Leaking Underground Storage Tanks Corrective Action Resources
Release Discovery and Confirmation
- Release sources
- Warning signs of a release
- Release confirmation
- Regulatory notification
- Immediate response actions
A typical leaking underground storage tank (LUST) scenario involves the release of a fuel product from an underground storage tank (UST) that can contaminate surrounding soil, groundwater, or surface waters, or affect indoor air spaces. Early detection of an UST release is important, as is determining the source of the release, the type of fuel released, the occurrence of imminently threatened receptors, and the appropriate initial response. The primary objective of the initial response is to determine the nature and extent of a release as soon as possible.
Warning signs of a release can be identified through inspection and monitoring, inventory control, and leak-detection technology. Once the release is confirmed, notification to the appropriate government agency must follow particular state or tribal requirements.
In some cases, emergency response actions must be taken immediately without waiting for government approval or oversight. Initial actions are all focused on protecting public health, safety, and the environment. Under most state regulations, the operator or owner has specific time frames to conduct initial response actions, submit reports, complete an initial site characterization, and conduct free product removal. It is important that LUST personnel reinforce these required targets in the event that an enforcement action becomes necessary.
Identifying the specific portion of the tank or tank system that has caused a subsurface release is a critical first step. Common vulnerable areas include the bottoms of USTs (particularly underneath the manhole where gauging sticks are or were formerly used), associated piping, UST fill manholes, dispensing pumps, and areas known likely to have installation issues. Piping failures are especially common at UST junction points and when ground settlement in the vicinity of an UST varies from one end of a tank to the other.
Many states have conducted studies on the sources and causes of releases. Links to some of these studies are provided below, but there may be additional information available from other sources.
- STP 1161 - Leak Detection For Underground Storage Tanks Exit
Compilation of 18 peer-reviewed papers on leak detection issues, such as internal monitoring, external monitoring, regulations and standards, and site and risk evaluation.
- Preventing Underground Storage Tank Releases
Guidance from EPA on how to prevent UST releases, including spill protection, overfill protection, and corrosion protection.
Releases are detected in various ways. Leak detection equipment may signal a release, or unexpected water may be detected in a tank. There may be a spill identified while delivering fuel into an UST or dispensing fuel at the point of sale. Releases may also be identified during tank upgrades or replacements as these activities are also known to be common causes of releases.
Often, inventory control can alert the UST operator of a release, which may be discovered as a discrepancy in the inventory of fuel delivered versus the fuel dispensed from the UST. Newer UST systems have automatic tank gauging systems that can immediately identify a discrepancy using electronic measurement sensors and sound an alarm.
If a tank or UST system is being upgraded or replaced, field screening and sampling by a qualified professional may help to quickly identify a release and its specific cause. Experienced field oversight can also help limit the impact of a release on public health, safety, and the environment. The benefits to an UST owner of an immediate discovery of a release are reduced downtime and costs.
- How can I Tell if a Release has Occurred?
Brief summary by EPA on warning signs of a release, with links to state and EPA regional contacts and reporting information.
- Musts for USTs: A Summary of the Federal Regulations for Underground Storage Tank Systems (EPA 510-K-15-001) November 2015
EPA guide to USTs that includes a chapter on what to do about UST releases.
- Detecting UST Releases
EPA summary of leak detection requirements and methods, and numerous links to additional publications and websites.
- UST Technical Compendium Category 3: Release Detection (RD)
Questions and answers compiled by EPA that provide clarification on release detection regulations.
- UST Technical Compendium Category 4: Release Investigation, Confirmation, and Corrective Action (RICC)
Questions and answers compiled by EPA that provide clarification on release investigation, confirmation, and corrective action.
- Release Detection for Underground Storage Tanks and Piping: Straight Talk on Tanks (EPA-510-K-16-003) May 2016
EPA booklet that provides descriptions of several leak detection methods for tanks and piping, as well as explanations of the regulatory requirements for leak detection.
- Operating and Maintaining Underground Storage Tank Systems: Practical Help and Checklists (EPA-510-K-16-001) February 2016
EPA document that identifies the operation and maintenance (O&M) procedures to follow to ensure that USTs do not have leaks, including information on detecting leaks.
- Subpart D–Release Detection
Federal regulation (40 CFR Part 280) on release detection (see 40 CFR 280.43 and 44 for methods of release detection for tanks and piping).
Confirming that a release has occurred from an UST should be done systematically. A first step is to determine if the UST system and monitoring equipment are operating correctly. Sensors that monitor releases may need to be checked to ensure that they are functioning properly. Another step may involve checking fuel delivery receipts to examine inventory. Once the equipment and inventory have been checked, a release can be confirmed by testing the tightness of the UST system using government and industry acceptable methods. Tank tightness is an indication of leaks, including very small or slow leaks.
- Tank Tightness Testing with Inventory Control
EPA summary page that includes information on tank tightness testing and inventory control and associated regulatory requirements.
- UST Technical Compendium Category 4: Release Investigation, Confirmation, And Corrective Action (RICC)
Questions and answers compiled by EPA that provide clarification on release investigation, confirmation, and corrective action (RICC) regulations.
- Test Method Index and Vendors Exit
List of vendors and equipment for specific test methods compiled by the National Work Group On Leak Detection Evaluations (NWGLDE).
- Subpart E–Release Reporting, Investigation, and Confirmation
Federal regulation (40 CFR Part 280) on release reporting, investigation, and confirmation (see 40 CFR 280.52 for release investigation and confirmation requirements).
Owners and operators of USTs are required to investigate, confirm, and notify the authorities of all suspected releases within 24 hours or other time period specified by the state or tribal agency. The amount of time permitted before providing notification as well as the reportable quantity threshold vary by implementing agency.
