*>EPA

United States
Environmental Protection
Agency

The National LUST Cleanup Backlog:

A Study of Opportunities

Printed on Recycled Paper


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v»EPA

United States
Environmental Protection
Agency

THE NATIONAL LUST CLEANUP BACKLOG:
A STUDY OF OPPORTUNITIES

STATE SUMMARY CHAPTER: WASHINGTON STATE

Office of Solid Waste arid Emergency Response
Office of Underground Storage Tanks
September 2011

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State Summary Chapter: Washington State

LIST OF ACRONYMS

cscs

Confirmed and Suspected Contaminated Sites

ECY

Washington State Department of Ecology

EPA

United States Environmental Protection Agency

ESA

Expedited Site Assessment

FR

Financial Responsibility

FY

Fiscal Year

ISIS

Integrated Site Information System

LUST

Leaking Underground Storage Tank

MNA

Monitored Natural Attenuation

MSA

Multi-Site Agreement

MTCA

Model Toxics Control Act

NFA

No Further Action

PCP

Pentachlorophenol

PLIA

Pollution Liability Insurance Agency

RCU

Reported Cleaned Up

RP

Responsible Party

UST

Underground Storage Tank

VCP

Voluntary Cleanup Program

WARM

Washington Ranking Method

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State Summary Chapter: Washington State

Washington State
LUST Data

By the Numbers1

Cumulative Historical Releases

6,414

Closed Releases

4,411/69%

Open Releases

2,003/31%

Stage of Cleanup



Pre-remediation3

518/26%

Remediation

1,485/74%

Media Contaminated



Groundwater

1,364/68%

Soil

630/31%

Other

7/ <1%

Unknown5

2/ <1%

National Backlog Contribution

1.9%

Median Age of Open Releases

14.7 years

EXECUTIVE SUMMARY

Leaks from underground storage tanks (USTs) threaten America's groundwater and land resources. Even a small amount of
petroleum released from a leaking underground storage tank (LUST) can contaminate groundwater, the drinking water source
for nearly half of all Americans. In surveys of state water programs, 39 states and territories identified USTs as a major source
of groundwater contamination.2 As the reliance on our resources increases due to the rise in population and use, there is a
correspondingly greater need to protect our finite natural resources.

From the beginning of the UST program to September 2009, more than 488,000 releases were confirmed from federally-
regulated USTs nationwide. Of these confirmed releases needing cleanup, over 100,000 remained in the national LUST backlog.
These releases are in every state, and many are old and affect groundwater. To help address this backlog of releases, the United
States Environmental Protection Agency (EPA) invited 14 states to participate in a national backlog characterization study.

ANALYSIS OF WASHINGTON STATE DATA

Washington State's Department of Ecology (ECY) has made significant progress toward reducing its LUST cleanup backlog. As
of February 2009, ECY had completed 4,411 LUST cleanups, which is 69 percent of all known releases in the state. At the time
of data collection, there were 2,003 releases remaining in its backlog.4 To most effectively reduce the national cleanup backlog,
EPA believes that states and EPA must develop backlog reduction strategies that can be effective in most states as well as those
with the largest backlogs. EPA invited Washington State to participate and represent EPA Region 10 in its national backlog study.

In this chapter, EPA characterizes Washington State's releases that have not been cleaned up, analyzes these releases based on
categories of interest, and identifies potential opportunities for ECY and EPA to explore that might improve the state's cleanup
progress and reduce its backlog. Building from the potential cleanup opportunities identified in the study, EPA will continue to
work with Washington State to develop backlog reduction strategies.

In Washington, as in every state, many factors affect the pace of cleaning up releases, such as the availability and mechanisms of
funding, statutory requirements, and program structure. The recent economic downturn has also had an impact on the ability
of many states to make progress on cleanups.

EPA included potential cleanup opportunities in this report even though current circumstances in Washington State might make
pursuing certain opportunities challenging or unlikely. Also, in some cases, ECY is already using similar strategies as part of its
ongoing program. The findings from the analysis of ECY's data and the potential cleanup opportunities are summarized below
in five study areas: stage of cleanup, media contaminated, state regional backlogs, voluntary cleanups, and geographic clusters.

1	Data were provided in February 2009 by ECY staff and are not identical to UST performance measures on EPA's website, available at:
www.epa.eov/oust/cat/camarchv.htm.

2	EPA, National Water Quality Inventory: 2000 Report, pp. 50-52. www.epa.gov/305b/2000report/chp6.pdf.

3	Available data do not distinguish between whether a release is in the confirmed release or the site assessment stage.

4	EPA tracks individual releases rather than sites in its performance measures. Therefore, the analyses in this report account for numbers
of releases, not sites.

5	Unknown media releases include those releases where the media is unknown as well as those releases where, based on available data,
it was not possible to identify the media contaminated.

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State Summary Chapter: Washington State

Stage of Cleanup (see page WA-12for more details)

Media Contaminated (see page WA-14for more details)

Washington Finding

Potential Opportunity

Releases

Washington Finding

Potential Opportunity

Releases

15 percent of releases:

•	have not finished site
assessment; and

•	are 10 years old or
older.

•	Provide information and technical
assistance to responsible parties (RPs) or
implement enforcement actions at old
releases.

•	Encourage RPs and stakeholders to
examine public and private funding
options.

305

43 percent of releases:

•	contaminate
groundwater;

•	are in remediation;
and

•	are 10 years old or
older.

Systematically evaluate cleanup progress at
old releases with groundwater impacts and
consider alternative cleanup technologies or
other strategies to reduce time to closure.

858

59 percent of releases:

•	are in remediation;
and

•	are 10 years old or
older.

Use a systematic process to explore
opportunities to accelerate cleanups and reach
closure, such as:

•	periodic review of release-specific
treatment technologies;

•	review of site-specific cleanup standards;

•	consider use of institutional or

1,191

6 percent of releases:

•	impact soil only;

•	have not finished site
assessment; and

•	are 10 years old or
older.

•	Continue to use targeted backlog
reduction efforts to close old releases
with soil contamination with minimal
effort.

•	Encourage RPs to use expedited site
assessment to move releases more
quickly into remediation.

118

engineering controls; and
pursue alternative funding mechanisms
or enforcement actions for old releases
that are stalled.

Washington State's releases are taking a long time to move through the cleanup
process and the progress of many old cleanups is stalled. There are several reasons
why many releases in the backlog are old, including: many releases are complex and
therefore take a long time to address; RPs are not moving cleanups forward quickly;
and program issues exist, such as LUST sites generally having low priority rankings
compared to other contaminated sites in ECY's cleanup program. EPA believes it is
important for ECY to explore opportunities to accelerate cleanups at older releases
and to make progress toward bringing these old releases to closure.

