New England Interstate
Water Pollution Control
Commission
www.neiwpcc.org/lustline
116 John Street
Lowell, Massachusetts
01852-1124
Bulletin 7O
May 2012
LUS.T.UNE
A Report On Federal & State Programs To Control Leaking: Underground Storage Tanks
SCORING
CLEANUPS
by Dorothy Malaier
It's hard to beat the out-
and-out pageantry
of a football game.
From the recruitment
of players to the
execution of the
plays, the game
of football is filled
with excitement.
Watching a team
playing together to
accomplish the goal
of winning the game
has become one of
America's favorite
pastimes.
But have you ever thought how the game of football
can be compared to our leaking underground storage tank
(LUST) cleanups? No? Well, for me, being from the South
where Southeastern Conference (SEC) football can con-
sume your life in the fall of every year (and hopefully in
January too!), it's not hard to think about life in terms of
making field goals and scoring touchdowns.
Managing UST cleanups is a big part of my life, and
over the years I've realized that cleanups and football are
not really that different. I am sure many of us in the LUST
programs sometimes feel like we're running with the ball.
Sometimes we "drop the ball," and sometimes we seem
to be getting nowhere because of the virtual 300-pound
obstacle in our way. In football, the goal of the game is to
• continued on page 2
Inside
31) E15 Rumblings
4() How Certain is FR? USEPA
6 () How Certain is FR? Insurance Perspective
7 () How Certain is FR? State Fund Perspectve
8 (J The Car That Went Bump into the Dispenser
11 () Lessons from Hudson Falls
13() Thar's Gold in Them Thar Hard Disks
14() Field Notes
15() 1888 Tanker Car/UST Found in TN
17() Tanks on Tribal Lands
18() FAQs from the NWGLDE
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LUSTLine Bulletin 70 • May 2012
m Scoring Cleanups from page 1
score more points than your oppo-
nent by running, passing, or kick-
ing the football over the goal line.
With LUST cleanups, the goal is to
complete the cleanup—the goal line.
How often have you felt like you are
losing yards or getting sacked when
a technology doesn't work or when
you are overwhelmed with all the
work there is to do in our program?
Just like a football game, a LUST
cleanup involves a variety of players.
Let me explain.. .player by player.
OFFENSIVE
Every good team needs a strong
offense. So let's say, our offensive
players are the cleanup contrac-
tors. They are given the ball by the
responsible party (RP) or the state
regulatory agency. The offense needs
to take that cleanup to the cleanup
goal. Sounds simple, but an equally
strong defensive line may prove
to be a challenge for even the best
offense.
L.U.S.T.Line
Ellen Frye, Editor
Ricki Pappo, Layout
Marcel Moreau, Technical Adviser
Patricia Ellis, PhD, Technical Adviser
Ronald Poltak, NEIWPCC Executive Director
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
LoweU, MA 01852-1124
Telephone: (978) 323-7929
Fax: (978) 323-7919
lustline@neiwpcc.org
te) LUSTLine is printed on recycled paper.
Tank owners can be part of the
offensive line. The cleanup is their
legal responsibility and they need to
be in the huddle hearing the plays
and working with the other offensive
players to get the ball headed in the
right direction.
Real estate developers and real-
tors are likely receivers. They want
to have everyone pass them the ball
so that they can score the points by
selling or redeveloping the property.
When we can clean up a site, every-
one wins!
DEFENSIVE
Football requires both offensive and
defensive players. For every good
offensive play, there are defensive
"players" on the field who try to
block the offense from getting to the
goal. Here are some of our key defen-
sive players:
• Recalcitrant Chemicals. These
tough guys try to block the pro-
gress of the ball by not respond-
ing to the cleanup technology
chosen for the site. They often
require other players to come off
the bench after the starters are
worn out.
• Delays in Permitting. While
permits are necessary for reme-
diation and waste management,
they can cause the offense to
stumble and experience game
delays. Being too long in the per-
mitting huddle can cause game
delays, and violations of the per-
mit can create more than just a
five-yard penalty.
• Legal Issues. These players
work hard and can come out
of nowhere to trip you up just
when you thought progress
was being made. They run the
"denied access" and "third-party
lawsuit" plays.
• Lack of Funding. This defen-
sive end can stop the play and
even sack the "quarter" back. No
money? No work! We've got to
try to have this defensive player
sit on the bench!
• Geology. A good stiff clay or
lack of adequate subsurface data
can stop forward motion during
most games...I mean cleanups.
These guys can cause the game
to be extended into overtime if
you don't watch out!
• Heavy Staff Workloads. It's hard
to get into the end zone when
you are tired and overworked.
You may need to bring in the
second string to help our start-
ers work through all the plays
we face. Maybe you need to be
sure that everyone understands
the process, plays their part, and
keeps the ball moving toward
the field goal.
THE OFFICIALS
Every good sport needs rules and
officials to make sure everyone is
playing the game according to the
rules. This is where regulators come
in.
Penalties can be charged when
a player "jumps off-sides" or, as we
say in cleanup, "has a release." How
about a delay of game penalty? Did
your offense take too long to per-
form the investigation, or are we in
year five of the "two-year cleanup"
plan? Should the flag be thrown
when these actions happen in our
cleanup game?
FANS_
Let's look beyond the game itself,
and see the other important parts of
a good football game. How about the
fans?
LUST cleanups have a variety of
fans that cheer on the offense to get
a fast cleanup—bankers, property
owners, adjacent property owners,
and the community. These parties all
want the cleanups to be performed
quickly and effectively so they can
breathe a collective sigh of relief.
CHEERLEADERS AND
MARCHING 3ANDS
Enthusiastic cheerleaders and a
great marching band can get that
adrenaline going. Do you have sup-
portive management in your agency
to "cheer" you on and make sure
everyone is marching to the same
tune?
SELECTION OF PLAYS
From the start of the investigation to
the abandonment of the monitoring
wells, the selection of your cleanup
plays will decide whether the drive
is a long one or whether you can
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May 2012 • LUSTLine Bulletin 70
close out the release with a hurry-up
offense.
The selection of natural attenua-
tion might be the more cost-effective
choice, but it could take a long drive
before goals are met. The decision
of cost effectiveness over timeliness
is played out frequently in cleanup
programs around the country. Most
cleanups involve a series of plays
that incorporate different strategies
for cleanup—maybe a first-down
play to excavate soil, a series of mul-
tiphase extraction plays, finished off
with some chemical oxidation, for
example. Decisions for the next play
need to be determined by experi-
enced players (staff) who know what
it takes to reach the goal line.
ENDGAME
When time is up and the last play is
made, the only good "score" or clo-
sure is one that can't be overturned.
Are we sure we investigated the site
well enough? Did we address the
areas of risk? Can we feel confident
the site poses no unacceptable risk to
future landowners? Hopefully, if the
game was played well and the final
whistle is blown, we will have scored
many touchdowns and our cleanup
backlogs will be reduced.
So, the next time you enter your
office, think of it as entering a giant
stadium where you can design the
plays and coordinate the offense to
clean up your state's UST releases.
With every cleanup completed, you
can hear the crowd roar!
Roll Tide! •
Dorothy Malaier is a lifelong Crim-
son Tide football fan and Corrective
Action Supervisor for the Alabama
Department of Environmental
Management. She can be reached at
DSM@adem.state.al.us.
E15 Rumblings
USEPA Approves First Applications for E15 Registration
USEPA approved the first applications for registration of ethanol for use in mak-
ing gasoline that contains up to 15 percent ethanol—known as E15. Ethanol is
a renewable fuel that has up to this point been produced and sold in gasoline at
a 10 percent concentration in most areas of the country. Registration of ethanol
to make E15 is a significant step toward its production, sale, and use in model
year 2001 and newer gasoline-fueled cars and light trucks. This action follows an
extensive technical review by USEPA as required by law.
Registration is a prerequisite to introducing E15 into the marketplace. Before
it can be sold, manufacturers must first take additional measures to help ensure
retail stations and other gasoline distributors understand and implement labeling
rules and other E15-related requirements. USEPA is not requiring the use or sale
ofE15.
After extensive vehicle testing by DOE and other organizations, USEPA
issued two partial waivers raising the allowable ethanol volume to 15 percent for
use in model year 2001 and newer cars and light trucks. E15 is not permitted for
use in motor vehicles built prior to 2001 model year and in off-road vehicles and
equipment such as boats and lawn and garden equipment. Gas pumps dispens-
ing E15 must be clearly labeled so consumers can make the right choice. For
more information, go to www.epa.gov/otaq/regs/fuels/additive/e15/.
The "Domestic Fuels Protection Act of 2012"?
As a heads-up, there is currently a House Bill (H.R. 4345) specifically designed
to "provide liability protection for claims based on the design, manufacture, sale,
offer for sale, introduction into commerce, or use of certain fuels and fuel addi-
tives, and for other purposes." This blanket liability waiver is in response to fuel
retailer concerns about liability arising from potential compatibility problems
associated with the use of E15 in on- and off-road motor vehicles and equip-
ment, not to mention the integrity of the UST system itself.
The bill would also assign USEPA responsibility for establishing regulations
that would set standards for determining whether an underground storage tank
system or associated dispensing equipment (not currently regulated in the fed-
eral UST rule) is compatible with a fuel or fuel additive. USEPAs current compat-
ibility guidelines essentially do this, except for the dispenser part.
We'll keep you posted.