Documentation and reporting requirements are also unique to each state and tribe; inventory and maintenance records must be maintained at the facility according to these requirements to allow consultants and regulators access to information on the release.
- Subpart E—Release Reporting, Investigation, and Confirmation
Federal regulation (40 CFR Part 280) on release reporting, investigation, and confirmation (see 40 CFR 280.50 and 53).
- What are my Reporting Responsibilities as an Owner or Operator?
EPA summary page on owner and operator reporting responsibilities that includes links to state and local contacts.
- How do I Report a Release from an UST System?
EPA summary page on how to report an UST release that includes links to state and local contacts and EPA regional UST program contacts.
Once a leak is confirmed, immediate response actions must be taken to minimize or eliminate the source of the release and to reduce potential harm to human health, safety, and the environment. Each state has unique requirements for initiating responses to a release, and it is up to the UST owner or operator to conduct actions in compliance with his/her local rules. State, local, and tribal contacts can help identify qualified professionals who will be able to provide quick assistance to help reduce costs and liability.
Immediate responses may include removing flammable or explosive materials from the release area and preventing discharges to stormwater utilities, wetlands, and surface waters. It may also be necessary to provide bottled water for individuals, families, or businesses that rely on groundwater for drinking, bathing, and food preparation. The intrusion of petroleum vapors into indoor building spaces has become an important concern and may require the active ventilation of indoor building spaces.
- What do I do About UST Releases?
EPA summary page outlining short- and long-term actions that must be taken after an UST release.
- ASTM Guide D5745-09: Standard Guide for Developing and Implementing Short-Term Measures or Early Actions for Site Remediation Exit
Industry standard that provides a systematic approach for the application and execution of early actions for site remediation, including development of a Conceptual Site Model.
Site Characterization and Conceptual Site Model
- Characterizing the source contaminants
- Characterizing the site and developing conceptual site model (CSM)
- Sampling and data collection
- Quality assurance and quality control
- Personal protection and safety
- Documentation and reporting
Site characterization is the process by which site-specific information and data are gathered from a variety of sources to characterize the physical, biological, and chemical systems at a contaminated site. A conceptual site model (CSM) integrates all lines of evidence into a three- dimensional picture of site conditions that illustrates contaminant distributions, release mechanisms, migration routes, exposure pathways, and potential receptors. The CSM uses a combination of text and graphics to portray both known and hypothetical information. The CSM documents current site conditions and is supported by maps, cross-sections, and site diagrams that illustrate human and environmental exposure through contaminant release and migration to potential receptors. Frequently, a CSM may be presented as a site map and/or developed as a flow diagram which describes potential migration of contaminants to sit. The CSM synthesizes data acquired from historical research, site characterization, and remediation system operation.
The initial identification of the contaminants that are released from a leaking underground storage tank (LUST) requires an understanding of the specific properties of the fuel involved. Different types of fuels and additives present different problems at a site. For example, older gasoline releases contained lead, while newer releases contain oxygenates that promote clean air (such as methyl tertiary butyl ether, or MTBE). Recent federal mandates to add ethanol and other biofuels to gasoline and diesel fuel may require modified or additional investigation.
Different contaminants of concern have different chemical and physical properties and toxicological characteristics, causing them to behave differently underground and to present a variety of risks to human health and the environment. It is important to identify the applicable contaminants present to develop an accurate idea of how to remediate the site effectively.
- Contaminants of Concern
- Light Non-Aqueous Phase Liquid (LNAPL) Resource CenterExit
Information portal compiled by the American Petroleum Institute (API) on LNAPLs, including answers to frequently asked questions, manuals, software, and technical reports.
- Oxygenates Exit
Information portal compiled by the American Petroleum Institute (API) on fuel oxygenates in soil and water, including technical protocols, conference reports, and publications of ongoing research in the field.
- Lead Scavengers Compendium: Overview of Properties, Occurrence, and Remedial Technologies
Compendium prepared by EPA on the state of the knowledge on additives to lead gasoline (known as lead scavengers) at LUST sites, including their occurrence in drinking water, environmental fate and transport, and case studies.
Site conditions play a critical role in the fate of a release and how contamination can best be mitigated. The known characteristics of a site, such as geology and hydrology, are used to create a conceptual site model (CSM), which is utilized to guide the collection of data and determine the type and amount of required cleanup. The location of the leak source and its extent, both horizontally and vertically, must be understood. Site conditions could affect response actions, so information is needed on the site’s proximity to receptors, such as drinking water supplies, sensitive wetlands or surface waters, schools, day-care facilities, hospitals, and residences that may complete exposure pathways.
Potential concerns associated with petroleum contamination may include, but are not limited to, threatened water supply sources, and impaired indoor air, also known as petroleum vapor intrusion, that can be an elevated threat to children and pregnant women, and exposure for construction workers and other potential sources of public exposures. In addition, storm drains and underground utilities can create preferential pathways that can alter and exacerbate the migration of pollutants. Site assessment activities may include removing USTs and piping to collect soil or groundwater samples. As specific site information is gathered, the data are used to refine the CSM.
One of the first steps in the site characterization process is reviewing existing records and historical site information to create a baseline of information on the problem. Typically the owner would have this documentation on-site or be able to access it from his monitoring system. A CSM is also developed at this stage. The CSM describes the geological and physical setting of the release, possible migration pathways, and the potential threat to public health and the environment. Once the historic and current UST system information is understood and the CSM is established, the process of identifying the exact source, quantity, and timing of the release can be more productive. Existing inventory records or data from electronic inventory systems can be used to estimate the source of the piping, tank, or system failure and the quantity of fuel that may have been released. This information can then be used to productively guide the remedial design and help evaluate the effectiveness of the cleanup.
