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Terwilliger, Timothy A.
Petroleum cleanup in the United States :
b a historical review and comparison of state programs
h [electronic resource] /
by Timothy A. Terwilliger.
[Tampa, Fla] :
University of South Florida,
ABSTRACT: Cleanup of leaking underground storage tank (LUST) sites has been a priority for the United States of America (USA) for more than 20 years due to the large number of sites, the potential harmful health affects associated with gasoline components and the fact that single owners may not have the ability to pay for cleanup of these sites. In June 2006, the US Environmental Protection Agency (EPA) reported that of the 459,637 confirmed releases from USTs that had occurred previously, 342,688 had been remediated, which leaves 116,949 sites yet to be completed across the USA. Petroleum cleanup programs tend to be managed at the State level; however, there are wide variations among State programs in terms of information access, risk perception and funding availability.^ ^While each of the Federal and State UST programs has evolved to meet specific requirements, there has not been a comprehensive comparison of the individual State programs.In this thesis, State petroleum cleanup programs across the USA are evaluated to determine similarities and differences in an effort to identify factors that affect petroleum cleanup progress. Many parameters enter the equation in determining petroleum cleanup effectiveness. Not only are the parameters of the State program operation important, but also the characteristics of each State, including drinking water source and perceived risk associated with petroleum contamination, factor into the determination.A representative group of States and State petroleum cleanup programs were evaluated and the characteristics of States were compared to cleanup progress to determine factors affecting efficiency.^ ^Based on trend analysis the cleanup levels for toluene, ethylbenzene and total xylenes correlate directly to the cost of LUST site cleanup. For States with less perceived risk from petroleum contamination, the cleanup goals are less stringent; therefore, fewer resources and less time are required to complete site cleanup. Consequently, petroleum cleanup in States with less-stringent goals is achieved more efficiently. The knowledge of these drivers of efficient petroleum cleanup can be used to expeditiously pursue completion of the thousands of sites remaining across the USA.
Thesis (M.S.E.E.)--University of South Florida, 2006.
Includes bibliographical references.
Text (Electronic thesis) in PDF format.
System requirements: World Wide Web browser and PDF reader.
Mode of access: World Wide Web.
Title from PDF of title page.
Document formatted into pages; contains 79 pages.
Adviser: Audrey D. Levine, Ph.D.
Underground storage tanks.
x Electrical Engineering
t USF Electronic Theses and Dissertations.
Petroleum Cleanup in the United States: A Historical Review and Co mparison of State Programs by Timothy A. Terwilliger A thesis submitted in partial fulfillment of the requirements for the degree of Master of Science in Environmental Engineering Department of Civil and Environmental Engineering College of Engineering University of South Florida Major Professor: Audrey D. Levine, Ph.D. L. Donald Duke, Ph.D. Robert Gan, Ph.D. Date of Approval: October 31, 2006 Keywords: gasoline remediation, underground storage tanks, government efficiency, progress evaluation, government performance Copyright 2006, Timothy A. Terwilliger
Dedication I would like to dedicate this thesis to my wife, Lei gh, and my children, Haley and Zachary Terwilliger. For my wifes encouragement, understanding, and, at times forceful, support in handling th e daily activities of a family and allowing me sufficient time to ponder these thoughts and conduct endless research, and my childrens understanding that daddy cant play right now ; he has do some research, I am forever grateful. Without their support, I would not have been able to complete this milestone. Additionally, I would lik e to dedicate this work to all of those people involved with petroleum cleanup. Given the multitude of environmental impacts across the US, thousands of people require an understanding of the numerous factors involved in petroleum cleanup. If the information contained herein gives insight to one person enabling that person to more completely addr ess a petroleum cleanup pr oject, then I have fulfilled my purpose with this thesis.
Acknowledgements I would like to first thank my major prof essor, Dr. Audrey D. Levine, for her guidance and tireless effort in keeping me on trac k throughout this thes is project. Dr. Levine was one of the first professors I encount ered at the University of South Florida in beginning my Masters Degree quest. For al l of her encouragement and direction in focusing this thesis, I am grateful. I appreciate the assistance of Dr. L. Donald Duke and Dr. Robert Gan, for providing insightful comments and direction during the preparati on of this thesis. Thank you for your time and efforts in serving on my thesis committee. I would like to thank Jessica Linville for her assistance w ith some of the research I needed to complete. Your efforts were always a complete and quick response. Lastly, I am very grateful to the three entities with which I have been employed since my Bachelors Degree from the Universi ty of South Carolina. From working with the South Carolina Department of Environmen tal Health and Control, I learned important information regarding environm ental regulations. From the two companies I have been employed with in Florida, Blasland, Bouck & Lee, Inc. and ARCADIS G&M, Inc, I have had many opportunities to complete various environmental cleanup, the bulk of which has involved petroleum cleanup. Without the support of numerous people in providing me the opportunity to explor e and complete many petrol eum cleanup projects, I would not have established my interest in this area.
i Table of Contents List of Tables................................................................................................................. ....iii List of Figures....................................................................................................................iv Abstract....................................................................................................................... .......vi Introduction................................................................................................................... ......1 Objectives...........................................................................................................................3 Approach.............................................................................................................................4 Federal Program Evaluation...................................................................................5 State Program Evaluation.......................................................................................5 Evaluation of the Florida Petr oleum Cleanup Program (FPCP).............................6 Statistical Analysis..................................................................................................6 Background.........................................................................................................................8 Birth of a National Issue.........................................................................................8 Fuel Consumption and Composition.............................................................9 Water Supply Resources..............................................................................13 Federal UST Program...........................................................................................16 State UST Programs..............................................................................................21 EPA-Approved Programs............................................................................22 Non-EPA Programs.....................................................................................23 Florida Petroleum Cleanup Program...........................................................24 Determination of Program Effectiveness..............................................................36 Definition.....................................................................................................36 Methods of Evaluating Efficiency...............................................................40 Factors Affecting Cleanup...........................................................................43 Petroleum Remediation Technology...........................................................44 Results........................................................................................................................ .......50 Conclusions.......................................................................................................................63 Engineering Implications..................................................................................................67 Additional Research..........................................................................................................68
ii References.........................................................................................................................69 Appendices........................................................................................................................71 Appendix A: State Petroleu m Program Web Addresses......................................72 Appendix B: Statistical Analysis Input & Outputs...............................................77
iii List of Tables Table 1. Physical and Chemical Proert ies of Select Gasoline Components.................... 12 Table 2. Regulatory Timeframes Florida...................................................................... 25 Table 3. State Petrol eum Cleanup Statistics.................................................................... 37 Table 4. State Petroleum Reme diation Technology Statistics......................................... 48 Table 5. Summary of States Chosen for Comparison...................................................... 51 Table 6. Summary of State Groundwater Cleanup Action Levels................................... 52 Table 7. Summary of Statistical Data Inputs................................................................... 54 Table 8. State Data Summary.......................................................................................... 55 Table 9. State Petroleum Program Web Addresses......................................................... 72
iv List of Figures Figure 1. Total Annual US Fuel Consumption (Source: IEA, 2006) .................................9 Figure 2. Fuel Consumption Per State in 2004 (Source, IEA, 2006) ...............................10 Figure 3. Public-Supply Versus Self-Supply in 2000 (Source: USGS, 2004) ................14 Figure 4. Public Supply by Source (USGS, 2004)...........................................................15 Figure 5. EPA-Approved Program States ........................................................................23 Figure 6. Regulatory Flowchart, Chapte r 62-770, Florida Administrative Code ............26 Figure 7. FPCP Site Scoring Checklist ............................................................................29 Figure 8. FPCP Cost Template Worksheet ......................................................................30 Figure 9. Florida Petroleum Cl eanup Program Site Score Chart .....................................32 Figure 10. Funding Score History ....................................................................................34 Figure 11. FPCP Operation History .................................................................................35 Figure 12. Site Closures Vers us Prior Fiscal Year Budget ..............................................35 Figure 13. Air Sparging with Vapor Extraction Technology (Source: EPA, 2004) ........46 Figure 14. Average Cleanup Cost per Site by State .........................................................49 Figure 15. Comparison of Gr oundwater Supply Percenta ge and Percentage of Sites Completed ...............................................................................................51 Figure 16. Florida Funding Score Trend..........................................................................54
v Figure 17. Fuel Consumption Versus 10-year LUST Cleanup Appropriations ...............56 Figure 18. Fuel Consumption Versus A ppropriations per Number of Releases ..............56 Figure 19. Fuel Consumption Versus Percentage of Site Completed ..............................57 Figure 20. Government Involvement Plot .......................................................................59 Figure 21. Benzene Cleanup Level Ve rsus Average Site Cleanup Cost.........................60 Figure 22. Toluene Cleanup Level Ve rsus Average Site Cleanup Cost..........................60 Figure 23. Ethylbenzene Cleanup Level Versus Average Site Cleanup Cost .................61 Figure 24. Total Xylenes Cleanup Leve l Versus Average Site Cleanup Cost .................61 Figure 25. BTEX Cleanup Level Ve rsus Average Site Cleanup Cost.............................62 Figure 26. MTBE Cleanup Level Ve rsus Average Site Cleanup Cost............................62
vi Petroleum Cleanup in the United States: A Historical Review and Comp arison of State Programs Timothy A. Terwilliger ABSTRACT Cleanup of leaking underground storage tank (L UST) sites has been a priority for the United States of America (USA) for more than 20 years due to the large number of sites, the potential harmful health affects associated w ith gasoline components and the fact that single owners may not have the ability to pay for cl eanup of these sites. In June 2006, the US Environmental Protection Agency (EPA) reported that of the 459,637 confirmed releases from USTs that had occurred previously, 342,688 had been remediated, which leaves 116,949 sites yet to be completed across the USA. Petroleum cleanup programs tend to be managed at the State level; however, there are wide variations among State programs in terms of information access, risk perception and funding availability. While each of the Fede ral and State UST programs has evolved to meet specific requirements, there has not been a comprehensive comparison of the individual State programs.
vii In this thesis, State petr oleum cleanup programs across the USA are evaluated to determine similarities and differences in an effort to identify factors that affect petroleum cleanup progress. Many parameters enter th e equation in determining petroleum cleanup effectiveness. Not only are the parameters of the State program operation important, but also the characteristics of each State, includi ng drinking water source and perceived risk associated with petroleum contamina tion, factor into the determination. A representative group of States and State petroleum cleanup programs were evaluated and the characteris tics of States were compared to cleanup progress to determine factors affecting efficiency. Base d on trend analysis the cleanup levels for toluene, ethylbenzene and tota l xylenes correlate directly to the cost of LUST site cleanup. For States with less perceived risk from petroleum contamination, the cleanup goals are less stringent; therefore, fewer res ources and less time are required to complete site cleanup. Consequently, petroleum cleanup in States w ith less-stringent goals is achieved more efficiently. The knowledge of these drivers of efficient petroleum cleanup can be used to expeditiously pursue completi on of the thousands of sites remaining across the USA.