API Report Gives Thumbs Down on E15
To add to the E15 fray, an American Petroleum Institute-funded report, A Compre-
hensive Analysis of Current Research on E15 Dispensing Component Compatibil-
ity, by Larry Gregory Consulting, LLC, was just released. It reviews several research
papers published on the effects of increasing the ethanol blend ratio to E15 from
the current E10 standard. After summarizing with a list of risks to the tank owner,
the report concluded that the only alternative is to not store E15 at the facility.
A copy of the report is available at http://www.api.org/policy-and-issues/policy-
items/alternatives/analysis-of-current-research-on-e15-dispensing-component-
compatibility.aspx. •
Vapor Recovery Systems to Be Phased Out
U SEPA's Air Office has determined that vapor recovery systems used at gas station pumps to capture harmful gasoline vapors
while refueling cars can be phased out. Modern vehicles are equipped to capture those emissions. Beginning later this year,
states may begin the process of phasing out vapor recovery systems since approximately 70 percent of all vehicles are
equipped with on-board systems that capture these vapors. This final rule will ensure that air quality and public health are protected
while potentially saving the approximately 31,000 affected gas stations located in mostly urban areas more than $3,000 each year
when fully implemented.
Since 1994, gas stations in areas that do not meet certain air quality standards have been required to use gasoline vapor
recovery systems. However, as required by the Clean Air Act, automobile manufacturers began installing onboard refueling vapor
recovery (ORVR) technologies in 1998, making gas stations' systems increasingly redundant. •
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LUSTLine Bulletin 70 • May 2012
A Message from Carolyn Hoskinson
Director, USEPA's Office of Underground Storage Tanks
How Certain Is FR?
USEPA's Quest to Follow That Star
Few people find underground storage tank (UST) finan-
cial responsibility (FR) a fascinating discussion topic.
There are so few, in fact, that I think we all know each
other. Yet, I'd be hard pressed to think of a subject more
essential to a successful leaking underground storage tank
(LUST) program than ensuring there are resources available
to pay for cleanups. Fortunately, the UST program's founding
fathers recognized the importance of financial responsibility.
In the mid-1980s, lawmakers amended Subtitle I of the Solid
Waste Disposal Act and directed the U.S. Environmental Pro-
tection Agency (USEPA) to develop financial responsibility
regulations for UST owners and operators. Congress wanted
UST owners and operators to be able to show that they have
the financial resources to clean up a site if a release occurs,
correct environmental damage, and compensate third parties
for injury to their property or themselves. In 1988, USEPApro-
mulgated the final UST FR regulation.
Like most aspects of the tanks program, the federal FR
regulation provides UST owners and operators with compli-
ance options such as obtaining insurance coverage; dem-
onstrating self-insurance using a financial test; obtaining
corporate guarantees, surety bonds, or letters of credit; or
relying on state financial assurance funds (a.k.a. state funds),
as well as a host of options for local governments. Currently,
UST owners primarily use insurance or state funds as their
financial responsibility mechanism.
So, how was this supposed to work? In an ideal world,
FR would mean that the moment a release is confirmed, the
money is in hand to immediately begin to address the prob-
lem. Also, ideally, the resources are sufficient to fully address
the cleanup needs as well as compensate third parties. When
USEPA drafted the FR regulation and approved each individual
state fund as an approved FR mechanism, we did our best to
ensure this ideal was met. Of course, we all know that very few
things in life work perfectly and as envisioned.
Over the years, USEPA has heard anecdotally that insur-
ance companies were denying claims, leaving tank owners
without funding for their cleanups. In addition, we've worked
with different states whose funds weren't adequately funded to
meet their obligations. Most recently, USEPA has been work-
ing with Connecticut, whose state legislature severely reduced
funding for its state fund. As I write this article, that situation
is continuing to unfold, and it is too soon to predict how Con-
necticut's efforts to resolve the problem will ultimately turn
out.
To address the concerns we heard and experienced,
USEPA recently issued a study on UST insurance, as well
as guidance for USEPA regions reviewing state funds. We
designed both of these documents to help enhance our dia-
logue on FR and better ensure funding is available to pay for
cleanups.
UST Insurance Study
To investigate and address concerns we heard about UST
insurance, USEPA studied the effectiveness of UST insur-
ance as an FR mechanism. More broadly, we studied whether
the current UST insurance structure provides owners and
operators with the financial responsibility USEPA originally
intended. Our study, issued in January 2012, summarizes
results of our UST insurance policy analysis and data collec-
tion effort; identifies certain areas of concern; and discusses
potential next steps. You can access the insurance study at
www. epa.gov/oust/pubs/insurancestudy. htm.
The study findings are inconclusive as to whether UST
insurance is effective as an FR mechanism. On one hand, the
analysis of UST insurance policy language revealed certain
definitions, terms, and conditions that could pose coverage
and claim challenges for UST owners and operators. Fur-
thermore, the litigation review suggests that UST pollution
insurance policies do not always respond in a timely manner
to provide financing for remediating releases from regulated
USTs. Yet the policies purchased by owners and operators
generally complied with the federal UST FR regulation. It also
does not appear that insurance carriers are excessively or dis-
missively denying claim payments.
Nonetheless, USEPA is aware of individual circumstances
where owners and operators feel their insurance carriers are
inappropriately denying coverage. Moreover, even though this
study identified several issues that may hinder the effective-
ness of UST insurance policies to provide prompt financing
of releases, it is still unclear to what extent UST insurance as
an FR mechanism has led to unremediated releases or stalled
remediation. Nevertheless, we acknowledge this study iden-
tified certain aspects of UST insurance that may be at odds
with USEPA's ideal of how and when an FR mechanism should
respond to releases.
USEPA presented several ideas in the paper to foster a
robust discussion of next steps:
Educate Owners and Operators about UST Pollution
Insurance. Possible strategies include educating own-
ers and operators about: UST insurance; compliance with
FR insurance requirements; specific policy provisions to
which they should pay particular attention; and recom-
mended practices that may reduce the chance of complica-
tions when filing claims with their insurance carriers (e.g.,
reporting releases as early as possible, or conducting a
site assessment prior to temporarily closing their UST sys-
tems).
Collect Additional Data. As a potential next step, USEPA
would like to work with interested parties to identify addi-
tional sources of information that could provide more
insight into insurance issues. We would also be glad to
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May 2012 • LUSTLine Bulletin 70
work with interested parties who would like to share, pro-
vide, or develop data that could further assist us in our
evaluation.
Revise Existing Federal UST FR Regulation. Our analysis
revealed UST insurance policy language that, while permit-
ted under the federal UST FR regulation, may limit coverage
provided by UST insurance. One way to remove or restrict
use of this policy language is to amend the current regula-
tion and place additional requirements on the use of UST
insurance as an FR mechanism. The paper presents for dis-
cussion purposes several potential revisions to the current
regulation. One critical consideration is the impact of any
potential change on the availability and affordability of UST
insurance to owners and operators.
Through the ideas presented in the paper or through
other suggestions, USEPA will work with owners and opera-
tors, state and tribal regulators, insurance carriers, and other
stakeholders to examine possible improvements to the UST
FR program. To learn more about USEPA's efforts regarding
insurance or provide feedback regarding UST insurance and
FR issues, contact Cho-Yi Kwan (kwan.choyi@epa.gov or
703-347-8908).
State Fund Soundness Guidance
In February 2012, USEPA issued guidance for regional office
review of state funds. This guidance provides USEPA regional
UST programs with recommended procedures and factors to
consider for monitoring the soundness of state funds. The
goal of the guidance is to help ensure the adequacy of state
funds. You can access the guidance at www.epa.gov/oust/
states/state-fund-soundness-guidance 1 -26-2012.pdf.
I can think of three reasons USEPA's meaningful and sys-
tematic oversight of state funds is essential—maybe you know
more!
1. State funds finance most UST cleanups in the United
States. For that reason alone, it is essential that we ensure
these state funds are and will be sufficiently funded to con-
tinue this impressive track record.
2. In order to serve as a legal FR mechanism for tank own-
ers to use in complying with the federal regulation requiring
owners to have FR, individual state funds received approval
from USEPA. That approval was based on the funds meet-
ing certain criteria. USEPA must ensure that as the years go
by, changes to the funds do not later bring the funds out of
compliance with those approval criteria.
3. Last and perhaps most important, we found several
instances where our oversight and identification of poten-
tial concerns enabled USEPA and the state to work together
to secure additional resources for the fund to boost its
soundness.
In our February 2012 guidance, we recognized two things
that make this oversight process challenging:
1. USEPA regional staff generally have environmental, not
financial, backgrounds. We developed an oversight process
that does not require the regional staff to perform complex
financial analysis they neither have the experience nor train-
ing for.
2. Of the 36 active state funds—which are rather like snow-
flakes and my children's personalities—no two are identi-
cal. In fact, in many cases they are really quite different. We
believe our guidance provides enough structure to make
oversight meaningful, yet flexible enough to account for
state-specific situations.
So what difference will a new guidance make? USEPA
has had state fund oversight guidance since 1994, yet our
implementation of that guidance has not been as meaning-
ful, complete, and systematic as it could be. Along with issu-
ing the new guidance, we are recommitting ourselves to the
importance of truly implementing this review as a high-priority
annual process. Currently, we are working with five states and
their USEPA regions to test a state fund data form and data
evaluation workbook, both of which will help regions imple-
ment the guidance. We are now evaluating the results of the
tests, as well as modifying the data form and workbook based
on what we found. We will be updating these tools within the
next few months, and all USEPA regions will review all of their
states' active funds this autumn and annually thereafter. To
learn more about our state fund guidance, contact Bill Foskett
(foskett.william@epa.gov or 703-603-7153).