Releases contaminating groundwater have always been the largest part of the
national backlog and 68 percent of releases in Washington State are documented
as contaminating groundwater. In general, groundwater contamination is more
technically complex to remediate and also takes longer to clean up than soil
contamination. For old, complex cleanups where long-term remediation is underway,
EPA believes it is important for ECY to periodically reevaluate cleanup progress and
consider whether the cleanup technology being used is still optimal.

Even though soil contamination is easierto remediatethan groundwater contamination,
many of Washington State's old releases that impact soil only are unaddressed or in
the early stages of cleanup. ECY only grants no further action determinations at sites
where all contamination is addressed, including non-LUST contamination. ECY might
not consider some of the releases with soil-only contamination as closed because of
additional non-LUST contamination. Nevertheless, EPA believes ECY should continue
to make progress toward closure for all of its LUST releases.

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State Summary Chapter: Washington State

State Regional Backlogs (seepage WA-16 for more details)	Voluntary C\Q3f\ Up S (see page WA-17 for more details)

Washington Finding

Several key release
attributes, including
release age, stage of
cleanup, and media
contamination vary among
ECY's regions.

Potential Opportunity

Develop region-specific strategies for moving
releases toward remediation and closure.

Releases

Variable
number of
releases6

EPA identified differences in the backlog among ECY's four regions. For example,
areas of higher population result in larger backlogs, property transfers provide
incentives for cleanup, particularly in urban areas and differences in management
and administration of the cleanup program might also cause differences between the
ECY regions. These differences could reveal opportunities for region-specific backlog
reduction. ECY should work with its regions to address their specific backlog issues
and facilitate the sharing of information and best practices.

Washington Finding

Only 18 percent of
releases are in the
Voluntary Cleanup
Program (VCP); 82 percent
are not in the VCP.

Potential Opportunity

Encourage RPs to enroll in the VCP;

Initiate enforcement actions to help move
cleanups toward remediation; or
Develop another process to move
cleanups forward.

Releases

1,645

Since Washington State does not have a state fund, RPs pay for almost all LUST cleanup
work. Private insurance is the primary means of maintaining financial responsibility
for Washington State UST owners. A large number of releases occurred prior to
the federal or state requirements for financial responsibility. In these cases, a RP's
existing insurance policy might not cover prior releases. Therefore, paying for these
cleanups are generally "out-of-pocket" expenses for RPs. ECY implemented a fee-
based VCP to facilitate its review of assessment and cleanup documents which allows
for rapid review of work plans and reports. As its name implies, entry into the VCP is
voluntary. ECY issues No Further Action (NFA) letters for releases that completed the
VCP and met all of its requirements. ECY also issues NFA determinations for releases
addressed through ECY's formal enforcement orders and consent decrees. To date,
property transactions are the reason most releases enter ECY's VCP, but EPA believes
ECY could improve the state's cleanup rate by encouraging more RPs to enter the
VCP. For stalled releases, ECY should consider taking enforcement actions, where
appropriate, to move cleanups forward.

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State Summary Chapter: Washington State

Geographic Clusters (see page WA-18for more details)

Washington Finding

Potential Opportunity

Releases

53 percent of releases are

Target releases within close proximity for

Targeted

clustered within a one-

multi-site agreements (MSAs) or other

number of

mile radius of five or more

resource consolidation opportunities.

releases7

other releases.





ECY has a multi-site cleanup agreement initiative with Shell Oil to clean up 83
releases at different locations affiliated with the company. Another approach ECY
could use to address multiple releases is to target cleanup actions at geographically
clustered releases. The geographic cluster approach might offer opportunities for
new community-based reuse efforts, using economies of scale, and addressing
commingled contamination. EPA believes that highlighting geographic clusters of
releases and working with state and local governments in area-wide initiatives will
accelerate ECY's pace of cleaning up releases. EPA intends to work with the states to
conduct further geospatial analyses on clusters of open releases in relation to RPs,
highway corridors, local geologic and hydrogeologic settings, groundwater resources,
and/or communities with environmental justice concerns. These analyses might
reveal additional opportunities for backlog reduction.

CONCLUSION

This chapter contains EPA's data analysis of Washington State's LUST cleanup backlog
and identifies potential opportunities to reduce the backlog in Washington State.
EPA discusses the findings and opportunities for Washington State, along with
those of 13 additional states, in the national chapter of this report. EPA will work
with states to develop potential approaches and detailed strategies for reducing
the backlog. Development of strategies could involve targeted data collection,
reviewing particular case files, analyzing problem areas, and sharing best practices.
Final strategies could involve EPA actions such as using additional program metrics
to show cleanup progress, targeting resources for specific cleanup actions, clarifying
and developing guidance, and revising policies. EPA, in partnership with states, is
committed to reducing the backlog of confirmed UST releases and to protecting the
nation's groundwater, land, and communities affected by these releases.

6 Opportunities marked as "targeted number of releases" relate to geographic

opportunities that will address a limited number of releases within select designated
geographic areas.

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State Summary Chapter: Washington State

Washington State
LUST Program
At a Glance

Cleanup Rate

In fiscal year (FY) 2009, ECY confirmed 43
releases and completed 69 cleanups.8

Cleanup Financing

As of February 1994, all storage tank facilities
in Washington State were required to
have a private financial responsibility (FR)
mechanism. Forty-eight percent of open
releases were reported to ECY prior to the FR
deadline.

Cleanup Standards

The MTCA sets cleanup standards but also
allows for site-specific flexibility.

Priority System

Priority is assigned at the facility level and
incorporates both LUST and non-LUST
contamination.

Releases Per Project Manager

On average, each project manager is
responsible for 184 open releases.10

Administrative Spending (FY 2006-2007)

$1.2 million.12

PROGRAM SUMMARY

State LUST Program Organization and Administration

Responsible parties (RPs) clean up releases with varying levels of oversight from Washington State's Department of Ecology
(ECY) Toxics Cleanup Program. ECY addresses all types of contaminated sites under Washington's Model Toxics Control Act
(MTCA), including underground storage tanks (USTs). Until recently, RPs conducted the majority of leaking underground
storage tank (LUST) cleanups without ECY oversight until they submitted the final closure report. ECY staff reviewed the
report to determine if the LUST release no longer posed a threat to human health or the environment. If the cleanup met
closure standards, ECY designated the release as "Reported Cleaned Up" (RCU) in its LUST database and included the release
in the completed cleanups count reported to EPA. Over the past few years, RCU closures accounted for half the LUST closures
reported by ECY on an annual basis to EPA. As of 2009, ECY stopped using the RCU designation. Closure is now only reached
through the more formal "No Further Action" (NFA) process.