1 Introduction Since the invention of the fi rst fuel-powered vehicle in the early 1900s, the use of gasoline has increased steadily, prompting the need for production, distribution and storage of fuel. The first fuel production, dist ribution and storage faci lities were designed and operated without regard to health and e nvironmental concerns, such as contamination of drinking water supplies. The use of st eel underground storage tanks (USTs) to store gasoline until the 1980s resulted in the unint ended release of millions of gallons of gasoline to soil and groundwater. In light of the extensive environmental contamination, the tanks used to store gasoline have evolve d from steel to fiberglass and from singlewalled to doubled-walled. Storage facilities vary in the types of construction ma terial, liner material, and leak detection methods, depending on their phys ical size and whether they are owned and operated by major oil companies or by individual s. In addition, day-to-day operations at facilities and the potential for fuel spills a nd leaks from major terminals for bulk storage are vastly different than from small fueling stations with attached convenience stores or mechanic shops. In the 1970s and 1980s, with a new awar eness of health and environmental concerns, including detection of petroleum and byproducts in drinking water supplies, the
2 US Environmental Protection Agency (EPA) began implementing a strategy to prevent releases and clean up sites where releases had occurred. The agency analyzed multiple pathways of releases, including releases to the soil, groundwater, surf ace water and air. Consequently, new requirements were implemented, including controlling the emissions from vehicles and detecting leaks fr om USTs, among others (USEPA, 2004a). The increase in UST and leaking UST (LUST) regulation caused a demand for additional resources, including funds to c onduct petroleum cleanup and government staff to enforce the regulations and review the cl eanup progress. The review and enforcement of the regulations is served more efficientl y by people closer to the problems, such as Stateand County-level govern ment agencies. With increased government oversight, review and enforcement, the percentage of c onfirmed releases that have achieved cleanup completion is 75%, over the past 22 years (1984 to 2006) (USEPA, 2004a). While this percentage is relatively high, pe troleum cleanup progress needs to continue at an efficient rate to provide an end to the risks posed by petroleum constituents to human health and the environment. An increase in government resources require s maintenance of the efficient use of those resources. An evaluation of the e fficient use of government resources and a determination of potential improvements in efficiency to maintain progress toward the completion of petroleum cleanup is crucial. The subsequent sections of this paper attempt to provide insight into the methods used for efficiency evaluation and the progress many States have made toward completion of petroleum release cleanup.
3 Objectives The purpose of this thesis is to asse ss State petroleum cleanup programs and compare the drivers that affect program and cleanup progress including regulations, funding and technology. The overa ll goal is to determine th e major factors affecting petroleum cleanup progress. The specific objectives are: 1. Define effectiveness to allow comparison across State programs 2. Identify factors that positively a nd negatively affect cleanup progress 3. Compare State programs to delineate at tributes that result in cost-effective and efficient petroleum cleanup.
4 Approach The Federal and State petroleum cleanup pr ograms were researched and evaluated to achieve the objectives of this thesis. Prev ious research and available information were reviewed, critiqued, and summarized. Th e relative effectiveness of cleanup technologies and the availability and util ity of guidance documents for conducting cleanup were assessed. The overall study design c onsisted of four steps: 1. Evaluate the major elements of the Federal program, including the following: a. Objectives of the program b. Cleanup funding availability c. Funding source. 2. Compare the major elements of State programs to the Federal program and compare programs between States. 3. Evaluate features unique to th e Florida Petroleum Cleanup Program (FPCP) to determine if uniquenesss enhance or obstruct cleanup progress and why. 4. Analyze key factors affecting cleanup progress.
5 Federal Program Evaluation Because more than half of the US fo llows the EPA program, evaluating the EPA program is key to understanding and comparing the petroleum cleanup programs in the 50 States. The parameters that were evaluate d are: 1) objectives of the program, 2) source of funding, and 3) the amount of funding available. These data were used as a baseline when evaluating i ndividual State programs. State Program Evaluation The background research included collec ting key information about each State program, such as number of UST sites with releases, regulatory differences, groundwater cleanup goals, program setup details, success of the program based on percentage of sites completed, etc. Additionally, one reason w hy State programs and goals vary is local conditions; therefore, specific variables such as drinking wa ter source, soil type and cleanup regulations were researched. Finall y, cleanup technologies were analyzed to determine whether one cleanup technology was more prevalent or mo re effective than another. A comparison of State programs was summarized and presented in tabular format, to allow ease of review. The main criteria presented include the funding amount, the number of UST sites known to be leaking, and the number of sites cleaned to date.
6 Questions that were aske d include the following: 1. Do environmental factors influence pr ogram effectiveness, (e.g., soil type, water supply source, etc.)? 2. Is one State program more effective than others, based on the percentage of cleanups completed in a chosen timeframe? If so, why? 3. Have State programs evolved base d on whether cleanup progress has increased significantly throughout the life of the program? Evaluation of the Florida Petroleum Cleanup Program (FPCP) A thorough review of the Florida Pe troleum Cleanup Program (FPCP) was conducted to provide baseline information on a strong State program. Factors evaluated were: the initiation and evolu tion of the program,the procedures used to begin and maintain progress toward LUST site clea nup, and the technologies used for cleanup. Criteria used to evaluate information incl ude commonality, effectiv eness and cost. Finally, the FPCP was compared to other St ate programs to determine similarities and differences, and evaluate whether the FPCP Progr am is more or less effective than similar State programs. Statistical Analysis Based on the data collected throughout this thes is research, an evaluation of the factors affecting petroleum site cleanup can be conduc ted using statistical tools. Several
7 factors were analyzed to determine correlations and identify patterns which present useful conclusive information. The two-tailed unpaired t-test was used to evaluate the following relationships: 1. The average cleanup cost per site and the funding appropriations per number of releases 2. The benzene cleanup level and the percentage of sites completed 3. The benzene cleanup level and the effectiveness for each State. Additionally, various data were plotted to determine correlations such as those between the following: 1. Fuel consumption versus funding appr opriations, number of releases and percentage of sites completed 2. Average cleanup cost per site and indi vidual, as well as grouped, cleanup levels for benzene, toluene, ethylben zene, total xylenes, BTEX and MTBE 3. Government involvement level and percentage of sites completed.
8 Background Regulation and cleanup of LUST sites requires significant investment of resources, varying amounts of time and re liance on physical, chemical and biological treatment technologies. To ensure that petroleum cleanup programs are targeted at protecting public health and the environment, Federal and State regulations have been enacted over the past 20 years. The cleanup of petroleum contaminants requires design and implementation of technologies to remove contaminants or convert contaminants to benign compounds, coupled with monitoring and oversight. Defining effectiveness of a petroleum cleanup program depends on the di fficulty of cleanup based on geology, size and make-up of contamination, and implement ed technology, the resources of personnel and funding available and the age or maturity of the program. Initiation of petroleum cleanup requires an understanding of the risk s associated with petroleum contamination, the chemical composition of fuel, the numer ous programs and technologies used, and the effectiveness of those pr ograms and technologies. Birth of a National Issue Increased fuel usage resulted in increas ed production and handling of fuel in various forms. While the composition of fuel varied slightly between producers, the
main components of fuel remained similar. Th is increase is fuel usage with a variety of inconsistent operations, led to increased potential risks to water supply resources. Fuel Consumption and Composition Little variation exists nationwide in th e methods used for production, distribution, and storage of gasoline. Fuel consumpti on varies, however, as needed by population density. Total US fuel consumption be tween the period of 1999 and 2004 is shown on Figure 1. In 2004, oil provided 34.3% of the worlds energy supply, and the USA population consumed approximately 25% of this supply (IEA, 2006). The total fuel consumption over this time period decreased likely due to alternative fuel options increasing in popularity. 10,000 10,500 11,000 11,500 12,000 12,500 13,000 13,500 14,0001999 2000 20 0 1 2002 2003 2004Gallons per Year (Millions) Average Figure 1. Total Annual US Fuel Consumption (Source: IEA, 2006) 9
The 2004 distribution of fuel consump tion across the US is summarized in Figures 2a and 2b. In general, population dens ity drives the amount of fuel consumption as shown by the peaks in Figures 2a and 2b co rrelating to more populated States such as California, Florida, Texas, and New York. 0 500 1,000 1,500 2,000 2,500 3,000Al aba m a Ala sk a Ar iz o n a Ar kansa s Califor n ia C o lora do C o n n e c t i c u t Delaware Distr ic t o f C o lu mbi a Flo r ida Ge o rgia H a w aii I d a h o Illino i s Indian a Io w a Ka ns as Ken t u ck y Louisi a n a Ma i ne Ma r yl a nd Massach u s e tts Michigan M i n n e s o t a Mi ss i ssippiGallons per Year (Millions) 0 200 400 600 800 1,000 1,200 1,400 1,600Missouri M o ntan a N eb r a s ka Nevada New Hampshire New Jersey Ne w M e xico New Y o rk N o r t h Caroli n a North Dakota O hio Oklahoma O re gon Pen n sylvania Rh od e Isl an d S o u t h Ca r o l i n a S o u t h Da ko t a Ten n es se e T e xas Ut ah V e r mont Vir g i n i a Washington W e st Vi r g i nia Wisc on s i n Wyo m i ngGallons per Year (Millions) Figure 2. Fuel Consumption Per State in 2004 (Source, IEA, 2006) 10
11 Gasoline, one of many petroleum products, is composed of numerous volatile and semivolatile organic compounds including ben zene, toluene, ethylbenzene, xylenes (collectively BTEX), naphthalenes and ethylene dibromide. Originally, tetra-ethyl lead was added to gasoline to provide an octane en hancer. Following concerns with lead in engines, in 1979, methyl tertbutyl ether (MTBE) began to be used in gasoline to replace lead. The concentrations of MTBE in gasoline increased from between 2 and 8 percent to as high as 15 percent in 1992, to accommodate the requirem ents of the Clean Air Act (CAA) Amendments of 1990, which set oxygenate requirements for gasoline (NSTC, 1997, AFCEE, 1999). These requirements incl uded the Winter Oxyfuel Program and the Year-round Reformulated Gasoline (RfG ) Program which dictate an oxygen concentration requirement of greater than or equal to 2% by weight in gasoline. The areas of the US with the highe st concentration of toxic and ozone-depleting air emissions, such as highly-populated areas of California Texas and the eastern coastline portions of New York, Pennsylvania and New Jersey, were required to imp lement the use of RfG. Due to widespread groundwater contamination involving MTBE, in 2006, Federal legislation amended the CAA to remove th e oxygen concentration requirement (EPA, 2006a). Several alternative oxygenates are availa ble for use such as ethanol, ethyl tertbutyl ether (ETBE) and tert-b utyl alcohol (TBA); however MTBE was widely chosen based on its low volatility, bl ending characteristics and economic appeal. From an economic perspective if MTBE is available at less cost, competitive sales of fuel with
12 alternative oxygenates would be non-existent The main compounds in gasoline have varying physical and chemical prope rties as summarized in Table 1. Table 1. Physical and Chemical Properties of Select Gasoline Components Compound CAS Number Molecular Formula Solubility 2 (grams per Liter) Henrys Law Constant 3 (dimensionless) Maximum Contaminant Level (micrograms per Liter) Benzene 71-43-2 C6H6 1.79 0.152 5 Toluene 108-88-3 C 6 H 5 CH 3 0.53 0.157 1,000 Ethylbenzene 100-41-4 C 6 H 5 C 2 H 5 0.15 0.183 700 Xylenes 1 1330-20-7 C 6 H 5 (CH 3 ) 2 Practically insoluble 0.155 10,000 Ethylene dibromide 106-93-4 C 2 H 4 Br 2 8.68 Not available 0.05 Naphthalene 91-20-3 C 10 H 8 Insoluble 0.009 Not available MTBE 1634-04-4 CH 3 OC(CH 3 ) 3 50 0.017 Not available 1 xylenes are composed of three isom ers, ortho-, metaand para-xyelene The values presented are based on an average of values for all three isomers. 2 Values collected from Wikipedia 2006 3 Values collected from EPA online calculator (EPA, 2006b) As shown, solubility levels and Henrys La w Constants, or affinity to the vapor phase versus the water phase, vary over tw o orders of magnitude. These physical and chemical properties affect removal of th ese compounds from contaminated soil and groundwater. MTBE, for example, is highly soluble in water and less volatile than BTEX, as indicated by the comparison of da ta in Table 1. MTBE has a Henrys Law Constant of 0.017 whereas BTEX constituents have Henrys Law Constants an order of magnitude higher, which indicates BTEX cons tituents have more affinity to the vapor phase than the water phase. This higher solu bility and lower volatility of MTBE resulted
13 in MTBE persistence in the groundwater for a longer extent (distance and time) than BTEX constituents. Therefore, remediation of MTBE contamination requires more resources (time and money) than BTEX. Consequently, the cleanup effectiveness is impacted by longer timeframes required to complete cleanup. Water Supply Resources Petroleum releases threaten the use of gr oundwater, a valuable resource in the US. In 2000, 85% of the US population was served by public water supplies. Of that 85%, approximately 37% was supplied by groundw ater. Conversely, 15% of the US population relied on self-supplied water, of which 98% was supplied by groundwater. A comparison of the percentages of public-suppl y versus self-supply for each State is shown in graphical form in Figure 3. Th e percentages of groundwater versus surface water source for public-supply water are shown in Figure 4 (USGS, 2004).
