New England Interstate 116 John Street	Bulletin 51
Water Pollution Control Lowell, Massachusetts	December
Commission 01852-1124	2005
www.neiwpcc.org/lustline.htm
LUS.T.UNE
A Report On Federal & State Programs To Control Leaking Underground Storage Tanks
Inside
hen disaster
strikes. When
devastation
rules and lives are tossed
and lost to the ravages of
wind and water. When
your world's gone topsy-
turvy and you cast about
to recapture... some-
thing. When a container
of 6,000 tons of frozen
chicken parts is washed
from ship to shore, destroying everything in its path
until it rests in a residential neighborhood and sits... in the
heat... for weeks... before it is cleared away. Wen
flies feast on all manner of rot and darken the sky at f e
slightest disturbance. When water and wastewater systems
sit choked, interrupted{and indifferent. When oils, metals,
industrial compounds, petrochemicals, pesticides, and other
glop coat the landscape. When moonlight is the sole relief
in the blackness of night. When cars are on top of houses,
and refrigerators are perched in trees, and Dr. Seuss is
nowhere to be found. When surreal is real... what can we
say about USTs?
'	¦ continued on page 2
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Did the Shear Valves Shear?
Case of the Buckled Steel Tanks
A Message from Cliff Rothenstein: A Summer to Remember
Who's on First—Energy Policy Act
LUST and Fuel Harmony
Case for Multicomponent Analysis of Gasoline
NAPL Using Electrical Resistivity Imaging
Michigan's Noninvasive UST Assessment Odessey
Maine's UST Third-Party Inspection Program
PEI's Online O/O Training and New UST Installation RP
Revitalizing Contaminated Sites
Tanks on Tribal Lands

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LUSTLine Bulletin 51 • December 2005
¦ Tanks in the Wake from page 1
First impressions
We have all seen the pictures of the
devastation wrought by Hurricanes
Katrina, Rita, arid Wilma on the Gulf
Coast states. In the hardest-hit areas,
few aboveground structures sur-
vived the 20- to 30-foot storm surge
and the 140-mile-an-hour winds.
Convenience stores, pump-island
canopies, and fuel dispensers were
no exception.
"It was like a bomb hit the
area... mainly from the water surge,"
says John Cemero, U.S. EPA Region 6
UST/LUST program manager, who
assisted the Louisiana Department of
Environmental Quality (LDEQ)
inspectors and a team of inspectors
from U.S. EPA regional offices in con-
ducting inspections to determine UST
system damage and operability.
"Some former UST facilities were
nothing but mud flats. Some were just
twisted rubble. So much rusted imme-
diately because of the salt water."
"There was much more than I
could have anticipated," sighs David
L.U.S.T.Line
Ellen Frye, Editor
RickiPappo, Layout
Marcel Moreau, Technical Adviser
Patricia Ellis, Ph.D., Technical Adviser
Ronald Poltak, NEIWPCC Executive Director
Lynn DePont, EPA Project Officer
LUSTLine is a product of the New England
Interstate Water Pollution Control Commis-
sion (NEIWPCC). It is produced through a
cooperative agreement (#T-830380-01)
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 oldest
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
LUSTLine is printed on Recycled Paper
A huge pile of debris was deposited at the dispenser islands of this store.
unsuspecting inspectors. "It's hard to
tell if some owners will come back
since some areas are not repopulated
yet," he says. "Some, I suspect, will
not return."
So I guess we can say that if we
didn't already have a sufficient
appreciation for the power of water,
most people, including tank owners,
operators, and regulators, do now. I
guess we could say that the lion's
share of gasoline sloshing around the
ing out of seven pipelines and coastal
storage tanks ruptured by Hurricane
Katrina.)
So how did the fuel systems and
associated structures fare, especially
in the zone near the coast? As Charles
Harp, Tanks Section Environmental
Manager for the Florida Department
of Environmental Protection's
(FLDEP's) Northwest District (the
Panhandle), points out, we need to
keep in mind that there are three types
Mud, mud everywhere, and not a sump...
Bernstein, U.S. EPA Region 2, who
headed up the EPA inspection team.
"Did you know that fiberglass sump
covers float, unless they are bolted
down? Do you know how hard it is
to conduct an inspection when a
facility is under a foot of mud?" He
recalls the smell of putrefying conve-
nience store food, and the exposed
sumps acting as booby traps for
post-Hurricane Ka-
trina/Rita flood-
waters in the New
Orleans area proba-
bly came from
flooded automo-
biles and not so
much from USTs.
At some UST facili-
ties in the affected
areas, the tanks
stayed put, while
everything above-
ground was swept
away.
Like so many
other things above-
ground, ASTs did
not fare so well.
Large field-erected and shop-fabri-
cated ASTs can be quite vulnerable
under certain storm conditions. Some
of the large aboveground crude oil
tanks and petroleum barge terminals
in the affected areas along the Gulf
Coast had significant releases. (On
September 15, the Natural Resources
Defense Council reported that nearly
six million gallons of oil were pour-
2

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December 2005 • LUSTLine Bulletin 51
of hurricane-damage scenarios: rain-
fall flooding, storm surges—flooding
with enormous wind and water
energy—and wind. Depending on
where they were located, UST facili-
ties ran the gamut. Harp has the many
storms that pummeled the Panhandle
etched firmly in his memory.
USTs in Mississippi?
According to Kevin Henderson, Mis-
sissippi Department of Environmen-
tal Quality (MDEQ), and as also
described by inspectors in Louisiana,
most convenience stores and
canopies in coastal areas subject to
storm surges were wiped out. "Some
had nothing to mark the place where
they'd been except the store's foun-
dation slab and the pump island,"
says Henderson. "Canopies were
reduced to twisted steel columns and
jumbled aluminum panels. Only a
few fueling dispensers were left
standing. The destruction was com-
plete."
Here we've got proper anchoring and resultant shearing...and lots of beer!
L				'~^ZZ7nefthfsto^Only
Henderson reports that although
there were some big releases from
ASTs, by and large the USTs survived
intact, even though the external pres-
sures they were subjected to from the
storm surge exceeded their design
pressure. "As long as the fill and tank
gauge caps were tight, little water got
into the tanks and the fuel seems to
have stayed put."
With all the rain and flooding,
UST inspection teams in Mississippi
and Louisiana were not reporting
instances where underground tanks
floated out. Apparently, tanks were
adequately anchored and stayed in
place despite the likelihood that they
were fairly empty due to a high
demand for fuel.
Many of the shear valves did not
properly shear. A number of piping
systems were damaged and left open
to the environment as a result of inade-
quate shear valve anchoring. This fail-
ure of shear valves to
shear was a common
finding in Louisiana as
well. (See "Did the Shear
Valves Shear?" on page
7.)
"Many dispenser
cabinets that were
poorly anchored were
knocked down," says
Henderson. "The four
bolts that typically
anchor the cabinets are
not nearly enough to
properly anchor them.
Although nothing
would have saved
one tank could be many of the dis-
parting lot¦	pensers, it is appar-
ent that they were
too easily knocked down.
High winds brought down some dis-
pensers with apparent ease.
"Vent lines should be all metal or
otherwise anchored at the transition
from above,ground to underground.
Only at those facilities where the vent
lines were broken at or near the sur-
face was there any real problem with
water intrusion into the tanks. If vent
lines are nonmentallic underground
and then transition to metal above-
ground, they have a tendency to
break off right at or just below
ground level when they are in the
soil. If they are in concrete, this is
usually not a problem."
With regard to tank-top fittings,
Henderson says that as long as there
was a "decent" cap and it had a gas-
ket on it, the tanks generally did not
take on any water. It seems as though
the hydraulic pressure of the water
on top of the tanks acted to seal the
caps tightly. "We have seen very little
water in any of the submerged tanks
where the vent lines were standing
and they had decent caps on the tank
risers," says Henderson. "A few
tanks lost their caps entirely, presum-
ably because they were not 'decent'
caps to begin with...or someone
removed them.
"A number of tank beds were
apparently scoured out, at least par-
tially, although we know of only
three or four where evidence of this
can been seen at the surface," says
Henderson. "I don't know what can
be done about this other than to
require paved coverings (maybe even
sheet pilings of the tank excavation
walls or some kind of vault in very
vulnerable locations)."
Kevin Henderson photographi-
cally documented his inspections. All
of the photographs in this article,
except for two, were taken by him.
He has graciously provided us with a
PowerPoint® presentation that can be
viewed on NEIWPCC's website at
ivwiv.neiwpcc.org.
USTs in Louisiana
While many coastal tank facilities in
Louisiana suffered damage similar to
that in Mississippi, the New Orleans
area experienced additional prob-
lems as a result of prolonged flood-
ing. Recognizing that an enormous
amount of work would be needed
to get systems back in operation
¦ continued on page 4
3

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LUSTLine Bulletin 51 • December 2005
"Typical" debris field in the parking lot of the store made inspection of
the tank system difficult.
how the water got into the tank and
the proper disposal of water after it
was removed from the tank. An oper-
ational concern might be the condi-
tion of an ATG system damaged by
water at a flooded facility. While a
nonoperational ATG might not be an
immediate environmental concern, it
will have to be repaired/replaced at
some point for the facility to meet
release-detection requirements.
"Basically, the inspectors per-
formed all the physical aspects of a
¦ Tanks in the Wake from page 3
(e.g., tightness testing and replacing
lines and electrical systems) and that
the speedy return of UST facilities to
normal operation was crucial to the
recovery effort, the LDEQ issued two
documents, a portion of an Emer-
gency Declaration pertaining to USTs
and a Plan for Evaluating Underground
Storage Tank Sites Impacted by Hurri-
cane Katrlna (www.deq.state.la.us).
The Emergency Declaration "sus-
pends provisions contained in the
UST regulations that owners/opera-
tors may not have been able to com-
ply with due to the storm and its
subsequent flooding. It also provides
for continuing coverage by the Motor
Fuels Underground Storage Tank
Trust Fund, with no additional
deductibles that might have attached
to a claim for reimbursement should
the owner/operator not have been
able to comply with the regulations
due to storm conditions. "
The sites flooded by the hurri-
cane had to be evaluated to deter-
mine the response actions necessary
to place UST facilities back into ser-
vice and protect human health and
the environment. The UST evaluation
plan contains "the expedited process
that tank owners/operators must fol-
low before bringing an UST system
back on line. The process describes
the steps owners and operators must
LDEQ inspec-
tors initially surveyed affected UST
areas for obvious signs of releases
(e.g., sheens). With the overwhelming
need to get UST facilities back into
operation, help was needed. The U.S.
EPA UST inspection team was
charged with determining operability.
"These were not 'compliance' inspec-
tions/' explains John Cernero. "They
were conducted to determine whether
an UST system could be placed back
into operation without further testing
(e.g., line/tank tightness testing) on a
temporary basis. If the UST could be
placed in operation, the owner/opera-
tor was required to at least conduct
inventory control." The team com-
pleted more than 900 facility evalua-
tions.
"We developed an inspection
routine to determine the degree of
damage caused by Hurricane Katrina
to the affected parishes as it related to
environmental and operational con-
cerns," explains David Bernstein.
"For example, water in an UST
would be considered an environmen-
tal concern, due to questions as to
UST inspection, allowing for LDEQ
follow-up work, in most cases, to be
completed by a request for docu-
ments," says Bernstein. "The facilities
were checked for whether shear
valves operated correctly, condition
of release-detection equipment, lev-
els of water and/or product in tanks
and groundwater monitoring wells,
cathodic-protection equipment such
as rectifiers, damaged vent lines,
damaged sumps, spill buckets, elec-
trical wiring, tank floatation, free
product, dispensers, and general
overall damage to the facility."
Water in All the Wrong
Places!
I asked David Bernstein, who spent a
month in Louisiana conducting these
inspections, and Scott Hoskins, U.S.
EPA Region 4, who may still be rack-
ing up time in Louisiana for all I
know, what they thought were the
biggest tank problems. What stood
out most in their minds (besides
shear valve issues) was that, due to
flooding, storm surges, and high lev-
take to bring the
UST safely on line
without having to
wait until preci-
sion tank and line
tightness tests
can be per-
formed."
This fill port of a "regular unleaded" tank was uncovered, and the tank
was found to be full of water when gauged by MDEQ personnel.
4

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December 2005 • LUSTLine Bulletin 51
anvm
Risen
service, but that
it should have
an integrity test
performed as
soon as contrac-
tors and ser-
vices become
available to per-
form the testing
and no later
than six months
after product
was first placed
into the tank
after flooding.
Where's the
Fuel When
You Need It?
Further east, in
	 Florida, where
hurricanes are no stranger, people in
parts of the state are still smarting
from September 2004's Hurricane
Ivan, when water surges were pow-
erful enough to move four multi-
million-gallon ASTs off their
foundations and devastate support
buildings. (Yes, Virginia, gigantic
aboveground bulk-storage tanks
move, particularly if they don't have
enough ballast.) During Hurricane
Ivan, the state had a significant loss
in bulk-storage capacity for fuel dis-
tribution—tank farms were lost and
docks couldn't receive fuel. In 2005,
after Hurricane Dennis in Florida,
Cap gone from tank fill allowing four-inch riser to become filled with sand
and debris during storm surge. This tank was found to be completely full
of water with nine inches of sand/debris in the bottom.
els of rain, many tanks were found to
contain water, with water levels
ranging from a few inches to com-
pletely full. The water had entered
the tanks through vent pipes and
loose or missing fill caps and bung
holes.
LDEQ will have the job of track-
ing the disposal of this contaminated
water by requesting copies of mani-
fest documents that detail where the
pumped water was disposed of after
removal. Because of the large amount
of contaminated water that must be
disposed of, at high cost to the
owner, follow-up to ensure proper
disposal is essential for preventing
adverse impacts to the environment.
The sheer volume of UST system
equipment destroyed by the hurri-
cane and ensuing floodwaters also
struck Bernstein and Hoskins—hun-
dreds of dispensers, ATG systems,
impressed current rectifiers, and
other electronic equipment. "A great
deal of follow-up work will be
needed to make sure that these sys-
tems are properly replaced," says
Bernstein. "On at least two occasions,
I witnessed a facility owner attempt-
ing to put a product dispenser back
into service although it had been
completely underwater."
"Many owners have told me that
they didn't realize that they would
have to do tank-tightness tests,"
remarks Hoskins. The Plan for Evalu-
ating Underground Storage Tank Sites
Impacted by Hurricane Katrina specifi-
cally states that a flooded system that
is determined to be suitable for re-
ceiving product may be put back into
and shortly after Rita and Katrina,
about one-third of the nation's refin-
ery capacity was out of service.
As Marshall Mott-Smith, Admin-
istrator of FLDEP's Storage Tank Pro-
gram explains, oil companies must
perform a ballast balancing act, trying
to keep fuel in the bulk-storage tanks
and at the same time keep the fuel
supply moving out to where it needs
to be. As Mott-Smith reminds us, all
USTs get their fuel from ASTs.
Because of what happened during
Ivan, this year's storms have fueled
concerns about fuel supplies—an
issue before, during, and after storm-
related evacuations in any coastal
area. Images of streams of vehicles
creeping along on major evacuation
routes in Texas, Louisiana, Missis-
sippi, and Florida during Katrina and
Rita attest to the seriousness of this
issue.
In many of the hardest-hit areas
of the Gulf Coast, U.S. EPA waived
certain requirements in order to facil-
itate the transport and distribution of
fuel needed to get the economy and
infrastructure up and running. Emer-
gency gasoline stations were permit-
ted for 30 days, for example, without
having to worry about issues such as
vapor recovery from the pumps. Skid
tanks, tank trucks, and even trucks
holding 55-gallon drums of fuel were
permitted (or not) on an emergency
basis.
¦ continued on page 6
This tanker was set up as a temporary fueling station for emergency vehicles during the fuel crisis
that followed the storm.
5

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LUSTLine Bulletin 51 • December 2005
¦ Tanks in the Wake from page 5
Charles Harp and Marshall Mott-
Smith can rattle off the names of hur-
ricanes and associated damage like
devoted scholars. They report that,
generally, during Ivan, Wilma, Jean,
and Francis, USTs suffered canopy
and dispenser damage but had few
problems with shear valves or float-
ing tanks or water in tanks (just in
sumps), because most of the damage
was wind related. But fuel availabil-
ity was the most serious issue,
whether it was because ASTs and
USTs were empty due to peak
demand, because the fuel supply net-
work was disrupted, or because
gasoline was stored in tanks but there
was no electricity available to operate
the fuel pumps.
The Florida Legislature is
proposing a new law that will require
tank owners and operators to have
The ASTs at this Munroe Barge Terminal in Biloxi floated off their footings. A release of 482,000
gallons of fuel occurred, but no evidence of this fuel was ever seen (presumed "lost" out to sea).
The three tanks that floated up against the larger tanks are 75,000-gallon gasoline tanks.
Bernstein

This
tanks, but no electric
power to run their fuel
dispensers"
When It's All Said
and Done...
According to a Novem-
ber 29, 2005 press release
from the National
Oceanic and Atmos-
pheric Administration:
"The 2005 Atlantic hur-
ricane season was the
busiest on record and
extends the active
hurricane cycle that
such as natural forces that will have
their way come hell or high water. If
shear valves are working properly,
then damage to an UST system will
be that much less. If caps are on tight,
then water might not enter the tank
itself. If tanks have anchor straps and
ballast, then they probably won't
float. The issues are bigger than our
little old storage tanks. We've just got
to do the best we can. In the next
issue of LUSTLine, David Bernstein
will provide additional information
on the results of U.S. EPA's 900-plus
inspections and tips they discovered
about performing inspections in a
topsy-turvy world II
emergency electric power backup,
such as generators or electric pumps
powered by portable generators.
"Our department is purchasing 30
portable electric fuel pumps that can
be powered by 12-volt car batteries,"
says Mott-Smith. "Although they are
designed for use on aboveground
tanks, we have had them adapted for
use on underground tanks. Flow
rates are 10 to 12 gallons per minute,
and we have acquired in-line meters
for quantifying the fuel dispensed.
The pumps will be used for Dade,
Broward, and Palm Beach County
government fleet management or
other essential government services
operations that have underground
began in 1995—a
trend likely to con-
tinue for years to
come. The season
included 26 named
storms, including
13 hurricanes [14
now with Epsilon]
in which seven
were major (Cate-
gory 3 or higher)."
On that
happy note, let's
just say we
should improve
what we can
improve and
accept that
which we can-
not change,
A boat
tin the wrong place.
ui Udviu
6

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December 2005 • LUSTLine Bulletin 51
Did the Shear Valves SheQf?
by Marcel Moreau
Kevin Henderson of the Mississippi Department of Environmental Quality had the job of assessing the damage caused by Hurricane
Katrina to some of Mississippi's hardest-hit fueling facilities. He took the photographs in this article (and many others) to document
the damage. I spoke with Kevin to find out what he observed regarding the condition of UST system dispenser shear valves. The fol-
lowing discussion reflects observations made by investigators in areas of Louisiana.
M, Your pictures show that most dispensers were knocked over by
forces of wind and water. Did the shear valves shear?
We found many instances where the shear valves (a.k.a.
crash valves, impact valves, or fire valves) did not shear off,
and some instances where the valve mechanism did not
close or only partially closed, even when dispensers had
been swept clean away. In a number of cases where the
shear valves did not separate, the flex connectors beneath
the shear valves were stretched and pulled out of the
ground because the shear valves' connection to the dis-
penser island did not hold. (See Figure 1.)