Under both the traditional and expedited assessment approaches, a sampling and analysis plan must be developed and samples collected as described below. Site assessment is an iterative process: as information is gathered about the site history and conditions, the CSM is modified and, in turn, the remedial action approach revised. Sample collection is also an ongoing process, and the analytical results from sampling help to inform the assessment and cleanup.
- Conceptual Site Model Checklist (PDF) (2 pp, 62K, About PDF) Exit
Checklist provided by Triad of requirements for completing a conceptual site model.
- Triad Issue Paper: Using Geophysical Tools to Develop the Conceptual Site Model
- Environmental Cleanup Best Management Practices: Effective Use of the Project Life Cycle Conceptual Site Model
- Best Practices for Environmental Site Management: A Practical Guide for Applying Environmental Sequence Stratigraphy to Improve Conceptual Site Models (EPA/600/R-17/293) (PDF) (62 pp, 3.6 MB, About PDF)
- ASTM E1689-95 Standard Guide for Developing Conceptual Site Models for Contaminated Sites Exit
This guide describes the major components of conceptual site models, provides an outline for developing models, and presents an example of the parts of a model.
- ASTM E2531-06e1 Standard Guide for Development of Conceptual Site Models and Remediation Strategies for Light Nonaqueous-Phase Liquids Released to the Subsurface Exit
Industry standard on LNAPL occurrence and behavior in the subsurface, identifying risk-based drivers and non-risk factors for action at a site and prioritizing resources based on those action drivers.
- Expedited Site Assessment Tools for Underground Storage Tank Sites: A Guide for Regulators (EPA 510-B-97-001) March 1997
EPA guidance document on the expedited site assessment process, a framework for rapidly characterizing UST site conditions for corrective action decisions (also known as accelerated site characterization, rapid site characterization, and expedited site investigation.)
- Public Health Assessment Guidance Manual – Chapter 6: Exposure Evaluation: Evaluating Exposure Pathways
Guidance manual from the Agency for Toxic Substances and Disease Registry (ATSDR) describing how to clearly define and explain exposure pathways, including the five elements of an exposure pathway that determine the extent to which an exposure may have occurred.
- Modeling Subsurface Petroleum Hydrocarbon Transport
OnSite is a set of online tools for site assessment that contains calculators for: formulas, models, unit conversion factors, and scientific demonstrations to assess the impacts from groundwater contaminants.
- Site Characterization for Subsurface Remediation (EPA 625-4-91-026) November 1991
Seminar publication from EPA on site characterization for subsurface remediation, focusing on concepts, processes, characterization, and data analyses.
- Innovative Technologies - Characterization and Monitoring
EPA website on characterization and monitoring that contains links to information on technology tools, statistics and sampling design, sample collection and handling, environmental data quality, and other topics.
- Triad Implementation Guide (63 pp, 418K, About PDF) Exit
Interstate Technology & Regulatory Council guide on implementing the EPA Triad process and the challenges of and solutions to anticipated issues.
- Triad: Overview And Key Concepts Exit
An overview from the Triad Resource Center that explains the Triad's three key components: systematic planning, dynamic work strategies, and real-time measurement technologies.
- Conceptual Site Model Checklist (2 pp, 62K, About PDF) Exit
Checklist provided by Triad of requirements for completing a conceptual site model.
- Fact Sheet: Resources for Strategic Site Investigation and Monitoring (EPA 542-F-01-030b) September 2001 (4 pp, 309K, About PDF) Exit
EPA fact sheet that lists education, training, and guidance resources about strategic investigation and monitoring activities at hazardous waste sites.
- Field Analytical and Site Characterization Technologies: Summary of Applications (EPA-542-R-97-011) November 1997
During site sampling, care must be taken to ensure that samples are representative of site contamination conditions and are handled properly so that cross-contamination does not occur or integrity of the samples is not compromised. EPA employs a process to identify specific requirements for each sampling event and to guide project managers in designing a sampling program. A good sampling program will record detailed site information at the time of collection, such as soil types at various depths, ground water observations, weather conditions, equipment used, photographs, and field personnel qualifications. These notes can be important in making key decisions related to cleanup of the site.
- Environmental Data Quality
EPA's process to identify specific requirements for each sampling event and to guide project managers in designing a sampling program.
- Field Sampling and Analysis Technologies Matrix Version 1.0 Exit
A Naval Facilities Engineering Command and EPA resource to assist remedial project managers in the process of evaluating alternative technologies and to enhance technology transfer among federal agencies.
- Expedited Site Assessment Tools for Underground Storage Tank Sites: A Guide for Regulators
EPA guidance on the evaluation of conventional and new site assessment technologies and the use of expedited site assessment.
- Monitoring Well Comparison Study: An Evaluation of Direct-Push Versus Conventional Monitoring Wells
A study conducted by BP Corporation North America Inc., and the underground storage tank programs of EPA Regions 4, Atlanta GA And Region 5, Chicago, IL. May 1, 2002.
Samples are typically sent off-site to laboratories for analysis. To more quickly identify conditions in the field, portable analytical equipment may be brought on-site during field sampling. This equipment can be used to achieve a more real-time understanding and reduce the need for iterative laboratory sampling. A specified percentage of the collected samples are then submitted to an analytical laboratory to confirm and correlate the results of the field instrument screening. Complete on-site labs can be expensive, and often site sampling and assessment becomes an iterative process whereby samples are collected and sent to an off-site lab to be analyzed with results fed into an interim assessment report. This process must be repeated until the extent of the contamination is fully characterized. Fully assessing a site may take months to complete.
Prior to collecting samples or undertaking any subsurface work, contact utility companies to identify the location of any underground utilities. Likewise, field personnel must be careful not to operate large excavation equipment where there might be interference with overhead utility lines. Furthermore, if contamination extends beyond the source property boundaries, site access agreements need to be executed to make provisions for proper access onto adjacent properties.
