
Underground Storage Tanks (OUST)
for over 25 years to enhance infor-
mation-sharing and provide train-
ing among state,
territorial, and tribal
UST, LUST, and State
Fund programs.
NEIWPCC coordi-
nates with OUST
to increase national
UST compliance and
improve the knowl-
edge base of UST
enforcement officials
by developing both
online and in-person
inspector training ses-
sions and hosting a
dedicated UST inspec-
tor website.
Since 2010,
NEIWPCC, OUST,
and a national UST
Inspector Training
Team comprised of
federal and state UST representatives
have been engaged in an ongoing
process of developing UST inspec-
tor training courses. Training topics
are chosen based on state recommen-
dations and recognized issues. Past
presenters include field experts, state
inspectors, manufacturers, and UST
equipment vendors. Since the Team's
inception, six national webinars (i.e.,
Tank and Line Tightness Testing, Sec-
ond Tank and Line Testing, Secondary
Containment, Corrosion Protection,
New Installations, and High-Through-
put Facilities); six region-wide, in-per-
son trainings; and one region-wide
webinar have been offered. One new
webinar (Automatic Tank Gauges) is
scheduled to be offered.
and archives of advanced training
webinars coordinated by NEIWPCC.
To find information on webinars,
classes, and to access the Inspec-
tor Forum, visit www.neiwpcc.orgl
ustinspectors.asp. •
New England Interstate Water Pollution Control Commission
Underground Storage Tanks i UST inspectors
Training Resources
Inspectors Forum
NEIWPCC Webinars
Webinar Archive
Training Schedule
Inspector References
Funded through a cooperative agreement with OUST,
NEIWPCC is working with state and EPA staff to develop and
provide LIST inspector training opportunities for state
programs nationwide. This website aims to serve as a focal
point for all state UST inspectors - a clearinghouse of
pertinent inspector information. Here you will find information
on available online and classroom training, an online forum
dedicated to LJ5T inspectors, links to state resources
(guidance documents, handbooks, checklists, etc.), and much
If there are additional links or items you would like to see included on the website, or you have
any questions regarding the site, please contact Jaclyn Harrison, coordinator of NEIWPCC's
UST/LUST Workgroup, atjharrison@neiwpcc.org
In early 2010, NEIWPCC
launched an UST inspector website
developed solely to serve as a clear-
inghouse for UST inspector news,
training information, and compli-
ance tools. The website also hosts an
online forum where federal, state,
and tribal UST inspectors can upload
questions and comments in order
to promote inspector interaction
and discussion. Finally, the website
includes registration information
Slots are available for state and
regional inspectors to participate on
the National Inspector Training Team.
The time commitment is minimal,
and you will have the opportunity
to provide valuable feedback and
guidance on UST inspector needs.
For more information, contact Jaclyn
Harrison, NEIWPCC, at 978-349-2507
orjharrison@neiwpcc.org.
Name
Subscription Form
Company/Agency
Mailing Address.
Email Address
LJ One-year subscription: $18.00
J Federal, state, or local government: Exempt from fee. (For home delivery, include request on agency letterhead.)
Please enclose a check or money order (drawn on a U.S. bank) made payable to NEIWPCC.
Send to: New England Interstate Water Pollution Control Commission 116 John Street, Lowell, MA 01852-1124
Phone: (978) 323-7929 • Fax: (978) 323-7919 • lustline@neiwpcc.org • www.neiwpcc.org
27
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LU.ST.JNE
New England Interstate Water
Pollution Control Commission
116 John Street
Lowell, MA 01852-1124
,gust 1985/Bulletin #1 - June 2011/Bulletin #68
The LUSTLine Index is ONLY available online.
To download the LUSTLine Index, go to
www.neiwpcc.org/lustline/and then click on LUSTLine.
NATIONAL TANKS CONFERENCE & EXPO
*NEIWPCC &ERA AST5WMO
-N
•U
JVIISSOURL
National
TRNKS CONFERENCE
March 19-21, 2012
Registration for the 23rd National
Tanks Conference and Expo in St.
Louis, Missouri, is now open! The
2012 agenda features sessions cover-
ing a wide range of underground stor-
age tank topics, including operator
training, remediation technologies, and
crucial financial responsibility issues.
In addition to the educational sessions,
ample opportunities for informal net-
working will be provided, allowing you to share knowledge and experiences with fellow attendees. The Expo will once
again feature informative booths from states, tribes, and federal agencies, as well as displays from vendors showcasing
the latest tanks-related products and services. As a host city, St. Louis offers several outstanding social opportunities
which we know will enhance your conference experience.
The conference website will be updated regularly with the latest information, so please visit it often. Additionally, if you
wish to be included on the National Tanks Conference e-mail list to receive periodic updates and reminders about the
conference, please send your e-mail address to NTCInfo@neiwpcc.org. We look forward to seeing you in St. Louis in
March! •
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