FIGURE 1. This trio of shear valves did not function as designed. The
valve body did not separate at the shear joint because the valves, along
with their anchoring bar, were pulled up and out of the dispenser island.
M. What do you think happened to cause the shear valves not to
separate?
A shear valve is designed to operate when shear forces
(forces acting perpendicular to the axis of the valve) affect
the top part of the valve above the shear joint relative to the
bottom part of the valve below the shear joint. (See Figure
2.) Shear forces are the kinds of forces involved when a
vehicle rams into a dispenser. The wind and maybe water
forces that tipped over these dispensers caused more of a
tensional (stretching) force to be exerted on the shear valves
as the dispenser cabinets tipped over. As a result, rather
than the shear joints separating, they held and the piping
was uprooted from the ground.
M. Were the shear joints properly anchored?
By and large they were solidly anchored, but again, they
were anchored to resist shear forces. The tensional forces
they experienced caused some of them to slide up and out
of the clamps that were supposed to hold them in place.
In some cases, the steel anchor bar to which the shear
valves were attached failed to hold and was torn out of
the dispenser island. (See Figure 1.) This is what generally
occurred when multiple shear valves were attached to a
single anchor bar that ran the length of the ciispenser
island opening. In cases where there were single shear
valves anchored to individual anchor bars running across
the short axis of the dispenser island opening, the anchor-
ing mechanism seemed to hold better. (See Figure 2.)
~~

FIGURE 2. This pair of shear valves functioned as designed. The valve
mechanisms closed completely and the bottom part of the valves
remains solidly anchored to the dispenser island. The top part of the
valves, along with the entire dispenser, has been blown away.
M. If another storm of Katrina's intensity were to threaten
Mississippi in the future, do you have any recommendations for
what UST system owners might do to prepare for the worst?
K. I'd suggest tripping all the shear valves by hand as a
good precautionary measure to take as you are shutting
down the station. There's nothing short of removing a dis-
penser to high ground that would save it from a storm of
this magnitude, but if you could find a qualified techni-
cian in time, you might consider disconnecting the unions
that connect the dispenser to the underground piping.
That way, the dispenser could get blown away without
disturbing the underground piping, which might simplify
the job of returning to business afterwards. Of course,
with a storm of this magnitude, it's going to be a long time
before anything returns to normal anyway. ¦
7

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LUSTLine Bulletin 51 • December 2005
The Case of the Buckled Steel Tanks on
Mississippi Highway 90
by Kevin Henderson
It was a Kangaroo convenience
store owned by The Pantry, Inc.,
located on the north side of High-
way 90, which runs parallel to the
Gulf Coast in Biloxi, Mississippi—
practically on the beach. The facility
had three 12,000-gallon sti-P3® tanks,
which were installed in 1994. The
tanks were buried approximately six
feet deep, anchored with deadmen,
and paved over with an eight-inch-
thick reinforced-concrete pad. The
store building was completely
destroyed by the 30-foot storm surge
of Hurricane Katrina. The dispenser
cabinets were recovered from the
storm rubble as far away as a quarter
mile from the store. The concrete pad
over the tanks was slightly sunken
and buckled, apparently due to
scouring of the backfill materials
underneath the pad during the storm
surge. Strangely, the tank vent lines
were left standing, although they
were leaning so that the tops of the
vents were approximately 10 feet
above ground level.
A few days after the storm
passed, the owner observed fuel
seeping up between the cracks in the
concrete pad of the store parking lot
and flowing onto Highway 90.
Observing the site conditions, we
surmised that the regular tank must
have somehow rolled or rotated—the
tank risers were out of alignment
with the manway openings in the
concrete pad. Since the tank was steel
we didn't believe it was buckled; we
thought the tank risers could have
been broken out of the nylon bush-
ings at the top of the tank, serving as
the source of the fuel we were seeing
at the surface.
When we stuck the tanks, we
observed the following:
® The diesel tank had about 50
inches of fuel in it with 10 inches
of water.
•	The premium tank was com-
pletely full of water/fuel (mostly
water).
•	We couldn't get a gauging stick
in any of the regular tank risers
After responding to the fuel
seepage, the owner made the deci-
sion to permanently close the tanks.
Due to several logistical concerns, the
tank removal did not begin until
October 19, 2005. The premium tank,
which was in the middle, was
removed first. The tank was buckled
along its entire length and one of the
end caps was buckled. Although the
tank was badly buckled, there were
no breaches in the wall and no fuel
was lost. The diesel tank was
removed next and was not damaged.
tank. These vertical braces probably
prevented the tanks from being
buckled much worse than they were.
So What Happened?
What caused these three tanks to
behave so differently given that they
were all exposed to the same 30-foot
storm surge? While an engineering
analysis has not been conducted,
consider the following scenario: The
30-foot storm surge rapidly inun-
dated the tanks and tank vent lines.
The 30-foot water column exerted a
(lending credence to our belief
that the tank risers were broken
out of the tank-top bungs).
The store was shut down at mid-
night on the day before the storm
made landfall in the early morning
hours of August 29, 2005. The owner
reported that the following inventory
was in the tanks at the time the store
was closed: regular - 5,650 gallons;
premium - 4,000 gallons; diesel -
3,760 gallons. A delivery of 3,000 gal-
lons was made to the regular tank on
the day the store was closed down.
The regular tank was the last to
be removed and with great diffi-
culty, as water infiltration could not
be stopped for quite some time and
the tank had approximately 18
inches of sand in it. The end-cap
weld seams—the entry points for the
persistent water infiltration—were
busted open along the top quadrant
of each end of the tank. (See photo
below.) Once the end caps of the
regualar and premium tanks were
removed, it could be seen that the
tank manufacturer had installed a
vertical brace in the center of each
The regular tank buckled and its end caps ruptured.
8

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December 2005 • LUSTLine Bulletin 51
force of around 15 psi at the top of
the tanks. Was the weight of the
water, combined with the six-foot
burial depth, enough to buckle the
tanks? Apparently not since the
diesel tank was unaffected and was
perfectly cylindrical.
But what caused the premium
and regular tanks to buckle? Since
the tank vent lines were submerged,
water would have entered the tanks.
However, the period of submergence
was apparently not great enough to
fill the tanks with water. Reports
indicate that the storm surge came
inland and then receded within two
to four hours. It could be that enough
water entered the tanks to quickly
bring down the temperature of the
fuel that was in the tanks. As the fuel
cooled, there was a rapid decrease in
volume (due to shrinkage). The
decrease in fuel volume caused a vac-
uum to be applied to the tank interior
since the vent lines were submerged.
The flame arrestors installed on the
vent lines apparently did not allow
enough water to enter the tanks to
compensate for the rapid fuel shrink-
age. This vacuum, combined with the
weight of the water /backfill on top of
the tanks, is apparently what caused
the tank buckling. So why did the
three tanks behave differently?
The diesel tank likely didn't
buckle because no appreciable vac-
uum was applied to the tank and the
temperature of the fuel was probably
cool to begin with. The fuel would
have been at or near ground tempera-
ture as no recent deliveries had been
made to the diesel tank. The premium
tank may have buckled because a vac-
uum was applied to it. Gasoline
undergoes relatively high shrinkage
when it cools, and the premium tank
received a delivery not long before
the store was shut down.
The regular tank buckled
severely and ruptured because a siz-
able great vacuum was generated
within this tank. The store had a high
throughput volume of regular gaso-
line immediately prior to the storm
since everyone was filling up his or
her vehicle in preparation for evacua-
tion. A delivery was made to the reg-
ular tank on the afternoon before the
storm hit. It is likely that this fuel was
quite warm relative to the seawater
that rapidly entered the tank when
the storm surge occurred.
So My Working Theory
Goes Like This...
The regular tank suffered severe
buckling and ruptured, while the
premium only buckled somewhat
and the diesel did not buckle at all
due to the difference in vacuum that
was generated as a result of fuel
shrinkage.
It is also possible that enough of
the backfill material surrounding the
regular and premium tanks was
scoured out during the storm to
allow the buckling to occur. Since the
structural strength of USTs is largely
dependent on the support of the
backfill, any loss of backfill around
these tanks could have allowed the
buckling. However, no evidence of
backfill scouring immediately
around the tanks was observed,
although it would probably have
been difficult to discern since it is
likely that any scour would have
been refilled as the storm surge
receded.
In all likelihood, it was probably
a combination of all these things that
ultimately led to the demise of these
tanks. Hey, what do you think? ¦
Kevin Henderson is with the Missis-
sippi Department of Environmental
Quality. He can be reached at
Kevin_Henderson@deq.state.ms.us.
Two Washington State USTfields Pilots Receive Phoenix Awards
The following Washington USTfields Pilot projects were among the 2005 Phoenix Award winners at the Brownfields Conference in
Denver in November:
¦	SEATTLE - USTfields Piiot funds were used to clean up 100 cubic yards of petroleum-contaminated soil at the former Daley's Dump
Truck Sen/ice site in a rundown and underserved section of Seattle. This helped prepare the site for its reincarnation as the location of
the Dakota, an appealing and much-needed 178-unit affordable, housing development. The development provides not only housing but
also jobs and economic benefits for an area of Seattle in need of both.
¦	ROSALIA - This Community Impact-UST award winner is a shining
example of how the cleanup and reuse of an old gas station can revitalize a
rural area. Rosalia is a town of about 600 people whose leaders and citizens
were determined to clean up an abandoned gas station dating back to 1923
and restore the station building. Funding from the Washington Department
of Ecology, Whitman County, U.S. EPA, and private donors enabled the
town to remove petroleum contamination at the site, work with the State
Historical Preservation Office to restore the old station, and create habitat
for native species. Rosalia now has an attractive regional visitor's center
that provides information about Rosalia and rural Whitman County and
serves as the interpretive center for visitors drawn to the nearby Steptoe
Battlefield, a state park listed on the National Register of Historic Places. The
center helps draw tourism dollars to rural southeastern Washington. ¦
9

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LUSTLine Bulletin 51 • December 2005
A MESSAGE FROM CLIFF ROTHENSTEIN
Director, U.S. EPA Office of Underground Storage Tanks
A Summer To Remember
'II remember the summer of 2005 for a long time; it gave
our country some significant tank-related events that will
keep EPA and state tank programs quite busy for the
coming months and years. On one front, EPA and states
have much work ahead to implement the new underground
storage tanks legislation. And on another, EPA and states
are supporting the Gulf Coast states as they deal with UST
facilities that were in the paths of Hurricanes Katrina and
Rita.
New UST Legislation
Over the last few years, Congress considered various pieces
of UST legislation. But it was not until summer 2005 that
Congress agreed on legislation and sent it to the President.
Consequently, on August 8, 2005, President Bush signed
the Energy Policy Act of 2005. Title XV of this act created the
Underground Storage Tank Compliance Act of 2005, which
sets forth amendments to Subtitle I of the Resource Conser-
vation and Recovery Act—the original legislation that cre-
ated the underground storage tanks program.
This new law significantly affects federal and state tank
programs and will require major changes to our programs.
Additionally, gas station owners and operators, as well as
other nonmarketers who own USTs, will be affected by the
changes EPA and states make to their tank programs.
We've always known that preventing releases is an
essential part of our program. And now with this legisla-
tion's focus on prevention, we will have more tools to make
changes to the tank program that will lead to fewer releases
from UST systems and help us to better protect America's
environment.
Specifically, the new law expands eligible uses of the
Leaking Underground Storage Tank Trust Fund, extends the
Trust Fund tax through 2011, and mandates new measures
to be taken, such as:
¦	Inspecting tanks every three years
¦	Developing operator-training requirements
¦	Prohibiting fuel deliveries at noncompliant UST
facilities
¦	Requiring secondary containment for new and replaced
tanks and piping, or financial responsibility for tank
installers and manufacturers
¦	Cleaning up releases that contain oxygenated fuel
additives
Some of the require-
ments must be in place as
soon as August 2006, with
other requirements effective in subsequent years. EPA has
already reached out to the Environmental Council of
States, the Association of State and Territorial Solid Waste
Management Officials Tanks Subcommittee, and others,
and has developed work groups with broad state, regional,
and tribal participation.
All of us will face enormous challenges to implement
the new provisions of the law. Fortunately, the tank pro-
gram's history has proven that together we can succeed
when we take on new challenges. And I believe that
together and in spite of tight deadlines and limited bud-
gets, we will turn our challenges into new opportunities to
ensure that our nation's land and water are safe from UST
system releases.
Katrina and Rita Are Not Merely Names
Hurricane Katrina devastated America's Gulf Coast in
August by obliterating entire communities; damaging
thousands of homes, some beyond repair; flooding rural,
suburban, and urban areas; and taking the lives of more
than 1,000 people. Weeks later, Hurricane Rita rushed
ashore, further complicating cleanup and delaying citizens'
return to their homes. With the floodwaters receding and
initial devastation assessed, state tank programs are now
focusing on damage to UST facilities.
I applaud the extraordinary efforts of state and EPA
regional tank program staff who are helping in so many
ways—assessing the damage, inspecting affected UST
facilities, evaluating risks from petroleum contamination,
and readying the Gulf Coast's UST facilities to return to
use. Additionally, I am grateful to those states with hurri-
cane and flood experience that have graciously shared
their knowledge in dealing with UST facilities impacted by
severe winds, storm surges, and flood damage. I thank all
of you and sincerely appreciate your personal dedication
and professional accomplishments in dealing with the
aftermath of the devastation from these hurricanes.
The Strength of Our Partnership
States, tribes, local governments, and industry—along
with EPA—have so far done a great job of protecting
America's environment from UST system releases. And I
am certain that our strong partnership will enable us to
succeed in conquering the challenges of summer 2005. ¦
10

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December 2005 • LUSTLine Bulletin 51
Okay, Who's on First?
The UST and LUST Aspects of the Energy Policy Act
by Ellen Frye
Title XV of the Energy Policy Act of2005 created the Underground Storage Tank Compliance Act (USTCA), under Subtitle B,
amending Subtitle I of the Resource Conservation and Recovery Act (RCRA)—the original legislation that created the under-
ground storage tanks program. Although Subtitle B does not touch the technical requirements of Subtitle I, it does substan-
tially change the UST program for both U.S. EPA and the states. And the deadlines? Put on your running shoes and FLY. The clock
started as of August 8,2005, when the Act was signed into law. And the funding? Not bad! Will the states ever see it? Don't know.
While many of the provisions of the Act sharpen the fangs of the nation's UST program, some of the provisions are giving state
programs unadulterated angst. For example, besides some painfully tight deadlines and an uncertain funding prognosis, the Act
seems to suggest that once the new funding regime does kick in, states that do not comply with the UST/LUST requiremen ts
completely will receive no funding. Yikes! So let's review the essence of USTCA.
Mandatory UST System
Inspections
Section 1523 of USTCA establishes a
tiered inspection approach that
requires states to conduct on-site
inspections of all regulated USTs at
three-year intervals. U.S. EPA will
need to provide states with guidance
that establishes "minimum credible"
inspection criteria. For states with
inspection backlogs, an initial two-
year period is provided to conduct
on-site inspections for all facilities not
inspected since December 22, 1998.
States with resource problems may
petition U.S. EPA for an additional
year to complete the first three-year
cycle. U.S. EPA is also required to
conduct a four-year study of compli-
ance assurance programs that could
serve as alternatives to the required
inspection program.
In a November 2005 memo to the
states and EPA regions from EPA
OUST Director Cliff Rothenstein, UST
programs were urged to focus their
inspections on facilities that had USTs
in place on or before December 22,
1998 and that have not been inspected
since that date. The memo explains:
"For inspections conducted in the
period from August 8,2005 to the date
of the publication of our guidance, we
will consider any on-site inspection as
meeting the inspection requirements
as long as the inspection is:
•	conducted by a state, local (when
contracted or delegated by a
state), EPA, or certified third-
party inspector; and
•	sufficient to determine compli-
ance with federal UST require-
ments in Subtitle I or state
requirements that are part of a
state UST program EPA has
approved under the state pro-
gram approval procedures."
Operator Training
Section 1524 gives U.S. EPA two
years to develop operator-training
guidelines, which are to be the basis
of state training programs. The
guidelines must be specific to three
classes of operator personnel respon-
sibilities:
•	Employees having primary
responsibility for on-site opera-
tion and maintenance of UST sys-
tems,
•	Employees having daily on-site
responsibility for the operation
and maintenance of UST sys-
tems, and
•	Daily on-site employees having
primary responsibility for
addressing emergencies pre-
sented by a spill or release from
an UST system.
The guidelines must also take
into account such considerations as:
•	Existing state training programs
•	Training programs already being
employed by tank owners/oper-
ators
•	The high turnover rate of tank
operators and other personnel
•	Improvements in UST equip-
ment technology
•	The nature of the business that
has an UST
•	Training needs for the different
classes of operators
States may receive up to $200,000
to develop and implement the
requirements. States will enforce
compliance with the requirements.
Delivery Prohibition
Section 1527 establishes a prohibition
on deliveries, two years following
enactment, to tanks that are deter-
mined to be ineligible, as defined in
guidance developed by EPA, one
year following enactment, and in
consultation with the states and other
parties. A special category of rural-
and remote-area tanks is eligible for
exemption from the delivery prohibi-
tion under certain circumstances.
Although earlier versions of the bill
included a delivery prohibition roster
or tamper-proof tag, this section does
not. There are provisions for enforce-
ment of the delivery prohibition. U.S.
EPA has one year to issue regulations
or guidelines to implement this sec-
tion. Enforcement of the delivery pro-
hibition will begin in two years.
Compliance
Reports/Strategies
Section 1526 requires states to report
all out-of-compliance USTs owned or
operated by the federal, state, and
local governments. Also required is
an annual public record of regulated
USTs that must include the number,
sources, and causes of releases; the
number of equipment failures; and
the record of compliance within the
state. States may need to establish
active websites for public access.
Section 1529 requires EPA to
develop a strategy for UST compli-
ance and LUST cleanup on tribal
lands and to submit a report to
Congress detailing implementation
progress.	¦ continued on page 12
11

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LUSTLine Bulletin 51 • December 2005
¦ Energy Policy Act from page 11
Secondary Containment
versus Installer/
Manufacturer Financial
Responsibility
Section 1530 provides additional
measures to protect groundwater
resources from petroleum releases.
States must require one of the follow-
ing:
•	Secondary containment of newly
installed underground tanks and
piping within 1,000 feet of an
existing community water sys-
tem, to include the motor fuel
dispenser system (i.e., dispenser
pans) under specified conditions.
•	Certain forms of financial
responsibility for manufacturers
or installers to provide for the
possible costs of corrective
action, and also a form of
installer certification. Manufac-
turers' financial responsibility
does not affect the liability of
owners/operators.
EPA must issue guidance or reg-
ulations and states must have
requirements in place within 18
months.
Federal Facility Issues
Section 1528 establishes an extensive
management regime for all USTs
owned or operated by the depart-
ments and agencies of the federal gov-
ernment, requiring that they comply
with all federal, state, interstate, and
local requirements, and explicitly
waives federal sovereign immunity
from such requirements. The only
exception is a specific Presidential
waiver in the paramount interests of
the United States. There is also a fed-
eral reporting requirement somewhat
more extensive than that required of
state governments under Section 1526.
And, of Course, the
Resources
The Act dramatically expands the use
of funds previously reserved for
cleaning up leaking underground
fuel tanks, in order to meet new
requirements to both prevent and
remediate tank leaks. Trust Fund
monies will also be able to be used
for compliance activities, as the focus
will shift over the next few years
from cleanup to prevention. Con-
gress authorized $605,000,000 annu-
ally. The appropriations, which
would come from five pots of money,
cover a number of different activities.
(See Table 1.) When or whether Con-
gress will actually appropriate the
funding is the huge unknown.
Section 1522 amends Subtitle I of
RCRA to require statutory distribu-
tion of 80 percent of LUST appropria-
tions to states. States may use these
funds to conduct corrective actions,
administer state assurance funds, or
carry out enforcement. Allocation of
funds to states will require a coopera-
tive agreement with EPA. EPA may
not distribute these funds for certain
purposes to any state that has
diverted funds from a state fund or
state assurance program for uses not
related to USTs after the date of
enactment.
The allocation process may be
adjusted, but only after consultation
with state LUST programs and taking
into consideration specified criteria.
A provision allows separate with-
drawal of approval for any state fund
or assurance program for cause with-
out withdrawing approval of the
state UST program. Also, there is a
description of the process for cost
recovery, which requires extensive
analysis of the owner/operator's
ability to pay. The Act expands the
permissible uses of LUST Trust Fund
monies to include inspection, en-
forcement for release prevention,
operator training, delivery prohibi-
tion, and federal/tribal tanks.
Section 1525 provides authority
for remediating oxygenated fuel con-
tamination using a specially allocated
LUST fund appropriation. It autho-
rizes up to $1 billion for oxygenated
fuels cleanup for fiscal years 2005-
2009. This is an additional authority
to that already provided to EPA and
states to undertake corrective action
for UST releases. To qualify, an oxy-
genated fuel release must be from a
UST.
Section 1531 authorizes appro-
priation levels between the years
2005 and 2009 that would permit
appropriations of up to $50,000,000
per year for UST management, and a
total of $555,000,000 annually from
LUST funds for the tasks authorized
in the Subtitle from this source. At
this point, this new funding will not
be appropriated for 2005 or 2006. We
won't know what Congress intends
to spend in 2007 until next summer.
Miles to Go...
Meeting USTCA's new requirements
and deadlines depends on swift
action on the part of both U.S. EPA
and the states. The EPA Office of
Underground Storage Tanks is on the
case and is working with the states
through the Association of State and
Territorial Solid Waste Management
Officials to begin the implementa-
tion process. Fourteen work groups
have been formed, composed of rep-
resentatives from state and EPA
regional and headquarters UST/
LUST programs. Go team! ¦
TABLE 1 Authorized USTCA Appropriations (New Subtitle I, Section 9014)
¦ Remediation - Covers administration, enforcement, cleanup.
Funding source: Section 9014(2)(A)
$200,000,000
¦ Oxygenated Fuel Remediation - Determine eligible uses of LUST funds
and oversee cleanup of eligible sites.
Funding source: Section 9014(2)(b)
$200,000,000
¦	Inspections - Develop cooperative agreement guidelines and determine sites to be
inspected.
¦	Additional Measure to Protect Groundwater - Monitor and enforce compliance
with secondary containment or financial responsibility regulations.
Funding source: Section 9014(2)(c) $100,000,000
¦	Operator Training - Develop guidelines on training for UST operators.
¦	Delivery Prohibition - Develop enforcement guidance.
¦	Compliance Enforcement-Conducting inspections, issuing orders,
bringing action.
Funding source: Section 9014(2)(d)
$55,000,000
¦ General Implementation - Covers implementation of Subtitle I
not covered by LUST Trust funding.
Funding source: Section 9014(1)
$50,000,000
Total Potential Funding
$605,000,000
12