ECY provides greater oversight in the NFA process. To obtain an NFA determination, the RP must have a formal order with
ECY or enter ECY's Voluntary Cleanup Program (VCP).8 Under the VCP, the RP pays ECY a fee for cleanup oversight and report
review and approval. An RP can choose to enroll in the VCP at any time in the cleanup process, even after the final report is
submitted. Less oversight reduces the fee amount, but an RP must enroll in the VCP before ECY will review the final cleanup
report and issue an NFA determination. For sites with formal orders, ECY is involved throughout the entire cleanup process
and seeks cost recovery for all of its oversight costs.

Under the VCP, the RP must address all contamination at a facility, regardless of the source of contamination. For example, if
a LUST is present at a wood treating facility that also has pentachlorophenol (PCP) contamination, the RP must meet cleanup
standards for both the LUST and PCP contamination before the facility will receive an NFA determination, especially if the
contamination from these two sources were commingled. In contrast, under the former RCU process, ECY could report a
LUST release as cleaned up without addressing the PCP contamination. Since ECY changed its policy, RPs must address all
contaminants to achieve closure, unless the contamination is separate and distinct, in which case the site can be divided into
sub-sites which proceed separately through the VCP. According to ECY, a typical gas station is usually not divided into sub-
sites because the contamination from multiple releases is either commingled or addressed under one cleanup action (e.g.,
the releases from spills and overfills and the surface contamination of motor oil from a former service station and auto repair
facility).10

Cleanup Financing

Washington State does not have a state fund; therefore, RPs privately finance all LUST cleanups, usually through private
insurance. Washington State has a unique program to support the availability of private insurance. Washington State's
Pollution Liability Insurance Agency (PLIA) acts as the reinsurer for private insurance companies. Washington State reimburses

7	Based on FY 2009 UST Performance Measures End of Year Activity Report.

8	Formal orders include administrative orders and consent decrees.

9	Estimate provided by ECY staff.

10	According to Mike Blum, UST & LUST Coordinator, ECY Toxics Cleanup Program.

11	Estimate includes personnel and indirect costs for the LUST program.

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State Summary Chapter: Washington State

insurance companies for costs over a certain percentage of the total insurance. For
example, PLIA will cover costs between $75,000 and $1 million at releases where
$1 million policies are in place. This reinsurance approach was implemented to
help make the cost of obtaining pollution liability insurance for UST owners more
affordable, especially for small businesses and local government.

In Washington State, RPs must cover the federal FR requirement. The FR requirement
was phased in between 1989 and February 18, 1994, for all releases except those
located on tribal lands, which occurred later. In the current backlog, ECY confirmed
38 releases prior to January 1,1989, and 926 releases between January 1,1989, and
February 18, 1994. Therefore, RPs for these 964 releases might not have had an FR
mechanism in place on the date of the release. However, 82 percent of these 964
open releases (794 releases) are in remediation, suggesting the RPs have funding for
at least some of the cleanup activities. The remaining 170 releases could be potential
orphan cleanups. These releases were confirmed prior to February 18,1994, and the
RPs have not begun remediation.12

If an existing UST facility was sold after February 1994 and no site assessment was
conducted to determine if a release had occurred, the later discovery of a release
would likely not be covered under either the existing (new) insurance policy or the
former policy. The pollution liability insurance policies are "claims-made" policies,
and policies only include a six-month insurance extension or "tail." If a claim for a
release is not made within six months of the expiration of the policy, that release is
not covered under the policy. Generally, new owners of existing UST facilities buy
new policies, which resets the retroactive coverage date. While buying an UST facility
without first determining if the site is contaminated is not a good business practice,
there are no regulatory requirements for doing so. The new owner incurs the liability
for the pre-existing contamination. However, without adequate monetary resources
and no insurance coverage, the contamination often is not addressed. Also, the
amount of the insurance deductible payment required of the policyholder can
sometimes be an impediment to initiating cleanup action by the site owner.13

review and all LUST and non-LUST contaminants at a facility must meet Washington
State's cleanup levels as defined in the MTCA.14

Release Prioritization

The MTCA requires ranking of all contaminated sites, including LUSTs, relative to each
other based on the level of risk to human health and the environment. ECY ranks all
sites on its Hazardous Sites List based on information collected during a site hazard
assessment. Scores range from high priority (1) to low priority (5). Facilities with
only LUST contamination are often ranked low priority because the single exposure
pathway is groundwater and the contaminants pose relatively lower risk to receptors.15
LUST releases with multiple exposure pathways are given higher priority. However,
in determining the level of priority, ECY also takes into account the availability of
oversight funds, the potential cost of cleanup, the media contaminated, the level
of cooperation shown by an RP, and the public concern about the release.16 Rank
does not play a role for cleanups in the VCP. In addition, facilities for which there
is a cooperative funding agreement in place, such as some Department of Defense
facilities, might be given higher priority than indicated by their hazard ranking.

The MTCA requires that all sites be ranked to determine their relative priority to all
other sites. Sites that are placed on the Confirmed and Suspected Contaminated
Sites (CSCS) List get scheduled for a Site Hazard Assessment so the priority ranking
can be completed. All cleanup sites, including LUST sites, are evaluated using the
Washington Ranking Method (WARM). That screening model evaluates risks to
human health and the environment based on various predefined exposure pathways.
Because more sites need ranking than there are resources available to complete that
work, sites to be ranked are also prioritized. Generally, sites assumed to be a greater
risk (higher priority) to human health and the environment are ranked before those
that would likely be lower-risk sites. Based on the data provided for this study, 194 of
the 886 releases on the CSCS List (22 percent) had a priority rank. None of the 1,117
sites still on the LUST List had been ranked.

Cleanup Standards

ECY used to allow RPs to set site specific cleanup standards as long as they met
Washington State's established cleanup levels for total combined risk. Previously, a
LUST release could achieve RCU status when it had met its cleanup standards based
on an informal review. ECY no longer makes RCU determinations. However, in order
for a LUST release to achieve an NFA determination, ECY must do a formal detailed

12	Pre-remediation releases include those releases where assessments have either not
begun or have not been completed.

13	According to Mike Blum, UST & LUST Coordinator, ECY Toxics Cleanup Program.

14	Washington State maintains a Web-based tool, Cleanup Levels and Risk Calculations, to
help parties performing cleanups choose appropriate site cleanup levels according to
MTCA Chapter 173-340 of the Washington Administrative Code
(fortress.wa.eov/ecv/clarc/CLARCOverview.aspx).

