August 1996
The deadline for compliance with the underground storage tank (UST) regulations is fast approaching. Companies that do not adequately plan to meet the December 22, 1998 deadline by beginning the process this year, may find that they are unable to comply. By starting the process of upgrading, closing or replacing USTs now, owner/operators can avoid potential problems such as:
But proper planning is not the only element necessary for a successful UST program. Understanding your options, and selecting the right contractor for your situation will will have a direct impact on your program.
The owner/operator's final option is to remove the existing UST and either fill in the hole or replace it with a new tank. Regardless of which route he elects, the owner still must have the soil surrounding the tank site sampled and tested for contamination.
Contamination standards in Michigan, however, have recently been eased to offset the elimination of MUSTFA. For example, cleanup standards for benzene in soil have been relaxed from 5PPM to 100PPM, effectively reducing the number of sites that previously would have required remediation.
If soil sampling during a UST closing or removal reveals that the site is contaminated, then the nature and extent of the contamination must be determined through site assessment and subsurface soil and groundwater testing. Once the exact nature of the contamination has been determined then the appropriate remediation technique can be selected.
The most frequent resource to be contaminated by leaking USTs is soil, which can be remediated through several techniques. Each decontamination techniques offer advantages and disadvantages that vary according to the characteristics of the UST site.
If a site has sandy soil and is contaminated with gasoline type product, then soil vapor extraction is a viable option. Soil vapor extraction can be accomplished in-situ or above-ground. In-situ soil vapor extraction relies on the optimized capture of contaminants from the unsaturated soil and the subsequent treatment through vapor-phase carbon absorption or catalytic destruction.
If the contaminant has reached the groundwater, then soil vapor extraction can be combined with sparging or pump and treat depending on the extent of the contamination.
Thermal desorption is another proven method for removing petroleum-based contaminants from soils and requires heating contaminated soils in a primary chamber, such as a kiln, and the subsequent destruction of the contaminants in a combustion chamber or catalytic unit. Thermal desorption is the most costly of the three systems and frequently is the least palatable alternative to property owners. A more viable approach for most sites is removing the contaminated soil from leaking petroleum UST areas for processing at a thermal treatment facility, which resembles an asphalt plant.
If the UST site has high permeability, shallow depth of contamination, and offers the ability to control the movement of fluids introduced into the subsurface, then bioremediation may be the most appropriate technique. Bioremediation can be used insitu or in above-ground reactors and is applicable where site constraints and time limitations are not critical factors. With in-situ bioremediation, nutrients and micro-organisms are introduced into the site through recharge wells. Bioremediation also can be accomplished by excavation of the soil and treatment in above-ground reactors for those sites where soil characteristics would prevent adequate exposure of contamination to injected nutrients and microorganisms.
Often the key to the successful resolution of a UST problem, be it upgrading, closing or removing the tank, depends more on the quality and experience of the consultant retained than the technique used. Not all firms are equally qualified to provide UST services even if they satisfy the legal definition of "qualified". Michigan law requires that a UST consulting firm have pollution liability insurance and at least one qualified professional on staff to supervise investigations and remediations.
To be 'qualified' , a professional such as a licensed engineer must have a minimum number of years of experience. However, it is possible for someone to satisfy these credential requirements yet still lack substantial hands-on UST experience. To ensure that your UST consultant has the first-hand experience required, ask for a list of prior UST projects the professional has supervised and then contact several of the past clients for their evaluation of the individual and the firm itself.
For more information on environmental programs for your business, contact Mr. Thomas Wackerman, Managing Partner at Applied Science &Technology, Inc. at 800.395.ASTI or visit our homepage
Property development has been strong over the past few years, and changes to environmental regulations have assisted many developers in developing while protecting the environment. Next issue we will look at developments in wetlands regulations effecting property development.
On October 10, Applied Science &Technology, Inc., in conjunction with Dickinson, Wright, Moon, VanDusen &Freeman, will present a breakfast seminar for bankers and financial institutions on property investigations, remediation and closure. For reservations or more information call Lenna Dietrich at 1-800.395.ASTI.
Applied Science &Technology, Inc. staff is presenting a one semester course on Environmental Information Management using the Internet. at Wayne State University in Detroit, Michigan. The course starts January, 1997 and is taught entirely on the Internet. For more information call Tom Wackerman at 800.395.ASTI or send email request to twacker@chem1.eng.wayne.edu
6th Unless exempted, each seller or lessor of more than four residential dwellings built before 1978 must comply with lead-based paint disclosure requirements. [TSCA: 24 CFR 745, FR 3/6/96]
19th Owners and operators of marine tank vessel loading operations operating before September 19, 1995 must notify the EPA if they are subject to the hazardous air pollutant emissions standards. [CAA: 40 CFR 63, FR 9/19/95]
19th Land disposal prohibited for radioactive waste mixed with the newly identified organic toxicity characteristic wastes and the newly listed coke by-product and chlorotoluene production wastes. [RCRA: 40 CFR 268.38, FR 9/19/94]
23rd Owners and operators of an existing dry cleaning facility subject to emissions standards must comply with emission control, testing, monitoring, and reporting requirements. [CAA: 40 CFR 63.320, FR 12/20/93]
25th Pollution prevention plans and compliance programs for general permits for industrial storm water discharge must be completed. [CWA: FR 2/9/96]
TECH-BITS is a monthly publication of Applied Science &Technology, Inc. (ASTI), P.O. Box 1328, Ann Arbor, Michigan, 48106. For a free mail subscription call 800.395.ASTI. For a free electronic subscription, send an email message to twacker@chem1.eng.wayne.edu, referencing Tech-Bits in the body of the message.
TECH-BITS is intended to provide information concerning current environmental issues, and is not intended to provide technical or legal advice regarding any particular situation. Questions about individual situations should be addressed to your environmental engineer. Copyright 1995 by ASTI