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December 2005 • LUSTLine Bulletin 51
/

¥
A roving column by reporter Patricia Ellis, a hydrologist with the
Delaware Department of Natural Resources and Environmental
Control, Tank Management Branch. Pat served as a member of
U.S. EPA's Blue Ribbon Panel on MtBE. She welcomes your
comments and suggestions and can be reached at
Patricia. Ellis@state. de. us.
LUST and Fuel
Ethanol and Motor Fuels Aspects of the Energy Policy Act of 2005
To the disappointment of many of us in state tanks programs, the Energy Policy Act of2005, signed by President Bush on
August 8, does not ban MtBE, nor does it clarify U.S. EPA or state authority to ban MtBE or other fuel additives. To the dis-
appointment of many petroleum refiners and marketers, the Act does not provide MtBE or renewable-fuel product-liability
waivers, nor does it provide transition assistance to MtBE manufacturers to convert MtBE-production facilities into other uses. So
let's see what the Act does do regarding the composition of gasoline. Let's consider the aspects of the Act that those of us in federal and
state LUST regulatory programs will need to be concerned with when there is a release from a fuel storage tank.
Air Quality-Related
Provisions
In Title XV, Subtitle A of the Energy
Policy Act, Congress eliminated the 2
percent by weight oxygen content
requirement for federal reformulated
gasoline (RFG). This provision takes
effect 270 days after signing of the
Act, unless a state already has a
waiver, in which case the provision
took effect the day the Act was
signed. (As far as I know, no states
have been granted waivers from the
oxygenate requirement if they are
required to use RFG. California, New
York, and Connecticut all had their
requests for a waiver from the oxy-
genate mandate turned down earlier
this year.)
However, while lifting the
requirement for use of oxygenates in
RFG, the Act requires that the total
pool of gasoline sold in the United
States contain increasing volumes of
renewables (e.g., ethanol), a volume
that starts in 2006 at 4 billion gallons
and grows to 7.5 billion gallons by
the year 2012. In 2004, approximately
3.5 billion gallons of ethanol were
being used in gasoline.
Each gallon of cellulosic biomass
is considered equivalent to 2.5 gal-
lons of renewable fuel for purposes
of the renewable fuel standard.
Increasing amounts of cellulosic bio-
mass ethanol must be used after 2013.
The Act provides incentives and
loans for construction of facilities that
can produce cellulosic biomass fuels
and for research on cellulosic bio-
mass fuels.
The Act allows for any area
within the ozone transport region to
opt into the RFG program, whether
or not the area is an ozone nonattain-
ment area. A governor would need to
petition U.S. EPA. The agency would
need to act on the petition within 180
days, and the program would be put
in place as soon as practicable, but
not later than two years after the date
of the approval.
The Act calls for the maintenance
of toxics air pollutant emission reduc-
tions resulting from RFG. To do this,
EPA is required to establish stan-
dards for air toxics reductions for
each refinery and importer based on
historical average annual emissions
from calendar years 2001 and 2002.
This provision is designed to elimi-
nate backsliding on gains made in
toxics reductions by the RFG pro-
gram when the oxygen mandate is
eliminated.
Health Effects of Substitutes
The Act requires U.S. EPA to conduct
a study of public health and environ-
mental (multimedia) impacts of the
increased use of MtBE substitutes
such as EtBE, TAME, DIPE, TBA,
ethanol, isooctane, and alkylates. It
would be nice to have health data for
these chemicals, but it's beyond my
understanding why anyone would
want to substitute any of the other
ethers for MtBE, when most of them
have taste and odor characteristics
similar to those of MtBE. If they
ended up in your drinking water,
you probably wouldn't be happy,
and their chemical properties would
make them nearly as difficult to
remediate as MtBE.
From the information made
available to the states, we don't even
have good public health data avail-
able for MtBE. Where is the EPA
¦ continued on page 14
13

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LUSTLine Bulletin 51 • December 2005
¦ LUST and Fuel Harmony
from page 23
draft risk assessment that promotes
MtBE from a likely animal carcino-
gen and possible human carcinogen
to a "likely" human carcinogen? Evi-
dently this document was written
more than a year ago and has been
circulating around EPA since then.
Rumor has it that the document has
been shelved. Possibly, it may return
from hyperspace when the winds
shift at some point in the future.
According to a news release by
the Environmental Working Group
(.http://www.ewg.org/issues/mtbe/20050
711/ index.php), the U.S. EPA Office of
Research and Development's
National Center for Environmental
Assessment has already approved
the risk assessment. When internal
review is completed, it still has to go
through the external review process.
This document was requested during
the congressional hearings on the
energy bill, but I don't believe it was
provided to Congress.
EPA is required to publish a
study within four years analyzing
changes in air emissions resulting
from the implementation of the pro-
visions in the Act, and must develop
a fuels model that reflects the effects
of gasoline characteristics on emis-
sions from vehicles in the calendar
year 2007.
The study must also estimate the
impact of blending increasing
amounts of ethanol into gasoline on
total evaporative emissions. Evi-
dently the study need not include
potential permeation effects of
ethanol through elastomeric materi-
als (rubber and plastic parts) that
make up the fuel and fuel vapor sys-
tems of a motor vehicle, despite the
fact that permeation may make a sig-
nificant contribution to emissions
from vehicles.
Permeation may also contribute
to releases from UST systems. Are
those of us in the tank program con-
vinced that every tank currently stor-
ing gasoline can safely store gasoline
that contains ethanol? Will every
owner and operator know whether all
plastic and rubber parts in his or her
system are compatible with ethanol?
What about the older fiberglass
tanks? What about scaling on the
inside of steel tanks from ethanol use?
The New England Interstate
Water Pollution Control Commission
and Northeast States for Coordinated
Air Use Management published a
three-volume report in 2001 entitled
the Health, Environmental, and Eco-
nomic Impacts of Adding Ethanol to
Gasoline in the Northeast States, which
addresses these and other important
concerns about increased usage of
ethanol in gasoline. Any other poten-
tial changes to the composition of
fuels need to be addressed in a simi-
lar manner—before, not after—the
fact. (The report is available at
http://www.nescaum.org/resources/
reports/ethanol/index.html.)
Fuel System Harmonization
Study
U.S. EPA and the Department of
Energy (DOE) are required to con-
duct a study of federal, state, and
local requirements concerning motor
vehicle fuels. The Fuel System
Requirements Harmonization Study
will contain recommendations for
legislative and administrative actions
for motor vehicle fuels to improve air
quality, reduce cost, and increase
supply liquidity.
The study will assess the effects
of a variety of fuel requirements on
supply, quality, and price; the effects
on achievement of air-quality stan-
dards and goals, and related environ-
mental and public health protection
standards and goals; the effects on
domestic refiners, the fuel distribu-
tion system, and industry investment
in new capacity; the effects on emis-
sions from vehicles, refiners, and fuel
haulers; the feasibility of providing
incentives to promote cleaner-burn-
ing fuels; and the extent to which air-
quality impacts and fuel prices can be
projected to result from Tier II vehicle
and fuel standards. The study and
recommendations are to be submit-
ted to Congress by June 1,2008.
The legislation requires EPA and
DOE to consult with governors,
automakers, state and local air pollu-
tion regulatory agencies, public
health experts, fuel producers and
distributors, and the public.
Wait a minute! Have we forgot-
ten about water-quality issues again,
as we did when the Clean Air Act
Amendments required the use of
oxygenates in RFG, thereby launch-
ing the MtBE problem? If we're going
to be messing around with fuel com-
position again, could we also involve
some water-quality people in the dis-
cussion so we don't have another
MtBE debacle? The group that EPA
and DOE consults with should also
include individuals who are knowl-
edgeable about how potential new
gasoline components will behave in
the environment. Or will it be, as
Yogi Bera said, deja vu all over again?
Additional fuel harmonization
legislation has been bandied about in
the House and Senate but hasn't
taken off. The bottom line is that dis-
cussion over fuel content may well
not be over.
Boutique Fuels
Subtitle C of Title XV addresses bou-
tique fuels. The Act requires the EPA
Administrator, in consultation with
the Secretary of Energy, to determine
the total number of fuels approved as
of September 1, 2004, in all state
implementation plans. The list was
required to be published in the Fed-
eral Register by November 6,2005.
There are currently 18 different
base blends of gasoline with 45 differ-
ent fuels. The most recent map of
"U.S. Gasoline Requirements,"
updated by K.W. Gardner of Exxon-
Mobil in June 2004, indicates that 17
different gasoline "varieties" are in
use in the United States. They include:
•	RFG - North
•	RFG - South
•	Oxygenated fuels
•	CACBG
•	RFG/CA CBG
•	AZ/CBG
•	Oxy fuels/7.8 RVP
•	Oxy fuels/7.0 RVP
•	Conventional gasoline
•	RFG with ethanol
•	NV CBG
•	7.2 RVP
•	7.0 RVP
•	7.8 RVP MTBE -no increase
•	7.8 RVP
•	7.0 RVP 30 ppm S
•	300 ppm S
Multiply these by three different
octane ratings, by summer and win-
ter variations, by low- and high-alti-
tude variation, by northern and
southern blends, and you've got a
real mess! Several of these blends are
used only in a small area of the coun-
try, or, if used in several areas, the
areas of usage are noncontiguous!
14

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December 2005 • LUSTLine Bulletin 51
The Act limits the number of
boutique fuels that states and locali-
ties can require. EPA is not allowed
to approve a state implementation
plan that will increase the total num-
ber of boutique fuels beyond the
number approved by September 1,
2004. If a previously approved fuel is
dropped from the list, another fuel
can take its place. States or regions
can adopt a fuel standard that is
already in place elsewhere.
EPA and DOE are required to
conduct a joint study that focuses on
determining how to develop a fed-
eral fuels system that maximizes
motor fuel fungibility and supply,
addresses air-quality requirements,
and reduces fuel price volatility. The
study must include recommenda-
tions to Congress for legislative
changes necessary to implement such
a system. Results of the study must
be presented to Congress not later
than 12 months after the date of
enactment of the Act.
What will RFG look like if new
legislation passes and the Federal
Fuels List contains only one variety
of RFG? Will it contain an ether, such
as MtBE or ethanol, or will it be like
California Cleaner-Burning Gasoline
(CA CBG)? This would depend on
how RFG is specified on the list.
Would RFG be defined by an allow-
able "recipe" or by a performance
standard?
What will conventional gasoline
look like if only one version is
allowed? Somehow, a tremendous
amount of ethanol needs to be incor-
porated into the fuel mixture within
the next few years. In which gasoline
variety will it be included? With the
high vapor pressure of ethanol, there
probably wouldn't be large amounts
of it specified for the RVP-controlled
gasolines.
Rather than dictating specific
ingredients and recipes for motor
fuels, the federal government should
limit its role to setting environmental
end goals for fuels. One of the recom-
mendations of the U.S. EPA Blue Rib-
bon Panel was that any changes in
gasoline composition should be
designed so as not to result in an
increase in MtBE use in conventional
gasoline areas. One benefit of estab-
lishing performance standards for
gasoline rather than dictating a recipe
would be added flexibility for gaso-
line production and distribution.
What About the Lawsuits?
How many MtBE producers or gaso-
line refiners plan to stop adding it to
gasoline because the Energy Policy
Act does not provide a safe harbor
against lawsuits? I don't think that
we have an answer to that yet.
We In the tank program need to be
aware of what is in our fuel supply,
so we can research issues that may
have an effect on tank systems, and
so we know whether anything needs
to be done differently during
investigations and cleanups.
How long was MtBE used in our
gasoline before the states
started to catch on?
Earlier drafts of the energy bill
included statements to the effect that
MtBE stinks, tastes bad, and contami-
nates water supplies—therefore let's
ban it! Yet the signed version of the
bill simply states that claims and
legal actions filed after the date of
enactment related to allegations
involving actual or threatened conta-
mination of MtBE may be removed to
the appropriate United States district
court.
This leaves the many lawsuits
filed by the State of New Hampshire
against a multitude of petroleum
companies last year as the only suits
that will definitely continue in state
courts. It is generally thought that
state courts tend to be more generous
with damage awards.
What About Groundwater
Cleanup?
Does the Act provide any type of
funding for dealing with impacted
water supplies? On one of my pro-
jects, I'm in the final stages of extend-
ing an existing water main into a
neighborhood where numerous
domestic wells were impacted by a
gasoline release. The source of the
release is a gas station that is eligible
for reimbursement under our state
program.
The cost of extending the line is
more than $500,000. Close to $250,000
was spent providing carbon filters
and sampling domestic wells during
the initial release investigation, and
until the water line extension could
be completed. About $400,000 has
been spent on investigating the 1,600-
foot-long plume, which extends at
least 75 feet into the unconfined
aquifer, and some additional plume
delineation is still needed. I've
approved a corrective-action plan for
one area of the plume, and the con-
sultant is working on plans for other
areas. The eventual cleanup cost is
unknown.
Our state reimbursement pro-
gram has a total of $1 million that we
can reimburse in one year, for all the
sites that are still eligible for reim-
bursement. Where does this site fall
in the money "promised" by Con-
gress? (See article on page 11.)
There's no recalcitrant responsible
party (RP), no poverty-stricken RP.
We have an RP, but the site is eligible
for reimbursement under our state
program.
Can any of the money go toward
supplementing state reimbursement
programs to cover the extra expense
required for oxygenated fuel
releases? In most states, tank own-
ers/ operators use either insurance or
a state fund as their mechanism for
financial responsibility. I'm sure that
many state funds have been hard hit
by increased investigation and
cleanup costs because of MtBE
releases.
The Act does indicate that the
oxygenated fuels funding requires
that the release of oxygenated fuel
must be from an UST. Did the Act
provide any funding to help deal
with sites with MtBE impacts, but for
which a source has not been identi-
fied (yet), or may never be identified?
If any of this funding is ever eventu-
ally appropriated, there needs to be
flexibility in how it can be spent.
Additional funding will certainly
be welcome.. .no, actually, it will be
essential, if Congress expects these
requirements to be met. The funding
that Congress has authorized for
appropriation must actually be
appropriated.
We in the tank program need to
be aware of what is in our fuel sup-
ply, so we can research issues that
may have an effect on tank systems,
and so we know whether anything
¦ continued on page 20
15

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LUSTLine Bulletin 51 • December 2005
The Case for Multicomponent
Analysis of Gasoline

by James Weaver
As we all know, leaking un-
derground storage tank
problems begin with a
release from a storage system and a
fuel. The fuel contains chemicals
that can be delivered to groundwa-
ter and soil gas. Since humans aren't
particularly good detectors of low
levels of specific chemicals in food,
water, or air, we can easily expose
ourselves to unknown hazards. In
the case of a leaking underground
storage tank, there is the potential
that we could be exposed to many
of the chemicals composing the fuel.
The importance of evaluating
gasoline composition then comes
from its obvious role as a source of
contamination to aquifers and soil
gas. I can think of six specific rea-
sons for the study of gasoline from a
LUST perspective:
•	Without an evaluation of all
components of gasoline, we can-
not be sure we are adequately
protecting against harmful sub-
stances.
•	Detailed characterization of
gasolines provides a means to
predict the types of potential
impacts that may occur. The
need to predict results follows
from the very nature of LUSTs:
releases occur unseen and unde-
tected for years in many cases. It
is clearly impossible to go back
in time and measure the compo-
sition of a leaked fuel, but
knowledge of composition is
needed to model or estimate the
risks associated with a release.
•	The loading of all components
of a gasoline to an aquifer can
impact remedial technologies,
because it's not just BTEX and
MtBE that enter a treatment sys-
tem.
•	Biodegradation is generally
acknowledged to be electron-
acceptor limited. Thus, the pool
of electron acceptors is available
only for a finite mass of contam-
inants at most sites. The loading
of all chemicals in a gasoline
contributes to usage of electron
acceptors and needs to be consid-
ered.
•	As shifts are made away from
MtBE and toward ethanol in
gasoline, other changes in gaso-
line composition will occur. This
might result in differing levels of
various other contaminants in
soil gas or groundwater. Knowl-
edge of shifts in composition can
give decision-makers the ability
to predict potential impacts.
•	Multicomponent analysis may be
useful for distinguishing among
different gasolines as part of an
environmental forensics investi-
gation. (See LUSTLine #49, "Envi-
ronmental Forensics: Chemical
Fingerprinting Gasoline and
Diesel Fuel at LUST Sites.")
To serve these ends, the U.S. EPA
Office of Research and Development
(ORD) has been studying gasoline
composition by organizing volunteer
samplers from around the United
States and generating detailed hydro-
carbon analyses of around 300 chemi-
cals, and by reviewing industry data
collected by Northrop Grumman
Mission Systems in Bartlesville, Okla-
homa. What factors have we learned
influence fuel composition? The short
answer is that regulatory require-
ments, octane needs, vapor pressure,
and performance requirements are
the major drivers.
Regulation, Benzene,
Oxygenates, and the Clean
Air Act
Federal and state regulations have a
major impact on gasoline composi-
tion, particularly on benzene and
oxygenate content. The Clean Air Act
Amendments of 1990 (40 CFR Part
80) mandated changes in gasoline
composition to improve air quality.
The amendments required that refor-
mulated gasoline (RFG) be sold in
major metropolitan areas and others
with the worst summertime ozone
levels. (This requirement will now be
eliminated by May 2006 due to the
passage of the Energy Policy Act of
2005.) The amendments also pre-
vented conventional gasoline sold in
the rest of the country from becoming
more polluting than it was in 1990.
The RFG requirements for ben-
zene and oxygen content can be
achieved on a per-gallon or average
basis. These have slightly different
standards. Those that were in force
since 1995 are shown in Table 1. If the
requirement is met on a per-gallon
basis, the oxygen content must be
greater than 2.0 percent by weight
and benzene must be less than 1.0
percent by volume. Where the
requirement is met, on average, a gal-
lon of gasoline could contain up to
1.3 percent benzene by volume and
as little as 1.5 percent oxygen by
weight, while still meeting the aver-
age standards of greater than 2.1 per-
cent by weight oxygen and less than
0.95 percent by volume of benzene.
(See Table 1.)
The Clean Air Act contains an
anti-dumping provision to prevent
compounds (e.g., benzene) limited in
one area from moving to areas where
they are not limited. The anti-dump-
ing provision of the Clean Air Act is
complicated, as it is based on the
fuels that were produced or imported
in 1990. Producers or importers
determine a baseline derived from
their 1990 production/importation. If
they were not in business in 1990 or if
they meet other requirements, their
baseline is set to the baseline for
"complex model" emissions. Under
this standard, the average benzene
concentration is 1.60 percent by vol-
ume. In areas using conventional
gasoline, the benzene content may
vary due to various refiner/importer
baselines. Recent EPA surveys (John
Weihrauch, U.S. EPA, Office of
Transportation and Air Quality, 2005,
personal communication) indicate
benzene levels as high at 5 percent,
by volume, in some samples,
although most samples are below
that level.
The winter oxygenate program is
implemented by the states to control
16