15	According to Mike Blum, UST & LUST Coordinator, ECY Toxics Cleanup Program.

16	According to ECY Focus Sheet 91-107, available online at:
www.ecv.wa.eov/biblio/ftc91107.html.

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State Summary Chapter: Washington State

State Backlog Reduction Efforts

In recent years, ECY conducted file reviews of approximately 1,000 releases to identify
releases that could be closed with minimal effort. Of these, 150 releases were given
RCU status. In a separate effort, ECY used an EPA grant to hire contractors to assess
approximately 120 releases classified by ECY as being in "monitoring" status. As of
August 2009, ECY determined these releases required either continued sampling
from existing wells, additional site characterization or additional cleanup effort
before qualifying for NFA determinations. In another effort, ECY initiated a multi-
site agreement (MSA) project. ECY worked with EPA staff through an interagency
personnel agreement to identify a set of potential participants covering both releases
and companies. Subsequent to that effort, ECY entered into a MSA with Shell Oil.17
This agreement includes cleanups over the next 10 years at 83 releases in the
Northwest region of the state and, if ECY determines it is successful, the MSA might
be expanded to include the entire state. In the future, ECY will consider whether
to pursue additional MSAs with other companies that have large numbers of open
releases.

17 For more information, see:

www.ecv.wa.eov/proerams/tcp/sites/vcp sites/vcpQverview.htm.

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State Summary Chapter: Washington State

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State Summary Chapter: Washington State

LUST Data Source

Electronic data for LUST releases occurring
between October 1979 and February 2009
were compiled with ECY staff in 2008 and
2009.21 Data were obtained from ECY's CSCS
List and Integrated Site Information System
(ISIS) database and selected based on quality
and the ability to address areas of interest in
this analysis.

ANALYSIS AND OPPORTUNITIES	

In this study, EPA analyzed Washington State's federally-regulated releases that have not been cleaned up (open releases).
EPA conducted a multivariate analysis on all of ECY's data. However, this technique did not identify strong underlying patterns
in the data.18 Next, EPA divided the open releases into groups that might warrant further attention. EPA used descriptive
statistics to examine the distribution of releases by age of release and stage of cleanup and highlighted findings based on ECY's
data.19 EPA then identified potential opportunities for addressing particular groups of releases in the backlog. Many releases
are included in more than one opportunity. These opportunities describe actions that EPA and ECY might use as a starting
point for collaborative efforts to address the backlog. Although EPA's analysis covered all releases in Washington State, there
are 116 releases that are not included in any of the subsets identified in the findings or opportunities due to the way EPA
structured the analysis. These releases might also benefit from some of the suggested opportunities and strategies.20

EPA's analyses revealed five areas of Washington State's backlog where there are potential opportunities for its further
reduction:

•	Stage of cleanup	• State regional backlogs	• Geographic clusters

•	Media contaminated	• Voluntary cleanups

Data Limitation

In an effort to consolidate tracking of contaminated sites, ECY is in the process of transferring all LUST release data from
its LUST-specific database within ISIS to its CSCS database also within ISIS. At the time of this analysis, 56 percent of open
releases had been transferred into the CSCS database. The LUST and CSCS databases track unique data fields related to
each contaminated site, so certain release characteristics (e.g., cleanup priority) were not available for all releases in this
analysis. Efforts to combine the two datasets yielded complete data attributes for the 17 percent of open releases that were
present on both lists.

The LUST and CSCS databases each maintain a data field indicating releases with RCU status that are considered closed and
are therefore reported to EPA as cleanups completed. For this analysis, all releases with RCU status were considered closed
and all remaining releases were counted as open. The 1,416 LUST releases that have received NFA determinations are not
tracked in either the LUST or CSCS databases and therefore fewer release-level data were available for this analysis. Sites
that receive an NFA determination are tracked in ECY's NFA Sites List. All releases with NFA determinations were included
in the overall closure count.

18	The analytic tree method, a multivariate technique used to identify underlying patterns among large data sets, did not reveal strong
patterns within the data. For more information on analytic trees, see Appendix A.

19	For a detailed description of release stages, see the Chapter Notes section (Stage of Cleanup Reference Table).

20	For a detailed description of the Washington State data used in this analysis, see the Chapter Notes section.

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State Summary Chapter: Washington State

STAGE OF CLEANUP

Washington Finding

15 percent of releases:

•	have not finished site assessment; and

•	are 10 years old or older.

Potential Opportunity	Releases

Provide information and	305

technical assistance to RPs

or implement enforcement

actions at old releases.

Encourage RPs and

stakeholders to examine

public and private funding

options.

As of February 10, 2009, the Washington State backlog consisted of 2,003 open releases. EPA analyzed the age of these
LUST releases and their distribution among the stages of cleanup. To facilitate analysis, EPA classified Washington State's
open releases into two stages of cleanup: the Pre-remediation stage (releases where site assessments have begun) and the
Remediation stage (releases where remedial activities have started).21 While EPA grouped the releases into linear stages for
this analysis, EPA recognizes that cleanups might not proceed in a linear fashion. Cleanup can be an iterative process where
releases go through successive rounds of site assessment and remediation. However, in the long run, this approach might be
both longer and more costly. Acquiring good site characterization can accelerate the pace of cleanup and avoid the extra cost
of repeated site assessment.

Since Washington State's LUST program began, ECY has closed 4,411 releases, half of which were closed in less than 3.6 years
(Figure 1 below). Of these releases, 2,995 (68 percent) were closed through ECY's RCU status and the remaining 1,416 releases
(32 percent) were closed with NFA determinations. The young median age of closed LUST releases might be attributable to
the rapid closure of relatively easy to remediate releases. Also, national program policy allows states to report confirmed
releases that require no further action at the time of confirmation as "cleanup completed." Therefore, some releases are
reported as confirmed and cleaned up simultaneously. In general, in the early days of the LUST program (pre-1998) when
many USTs were being removed and legacy contamination was being discovered, ECY did not classify a number of those as
LUST sites if the cleanup involved removal and disposal of only a small volume of contaminated soil. That small volume of soil
was considered incidental during removal of tanks and piping. Therefore, the total number of LUST sites in Washington State
would have been larger and the percentage of cleanups completed would also have been higher.

Figure 1. Age of Releases among Stages of Cleanup

20	1-485

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State Summary Chapter: Washington State

ECY initiated two projects to look for releases that could be closed with minimal effort.22 ECY staff closed 150 releases based
on file reviews and are currently pursuing final sampling at another group of releases with groundwater contamination. States
might find opportunities for closure with minimal effort at lower priority releases where little or no remedial work is required
to reach closure standards or at releases that have met closure standards but have not finished closure review.