0% 50% 100% Alabam a A l aska Arizo n a A rk an s as Califo r ni a Colorad o C o n nect i cu t De l aw a re Fl o rid a G e o r g ia Ha w ai i Id a ho I l l i noi s I n d ia n a I o wa Kansa s Kent u ck y L o u isi a n a Mai n e M ar y lan d Ma s sach u sett s Mich i ga n Min n e s o t a Miss is sip p i Public Supply Self-Supplied 0% 50% 100% Mis s ou r i Mo n t a n a N e bra s ka Nevada Ne w Ha mp sh i r e N e w J e r s e y New Me xico New Y or k North C a rol i n a Nort h D a ko t a Ohi o Oklahom a Oregon P e n n sylva n ia R h od e I sl a n d South Carolin a South Dakot a Tennesse e Texas Ut a h V er mo nt V irgi n i a W a sh i n gton West Virg i nia W i sc o ns i n Wy o mi n g P u erto Rico US Virgin Isl a nd s Public Supply Self-Supplied Figure 3. Public-Supply Versus Self-Supply in 2000 (Source: USGS, 2004) 14
0% 50% 100% Alabam a Alask a Arizo n a Ar k a ns a s Ca l ifor n i a Co l o r ad o Connectic ut De l a war e Flori d a Geor g i a H awa i i I d a h o I l li n oi s I n di a n a I o wa K ans a s Kentuck y Lo u i s i a n a Ma in e Ma r ylan d Mass a ch u set t s Michiga n Minneso ta Mississ i p p i Mi s so u ri GW % SW % 0% 50% 100% Montana Nebraska Ne v ada New H a m pshi r e N e w Je r se y New Mexico N e w Y o r k N o rth Carol i n a N o r t h Dako t a Ohi o Oklahom a O reg o n P e nn syl va ni a R h od e I sl a n d South Ca r olin a S o ut h Dako t a T e nne s see Texas Utah V e r mo n t V ir g inia Wa sh i ng t o n We st Vi r g i nia Wiscon s in Wyo mi n g Puert o Rico US V i rgi n I slan d s GW % SW % Figure 4. Public Supply by Source (USGS, 2004) In general, public-supply is the main s ource of water for the population in most States and surface water is the main s ource of public-supply water. Groundwater resources however, supply approximately 46% of the population in the US, and therefore, 15
16 threats to groundwater quality remain of concern. The US realized th is fact in the early 1980s and began the initiation of a Federal progr am to address potential risks associated with LUSTs. Federal UST Program Cleanup of LUST sites has been a priority for the US for more than 20 years due to the large number of sites, the potentia l harmful affects associated with gasoline constituents and the inability of site owners to pay the high costs of cleanup. In 1984, the US Congress amended the Resource Conser vation and Recovery Act (RCRA) to add Subtitle I which required EPA to establish regulations for USTs. The following year, the US EPA created the Office of Underground Storage Tanks (OUST), which remains in place today. The OUST began development of st andards and rules to regulate the use of USTs. The regulations were required to address the operation and maintenance of existing USTs, the installation of new USTs and the cleanup of LUSTs. The regulations included standards such as testing the USTs and undergr ound piping for tightness using pressurization of the USTs and lines, comp liance monitoring and other leak detection methods, including inventory reconciliation. The OUST communicated with the owners and operators of UST sites, State and local officials, environmental groups, environmental consultants and companie s such as McDonalds (EPA, 2004a). The EPA conducted a survey of establis hments around the US to attempt to determine the number of USTs in existen ce. Field verification and testing were
17 conducted at a select number of the facili ties to quantify the nu mber of USTs, their general use (i.e., farm, gasoline station, etc.) and tightness testing re sults. Approximately 35% of the non-farm USTs tested, or 189,000 USTs, did not pass the tightness testing, which indicates a leak had occurred and/or was continuing to occur (EPA, 1986). In 1986, the US Congress amended the RCRA Subtitle I, to create the LUST Trust Fund (Fund). The Fund was created sp ecifically to accomplish the following: 1. Oversee cleanups 2. Enforce cleanups 3. Pay for cleanups when the owner/operator was unwilling or unable to pay 4. Pay for emergency actions. The US LUST Trust Fund was created to provide a 0.1 cent Federal tax on each gallon of motor fuel sold in the USA. EPA administers money from the LUST Trust Fund to assist with UST cleanup programs (EPA, 2004a). In some cases, individual States have an additional tax to supple ment LUST funds and finance State cleanup programs for remediation of UST sites within the State. The EPA OUST realized that the enormous task emplaced on the agency would require involvement from State governments OUST used the approach of a business franchise for the implementation of the Fede ral UST program. Individual States could
18 create their own processes, goals, etc.; howev er, the regulation of USTs would maintain a consistent approach based on the Federal UST program. In 1988, the Federal UST regulations were promulgated and are located in the Code of Federal Regulations (CFR) Chapter 40, Part 280. UST operation and maintenance regulations included the requirement to install leak dete ction methods within five years, to close, upgrade or replace USTs within 10 years, and provide financial mechanisms to demonstrate the operator had th e financial resources available to clean up leaks from their tanks. The regulations also set forth requirements to report leaks and begin cleanup of leaks. Due to the abundance and distribution of US T sites, the EPA planned to have the UST program implemented by the States. The State programs have the option of either adopting the EPA requirements or implementi ng more stringent requirements for the operation and cleanup of UST sites. The EPA approval of State programs depe nds mainly on the financial assurance mechanisms required of the owners/operators by each State. States submit their financial assurance program details for approval from EP A. If the State program meets or exceeds the requirements of the Federal program, the EPA approves the State program. Owners and operators located in States without EP A-approved programs have to meet Federal financial assurance requirements through other means, such as insurance, a letter of credit, bonds, etc.
19 EPA published guidance for States maki ng a transition from State Funds to alternate financial mechanisms (EPA, 1997). The guide provides information on State Funds that have made the transition to private insurance or other means, and summarizes data regarding State Funds that were making the transition in 1997. Based on the strain on resources certain States acquired by provi ding the financial assurance for LUST cleanup, such as cumulative reimbursement claims for more funds than the State Programs were receiving annually, the backlog of claims outgrew the available income the funds received. States such as Florida and Texas experienced this level of cleanup activity and claims and were forced to iden tify alternate means to pay the backlog of claims and maintain protection of human health and the environment. Texas has an EPAapproved UST program to act in lieu of th e Federal program; whereas Florida does not have an EPA-approved UST program. Conseq uently, owners and operators in Florida need to comply with both the State regulations and the Federal regulations. The States regulations generally are more stri ngent than the Federal regulations. The LUST Trust Fund continues to recei ve money from a 0.1 cent tax on each gallon of fuel sold in the USA. In September 2005, the LUST Trust Fund had approximately $2.4 billion, of which the US Congress appropriated approximately $70 million for use by the program, which equals the amount the fund earns in interest each year. For fiscal year 2005, the EPA program had allocated approximately 85% of the annual appropriation to States and tribes (EPA, 2006a).
20 The EPA OUST Program continues to track the status of UST regulations, UST compliance and LUST cleanup across the USA, administers grants from the LUST Trust Fund to provide assistance to States and tribal lands for LUST cleanup and funds initiatives such as technical training. During the fiscal year of 2006, EPA provided approximately $60 million for cooperative agreem ents to increase the number of cleanups initiated. Additionally, approximately $15 million was supplied for supplemental Hurricane funding for States in EPA Regions 4 and 6 (Gulf of Mexico States). In June 2006, the OUST program reporte d that 63% of active operational UST systems are in compliance with release prev ention and release dete ction regulations and requirements. According to results from June 2006, the number of confirmed releases is 459,637. Of these releases, approximately 430,000 cleanups have been initiated and approximately 342,700 cleanups have been comp leted, which represents approximately 75% (EPA, 2006a). The State programs, incl uding 40 States, collectively accumulate and spend approximately $1 billion per year on LU ST cleanup, separate from the LUST Trust Fund (EPA, 2006a).