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December 2005 • LUSTLine Bulletin 51
FIGURE 1. The relationship between oxygen and benzene
content in samples from the US EPA gasoline study
(Weaver et a I., 2005)
TABLE 1 Clean Air Act standards for
reformulated gasoline (40 CFR, Part 80.)
COMPONENT
PER GALLON
AVERAGE BASIS
STANDARD
PER-GALL0N LIMITS
Oxygen
>2.0% wt
>2.1% wt
>1.5% wt
Benzene
<1.0% vol
<0.95% vol
<1.30% vol
3
A A
C3
O
2
H—<
C
Oo
CD
H—<
c
o
O
c
CD
O) -i
s?
o
0
0
3
Benzene (wt %)
~ Conventional
O Reformulated
A Winter Oxygenate
carbon monoxide pollution—an oxy-
genate is added to gasoline to cause
the fuel to burn cleaner. Under this
program, there is not a requirement
to reduce benzene as there is for
reformulated gasoline. Thus, we find
fuels with oxygenates and high ben-
zene concentrations.
Many of the greatest differences
among gasolines are driven by regu-
latory requirements for benzene, oxy-
genates, and ethers. Figure 1 is a
scatter plot of oxygen content from
all oxygenates versus benzene con-
tent. Samples of RFG (circles) had
benzene contents of less than 1 per-
cent by weight, as is required. Most
conventional gasolines had low oxy-
gen and benzene contents—between
0.5 and 2.75 percent. Some conven-
tional gasolines had oxygen contents
between 0.5 and 1.0 percent. These
were all premium gasolines from
Georgia, and the oxygen (MtBE) in
the gasoline was likely used just for
octane enhancement.
MtBE and/or other oxygenate
bans are now in place in about 20
states. Several of these states were
included in our study (New York,
Colorado, California, Illinois) and we
found that oxygenate requirements
were being met through the use of
ethanol.
Octane
When crude oils are distilled in the
first stage of refining, gasoline is one
of the products. Because crude oil
does not produce sufficient amounts
of straight-run gasoline and the
octane rating of this gasoline is too
low for modern automobiles, addi-
tional processes are used to produce
more gasoline and higher octane rat-
ings. These processes include catalytic
cracking, reformulating, isomeriza-
tion, and alkylation. Our gasoline
composition study has found that
major component differences
between premium and regular gaso-
lines are usually related to increases
in toluene, oxygenates, and alkylation
products in pre-
mium fuels.
Alkylation
is used to pro-
duce branched
alkanes called
isoparaffins that
boost the octane
rating of gaso-
line. Ironically,
octane, being a
straight-chain
organic, lowers
the octane rat-
ing, while its
highly branched
isomers boost
octane. These
isomers are
2,2,4-trimethyl-
pentane, 2,2,3-
trimethylpen-
tane, and 2,3,4-trimethlypentane.
Since the octane number is also
boosted by oxygenates, they are often
used for this purpose, even in the
absence of an oxygenate require-
ment. We found this to be the case in
gasoline from Georgia and other
southeastern states. Observations like
this showed that regular and pre-
mium and conventional and refor-
mulated gasolines could be reliably
differentiated by their composition
(Weaver et al., 2005).
However, forensic differentiation
among fuels may be limited by such
factors as the changing composition
of fuel delivered to tanks, releases of
premium and regular from the same
station, the supplying of differently
branded gas stations by the same
refiners, and trading of gasoline
among suppliers.
Historical Analysis
Our current data represent contem-
porary gasolines, but fuel from prior
releases is likely to have had a differ-
ent composition. To address this, we
are using industry data that date
back to the 1930s. The Northrop-
Grumman Mission is the successor to
prior organizations that collected
these data, and is the current source
for the data. The data collected in
their surveys has varied over the
years, but it now contains results for
benzene and the oxygenates. From
these we will be able to see the
changes that have occurred in gaso-
line for about 170 locations in the
United States.
Figure 2 shows benzene concen-
trations measured over four years for
Atlanta. Earlier data show generally
higher benzene concentrations than
in later years. Both winter and sum-
mer data show roughly the same con-
centrations. MtBE data for the same
time period (Figure 3) show higher
MtBE concentrations in Atlanta pre-
mium gasoline than in mid-grade
and regular, and sometimes higher
MtBE concentrations in winter than
in summer. When filled in with prior
years, these data will form the basis
of estimates of composition over the
past 30 years.
Environmental Impacts
Figure 4 shows the estimated water
solubilitiesof the most prevalent com-
¦ continued on page 18
17

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LUSTLine Bulletin 51 • December 2005
FIGURE 2. Plot of "Bartlesville" benzene data for the years 1990/1991,
1994/1995, 1998/1999 and 2001/2002.
C

4k 3 RfegJsr 67
¦ VV Retjuh* - 87
S Medwm - 09
W Medf-nt -
S P>etTuflJi S2 -93
Vv PrefMutTi yj¦ '+.
- S JrwiTrerentatecl
+ V1. Untliflerertletfed
Atlanta
J
k
4r-**
¦ H
A
P
a
li> 5j>
CD tO
oi ^ oi 'ti cr> o-i> S o o
Date
FIGURE 3. Plot of "Bartlesville" MtBE data for the years 1990/1991, 1994/1995,
1998/1999 and 2001/2002.
Atlanta
LU
CD
A S Regular - 87
¦ W. Regular - 37
S. Medium - 89
VV Medium - 89
S Premium 92-93
VV. Premium 92-93
- S Undifferentiated
+ W. Undifferentiated
4
K. CO 00 O
CO CO CO CO
IT)  
Date
A D
to
 <7> 
k
Mm.
» Multicomponent Analysis of
Gasoline from page 17
pounds found in a conventional
gasoline, and it is also plotted for a
reformulated gasoline and a reformu-
lated/MtBE-ban gasoline. The con-
centrations of each component differs
among the samples, but the largest
differences occur for the ethers and
alcohols.
Figure 4 also shows that all of
these compounds have predicted sol-
ubilities above 0.1 mg/L. These are
theoretical effective solubilities, so
they represent the maximum concen-
trations that might occur. These con-
stitute the additional loading to the
aquifer beyond that of BTEX and
oxygenates, which could impact
biodegradation of BTEX and other
components and ex-situ treatment
systems such as carbon filtration
units. These impacts occur because of
the limited capacity associated with
each of these processes.
De Minimis Concentrations
There is a small detail evident from
the MtBE concentrations shown on
Figure 4: The estimated MtBE con-
centrations in water for reformulated
gasoline in an MtBE-bari state are
above 10 mg/L. In conventional
gasoline, concentrations are above 50
mg/L, while in reformulated gaso-
line they are above 1,000 mg/L. This
shows that small amounts of MtBE in
gasoline can still dissolve in water.
If the de minimis concentration is
0.5 percent (wt), there would be
roughly 743 grams of MtBE per gal-
lon of gasoline (compared with 11%
(wt) MtBE in gasoline with 18,670
grams per gallon). Thus, although
there is a reduction of MtBE content
by a factor of 25, there is still enough
MtBE in the gasoline to equilibrate
with water on the order of 10 mg/L.
Contaminant plumes associated
with three premium gasolines are
shown in Figure 5. These plumes
were generated with U.S. EPA's
Flydrocarbon Spill Screening Model,
which includes simulation of the
flow of the gasoline and its emplace-
ment in the aquifer, followed by
aquifer transport (Weaver et al., 1994,
EPA/600/R-94/039a.). The simula-
tions differ only by MtBE content in
the source gasoline.
The most notable fact about these
results is that the extent and area of
the plumes is only slightly less for the
MtBE-ban RFG of New York com-
pared to the Georgia premium with
MtBE for octane enhancement
(4.89%) and Virginia RFG with MtBE
(13.13%). This follows from the basic
principles of contaminant transport:
the advective term of the equation
doesn't depend on the concentration.
So, either a high-ground water
velocity will generate similar-sized
plumes in any of these cases, or a low-
groundwater velocity will not spread
the MtBE much in any case. The con-
centrations, however, are much less
for the low-MtBE gasoline. Thus, the
impact may be below a reasonable
level, given the standards set for
groundwater.
Additives
Our work still has not addressed the
third major category of compounds
18

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December 2005 • LUSTLine Bulletin 51
FIGURE 4. Comparison of estimated water solubilities of regular low-eleva-
tion gasolines. Includes most prevalent compounds in conventional gasoline
plus ethanol.
Regular. Low Elevation Gasolines
100000
s
E
5
¦ Convention#
a Reformulated
~ Reformulated. MTBE ban
I? I l l; H
— *r c »- t— — „¦
5
FIGURE 5. Contaminant plumes generated from premium gasolines with
0.28% (NY) MtBE, 4.89% (GA) MtBE and 13.13% (VA) MtBE, respectively.
Contaminant Plume
d) 600
to 200
NY Premium (0.28 % MTBE)
> -400
0 000001
¦	0.00001
-0.0001
¦0.001
•0.01
¦	0.02
¦0.1
»1
•10
200 400 600 800 1,000 1,200 1,400 1,600 1,800
Longitudinal Distance (ft)
Contaminant Plume
IJ.UUUUU1
a. 00001
?> 600
u ouoi
 200
0)
« -200
GA Premium (4.89% MTBE)

> -400
w
C -600
C5
200 400 600 300 1,000 1,200 1,400 1,600 1,800
Longitudinal Distance (ft)
Contaminant Plume
<5 400
« 200
VA Premium (13.13% MTBFi
C -600
•0.000001
-0.00001
0.0001
¦ 0.001
¦0.01
-0.02
•0.1
•1
-10
-100
200 400 600 800 1,000 1,200 1,400 1,600 1,600
Longitudinal Distance (ft)
in gasoline—additives. These com-
pounds are added for a variety of
purposes and are largely proprietary.
One of our next steps in evaluating
gasoline is to use publicly identified
additives in simulation models to
evaluate the potential impact of these
compounds.
What's on Our Radar Screen?
Tracking the composition of gasoline
reveals many aspects of LUST prob-
lems and can benefit the program by
providing an understanding of one
main driver of the problems: What
compounds are we concerned with at
a given site? From time to time,
"new" problems emerge for the tanks
program, and sometimes these new
problems aren't so new, but a prod-
uct of incomplete treatment of our
old problems. In the mid-1990s, was
MtBE a new problem (when it had
been approved for use since 1979), or
was it simply not on our radar
screen? Are lead scavengers a new
problem, or are they the result of the
lack of consideration of the composi-
tion of older gasolines? What's next?
Jim Weaver is a hydrologist at the U.S.
EPA Office of Research and Develop-
ment in Athens, Georgia. He can be
reached at weaver.jim@epa.gov.
Jim gratefully acknowledges the volun-
teers who collected samples for the
ORD gasoline composition study
(see the listing in
http://www.epa. gov/athens/
publications/ downloadable.htmlj
and Lourdes Prieto and
JoAnn Action of EPA.
Disclaimer
Although this work was reviewed by U.S. EPA and
approved for presentation, it may not necessarily
reflect official agency policy. Mention of trade names
or commercial products does not constitute endorse-
ment or recommendation for use.
[Editor's note: The online version of
LUSTLine #51 at www.neiwpcc.org
contains color versions of the figures in
this article.]
19

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LUSTLine Bulletin 51 • December 2005
ORD Publishes Report on MtBE Remediation at
LUST Sites
¦ LUST and Fuel Harmony
from page 15
needs to be done differently during
investigations and cleanups. How
long was MtBE used in our gasoline
before the states started to catch on?
MtBE was first used in gasoline
in parts of the United States in 1979.
Garrett, Moreau, and Lowry raised
the alarm in 1986 ("MTBE as a
Ground Water Contaminant," 1986,
Proceedings of Petroleum Hydrocarbons
and Organic Chemicals in Ground
Water Conference, NWWA-API,
November 1986). Most states didn't
even start looking at MtBE as a chem-
ical of concern until about 10 years
after that, if not longer, and even then
they didn't necessarily know how or
where to look for it.
We're trying to play catch-up
now with lead scavengers—and
leaded gasoline is long gone. Just
once, it would be nice to be on the
leading edge, helping to prevent a
problem, rather than dealing with
one after it has happened. ¦
Ford and VeraSun to
Cooperate on E-85
Infrastructure
Promotion
Ford Motor Company and Vera-
Sun Energy Corporation
recently announced the forma-
tion of a new partnership designed
to expand the fueling infrastructure
to support flexible-fuel vehicles
capable of running on E-85.
According to Ford, only about 500
fueling stations in the United States
currently offer E-85. The company
said its new initiative with VeraSun
should increase the number of sta-
tions that support flexible-fuel
vehicles capable of running on E-
85, particularly in the Midwest,
where ethanol availability is grow-
ing. Specifically, the effort will
serve to convert fuel pumps to
VeraSun's branded E-85 (VE85) in
existing fueling facilities. The com-
panies will also launch a consumer-
awareness campaign to promote
the benefits and use of E-85. ¦
U.S. EPA's Office of Research and Development
(ORD) has published Monitored Natural Attenu-
ation of MtBE as a Risk Management Option at
Leaking Underground Storage Tank Sites
(EPA/600/R-04/179). The 88-page report is intended
for UST technical staff in state agencies. It reviews
the current state of knowledge on the transport and
fate of MtBE in groundwater, emphasizing the natural
processes that can be used to manage the risk asso-
ciated with MtBE in groundwater or that contribute to
natural attenuation of MtBE as a remedy. It provides
recommendations on the site-characterization data that are
necessary to manage risk or to evaluate monitored natural
attenuation (MNA) of MtBE, and it illustrates procedures
that can be used to work up data to evaluate risk or assess
MNA at a specific site. The report is available at
http://www.epa.gov/ada/download/reports/600R04179.pdf. A limited number of
hard copies are available through the ORD Library by e-mail at ill.ada@epa.govor
by phone at (580) 435-8505.
On a related subject, an article entitled "Anaerobic Biodegradation of MtBE at a
Gasoline Spill Site" recently appeared in Ground Water Monitoring and Remediation
[25(3):103-115]. (Most of the information in this article is discussed in the ORD
study.) The article describes an MtBE plume at a retail gasoline station in New Jer-
sey where long-term monitoring data indicated that the concentration of MtBE was
slowly declining over time in the wells that were within the footprint of the plume.
The ratio of TBA to MtBE increased with distance from the source area, and the ratio
of TBA to MtBE in individual monitoring wells in the plume increased over time. As
concentrations of MtBE declined in the microcosms, concentration of TBA
increased. The decrease in concentrations of MtBE in the microcosms could be
accounted for by an increase in the concentration of TBA. ¦
List of Known Insurance Providers
for USTs Updated
UST recently revised its publication, List of Known Insurance Providers for
Underground Storage Tanks (EPA/510/B-05/003, September 2005). This booklet
provides UST owners and operators with a list of insurance providers that may be
able to help them comply with financial responsibility requirements by providing
a suitable insurance mechanism. The revised version is available through the
OUST website at http://www.epa. gov/oust/pubs/inslist.htm. ¦
Oil Company to Pay $10.7 Million for UST Violations
A major oil company with 62 stations in San Diego County will spend $10.7 mil-
lion on fines and equipment upgrades under a settlement of UST violations. The
settlement covers approximately 2,200 violations of UST requirements, haz-
ardous waste laws, and an unfair business practice statute. Under the agreement,
the stations are required to provide tamper-resistant underground sensors and
improve maintenance and management practices to prevent a repeat of the viola-
tions. ¦
20

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December 2005 • LUSTLine Bulletin 51
Breaking Up Isn't Hard to Do
A View of NAPL Using Electrical Resistivity Imaging
by Todd Halihan, John Billiard, and Stuart McDonald
Characterizing a site affected by fugitive fuel products from spills, leaks from tanks and lines, or an accidental release (e.g.,
sudden flooding in New Orleans) is a prerequisite to any cleanup project. Assessing the lateral and vertical exten t of
sources and the associated environmental impact is the first step in knowing how to address these issues and to develop an
appropriate project schedule and budget. On most nonaqueous-phase-liquid (NAPL-) -affected sites, drilling programs are the usual
first step in most cleanup programs, closely followed by a best-judgment interpolation between discrete sampling data from soil bor-
ings and wells to create a site-conceptual model.
This industry standard methodology has most often led to the creation of inaccurate site-conceptual models that guide planning
for marginally successful remedial work to remove the NAPL. Frequently, more time and money are required for remediation than
originally predicted, leaving frustrated stakeholders in the wake of the investigation and cleanup efforts.
This article examines some fundamental problems that plague the characterization and cleanup processes, and presents some case
studies of an improved electrical resistivity imaging (ERI) geophysics approach that yielded innovative views of the subsurface at sev-
eral difficult sites. Further, these case studies illuminate a relatively new conceptual model for consideration when characterizing and
remediating sites.
Specifically, when using ERI geophysics followed by drilling to support the results of the image, NAPL sources in these cases are
confirmed to exist as "blobs," not as continuous layers or "plumes" as currently believed by many in the environmental industry.
Finding the full extent of NAPL blobs using only conventional drilling techniques is like trying to round up quiet cattle in a dark
field, where the end result is that most often some will get away. ERI geophysics can help find the NAPL blobs and often finds the
related dissolved-phase impacts, making cleanup strategies more predictable and more reliable.
What's the Problem?
The problem with finding the blobs
stems from the fact that a real-world
site rarely, if ever, resembles the con-
ceptual model of the idealized site. In
the idealized model, NAPL migrates
into both the unsaturated and satu-
rated zones as a cohesive mass, ulti-
mately ending up on top of the
groundwater table as a layer
(Walther et al., 1986). Ultimately, the
NAPL begins to dissolve into
groundwater and migrate based on
groundwater gradient. Simple car-
toons that illustrate the idealized con-
ceptual model are generated to
indicate how the world works
(Schwartz and Zhang, 2003). We call
this the "world we would like" con-
ceptual model.
These cartoons are not consistent
with the "real world," but unfortu-
nately they are commonly used to
form the conceptual model, guiding
the decisions that precede the
cleanup process. The use of a more
sophisticated real-world, site-concep-
tual model has not been practical
until recently when ERI geophysics
provided a tool that allows one to
effectively "see" into the subsurface
in a cost-effective and meaningful
way.
The real-world, site-conceptual
model is complex and was previously
difficult to impossible to derive. To
make matters worse, the NAPL
source itself is a cocktail of hundreds
of compounds that can vary between
refinery locations and seasons of the
year. NAPL can change over time
while stored in tanks and will
undergo changes once it makes its
way into the environment.
The "World We Have" Model
When NAPL enters the subsurface, it
starts migrating in three dimensions
as a NAPL source, a dissolved phase
in the groundwater, and a vapor in
the unsaturated portions of the sub-
surface. NAPL changes character
with time and migrates under vari-
ous retardation and degradation
mechanisms. After some period of
time, NAPL sources end up as dis-
crete blobs that are difficult to find
using conventional characterization
techniques. We call this the "world
we have" conceptual model.
The fact that NAPL is observed
and migrates as blobs is seen in pore-
scale experiments, where NAPL in
groundwater disperses as it migrates
(Conrad et al., 1992). Similarly, on the
basin-wide scale, oil fields are not
continuous, but occur in distinct
patches in a region. This knowledge,
plus the data that the new techniques
our collective research have devel-
oped, is showing us that the world
we get is definitely not continuous
(Halihan et al., 2005a).
Research and technical practice
demonstrate every day that the
"world we would like" conceptual
model is a failed paradigm and that
we collectively need a new "recipe"
in the cookbook for environmental
cleanups. Abandoning idealized con-
ceptual models and embracing the
"world we have" conceptual model
makes sense because we get closer to
understanding the scope of the true
problem, which is the only way an
appropriate and cost-effective solu-
tion can be developed.
In the idealized "world we
would like" paradigm, a project typi-
cally starts with drilling and other
conventional techniques in an
attempt to find and track the NAPL.
This site-characterization work is
conducted by effectively "drilling
blind," and it likely results in unde-
tected NAPL blobs between borings
that act as ongoing sources during
and after active remediation. In the
¦ continued on page 22
21