The Mission Continues
I'll be the first to admit, we still have a lot of work to do. We're
not alone. I'm not aware of a single environmental program
that has completely solved financial responsibility. What I am
absolutely sure of is that it is vitally important, but extremely
complex and challenging. So what do we do when a problem
is huge and tough? It's just like the question, "How do you
climb a mountain?" The answer is, "One step at a time." •
FINANCIAL RESPONSIBILITY RESOURCES
Insurance for USTs Web Page: www.epa.gov/oust/ustsystm/insurance.htm provides links to:
• USEPA's study on the effectiveness of UST insurance as a financial responsibility mechanism
• ASTSWMO's guide to assist owners and operators when purchasing UST insurance
• USEPA's list of known insurance providers for UST owners and operators
State UST Financial Assurance Web Page: www.epa.gov/oust/states/fndstatus.htm provides:
• Status of state UST financial assurance funds
• USEPA's guidance for regional office review of state underground storage tank financial assurance funds
Financial Responsibility for Underground Storage Tanks: A Reference Manual: www.epa.gov/swerust1/pubs/
frustman.htm provides UST inspections with the restrictions, limitations, and requirements of each financial
responsibility mechanism provided in the federal UST regulations.
Facts About Financial Responsibility for Owners and Operators: www.epa.gov/oust/ustsystm/finresp.htm
provides an overview about financial responsibility.
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LUSTLine Bulletin 70 • May 2012
Unlocking the
Mystery of FR
A new column by Jill Williams
Hall, 5enior Planner with
the Delaware Department
of hatural Resources and
Environmental Control,
discussing FR-related matters.
Her insight and experience with
matters of U5T and A5T system
Financial Responsibility and other
U5T-related miscellany is simply stunning.
5he can be reached atjill.hall@state.de.us.
How Certain Is FR?
The Insurance Perspective
State Fund, Insurance, Self-
Insurance, Guarantee, Letter
of Credit. What do these terms
have in common? They are all accept-
able mechanisms for showing proof
of financial responsibility (FR) as
required by the federal UST regula-
tions. But once an UST owner/opera-
tor has shown the state inspector a
piece of paper that shows compliance
with the FR regulation what must the
FR mechanism actually do? To under-
stand the purpose of FR one must
take a trip back in time to October
1988 when the FR requirements were
published in the federal Register.
The program objectives for the
final FR rules state that:
The financial responsibility program
for petroleum USTs must require ade-
quate and reliable financial assurance
for the costs of UST releases, based on
the following considerations:
(1) The certainty that funds will be
available;
(2) The sufficiency of funds to cover
the costs of releases; and
(3) The availability of funds for cor-
rective action and third-party
liability.
So how well do the allowable
mechanisms fulfill the intent of the
requirements? For any mechanism
the answer lies somewhere between
0 and 100 percent. By far the most
widely utilized FR mechanisms are
state funds and insurance. For states
without a state fund (about a quarter
of the states), insurance is the most
widely used form of FR and possi-
bly the least well understood. UST
insurance is an alien being to most of
us, with its own language and rules,
and by nature we humans tend to be
afraid of things we don't understand.
To unlock the mystery of insurance
and leave our fears behind we must
learn its language and honor its rules.
With this knowledge, the certainty
that insurance will fulfill the intent of
the UST regulations rises significantly.
Does Insurance Fulfill
Regulatory Criteria?
Looking at the criteria listed above,
#2 and #3 are the easiest to answer
regarding fulfillment of FR. Just as
USTs are regulated by state and fed-
eral environmental agencies, insur-
ance companies are subject to state
and federal insurance regulations.
Therefore we can safely assume that
through regulation, insurance com-
panies must be able to show proof
that they have a bank account large
enough to pay claims. Thus we prob-
ably need not concern ourselves with
the issues of compliance with those
two criteria.
As for criteria #1—certainty that
funds will be available—we are faced
with the question of "how certain is
certain?" We have all heard the horror
stories of how "insurance never pays"
or "the first three answers to any
insurance claim are 'no, no and no.'"
So where is the problem? Or better
yet, is there a legitimate problem? The
answer is not a simple "yes" or "no."
The Federal Register publishing
the final FR rule (Vol. 53, No. 207)
states that in specifying certain pol-
icy conditions USEPA attempted to
meet two objectives: (1) the need to
ensure that insurance coverage will
provide the same level of protection
as other mechanisms; and (2) the
need to preserve flexibility in policy
specifications to allow insurers to
develop acceptable policies and to
avoid unnecessarily restricting the
availability of insurance.
In the final rule, USEPA delib-
erately set forth minimal policy lan-
guage, therefore tank insurance
policies come in a variety of flavors,
all of which meet the regulations
but do not provide exactly the same
coverage. Insurance is a contract
between the insured and the insur-
ance company and therefore the pol-
icy language and compliance with
the rules it sets forth is paramount
in determining the level of certainty
that funds will be available.
In December 2011, USEPA pub-
lished a document, EPA Study on the
Effectiveness of UST Insurance as a
Financial Responsibility (FR) Mecha-
nism. The study states: "What has
evolved over time and exists today is
an assortment of UST insurance poli-
cies purchased by owners and opera-
tors which, depending on a lengthy
set of circumstances and contingen-
cies, may cover remediation and
third-party expenses arising out of
releases from regulated USTs."
So what does one do with a
statement like that? Deliberate use of
the word "may" implies there must
also be a "may not." After studying
25 policies issued by 12 different car-
riers, USEPA concluded that the poli-
cies did comply with the regulations.
But does that translate to a complete
certainty that every claim for every
UST release is paid? In a word, no.
Because there is such a variety
in policy language, and the policy is
a contract, there is always the pos-
sibility that a release will not be cov-
ered. USEPA acknowledges that due
to differences in policy language and
the very structure of insurance itself,
there are "gaps" where the costs
of cleanup for a release may not be
covered by insurance. It is a fact that
releases that occur before a policy is in
effect—commonly called historic con-
tamination—are not the responsibility
of the insurance company. The anal-
ogy here would be purchasing fire
insurance ten minutes after flames are
shooting out the house windows.
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May 2012 • LUSTLine Bulletin 70
The Key to Successful
Insurance FR
What then is the key to a success-
ful UST program that utilizes insur-
ance as an FR mechanism? The
USEPA insurance study concludes
that "Practically, relying on pollu-
tion insurance to finance UST clean-
ups and third-party damages means
that someone, other than the owner
or operator, plays a predominant
role in determining and controlling
whether and when funds will be pro-
vided by the insurance policy and
which expenses will be reimbursed."
So how do we ensure that the indi-
viduals who should benefit from
the insurance policy but are not in
total control of the situation are best
positioned to receive the benefit of
insurance?
First and foremost the purchas-
ers of UST pollution liability insur-
ance must understand what they
are purchasing and the rules asso-
ciated with the insurance contract.
To that end the Association of State
and Territorial Solid Waste Manage-
ment Officials has published a sim-
plified Guide to Tank Insurance (http://
astswmo.orglFileslPolicies_and_Publi-
cations/Tanks/2011.10_Guide_to_Tank_
Insurance_FINAL.pdf). When tank
owners and operators blindly pur-
chase insurance without understand-
ing what the policy will actually pay
for and what their obligations under
the contract are, there is much less
certainty that a release will be cov-
ered by the insurance company.
Coming Up
Future articles will discuss the finer
nuances of pollution liability insur-
ance, including an explanation of
insurance terms, differences in policy
language, gaps where insurance will
not pay for contamination and what
can be done to close these gaps, what
is acceptable documentation of ade-
quate tank insurance, and whether
tank insurance adequately fulfills the
intent of the regulations as opposed
to just the letter of the law. •
How Certain is FR?
The State Fund Perspective
by Chuck Schwer
It's been more than 25 years since
the federal UST rules were pro-
mulgated, requiring UST owner/
operators to have a financial respon-
sibility (FR) mechanism in place to
mitigate any harmful effects from
leaking underground storage tanks
(LUSTs). At the time, with the private
insurance option either unavailable
or unaffordable for most tank own-
ers, 36 states adopted a state cleanup
fund to satisfy the FR requirement.
It seems like yesterday when in
1992 we "new" state fund adminis-
trators got together in South Dakota
to discuss this challenge. Looking
back over these past 20 years, it's not
a moment too soon to reflect on how
well state funds have satisfied the
requirements of FR. But any kind of
sweeping assessment of state funds
is not all that easy...not all state
funds were created equal. Some state
funds cover more than just USTs.
Some must answer to a board. Some
have adequate revenue and oth-
ers not so much. Yet, after careful
consideration, I am comfortable in
saying that, for the most part, state
funds have met the intent of FR.
Money Well Spent
Over the past 20 years state funds
have spent more than $18 billion
to address petroleum contamina-
tion at LUST sites. These funds have
been used to mitigate both public
health and environmental problems
at nearly 200,000 contaminated sites
throughout the country. These sites
include circumstances where public
and private drinking water supplies
were contaminated; where petro-
leum threatened the health of surface
water bodies, including lakes, ponds,
and wetlands; and where petroleum
vapors adversely affected the indoor
air in businesses and homes and, in
some cases, posed a risk of explosion.
Over the years, state fund pro-
gram personnel have worked hard
to find ways to use their often-lim-
ited public funds more efficiently.
Various cost-control tools were
developed and tested, including
preapproval, fee schedules, pay-for-
performance, equipment reuse, pay-
ment limits, and more. State fund
programs also sought to ensure that
site cleanups were more effective.
Innovative techniques such as soil
vapor extraction (SVE), air sparging,
bioremediation, chemical oxidation,
and surfactant flushing have all been
tried and tested in hopes of finding
better ways to remediate LUST sites.