21 State UST Programs Petroleum cleanup programs tend to be mana ged at the State level; however, there are variations among State pr ograms in terms of informa tion access, risk perception, funding availability, regulatory review and how efficiently cleanup of LUST sites is completed. Some States rely solely on guida nce from the EPA for cleanup requirements. Several States, however, have highly-structur ed programs for petroleum cleanup that are more stringent than the Federal guidelines. While each of the State petroleum cleanup programs has evolved to meet specific require ments, and a comparison of various factors influencing program operation has been eval uated, a comprehensive comparison of the individual State programs has not been completed to date. Programs in individual States are based on assessment of risks posed by LUSTs, the level of effort required to implement re gulations and enforcement of regulations both for UST operations and LUST cleanup. Add itionally, the level of support from the Federal program versus the State su pport factors into the decisions. EPA encouraged the States to pursue creation of State petroleum cleanup programs based on the following ideas: 1. The size and complexity of the UST program requires numerous resources much more than the EPA can provide alone 2. State and local agencies are located in close proximity to the individual sites
22 3. State programs were required to be as stringent as the Federal regulations in order to act in lieu of the EPA. Currently, 35 States plus th e District of Columbia and Puerto Rico have approval from EPA for their UST programs (EPA, 2006a). The remaining States rely on alternate means for owners and operators to comply with financial assurance requirements, but maintain for the most part at least as stri ngent regulations for the installation, operation and maintenance of USTs and the cleanup of LUSTs. For those States without EPA approval, the EPA works with the States thr ough grants or cooperative agreements and the State is the primary lead in the impleme ntation and enforcement of the regulations. Approximately 40 States have UST cleanup f und programs. Appendix A provides a list of State program web addresses. EPA-Approved Programs EPA has approved 35 State Programs along with the District of Columbia and Puerto Rico. The approval mainly involves th e confirmation that Stat e regulations are as stringent as the Federal regulations, includi ng the installation, ope ration and closure of USTs and the financial responsibility required to operate USTs. This thesis will discuss the characteristics of two EPA-approved State Programs in comparison to non-EPA approved States. A summary of the States with EPA-approved programs is shown in Figure 5.
Figure 5. EPA-Approved Program States Non-EPA Programs Non-EPA approved State programs con tinue to operate under cooperative agreements or grants that provide the prim ary oversight in the enforcement of UST and LUST regulations. The main reason States do not have an EPA-approved program is the lack of a financial assurance mechanis m to accommodate the Federal regulations regarding financial responsibil ity. Owners and operators in these States must show financial responsibility through other means, su ch as commercial insurance, a letter of credit or bond. 23
24 Florida Petroleum Cleanup Program The Florida Petroleum Cleanup Program ( FPCP) is a unique, Non-EPA-approved program. The State of Florida passed legisl ation in 1984 requiring the creation of a UST Program to initiate UST compliance and leak prevention requirements. The Florida Department of Environmental Protection (FDE P), formerly the Florida Department of Environmental Regulation, was required to manage this effort. In 1986, the Inland Protection Trust Fund (IPTF) was created to pr ovide for the cleanup of LUST sites. The FPCP established criteria for the cleanup of LUST sites and created three eligibility programs. Remediation of petroleum sites involves coordinating engineering, field investigations, and treatment with re gulatory deadlines and specific operating timeframes. Federal and State regulations have been emplaced to assign generic timeframes to various steps in the petroleum cleanup process. For example, according to Chapter 62-770, Florida Administrative Code (FAC), for sites in Florida, a site assessment report must be submitted within 270 days from notification of a release of petroleum products (FDEP, 2005b). A summ ary of the regulatory timeframes is presented in Table 2 and a flowchart outlini ng the major activities associated with a petroleum cleanup process according to Chap ter 62-770, FAC is displayed in Figure 6. As shown, the entire sequence of events can take up to 12 years to complete for each individual site.
25 Table 2. Regulatory Timeframes Florida Activity or Event Timeframe Previous Event New petroleum release reporting 24 hours Release Free product recovery 3 days Discovery of free product Source Removal Report 60 days Completion of source removal activities. Site Assessment Report (SAR) 270 days Release Regulatory Review of SAR 30 days Submittal of SAR Remedial Action Plan (RAP) 90 days SAR approval Regulatory Review of RAP 60 days Submittal Remedial Action Implementation 120 days RAP approval Active Remediation 1 to 5 years RAP Implementation Regulatory Review of Remediation Completion 60 days Recommendation receipt Monitored Natural Attenuation or Post-Active Remediation Monitoring 1 to 5 years Regulatory approval Regulatory Review of No Further Action (NFA) 60 days NFA recommendation receipt ~12 years Theoretical Maximum Timeframe
Figure 6. Regulatory Flowchart, Chapt er 62-770, Florida Administrative Code 26 The eligibility programs encompassed vari ous funding levels and in some cases caps on funding based on the timeframe in which a site was reported to be a LUST site. The Early Detection Incentive (EDI) progr am was the first program, created in 1986, which assigned cleanup eligibility to a site if an owner/operator submitted a notification to FDEP based on an actual det ection of a petroleum release, or a potential indication of a release. The EDI program does not have a funding cap assigned; therefore, the FDEP provides for complete cleanup of these sites regardless of the cost. The application period for this program ended December 31, 1988.
27 The second program, created in 1989, was the Petroleum Liability and Restoration Insurance Program (PLRIP). This program was meant for active UST sites and the State underwrote the restoration por tion of insurance for new releases. The program had funding caps ranging from $1 million to $150,000 and deductibles ranging from $500 to $10,000, depending on the timeframe of application to the program. The application period for this program ended December 31, 1998. The third program, created in 1990, was the Abandoned Tank Restoration Program (ATRP) which was meant primarily fo r inactive sites that had closed business operations prior to March 1990. The applicati on period ended in June 1996; however, the program remains open for facilities where the owner/operator can not pay for the petroleum cleanup. This program does not ha ve a funding cap; howev er, a deductible is required. The early stages of the FPCP included these programs and cleanup was conducted either by a State-designated contractor, or a contractor designated by an owner, operator, or responsible party (RP). The work completed by the owner, operator or RP, was paid for by that entity and then a reimbursement request was submitted to the FPCP for consideration. The FPCP evaluated and issued payment for reimbursement of petroleum cleanup on a first-come, firstserved basis (FDEP, 2005a). From 1986 to 1996, the reimbursement claims submitted amounted to approximately $1.2 billion. The annual budget for reimbursement was approximately
28 $100 million. Due to the magnitude of petroleum cleanup work, the reimbursement claims amount exceeded the available funds Therefore, the 1995 Laws of Florida abruptly ended the reimbursement program, with $556 million remaining in claims unpaid (ASTSWMO, 1998). Even with the backlog of claims requiring payment, the FPCP could not completely shut down, or risks to the public and the environment would increase while the program awaited funding to address those risks. Consequently, the State sold bonds to pay for the remaining claims under the fo rmer reimbursement program and therefore, the annual cleanup budget could re main applicable to continue reducing the risks to public and environmental health. To continue site cleanup and maintain control of the expenditures, in 1996, the FPCP created the Preapproval Program. The Preapproval Program created a site scori ng system to evaluate the risk of the site characteristics to public and environmen tal health receptors. A portion of the Site Scoring Checklist is displayed in Figure 7.
Figure 7. FPCP Site Scoring Checklist The FPCP Preapproval Program relies on designated consultants to submit proposals for work to be completed and paid for by funds from the IPTF. The FPCP staff review and approve the proposals by issuing work orders to the consultants. Over the last ten years, the Preapproval Program procedur es and library of guidance documents has grown significantly. The guidance document s include a variety of cost guidelines, technical guidelines and program policies. The cost guidelines limited the specific cleanup components based on a lump sum amount per task. Tasks such as mobilization, soil boring installation, monitor well sampling, and various reporting ar e included. There is also a generic spreadsheet to use 29
for building up the cost for a task that does not already have a template amount. Additionally, sections for subcontractor costs and in-house service costs are included. A portion of the template cost worksheet us ed by the FPCP is displayed in Figure 8. Figure 8. FPCP Cost Template Worksheet The allowed cost for each task is determined based on typical values for personnel used, the time required to complete the task, pay rates for personnel, overhead costs and equipment costs. Additionally, laboratory anal ytical costs and dril ling rates are set by a survey of average costs. Periodically, the program evaluates whether a new survey of costs is needed to account for inflation or ot her changes that affect the cost of conducting cleanup activities (FDEP, 2005c). 30
31 The FPCP has created many technical a nd policy guidance documents over the 20-year history of the program. These docum ents range from the preferred procedures for installation of monitor wells to the complete guide for information to be considered for a Site Assessment Report (SAR). As the FPCP evolved, additional guidance documents were issued to accommodate consistent issues which required consistent resolution. The FPCP relies on five teams located in th e State capitol, Tallahassee, and issues contracts to Local Programs, often times a County government department. Currently, the FPCP has contracted 14 local programs to a ssist with the review and processing of the multiple reports, proposals, work orders and invoices generated each month. The five teams in Tallahassee and the staff from the Local Programs amount to approximately 230 people. The FPCP contracts the Local Programs due to the following: 1) provide personnel in close proximity to the sites to allow ease of site inspections, 2) have local knowledge of site conditions and local geology, and 3) have local contact with the local community. Through the use of Local Programs, the FPCP has less of a burden filling all the staffing needs from one central location. As reported at the June 2006 Annual Tanks Conference by the FPCP, approximately 6,700 petroleum cleanup sites are actively conducting assessment and/or remediation activities. Each site is assigned a priority score as detailed above and funding is appropriated each fiscal year according to the volume of activ ity anticipated for the high priority sites. For the 2006-2007 fiscal year, the funding amounts to approximately $181 million, to