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LUSTLine Bulletin 51 • December 2005
¦ NAPL Using Imaging
from page 21
"world we have" paradigm, the site-
conceptual model must have field
data that locates the blobs, before
drilling starts. Therefore, follow-up
confirmation drilling is more focused
and effective and can provide a pre-
dictable and successful exit to a
cleanup project.
How About Using
Underground "Photography"
First?
ERI geophysics is a potentially attrac-
tive way to assist in characterizing
NAPL-affected sites and is analogous
to taking a digital electrical "picture"
of the subsurface. Punching holes
with direct-push or auger drilling is
time consuming and provides a lim-
ited one-dimensional sample of the
subsurface at a single point in time.
Assuming wells are installed, main-
tained, and monitored properly, the
question of what is between adjacent
well or boring locations always
remains. Most sites that we have
examined have wells that are
improperly placed, screened in the
wrong location, and/or not in good
communication with the groundwa-
ter system.
ERI geophysics can produce two-
or three-dimensional images (pic-
tures) of the subsurface that provide
a more complete understanding of
the distribution of NAPL and related
contamination. Three-dimensional
images can most easily be generated
on typical sites by coalescing a set of
two-dimensional datasets. The relia-
bility standard to be applied to any
geophysical technique, including ERI
geophysics, is that the resulting
images must be sufficiently accurate
so that they have a direct correlation
to the subsurface—the images should
be "drillable." Without data of this
quality, the cost of geophysical tech-
niques does not justify their use in
many cases.
ERI geophysics has several quali-
ties that make it attractive for shal-
low-site investigations (i.e., less than
500 ft). It works in a wide range of
natural aquifer materials, gives accu-
rate measurements with relative ease,
and produces draft images on-site
within an hour of completing an ERI
geophysical survey. A rapid and
accurate result while on-site is very
attractive, as investigations can be
tailored in real time.
Proprietary research developed
at Oklahoma State University (OSU)
in concert with its commercial part-
ner Aestus, Inc., now allows for very
accurate pictures of the subsurface
that assist in guiding subsequent
drilling investigations or remedia-
tion. In most cases, high-resolution
ERI geophysics (commercially avail-
able as GeoTrax Survey™ via Aestus,
Inc.) can be deployed quickly from
the surface only, and can provide
images at depths within the typical
site needs.
The Research Behind
the Magic
Much of the initial ERI geophysics
research was done through collabora-
tive efforts between OSU, the Okla-
homa Corporation Commission,
Petroleum Storage Tank Division
(PSTD), and Aestus, Inc. On one of
the PSTD sites, OSU developed a
technique to use ERI geophysics in
direct-push boreholes so the site
could be monitored very accurately
over a period of time (Halihan et al.,
2005b). The site had relatively simple
geology and had not yet been reme-
diated at the start of the project.
The results initially appeared
problematic relative to the "world we
would like" site-conceptual model
that the team used going into the pro-
ject. Although the site had a rela-
tively simple geology with clay
overlying a sand aquifer, no continu-
ous NAPL plume was apparent in
the ERI images.
Instead, separate blobs of NAPLs
that correlated with slight variations
in the elevation of the clay/sand
interface were found. There was no
continuous NAPL plume at the
groundwater interface, as expected
using the "world we would like"
conceptual model. After checking the
cables, instruments, methodologies,
and interpretations, OSU conducted
an intensive direct-push coring pro-
gram to confirm the ERI images. The
results of the confirmation-drilling
program were completely inconsis-
tent with the conceptual model of a
continuous NAPL plume.
The site was sampled using the
direct-push method, and some cores
indicated high concentrations of
NAPL in both the sand and the clay
(Figure 1). Other cores indicated high
concentrations of NAPL in just the
clay, and in other areas, just the sand.
In addition, some soil cores were
completely clean within a few feet of
highly contaminated areas.
In other words, moving the bor-
ing location by only a few feet in cer-
tain locations resulted in data that
supported a completely different
FIGURE 1. PID readings of NAPL in dual-tube direct-push cores sampled within 60
feet of each other at a site in Enid, OK. Cores were located using ERI images. Note
that each core provides a different conceptual model for the site, but the cores are
close enough to one another to be considered from a single sample location.
92
91
90
e
| 89
flj
>
_a>
LU
88
87
86
Clean
1513-8.0
-Clay
Sand
- Bedrock
Sand
14131110
Clay
1011-2.5
Both
0311-3.0
1000 2000
1000 2000 0 1000
PID Measurements (ppm)
2000
1000 200C
22

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conceptual model of the site (Figure
1). Therefore, depending on how
lucky (or unlucky) the consultant/
driller was, the site-conceptual model
and hence cleanup strategy would
change drastically. In addition, these
data clearly did not support the
"world we would like" conceptual
model with NAPL in a layer on top of
the groundwater table.
When compared, the ERI geo-
physical image/data matched the
drilled core data (Figure 2). It was
clear the site-conceptual model
needed to change from the "world
we would like" to the "world we
have" paradigm.
After remediation began at the
site, additional ERI geophysical
datasets confirmed the blob configu-
ration (Figure 3). The subsequent ERI
geophysical data indicated the site
was getting dirtier in some areas, not
cleaner. The ERI images suggested
that previously unmapped hydrocar-
bons were entering the site from an
area that was not originally charac-
terized. The "world we would like"
site-conceptual model of a continu-
ous NAPL plume prevented the orig-
inal investigators from looking past
clean location boundaries, since these
edges would have been outside the
area of a continuous NAPL plume.
Since the work performed at the
Enid, Oklahoma site, numerous other
sites have been characterized using
this improved method for ERI geo-
physics with similar results. That is,
the original site-conceptual model
has changed from one that envi-
sioned a continuous NAPL plume, to
one with discontinuous NAPL blobs.
Most of the sites characterized by
ERI geophysics have been subse-
quently characterized using drilling
techniques. In all cases where confir-
mation data are available, the ERI
images were proven to be correct and
the site-conceptual models have
improved to include the discontinu-
ous NAPL blob concept.
What You Don't Know Will
Hurt You
On many of the sites where
improved ERI geophysics has been
used and the results confirmed via
drilling, NAPL blobs have been dis-
covered in areas thought to be clean
or at least devoid of ongoing N APL
¦ continued on page 24
December 2005 • LUSTLine Bulletin 51
FIGURE 2. Three-dimensional ERI geophysics of a site in Enid, OK prior to site reme-
diation in December 2002. Over 50,000 field data points were collected to generate
this image. Image is positioned looking from the southwest towards the northeast.
The northwest corner has no data since no cable was located in this position. Fifteen
subsurface cables with 27 electrodes each were used to obtain the dataset. The
isoshells in red represent the volume of the subsurface that has resistivity above 46
ohm-meters. This is estimated to correspond to the location of free product on the
site. The image was produced using data from OSUin EarthVision in conjunction with
Aestus, Inc. and Hazlett-Kincaid, Inc.
Explanation
Property value units: ohm-m
Unit Surface: black line
Unit Sequence: clay
sand
bedrock
I Monitor wells
Screened interval
Electrode wells
I Recovery wells
Soil zone
Property color key
Active P: p(.3grd)
P Units: unknown
0- >= 50.0
|- 45.0
40.0
-	35.0
30.0
-	25.0
-	20.0
-	15.0
10.0
Z exag:	1.0
Azimuth:	308.44
Inclination:	31.53
X front cut:	0.0
Y	front cut:	0.0
Z front cut:	95.5
X chair cut:	21.2
Y	chair cut:	16.0
Z chair cut:	92.5

estUS J^mgett-Kincaid, !n&

Modeling & VisuaHtuion
FIGURE 3. Three-dimensional ERI geophysics of a site in Enid, OK during site remedi-
ation in August 2003. Image is positioned looking from the southwest towards the
northeast. The northwest corner has no data since no cables were operational in this
position. Thirteen subsurface cables with 27 electrodes each were used to obtain the
dataset. The isoshells in red represent the volume of the subsurface that has resistiv-
ity above 46 ohm-meters. This is estimated to correspond to the location of free prod-
uct on the site. Note the new orientation of resistive "blobs" that has occurred since
remediation began. No significant "blobs" remain within the area enclosed by the
remediation wells. The image was produced using data from OSUin EarthVision in
conjunction with Aestus, Inc. and Hazlett-Kincaid, Inc.
Property color key
Active P: p(.3grd)
P Units: ohm-meters
r FHT >= 500
Explanation
Property value units: ohm-rr
Unit Surface: black line
Unit Sequence: clay
bedrock
| Monitor wells
Screened interval
Electrode wells
I Recovery wells
Soil zone
LZlett-Kincaid. Inc.
Modeling & Visualization
23

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LUSTLine Bulletin 51 • December 2005
¦	NAPL Using Imaging
from page 23
sources. The following case studies
illustrate why what you don't know
will hurt your schedule and your
budget, at the very least.
¦	Golden, Oklahoma
This was a LUST site where char-
acterization was conducted several
times via drilling and direct-push (92
monitoring wells were installed in a
five-acre area), and three separate
remediation technologies were sub-
sequently deployed. Remediation
consisted of standard NAPL removal
via pneumatic pumps, soil-vapor
extraction, and finally the use of an
innovative soil-surfactant flush to
achieve predefined cleanup levels.
Characterization and remediation
were conducted over a 10-year
period. About $1.2 million had been
expended over that period at this
rural site.
ERI geophysics was deployed at
the tail end of this project to evaluate
the effectiveness of the cleanup tech-
nologies. NAPL blobs were detected
outside of the delineated plume at
the site (Halihan et al., 2005a). Staff
from the U.S. EPA Ground Water
and Ecosystems Restoration Research
(GWERD) laboratory in Ada, Okla-
homa used the image produced by
ERI geophysics and conducted their
own drilling program to confirm the
ERI image results. EPA advanced
seven soil borings within a 50-foot
distance along the ERI geophysics
survey line in the area of the NAPL
blobs (Figure 4). Soil samples were
collected about every 6 or 12 inches
along the soil core and analyzed for
total petroleum hydrocarbon (TPH).
EPA's TPH confirmation data
indicated a semi-quantitative correla-
tion between TPH concentration and
ERI resistivity values. The ERI geo-
physics data as well as the borings
also confirmed that NAPL blobs
existed between the site-remediation
wells. Additionally, the highest TPH
value ever measured at this site was
detected using the ERI geophysics
image after all of the characterization
and remediation work had already
occurred. This ERI geophysics field
work was completed in less than one
week.
¦ Hobart, Oklahoma
This site had a significant gaso-
line vapor intrusion into a nearby
State Department of Human Services
building, creating health concerns for
employees. There were no obvious
source sites nearby (e.g., a gas sta-
tion). A consultant had already char-
acterized the site and had not
discovered NAPL sources but did
discover high levels of VOCs in the
vadose zone. Although a shallow
soil-vapor-extraction trench was
installed next to the building, the
vapor intrusion into the building was
not fully mitigated.
ERI geophysics was used to sur-
vey the area around the building
(Figures 5 and 6). The images sug-
gested that the NAPL sources were
slightly deeper than what had previ-
ously been the deepest soil-boring
depth (i.e., greater than 12 feet).
The previous characterization
had been conducted using direct-
push, which encountered refusal
from a hard layer at about 12-feet
deep. A larger auger-type rig was
brought to the site and advanced soil
borings to confirm the ERI geo-
physics image results. In every case
where ERI images indicated the
likely presence of a NAPL blob,
NAPL was discovered in the soil bor-
ing. At the conclusion of the ERI geo-
physics work, a three-dimensional
ERI image was created using a resis-
tivity value roughly equivalent to
NAPL locations at this site (Figure 6).
Note that the NAPL blobs were
all discovered slightly below the 12-
foot depth where the hard layer was
encountered by the direct-push rig.
Also, some of the NAPL blobs were
deeper than the current water table.
As a result of this work, the Okla-
homa Corporation Commission,
PSTD is now considering alternative
methods of source removal.
Designing Better Ways to
Characterize NAPL Sites
The bottom line is that the LUST
cleanup industry needs better tools
and a new "recipe" for characterizing
NAPL-impacted sites. Because
drilling alone does not allow NAPL
sites to be characterized without sig-
nificant unknowns, these unknowns
often manifest themselves as future
liabilities for project stakeholders.
The use of improved characteri-
zation techniques/paradigms will
lead to more accurate site-conceptual
models. Such models will ultimately
yield more realistic and reliable
results during the remediation and
monitoring phases of these projects.
Stakeholders will better understand
the extent (or lack of extent) of envi-
ronmental impacts being addressed
and will ultimately become less frus-
trated. Site remediation will become
more predictable, reducing surprises
FIGURE 4. Electrical image EI-2-NS from Golden, OK site (modified from Halihan et
al., 2005a). A) Vertical lines in image indicate the location of monitoring and remedia-
tion wells. Dotted line indicates area of inset. B) Vertical lines indicate the location of
EPA soil borings used to sample high resistivity anomalies. Notes: Estimated TPH val-
ues are an approximation, and resistive surface anomalies correspond to soil vari-
ability, not hydrocarbon contamination.
South ^	4*

North
20	30
Distance (m)
Estimated TPH (mg kg"')

s s s
Resistivity (ohm-m)
30	35
Distance (m)
24

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December 2005 • LUSTLine Bulletin 51
FIGURE 5. Two-dimensional ERI geophysics of site in Hobart, OK during site charac-
terization. Dotted lines indicate the location of ERI geophysical data lines. Fifty-six
electrodes were used to obtain the dataset along each line. The isoshells in red rep-
resent the approximate location of free product.
and years of monitoring the
unknown.
ERI geophysics has the potential
to be integrated throughout various
phases of the site-cleanup process. As
a first step, ERI geophysics can be
used to direct the drilling for
improved site characterization. Dur-
ing remediation, ERI geophysics can
be used to track the progress of reme-
diation efforts. When NAPL removal
is believed to be complete, ERI geo-
physics can be used to confirm that
the site is devoid of NAPL blobs.
Although this article is focused on
NAPL blobs, it should be noted that
many case studies exist where ERI
geophysics has been successfully
used to semi-quantitatively locate and
track NAPL-related dissolved-phase
contamination in groundwater.
Future Directions
In order to better manage the risks
and uncertainties that surround
LUST and other environmental site
investigations, we believe geophysi-
cal techniques will play a significant
role. More and more evidence sup-
ports the assertion that our current
understanding of contaminant be-
havior in the earth's subsurface is not
very good, largely because our view
of the world to date has been derived
predominately from borings and
monitoring wells.
The consequences of this poor
understanding are far reaching—it
costs more money to characterize a
site and more time to remediate a
site. The impacts may even affect a
project stakeholder's company bal-
ance sheets via environmental liabil-
ity reporting. It is critical that we
have a good understanding of these
sites and a sound site-conceptual
model from the outset. We are confi-
dent that high-resolution geophysical
approaches, tied to confirmation bor-
ings, will become the new standard
in site characterization, as stakehold-
ers demand more certainty and less
risk from their site-remediation
investments.
ERI and other techniques will
evolve toward full three-dimensional
site characterization methods. The
characterization process will require
that data be collected and visualized
in three dimensions or four dimen-
sions (i.e., three-dimensional data
tracked over time) so stakeholders of
all backgrounds can understand the
problems and the potential solutions.
Computing and software
improvements will drive this tech-
nology forward—a process that has
already occurred in the medical field
as CAT scans, MRIs, and X-rays have
become the first ingredients in that
industry's new "recipe" for dealing
with "unknown subsurface prob-
lems" before operating on a patient.
Historically, the progression of
ideas has always evolved from doubt
to argument to acceptance and finally
to a state of obviousness. What is
originally controversial becomes
obvious and other ways of approach-
ing environmental problems become
quaint or "old school." We should
always remember that young tech-
nologies need to be introduced to the
world with a little care, and that
those that become proven will help
us foster the health of the environ-
ment. II
¦ continued on page 37
	! L
East 5th Street
/estus
. ..	Maaehnc.
izlett-Kincaid. Inc.
GeoTm -	4
Car Club Building
FIGURE 6. Three dimensional ERI geophysics of site in Hobart, OK during site char-
acterization. Image is positioned looking from the northeast towards the southwest.
The isoshells in red represent the approximate volume of the subsurface that has
free product on the site. Note the color scale of this figure is slightly different from
Figure 5 to show detail in each view.
HHS Building County Maintenance Building
Property color key
Z exag: 2.0
Azimuth: 128.70
Inclination: 3.26
Faces: 367,685.2926 ft 3
3D Grid: 26,260.28437 ft 3
n^Hazlett-Kincaid, Inc.
Modeling 4 VisuaHtMton
25