New sampling technologies are available to help collect samples cost effectively and to provide better protection of samples prior to analysis. For example, some new technologies allow for soil sampling in a way that minimizes the loss of any potentially volatile chemicals prior to lab analysis. Other methods or preservation techniques maintain the integrity of the sample during transit between the site and the lab.
Finally, it is important that all sampling equipment be properly decontaminated between individual sampling points. Equipment decontamination is a critical practice to ensure the integrity of each sample by preventing cross-contamination.
Determining the nature and extent of a petroleum release generally begins with characterizing soil and rock permeability and conducting soil sampling, and this is typically an iterative process. Soil samples are collected to establish the full horizontal and vertical extent of the release in the soil. Samples are often screened for petroleum hydrocarbons in the field using a portable photo-ionization detector (PID), flame-ionization detector (FID), or an ultraviolet fluorescence (UVF) instrument to quickly establish where contamination is present. Continuous sampling of soil cores allows rapid visual observations of soil staining from releases, and technologies such as UVF screening can quickly identify the exact vertical extent of a release in the soil column. Using continuous screening of soils in this way, from the ground surface to the bottom of the borehole, allows a precise understanding of the vertical extent of contamination at each boring. Identifying soil strata is critical in development of the CSM and in design of the remediation strategy. Each implementing agency will have its own acceptable field screening methods and requirements for analytical testing.
Commonly a fuel release will be present as dissolved contaminants in the groundwater. Monitoring wells are usually constructed to establish the horizontal and vertical impact to the groundwater resource. Groundwater nearly always flows in a specific direction, although the direction can change during various times of the year or be artificially impacted by underground utilities or man-made changes. Monitoring wells are typically established around a release to understand the extent of contamination, together with background up-gradient and down-gradient conditions that existed before the release. The number and location of ground water monitoring wells are used to characterize the nature and extent of contamination. A minimum of three monitoring wells is necessary to establish the direction of groundwater flow. For sites with complex geologic conditions, man-made disturbances, or underground utilities within the groundwater, more wells will be necessary to fully understand groundwater flows.
Gauging groundwater depths periodically is important in understanding how a fuel release behaves underground throughout the year. Seasonal fluctuations in ground water levels may impact dissolved contaminants in the groundwater. To accurately characterize ground water contamination at a site, groundwater sampling should be conducted during different seasons to account for potential variations in dissolved contaminant levels.
When a large quantity of product has been released, pure gasoline or fuel is often found floating on the groundwater surface. This free-floating petroleum is referred to as Light Non-Aqueous Phase Liquid (LNAPL). The thickness of the LNAPL layer must be accurately gauged with an oil or water interface probe. Thickness of the LNAPL will vary considerably as the groundwater table rises and falls and the product either saturates or evacuates from the surrounding soil particles. To fully characterize LNAPL thicknesses, it is best to collect measurements at various times of the year to account for seasonal groundwater fluctuations in LNAPL depths. Before any remedial action is conducted to remove the LNAPL, it is important to quantify the mass or volume of the product, evaluate the LNAPL mobility, consider any vapors that may partition from the product, and evaluate the exposure pathways of the LNAPL. These are unique considerations regarding cleanup of sites impacted with LNAPL. Federal regulations require that any free product identified during the LNAPL assessment be removed from the ground and properly managed.
- LNAPL Documents Exit
Interstate Technology & Regulatory Council guidance documents addressing natural source zone depletion (NSZD) for LNAPLs, the processes involved, their rates, and long-term progress.
- Downward Solute Plume Migration: Assessment, Significance and Implications for Characterization and Monitoring of "Diving Plumes" (PDF) Exit (38 pp, 2.6 MB, About PDF)
This document was produced by the American Petroleum Institute (API) Soil and Groundwater Technical Task Force. The report's purpose is to promote a common understanding of the phenomenon of diving plumes. The term diving plume refers to the gradual downward vertical migration of a dissolved-phase contaminant plume to greater depths in the subsurface with increasing distance along the flow path, resulting in the existence of a region of uncontaminated water overlying portions of the plume. An unrecognized diving plume could result in an inadequate evaluation of risk to receptors, erroneous interpretation of the significance of natural attenuation, under-design of a remediation system or inadequate assessment of remedial performance.
Petroleum contamination can partition from soil or groundwater and migrate into indoor air spaces where it can cause a health hazard to humans. The impact to indoor air may be affected by site conditions that increase the potential for vapor intrusion into buildings, such as direct contact between a contaminant source (groundwater or LNAPL) and a building foundation. Soil vapor can be sampled outside or underneath building slabs before it reaches indoor pathways. Alternatively, indoor air can be sampled directly for volatile organic compounds (VOCs). Care must be exercised in sampling indoor air spaces because many household and industrial products, such as paints, new carpet, or household cleaners, can lead to false positive readings.
- Petroleum Vapor Intrusion
This resource provides UST stakeholders with information regarding intrusion of petroleum vapor into indoor air.
- API – Vapor Intrusion Exit
Information portal from the American Petroleum Institute (API) on vapor intrusion, the migration of vapors from subsurface contaminant sources to buildings, including training, modeling, publications, and presentations.
- Vapor Intrusion
EPA website that provides topical information on vapor intrusion, primarily for non-petroleum contaminants.
- EPA CLU-IN resources regarding field investigation of vapor intrusion, mitigation approaches, and current relevant initiatives. Exit
- ITRC Vapor Intrusion Documents Exit
Interstate Technology & Regulatory Council guidance documents addressing investigating and evaluating the vapor intrusion pathway, data evaluation, and mitigation.