Survival Challenges
Despite state fund successes, many
fund managers have had to slog
through some difficult mine fields...
in a few cases the difficulties were
ultimately insurmountable. Pitfalls
along the way—raids on state funds,
insufficient revenues, too many sites,
too many commitments—have cre-
ated circumstances where some
funds have had to take rigorous
measures that resulted in slowing
the pace of cleanups. These measures
include prioritizing claims, delaying
reimbursements, and changing fund
eligibility criteria.
While most state funds have
been able to work through their chal-
lenges, some have not. For example,
the Michigan state fund declared
insolvency in 1995 and is no lon-
ger active. Currently, the Connecti-
cut state fund is having difficulties.
Its future will depend on whether
the state legislature takes necessary
steps to satisfy USEPA requirements.
If not, will Connecticut tank owners
be able to satisfy FR requirements
without the state fund? Experiences
in other states suggest that going it
without a state fund creates a serious
challenge with regard to cleaning up
the backlog of contaminated sites—
the primary goal of FR.
So as we look ahead to the
future, what is the certainty of state
funds and their ability to satisfy FR
requirements? If past performance
is any indication of the future, and
barring some tumultuous set of cir-
cumstances, I believe we will see
continued state fund success for
most state fund programs. •
Chuck Schwer is a section chief with
the Vermont Department of Environ-
mental Conservation. Chuck and his
team have been preparing the annual
state fund survey since 1993. He can be
reached at chuck.schwer@state.vt.us.
-------
LUSTLine Bulletin 70 • May 2012
-jnically Speaking
by Marcel Moreau
Marcel Moreau is a nationally
recognized petroleum storage specialist
whose column, Tank-nically Speaking,
is a regular feature o/LUSTLine.
As always, we welcome your comments
and cjuestions. If there are technical
issues that you would like to have
Marcel discuss, let him know at
marcel.moreau@j uno.com.
The Car That Went Bump into the Dispenser
It was a dark and stormy night in the peaceful hamlet of Fort Edward, in
upstate New York, some 50 miles north of Albany, when...
' E1aine Pagana, Fort Edward resident
interview with Christine O'Donnell, NewslOabc, 12/28/1
Intervtew wlth Matt Hunter for YNN News,
Emergency respond-
ers on the scene at
Cumberland Farms
in Hudson Falls, New
York. The NYDEC
estimates up to 1,200
gallons of gasoline
leaked from a pump
at the store on the
night of December
27, 2011, after a car
bumped the pump.
a XoZ* erf f/a/>ie3 do/^ina ottft of ithe
'ft iOOS Vet-y /o&td. Z£ t-eaj/y ao£ out-
Mark Hurlburt, Fort Edward Fireman
Interview with Christine O'Donnell, NewslOabc, 12/28/11
8
-------
May 2012 • LUSTLine Bulletin 70
What Can Go Wrong
Did Go Wrong
For terrified residents, it was
a chilling night to remem-
ber. The chain of events began
with a minor encounter between a
vehicle and a gasoline dispenser, fol-
lowed closely by a fractured shear
valve that failed to close, a runaway
submersible pump, and a delayed
response by employees. The end
result was the release of 1,200 gal-
lons of gasoline that flowed directly
into the adjacent storm drain. Add
an unidentified source of ignition
for the gasoline vapors in the Fort
Edward combined storm/sani-
tary sewer system, and you have
an instant war zone, with pillars of
flame and smoke launching hundred
pound manhole covers over the roofs
of houses.
For a Cumberland Farms gas sta-
tion some two miles away in Hudson
Falls, New York, it was the beginning
of a nightmare that is not likely to be
over any time soon.
Here's what I have pieced
together from news reports of the
incident. A man stopped at a Cum-
berland Farms store in Hudson Falls
to buy some beer. It was about 7:15
on the evening of December 27, 2011.
It had been raining heavily. The man
was the only customer at the store.
After completing his purchase, he
backed his recently purchased car out
of his parking spot, nudging a gaso-
line dispenser in the process. He said
the radio was playing. He swore he
did not know he'd hit the dispenser
and that if he had known, he would
have stopped and told someone.
All indications are that this was
in fact a minor accident. His car
showed a barely noticeable narrow-
ing of the joint between the bumper
and the fender. There were no dents.
The paint was intact. The dispenser
showed an obvious dent on a front
panel, but one that looked like it
could have been inflicted by a solid
kick with a booted foot, not a signifi-
cant encounter with an automobile. I
can imagine that many a distracted
driver talking on a phone or tending
to a crying infant could have caused
the same damage without noticing.
The impact of the car, though
minor, was sufficient to move the
dispenser slightly. This movement
was sufficient to fracture the shear
section of at least one shear valve.
But the movement of the dispenser
was not sufficient to cause the trip
mechanism of the shear valve to
operate, so the shear valve remained
open. This is not exactly a common
occurrence with shear valves, but it
is a known issue.
When properly installed, dis-
pensers are firmly bolted to the
concrete island on which they sit.
Because such a relatively minor
impact had such severe conse-
quences, it is my suspicion that this
dispenser may not have been prop-
erly anchored.
Under normal circumstances,
the shear valve would have begun to
leak when the next customer arrived
to pump the grade of gas that flowed
through the valve. The leak rate
would have been substantial, so a
mechanical leak detector would have
put the dispenser into slow flow,
and an electronic line-leak detector
would have shut down the pump at
the end of the dispensing cycle. With
appropriate response from the per-
sonnel involved, the release would
have been relatively minor.
But there was an additional
problem. News reports make it clear
that fuel was gushing out of the dis-
penser even though no customers
were pumping gas. With all of the
nozzles hung up, the submersible
pump should have been off. Why
was the pump on? I believe the most
likely answer is that the pump relay
was stuck in the "on" position.
Submersible pump motors are
generally energized only when a cus-
tomer removes a nozzle and pushes
a button to select a specific grade of
fuel. The switch mechanism at the
dispenser typically operates on low
current that activates a heavy-duty
switch (known as a relay) inside the
facility that directly controls the cur-
rent to the pump motor. The heavy
current loads on these relay switches
sometimes cause the switch contacts
to weld together. When this happens,
the switch becomes stuck in the "on"
position, and the pump motor runs
continuously. Because the pump
motor is always "on," there is no
immediate indication that there is
a problem because customers are
able to get fuel just as they normally
would.
If you are an astute UST person,
you will immediately be saying "uh-
oh," because you realize this means
that the line-leak detector, which
requires the pump motor to be cycled
"on" or "off" depending on the type,
would not be able to detect this leak.
Even worse, because the pump would
always be on, the fractured shear
valve would begin to leak immedi-
ately, even though there were no cus-
tomers at any of the dispensers.
Some Time Later...
It was a dark and stormy night, so
the Cumberland Farms facility was
not exactly a beehive of activity. At
least several minutes after the beer
customer left the facility, another cus-
tomer rushed into the store announc-
ing that gasoline was pouring out of a
dispenser. News reports indicate that
an employee followed procedures to
shut down all gasoline dispensing
but that the fuel kept flowing.
A likely scenario is that the
employee activated the "all stop"
button on the point-of-sale system.
This button stops dispensing activity
by closing valves in all the dispens-
ers. The "all stop" button would be
effective if there were a defective
nozzle spewing gasoline all over
the forecourt, but this button does
nothing to turn off the power to the
submersible pump motor. What
was needed was an emergency stop
switch. This store either did not have
one or the employee did not know
where to find it.
Emergency stop switches have
been part of fire codes for decades.
Fire codes generally specify the loca-
tion of these switches and that they
must be clearly identified and easily
accessible. Emergency stop switches
are intended to immediately stop
all fuel-pumping activity by cutting
power to all of the pump motors
present at the site. Since 2000, the
NFPA fire code also specifies that
activating the emergency stop switch
should also de-energize all electri-
cal circuits in any area where flam-
mable vapors may be present. This
would eliminate electrical sparks as
a source of ignition for fuel vapors.
Emergency stop switches are a criti-
cal component of gas station safety.
Having no success in stopping
the flow of gasoline out of the dis-
penser, a store employee called the
Cumberland Farms "help desk" and
left a message. The employee did not
• continued on page 10
-------
LUSTLine Bulletin 70 • May 2012
m Tanknically Speaking from page 9
receive a call back. At some point, an
employee called the fire department.
Eventually, an employee succeeded
in turning off the pumps, apparently
by shutting down circuit breakers
at the main electrical panel. By this
time, fuel had been flowing from
somewhere between 15 minutes to a
half hour and some 1,200 gallons of
gasoline had been released. The gas-
oline flowed a short distance across
the facility driveway and directly
into a storm drain.
Journey Through the Storm
Sewer
The short surface pathway the gas-
oline took may have prevented a
major conflagration. On a similarly
rainy night in Biloxi, Mississippi
in 1998, gasoline from a tank over-
fill incident flowed to an intersec-
tion where vehicles were stopped
for a traffic light. When the gasoline
ignited, five people burned to death.
The combined storm/sanitary
sewer system in Hudson Falls was
flowing nicely because of the recent
rain. The 1,200 gallons of gasoline
flowed some two miles within the
sewer system to the community of
Fort Edward. Somewhere in the sew-
ers of Fort Edward, gasoline vapors
in the flammable range encoun-
tered a source of ignition and several
explosions ensued.