provide for the administrative processing and cleanup activities associated with 4,201 sites scored 37 and above. The distribution of site scores is presented in Figure 9. SNS NIPVV OIPNT M RMM NIMMM NIRMM OIMMM OIRMM PIMMM PIRMMR N M N R O M OR P M PR QM Q R RMp=p EkW==^=~=~==~=Fk==pCurrent Work 2006: 4,201 Sites (Sites scored >36) Figure 9. Florida Petroleum Clea nup Program Site Score Chart The numbers presented next to each peak of the chart in Figure 9 represent the number of sites with the co rresponding score for the peak. For example, there are 1,399 sites with a score of 30. The di stribution of sites in these gro ups of score correlates to the scoring checklist in Figure 7. For example, a petroleum site located within -mile of a community well field producing 100,000 gallons pe r day or more receives a score of 20 for that characteristic. As can be determined in reviewing the entire scoring system, sites within -mile of a private potable well receive 20 points for this designation. Additionally, the geology and t ypes of petroleum present in the groundwater increase the 32
33 score. Consequently, numerous sites have similar characteristics and distance from private and public wells, which result in th e trimodal distribution of the groups of sites shown in Figure 9. When funding reaches a sufficient surplus to fund the assessment and remediation of 1,399 sites, the FPCP will lower the eligib le funding score to 30. Actually, large groups of sites such as those scored 30 will likely be sub-grouped to allow a lesser impact on the financial strain of the FPCP. For example, during the 2005-2006 fiscal year, the funding level was lowered to sites scored 30; however, onl y a group of approximately 300 sites were eligible for funding. This sub-group was based on t hose sites which had the earliest dated determination of eligibility for the EDI pr ogram within the group of sites scored 30. Upon initiating this funding leve l, a backlog of work orders from the FPCP developed and the work could not be funded due to the co ntrolled spending in place. Therefore, the funding eligibility level wa s raised at the end of the fiscal year to a score of 37 and above (FDEP, 2006). Throughout the history of the FPCP, the pr ogram has experienced fluctuations in fiscal health, including re ceiving cleanup reimbursement claims for a cumulative amount in excess of the annual funding amount. Fundi ng for the program has steadily increased over the last 10 years, from a low of appr oximately $45 million to the current budget of approximately $181 million. With increased funding came the ability to increase the
amount of petroleum cleanup work; howev er, increased program management requirements also followed. As a surplus aros e, the eligible funding score decreased to allow initiation of work on a dditional sites; however, as th e funding experienced backlog, the funding score increased, thereby crea ting an undulating program operation with uncontrolled uncertainty. The history of the eligible site scoring, detailing the fluctuations in eligible fundi ng scores, is shown in Figure 10. 0 10 20 30 40 50 60 70 801995 1 9 9 6 1997 1 9 9 8 1999 2 0 0 0 2 0 0 1 2002 2 0 0 3 2 0 0 4 2 0 0 5Funding Score Figure 10. Funding Score History The number of site closures achieved during each fiscal year (FY) and the fiscal year budgets are shown in Figure 11. As s hown by the chart, the fiscal year budget increased over time followed subsequently by an increase in the number of site closures. Due to the multiple factors and timeframes included in obtaining site closures, a delay of effect is evident by the graphs in Figures 11 and 12. For example, a fiscal year peak in FY01 presented a site closures peak in FY03. This trend is clearly identified by the plot in Figure 12, which includes the site closures per year versus the funding of the prior 34
fiscal year. Based on the plot in Figure 12, an increase in funding caused an increase in the number of site closures the following year. 0 100 200 300 400 500FY 9 7 FY 9 8 FY 9 9 FY 00 FY 0 1 FY 0 2 FY 0 3 FY 0 4 F Y 0 5 FY 0 6Fiscal YearClosures0 40 80 120 160 200FY Budget ($ millions) Closures FY_Budget Figure 11. FPCP Operation History y = 2.2574x + 20.5 R2 = 0.6816 0 100 200 300 400 5000 20 40 60 80 1 00 120 1 40 160Prior Fiscal Year BudgetNumber of Closures Figure 12. Site Closures Versus Prior Fiscal Year Budget 35
36 Determination of Program Effectiveness In recent years, government agencies have experienced increased scrutiny of their operations. Many factors affect petroleum cleanup including government efficiency. The following sections attempt to evaluate effectiveness for the purposes of this thesis and present methods of efficien cy evaluation previously used. Definition The US Congress passed legislation in 1993 entitled the Government Performance Results Act (GPRA). The pur poses of the GPRA are: 1. Holding Federal agencies accountable for achieving program results 2. Measuring program performance agai nst set goals, and publicly reporting the progress toward those goals 3. Improving Federal program effectiv eness and public accountability 4. Helping Federal managers improve service delivery 5. Improving internal management of the Federal Government. In 2002, President George W. Bush, pub lished the Presidents Management Agenda (PMA) calling for improved governme ntal agency management. The report outlined initiatives to improve fiscal ma nagement and reduce waste and abuse of government agency resources (OMB, 2002). In response to the PMA, the USEPA developed a Strategic Plan which set goals over a three-year period to continue
37 improving management of their programs for results. For example, the USEPA reported 7,332 cleanups completed, which represented 54 percent of their GPRA goal (EPA, 2006a). Additionally, the USEPA set up the En vironmental Council of States to involve State agencies with the Strategic Plan. Typically, petroleum cleanup programs use the number of sites cleaned up to quantify program effectiveness. A summar y of the 2006 details for each State and territory is given in Table 3. Table 3. State Petroleum Cleanup Statistics (Source: EPA, 2006b) State/ Territory Confirmed Releases Cleanups Initiated Cleanups Completed Percentage Completed AK 2,292 2,218 1,577 68.8% AL 10,962 10,802 9,362 85.4% AR 1,308 1,002 976 74.6% AZ 8,221 5,712 6,619 80.5% CA 44,510 44,510 30,133 67.7% CO 6,620 6,683 5,684 85.9% CT 2,483 2,431 1,636 65.9% DC 830 830 583 70.2% DE 2,309 2,194 2,044 88.5% FL 24,224 14,893 9,311 38.4% GA 11,183 10,798 8,683 77.6% GU 135 135 111 82.2% HI 1,856 1,760 1,532 82.5% IA 5,817 5,540 4,008 68.9%
38 Table 3. (Continued) State/ Territory Confirmed Releases Cleanups Initiated Cleanups Completed Percentage Completed ID 1,356 1,321 1,193 88.0% IL 22,626 21,415 14,969 66.2% IN 8,373 7,581 5,254 62.7% KS 4,648 4,425 2,705 58.2% KY 13,354 13,320 10,888 81.5% LA 3,034 3,034 1,810 59.7% MA 6,147 5,934 5,152 83.8% MD 10,346 10,089 9,489 91.7% ME 2,285 2,205 2,136 93.5% MI 20,962 20,525 11,924 56.9% MN 9,623 9,096 8,588 89.2% MO 6,214 5,837 4,873 78.4% MS 6,583 6,396 6,267 95.2% MT 2,918 2,131 1,799 61.7% NC 23,681 22,493 17,229 72.8% ND 813 804 779 95.8% NE 5,975 4,214 3,901 65.3% NH 2,254 2,254 1,436 63.7% NJ 9,799 8,942 5,807 59.3% NM 2,483 1,802 1,691 68.1% NV 2,418 2,410 2,188 90.5% NY 24,447 24,432 21,459 87.8% OH 23,799 23,224 20,838 87.6%
39 Table 3. (Continued) State/ Territory Confirmed Releases Cleanups Initiated Cleanups Completed Percentage Completed OK 3,557 3,557 2,940 82.7% OR 6,886 6,643 5,543 80.5% PA 14,017 13,542 10,031 71.6% PR 1,023 872 448 43.8% RI 1,253 1,253 997 79.6% SC 8,757 8,269 5,406 61.7% SD 2,354 2,354 2,170 92.2% TN 12,993 13,090 12,144 93.5% TX 24,460 21,721 20,750 84.8% UT 4,191 4,163 3,733 89.1% VA 10,641 10,364 9,845 92.5% VI 22 14 4 18.2% VT 1,937 1,925 1,159 59.8% WA 6,181 5,846 4,158 67.3% WI 18,451 17,817 15,284 82.8% WV 2,938 2,738 1,804 61.4% WY 1,992 1,592 933 46.8% Based on the data in Table 3, North Da kota, South Dakota and Tennessee have the most effective petroleum cleanup programs. However, this analysis overlooks other factors that may be importan t in determining the effectiveness of a State petroleum cleanup program, such as: groundwater clea nup target levels (also known as maximum contaminant level or action level), number of releases and available funding.
Furthermore, a States definition of clea nup may vary. For example, in Colorado, actions completed beyond No Action are considered to be cleanup completion. While other States require act ual completion of contaminant reduction before a cleanup is considered complete (ASTSWMO, 2004). In this thesis, the definiti on of program effectiveness is expanded to include the percentage of site cleanups completed in a State divided by the tota l number of releases in the US, divided by the dollars spent to achieve these cleanups, as shown by Equation 1: ) Funding Cleanup USTotal Completed Sites theCleanup Spent to Dollars ( ) USin the Releases Confirmed of # Total Completed Sites of # ( ess Effectiven (1) It is evident that a single definition of effectiveness cannot encompass the variability among State programs. To devel op a meaningful measur e of effectiveness a detailed analysis of several State programs was conducted. Methods of Evaluating Efficiency Over the past century the efficiency of governmental programs has been assessed and criticized by various entities. The earliest document discovered through this research indicates a Georgia Gorvernors Commissi on for Efficiency and Improvement in Government was created in 1963 to study th e organization and operation of the State 40
41 government and determine methods of improving government efficiency (Georgia, 2006). Several US Congressional H earings have evaluated the effectiveness of programs such as the GPRA, GPRA tools for performance budgeting, LUST Cleanup Programs, and Federal Government assistance to States in preparing for biological, chemical or nuclear attack, etc. One article supp orting information discussed during a US Congressional Hearing provides suggested methods of linking funding to program results. The methods include the creation of a Program whose sole purpose would be analysis of government programs to provide results to Congress and increased oversight by Congress of demonstrated results prior to allocating resources to programs. The report proceeds in evaluating the curr ent approaches used and the details of the recommended approaches (US House of Representatives, 2002). The Association of State Undergroun d Storage Tank Cleanup Funds (ASUSTCF) published at least two reports summarizing su ccess stories of State Fund Programs. In June 1998 and June 2000, the Third and Fifth Editions of the State Fund Success Stories Compendium were published by the ASUSTC F, supported by ASTSWMO. The report presents details from various State agenci es regarding financial success, policy, innovation and productivity successes and success with stakeholders. These editions of the Compendium provided an excerpt of more than 25 State Fund achievements in these three categories. The documents do not anal yze specifically the efficiency of State
42 programs, but share methods of achieving success in petroleum cleanup (ASUSTCF, 1998 and 2000). The financial success category reported a va riety of financial aspects related to UST operation and LUST cleanup. From provi ding grants to owners and operators to upgrade their UST systems, to innovative appr oaches of reducing the backlog of cleanup reimbursement claims, State programs have benefited by evaluating a more efficient system of conducting State busin ess, saving time and money. The policy, innovation and productivity category reported successes involving ideas such as technology design modifications standard report and invoice formats, and review process changes. Each of these id eas, as well as the others reported, provided time and cost savings. The successes with stakeholders cate gory contained reports of enhanced communication between regulators, the regulated community a nd the public in general. Providing open communication between the multitude of stakeholders in many cases allows improved acceptance of the cost and progress of petroleum cleanup. Through increased understanding of th e activities involved with completing pe troleum cleanup at a site, all parties involved are more educated, thereby providing more agreeable approaches to the cleanup completion.