Quality assurance (QA) addresses process management and refers to the establishment of a system to plan, carry out, and review data collection activities. Quality control (QC) focuses on operational aspects and refers to the process of taking appropriate scientific precautions, such as proper calibrations and duplications, to ensure data quality of the collected samples. During site assessments, QC samples are collected in the field to check whether the site characterization samples are representative of site conditions. The samples are used to evaluate the quality and usability of data collected from soil, groundwater, and air for accuracy, representativeness, comparability, and completeness. Government agencies may require that a QA project plan be approved before sampling or that a data usability assessment be conducted after samples are analyzed at a laboratory.
- Environmental Data Quality
EPA's process to identify specific requirements for each sampling event and to guide project managers in designing a sampling program.
- ASTM D6311 - 98(2009) Standard Guide for Generation of Environmental Data Related to Waste Management Activities: Selection and Optimization of Sampling Design Exit
ASTM guide to provide practical assistance in the development of an optimized sampling design.
Fuel releases from LUSTs can present dangerous conditions to site workers and occupants of nearby buildings. Examples of these conditions include elevated concentrations of VOCs creating low levels of oxygen in confined spaces (i.e. suffocating conditions) or potentially explosive concentrations of vapors. Workers and other individuals who may be exposed to petroleum-contaminated soil or groundwater need to avoid direct contact with the material. Ingestion and inhalation exposures can be dangerous and hazardous to health.
In addition, excavation or trenching is sometimes conducted in association with a remedial action, and may pose a risk of collapse. Personnel involved in underground storage tank removals, site assessments, and remedial actions must complete Hazardous Waste Operations and Emergency Response Standard (HAZWOPER) training certified by the Occupational Safety and Health Administration (OSHA) of the U.S. Department of Labor. Local implementing agencies may require additional certifications for these individuals. OSHA has recently adopted stricter guidelines for trenching and excavation in response to a number of accidental deaths caused by excavation collapses during UST removal and installation projects. Worker health and safety should remain a continuing priority during all assessment and cleanup actions.
- Hazardous Waste Operations and Emergency Response Exit
OSHA regulations pertaining to personal protective equipment related to hazardous materials at 29 CFR Part 1910.120 et seq.
- HAZWOPER Frequently Asked Questions Exit
OSHA site that lists frequently asked questions and answers about HAZWOPER training.
- OSHA HAZWOPER Safety Training Online Exit
Online OSHA HAZWOPER safety training
- Excavations: Hazard Recognition in Trenching and Shoring Exit
OSHA Technical Manual on excavations to assist in the recognition of trenching and shoring hazards and their prevention.
Field observations and results from all site assessment work should be documented in a written site assessment report. Report requirements can vary among implementing agencies; the relevant authority should be contacted for specific report requirements and guidance. In general, a site assessment report will document the environmental investigation work performed at the site and an evaluation of the findings. It may include maps and cross-sections that show the geologic and hydrogeologic conditions and the distribution of contaminants as well as recommendations for future assessment or mitigation of the contamination. Assessment actions generally need to be documented and filed with the appropriate government agency. Some agencies require that the scope of work of a proposed assessment action be reviewed and approved prior to implementation.
- ASTM E1527 - 05 Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process Exit
ASTM guide that defines good commercial and customary practice for conducting an environmental site assessment of a parcel of commercial real estate with respect to the range of contaminants within the scope of CERCLA and petroleum products.
- ASTM E1903 - 97(2002) - Standard Guide for Environmental Site Assessments: Phase II Environmental Site Assessment Process Exit
ASTM guide to employing good commercial and customary practices in conducting a Phase II environmental site assessment of a parcel of commercial property with respect to the potential presence of a range of contaminants that are within the scope of CERCLA as well as petroleum products.
- Corrective action plan
- Remediation methodologies
- Light non-aqueous phase liquid recovery
- Performance monitoring
- Institutional and engineering controls
- Documentation and reporting
- Case studies
The conceptual site model (CSM) along with acceptable risk factors, cost, local policies, available technologies, and community input will all help dictate the appropriate cleanup method to apply to a leaking underground storage tank (LUST) site. Various remedial actions are reviewed for effectiveness, and a detailed corrective action plan (CAP) may be developed according to the requirements of the implementing agency. To ensure protection of public health, safety, and the environment, the site owner or his/her consultant may discuss the proposed immediate actions directly with the implementing agency to avoid delays and misunderstandings. Possible corrective action options, such as excavation and removal, pump and treat, or soil-vapor extraction, undergo a thorough analysis to select a reasonable approach from both a technical and cost perspective. An evaluation report that summarizes the benefits and drawbacks of each alternative is usually prepared for review by government agencies. A pilot test may be necessary to determine the effectiveness of the selected remedy prior to full scale application. Once the review of alternatives is completed, a specific corrective action or set of actions is selected and implemented.
The selected remedial action is described in detail in the CAP and may include preparation of written specifications and detailed engineering drawings. The plan may require that the action be performed by qualified contractors and may outline strategies to help the tank owner or operator control costs. The plan may also include specific cleanup goals, a project schedule, and project milestones.
This section of the LUST Corrective Action Resources offers an overview of the corrective action process as well as the operation, maintenance, and monitoring requirements that will likely be an integral part of the process.
A corrective action plan (CAP) is a comprehensive plan that describes how a LUST will be cleaned up and justifies why this remedial method has been chosen. The CAP typically needs to be approved by the local implementing agency. Any confirmed release that requires a CAP also requires notifications to local municipal or county officials, notices in the local newspaper, and public hearings to provide a forum for parties who may be impacted by a specific response or corrective action. Additional measures may also be proposed to protect people from harm, such as supplying drinking water to nearby residences or venting indoor air spaces.
Risk-based decision-making is used in some states to determine the appropriate levels of action and oversight based upon the risk to human health and environmental receptors. One state example is offered in the links below. ASTM's E1739 standard is an example of a framework for implementing a risk-based corrective action strategy. With this process, implementing agencies can make sound, quick, consistent management decisions for a variety of sites using a three-tiered approach to data collection and site review.