Flames belched from sewer open-
ings as some 25 manhole covers were
blown into the air, in some cases over
the tops of houses, and came crash-
ing back to earth. Windows were bro-
ken, dishes crashed to the floor, and
pavement was cracked. The sewer
Debris from the sewer explosion lies in the middle of Satterlee Lane in Fort Edwards, December
28,2011.
treatment plant was flooded with
gasoline. Not knowing exactly what
was going on or what was to come,
police and fire crews evacuated hun-
dreds of residents. Miraculously,
there were no injuries, except for an
individual who was blown into some
bushes and twisted his knee.
Stay Tuned
That's the story of "the car that
went bump into the dispenser" as
ascertained primarily from news
reports of the incident. I have also
deduced information presented in
this article from my own knowledge
and experience with UST systems
and corroborated some information
with personnel from the New York
Department of Environmental Con-
servation who are familiar with the
investigation.
As might be expected, there is
enforcement action simmering over
the events that happened in Hudson
Falls and Fort Edwards. Luckily, the
damages involve primarily sewer
lines and a sewage treatment plant,
not death or serious bodily injury.
Because of the pending enforcement
action, however, there are still some
details of the incident that have not
been made public. I don't expect that
additional information will change
the general picture of what occurred
as described in this article, but if this
happens, corrections will appear in a
future LUSTLme. •
Shear Valves Did Their Job in Recent Kentucky Tornadoes
I found the "Extremes" articles in LUSTLine #69 quite interesting. On March 2, 2012, tornadoes tore through
West Liberty and Salyersville in Eastern Kentucky. These two towns both experienced EF3 tornadoes. Though stron-
ger tornadoes hit elsewhere in the state, these were the only two areas where gas stations were severely walloped.
I am happy to say that out of the eight UST facilities destroyed during the tornadoes, none experienced releases to
the environment. At seven of these eight UST facilities, the shear valves all closed properly when the dispensers were
ripped off. At the one facility where this didn't occur, the dispenser lines were not severed to cause the shear valves to
trip, so there was no release.
Many times we wonder if our compliance efforts are doing any good. It was gratifying to see the equipment
operate the way it should to prevent releases and protect the environment in the aftermath of such a tragedy. •
Leslie Can, Kentucky DEP
10
-------
May 2012 • LUSTLine Bulletin 70
What Can We Learn from the Hudson Falls
Incident?
by Marcel Moreau
Incidents such as the one in Hudson Falls, New York, are not commonplace. But when they occur, they present "teachable
moments" for all who own, operate, service, or regulate fueling facilities. This Incident Illustrates just why It is we have codes,
regulations, manufacturer's instructions, and industry recommended practices. Here's what I see as the lessons to be learned from
this Incident.
Don't Forget the Little Stuff
Whether the dispenser in this event
was bolted to the concrete is a detail
that has not yet been made public.
But regardless of whether this dis-
penser was properly anchored, now
is a good time to reflect on the impor-
tance of dispenser anchoring. Bolting
a dispenser may seem like a trivial
aspect of installing today's complex
multiproduct dispensers (MPDs).
After all, MPDs are heavy, and grav-
ity is a pretty reliable force for keep-
ing them in place. But an unanchored
dispenser can be easily budged by
a slight collision with a vehicle, an
event that is not that uncommon. It
is exactly this minor movement of
the dispenser relative to the rigidly
anchored shear valve that can cause
the shear valve to crack but not to
trip, as may have been the case in the
Cumberland Farms incident.
In addition, dispensers nowa-
days should have breakaway cou-
plings installed on dispenser hoses
designed to separate when custom-
ers drive off with a nozzle still in the
fill opening of the vehicle. It takes a
very substantial force to separate a
breakaway coupling, and that force
will be pulling at the very top of
the dispenser cabinet. If not solidly
anchored, the dispenser may tip over
before the breakaway separates.
Anchoring is not an optional
step in dispenser installation.
The Shear Valve Can Save
the Day
Shear valves are among the wall-
flowers of the UST world, waiting
patiently and inconspicuously at the
base of the dispenser cabinet for the
one heroic moment when they can
save the day. They were developed
in the 1950s, shortly after the intro-
duction of submersible pumps. They
are a critical safety component of
pressurized pumping systems. The
type of failure that occurred in the
Hudson Falls incident has been rec-
ognized for some time, and there is
now a shear valve on the market that
has addressed this problem (Figure
1). The shear section of this valve is
enclosed in a flexible bladder that
is inflated by the gasoline leaking
from the shear section. As the blad-
der inflates, it trips the shear valve
and closes it. The Cumberland Farms
incident illustrates why a shear valve
with this feature can be cheap insur-
ance against catastrophic releases.
While I'm on the subject of shear
ground piping with a single-valve
mechanism (or poppet) (Figure 3).
Gasoline in the dispenser piping is
not contained and generally flows
out of the dispenser when the shear
valve operates. Double-poppet shear
valves have an additional poppet
that closes off the dispenser piping
so that the substantial amount of
fuel present in a typical MPD is not
allowed to flow out when the dis-
penser is hit.
Fires codes have not favored
double-poppet shear valves for
fear that the gasoline trapped in
the dispenser piping would cre-
ate a "bomb" should there be a fire
FIGURE 1. This shear
valve is designed to
operate even when only
minor impacts occur.
The shear point is
enclosed in a liquid-tight
flexible bladder (shown
in blue online). When
the shear point fractures
and fuel leaks out, it
inflates the bladder. The
bladder presses against
the trip mechanism,
which, in turn, unlatches
the arm holding the
poppet open, and the
valve closes—regard-
less of whether the top
part of the valve moves
relative to the bottom part. The valve will also operate in the traditional manner if a
major impact occurs. The trip mechanism in this photo is disengaged and the valve
is closed. Note the heavy-duty bolts and steel framework used to fasten the shear
valve. The bottom part of every shear valve must be rigidly anchored for the mecha-
nism to operate as designed.
valves, let me pull up my soapbox.
I think it's time to look seriously at
double-poppet shear valves (Figure
2). Traditional single-poppet shear
valves only close off the below-
when the dispenser is knocked over.
Some 15 years of experience with
double-poppet shear valves shows
that the "bomb" fears are ground-
• continued on page 12
11
-------
LUSTLine Bulletin 70 • May 2012
m What Can We Learn from page 11
less, because double-poppet shear
valves are effective in containing the
fuel and preventing fires from occur-
ring in the first place. Single-poppet
shear valves, on the other hand, are
commonly associated with signifi-
cant fires when subjected to a major
impact. People die in these fires. It's
time to recognize that double-poppet
shear valves can save lives, and their
use should be encouraged, not dis-
couraged.
Like all mechanical devices,
shear valves should be periodi-
cally operated and tested to be
sure they will function appropri-
ately when their big heroic moment
comes. Fire codes have specified an
annual test of shear valves for as far
back as I can tell, which is some 30
years. A specific procedure for test-
ing the operation of shear valves is
described in PEI/RP500, Recom-
mended Practices for Inspection
and Maintenance of Motor Fuel Dis-
pensing Equipment.
Emergency Shu toff Switches
Are Not Optional
When bad things happen, person-
nel at a fueling site need to have a
simple, effective, convenient, eas-
ily recognized way to shut-off all
possible flow of fuel and minimize
electrical sources of ignition. This is
what emergency shutoff switches
do. Like seat belts, airbags, and fire
extinguishing systems, you hope
you never need them, but you sure
are grateful to have them do their
job when you do need them. Such
equipment is insurance against
catastrophe. And just like any insur-
ance policy, this equipment has to be
in place before the accident happens.
And once the switch is installed
it must not become a convenient
place to hang your jacket, nor must
all those display cases of beer be
stacked in front of it. Emergency
shutoff switches are crucial pieces of
equipment.
Although usually more colorful
and located in a more obvious loca-
tion than shear valves, emergency
shutoff switches are also among the
wallflowers of the UST world, wait-
ing patiently for their turn to dance.
They too should be tested annually
for proper operation. Refer to PEI/
RP500, Recommended Practices for
12
Upper poppet
keeps fuel in
dispenser piping
NOTE: poppets are
shown in the open
position
Lower poppet
keeps fuel in
below-grade piping
Photo courtesy of OPW
FIGURE 2.This cutaway shows the internal workings of a double-poppet shear
valve. When the shear valve "trips," the lower poppet rotates upward and closes
off the flow of fuel, while the upper poppet moves straight down and closes the
opening so that fuel cannot drain out of the dispenser piping.
Single-Poppet
Shear Valve
FIGURE 3. Shear
valves get their name
from the shear point,
a thin part of the metal
casting designed to
break when the top part
of the valve above the
shear point moves rela-
tive to the bottom part.
The valve mechanism
includes a hefty spring
that closes the pop-
pet, the disk that closes
off the flow of fuel (see
Figure 2). The poppet
is held open by a trip
mechanism, a thin bar
of metal with a notch in
it. An arm on the outside
of the shear valve sits in
this notch and holds the
poppet inside the valve
in the open position. When the top part of the shear valve moves relative to the
bottom part, the arm slips out of the notch and the spring closes the poppet, stop-
ping the flow of fuel. In the Hudson Falls incident, the top part of the shear valve
moved enough to fracture the metal at the shear joint, but there was not enough
movement to cause the trip mechanism to operate, so the poppet remained open.
Inspection and Maintenance of Motor
Fuel Dispensing Equipment, for a
description of the test procedure.
Employee Training Is
Imperative
The frequent turnover in con-
venience store industry person-
nel means that inexperienced
operators are commonplace. This
incident points to the importance of
providing emergency response train-
ing before handing over responsi-
bility for a facility to an employee. I
don't know the details of the training
provided to the personnel on duty at
this Cumberland Farms facility, but it
seems to me that they took an inordi-
nately long time to shut off the flow
of fuel.