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LUSTLine Bulletin 51 • December 2005
Michigan's Noninvasive
1	UST Assessment ©&¥$$£¥
by Dan Yordanich
Since 1999, I've had the task of coordinating the litigation and the development and implementation of an enforcement initiative
for the largest and most important case to date involving Michigan's underground storage tank regulations. The case involved a
non invasive assessmen t methodology based on predicting the leak-free life of a storage tank that could be used to determine
whether an UST was suitable to be upgraded by installing a cathodic-protection system.
As I sit here pondering the task of writing this article, I have to wonder whether other states have experienced similar problems
with these noninvasive assessments. This story is about our odyssey of litigating and enforcing this case and the results of our find-
ings. For many of you, I suppose, our findings will come as no surprise. This is the Michigan story. Draw your own conclusions.
The Alternative-Methods
Route
On December 22,1988, when the fed-
eral 40 CFR Part 280, Underground
Storage Tank; Technical Require-
ments, became effective, many states
followed suit either by adopting the
provisions of the rules or by adopting
the provisions of the rules with state-
specific amendments. In response to
the threat posed by a very large pop-
ulation of existing bare-steel storage
systems, the rules required the
mandatory upgrade of these USTs by
no later than December 22,1998.
To meet the requirements of the
rules, USTs could be upgraded by
internal lining, cathodic protection,
or a combination of both. For bare-
steel USTs being upgraded with
cathodic protection, the integrity of
the tank had to be established by
using one of four methods:
•	The tank is internally inspected
and found to be structurally
sound and free of corrosion
holes;
•	The tank is less than 10 years old
and can be monitored for leaks
using a monthly monitoring
method (not inventory control)
after the application of cathodic
protection;
•	The tank is less than 10 years old
and is assessed for corrosion
holes by undergoing a tightness
test before and three to six
months after the installation of
cathodic protection; or
•	Some other method if approved
by the implementing agency.
This story involves the develop-
ment, use, and approval of a method
of assessment allowed by the fourth
option.
U.S. EPA recognized that alterna-
tive assessment methodologies had
been developed by the cathodic-pro-
tection industry and chose to not
include them at the time the rules
were adopted because an industry-
wide consensus code had not been
established. To be competitive with
the internal-lining industry, the
cathodic-protection industry set
about to develop a consensus code.
In January 1995, an industry-
wide consensus code for alternative
methodologies was established and
published as the American Society
for Testing and Materials (ASTM)
Designation: ES 40-94 Emergency
Standard Practice for Alternative Proce-
dure for the Assessmen t of Buried Steel
Tanks Prior to the Addition of Cathodic
Protection.
This emergency standard inden-
tified three alternative methodologies
for the assessment of buried steel
tanks:
•	a noninvasive method using a
statistical evaluation of site data
to predict corrosion failure (i.e.,
perforation)
•	an invasive method using predic-
tive analytical models in conjunc-
tion with video camera in-
spection
•	a method using robotic devices
equipped for ultrasonic inspec-
tion.
This story is about the first of these
methods.
It is important to note that ASTM
ES 40-94 required that prior to evalu-
ating the suitability of tanks for
upgrading with cathodic protection,
tanks had to be tightness tested by an
approved method to establish that
they were not leaking. According to
the emergency standard, tanks 10
years old or older found to be leak-
free with a probability of corrosion
failure of less than 0.05 could be
upgraded by cathodic protection.
The Michigan Department of
Environmental Quality (MDEQ) was
fortunate to have had a senior-level
engineer serve on ASTM's Subcom-
mittee E50.01 on Storage Tanks who
provided valuable insight regarding
these alternative assessment method-
ologies, and who recommended that
MDEQ not adopt this ASTM emer-
gency standard.
Even though EPA recommended
the use of the methodologies identi-
fied in ASTM ES 40-94, MDEQ did
not adopt this standard because it
believed that the Michigan UST rules
provided adequate authority to the
agency to approve or reject alterna-
tive methodologies. MDEQ was not
convinced that the standard pro-
vided adequate justification for
accepting only the methods
described in the standard, and most
importantly, adopting the standard
would limit the agency's ability to
provide a thorough technical review
of the alternative methodologies
being proposed. MDEQ chose to
review and approve alternative
methods on a case-by-case basis.
Corrosion Processes
Before I proceed, let me interject a
brief description of the corrosion
process, which can proceed in two
distinct ways that have important
consequences on the useful life of a
buried structure. The first of these
two processes is pitting corrosion,
which occurs when anomalies exist
26

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December 2005 • LUSTLine Bulletin 51
¦ &V'-.
J
. »¦
'
	


FIGURE 2. Internal corrosion so severe the tank could not be repaired for
lining. The assessment of this tank predicted uniform corrosion.
in backfill in direct contact with the
buried structure or on the surface of
the structure. Pitting corrosion is the
result of a high rate of corrosion con-
centrated on a small portion of the
surface area of the structure and is
not uniform.
The second process is uniform
corrosion, which occurs when there
are no anomalies in the backfill of the
buried structure or on the surface of
the structure and corrosion occurs
uniformly over the structure's sur-
face. Uniform corrosion occurs as the
result of a very low rate of corrosion.
In general, buried structures are
more likely to be subjected to pitting
corrosion than uniform corrosion.
EPA's Causes of Release from UST
Systems (EPA, 1987) study concluded
that about 50 percent of the corrosion
holes in tanks were plugged and did
not leak, and that approximately 7
percent of USTs 12 to 15 years of age
were leaking. The study also con-
cluded that as many as 7 percent of
existing USTs were corroded through
but not leaking. This may be because
corrosion-induced "rust plugs,"
backfill, and interior sludge seal the
holes (Figure 1). In addition, informa-
tion obtained by EPA from industry
experts indicated that cathodic pro-
tection can cause these "rust plugs"
to loosen, triggering a release soon
after cathodic protection is applied to
the UST.
Approving Alternative
Methods
So, with MDEQ's decision to review
and approve alternative methods on
a case-by-case basis, an international
company that represents a coalition
of cathodic-protection companies
specializing in analyzing corrosion
problems and designing and imple-
menting programs to stop corrosion
on all types of structures enters the
picture. The company sought Michi-
gan's approval to use a noninvasive
technology to assess USTs to deter-
mine their suitability for cathodic-
protection upgrade.
The company indicated that it
had worked closely with a well-
known statistician to develop a non-
invasive assessment methodology
that was (interestingly enough) simi-
lar to the noninvasive assessment
method specified in ASTM ES 40-94.
This methodology used a proprietary
statistical analysis model composed
of many probability measures that
incorporate site-specific information
to predict the expected leak-free life
and present and future probabilities
of corrosion failure for the UST being
investigated.
The method determined, among
other things, the conditional proba-
bility of corrosion failure given pit-
ting corrosion (CPL), the probability
of localized corrosion (an "uncondi-
tional" probability of pitting corro-
sion), and the expected leak-free life
of the tank if pitting corrosion exists.
The company's recommendation for
cathodic-protection upgrade was to
be based on these determinations.
In reviewing the proposed non-
invasive assessment method, MDEQ
recognized that it had merit as an
assessment tool; however, the agency
also recognized that the method did
not allow for the assessment of all
conditions, such as tank-wall thick-
ness, internal corrosion1 (Figure 2), or
structural defects that could lead to
tank failure, or the need to install
striker plates (Figure 3). MDEQ con-
cluded that the method should not be
approved without added conditions.
One of the most important condi-
tions MDEQ placed on the use of this
methodology was that should the
noninvasive assessment of site-spe-
cific information result in a tank
having a CPL in excess of 0.05, the
tank would need to pass an internal
¦ continued on page 28
1 The procedure for noninvasive assessment
described in ASTM ES 40-94 did require the deter-
mination of the presence and extent of internal cor-
rosion, but only immediately below the fill riser.
27

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LUSTLine Bulletin 51 • December 2005
¦ Michigan UST Assessment
from page 27
inspection to ensure its structural
integrity prior to upgrade. MDEQ
did not approve the use of the
"unconditional" probability of local-
ized corrosion. MDEQ reasoned that
if the tanks had no perforations or
leaks when the CPL was determined
to be high (>0.05), then one would
conclude that the "unconditional"
probability of localized corrosion was
very small, and therefore assume that
uniform corrosion was taking place.
MDEQ did not want to make this
assumption.
In July 1995, MDEQ issued condi-
tional approval of this noninvasive
methodology. In its approval, MDEQ
did not make any reference to the
ASTM ES 40-94 standard or any other
standard, since the approval was
based exclusively on the company's
proposal.
It is noteworthy that upon notifi-
cation of MDEQ's conditional ap-
proval of the noninvasive assessment
method, the company did not request
clarification, reconsideration, or mod-
ification of the terminology used or
the conditions imposed by MDEQ.
The Beginning of the End
While the company was not required
to submit noninvasive assessment
reports directly to MDEQ, we
acquired several reports from owners
as part of our regulatory function.
Upon review of these reports, it
became clear that the company was
recommending cathodic-protection
upgrades of tanks that had failed the
CPL and was basing its recommen-
dation on the "unconditional" proba-
bility of pitting corrosion, a part of
the procedure that Michigan had
specifically NOT approved.
Late in 1997, MDEQ notified the
cathodic-protection company that its
conclusions and recommendations
were in direct contradiction with the
conditions on our approval of the
methodology. Negotiations between
the company and MDEQ intensified
as the company tried to convince us
that we did not understand the terms
or the statistical process used in its
method and requested that we
approve the full assessment method-
ology.
MDEQ claimed all along that we
fully understood the terminology
and statistical process used and that
we intentionally sought to limit the
process so that it was, we believed,
no less protective of human health
and the environment than Michigan's
UST regulations required.
Meanwhile, it appears the com-
pany altered its reporting format in a
manner that made it difficult for us to
determine the statistical probability
basis for the recommendation that an
UST was suitable for upgrade. Based
on these reports, USTs continued to
be upgraded.
During the period of negotia-
tions, MDEQ received at least three
reports of tank failure at facilities
where the USTs were assessed and
recommended for cathodic-protec-
tion upgrade, based on the use of this
noninvasive assessment methodol-
ogy. The tanks at two of these facili-
ties were found to be severely pitted
and perforated (Figure 4). The UST at
the third facility had a split weld
seam; however, there was no deter-
mination as to whether the weld
seam failed as a result of corrosion or
some other structural deficiency.
Once extensive negotiations had
failed to yield an agreement and
MDEQ recognized that numerous
existing USTs could present an unac-
ceptable risk to public health and the
environment, MDEQ issued a Janu-
ary 2000 final decision to reaffirm its
original conditional approval and
deny the company's request for
approval to use the full methodology.
Litigation and Due Process
Once MDEQ issued its final decision,
the company appealed. In November
2000, Michigan's circuit court issued
an order affirming MDEQ's decision.
The order was appealed through
Michigan's judicial system until, in
August 2001, the Michigan Supreme
Court denied the company's applica-
tion for leave to appeal.
Late in 2001, the company volun-
tarily provided MDEQ with records
for over 400 facilities in Michigan for
review to determine whether the vio-
lations and the potential risks to pub-
lic health, safety, welfare, and the
environment were of substance
rather than form. After reviewing
these records, MDEQ determined
that USTs in use at approximately
253 facilities had been assessed and
upgraded with cathodic protection
contrary to MDEQ's conditional
approval of the method.
As a result of this review, in July
2002, we provided notice to the own-
ers of these facilities informing them
of our findings and advising them of
the corrective actions they needed to
undertake to bring the affected UST
systems into compliance. While
MDEQ did not establish a deadline
for compliance, a one-year deadline
was conveyed verbally to owners,
industry representatives, and the
court.
In light of the courts' findings
and the realization that they would
be facing potential enforcement
28

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December 2005 • LUSTLine Bulletin 51

FIGURE 4. Perforation in end cap.
[Editor's note: To view more MDEQ photographs of various causes of tank failure,
visit the NEIWPCC website at www.neiwpcc.org.]
actions, such as red-tagging to pro-
hibit delivery of product to substan-
dard USTs, the owners of affected
USTs filed suit against the cathodic-
protection company and MDEQ in
July 2002. Hie suit sought to establish
a class action against the company
and prevent MDEQ from taking
enforcement actions.
In September 2002, the court
denied the motion to prevent MDEQ
from taking enforcement actions and
ordered the parties in litigation to
establish a schedule that would allow
the affected owners to perform the
corrective actions required to return
their USTs to compliance. In Novem-
ber 2002, the court granted the
motion to certify the class of affected
owners.
One of the primary concerns of
the affected class and the court was
that MDEQ would take actions
against the affected parties without
giving adequate notice and the
opportunity to show compliance.
MDEQ was concerned about due
process because of the potential that
the enforcement actions could result
in many separate instances of litiga-
tion.
With these concerns in mind,
MDEQ outlined for the court the
administrative process it would fol-
low in taking action against an owner
of a facility with noncompliant USTs.
The process entailed a series of three
notices, whereby the owner was
given deadlines for bringing USTs
into compliance and an opportunity
to prove, by the submittal of substan-
tiating documentation, that the USTs
were in compliance. In July 2003,
MDEQ initiated the first step in this
administrative enforcement process.
In October 2003, the court
granted and approved a settlement
between the tank owners/operators
and the company. By this settlement,
the owners/operators agreed to fully
and forever release and discharge the
company from any and all claims and
causes of action of every kind, nature,
and description which they, collec-
tively and individually, may have
had, or may now have, or possibly
could have against the company in
return for payment from the com-
pany.
Finally, in December 2003, the
court granted MDEQ's motion to
have the affected class's claim against
MDEQ in the original suit dismissed.
With this dismissal, MDEQ was free
to fully implement the administrative
enforcement process outlined for the
court.
Process Results and Findings
The initiative that was undertaken to
enforce the upgrade requirements of
Michigan's UST rules began with the
identification of 253 facilities and
includes information about 260 facili-
ties. This amounts to approximately
900 USTs that MDEQ determined
were assessed and upgraded with the
installation of cathodic protection in
a manner contrary to MDEQ's condi-
tional approval of the noninvasive
assessment methodology. The data
described here were obtained by
MDEQ as a result of internal inspec-
tions or observations made during
excavation of these USTs at the time
of closure.
Since the beginning of the initia-
tive, MDEQ has achieved a 97 per-
cent facility compliance rate with the
internal inspection and permanent
closure requirements. The remaining
3 percent of noncompliant facilities
have been abandoned or are other-
wise not currently in use, and the
USTs were red-tagged to prohibit
product delivery.
Of the approximately 900 tanks
involved, a total of 340 USTs were
excavated. Of those, MDEQ staff con-
ducted 172 external inspections to
determine the type of corrosion
process that was taking place. Based
on these inspections, pitting corro-
sion was determined to be the opera-
tive corrosion process on 79 percent
of the USTs, and uniform corrosion
was the operative corrosion process
on the remaining 21 percent.
Of the facilities where pitting cor-
rosion was observed to be the opera-
tive process on one or more of the
USTs, MDEQ determined that at 72
percent of these facilities the site con-
ditions did not justify the company's
assumption that uniform corrosion
was the operative corrosion process.
To date, a total of 509 USTs have
been inspected internally to deter-
mine structural integrity—visual
inspection and gauging ultrasonic
thickness of the tank shell in accor-
dance with the requirements of
National Leak Prevention Associa-
tion, Standard 631 (NLPA 631) enti-
tled Entry, Cleaning,. Internal
Inspection, Repair and Lining of Under-
ground Storage Tanks - with Appen-
dix MI (1991). It should be noted that
because of the obvious limitations of
internal inspections, the corrosion
process that is operative on the out-
side surface of an UST and the degree
to which that process is occurring
cannot be determined with complete
certainty or accuracy.
Of the USTs inspected internally,
approximately 8 percent failed the
internal inspection due to pitting
corrosion or perforations, and less
than 1 percent failed due to uniform
corrosion. Nearly 5 percent of the
USTs failed the structural integrity
requirements of NLPA 631, because
the UST was more than 2 percent out
of round, had a split weld seam, or
¦ continued on page 30
29

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LUSTLine Bulletin 51 • December 2005
¦ Michigan UST Assessment
from page 29
had dents or flat spots exceeding the
criteria for tank repair.
Of the 252 facilities (out of the
total of 260) where corrective actions
were performed to remove or inter-
nally inspect USTs, 19 percent were
found to have one or more perforated
USTs. Of the 681 USTs that were
externally or internally inspected, 10
percent were found to be perforated
due to pitting corrosion.
It is important to note that the
main objective of an internal inspec-
tion is to assess the structural
integrity of an UST, and not just
whether or not the UST has perfora-
tions. In examining the causes and
frequency of tank failure, we deter-
mined that 94 out of 681 USTs that
were visually or internally inspected
failed because of a structural defi-
ciency. Of these USTs, 71 percent
failed due to pitting compared to a 3
percent failure rate due to uniform
corrosion. UST failure due to other
structural deficiencies, such as the
tank being out of round, occurred in
26 percent of the failed USTs.
Other Findings
It should come as no surprise to the
seasoned tank regulator that as a
result of our close scrutiny of this
population of facilities and USTs,
MDEQ found other deficiencies that
were affecting the operation and
maintenance of the UST systems and
our ability to regulate them.
During inspections of excavated
USTs, we found that damage to the
asphaltic or dielectric coating on the
outer surface of an UST that occurred
during installation could cause pref-
erential corrosion to occur where the
bare metal was exposed to the corro-
sion processes.
Of facilities performing corrective
actions, 33 percent reported con-
firmed releases. MDEQ was unable to
determine the exact number of
releases that were attributable to the
improper assessment of the UST's
suitability for cathodic-protection
upgrade or to historic releases from
other USTs at the facility, piping, or
overfills. However, a review of
MDEQ records from prior to this ini-
tiative showed that there were a num-
ber of facilities that reported releases
within six months, or shortly there-
after, following cathodic-protection
upgrades that MDEQ believes are
attributable to the dissolution of "rust
plugs."
During our initiative, nearly 8
percent of the USTs inspected inter-
nally failed due to pitting corrosion
or perforations; however, when we
reviewed tank-tightness testing, leak
detection, and monthly monitoring
records, there was no evidence that
the USTs were leaking at rates
detectable by the release-detection
methodology being used. This find-
ing coincides with concerns
expressed by EPA in the preamble to
the federal rules that as many as 7
percent of existing USTs are corroded
through but not leaking because
"rust plugs," backfill, or interior
sludge seal the hole.
We also found that the vast
majority of the owners/operators
were not performing the required
three-year cathodic-protection sys-
tem testing or inspecting their
impressed-current cathodic-protec-
tion systems every 60 days, as
required by state and federal regula-
tions. In addition, many owners/
operators had performed repairs to
their facilities or other UST system
components that severed buried
cables or otherwise caused damage to
the impressed-current cathodic-pro-
tection systems, rendering the sys-
tems incapable of providing
adequate cathodic protection to the
USTs.
MDEQ also questioned the accu-
racy of some information on the con-
struction of USTs reported on
registration forms. This tended to be
the case where UST ownership
changed numerous times, and the
subsequent owners apparently did
not verify tank construction prior to
purchase. Nearly 8 percent of the
USTs targeted during this initiative
that were reported to be cathodically
protected steel were either fiberglass,
steel with fiberglass coating (compos-
ite tank), or sti-P3® tanks. Unfortu-
nately, several sti-P3 tanks that
appeared to be in good condition
were excavated.
In instances of discovery or claim
of an sti-P3 tank, MDEQ required fur-
ther cathodic-protection testing or
documentation to prove the UST was
adequately protected by the sacrifi-
cial anode at the time of installation
of the impressed-current cathodic-
protection system. If a sti-P3 tank
was found to be inadequatley pro-
tected, an internal inspection was
required by MDEQ.
The problem of accurately
reporting information on UST regis-
tration forms only highlighted the
need for owners to verify tank
construction prior to purchasing
facilities and the complications
implementing agencies encounter
that hinder effective implementation
of the UST program.
How Many More Out There?
The continued use of noninvasive
assessment methodologies to predict
the suitability of USTs for cathodic-
protection upgrade is unlikely with
the passing of U.S. EPA's 1998 dead-
line for upgrading bare-steel USTs of
a certain age. However, these
methodologies could be used to eval-
uate bare-steel USTs in other coun-
tries, bare-steel USTs not regulated
by federal and state UST rules, as
well as other buried metal structures,
such as pipelines.
I will let you draw your own con-
clusions regarding the effectiveness
of noninvasive assessment method-
ologies to predict UST failure due to
corrosion as the sole means of assess-
ing the suitability of an UST for
cathodic-protection upgrade. Regula-
tors should consider our findings,
together with the means by which
they regulate their UST programs,
when evaluating whether or not
there exists a population of USTs
whose cathodic-protection upgrade,
based on the use of noninvasive
assessment methodologies, is suspect
and should be subjected to further
scrutiny. ¦
¦ continued on page 39
THE RATES FOR CAUSES OF UST FAILURE
Uniform Corrosion 3%
-r, Structural 26%
rtj
Pitting Corrosion 71%
30