LUST releases in the ECY's backlog are significantly older than closed releases. According to ECY, nearly all LUST releases have
completed site assessments, although EPA cannot confirm this with the available data. Figure 2 below shows the backlog of
open releases by age and stage of cleanup and allows for the identification of older releases by stage. Figure 2 shows there are
305 releases in the Pre-remediation stage (15 percent of the backlog) that are 10 years old or older. ECY's data indicate that
these releases have not moved into remediation quickly. Providing information and technical assistance to RPs, encouraging
the use of the VCP or pursuing enforcement action of old releases could move releases toward remediation and more rapid
cleanup. ECY has initiated a regular process of sending letters to RPs every one-to-two years to encourage cleanup activities.
ECY should encourage RPs and communities to look at other funding options such as other public and private funding sources
to facilitate assessment, cleanup, and reuse. Where there is no viable RP, ECY can encourage the use of petroleum brownfields
grants for low priority releases.

Stages of Cleanup

Washington State has many old
releases in the Remediation stage.
Approximately 75 percent of all open
releases (1,485 releases) are in the
Remediation stage (Figure 1). Fifty-
nine percent of Washington State's
releases (1,191 releases) are in the
Remediation stage and are 10 years
old or older (Figure 3, page 14). This
older group of releases represents
80 percent of the releases in the
Remediation stage. The data might
overinflate the numbers of releases

actually in remediation. In ECY's data management process, when a LUST release entered the remediation phase, its status
in the database was changed to "cleanup in progress." The classification of "cleanup in progress" would have been given to a
release where initial soil removal was implemented. However, in many cases, the impacted groundwater issues were never
addressed and the state database shows no further work is currently "in progress." ECY's current practice is to not move
releases backwards in its status even if the site has been stalled for many years. So, for many sites that are in the Remediation
stage, initial cleanup might have occurred years ago but no further work is currently being conducted.23

Pre-remediation
(518 Releases)

Remediation
(1,485 Releases)

Washington Finding

59 percent of releases:



• are in remediation; and



• are 10 years old or older.





Potential Opportunity

Releases

Use a systematic process to
explore opportunities to accelerate
cleanups and reach closure, such
as:

•	periodic review of
release-specific treatment
technologies;

•	review of site-specific cleanup
standards;

•	consider use of institutional
or engineering controls; and

•	pursue alternative funding
mechanisms or enforcement
actions for old releases that
are stalled.

1,191

Because EPA only has the date that a release was confirmed but not for when it moved from one stage to the next (i.e., from
assessment to remediation), EPA can calculate the overall age of the release but not the actual time spent in the Remediation
stage. It is possible that some of these releases might have only recently begun remediation. Increasing efficiency and

22	See State Backlog Reduction Efforts in the Program Summary.

23	According to Mike Blum, UST & LUST Coordinator, ECY Toxics Cleanup Program.

Figure 2. Release Age Distribution among

1

< 1%

< 10 Years
212
41%

> 10 Years
305
59%

September 2011

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State Summary Chapter: Washington State

Washington Finding

43 percent of releases:



• contaminate groundwater;



• are in remediation; and



• are 10 years old or older.





Potential Opportunity

Releases

Systematically evaluate cleanup	858

progress at old releases with
groundwater impacts and consider
alternative cleanup technologies
or other strategies to reduce time
to closure.

getting releases through the cleanup process as quickly as possible will expedite the reduction of the backlog. ECY should
establish a systematic process to evaluate existing releases in remediation and optimize cleanup approaches, including choice
of technology and site-specific risk-based decision-making. This process might save ECY resources and bring releases to
closure more quickly. If releases are stalled, ECY should encourage RPs and stakeholders to pursue alternative public and
private funding sources, particularly petroleum brownfields grants in the case of low priority releases with no viable RP. ECY
should also consider enforcement actions against RPs that are not moving forward with cleanups.

MEDIA CONTAMINATED

Groundwater is an important natural resource at risk from petroleum contamination. Releases impacting groundwater make
up the majority of Washington State's backlog. In general, groundwater contamination takes longer and is more expensive
to clean up than soil contamination. In this study, EPA examined media as a factor contributing to the backlog. The following
analysis classified media contamination into four categories: groundwater (1,364 open releases), soil (630 open releases),
other media, which includes vapor and surface water (seven open releases), and "unknown" media, which includes releases
with no media specified (two open releases).24

In Washington State, 68 percent of open releases (1,364 releases) involve groundwater contamination; these releases
have a median age of 15.0 years (Figure 3 below). In contrast, only 22 percent of closed releases (976 releases) impacted
groundwater. These closed releases have a significantly younger median age of 5.6 years compared to the median age of
open releases (Figure 3). Of the 1,065 Remediation stage releases that impact groundwater, 81 percent (858 releases) are
10 years old or older (Figure 4, page 15). This subset of older releases that contaminate groundwater and are in remediation
accounts for 43 percent of Washington State's total backlog. Groundwater contamination is typically more complex and
difficult to remediate. However, if ECY could identify opportunities to improve cleanup efficiency, ECY might be able to
accelerate the pace of cleanups. For example, encouraging RPs to reevaluate the cleanup progress, current contaminant
levels, and treatment technologies might move releases through remediation faster.

Figure 3. Age of Releases by Media Contaminated and Stage of Cleanup

_0J

a>
cc

U—

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State Summary Chapter: Washington State

The use of institutional or engineering controls can also reduce the time to closure by eliminating exposure pathways and
allowing for less stringent cleanup standards, where protective and appropriate. ECY has occasionally used institutional
controls as a remedy to minimize exposure to contamination. For example, restrictive covenants have been in place at 31
closed releases since 1991.

According to ECY, there are additional institutional controls used through the NFA process, but data were unavailable for this
analysis. ECY has implemented a formal five-year review process for releases with institutional controls to ensure the cleanups
are still protective of human health and the environment.

Releases that contaminate soil only represent a potential threat to groundwater resources and contaminate properties in
neighborhoods and communities. Contaminated soil can typically be cleaned up faster than contaminated groundwater.
Most of Washington State's releases with soil contamination have been closed, but those releases that remain open are
significantly older than the closed releases with soil-only contamination. Thirty-one percent of the Washington State backlog
(630 releases) involves soil contamination and has a median age of 14.1 years, compared to 78 percent of closed releases
(3,426 releases), half of which were closed in less than 2.8 years (Figure 3). ECY might not consider some of these soil cleanups
closed because they are sites with additional non-LUST contamination present. However, 118 soil cleanups (6 percent of the
backlog) have not begun remediation 10 years or more after the release was confirmed (Figure 5 below).

ECY can encourage RPs to use expedited site assessments to help rapidly characterize site conditions and move releases into
remediation and to closure sooner. One of the tools available to both regulators and RPs is EPA's Expedited Site Assessment
(ESA) guide.25 The guide explains the overall ESA process as well as specific site assessment tools and methods. Conducting
site assessments efficiently and quickly can help reduce the backlog.