-------
May 2012 • LUSTLine Bulletin 70
Proper training should empha-
size knowing the location and func-
tion of the emergency stop switch
and understanding the distinction
between the "stop" button on the
point-of-sale console and the emer-
gency stop switch. Learning the loca-
tion and the purpose of these switches
and when to use them should be the
first thing new employees learn about
their new workplace.
Pump Relay Failure Should
Be Monitored
Pump relays that are permanently
"on" are a problem that garners lit-
tle attention in the retail fuel indus-
try because the switch failure does
not interrupt fueling operations and
has little effect other than increas-
ing the electric bill. But such failures
effectively disable line-leak detec-
tion and can contribute significantly
to the severity of releases resulting
from cracked-but-not-tripped shear
valves, as well as typical piping and
dispenser leaks. These days, there are
pump controllers and some electronic
line-leak detectors that can monitor
the operation of the pump relay to
be sure that it is cycling properly and
provide an alarm signal when a stuck
relay is detected. It seems to me that
it is about time for the industry to
acknowledge and implement solu-
tions to this problem. •
Cleanup Corner
A Neat Little Column by Gary Lynn
Gary Lynn is Petroleum Remediation Manager for the State of New Hampshire.
Over the years he has authored many insightful and informative LUSTLine articles,
so we figured it was high time to put his stories in his own Cleanup Corner.
THAU'S GOLD IN THEM THAR HARD
.5KS1
The sheer volume of informa-
tion collected by state envi-
ronmental programs can
overwhelm and numb the uniniti-
ated. I call the process of making the
data meaningful and useful "data
mining." This terminology was par-
ticularly apt back in the days when
researching files was comprised of
visits to poorly lit storerooms with
file boxes rising up from floor to ceil-
ing. Although a paper cave-in never
seriously hurt anyone in my agency,
data mining in the old days was time
consuming, frustrating, and at best,
somewhat successful.
With the advent of networks, file
servers, and computerized records,
data mining has come of age. The
New Hampshire Department of
Environmental Services (DES) has
been able to use data mining tech-
niques to resolve dormant sites,
identify brownfields sites, reduce
receptor risks at contaminated
sites, and to troubleshoot emerging
groundwater threats. So let's put our
hard hats and head lamps on and
explore some ways to get more out of
your data.
Pinpointing Those
Brownfield Sites
One of the more interesting uses of
data mining is identifying petroleum
brownfields sites. Pinpointing these
types of sites improves the ability
of municipalities and other groups
to apply for and obtain brownfields
grants and allows the state to target
its resources to facilities that might
have a blighting or negative eco-
nomic impact.
What types of data are avail-
able that could help identify brown-
fields sites? In New Hampshire a
number of deadlines are approach-
ing that will require tank system
hardware upgrades. For example,
single-walled tanks and piping must
be upgraded by the end of 2015
and substandard Enviroflex pip-
ing must be upgraded within the
next 18 months. In addition to tank
hardware-upgrade data, we have
data on tanks that are in temporary
closure and tanks with leaks into the
interstitial space.
Such upgrade-induced economic
stresses are likely to lead to fore-
closures or an interest in the sale or
reuse of some of these properties. It
is possible to couple the tank-facility
upgrade data with internet resources
and further refine lists of potentially
distressed properties that could be
helped by brownfields programs.
For example, tools such as Google
Earth/Street View, and in New
Hampshire our online digital library
of site photos, make it possible to
view the condition of a property.
Web search engines can also identify
properties that are for sale or have
been foreclosed on by simply enter-
ing the property street address as the
search criteria.
DES has successfully identi-
fied owners that had major health
issues or were nearing retirement
and has helped them via brownfields
programs to sell their property or
remove unwanted USTs. The typi-
cal end result of this assistance is a
property that is either brought into
compliance or has a new owner with
more energy and resources available
to address site issues.
• continued on page 19
13
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LUSTLine Bulletin 70 • May 2012
from Robert N. Renkes, Executive Vice President, Petroleum Equipment Institute (PEI)
25 Years Since LIST Leaks Were an Inconvenience
The PEI Journal will include two articles in its 2nd Quarter 2012 issue about the biggest developments and changes the underground storage
tank industry has seen since the UST regulations were first proposed in 1987. One will be written by LUSTLine's own Marcel Moreau. The
other will feature perspectives, memories, and thoughts from eight industry experts who were around in 1987 and continue to be active in the
industry today. One of those experts is Jim O'Day, CEO of O'Day Equipment, LLC, headquartered in Fargo, North Dakota. Jim's com-
ments, as a longtime member of the Petroleum Equipment Institute and the Steel Tank Institute, were just plain old good and—quite honestly—
better than anything I could write on this 25th Anniversary year of the proposed UST regulations. So I decided to share them with you. Enjoy.
First of all, I am disturbed that it has been 25 years
since the UST rules were first proposed. That
means I have been doing this stuff a long time and
I must be at least "middle age" or older.
When I started in the business during the 1970s,
underground tank leaks were a common but inconve-
nient reality of tank ownership. I recall the senior mem-
bers of the company telling customers that the expected
life of an underground tank was about 10 years...before
it leaked.
Leaks were inconvenient. Back then it was all about
product loss and water intrusion. Disputes over leaks
were always about product loss; the environmental
impacts were never in the discussion. Our company
started manufacturing sti-P3 tanks in 1975 but it was a
tough sell.
A turning point for UST owners and suppliers was
the awareness of the environmental impact of leaking
tanks and piping and the "absolute pollution exclusion"
that became part of liability insurance policies.
A turning point for our business was when, as a
policy, we would no longer sell or install unprotected
tanks and piping for UST systems. We made this move
in 1985. While we lost business as a result, the USTs we
installed the next several years did not require anything
when the new regulations came into effect.
One thing that made a significant impact on the
industry was the first Recommended Practice PEI spon-
sored. RP100 was the first guidance document that
brought together best practices from a group of subject
matter experts with real world experience. This was a
big help in improving installation practices across the
United States.
One technology that was around but hardly worked
was "leak detection." It was often sold, but always dis-
abled, because it just did not work in the field. Today, we
respond to leaks that are as small a seep from a gasket.
Inventory reconciliation and other fuel management is
made easy with automatic tank gauge (ATG) systems
developed for testing tanks.
I was at a Steel Tank Institute meeting in 1978 where
a fellow from Germany was presenting how they devel-
oped double-walled tanks. The audience of U.S. tank
builders looked at him like he was from outer space. A
year later a Canadian presented his concept of the "Haz-
Bag," which gave everyone in attendance a chuckle. We
did not understand that we were looking at the future.
One thing that is different today from 1986 is the
care and attention today's UST owners and operators
need to give to their UST system operation. There must
be a need beyond mere fueling convenience to own an
UST today, because the operational aspects associated
with dealing with the ongoing compliance responsibili-
ties are daunting.
Who would have thought that double-walled tanks
and piping would be the norm when this all started? I
never expected would be the standard for all new USTs.
That being said, I do understand that that's the way it
should be. •
An AST Conflagration That Needn't
On August 18, 2011, a delivery driver from Flor-
ida Rock & Tank Lines was refilling an above-
ground storage tank at the 5th Wheel BP gas
station in St. Augustine, Florida. According to the U.S.
Department of Labor's Occupational Safety and Health
Administration (OSHA), the tank had a broken liquid-
level gauging system. Gasoline overflowed from the
tank. Vapors then combined with heat from the running
delivery truck to trigger an explosion. According to
published reports, the resulting fire took several hours
to put out. The delivery driver suffered third-degree
burns and spent several weeks in the hospital.
Following a six-month investigation, OSHA pro-
posed a $70,000 fine against Florida Rock & Tank Lines,
along with a citation for a willful violation for "failing to
provide a means for the delivery driver to determine if
the storage tank had enough capacity for additional gas-
oline." Coomes Oil was cited for one serious violation
with a proposed penalty of $7,000 for "failing to provide
Have Been
employees and delivery drivers a means to determine
the gasoline levels in the aboveground storage tank."
The fire, injuries, and property damage would not
have happened if PEI's Recommended Practices for Over-
fill Prevention of Shop-Fabricated Aboveground Tanks (PEI/
RP600) had been followed. Published first in 2007 and
just now revised, the document continues to fill the need
for a comprehensive reference guide that the industry
and regulators can use to minimize aboveground tank
overfill incidents.
The second edition of PEI/RP600 has been reviewed
and revised to provide better clarity to some provisions
of the document. The 27-page document supersedes
and replaces the previous edition of PEI/RP600. If you
install, maintain, own, fill, regulate, or manage aboveg-
round storage tanks, you should have a copy of this
publication. Learn more and order online ($40 for mem-
bers and regulators; $95 for nonmembers) at www.pei.
org/rp600. •
14
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May 2012 • LUSTLine Bulletin 70
Circa 1888 Rail Tanker Car/UST Discovered in
Knoxville, TN
by Lamar Bradley
Following up on a complaint last
July, Tennessee Department of
Environment and Conservation
(TDEC) staff members discovered
what could possibly be the oldest
underground fuel storage tank in the
world, dating back to just after the
Civil War. TDEC was notified when a
local resident reported seeing people
in the vicinity of a cylindrical metal
protrusion with a large and poten-
tially unsafe opening (Figure 1). The
cylinder was located in a remote,
overgrown area, and the caller was
concerned about the safety of chil-
dren playing in the area of this...
thing.