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December 2005 • LUSTLine Bulletin 51
DdWjJ iiSJS'j:
by W. David McCaskill
David McCaskill is an Environmental Engineer with the Maine Department of
Environmental Protection. "Tanks Down East" is a regular feature of
LUSTLine. David can be reached at David.Mccaskill@maine.gov.
As always, we welcome your comments.
SHIPSHAPE FROM STEM TO STERN
Maine's Comprehensive Annual Third-Party USTInspection Program
Penobscot Bay is a stunning place, studded with spruce-trimmed granite islands, the exposed tops of drowned mountains left
over when the glaciers completed sculpting their masterpiece some 13,000 years ago. Plying these cold, bold waters are elegant
two- and three-masted schooners that look more organic than mechanic. In this real-life Earth Sea, all creatures and crafts
must be well built and well maintained to withstand the rigors of winter, wind, and wave. Here in Maine, we have a tradition of mak-
ing sure that all things—200-year-old farmhouses, 125-year-old schooners, or 15-year-old USTs—are shipshape from stem to stern.
In this installment of "Tanks Down East," we'll take a look at how Maine's annual third-party inspection program has fared the
rigors of ensuring that our UST systems are performing their dual duties of providing for our energy needs and protecting precious
groundwater resources.
Our Inspection Law
Annual UST inspections have been
required in Maine since 1991, but the
inspection results were not required
to be reported to the Department of
Environmental Protection (DEP). In
1995, we started sending out letters to
our petroleum-containment captains
(owners/operators) to remind them
of their sacred inspection duties. But
a study conducted in 2000 found that
only 25 percent of our UST systems
were being inspected, and of the
facilities inspected, 35 percent had
deficiencies that remained unfixed
year after year. (See LUSTLine #38,
"There Ought to Be a Law!")
In 2000, our inspection law was
amended to require all UST owners
to submit annual UST inspection
results to DEP on or before July 1,
2003, and on or before July 1 annually
thereafter. In Maine, we regulate all
underground petroleum tanks,
including those used to heat homes,
schools, and businesses. So this
inspection requirement touches a
bunch of different folks besides your
typical gas station operator. The
inspections are paid for by the
owner/operator and cost between
$250 and $500, depending on the
number of tanks at the facility and
the kind of equipment on the site.
The Inspection Report
Failure to submit a passing inspec-
tion report can result in the ultimate
penalty—a shutdown order. The
inspection must be performed by a
certified inspector or tank installer.
The inspection report form, which
was developed by our crack DEP
UST staff, summarizes all the
required annual inspection criteria in
Maine's UST rules. The goal of the
new law is to ensure that the inspec-
tions are undertaken and that any
deficiencies discovered are corrected.
The items to be inspected include
the oft-repeated litany of the prac-
ticed UST regulator—leak detection,
corrosion protection, and spill- and
overfill-prevention equipment. But in
Maine, the inspection consists of see-
ing not only that these components
are present, but that they are, in fact,
in good condition, installed properly,
and operating correctly.
The inspection includes a func-
tional test of all significant compo-
nents—interstitial space probes,
gauge sticks, inventory control
records, cathodic-protection read-
ings, spill buckets and their often-
broken lids, and the proper opera-
tions of those fickle flapper valves
and their evil equivalent, the ball-
float valve!
Prior to the change in the annual
inspection requirement, the reporting
forms were vague, to say the least.
Following the implementation of our
new inspection form, it was still
apparent that some inspectors were
simply identifying the type of UST
equipment at a facility and not neces-
sarily removing each item and
inspecting it for proper operation.
During the first season of the new
inspection requirement, DEP identi-
fied a number of facilities where elec-
tronic sensors and overfill-prevention
devices were inoperable and appar-
ently had been for some time. In other
cases, there was no access to this
equipment provided during the initial
tank installation and therefore no way
to properly inspect the equipment.
So we've continued to improve
upon our inspection form. That's
why it is now eight pages long and
has a 22-page handbook to go with it.
(Go to http://www.maine.gov/dep/rwm/
ust/annualinspects.htm to see what's
on the form.)
¦ continued on page 32
31

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LUSTLine Bulletin 51 • December 2005
¦ Maine's Third-Party UST
Inspection Program from page 31
A New Tank-Inspector Class
With our new inspection program we
had to create a whole new class of
licensed technician—the certified
tank inspector. We already had about
85 certified installers who were auto-
matically qualified to be tank inspec-
tors, but the industry had concerns
that there would not be enough certi-
fied tank installers to perform all
these inspections. (To become a certi-
fied tank installer, you must appren-
tice under an installer at four UST
installations and take an initial and
final written test.)
Since few new tanks were being
installed in Maine, it was difficult to
attract people to the business. How-
ever, many tank and pump compa-
nies had pump technicians who were
factory trained to work on various
kinds of UST equipment and who
could potentially fill the inspector
gap. Before the inspector program,
our UST rules allowed only certified
tank installers and manufacturer-cer-
tified persons to perform the annual
equipment inspections.
The manufacturer-certified per-
sons were not under the jurisdiction
of our tank installer board. This cre-
ated a somewhat unlevel playing
field in that certified installers could
be fined or disciplined for improper
behavior, but manufacturer-certified
persons had no one to put them to
the lash!
There were a few existing
companies that were using their
manufacturer-certified personnel to
perform inspections, but they were
limited in what they could work on.
For example, to test the cathodic-pro-
tection readings you had to hire a cer-
tified tank installer or NACE-c
ertified cathodic-protection tester (of
which there are very few).
To deal with all of these issues,
we developed the certified tank-
inspector class. To become a certified
tank inspector you must pass a very
comprehensive test. Certified tank
inspectors must still be manufacturer
certified to work on manufacturer-
certified equipment and must be
NACE certified for cathodic-protec-
tion testing if they choose to test that
portion of an UST facility. Currently
there are about 27 certified tank
inspectors. So between this new
group of tank inspectors and our 85
installers, we now have about 112
certified tank inspectors out there.
Getting Ready
We knew that such a new and com-
prehensive program would have
some growing pains. So we decided
to commit resources upfront to pro-
vide several statewide training
venues for inspectors and installers
and send mailings to facilities own-
ers. As part of our preparation, we
convened a work group with
installers to help us develop and cri-
tique our inspection report form. In
2002, we set out on a statewide voy-
age to train the installers and inspec-
tors and to get even more input.
How's It Going?
In 2004, of the 3,180 registered UST
facilities in Maine, 2,276 submitted a
passing inspection report, 205 sub-
mitted only a failed report (i.e., they
didn't get the problems fixed in
time), and 699 didn't submit any
report. After invoking the whole
suite of our usual regulatory torture
tools—follow-up letters, phone calls,
and compliance inspections—we had
a "shutdown" list with just six facili-
ties located in sensitive groundwater
areas.
The shutdown orders gave facil-
ity owners 30 days to come into com-
pliance with the inspection law (i.e.,
fix their UST systems so that they
would pass) or they would have to
shut down their pumps. All six got
their systems shipshape prior to the
30-day compliance deadline.
Based on our preliminary results
for this year, the number of own-
ers/ operators that are not sending in
inspection reports has been, roughly,
cut in half. It's getting better, and we
are planning to use the same strategy
for this round of nonconformers.
After a few more years, using a com-
bination of hand-holding and wrist-
slapping, we'll hopefully reduce the
number of brigands to a minimum.
Checks and Balances
So, at least once a year, all the things
you wish the owners/operators
would pay attention to are examined
by a knowledgeable person. At least
once a year, product and/or water in
sumps is pumped out, the probe is
put back in place where it can do its
job (not hanging a foot above the bot-
tom of the sump!), and the leak-
detection console alarm is reset. We
also gain all this data for trend analy-
ses on equipment failure and the
effectiveness of our inspection form
and our rules, so we can tweak, as
needed.
Suspicious-minded regulators
may wonder what will keep un-
scrupulous inspectors from passing
their favorite customers year after
year. We have several checks on such
behavior. Our inspectors are certified
by the Maine Board of Underground
Tank Installers, so there is an incen-
tive to "do the right thing." Other-
wise, if they are caught they will be
referred to a disciplinary board
where they can be fined or lose their
licenses. There are several ways to be
caught. Our staff perform between
400 and 500 compliance inspections a
year where we field truth the inspec-
tion data.
Competition also serves as a
check on the program. In the yearly
mad dash to get their tanks
inspected, some owners wait until
late in the inspection season and find
that their usual inspector is booked.
So they hire another inspector, who
may see things in a different light.
For example, there have been
flaps over the flapper valve among
inspectors. The flapper valve is an
overfill-prevention device that sits
down in the drop tube of the tank
and is set to reduce flow at 95 percent
of the tank volume. It shuts off flow
all together at 98 percent. The differ-
ence between 95 percent flow reduc-
tion and 98 percent shut-off gives the
driver room to drain the delivery
hose.
During an inspection, the inspec-
tor is required to pull out the flapper-
valve assembly to check that it is
operating properly and set at the
correct height. There have been cases
where a facility's regular inspector
has passed the same flapper valve
year after year, but then a new, hired-
at-the-last-minute inspector finds the
valve set higher than the required 95
percent (allowing more product to be
squeezed into the tank and increas-
ing the risk of an overfill). (See LUST-
Line #49, "Small Spills Count.")
¦ continued on page 37
32

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December 2005 • LUSTLine Bulletin 51
field-
from Robert N. Renkes, Executive Vice President, Petroleum Equipment Institute
PEI Introduces Online Owner/Operator Training;
Revises UST Installation Document
Online Owner/Operator Training
Online training designed to assist owners and opera-
tors in understanding and operating their under-
ground petroleum storage systems is now available
through the Petroleum Equipment Institute (PEI).
The training, provided through the PEI Learning
Center at zviviv.pei.org/learn, currently includes courses
that teach owners and operators:
•	The main features of their Veeder-Root TLS-350
automatic tank gauges, including inventory, leak
detection and important alarms
•	The fundamentals of how their pressurized
pumping and dispensing systems work, and what
needs to be done to detect leaks in these systems
•	The basic principles of operation, potential pit-
falls, and operation and maintenance procedures
associated with spill-containment and overfill-
prevention equipment.
The courses are designed with the audience in
mind. Students view short video lessons (each about
two minutes long) that depict authentic characters in
real-world scenarios who learn from a peer. A friendly
technician, an experienced brother-in-law, or a knowl-
edgeable pump and tank contractor explains what stu-
dents need to know to operate their storage systems
knowledgeably, safely, and within the requirements
of the federal regulations. While a video window
provides a story line and audio information, an
accompanying graphics window provides pictures,
graphics, animation, and summary notes that further
explain and illustrate the course content.
The lessons are followed by multiple-choice
quizzes that reinforce the information that has just
been presented. At the end of the course, students
may download or print course materials for future ref-
erence. After completing a final exam, students may
print a certificate of course completion. Courses cost
$79 and take about an hour to complete. Any com-
puter with a high-speed Internet connection and
sound capabilities can be used to access the courses
24/7.
Course content has been carefully researched and
reviewed by a panel of equipment manufacturers,
installers, distributors, service companies, tank own-
ers, and state and federal regulators. While specifi-
cally targeted for UST operators and owners, the
courses are ideal for newly hired UST regulators, service
technicians, and sales or customer service personnel
who need to understand the fundamentals of UST oper-
ation and maintenance.
State UST regulators are encouraged to provide a
link to the PEI Learning Center on their websites so any-
one seeking UST information can easily find the training
they need.
These courses represent the first offerings in PEI's
online UST university. Future courses being considered
include fueling safety, dispenser inspection and mainte-
nance, and cathodic protection of tanks and piping. If
you would like to recommend topics for future course
development, contact Bob Renkes at PEI: (918) 494-9696.
RP100 - 2005
The 2005 edition of PEI's Recommended Practices for
Installation of Underground Liquid Storage Systems
(PEI/RP100) is now available. This edition supersedes
the previous recommended practices of the same name
that were published in 2000. PEI revises RP100 when
warranted to ensure that users of its documents receive
the latest guidance on the proper methods and tech-
niques for installing UST systems.
PEI's Tank Installation Committee reviewed 118
suggestions submitted by various individuals and
groups to revise the previous edition of PEI/RP100.
Over 50 percent of these comments were accepted in
some manner by the committee. Significant changes in
the 2005 edition include:
•	A recommendation to install monitored contain-
ment sumps around submersible pumps and
beneath dispensers
•	A recommendation against the use of ball-float
valves for overfill prevention
•	An expanded discussion of piping testing require-
ments during and after installation
•	A requirement that UST owners establish an inspec-
tion, maintenance, and testing schedule for their
storage system equipment.
The 2005 PEI/RP100 is copyrighted and may not be
photocopied or otherwise reproduced. Order copies
online at iviviv.pei.org/RP100 or request an order form by
faxing PEI at (918) 491-9895.
33

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LUSTLine Bulletin 51 • December 2005
Revitalizing Contaminated Sites:
WE'VE com A LONG WAV; BAB
by Edward H. Qui
Over the past three decades,
we have seen an evolution
in the way our country
approaches the assessment and
cleanup of contaminated sites. As
we've come to realize the extent and
magnitude of our environmental
problems, we've (appropriately)
focused our attention squarely on
addressing the immediate threats to
our health and well-being. During
the formative years, we struggled to
better understand the threats and
figure out how best to address them.
Our more mature land cleanup pro-
grams now reflect hard-wrought
experience in assessing and cleaning
up contaminated sites, whether from
hazardous wastes or petroleum and
petroleum-related products.
With this maturity comes wis-
dom. For example, we now better
understand the social and economic
context that contaminated sites have
in their respective communities, and
the potential that these sites have to
improve the well-being of people in
those communities. We also under-
stand that land is a valuable and
finite resource and that ignoring pre-
viously developed, and sometimes
contaminated, land has profound
impacts on our quality of life.
In short, we understand the
importance of reusing sites with real
or perceived contamination once
they've been assessed and cleaned
up. Communities, too, are seeing the
opportunities to reclaim sites follow-
ing cleanup, and some developers
and others with an interest in the
land are increasingly eager to meet
their needs.
In keeping with this movement,
those of at U.S. EPA have a very sim-
ple vision and goal for our cleanup
programs—to restore and return all
contaminated (and potentially conta-
minated) properties to America's
communities so that they can reuse
the land for beneficial and productive
purposes. In creating this new vision
for our cleanup programs, we are
shifting our focus from cleanup only
to cleanup and reuse.
To carry out our revitalization
vision, EPA established the Land
Revitalization Office to coordinate
and promote efficient cleanup and
reuse of contaminated properties
across the agency's land programs
and to remove or minimize barriers
that may be preventing site reuse
from occurring. Our success requires
a cooperative effort among EPA,
states, tribes, local governments and
communities, potential developers,
and others. We have nothing to lose
and a whole lot to gain. Let's consider
the sense of all of this and find out
what EPA has to offer, so we can
really begin to move forward.
Assets Galore!
The cleanup and reuse of contami-
nated sites is a critical element in
ensuring the health and well-being of
communities. This is particularly true
for former gas stations and other
properties with idle, abandoned, or
leaking USTs, where the revitaliza-
tion opportunities are tremendous.
There are more than 250,000 of these
sites across the country! Most of these
properties are located in urban areas,
along business corridors, and in
places where people live or work.
They tend to involve small parcels of
land and are often situated on corner
lots and other prime real estate loca-
tions.
Because these sites are often sur-
rounded by other idle or abandoned
properties, they also tend to be the
linchpin to area-wide revitalization
efforts. These points were not lost on
Congress when it enacted national
brownfields legislation three years
ago to support the reuse of the vast
majority of LUST sites, and these
points are not lost on EPA.
The new law expanded the origi-
nal U.S. EPA Brownfields Program
by including relatively low-risk
petroleum sites as eligible sites for
brownfields assessment and cleanup
grant funding. Under the law, EPA
makes 25 percent of the total brown-
fields grant funds available each year
for these sites. In 2005, EPA awarded
approximately $22 million in brown-
fields grants to petroleum-contami-
nated sites. Recipients include
abandoned sites, such as gas stations,
and industrial and retail properties
that have, or are believed to have,
contamination from petroleum.
Imagine That!
Site reuse is an integral and invalu-
able element in our cleanup pro-
grams; more importantly, it allows us
to get our creative juices going and
use our imaginations. How? Well, for
one thing, when site reuse is an
explicit component of the cleanup
process, we start to see constructive
community involvement. Members
of the community have something to
look forward to—new parks, hous-
ing, and retail. They have more rea-
son to find common areas of
agreement. We begin to see stronger
partnerships among government,
private developers, and community
organizations because everyone wins
when a neighborhood springs back to
life.
When you are looking forward to
something better, you begin to
develop cleanup plans that are tai-
lored to future uses while ensuring
their long-term protectiveness. Pri-
vate funding is often more available
because cleanup money is seen as an
investment with a stream of future
returns. Because the partnerships,
planning, and funding are targeted at
future potential, not past failures,
contamination can be cleaned up
more quickly.
Finally, by encouraging sustain-
able reuses such as green spaces,
energy-efficient buildings, smart-
growth community developments,
and wetlands, we may also be able to
prevent the recontamination of for-
mer contaminated sites. Imagine that!
Making a Vision a Reality
The Land Revitalization Office has
identified the following 10 actions
that U.S. EPA is (or will be) taking to
make this revitalization vision a
reality:
34

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December 2005 • LUSTLine Bulletin 51
•	Promote land revitalization as a
national policy by ensuring that
reuse options are considered
explicitly in the evaluation of site
cleanup options.
•	Commit the necessary resources
to address reuse as a top priority
in cleanup decisions. In addition
to the brownfields grants that are
available, we will look for incen-
tives to encourage private invest-
ment and explore ways to better
leverage other federal funding.
We believe that encouraging pri-
vate investment is a means to
further the public's goal of pro-
tection in a timely and cost-effec-
tive manner.
•	Develop new comprehensive
policies and programs to address
unintended cross-jurisdiction
and cross-program barriers to the
safe reuse of previously contami-
nated properties. Because in the
past we have created uninten-
tional barriers to reuse and rede-
velopment activities that
contribute to community well-
being, EPA is reviewing its poli-
cies, practices, and guidance to
reduce and in some cases tear
down some of these unintended
barriers to beneficial reuse.
•	Promote safe, long-term reuse of
sites. When we say a property is
ready for reuses, we will mean it,
for now and later. EPA will pro-
mote long-term stewardship by
establishing and maintaining
appropriate engineering and
institutional controls that protect
future generations from inappro-
priate reuse of sites. For example,
we are working with states and
local governments to address
long-term safety issues systemat-
ically.
•	Promote sustainable reuse to pre-
vent recontamination and mini-
mize other environmental
problems that may result from
some reuse. Sustainable reuses
include such things as green
spaces managed in environmen-
tally sound ways, energy-effi-
cient buildings, smart-growth
community developments, and
wildlife habitats.
•	Develop and promote a Land
Revitalization Research Agenda
that improves our understanding
of, and ability to reuse, contami-
nated or potentially contami-
nated sites.
• Build partnerships to leverage
knowledge, expertise, and re-
sources for revitalizing sites. This
includes government-to-govern-
ment partnerships at the local,
state, tribal, and federal levels, as
well as partnerships with non-
governmental, private, and com-
munity organizations. EPA is
going to expand its use of part-
nerships that can stimulate pri-
vate investment in cleanup
activities, and we're going to do a
better job of coordinating multi-
ple federal cleanup programs at
area-wide clusters of properties.
By designing cleanups to mesh with
community-driven redevelopment
plans, developers are able to avoid
redundant construction activities,
minimize public distrust or
opposition, and increase certainty
among all principal! stakeholders.
•	Expand community capabilities
by providing improved public
involvement tools and informa-
tion systems on contamination,
cleanup, reuse, and long-term
stewardship. We hope to ensure
early and continuing community
involvement. EPA will work
with states and tribes to develop
a web-based tool so communi-
ties, investors, and developers
have a national inventory of
available clean sites.
•	Expand and promote educational
and training programs that pro-
vide needed tools to achieve land
revitalization in such areas as
real estate development of envi-
ronmental properties, risk-man-
agement tools (e.g., insurance),
and financing.
•	Promote efforts to measure and
report the status and impacts of
our collective efforts to revitalize
properties. EPA is exploring
approaches for obtaining a better
picture of total contamination
and mechanisms for measuring
progress in restoring and return-
ing land back into use.
Back to Streamlining
This evolution of thought and clarity
of focus is beginning to have signifi-
cant impacts on how we assess and
clean up sites under our government
programs. For example, in the past,
site assessments have been con-
ducted to find contamination and
determine whether a cleanup was
necessary. Now, these assessments
are also used to identify and docu-
ment where there is no contamina-
tion or where cleanup is not
necessary.
This information, when made
available on a timely basis and in an
easy-to-understand format, reduces
uncertainty for developers and com-
munities that want to use the land.
EPA recognizes the importance of
information in the real estate market
and the need to ensure that environ-
mental stigma, whether real or per-
ceived, is appropriately managed.
In the area of cleanup, we are
seeing more integrated cleanup and
reuse activities, which can make revi-
talization projects happen faster and
cost less without reducing their pro-
tectiveness. By designing cleanups to
mesh with community-driven rede-
velopment plans, developers are able
to avoid redundant construction
activities, minimize public distrust or
opposition, and increase certainty
among all principal stakeholders.
Providing information about
sites is equally important to lenders,
mortgage companies, and others who
may be in a position to support reuse
of the sites. Through such informa-
tion tools as ready-for-reuse determi-
nations and clarification of liability
for developers, lenders, and prospec-
tive purchasers, previous barriers to
redevelopment of contaminated sites
are being removed.
Through the Lens of Reuse
There are countless examples of site
reuse that have led to increased
employment opportunities, increased
property values, increased tax rev-
enues, and the potential for addi-
tional economic development on
¦ continued on page 39
35