Figure 5. Age Distribution of Pre-remediation Stage Releases with Soil Impacts

Age Unknown
1

< 1%

> 10 Years
118
55%

< 10 Years
96
45%

Washington Finding

6 percent of releases:

•	impact soil only;

•	have not finished site assessment; and

•	are 10 years old or older.

Potential Opportunity

Continue to use targeted
backlog reduction efforts to
close old releases with soil
contamination with minimal
effort.

Encourage RPs to use
expedited site assessment to
move releases more quickly
into remediation.

Releases

118

Figure 4. Age Distribution of Remediation Stage
Releases with Groundwater Impacts

< 10 Years
207
19%

10 Years
858
81%

25 EPA's 1997 guidance document, Expedited Site Assessment Tools for Underground Storage Tank Sites: A Guide for Regulators (EPA 510
B-97-001), is available online at: www.epa.eov/OUST/pubs/sam.htm.

September 2011

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State Summary Chapter: Washington State

Washington Finding

Several key release attributes, including
release age, stage of cleanup, and media
contamination vary among ECY's regions.

Potential Opportunity	Releases

Develop region-specific	Variable

strategies for moving releases number of
toward remediation and closure. releases27

Figure 6. ECY Regions

STATE REGIONAL BACKLOGS

EPA analyzed the cleanup backlogs in ECY's four regions to identify patterns and opportunities for developing targeted backlog
reduction strategies within each region. There are significant differences in media contamination and release age among
the releases managed by ECY's four regional offices (Figure 6 below left and Table 1 below). The more densely populated
Northwest and Southwest regions include the majority of releases. More than half of all open releases (1,055 releases) are
located within the Northwest region (Figure 7 below). Releases with groundwater contamination also predominate in these
two regions (Table 1). In contrast, soil contamination is more common in the Central and Eastern regions (Table 1). The
Northwest and Southwest regions have large numbers of old releases in the Pre-remediation stage (Table 1 and Figure 7).
The Southwest region is the only region where there are more releases in the Pre-remediation stage than in the Remediation
stage (Table 1 and Figure 7). Urban areas with larger populations can create greater financial incentives for cleanup due to
property transfers. A strategic regional approach to these unique backlog characteristics should help reduce the backlog. EPA
encourages ECY to look for opportunities to share best practices among its regions and with other states.

Table 1. Washington State Backlog, by ECY Region



SOUTHWEST

NORTHWEST

CENTRAL

EASTERN

HEADQUARTERS28

State Backlog Contribution

25%

53%

12%

7%

3%

Cumulative Historical Releases

1,742

3,117

691

769

95

Closed Releases

1,237/71%

2,062/66%

440/64%

632/82%

40/42%

Open Releases	505/29%	1,055/34%	251/36% 137/18%	55/58%

Stage of Cleanup

Pre-remediation

293/58%

134/13%

59/24%

18/13%

14/25%

Remediation

212/42%

921/87%

192/76%

119/87%

41/75%

Media Contaminated

Groundwater

363/72%

758/72%

146/58%

84/61%

13/24%

Soil

141/28%

293/28%

102/41%

53/39%

41/74%

Other

1/ < 1%

4/ < 1%

1/ < 1%

-

1/2%

Unknown

-

-

2/ 1%

-

-

Median Age of Open Releases

13.3 years

15.4 years

14.5 years

14.3 years

16.2 years

Figure 7. Age of Release by Region and Stage of Cleanup

20

0

15
10

5	2'™2	14

7

o Pre-remediation
0 Remediation
¦ Closed

18
O

Southwest	Northwest	Headquarters	Central	Eastern

26	Opportunities marked as "variable number of releases" affect an unknown number of releases potentially including all open releases.

27	While ECY Headquarters is not an official ECY region, it is listed as the "responsible unit" for 55 open releases and was therefore
analyzed as a region. ECY Headquarters manages federal facilities in the western part of the state.

WA-16

September 2011


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State Summary Chapter: Washington State

VOLUNTARY CLEANUPS

RPs privately finance all LUST cleanups in Washington State typically by private insurance. Therefore, a lack of funds should
not be a cause of delayed remedial activities. Until 2009, RPs conducted most cleanup activities independently. ECY was only
involved at the end of the process, reviewing documents to make sure that risks were adequately addressed. If ECY's review
determined that a cleanup was complete, ECY applied a RCU status to the release and reported it as closed to EPA. In these
cases, ECY did not issue an NFA determination letter. RPs must enter the VCP or be subject to an administrative order or
consent decree to receive an NFA determination.

In the current backlog, 82 percent of the releases (1,645 releases) are independent cleanups that are not in the VCP (Figure
8 below). As of 2009, ECY no longer uses the RCU process and cleanups are not considered complete unless RPs receives
an NFA determination through the VCP or an order or decree. The consequence of this process change is that releases from
RPs that do not enroll in the VCP or have an enforcement order will be considered open indefinitely. ECY notes the following
advantages to the change in the closure process for independent cleanups; the NFA determination is based on a more rigorous
review than the RCU process and addresses all contamination issues at that facility; and the NFA determination is a letter that
RPs can "take to the bank" to identify the site as cleaned up for property transaction and loan purposes. The RCU process
was a less rigorous review and resulted in a less formal opinion from ECY. The review was focused solely on the LUST issues
at a facility. Also, the RCU process was implemented primarily for ECY and EPA reporting purposes and it was not a fee-based
review.

Washington Finding

Only 18 percent of releases are in the VCP; 82
percent are not in the VCP.

Potential Opportunity	Releases

Encourage RPs to enroll in the 1,645
VCP;

Initiate enforcement actions
to help move cleanups toward
remediation; or
Develop another process to
move cleanups forward.

Figure 8. Age of Releases by VCP Participation and Stage of Cleanup21

20

15

10

0

CD

01
<

300

A

460

1,185

A

w

O

W

58

o



O Pre-Remediation
0 Remediation

Voluntary
Cleanup
Program

Independent
Cleanup

Within the current backlog, independent cleanups in the Pre-remediation stage are significantly older than pre-remediation
releases enrolled in the VCP. Twelve percent of open releases (230 releases) are independent cleanups that have not yet
begun remediation 12.5 years or more since the releases occurred, compared to the 5.8-year median age of Pre-remediation
stage VCP releases (Figure 8). Most RPs enroll in the VCP for property transactions and therefore have a financial incentive
to move the cleanups forward. ECY's encouragement of RPs to enroll in the VCP and/or their increased use of enforcement
actions could help to move cleanups toward remediation.