43 These reports provide case studies in an effort to share lessons learned and the results of evaluating new approaches to petroleum cleanup. The reports provide sufficient detail to allow other State programs to benefit and increase their efficiency in addressing consistent factors affecting cleanup progress. Factors Affecting Cleanup Numerous factors are invol ved in the effective cleanup of petroleum in the Nations soil and groundwater. Theses factors include: 1. Site Operations 2. Physical and chemical characterist ics of the petroleum constituents involved 3. Size and age of the soil and groundwater impacts 4. Geology and hydrogeology of the LUST site 5. Cleanup goals 6. Funding available for cleanup 7. Level of government involvement 8. Use of effective cleanup technologies. Each factor has input into the more comprehensive equation for petroleum cleanup efficiency. Site operations can incl ude properties that are vacant to properties with dentists offices and a variety in between As discussed previ ously, the physical and chemical characteristics of petroleum constitu ents affect how readily those constituents
44 will degrade, desorb or disperse. Newer releases of petroleum have not traveled as far or had as much opportunity to adsorb to soils as older rel eases. Removing contaminants from less permeable soil can be more difficult that removing contaminants from soil that easily allows air and water passage. If fundi ng is not available for cleanup, contaminants will remain in the ground continuing to disperse. If government has stringent controls on the progress of petroleum cleanup, that progre ss can be slowed considerably as compared to a government that allows cleanup progress without stringent control. Finally, innovative technology attempts are made to remain cost-effective; however, the successful completion of petroleum cleanup may not occur as rapidly using an innovative technology versus a proven traditional technology. Petroleum Remediation Technology Petroleum remediation technology plays a key role in the timeframes associated with petroleum cleanup. The selected t echnology for a given site depends on the following site characteristics, among others: 1. Geology, including soil types, porosity 2. Hydrogeology, including depth to groundwater, groundwater flow characteristics 3. Contaminant Concentrations, including the distribution of mass in the soil and groundwater 4. Site operations, including land uses, locations of structures, underground and overhead utilities
45 5. Distance to potential exposure points or receptors, such drinking water sources. Based on the site characteristics, an an alysis of appropria te technologies was conducted including considerations regarding methods of conducting the remedial action, effectiveness of technologies, and costs associated with each technology. Common technologies include the following: 1. Soil Excavation with Ex-Situ Soil Treatment 2. Vapor Extraction 3. Air Sparging 4. Groundwater Recovery and Treatment (also known as Pump and Treat) 5. Multi-phase Extraction 6. Chemical Oxidation 7. Multiple forms of insitu innovative technologies in cluding the injection of microorganisms, injection of butane gas and steam injection. Each technology has parameters that determine whether the petroleum cleanup site is suited for the select technology. For example, the use of air sparging with vapor extraction is common in Florida due to the widespread sandy soils in the subsurface at varying depths. Air sparging involves the in jection of air into the groundwater forming bubbles which promote mass transfer through contaminant volat ilization. Vapor extraction involves the applica tion of a negative pressure to the subsurface soil to promote contaminant volatiliza tion as well as collect the vol atilized contaminants from
the air sparging operation. These operations de pend on air as the carrier of contaminants to be removed from the subsurface. Therefore, soil porosity is an important factor in the determination of site conditions suitable fo r the technology based on th e fact that if the air cannot move through the subsurface, the technology operations will not be able to recover the contaminants (Nyer et. al., 2001). A representation of air sparging with vapor extraction insitu treatment is displayed in Figure 13. Figure 13. Air Sparging with Vapor Extraction Technology (Source: EPA, 2004) A technology formerly common during the 1990s was groundwater recovery and treatment. This technology relied on water as the carrier of cont aminants and exsitu treatment, to reduce the distribution of contaminant ma ss. Groundwater was pumped from extraction wells and flowed through a variety of exsitu treatment operations, including air stripping, gr anular activated carbon and air sparging, for example. 46
47 Each of these insitu and exsitu treatment technologies rely on air or water as the carriers of contaminants. One issue with this reliance is the ability of the fluid to reach the contaminants. These methods rely on diffusion, dispersion and drainage characteristics of the subsurface soil and groundwater. Due to interstitial forces, soil pores cannot be entirely draine d; therefore, a limit of recoverability exists termed the drainage porosity (Hillel, 1998). Cleanup techno logies that rely on removing the water or air from pore spaces in soil will experience this physical limitation which may constrain the ability of the technology in completing site cleanup. Modifications to technology designs can overcome these limitations; how ever, early attempts involving these technologies suffered from this occurrence. Soil excavation and treatment is a common technology. This approach relies on physical removal of impacted soil, thereby providing a more eff ective removal of mass than the insitu treatment methods. Transportation and treatment of removed soil became increasingly costly and i nnovative technologies, and/or commonly used technologies evolved to present a cost benefit versus excavation. Depending on the site conditions, soil excavation and treatment can provide a cost efficient approach versus multiple years of operation and maintenance of an insitu treatment system (USEPA, 2004b).
48 Table 4. State Petroleum Reme diation Technology Statistics State/ Territory Excavation % Air Sparging % Bioremediation % Dual Phase Extraction % Pump & Treat % FL 12.9 44.3 11.3 15.0 16.4 OH 44.8 9.9 7.0 19.4 19.0 TX NA 10 90.0 NA Note: These data were gathered from personnel working in each State program (Chace, et al, 2006). The frequency of various treatment technol ogies by State is su mmarized in Table 4 for three States that provided data. These technologies have varying success based on the treatment system design, site lithology, and the treatment system implementation, operation and maintenance. Given the variables entering the petroleu m cleanup equation, St ate programs have received varying amounts of funding based on pe rceived risk to public and environmental health, legislative priorities and community involvement. Petroleum cleanup occurs at sites requiring varying amounts of funding per site. According to a 1995 study, the California LUFT program could have been enhanced by modification of various items and site cleanup would require an average of approximately $400,000 (University of California, 1995). As shown in Figure 14, the average cost per site varies by State. As indicated in Figure 14, the cost per site is highest in Flor ida, Michigan and California.
0 100 200 300 400 500Florida Mic h i g a n Ca li fo r n i a North C a rolina Texas OhioCost ($ thousands) Figure 14. Average Cleanup Co st per Site by State 49
50 Results A thorough review of the background inform ation provides insight to the various ingredients of a petroleum cl eanup process. Based on the information collected, results can be gathered to provide a useful comp arison of State petroleum cleanup programs. The factors affecting petroleum cleanup and a comparison of how State programs addressed these factors are presented in the following paragraphs. Based on the number of releases reported in various States a baseline selection of States with 20 to 24 thousand releases was chosen for comparison. A summary of the States and key data for each State are presented in Table 5. California is included based on the petroleum cleanup statistics for the St ate, which includes the highest number of releases and one of the highe st percentages for sites completed. A comparison of the percentage of groundwater supply per Stat e and the number of sites completed is presented in Figure 15.
Table 5. Summary of States Chosen for Comparison State EPA or Non-EPA Number of Releases Cleanup Program Type Groundwater Supply % % of Sites Completed Florida Non 24,224 Pre-approval 90.2 % 38.4 % Michigan Non 20,962 Reimbursement 21.7 % 56.9 % Illinois Non 22,626 Reimbursement 20.1 % 66.2 % California Non 44,510 Reimbursement 45.8 % 67.7 % North Carolina EPA 23,681 Pre-approved Reimbursement 22.7 % 72.8 % Texas EPA 24,460 Pre-approved Reimbursement 29.8 % 84.8 % Ohio Non 23,799 Reimbursement 34.0 % 87.6 % New York Non 24,447 None* 17.6 % 87.8 % *No funding available for responsible parties cleaning up old releases. 0% 20% 40% 60% 80% 100%Fl or i d a M i ch igan I l linois California N or t h C ar o lin a Texas O hi o New Yor k GW % Public Supply Sites Completed % Figure 15. Comparison of Groundwater Suppl y Percentage and Percentage of Sites Completed 51
52 Florida relies mainly on the groundwater re sources of the State to supply public water. Based on this fact, the FDEP a nd Florida legislature emplaced stringent requirements on the cleanup of contamin ated groundwater. A summary of the groundwater cleanup action levels for select petroleum constituents in each State, as weel as the Federal drinking water maximum contaminant level (MCL), is presented in Table 6. Table 6. Summary of State Gro undwater Cleanup Action Levels State Benzene Toluene Ethylbenzene Total Xylenes MTBE Florida 1 40 30 20 20 Illinois 5 1,000 700 10,000 NA Michigan 5 140 18 35 40 New York 1 5 5 5 10 North Carolina 1 1,000 550 530 200 Ohio 5 1,000 700 10,000 40 Texas 5 1,000 700 10,000 NA Federal MCL 5 1,000 700 10,000 NA The State of New York has more stringe nt requirements; th erefore, petroleum cleanup in New York versus Florida require s a longer timeframe. The Oil Spill Fund (OSF) in New York was created by legislature in 1977, to address cleanup of releases for which the responsible party was unknown or unwilling to pay for cleanup, or could not afford to clean up the release. Additiona lly, the fund provided settlements for claims against the responsible parties. The OSF pur sued cost recovery to the maximum extent
53 possible (NYSOSC, 2006). Ther efore, with the early origins of the program and the approach of firm protection of the public and environment, persons responsible for petroleum releases had many reasons to conduct cleanup quickly and limit their liability. As shown in Table 5, New York has the highest percentage of completed sites. In general, Florida has the second most-s tringent cleanup levels in comparison to the States listed in Table 6. This is due mainly to the high reliance on groundwater as a public-water supply source. Consequently, cleanup of petroleum releases to more stringent levels causes the need for additional time and resources to complete those cleanups thereby resulting in th e low percentage of complete d sites shown in Table 5. Progress is shown by Florida cleanup data as determined by the funding score trend in Figure 16. The trend identified indicates a combination of occurrences including an increase in funding received and the completi on of higher-scored sites; thereby providing an opportunity to lower the funding score and begin cleanup of lower-scored sites. Even with fluctuation, the overall trend is downwa rd, thereby indicating progress in addressing additional sites as higher-sc ored sites are completed.