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LUSTLine Bulletin 51 • December 2005
TRI1II3
EDfl
TRIBRb LRI1DX |
rJfJpJ
wmwm
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mm
This column focuses on the unique logistical and geographic issues, activities, solutions, and successes associated with USTs and
LUSTs in tribal lands. In this issue, Greg Pashia, U.S. EPA Region 6, discusses two award-ivinning capacity-building projects
undertaken by the UST programs of two Oklahoma tribes—the Choctaw Nation and the Chickasaw Nation. Jonathan Hook,
Region 6 Office of Tribal Affairs Director, recognized the Chickasaw and Choctaw Nations for "environmen tal excellence above
and beyond the call" during the Region's Ninth Annual Environmental Tribal Summit in Oklahoma City. Chuck Tillman
(Choctaw UST program) and Josh Presley (Chickasaw UST program) accepted the awards for their work and the work of Brian
McClain, Director, Choctaw Nation Office of Travel Plazas, and Darren Clinton, Regional Manager, Chickasaw Enterprises, in
the tribal UST programs.
Kudos for Two Tribal UST
Capacity-Building Projects
The Choctaw Nation has 13 tribally
owned and operated travel plazas
with a total of 43 USTs. The Chicka-
saw Nation had nine tribally owned
and operated travel plazas. Two of
the travel plazas have been closed
and evaluated for release of gasoline
to the environment (no releases were
found). At present, the Chickasaw
operate seven UST facilities.
The Choctaw, the Chickasaw,
and the EPA Region 6 UST program
developed capacity-building grant
projects that started in 2003 and will
conclude in 2006 to train a full-time
staff member for each tribe. This staff
member's main duty is monitoring
the tribally owned active facilities for
compliance with all applicable fed-
eral UST regulations with regard to
the installation, upgrade, repair,
removal, and investigation/remedia-
tion of any releases to the environ-
ment of petroleum product. UST
monitors Chuck Tillman and Josh
Presley provide their tribes with
advice on and oversight of the com-
pliance and maintenance of the UST
systems. In addition, Chuck and Josh
train the facility staff members who
conduct the day-to-day operation of
the retail fuel facilities on safety and
leak detection.
Both the Choctaw and the Chick-
asaw have advanced very quickly to
a level of expertise on the operation
and compliance with federal regula-
tions at all of their travel plazas. The
parties involved in the project have
willingly and expeditiously followed
up on all recommendations from the
UST monitors concerning the need
for financial expenditures to have the
UST facilities managers obtain equip-
ment and UST contractors to address
all deficiencies at the UST locations.
A Way of Life
The Choctaw and Chickasaw UST
staff monitors continue to acquire
knowledge and experience concern-
ing the operation and maintenance of
UST facilities through various train-
ing opportunities. This knowledge is
effectively being transferred to the
staff that conducts the day-to-day
operation of the UST facilities.
"Prior to this grant," says Josh
Presley, "the USTs within the Chicka-
saw Nation were assessed, but not as
thoroughly as they are currently.
With the economic growth of the
tribe, it is vital that the environment
be considered and every measure
taken to protect it. The tribe's natural
resources are an essential part of the
Chickasaw culture and are worth the
extra steps required to ensure their
longevity. The UST program will
continue to be an important aspect of
tribal environmental protection. We
expect that by the end of 2005, all
Chickasaw travel plazas will be in
full compliance with all federal UST
regulations."
"We are now paying attention to
our UST facilities," says Chuck Till-
man. "For example, cathodic-protec-
Developing a Low-Cost, Low-Tech Hydrocarbon Sampling Tool, Members of the South-
ern Methodist University (SMU) Department of Environmental and Civil Engineering con-
duct a field test to verify the use of a field-detecting device for hydrocarbons in soil. U.S.
EPA Region 6 gave the Inter-Tribal Environmental Council a grant to develop a tool that
would be portable, low cost, low tech, but accurate (>50 ppm) in detecting the mass of
hydrocarbons in soil samples collected and analyzed in the field. The cooperation of the
Choctaw Nation helped SMU validate its laboratory-developed data on the tool.
36

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December 2005 • LUSTLine Bulletin 51
tion testing had not been completed
since the original installation of tanks
that required CP at three sites
approximately 10 to 15 years ago.
This occurred simply due to the lack
of knowledge of the type of tanks
present and the lack of knowledge of
federal compliance requirements.
"Now," says Tillman, "a full com-
pliance inspection is completed for
each facility once a quarter. The pro-
gram has become more hands-on. As
UST program monitor, I inspect spill
buckets, oversee the installation of
equipment, and track the required
testing for LLD and lines, CP, and
monthly leak detection. The Choctaw
Nation has identified one facility that
has had a release. Remediation efforts
are currently underway, and the
Choctaw Nation expects to be able to
receive a no further action letter soon
from EPA in regard to the release."
In spring 2006, training will com-
mence at the Choctaw Nation travel
plazas. The managers will receive
training regarding the procedure to
monitor the ATG equipment, record-
keeping, and spill response. Once
this round of training is completed,
training will be given to all Choctaw
Nation travel plaza employees who
are present for the day-to-day opera-
tion on the purpose and operation of
ATG alarm systems and spill-
response procedures. The Choctaw
Nation is currently supplying each
travel plaza with a spill-response kit.
The tribe expects to achieve 100 per-
cent Significant Operational Compli-
ance by spring 2006.
Both Chuck and Josh have
attended trainings on tank installa-
tion, tank removal, ATG operation,
and compliance issues. The grant has
allowed them to obtain UST Tribal
Inspector Certification from the Inter-
Tribal Council of Arizona.
The capacity-building projects
have allowed the Choctaw and
Chickasaw to develop a working
relationship/partnership with U.S.
EPA and other tribes throughout the
United States. The partnership with
EPA has been more of a trust-build-
ing program, because it has allowed
for better communication among the
organizations. As a result, EPA is not
looked at solely as an enforcement
authority, but also as a partner of
whom questions can be asked and
with whom information can be
shared freely. ¦
¦ NAPL Using Imaging
from page 25
Acknowledgments
The authors would like to acknowledge the Okla-
homa Corporation Commission, Petroleum Storage
Tank Division, and especially Mary O'Kelley and
Joseph Thacker, for funding this work and providing
tremendous support for the project. We would also
like to thank the U.S. EPA GWERD laboratory and
John Wilson for providing a great intellectual sound-
ing board for portions of this research. Thanks also to
Aestus, Inc. and Hazlett-Kincaid, Inc. for supporting
innovative methods and approaches to environmen-
tal problems. Finally, we would like to thank OSU
faculty and students in the School of Geology for the
field work and efforts expended to collect the confir-
mation data required of these ERI geophysical
images.
Todd Halihan is Assistant Professor at
Oklahoma State University, School of
Geology at Oklahoma. He can be
reached at halihan@okstate.edu.
John Billiard is with Aestus, Inc. in
Centennial, Colorado. Contact him at
jwb@aestusinc.com.
Stuart McDonald is also with
Aestus, Inc. Contact him at
swm@aestusinc .com.
References
Conrad, S.H., Wilson, J.L., Mason, W.R. and Peplin-
ski, W.J., 1992. "Visualization of residual organic
liquid trapped in aquifers." Water Resources
Research, 28(2): 467-478.
Halihan, T., Paxton, S.T., Graham, I., Fenstemaker,
T.R. and Riley, M., 2005a. "Post-remediation evalu-
ation of a LNAPL site using electrical resistivity
imaging." Journal of Environmental Monitoring, 7:
283-287.
Halihan, T., Paxton, S.T., McPhail, M.L., McSorley,
J.D. and Riley, M., 2005b. Final Report for Characteri-
zation and Monitoring of LNAPL Using Electrical
Resistivity Tomography (ERT) and Hydraulic Push
Techniques. Oklahoma Corporation Commission,
Petroleum Storage Tank Division, Oklahoma City,
OK.
Schwartz, F.W. and Zhang, H., 2003. Fundamentals of
Ground Water. John Wiley and Sons, Inc., New York,
583 pp.
Walther, E.G., Pitchford, A.M. and Olhoeft, G.R.,
1986. "A strategy for detecting subsurface organic
contaminants," Ground Water: Prevention, Detection
and Restoration. National Water Well Association,
Dublin, OH, pp. 357-381.
¦ Maine's Third-Party UST
Inspection Program from page 32
Our Ship Has Sailed
So our inspection ship has sailed,
and we sure do hope that these
third-party inspections count toward
U.S. EPA's three-year inspection
schedule as per the new Energy Pol-
icy Act! Without third-party inspec-
tions, we would be forced to limit
our DEP inspections to only feder-
ally mandated tanks, leaving a large
population of our tanks adrift on
uninspected seas. We believe that
annual third-party inspections, cou-
pled with regulatory inspection
spot-checks, will go a long way
toward taking the wind out of our
leaking UST problem in Maine. ¦
Uo download the
\ LUSTLine Index, go to
Lww.neiwpcc.oirg/
llustline.htm» and then
[click on LUSTLine Inde^
OSRTI Publishes Results
of Study of Triad at
Petroleum Sites
The September 2005 issue of Cleanup
News //contains the article "Triad Saves
$109K on Three Petroleum Sites." The
article describes the results of a study
undertaken in fall 2004 with the South
Dakota Petroleum Release Compensa-
tion Fund, evaluating whether the Triad
approach could significantly improve the
management of petroleum release sites.
South Dakota's experience showed
that conventional assessment programs
were providing an inadequate under-
standing of contaminant sources and the
extent of contamination, which in turn
led to inappropriately designed remedia-
tion systems—all of which were driving
up costs to the Fund.
Triad is an innovative approach for
remedial decision-making at contami-
nated sites. The approach was formu-
lated to produce highly reliable "pictures"
of contaminant locations and concentra-
tions, promote efficient remedial actions,
and lower costs. These benefits are
achieved through integration of three pri-
mary components: systematic planning,
dynamic work strategies, and real-time
measurement systems. Triad offers a
technically defensible methodology for
managing decision uncertainty that lever-
ages innovative characterization tools
and strategies.
The full article can be read at
http://www. epa.gov/compliance/
resources/newsletters/cleanup/
cleanup21s2.pdf.
37

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LUSTLine Bulletin 51 • December 2005
A River Runs Through It
by Lynn A. Woodard
The New Hampshire Department
of Environmental Services
(NHDES) requires that UST sys-
tems have a separation distance of at
least 75 feet from surface water. But
what about placing a surface water
body on top of an existing UST sys-
tem? This is exactly what happened
on October 8, 2005, during severe
flooding in Alstead, New Hampshire.
The high intensity and long duration
of the rain event caused extensive ero-
sion. When a 12-foot culvert plugged
up with debris, the hydraulic pressure
built up and punched through, taking
the road with it and diverting the
course of Warren Brook, a tributary of
the Cold River. Suddenly, the KMEC
Garage was in the middle of the river
and being washed downstream... The facility just after the river rerouted through it. Only the tanks remain: the building was washed
except for its USTs.	amy durjnQ the flood
The facility consisted of a compos- 	
ite 6,000-gallon gasoline tank with
three 2,000-gallon compartments, and a 2,000-gallon diesel tank. The tanks were installed in September 1997 and closed
on October 14, 2005. The tanks were pulled by an NHDES contractor, who pumped 1,000 gallons of a diesel/water mix-
ture and 4,500 gallons of a gas/water mixture prior to removing the tanks. A total of 1,700 gallons of water was recovered
from the two tanks. No contamination was in evidence. We will have to determine cost recovery later. The river has been
redirected back to its original course; however, the land may not be recoverable. II
Lynn A. Woodard, P.E. is Supervisor of the Oil Compliance Section, Waste Management Division, NHDES.
He can be reached at lwoodard@des.state.nh.us.
On September 22, heavy rains
caused three of the four gasoline
tanks at Phillips 66/Miller Mart in
Lawrence, Kansas to float out of
their subterranean home, smashing
through the concrete pavement.
The tanks were not anchored and
contained little fuel, which would
have served as ballast.
38

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¦ Revitalizing Contaminated Sites from page 35
surrounding properties. Communi-
ties have also benefited from new
recreational and ecological areas
where the availability of land for
such uses was limited.
Reused sites improve the aes-
thetic quality of the community
through the creation of well-main-
tained properties, the removal of
blight, and the discouragement of
illegal waste disposal and similar
unwanted activities. Reusing a site
also benefits the cleanup itself
through increased day-to-day atten-
tion to the site.
Through the lens of reuse, we
have the opportunity to rethink how
we approach sites in a way that
meets the needs of the public and pri-
vate sectors and, most importantly,
affected communities. The reuse of
sites represents a move beyond the
singular, essential goal of protecting
human health and the environment,
and embraces the increasing impor-
tance of land as a source and a
resource for community revitaliza-
tion. It reflects the idea that sites can-
not, and should not, be fenced,
abandoned, and unavailable for use
by the community.
In the decades to come, our
cleanup programs will view sites
with an understanding that these
properties are woven into the fabric
of their communities. We must
approach them with the interests and
needs of future generations in mind.
We've come a long way, and we will
continue to build on this excellent
foundation to help communities
become even more vibrant. ¦
Edward H. Chu is the Acting Director
of U.S. EPA's Land Revitalization
Office. He can be reached at
chu.ed@epa.gov.
Trenton, NJ, Mayor Acts to Spur Reuse of
Abandoned Gas Stations
A news article in the Trenton Times on November 7,2005, described the plans
of Trenton Mayor Glen Gilmore and the township of Hamilton for contacting
the owners of abandoned gas stations and involving them in planning for
reuse of their properties. Trenton has been a leader in the reuse of abandoned
gas station sites ever since it was awarded one of the first USTfields Pilot
grants in 2000. The article can be seen at http://www.nj.com/news/times/
index.ssf?/base/news-0/1131356183151560.xml&coll=5.
December 2005 • LUSTLine Bulletin 51
¦ Michigan UST Assessment
from page 30
Dan Yordanich is a geologist specializ-
ing in the enforcement of storage tank
regulations for the Michigan Depart-
ment of Environmental Quality's
Waste and Hazardous Materials Divi-
sion. Dan welcomes your comments
and questions, and may be reached at
yordanid@michigan.gov.
Disclaimer
Any opinion expressed herein is that of the author
and does not represent opinions of the State of Michi-
gan, Michigan Department of Environmental Quality,
or EPA.
Acknowledgments
I would like to thank Andrea Zajac, Chief, and Mike
Kadri, Senior Engineer, of the MDEQ's Waste and
Hazardous Materials Division's Storage Tank Unit,
for technical guidance and many long hours of file
review. I would also like to give special recognition to
MDEQ's Hazardous Materials Storage Inspectors for
their persistence in dealing directly with the regu-
lated community in successfully implementing the
enforcement process, and without their efforts we
would not have the photos for this article.
References
Federal Register. 52 FR 12665, December 23, 1987,
Supplemental Notice. Causes of Releases from UST
Systems.
Federal Register. Vol. 53, No. 185. September 23, 1988.
Rules and Regulations. 40 CFR Part 280. Under-
ground Storage Tanks; Technical Requirements.
American Society for Testing and Materials (ASTM)
Designation: ES 40-94 Emergency Standard Practice
for Alternative Procedure for the Assessment of Buried
Steel Tanks Prior to the Addition ofCathodic Protection,
January 1995.
American Society for Testing and Materials, Technical
Bulletin STP1013, January 1989.
J.B. Bushman and T.E. Mehalick, Statistical Analysis of
Soil Characteristics to Predict Mean Time to Corrosion
Failure of Underground Metallic Structures, ASTM
STP 1013, American Society for Testing Materials,
Phil., 1989, g. 2.
National Leak Prevention Association, Standard 631,
Entry, Cleaning, Internal Inspection, Repair and Lining
of Underground Storage Tanks. - with Appendix MI
(Fourth Edition, 1991).
L.U.S.T.LINE Subscription Form
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116 John Street, Lowell, MA 01852-1124
Phone: (978) 323-7929 ¦ Fax: (978) 323-7919 ¦ lustline@neiwpcc.org ¦ www.neiwpcc.org
39

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FAQs from the NWGLDE
...All you ever wanted to know about leak detection, but were afraid to ask.
CITLDS and Throughput
In this issue of the National Work Group on Leak Detection
Evaluations' (NWGLDE's) FAQs, we discuss Continuous In-
Tank Leak Detection Systems (CITLDS) protocol throughput
limitations. It may help to look back at the last issue's (August
2005) FAQs concerning CITLDS protocols to better under-
stand the following discussion. Please note: The views
expressed in this column represent those of the workgroup and
not necessarily those of any implementing agency.
Q Why does the CITLDS protocol (1/7/2000 edition)
' include a limitation on throughput?
^ Before we can discuss throughput, we must first
know how it is defined in the protocol. According
to the CITLDS protocol, throughput is the volume
of product dispensed from a tank in a month. The
operation of CITLDS depends on "quiet time" (no
deliveries and no dispensing operations). Jairus D.
Flora Jr., author of the protocol, thought it was
important to limit throughput because CITLDS is
most commonly used on tank systems at high-
throughput, 24-hour-operation facilities. Exces-
sively high throughput could severely limit the
amount of "quiet time." Without enough "quiet
time" the CITLDS would be unable to perform a
valid leak test within the required monthly time
period. Dr. Flora believed limiting throughput
was the best way to ensure that enough "quiet
time" was available for CITLDS to operate prop-
erly. The throughput limitation of a CITLDS
should be an important consideration for a
prospective purchaser who intends to install a
CITLDS at a busy location.
Q How should the monthy throughput limitation be
applied to manifolded tank systems?
^ The throughput limitation applies to manifolded
tanks as follows. Since the statistical calculations
in the protocol are based on dataset records from
tank systems, the monthly throughput limitation
must also apply to tank systems, including mani-
folded tank systems. This means that the through-
put limit applies to all the tanks manifolded
together and not each one separately. For exam-
ple, if you have three 10,000-gallon tanks joined
by manifolds to each other and are using CITLDS
equipment where the evaluation limits the use of
a tank system to a monthly throughput of 200,000
gallons, then the throughput limit for this storage
system is 200,000 gallons, NOT 600,000 (3 x
200,000) gallons.
About NWGLDE
NWGLDE is an independent work group comprising 10
members, including eight state and two U.S. EPA mem-
bers. This column provides answers to frequently asked
questions (FAQs) NWGLDE receives from regulators
and people in the industry on leak detection. If you
have questions for the group, please contact them at
questions@nwglde.org.
NWGLDE's mission:
¦	Review leak-detection system evaluations to deter-
mine if each evaluation was performed in accor-
dance with an acceptable leak-detection test method
protocol and ensure that the leak-detection system
meets U.S. EPA and/or other applicable regulatory
performance standards
¦	Review only draft and final leak-detection test
method protocols submitted to the work group by a
peer review committee to ensure they meet equiva-
lency standards stated in the U.S. EPA standard test
procedures
¦	Make the results of such reviews available to inter-
ested parties
LUST. JNE
New England Interstate Water
Pollution Control Commission
116 John Street
Lowell, MA 01852-1124
Nan-Profit Org.
U.S. Postage
PAID
Wilmington, MA
PemiitNo.
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