28 The Independent Cleanup designation includes 42 releases addressed under formal actions.

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State Summary Chapter: Washington State

Although most cleanups are addressed independently by RPs, 18 percent of open releases (358 releases) are currently being
addressed through the VCP (Figure 8). The majority of the VCP releases are in the Remediation stage, 42 percent of which
(150 releases) are more than 15.5 years old. The age gap between releases in the Pre-remediation and Remediation stages
in the VCP is likely due to variable ages of releases entering the VCP (Figure 8). For example, a release might wait 15 years
without remediation and then enter the VCP due to a property transaction. Over the past five years, ECY has received
approximately 300 VCP applications annually, and approximately 810 cleanups have been completed under the VCP during
that period.29 Because ECY no longer issues RCU determinations for independent cleanups, ECY should encourage RPs to
enter the VCP, conduct enforcement actions, or develop other requirements to ensure that RPs will make progress cleaning
up and closing releases.

GEOGRAPHIC CLUSTERS

Washington Finding

53 percent of releases are clustered within a
one-mile radius of five or more other releases.

Potential Opportunity

Target releases within close
proximity for MSAs or other
resource consolidation
opportunities.

Releases

Targeted
number of
releases31

Figure 9. Map of All Open Releases, by ECY
Region

Spokane

EPA performed a geospatial analysis to look for alternative ways to address the backlog. While releases in geographic
clusters might not have the same RP, they tend to be located in densely populated areas and might present opportunities to
consolidate resources and coordinate efforts. Geographic proximity can call attention to releases in areas of interest such as
redevelopment, environmental justice, or ecological sensitivity.

State and local governments can utilize geographic clusters for area-wide planning efforts. EPA's analysis identified 1,055
open releases (53 percent of open releases) located within a one-mile radius of five or more other open releases (Figure
9 below left). Of these releases, 576 (29 percent of open releases) are located within a one-mile radius of 10 or more
other open releases. Approaching the assessment and cleanup needs of an area impacted by LUSTs can be more effective
than focusing on individual sites in isolation from the adjacent or surrounding area. Considering geographically-clustered
releases might pave the way for new community-based revitalization efforts, utilize economies of scale to yield benefits such
as reduced equipment costs, and present opportunities to develop multi-site cleanup strategies, especially at locations with
commingled contamination. ECY has recently approached cleanup in Montesano, Washington, based on a geographic cluster
where three adjacent sites are being addressed simultaneously through separate agreed orders. EPA encourages states to
look for opportunities for resource consolidation and area-wide planning but also recognizes that this approach is best geared
to address targeted groups of releases such as Washington's Montesano initiative as opposed to a state-wide opportunity for
every cluster of releases. EPA also recognizes that state laws and regulations might present implementation challenges. For
example, in Washington State, if two (or more) facilities have commingled plumes, then ECY considers and addresses those
programs as one cleanup site. If the contamination is not commingled, however, they must then be treated as individual
sites. EPA intends to conduct further geospatial analyses on clusters of open releases in relation to RPs, highway corridors,
local geologic and hydrogeologic settings, groundwater resources, and/or communities with environmental justice concerns.
These analyses might reveal additional opportunities for backlog reduction.

29	According to Mike Blum, UST & LUST Coordinator, ECY Toxics Cleanup Program.

30	Opportunities marked as "targeted number of releases" relate to geographic opportunities that will address a limited number of
releases within select designated geographic areas.

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State Summary Chapter: Washington State

Washington State LUST
Program

Contact Information

Washington State Department of Ecology

Toxics Cleanup Program
Underground Storage Tank / Leaking
Underground Storage Tank Section
P.O. Box 47600
Olympia, WA 98504-7600

Phone: 360-407-7170
Fax: 360-407-7154

www.ecv.wa.gov/programs/tcp/ust-lust/
tanks.html

CONCLUSION

In this state chapter, EPA presented the analysis of LUST data submitted by ECY and highlighted information on Washington
State's LUST program. Based on the analytic results, EPA identified potential opportunities that could be used to address
specific backlog issues within Washington State. Over the course of the entire study, EPA also analyzed data from 13 other
states. Findings and opportunities that apply to all 14 states are discussed in the national chapter of the report. Each
opportunity represents one potential approach among many to address the backlog. Discussion of the opportunities as a
whole is intended as a starting point for further conversations among EPA, ECY, and the other states on strategies to reduce
the backlog. Development of the strategies might include targeted data collection, reviewing particular case files, analyzing
problem areas, and sharing best practices. The strategies could also involve actions from EPA, such as using additional
program metrics, targeting resources for specific cleanup actions, clarifying and developing guidance, and revising policies.
EPA, in partnership with states, is committed to reducing the backlog of confirmed UST releases and to protecting the nation's
groundwater and land and the communities affected by these contaminated releases.

September 2011

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State Summary Chapter: Washington State

CHAPTER NOTES

WASHINGTON STATE DATA BY ATTRIBUTE

The following table provides details on the data elements of interest in this analysis. Data were provided by ECY staff in 2008 and 2009 for use in this analysis. Several data
elements of interest could not be addressed with the information available. All available data elements were analyzed and only those data elements that revealed informative
patterns of interest are included in the report.

1 Data Element

Washington State Data

Use in Analysis 1

Administrative Cost

Estimates were provided by ECY staff.

Included in the "Program Summary"
section and in the national chapter.

Age

Age was calculated for closed releases by subtracting the confirmed release date from the closure date and dividing by
365. Age was calculated for open releases by subtracting the confirmed release date from the data date and dividing by
365. Any values less than -.1 were left blank. Values between -.1 and 0 were counted as 0. All dates were rounded to one
decimal point. Ages of releases with insufficient or invalid data were left blank.

Variable in all analyses.

Cleanup Financing

Washington State does not have a state fund and no data on private financing mechanisms were available.

Not applicable.

Cleanup Standards

No site-specific data available.

State-wide standards examined in the
national chapter.

Closure Date

Data were obtained from the date field "Release Status Change Date" in "LUSTList_data.xls" and from the "STATUSDATE" in
"WA_RawDatal009." The former corresponds with releases that achieved an RCU status and the latter corresponds with
releases that achieved an NFA status.

Included in the calculation of release age.

Confirmed Release Date

Data were obtained from the "Release Notification Date" field in the "LUSTList_data.xls" and "WA_RawDatal009.xls" files.

Included in the calculation of release age.

Data Date

February 10, 2009, is used for all records. This is the date the data were sent.

Included in the calculation of release age.

ECY Region

Data were obtained from the data field "Responsible Unit" in "LUSTList_data.xls" downloaded from ECY's ISIS Web site.
There are four ECY regions in Washington State: Central, Eastern, Northwest, and Southwest. Headquarters is also included
as an entry in this field.

Examined in "Regional Differences"
section.

Federally-Regulated
LUST Releases

All releases in the "LUSTList_data.xls" file are federally-regulated LUST releases.

Identifies the appropriate universe of
releases for analysis.

Free Product

No data available.

Not applicable.