y = -0.0084x + 356.92 R2 = 0.6315 0 10 20 30 40 50 60 70 801 9 95 1 996 1 997 1 99 8 1 9 99 2 000 2 001 2 002 2 003 2 0 04 2 0 05Funding Score Score Linear Trendline Figure 16. Florida Funding Score Trend Statistical analytical methods can be used to determine conclusive results. The two-tailed unpaired t-test was used to ev aluate relationships as detailed in the methodology section. A summary of data used for statistical analys is is presented in Table 7. Table 7. Summary of Statistical Data Inputs State Benzene Cleanup Level ( g/L) % of Sites Completed % of US Releases % of US Funding Spent Effectiveness Florida 1 38.4 2.02 11.10 0.18 Michigan 5 56.9 2.59 1.06 2.45 California 1 67.7 6.56 20.00 0.33 North Carolina 1 72.8 3.75 2.85 1.32 Ohio 5 87.6 4.54 1.20 3.78 Texas 5 84.8 4.51 7.78 0.58 Note: Total US dollars spent is a pproximately $10 billion (USEPA,2006a) 54
55 Upon analyzing the relationship between the benzene cleanup level per State and the percentage of sites completed, as we ll as the benzene cleanup level versus the effectiveness of the State program, the resu lts indicate no significant difference between the means and variances. Therefore, th e benzene cleanup level does not have a significant impact on the effec tiveness of individual State petroleum cleanup programs. The statistical analyses were conducted using the software program GraphPad, for which the print out of results is provided in Appendix B. Based on the various data collected, data plots assist in determining the correlations of variables. Da ta such as the average clea nup cost per site versus the individual petroleum constituents cleanup levels per State provide valuable information. Data included in Tables 6, 7 and 8 were us ed to evaluate plotte d relationship trends. Table 8. State Data Summary State Benzene Cleanup Level ( g/L) Number of Petroleum Cleanup Staff 10-year Appropriation ($ millions) Florida 1 230 1,110 Michigan 5 48 106 California 1 250 2,000 North Carolina 1 139 285 Ohio 5 17 120 Texas 5 63 778
Based on fuel consumption data presented in Figure 2, three relationships were evaluated. The relationship between fuel consumption per State and the 10-year appropriation, the appropriati on per number of releases and the percentage of site completed are displayed in Figur es 17 through 19, respectively. y = 0.5227x + 288.5 R2 = 0.4759 0 500 1,000 1,500 2,000 2,500 05001,0001,5002,0002,5003,000 Average Annual Fuel Consumption (milions of gallons)10-year Appropriation ($ millions) Cleanup appropriations Linear Trendline Figure 17. Fuel Consumption Versus 10year LUST Cleanup Appropriations y = 0.0178x + 8.9707 R2 = 0.8173 10 20 30 40 50 60 05001,0001,5002,0002,5003,000 Average Annual Fuel Consumption (milions of gallons)Appropriations per # of Releases Appropriations per # of Releases Linear Trendline Figure 18. Fuel Consumption Versus A ppropriations per Number of Releases 56
y = -0.0001x + 0.788 R2 = 0.4493 0% 20% 40% 60% 80% 100% 05001,0001,5002,0002,5003,000 Average Annual Fuel Consumption (milions of gallons)Percentage of Sites Completed % of Sites Completed Linear Trendline Figure 19. Fuel Consumption Versus Percentage of Site Completed The data presented in Figure 17 indicates that as fuel consumption increases, the amount of LUST funding increases. This re lates directly to the LUST funds creation being populated by a percentage of a cent tax on each gallon of fuel sold in each State. Consequently, more fuel sold in a State result ed in an increase in tax thereby providing an increase of cleanup funding appropriations. The data displayed in Figure 18 presents a similar trend as Figure 17. The appropriations over the last decade per the number of releases in each State increased with fuel consumption increase. This trend is skewed by the baseline of the data set chosen for analysis. The data set includes States with a similar number of releases, nearly 20 thousand, with the addition of California, which has over 40 thousand releases. As expected, an increase in fuel consumed in a State resulted in an increase in the appropriations for that State. 57
58 The plot in Figure 19 indicates that as fuel consumption increases, the percentage of sites completed decreases. This result is counterintuitive based on the previous two figures, which indicate States with higher fuel consump tion receive an increase in cleanup appropriations. Alternatively, an in crease in fuel consumption resulted in an increase in spill potential, which requires additional resources to complete cleanup. Therefore, additional factors beyond appropr iations affect the cleanup completion of these LUST sites. One of these additional factors is governm ental involvement. As Stated earlier, The State of New York has less involvement in petroleum cleanup than Florida. The New York petroleum cleanup program and regulations has also existed more than 10 years longer than Florida, for example. W ith the high percentage of sites completed in New York, an evaluation of government involvement is necessary. The government staff data summarized in Table 8 was used to create the plots in Figure 20.
0% 20% 40% 60% 80% 100% 050100150200250300 Number of PersonnelCompleted Sites Low involvement High involvement Figure 20. Government Involvement Plot The plots in Figure 20 sugge st that an increase in the number of government personnel does not necessarily provide an increa se in the number of completed sites. The trends for low versus high government involve ment are similar; however, additional data points are needed to verify this hypothesis. One final factor evaluated as part of th is thesis is the individual and grouped cleanup levels for various States As shown in Table 6, the selected States have a wide range of cleanup goals for constituents in groundwater. The trends for average site cleanup cost versus cleanup goals for benzen e, toluene, ethylbenzene, total xylenes, BTEX and MTBE are displayed in Figures 21 through 26, respectively. 59
y = -32x + 343.67 R2 = 0.2039 0 50 100 150 200 250 300 350 400 450 -123456 Benzene Cleanup Level (micrograms per liter)Cleanup Cost ($ thousands) Benzene Linear Trendline Figure 21. Benzene Cleanup Level V ersus Average Site Cleanup Cost y = -0.3136x + 421.71 R2 = 0.9755 0 50 100 150 200 250 300 350 400 450 -2004006008001,0001,200Toluene Cleanup Level (micrograms per liter)Cleanup Cost ($ thousands) Ethylbenzene Linear Trendline Figure 22. Toluene Cleanup Level Vers us Average Site Cleanup Cost 60
y = -0.4553x + 422.06 R2 = 0.8492 0 50 100 150 200 250 300 350 400 450 200400600800Ethylbenzene Cleanup Level (micrograms per liter)Cleanup Cost ($ thousands) Ethylbenzene Linear Trendline Figure 23. Ethylbenzene Cleanup Level Versus Average Site Cleanup Cost y = -0.0238x + 336.22 R2 = 0.5644 0 50 100 150 200 250 300 350 400 450 5,00010,00015,000Xylenes Cleanup Level (micrograms per liter)Cleanup Cost ($ thousands) Xylenes Linear Trendline Figure 24. Total Xylenes Cleanup Level Versus Average Site Cleanup Cost 61
y = -0.0227x + 353.3 R2 = 0.6503 0 50 100 150 200 250 300 350 400 450 5,00010,00015,000BTEX Cleanup Level (micrograms per liter)Cleanup Cost ($ thousands) BTEX Linear Trendline Figure 25. BTEX Cleanup Level Versus Average Site Cleanup Cost y = -0.4558x + 304.87 R2 = 0.1084 0 50 100 150 200 250 300 350 400 450 -50100150200250300MTBE Cleanup Level (micrograms per liter)Cleanup Cost ($ thousands) MTBE Linear Trendline Figure 26. MTBE Cleanup Level Versus Average Site Cleanup Cost The data presented in Figures 21 through 26 indicate that tolu ene, ethylbenzene and total xylenes influence the average site cleanup cost. Target levels of benzene and MTBE are not controlling fact ors in site cleanup costs. 62
63 Conclusions Each factor identified in this thesis is inherently involved in defining effectiveness of petroleum cleanup programs. For the purposes of this thesis, effectiveness is defined by Equation 1. The data in Table 7 summarize the effectiveness of State programs based on the definition in Equation 1. Factors that negatively aff ect cleanup progress include: 1. Stringent government involvement 2. MTBE presence (or other recalcitrant compounds) 3. Difficult lithology or hydrogeology that allows rapid movement 4. No available funding for cleanup 5. Inefficient technology or inad equately-designed technology implementation 6. Busy site operations or a building situated over the petroleum impacts below-ground 7. Stringent cleanup goals. These factors lengthen the amount of tim e required and require additional funding to complete LUST site cleanup. For example, a small areal extent of petroleum impacts
64 may pose a difficult cleanup if the lithology is no t permeable, or if the lithology is highly permeable, the impacts can be spread in groundwater over more than a -mile. Factors that positively affect cleanup progress include: 1. Less government involvement 2. Vacant sites 3. Sufficient funding 4. Conservative design, ade quate installation and op eration of remediation technology 5. Small size of impacts with lithology permeable enough to allow efficient insitu treatment 6. Less-stringent cleanup goals. Conservative design can often increase cost s of remediation system installation; however, overall cleanup timeframe and conseq uently cleanup costs can be reduced by instituting more effective treatment. One example of this approach to cleanup is the Florida Remedial Action Intiative (RAI). The RAI specified guidelines for system design, installation and operation to maintain remedial system operations at 80% runtime or greater. If runtimes decreased below 80% the contractor responsible for operating the system faces potential penalties, including being removed from the project (FDEP, 2004). This initiative may provide Florida with a unique approach to ma intaining the progress toward site cleanup.
65 In comparing State petroleum cleanup programs, many conclusions can be inferred. One conclusion is that New York has less government involvement than Florida and yet more stringent cleanup goals; theref ore, responsible parties are required to cleanup petroleum sites according to the regula tions. In Florida, petroleum cleanup of sites that are eligible for St ate-funding do not have to abide by the timeframes of the regulations due to the fact that the cleanups are implemented and c ontrolled by the State program. Less government involvement is more effective in this case. Secondly, Texas and Florida are similar in State characterist ics and pre-approval of petroleum cleanup costs; however, Texas requires cleanup to less stringent goals. Consequently, cleanup to lessstringent goals requires fewer resources and can occur in less timeframe. Additionally, pre-approval of petroleum cleanup costs in Texas involves submitting a proposal for work, but not awaiting a State work order to initiate the work; therefore, the timeframe of regulatory revi ew is reduced thereby reducing the overall timeframe of site cleanup. Thirdly, toluene, ethylbenzene and to tal xylenes cleanup goa ls affect cleanup costs and inherently affect th e timeframe for States with mo re stringent cleanup goals for these compounds. These States will experi ence increased cost and timeframes for cleanup. Consequently, the State effec tiveness may generally appear less than comparable States.
66 Finally, the Florida petroleum cleanup pr ogram is based on objectives protective of public health and the environment due to the shallow groundwater and the potential of LUST sites to impact the groundwater resources of the State. This heightened duty to protect public health and the environment pos itions Florida with the responsibility of providing more structured control of cleanup progress to ensure that cleanup approaches accommodate the multi-faceted concerns of the State.
67 Engineering Implications This thesis should provide environmental professionals with an initial understanding of factors that affect petr oleum cleanup to allow efficient planning, implementation and maintenance of petrol eum cleanup progress. The information contained herein can assist environmental engineers in understanding the requirements of petroleum cleanup in the State in which their site is located. The efficiency of petroleu m cleanup programs is currently evaluated as simply as can be without reservation of additional re sources to conduct in-depth analyses of programs. Certainly, a maturing program should experience constant improvement; however, the tools currently used in evaluating efficiency are sufficient for the government-mandated requirements emplaced on petroleum cleanup programs. Tools such as providing average cost of activities, pre-approving the costs of cleanup and instituting standard, conservative designs, will enhance and expedite the process of government review and approval of costs and technologies. Given the multitude of factors invol ved in determining petroleum cleanup effectiveness, an optimum program does not exist. Further evaluation of individual program details may expose potential enhan cements to optimize a cleanup program.
68 Additional Research The timeframes for site closure impact ev aluation of program effectiveness. Unfortunately, the data required to estim ate cleanup expenditures are not readily available. The majority of petroleum cleanup programs report the total number of closures and the total dollars spent; therefore, evaluation based on site-specific data is not feasible without significant investment of time for researching indi vidual site data. Additional research should be conducted to review and evalua te individual site data to statistically analyze the factor s involved in petroleum cleanup. With additional data and statistical analysis, perhaps an overwhelming factor can be identif ied and addressed to increase the efficiency of petrol eum cleanup programs across the US.