- Life Cycle Cost Analysis (18 pp, 536K, About PDF) Exit
Interstate Technology & Regulatory Council guide on life cycle cost, which is the total project cost across the lifespan of a project, including design, construction, operation and maintenance, and closeout activities.
- Remediation Process Optimization: Identifying Opportunities for Enhanced and More Efficient Site Remediation (133 pp, 1.2M, About PDF) Exit
Guidance from the Interstate Technology & Regulatory Council Remediation Process Optimization Team on how to use remediation process optimization as a tool to evaluate and manage remediation process uncertainty.
- Vendor Information Exit
EPA CLU-IN page that links to a searchable directory of remediation and characterization technology vendors.
- ASTM E2205 / E2205M - 02(2009)e1 Standard Guide for Risk-Based Corrective Action for Protection of Ecological Resources Exit
ASTM Guide on the Eco-Risk-Based Corrective Action process, which involves implementing corrective action in a manner that is protective of ecological resources.
- ASTM E2081 - 00(2010)e1 Standard Guide for Risk-Based Corrective Action Exit
ASTM guidance on risk-based corrective action at chemical release sites that uses a tiered approach with a focus on protecting human health and the environment.
- Risk Based Decision Making (RBDM)
RBDM policy for USTs and technical supporting documents.
Corrective Action Plans (CAPs) typically include an overview and evaluation of the proposed remediation methodologies. Each alternative is analyzed to address its effectiveness, efficiency, and cost as well as environmental sustainability, and, increasingly, the impact on greenhouse gas emissions. The selection of a remedial solution is optimized to consider the oil and hazardous materials present, the media that is contaminated, the feasibility of achieving cleanup, the potential greenhouse impacts, the cost-benefit of various solutions, and the unique subsurface characteristics at the release site. Remedial action alternatives are identified by screening various cleanup options to determine which alternative will meet the performance goals of the reviewing agency. The thorough evaluation of alternatives ensures that the optimal remedial solution is reliable, effective, energy-efficient, and protective of human health and the environment.
Remediation methods for liquids or vapors include free-product recovery as well as passive and active single-phase and multi-phase recovery. Depending on site conditions, it may be possible to collect free product passively, as opposed to using active methods that rely on electricity or pneumatic devices. Passive product collection may be just as effective as active remediation while having significantly lower operational costs and electrical demands and producing lower greenhouse gas emissions. Examples of passive remediation methods may include skimmers, absorbent socks, or floating oil/water separators. Examples of active remediation systems may include soil vapor extraction or ground water pumping with activated carbon treatment. For soil, some treatment methods require excavation of the soil (ex situ treatment) while others allow soil to remain in place (in situ treatment) for procedures such as in situ oxidation or bioremediation. Excavated soil may even be reused in the making of asphalt.
- Evaluating LNAPL Remedial Technologies for Achieving Project Goals (144 pp, 986K, About PDF) Exit
Interstate Technology & Regulatory Council Technical/Regulatory Guidance to help stakeholders select the best-suited LNAPL remedial technology for an LNAPL site and help the regulator and others understand what technologies apply in different site situations.
- New England Interstate Water Pollution Control Commission (NEIWPCC) – Underground Storage Tanks Exit
NEIWPCC, a not-for-profit interstate agency, is involved in local and national underground storage tank issues and also publishes LUSTLine, a national bulletin covering UST/LUST issues, federal and state programs and activities, and technologies.
- Above Ground Treatment Technologies (26 pp, 578K, About PDF) Exit
Interstate Technology & Regulatory Council document that discusses the basics of optimization of above ground technology for extracted groundwater, air sparging/soil vapor extraction, and multi-phase extraction.
- Green Remediation: Incorporating Sustainable Environmental Practices into Remediation of Contaminated Sites (EPA 542-R-08-002) April 2008 (56 pp, 814K, About PDF) Exit
EPA Technology Primer on the basics of green remediation and how to reduce the negative environmental effects of cleanup activities by using a whole-site approach.
- CLU-IN Remediation Technologies Exit
EPA CLU-IN home page on remediation technologies that includes links to information on remediation technologies, project and site profiles, case studies, a technology screening matrix, newsletters, and how to select an innovative cleanup technology.
- CLU-IN Green Remediation Focus Exit
EPA CLU-IN page on green remediation that provides links to policies and strategies, incorporating best management practices, green remediation in the news, and more.
- OSWER Directive 9200.4-17P: Use of Monitored Natural Attenuation at Superfund, RCRA Corrective Action, and Underground Storage Tank Sites (EPA, 1999) (41 pp, 286K, About PDF)
EPA OSWER Directive regarding EPA's policy on the use of monitored natural attenuation for remediation of contaminated groundwater and soil.
- Innovative Technologies, Contaminant Focus Exit
EPA CLU-IN site on cleanup information organized by contaminant and contaminant groups.
- Innovative Technologies, Technology Focus Exit
EPA CLU-IN site on cleanup information organized by particular technologies that may be used in a variety of applications.
- How to Evaluate Alternative Cleanup Technologies for Underground Storage Tank Sites: A Guide for Corrective Action Plan Reviewers (EPA 510-B-94-003; EPA 510-B-95-007; and EPA 510-R-04-002) May 2004
EPA manual that discusses different alternative cleanup technologies, including soil vapor extraction, air sparging, biosparging, landfarming, biopiles, bioventing, low-temperature thermal desorption, natural attenuation, dual-phase extraction, in-situ groundwater bioremediation, enhanced aerobic bioremediation, and chemical oxidation.
- Green Remediation Best Management Practices: Soil Vapor Extraction & Air Sparging (EPA 542-F-10-007) March 2010 (4 pp, 131K, About PDF) Exit
EPA CLU-IN fact sheet on designing, constructing, operating, and monitoring a soil vapor extraction system or air sparging system.