Institutional and
Engineering Controls

Data were obtained from the "TYPE" data field (when "TYPE" = "Restrictive Covenant") in the "UECARgistry_data.
xls" ("Environmental Covenant Registry") from ECY's ISIS website. However, this list only tracks releases that have left
contaminants on site and require a five-year review process. There are only records of institutional controls for 31 releases.

Data not suitable for analysis.

Latitude and Longitude

Data were obtained from the "Latitude" and "Longitude" fields in the "LUSTList_data.xls" file. Where possible, coordinates
for releases without existing latitude and longitude values were obtained by EPA staff by geocoding address and street
locations.

Used in geospatial analysis calculating the
number of open releases within a one-
mile radius of other open releases.

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State Summary Chapter: Washington State

Data Element

Washington State Data

Use in Analysis

Media

Data were obtained from the "Media" field in the "LUSTList_data.xls" file (see Media Reference Table). Releases with
groundwater contamination marked (in addition to any other media) were counted as "groundwater." Releases with only
soil contamination marked were counted as "soil." Releases with any other combination of media were counted as "other."
"Unknown" releases might include those releases for which there are no data available in the database, but for which
information is available in other files and releases for which the type of media contaminated is truly unknown. Note that
ECY is in the process of eliminating drinking water as a media choice and moving those few releases into the groundwater
category.

Examined in the "Media Contaminated"
section.

Monitored Natural
Attenuation (MNA)

Data were obtained from the "TLU COMMENT DS" field in the "r tab lust non nfa rcu w contam.xls" file. Releases
with the value "GW - Monitored Natural Attenuation" were marked as using MNA. These data were only tracked since
2000 and only 12 releases met these criteria.

Data not suitable for analysis.

Methyl Tertiary Butyl
Ether

Data were obtained from the "CTLU COMMENT DS" data field in "r tab lust non nfa rcu w contam.xls." These data
were only tracked since 2000.

Data not suitable for analysis.

Number of Releases
per RP

No data available.

Not applicable

Orphan	ECY has an "abandoned" data field to mark abandoned sites in its UST and LUST databases. This status designation is not Data not suitable for analysis,

routinely used and there is not a clear ECY definition available to indicate which releases qualify as "abandoned." Some
LUST releases are truly abandoned, whereby the site owner/operator is no longer present or viable and the property has or
might default back to a prior owner, bank, or locality due to back taxes or lack of mortgage payments. Other "abandoned"

LUST releases might have an owner/operator but the parties might have no financial resources to affect a cleanup. ECY staff
does not recommend using this data field to draw any conclusions.

Proximity	Geospatial analysis performed by EPA revealed the number of other open releases located within a one-mile radius of each Examined in the "Geographic Clusters"

open release.	section.

Public Spending	Data were obtained from the "Grant Amount" field in the "AIIGrantsJd of New and LUST.xls" file. This data set contains Data not suitable for analysis,

information on the amount of public grant money awarded for 30 LUST cleanups between 1997 and 2009. However,

ID numbers to link these data to other release-level information are not available. The average grant amount per LUST
cleanup based on this data set is $256,044; the average project cost per LUST cleanup based on the same data set is
$412,206, indicating that public spending is only a portion of the overall cleanup cost. Because the grant money was spent
over several years but reported as a cumulative sum, inflation adjustment is not possible.

Release Priority	Data were only available on the CSCS List, which contains only a subset of LUST releases (ECY is in the process of moving all No informative patterns were identified.

LUST release data to the CSCS List). Data that are available only on the CSCS List are at the facility level and can be linked
only to individual releases through facility IDs. Accordingly, the priority rank for a facility on the CSCS List will be assigned
to all releases at that facility. In addition, because this priority rank is based on all contamination, not just LUST-related
contamination, LUST releases are in general low priority. Therefore, this data field would not indicate priorities among LUST
releases.

RP

No data available.

Not applicable.

RP Recalcitrance

No data available.

Not applicable.

Site Owner Type

Data were obtained from the "ownertyp ds" field in the "r tab lust non nfa rcu w contam.xls" file. These data were
only tracked since 2000. The type of owners that ECY tracks include: Private, Municipal (City/PUD/Town/Port), County,
Federal, State, Mixed, Public School, and 1872 Mining Law.

No informative patterns were identified.

September 2011

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State Summary Chapter: Washington State

I Data Element

Washington State Data

Use in Analysis 1

Staff Workload

Estimates provided by ECY staff.

Examined in the "Program Summary"
section and in the national chapter.

Stage of Cleanup

Data were obtained from the "Release Status" field in the "LUSTList_data.xls" file downloaded from ECY's ISIS website. ECY
uses several release statuses, such as "Awaiting Cleanup," "Cleanup Started," "Reported Cleaned Up," and "Monitoring"
(see Stage of Cleanup Reference Table). There is not an easy way to further separate open releases into Confirmed Release
and Site Assessment stages. In Washington State, a site assessment is usually completed to confirm a release.

Variable in all analyses.

Status	Data were obtained from the "Release Status" data field in the "LUSTList_data.xls" file downloaded from ECY's online Identifies the appropriate universe of

ISIS website. When a release had an RCU status, it was marked as "Closed;" other releases were marked as "Open." In releases for tree analysis.

Washington State, "closed releases" are those releases with an RCU status or NFA determination. An NFA determination is
a formal determination from ECY. An RCU status is not a formal agency determination. A list of additional releases closed
with NFA determinations was obtained from the "r_tab_lust_nfa_excel_version_4_epa_10-7-09.xls" file. These releases
were counted as closed.

VCP	Data were only available on the CSCS List, which contains a partial subset of LUST releases. (ECY is in the process of moving Examined in the "Cleanup Oversight"

all LUST release data to the CSCS List.) Data that are available only on the CSCS List are at the facility level and can be linked section,
to individual releases only through facility IDs. However, because LUST releases were added to the CSCS List when they
entered the VCP, this data element is representative of the majority of releases in the VCP.

Media Reference Table

Each release was assigned to a single media type for this analysis, based on the ECY
Media data.

Stage of Cleanup Reference Table

Each release was assigned to a specific stage of cleanup for this analysis, based on the
ECY Release Status. Releases represented in a supplemental list of releases closed
with NFA determinations were counted as closed.

ECY Media	Analysis	^	Stage in this Analysis

Air	Other	Awaiting Cleanup	Confirmed Release/Site Assessment

Drinking Water	Groundwater	Other	Confirmed Release/Site Assessment

Groundwater	Groundwater	Unknown	Confirmed Release/Site Assessment

Sediments (Underlying Water) Other		Cleanup Started	Remediation

Soil	Soil	Monitoring	Remediation

Surface Water	Other	Reported Cleaned Up	Closed

Unknown	Other

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September 2011


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