Rick Huchison, a staff member
with TDEC's Division of Under-
ground Storage Tanks in Knoxville,
visited the reported location and dis-
covered an exposed metal cylinder
with an opening of approximately
one and a half feet in diameter and
standing about one and a half feet
high. The structure was in a heavily
wooded area on property that had
once been used for zinc mining. The
mining operation had ceased in the
early 1970s and the property had
been essentially abandoned since
that time. Raised letters in the metal
dome around the opening of the cyl-
inder read "Harrisburg Car Manu-
facturing & Makers Harrisburg PA
1888." It appeared we had ourselves
some kind of buried tank from a rail
car.
There were several steel posts
around the tank opening, indicat-
ing the area had once been gated.
Buckets, ropes, rubber bands, plastic
jugs, and other debris were on the
ground around the cylinder open-
ing. The tank had no lid, nor was any
lid visible on the ground nearby. By
using a tank gauging stick to deter-
mine if there was liquid inside we
discovered that the bottom of the
tank was 103 inches from the open-
ing and that the tank contained what
appeared to be 20 inches of prod-
uct and an immeasurable amount
of water. The liquid appeared to
be heavy-end petroleum, possibly
diesel, heating oil, or kerosene. We
FIGURE 1. Top of 1888 railroad car originally built to transport oil for the Pennsylvania Railroad.
This is all that was visible to Huchison when the tank was first discovered.
later determined that the old, sticky
product masked the product-find-
ing paste and the liquid was mostly
water.
The Harrisburg Car
Manufacturing Company
Curious about his unusual find,
Huchison conducted some research
the next day and, based on informa-
tion he found online, he believed the
exposed metal cylinder was indeed
the top dome of an old railroad
tanker car. Wording stamped into
the metal superstructure indicated
this rail car was manufactured by the
Harrisburg Car Manufacturing Com-
pany.
The Harrisburg Car Manufac-
turing Company had an interesting
history. Founded before the Civil
War, the company produced railroad
cars for passengers, mail, baggage,
box, cattle, platform, coal, and hand
cars. Local blacksmiths employed
by the company forged and crafted
the metal portions of the rail car. The
company weathered the economic
ups and downs of the 1850s and sur-
vived the Civil War.
The discovery of oil in Titusville
resulted in an oil boom in Pennsylva-
nia following the war, and company
business boomed supplying oil tank
cars for transporting oil from the oil
fields. Harrisburg's early tank cars
were nothing more than conven-
tional flat cars with a metal tank sit-
ting on top and stabilized by wood
blocks. An iron railing around the
perimeter of the car was supported
by wood stanchions. The design
was improved and modernized dur-
ing the following years but always
retained the wooden frame. Our bur-
ied tank car appeared to be based
on the company's 1875 design when
compared with drawings that were
available online (Figure 2).
By the mid-1880s, the railroad
building boom had reached its peak
and production slowed. However,
by the end of the 1880s, meat packers
had perfected the art of preserving
beef. What was needed was a means
of transport—a refrigerated box car.
Harrisburg Car Manufacturing Com-
pany was the first to build such a car.
Things looked up, and the company
was enlarged, based on the expecta-
tion of more orders. Alas, that did
not happen, and the financial diffi-
culties of the 1880s left the company
with little in assets. By 1893, the com-
pany was in bankruptcy court, never
to emerge.
• continued on page 16
15
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LUSTLine Bulletin 70 • May 2012
Rail Tanker^rom page 15
FIGURE 2. Harrisburg Car Works designed this tank car in 1875 for the Pennsylvania Railroad.
Information about the Harrisburg Car Manufacturing Company and the illustration of the 1875 rail
car are used with the permission of the Mid-Continent Railway Museum, North Freedom, Wisconsin.
The Exhumation
Our Underground Storage Tanks
Division was concerned that
someone could fall into the large,
unsecured opening to this tank and
quickly engaged a state contractor
to empty and secure the tank. A few
days after the initial visit, UST per-
sonnel made another visit to the site
to oversee the removal of product/
water from the tank and to secure
the opening until it could be deter-
mined who would take responsibil-
ity for the tank. The tank was gauged
again and a total of 20 inches of liq-
uid was documented. A vacuum unit
removed approximately 410 gallons
of product/water. Before leaving the
site, the tank openings were covered
and secured.
The current property owner was
not aware of the existence of the tank
nor any use of the tank since the
days of the active mining operation.
It was not exactly clear who would
be responsible for removal of the
tank or what would be found when
the tank was unearthed. Ultimately,
the property owner agreed to take
responsibility for removing the tank.
In January 2012, the tank was
removed from the ground and its
identity as a tank from a railroad
tanker car manufactured in 1888 was
confirmed. We were unable to ascer-
tain when this rail car tank was bur-
ied or how long it had been in the
ground. The tank measured approxi-
mately 26 feet long and 6.5 feet in
diameter. It was in good condition
with no observed corrosion holes.
The tank was not on any kind of
platform, and there were no railroad
wheels found in the excavation.
16
When built, it appears the tank
container was minimally secured to
the platform and removing it from
the platform to be buried would not
have been difficult. While uncov-
ering the tank, the excavator inad-
vertently made a hole in its top.
Interestingly enough, no petroleum
contamination was identified in the
four soil samples that were collected
from the bottom corners of the pit.
The native soil in the tank pit was
red clay and the backfill material was
a limestone sand and regular sand.
We speculated this may have been
the oldest underground storage tank
in use in the world at 124 years old...
but that is mere speculation.
So What Happened to This
Remarkable Find?
Since this rail car was used as an
underground storage tank, tank clo-
sure was handled according to the
normal UST closure procedures.
Typically, used tanks are cut up and
sold for scrap metal value. However,
as unique as it was, I got to thinking
that there may be some interest on
the part of a railroad museum in pre-
serving the car as a historic artifact.
After several phone calls, person-
nel at the Tennessee Valley Railway
Museum in Chattanooga expressed
an interest in taking possession of
this artifact and possibly restoring it.
Museum personnel were put in
contact with the tank excavator and
an agreement was reached for the
museum to acquire the tank.. .a mere
one day before the tank was sched-
uled for destruction. As this article
was being written, the museum is
awaiting arrival of a piece of railroad
history. •
Lotnar Bradley is the Assistant Director
of the Division of Underground Storage
Tanks with the Tennessee Department
of Environment and Conservation.
He can be reached at
Lamar.Bradley@tn.gov.
FIGURE 3. The Harrisburg Car Manufacturing Company 1888 rail car being removed from the
ground. It is unknown how long this tank was buried, but there were no corrosion holes in the tank
when it was excavated.
-------
May 2012 • LUSTLine Bulletin 70
TRflHS Dfl TRIBAL LRI1DS
Exemplary Response to a Diesel Fuel Release
at a Laguna Pueblo Route 66 Travel Center
The Laguna
Pueblo Route 66
Travel Center
is a major truck stop
located about 30 miles
west of Albuquerque,
New Mexico. The
Laguna Development
Corporation (LDC),
an entity of the Pueblo
of Laguna, operates
the center. During a
routine facility check,
the security staff dis-
covered a release from
the large diesel tank
system. Diesel fuel
was coming out of a
manhole and through
the cracks near the
asphalt, spilling onto
the parking lot.
The LDC security
staff quickly notified
the manager on duty,
who immediately shut
off the power to the
tank fuel pumps. LDC
took immediate action to contain
the emergency, including contacting
the Risk Management Department,
Laguna Police, and New Mexico State
Police. The next morning, the LDC
notified the Laguna Environmen-
tal Office of the release and took the
necessary steps to prevent fuel from
migrating and adversely impacting
two nearby drinking water wells. The
wells supply water to the truck stop
and to adjacent entertainment, res-
taurant, and hotel facilities. USEPA
Region 6 UST staff corresponded and
met with the LDC and the Laguna
Environmental Office shortly after the
incident to provide further response
guidance and confirm the release of
petroleum product.
About 2,200 gallons of diesel
fuel had been released as a result of
an improperly installed new fueling
system that the LDC had recently
added to the facility. The LDC hired
several remediation and UST equip-
ment companies to complete the
Laguna Pueblo Route 66 Travel Center.
Remediation trench along diesel-fuel-release pipeline.
emergency response, clean up the
release, dispose of contaminated
spill absorbents properly, and fix the
fueling system.
The LDC takes pride in their
proactive, preventative manage-
ment approach to minimizing future
releases from their UST systems.
In this case, they went beyond the
required response by upgrading the
equipment in the tank pit and at the
dispenser fueling area in an effort
to prevent future releases. In addi-
tion, they installed three wells to
ensure ongoing water supply moni-
toring. During January 2012, the
LDC, Laguna Environmental Office,
and EPA Region 6 met to verify that
no contamination from this release
affected the drinking water sup-
ply and agree that the cleanup was
completed. This is a great example
of a responsible party taking prompt
action to respond to a release and to
pay for a cleanup. •
Crow Creek
Reservation LUST
Site Becomes Boys
and Girls Club
The former Rank's Service Sta-
tion is a leaking underground
storage tank site located on the
Crow Creek Indian Reservation in
Fort Thompson, South Dakota. When
the South Dakota Department of
Environment and Natural Resources
(SDDENR) conducted a limited site
assessment in 2000, results showed
elevated concentrations of petroleum
hydrocarbons. At that time, Har-
vest Initiative, an organization that
facilitates economic investment on
the Crow Creek Sioux Indian Reser-
vation, contacted USEPA Region 8
to express interest in constructing a
Boys and Girls Club and office space
at the site.