- ASTM E1943-98(2010) Standard Guide for Remediation of Ground Water by Natural Attenuation at Petroleum Release Sites Exit
ASTM guide for determining the appropriateness of remediation by natural attenuation and implementing remediation by natural attenuation at a given petroleum release site.
When pure gasoline or fuel is floating on the groundwater surface, the product needs to be recovered as quickly and efficiently as possible. The longer it stays in the ground, the greater the chance of migration into utilities, drinking water wells, or indoor spaces. Free-floating petroleum is often referred to as Light Non-Aqueous Phase Liquid (LNAPL). The thickness of LNAPL varies considerably as the water table rises and falls. When groundwater subsides, LNAPL thickness tends to be greatest. LNAPL can be removed through excavation, withdrawn by active or passive collection equipment, or chemically oxidized in situ.
- Answers to Frequently Asked Questions About Managing Risk at LNAPL Sites Exit
American Petroleum Institute document of frequently asked questions and answers about light non-aqueous phase liquids.
- A Decision-Making Framework for Cleanup of Sites Impacted with Light Non-Aqueous Phase Liquids (LNAPL) (EPA 542-R-04-011) March 2005 (86 pp, 1.3M, About PDF) Exit
Non-Aqueous Phase Liquid (NAPL) Cleanup Alliance document prepared as a guide for long-term management of light, non-aqueous phase liquid (LNAPL) at impacted sites.
- LNAPL Distribution and Recovery Model (LDRM) Exit
American Petroleum Institute's LNAPL Distribution and Recovery Model simulates the performance of proven hydraulic technologies for recovering free-product petroleum liquid releases to groundwater.
- How to Effectively Recover Free Product at Leaking Underground Storage Tank Sites: A Guide for State Regulators (EPA 510-R-96-001) September 1996
EPA technical guidance document to help state regulators and cleanup contractors review those parts of an UST corrective action plan that propose free-product recovery technologies.
- API Interactive LNAPL Guide Exit
American Petroleum Institute electronic information system designed to provide an approach for evaluating LNAPL at a site: assessing its potential risk, quantitatively defining mobility and recoverability, developing remedial strategies, and examining methods to enhance site closure opportunities.
The selected corrective action must be monitored and evaluated for both cost control and achievement of objectives throughout implementation. Performance monitoring approaches will vary depending on the situation. If surface water has been impacted, periodic monitoring of aquatic organisms, plants, or sediments may be undertaken. In the case of groundwater, many government agencies require semi-annual or quarterly reporting to document the performance of the selected action because of variation in groundwater contamination levels at different times of the year. Indoor air monitoring may be conducted more frequently in the wintertime because of the stack effect that occurs in buildings when they are closed during cold weather resulting in less air flow. If a particular action does not appear to be effective, an alternative corrective action may be proposed by the tank owner or operator.
- Characterization and Monitoring Technologies Exit
EPA CLU-IN site that lists and describes many resources on characterization and monitoring technologies.
- Performance-Based Management - Fifth in a Series of Remediation Process Optimization Advanced Topics (22 pp, 600K, About PDF) Exit
Interstate Technology & Regulatory Council technology overview of the basic concepts of performance-based management.
- Optimizing Site Cleanups Exit
EPA CLU-IN site with information on remediation optimization, which uses defined approaches to improve the effectiveness and efficiency with which an environmental remedy reaches its stated goals.
- Data Management, Analysis, and Visualization Techniques - Fourth in a Series of Remediation Process Optimization Advanced Topics (22 pp, 563K, About PDF) Exit
Interstate Technology & Regulatory Council document that introduces the basics of data management, analysis, and visualization techniques.
- Improving Environmental Site Remediation Through Performance-Based Environmental Management (144 pp, 3.4M, About PDF) Exit
The Interstate Technology And Regulatory Council guidance on performance-based environmental management that includes regulatory and stakeholder preferences.
Institutional controls (ICs) are non-engineered instruments, such as administrative and legal controls, that help minimize the potential for human exposure to contamination and/or protect the integrity of the remedy. Although it is EPA's expectation that treatment or engineering controls will be used to address principal threat wastes and that ground water will be returned to its beneficial use whenever practicable, ICs play an important role in site remedies because they reduce exposure to contamination by limiting land or resource use and guide human behavior at a site. For instance, zoning restrictions prevent site land uses, like residential uses, that are not consistent with the level of cleanup.
Institutional controls are meant to be used in conjunction with treatment or engineering controls such as containment. Engineering controls are the physical structures that limit or restrict exposure to contamination in the short term or for extended future use. Typically they are well-engineered barriers, such as a reinforced concrete slab constructed in the ground to prevent access to contamination and reduce the exposure pathway.
- Institutional Controls
EPA website with links to guidance documents for community members, site managers, and other decision-makers on the types of institutional controls and their role.
- Institutional Controls: A Site Manager's Guide to Identifying, Evaluating and Selecting Institutional Controls at Superfund and RCRA Corrective Action Cleanups (EPA 540-F-00-005) September 2000 (32 pp, 221K, About PDF)
EPA fact sheet describing the types of institutional controls (IC) that are commonly available, their strengths and weaknesses, and key considerations, as well as the relationship between IC and engineering controls.
- Understanding the Role of Institutional Controls at Brownfields Sites: Major Concepts and Issues Exit
Web page describing institutional controls at a glance.
- ASTM E2435 – Standard Guide for Application of Engineering Controls to Facilitate Use or Redevelopment of Chemical-Affected Properties Exit
ASTM guide that discusses the application of engineering controls to allow the use or redevelopment of properties containing chemical-affected soil, ground water, or other media.
Long Term Stewardship at Leaking Underground Storage Tank Sites with Residual Contamination
EPA’s 22-page document provides an overview of long term stewardship at leaking UST sites.