69 References The Association of State and Territorial Solid Waste Management Officials, State Response Programs: Measuring Success, 2004. The Association of State Underground St orage Tank Cleanup Funds, State Fund Success Stories Compendium, June 1998. The Association of State Underground St orage Tank Cleanup Funds, State Fund Success Stories Compendium, June 2000. Chace, Peter, Ohio Bureau of Underground Storage Tank Regulation; Meyers, Fred, Texas Commission on Environmental Quality ; Wright, John, Florida Bureau of Petroleum Storage Systems, 2006. Florida Department of Environmental Protecti on, Bureau of Petroleum Storage Systems, Remedial Action Initiative, March 2, 2004. Florida Department of Environmental Protecti on, Bureau of Petroleum Storage Systems, Preapproval Program Standard Operating Procedures, April 4, 2005. Florida Department of Environmental Protection. Chapter 62-777, Florida Administrative Code, Table I, April 17, 2005. Florida Department of Environmental Protecti on, Bureau of Petroleum Storage Systems, Preapproval Program Standard Operating Procedures Supplement, December 8, 2005. Florida Department of Environmental Protecti on, Bureau of Petroleum Storage Systems, Priority Score Funding Thre shold Notice, May 19, 2006. Georgia Environmental Protection Divisi on. Chapter 391-3-6, November 2004. Georgia Governors Commission for Effici ency and Improvement in Government, Collection of Agency Reports, University of Georgia, William Russell Library, Special Collections Section, accessed via world wide web, May 6, 2006. Hillel, Daniel, Environmental Soil Physics, 1998.
International Energy Agency, Key World Energy Statistics, 2006. New York State Office of the State Comptroller, Oil Spill F und Website, accessed May 21, 2006, http://nysosc3.osc.state.ny.us/oilspill Nyer, Evan K., Palmer, Peter L., Carman, Eric P., Boettcher, Gary, Bedessem, James M., Lenzo, Frank, Crossman, Tom L., Ror ech, Gregory J., and Kidd, Donald F., In Situ Treatment Technology, 2 nd Edition, 2001. Office of Management and Budget. Presiden ts Management Agenda, Fiscal Year 2002. United States Environmental Protection Ag ency. Underground Motor Fuel Storage Tanks: A National Survey. EPA-560/5-86-013, May 1986. United States Environmental Protection Agency. State Funds in Transition: Models for Underground Storage Tank Assurance Funds. EPA 510-B-97-002, January 1997. United States Environmental Protection Agen cy. Underground Storage Tanks: Building on the Past to Protect the Futu re. EPA 510-R-04-001, March 2004. United States Environmental Protection Agency. How to Evaluate Alternative Cleanup Technologies for Underground Storage Tank Sites. EPA 51-R-04-002, May 2004. United States Environmental Protection Agency. FY 2006 Mid-Year Activity Report, June 2006. United States Environmental Protection Agen cy. Online Henrys Constant Estimation Calculation, October 2006, http://www.epa.gov/athe ns/learn2model/parttwo/onsite/esthenry.htm United States Environmental Protection Agen cy, Office of Underground Storage Tanks, www.epa.gov/oust/ United States Geological Survey. Estimated Use of Water in the United States in 2000, 2004. United States House of Representatives, 107 th Congress. Linking Program Funding to Performance Results, Serial No. 107-228, September 19, 2002. University of California. Recommendati ons to Improve the Cleanup Process for Calfornias Leaking Underground Fuel Tanks (LUFTs), October 16, 1995. 70
72 Appendix A: State Petrol eum Program Web Addresses Table 9. State Petroleum Program Web Addresses State/ Territory Program Type World Wide Web Address U http://www.dec.State.ak.us/spar/ipp/ust.htm L http://www.dec.State.ak.u s/spar/csp/leaking.htm AK F http://www.dec.State.ak.us/spar/rfa/index.htm U http://www.adem.State.al.us/Wat erDivision/Ground/UST%20GW/G WUSTCompli.htm L http://www.adem.State.al.us/Wat erDivision/Ground/UST%20GW/G WUSTCorrAction.htm AL F http://www.adem.State.al.us/Wat erDivision/Ground/UST%20GW/G WALTankTrustFund.htm U,L http://www.adeq.State.ar.us/rst/ AR F http://www.adeq.State.ar.us/rst/branch_programs/trustfund.htm U,L http://www.azdeq.gov/environ/ust/index.html AZ F http://www.azdeq.gov/environ/ust/saf/index.html U,L http://www.swrcb.ca.gov/cwphome/ust/ CA F http://www.swrcb.ca.gov/cwphome/ustcf/index.html U,L http://oil.cdle.State.co.us/ CO F http://oil.cdle.State.co.us/OIL/Fund/fundindex.asp CT U,L http://www.dep.State.ct.us/wst/ust/indexust.htm DC U,L,F http://doh.dc.gov/doh/cwp/view,a ,1374,Q,585826,dohNav_GID,1813 ,.asp U,L http://www.dnrec.State.de.us/dnrec2000/Divisions/AWM/ust/ DE F http://www.dnrec.State.de.us/dnrec 2000/Divisions/AWM/ust/firstfund /default.asp
73 Appendix A: (Continued) Table 9. (Continued) State/ Territory Program Type World Wide Web Address U,L http://www.dep.State.fl.us/waste/categories/pss/default.htm FL F http://www.dep.State.fl.us/waste/categories/pcp/default.htm GA U,L http://www.gaepd.org/Documents/index_land.html HI U,L http://www.hawaii.gov/health/environmental/waste/ust/index.html U,L http://www.iowadnr.com/land/ust/index.html IA F http://www.iowadnr.com/land/ust/ustfundindex.html U,L http://www.deq.State.id.us/waste/ prog_issues/ust_lust/index.cfm ID F http://www2.State.id.us/pstf/ U http://www.State.il.us/osfm/PetroChemSaf/home.htm L http://www.epa.State.il.us/land/lust/index.html IL F http://www.epa.State.il.us /land/lust/ust-fund.html U http://www.in.gov/idem/programs/land/ust/index.html L http://www.in.gov/idem/programs/land/lust/index.html IN F http://www.in.gov/idem/programs/land/eltf/index.html U,L http://www.kdhe.State.ks.us/tanks/ KS F http://www.kdheks.gov/tanks/trust_fund/index.html U,L http://www.waste.ky.gov/programs/ust/default.htm KY F http://www.waste.ky.gov/ programs/ust/claims/ U,L http://www.deq.louisiana.gov/portal/Default.aspx?tabid=2440 LA F http://www.deq.louisiana.gov/portal/tabid/230/Default.aspx
74 Appendix A: (Continued) Table 9. (Continued) State/ Territory Program Type World Wide Web Address U http://www.mass.gov/dfs/osfm/fireprevention/ust/index.htm L http://www.magnet.State.ma.us/dep/bwsc/bwschome.htm MA F http://www.dor.State.ma.us/ust/ust_home.htm MD U,L,F http://www.mde.State.md.us/Progra ms/LandPrograms/Oil_Control/P ollutionManagement/index.asp U,L http://www.dnr.mo.gov/env/hwp/tanks/tanks.htm MO F http://www.pstif.org MS U,L,F http://www.deq.State.ms.us/MDEQ.nsf/page/UST_PageHome?Open Document U http://www.deq.State.mt.us/ust/ L http://www.deq.State.mt.us/rem/Index.asp MT F http://www.deq.State.mt.us/pet/index.asp U,L http://wastenot.enr.State.nc.us/programs.htm NC F http://ust.enr.State.nc.us/trus tfunds.html for forms see http://ust.ehnr.State.nc.us/forms.html ND U,L http://www.health.State.nd.us/wm/ust/index.htm U http://www.sfm.State.ne.us/programs-services/fuels/flst/ust.html NE L,F http://www.deq.State.ne.us /LUST-RA.nsf/Pages/LUST U http://www.des.State.nh. us/orcb/ustprog.htm L http://www.des.State.nh.us/orcb/irs_intro.htm NH F http://www.des.State.nh. us/ORCB/costprog.asp U,L http://www.State.nj.us/dep/srp/bust/bust.htm NJ F http://www.nj.gov/dep/srp/finance/ustfund/
75 Appendix A: (Continued) Table 9. (Continued) State/ Territory Program Type World Wide Web Address U,L http://www.nmenv.State.nm.us/ust/ustbtop.html NM F http://www.nmenv.State.nm.us/ust/caf.html U http://ndep.nv.gov/bca/ust_home.htm L http://ndep.nv.gov/bca/rem_home.htm NV F http://ndep.nv.gov/bca/fundhome.htm U http://www.dec.State.ny.us/website/der/bulkstor/index.html L http://www.dec.State.ny.us/we bsite/der/spills/index.html NY F http://nysosc3.osc.S tate.ny.us/oilspill/ U,L http://www.com.State.oh.us/sfm/bust/ OH F http://www.petroboard.com OK U,L,F http://www.occ.State.ok.us/Di visions/PST/USTDEAD.HTM OR U,L http://www.deq.State.or.us/wmc/tank/ust-lust.htm U http://www.depweb.State.pa.us/landrecwaste/cwp/view.asp?a=1240 &Q=453631&landrecwasteNav=|30786|30715| L http://www.depweb.State.pa.us/landrecwaste/cwp/view.asp?a=1241 &Q=461919&landrecwasteNav=|30816| PA F http://www.ins.State.pa.us/ins/c wp/view.asp?a=1333&Q=542426&in sNav=%7C&insNav_GID=1637 U,L http://www.State.ri.us/dem/programs/benviron/waste/index.htm RI F http://www.ustrb.State.ri.us/ SC U,L,F http://www.scdhec.gov/eqc/ust/index.html U,L http://www.State.sd.us/denr/DES/ground/tanks/tanksection.htm SD F http://www.State.sd.us/drr/reg/prcf/Prcfhome.htm
76 Appendix A: (Continued) Table 9. (Continued) State/ Territory Program Type World Wide Web Address U,L http://www.tennessee.gov/environment/ust/ TN F http://www.tennessee.gov/environ ment/ust/fund&reimburs.shtml U http://www.tceq.State.tx.us/ nav/permits/pst_cert.html L http://www.tceq.State.tx.us/nav/cleanups/pst.html TX F http://www.tceq.State.tx.us/permitting/review/reimbursement/ U,L http://undergroundtanks.utah.gov UT F http://www.deq.State.ut.us/EQERR/ ust/ustcomp/whatisthepstfund.ht m U,L http://www.deq.State.va.us/tanks VA F http://www.deq.State.va.us/tanks/reimbrs.html VT U,L,F http://www.anr.State.vt.us/ dec/wastediv/ust/home.htm U,L http://www.ecy.wa.gov/programs/tcp/ust-lust/tanks.html WA F http://www.plia.wa.gov/ust/index.htm U http://www.commerce.State.wi.us/ER/ER-BST-HomePage.html L http://www.dnr.State.wi.us/org/ aw/rr/cleanup/ust_lust.html WI F http://www.commerce.State.wi.u s/er/er%2Dpecfa%2Dhome.html WV U,L http://www.dep.State.wv.us/item.cfm?ssid=13&ss1id=729 WY U,L http://deq.State.wy.us/shwd/stp/ U.S. Territories CNMI U,L http://www.deq.gov.mp/aupm/AUPM%20main.htm GU U,L http://www.guamepa.govguam.net/ VI U,L http://www.dpnr.gov .vi/dep/tanks.htm U = UST, L = LUST, F = Fund
Appendix B: Statistical An alysis Input & Outputs 77
Appendix B: (Continued) 78
Appendix B: (Continued) 79