The Region worked closely with
all involved parties to expedite clean-
up of the site; including removing
approximately 1,800 cubic yards of
contaminated soil and incorporat-
ing a vapor barrier into the construc-
tion design. The barrier will prevent
petroleum vapors from the ground-
water contamination from entering
the Boys and Girls Club and ensure
the site will be safe for reuse. USEPA
is continuing remediation at the site
and anticipates completing cleanup
by 2014. •
Former Rank's Service Station.
New Boys and Girls Club.
17
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LUSTLine Bulletin 70 • May 2012
FAQs from the NWGLDE
... All vou ever wanted to know about le
afraid to ask.
Here's How to Determine if an NWGLDE Listing Is
Applicable for Use with Biodiesel Blends
In this LUSTLine FAQs from the National Work Group on Leak Detection Evaluations (NWGLDE), we discuss a change of policy
that was implemented after the addition of biodiesel blends to NWGLDE listings, which was discussed in LUSTLine Bulletin 67.
Note: The views expressed in this column represent those of the work group and not necessarily those of any implementing agency,
Q
. I submitted a request to add biodiesel blends to my
ATG listings on the NWGLDE List. Why do I not
see them listed under "Applicability" in any of my
listings?
A. The following NWGLDE policy for listing biodiesel
blends appeared in the NWGLDE FAQ in the March
2011 issue of LUSTLine, Bulletin #67:
"Manufacturers of leak detection equipment are
encouraged to contact the appropriate members of
the NWGLDE to request the addition of ASTM stan-
dard biodiesel blends to their current listings."
The NWGLDE realized shortly after this was pub-
lished that some leak detection equipment is still in
use where a manufacturer of the equipment is no
longer in business. Without a change in NWGLDE
policy, this equipment could not be used with any
biodiesel blends, even though it is likely capable of
being used with certain biodiesel blends. As a result,
we added a new definition and a disclaimer to our
website at iviviv.NWGLDE.org that supersedes the
above policy. Bold statements were added to the top
of our home page with active links to the following
definition and disclaimer in an effort to ensure the
new policy would be noticed by everyone visiting
the site.
Definition
Diesel or Diesel Fuel:
Middle petroleum distillate fuel that may contain up to
5% biodiesel in accordance with ASTM standard D975.
Disclaimer
Unless specifically indicated on the individual data sheets,
equipment listed by the NWGLDE has not been deter-
mined to be acceptable for use with alternative fuels with
the following exception:
Biodiesel B6 through B20 meeting ASTM D7647
and biodiesel B100 meeting ASTM D6751 may be
used with all equipment listed for diesel in the NWGLDE
list whether or not these alternative fuels are included
on individual data sheets. This exception DOES NOT
APPLY to leak detection test methods using Out-of-Tank
Product Detection (Vapor Phase) for B6-B20, and Out-
of-Tank Product Detection (Liquid and Vapor Phase) and
any tracer-based test methods for B100. For these meth-
ods, individual data sheets will have to be referenced for
applicability.
Since the definition and disclaimer may be somewhat
difficult to follow, we have broken them down to clar-
ify what they are saying as follows:
• Biodiesel B5 will not be shown on any NWGLDE
leak detection equipment listings. Instead, all
NWGLDE listings that are applicable for diesel are
by definition also acceptable for use with biodiesel
B5.
• Biodiesel B6 through B20 will also not be shown on
any NWGLDE leak detection equipment listings.
Instead, all NWGLDE listings that are applicable for
diesel are now considered acceptable for use with
biodiesel B6 through B20.
• Because diesel and biodiesel blends do not pro-
duce vapors, Out-of-Tank Product Detection (Vapor
Phase) leak detector listings do not include diesel,
and therefore will not be acceptable for use with any
biodiesel blends.
• Biodiesel B100 will not be shown on NWGLDE leak
detection equipment listings with the exception of
Out-of-Tank Product Detection (Liquid and Vapor
Phase) and any tracer-based test methods. Instead,
all NWGLDE listings other than Out-of-Tank Prod-
uct Detection (Liquid and Vapor Phase) and any
tracer-based test methods that are applicable for die-
sel are also acceptable for use with Biodiesel B100.
• Manufacturers of Out-of-Tank Product Detection
(Liquid Phase) and any tracer-based test methods
must perform an evaluation using Biodiesel B100,
and must submit the evaluation to the NWGLDE
before any of the Biodiesel blends may be added to a
NWGLDE leak detection equipment listing.
• Because biodiesel B21 through B99 blends are not
included in an ASTM standard (see LUSTLine 67),
leak detection equipment manufacturers must per-
form a third-party evaluation using these biodiesel
blends. The evaluation must be submitted to the
NWGLDE before the NWGLDE will consider add-
ing any of these biodiesel blends to any NWGLDE
leak detection equipment listing.
The NWGLDE needs to clarify that the above discus-
sion concerning applicability of the diesel and biodie-
sel is based on functionality and not compatibility. The
following NWGLDE disclaimer, which can also be
found on our website, was written to clarify the reason
for this:
18
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May 2012 • LUSTLine Bulletin 70
FAQs... continued from page 18
Since long-term material compat-
ibility with the product stored is
not addressed in test procedures
and evaluations, the NWGLDE
makes no representations as to
the compatibility of leak detec-
tion equipment with the product
stored. •
• About the NWGLDE
The NWGLDE is an independent work
group comprising ten members, includ-
ing nine state and one USEPA mem-
ber. This column provides answers
to frequently asked questions (FAQs)
the NWGLDE receives from regula-
tors 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 eval-
uations to determine if each evalu-
ation was performed in accordance
with an acceptable leak detection
test method protocol and ensure
that the leak detection system
meets USEPA and/or other appli-
cable 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.
• Gold in Hard Disks from page 13
Discovering the Success
Stories
Another way to strike data-mining
gold is to research program suc-
cess stories. Petroleum cleanup
programs tend to function mostly
in an "aw shucks, just doing my
job" mode. Unfortunately, legisla-
tures and politicians of all stripes
are making tough budgeting deci-
sions and are asking fundamental
questions about continuing well-
established programs. It is now
essential to be able to articulate and
promote the value of governmental
programs.
Aggregate statistics touting
tanks removed, sites closed, and
tons of soil treated are valuable,
but probably just as important is
the development of success stories.
These summaries can use a specific
site to explain in a concrete fashion
how our programs can assist with
solving difficult problems. The
internet is a wonderful way to find
information on redevelopment suc-
cess stories. We have been able to
find data on economic impacts of
sites that our programs helped to
clean up and even awards won by
those projects. I used this informa-
tion to craft a series of well received
success stories on the positive envi-
ronmental and economic impacts of
New Hampshire petroleum reim-
bursement funds.
Take Charge of Your Data
Data management and mining
should play an essential role in
developing good tank programs and
sound state fund management. We
have found it useful when research-
ing sites that are out of compliance to
make the effort to better understand
and address underlying issues. It is
useful, for example, to determine cur-
rent site ownership (e.g., foreclosure,
tax deeding, property sale, property
owner death) when attempting to
obtain compliance. There are excellent
online registry-of-deeds websites in
New Hampshire that can be searched
for tax, deed, and recent sale informa-
tion. Simple queries can now identify
all sites with overdue cleanup, UST
compliance, or even cross-program
compliance issues.
I particularly like the ability to
find information on tank system hard-
ware. This has provided very useful
cross-program data that our remedia-
tion section has used to troubleshoot
new releases or emerging threats
(e.g., vapor recovery system hard-
ware information was correlated with
groundwater data to discover a link
between groundwater contamination
and vapor releases).
Finally, a variety of tools are now
available to verify the accuracy of
consultant contaminant-receptor sur-
veys. Online access to recent aerial
photograph data can confirm whether
an undeveloped lot has been redevel-
oped into a lot with a brand new, vul-
nerable water supply well. Also, New
Hampshire's geographic information
system (GIS) makes it very easy to
identify public water supply wellhead
protection areas or private wells using
our online water-well inventory GIS
layer.
This is just a quick summary of
the possibilities lurking in many rich
veins of data that can be sifted and
sorted to meet your program needs.
My advice? Take charge of your data
and make it work for you. •
Name
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Phone: (978) 323-7929 • Fax: (978) 323-7919 • lustline@neiwpcc.org • www.neiwpcc.org
19
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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.
Kuhn and Falta Receive LUST Lifetime Scientific Achievement
Award at the 2012 National Tanks Conference
This year's LUST Lifetime Scientific Achievement Award was
presented to Ron Falta, Professor of Geology and Environ-
mental Engineering at Clemson University, and to Jeffrey
Kuhn, hydrogeologist and LUST/Brownfields section man-
ager with the Montana Department of Environmental Quality.
During the past several National Tanks Conferences, LUST
program friends and colleagues have presented these awards
as a thank you for the dedication and significant contributions
of the recipients.
Ron's award was given for helping LUST programs rec-
ognize the dangers of lead scavengers associated with fuel
spills and for contributing significantly to the science of site
assessment and risk evaluation for LUST sites. Jeff's award
was given in appreciation for his years of dedication, leader-
ship, and advocacy for a scientific approach to site assess-
ment, risk evaluation, and cleanup of fuel oxygenates and
additives at Leaking Underground Storage Tank sites. •
Friends, colleagues, and former award recipients join Jeff and
Ron in appreciation and celebration. From left to right: Bruce
Bauman, API, 2008 award recipient; Ellen Frye, LUSTLine Editor,
2010 recipient; John Wilson, USEPA ORD, 2007 recipient; Ron
Falta, Clemson University, 2012 recipient; Matt Small, USEPA
Region 9; Jeff Kuhn, Montana DEQ, 2012 recipient; and Jim
Weaver, USEPA ORD.
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