Reporting requirements for corrective actions can vary among implementing agencies. Corrective actions generally must be documented and filed with the appropriate government agency. Some agencies require that the performance of an implemented action be periodically reviewed and evaluated to justify continuing the action. Field documentation is conducted to meet this requirement through field notes, photographs, and performance monitoring. It is also important to develop and review a health and safety plan to protect workers who are involved in the action.
- Regulations Pertaining to Underground Storage Tanks (40 CFR Part 280): Subpart E – Release Reporting, Investigation, and Confirmation
Federal regulations addressing the reporting of suspected releases, investigation and confirmation of the suspected release, and reporting and cleanup of spills and overfills.
Case studies of various corrective actions are often provided by government agencies and industry associations to assist responsible parties and their consultants in selecting the most efficient and cost-effective action for a particular release. EPA maintains a comprehensive website to evaluate innovative corrective actions at Clu-In.
- Cost and Performance Case Studies
Federal Remediation Technologies Roundtable site with case study reports that describe the performance and cost of technology applications at large scale and full scale demonstration projects.
- Profiles and Case Studies of Green Remediation Exit
EPA CLU-In site that links to numerous site-specific project profiles that demonstrate green remediation strategies.
- Remediation Technology Demonstration Project Profiles Exit
EPA searchable database of thousands of ongoing and completed remediation technology demonstration projects.
- Characterization and Monitoring Demonstration Project Profiles Exit
EPA searchable database of thousands of ongoing and completed characterization and monitoring technology demonstration projects.
- Greener Cleanups
EPA site that features case studies and links to sites that contain many case studies of successful green cleanups.
- Reusing Cleaned Up Petroleum Sites
EPA page with numerous examples of how petroleum brownfield sites are being reused, reuse success stories, and information on the redevelopment process.
- Use of Risk Assessment in Management of Contaminated Sites (249 pp, 6.2M, About PDF) Exit
Interstate Technology & Regulatory Council report on the use of risk assessment and risk-related practices in the management of contaminated sites through a series of case studies.
EPA maintains a comprehensive website to evaluate innovative corrective actions.
- Risk characterization and closure
- Maintenance and abandonment of sampling points
- Documentation and reporting
- Closure Records
Site closure is a milestone achieved when the remaining contamination in the soil, surface water, groundwater, or air meets a risk or cleanup threshold determined not to pose a threat to human health or the environment. Determining the end point of a corrective action at a leaking underground storage tank (LUST) site may involve reaching a targeted concentration for certain contaminants or reducing the risk of contamination to a specific threshold. Risk-based decision-making (RBDM) criteria are applied more and more frequently to enable tank owners and operators to achieve a quicker and more cost-effective site closure. RBDM allows cleanup to be performed to a risk level that reflects the future use of the site rather than a generic, potentially more stringent cleanup level that is difficult to justify in the context of certain site uses.
- Risk Based Decision Making (RBDM)
RBDM policy for USTs and technical supporting documents.
Depending on the jurisdiction overseeing the remedial activity, completion of corrective action at a LUST site may be based on the remaining and foreseeable risk to human health and the environment. Risk assessors or toxicologists are often engaged to evaluate human risks based on the potential inhalation, skin, or ingestion exposures from the contamination. These risk characterizations often analyze the potential carcinogenic threats of petroleum constituents to pregnant women and small children. Environmental risks are evaluated based on the impact to vertebrates and invertebrates, plants, and their respective habitats. Once a characterization adequately evaluates the risk of all contaminants of concern and their potential exposures, a risk-based decision can be made regarding closure of a LUST site.
In cases when site closure is not based on risk, there are conservative thresholds established by government agencies that must be met for site closure. These thresholds are calculated levels based on generally accepted safety standards.
- UST Technical Compendium Category 5: Closure (CL)
EPA UST Technical Compendium that includes clarifications of notifications and requirements on UST closure.
- Exit Strategy–Seeing the Forest Beyond The Trees - Second in a Series of Remediation Process Optimization Advanced Topics (18 pp, 533K, About PDF) Exit
Interstate Technology & Regulatory Council technology overview on the basics and advantages of a performance-based exit strategy as a component of performance-based management of the environmental remediation process.
- Closing USTs
EPA site that discusses the basics of UST tank closure, including temporary and permanent closure.
Groundwater and vapor intrusion sampling points are often maintained after site closure to allow owners, operators, or implementing agencies an opportunity to confirm and re-evaluate the decision to close a LUST site. Ground water monitoring wells must be properly maintained at the ground surface to ensure that surface petroleum releases or contaminated stormwater do not flow into the well boring and contaminate a clean groundwater resource.
Site closure requirements vary significantly among implementing agencies. Final closure actions generally must be documented and filed with the appropriate government agency. Documentation typically includes narrative descriptions of the release, a full summary of assessment, and corrective actions, maps, plans, summaries of field and laboratory data, a data quality assessment, and a risk characterization. Closure reports are public records that remain open for inspection. Some jurisdictions require legal notices in the local newspaper or certified notifications to adjoining property owners when the cleanup process has been completed.
Once the implementing agency approves the final documentation and reporting from a cleanup, a final approval may be certified in writing. This written approval documents a liability endpoint that can be used for lending or conveyancing purposes.
Increasingly, many implementing agencies are relying on qualified professionals to certify that a permanent closure has been achieved. These individuals are usually licensed, and their certification of closure states that the cleanup endpoints, which are either established by the implementing agency or carefully evaluated based upon risk to public health or the environment (i.e., RBDM) have been met. This certification may be subject to screening and audit at the discretion of the implementing agency.
- Regulations Pertaining to Underground Storage Tanks (40 CFR Part 280): Subpart G – Out-of-Service UST Systems and Closure
Federal regulations on UST closure; 280.74 pertains to closure records.