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Development of a Systematic Approach for Analyzing Risk-Based Corrective Action Plans Applied at Petroleum Release Sites

Permanent Link: http://ufdc.ufl.edu/UFE0024191/00001

Material Information

Title: Development of a Systematic Approach for Analyzing Risk-Based Corrective Action Plans Applied at Petroleum Release Sites
Physical Description: 1 online resource (202 p.)
Language: english
Creator: Lewis, Don
Publisher: University of Florida
Place of Publication: Gainesville, Fla.
Publication Date: 2009

Subjects

Subjects / Keywords: action, based, biodegradation, cercla, control, corrective, countermeasure, epa, fdep, natural, oil, plans, prevention, quality, rbca, risk, spcc, spill, storage, water
Civil and Coastal Engineering -- Dissertations, Academic -- UF
Genre: Civil Engineering thesis, Ph.D.
bibliography   ( marcgt )
theses   ( marcgt )
government publication (state, provincial, terriorial, dependent)   ( marcgt )
born-digital   ( sobekcm )
Electronic Thesis or Dissertation

Notes

Abstract: This dissertation reviews environmental laws and analyzes the results of risk-based management procedures mandated by Congress. The United Sates Congress ordered that state and federal cleanup funds be disbursed based on a quantifiable, risk-based formula and that information about each discharge be collected and stored in a publicly accessible database. After a thorough literature review, no researcher has examined or documented the results contained therein. Data collected by field inspectors evaluating discharges of various types was evaluated in Minitab, and the results show interesting contrasts among various levels of enforcement. Enforcement of environmental laws was shown to be a function of fuel tax rates, particularly the local option sales tax that many counties have imposed to acquire environmentally sensitive lands, enforce state and federal laws regarding protection of the environment, and fund local Departments of Environmental Protection (DEP). Alachua County has historically been on the cutting edge of passing and strictly enforcing environmental laws. In fact, Alachua County has on several occasions tried to adopt local codes that are more stringent than state law only to have the effort be ruled unconstitutional. A stepwise comparison showed this county to score discharges above the quantified level of risk of the rest of the state but clearly below the funding threshold. This result is significant in the sense that when discharges do occur in Alachua County, one is more likely to face fines and penalties without cleanup reimbursement from the IPTF trust fund. Another surprising result of this research is that Miami-Dade County, which has adopted its own set of environmental guidelines separate from the rest of the state (e.g., vapor recovery), had a much lower overall score mean and a corresponding higher average ranking. These differences compare equally to Alachua County and other counties that have adopted the highest allowable local option motor fuel tax. Additionally, rural counties tended to have fewer discharges at higher overall scores, above the funding threshold, than more urban counties. A discharge and its corresponding level of contamination are scored based on the amount of hydrocarbons released into the environment and the exposure of the discharge to potable wells. Fire and explosion hazards also figure into the scoring review, as do the migration potential and overall environmental setting the discharge occurs in. Ideally, this review is based on the facts pertaining to each discharge. If this is true, then a random sample of data selected from the main database should provide an even representation of discharges without noticeable differences between the main database and the sample. However, noticeable differences were detected using 95% confidence intervals with a P-value of < 0.005. The data followed a classic normal distribution, thereby facilitating the use of the Student s t-distribution to illustrate the margin of error and mean. Box plots also were used to compare the median or the centermost value among different counties. It was interesting to note that the results showed considerable bias in the reporting of discharges. Counties with higher tax rates consistently ranked higher than the rest of the state and had lower overall scores.
General Note: In the series University of Florida Digital Collections.
General Note: Includes vita.
Bibliography: Includes bibliographical references.
Source of Description: Description based on online resource; title from PDF title page.
Source of Description: This bibliographic record is available under the Creative Commons CC0 public domain dedication. The University of Florida Libraries, as creator of this bibliographic record, has waived all rights to it worldwide under copyright law, including all related and neighboring rights, to the extent allowed by law.
Statement of Responsibility: by Don Lewis.
Thesis: Thesis (Ph.D.)--University of Florida, 2009.
Local: Adviser: Glagola, Charles R.

Record Information

Source Institution: UFRGP
Rights Management: Applicable rights reserved.
Classification: lcc - LD1780 2009
System ID: UFE0024191:00001

Permanent Link: http://ufdc.ufl.edu/UFE0024191/00001

Material Information

Title: Development of a Systematic Approach for Analyzing Risk-Based Corrective Action Plans Applied at Petroleum Release Sites
Physical Description: 1 online resource (202 p.)
Language: english
Creator: Lewis, Don
Publisher: University of Florida
Place of Publication: Gainesville, Fla.
Publication Date: 2009

Subjects

Subjects / Keywords: action, based, biodegradation, cercla, control, corrective, countermeasure, epa, fdep, natural, oil, plans, prevention, quality, rbca, risk, spcc, spill, storage, water
Civil and Coastal Engineering -- Dissertations, Academic -- UF
Genre: Civil Engineering thesis, Ph.D.
bibliography   ( marcgt )
theses   ( marcgt )
government publication (state, provincial, terriorial, dependent)   ( marcgt )
born-digital   ( sobekcm )
Electronic Thesis or Dissertation

Notes

Abstract: This dissertation reviews environmental laws and analyzes the results of risk-based management procedures mandated by Congress. The United Sates Congress ordered that state and federal cleanup funds be disbursed based on a quantifiable, risk-based formula and that information about each discharge be collected and stored in a publicly accessible database. After a thorough literature review, no researcher has examined or documented the results contained therein. Data collected by field inspectors evaluating discharges of various types was evaluated in Minitab, and the results show interesting contrasts among various levels of enforcement. Enforcement of environmental laws was shown to be a function of fuel tax rates, particularly the local option sales tax that many counties have imposed to acquire environmentally sensitive lands, enforce state and federal laws regarding protection of the environment, and fund local Departments of Environmental Protection (DEP). Alachua County has historically been on the cutting edge of passing and strictly enforcing environmental laws. In fact, Alachua County has on several occasions tried to adopt local codes that are more stringent than state law only to have the effort be ruled unconstitutional. A stepwise comparison showed this county to score discharges above the quantified level of risk of the rest of the state but clearly below the funding threshold. This result is significant in the sense that when discharges do occur in Alachua County, one is more likely to face fines and penalties without cleanup reimbursement from the IPTF trust fund. Another surprising result of this research is that Miami-Dade County, which has adopted its own set of environmental guidelines separate from the rest of the state (e.g., vapor recovery), had a much lower overall score mean and a corresponding higher average ranking. These differences compare equally to Alachua County and other counties that have adopted the highest allowable local option motor fuel tax. Additionally, rural counties tended to have fewer discharges at higher overall scores, above the funding threshold, than more urban counties. A discharge and its corresponding level of contamination are scored based on the amount of hydrocarbons released into the environment and the exposure of the discharge to potable wells. Fire and explosion hazards also figure into the scoring review, as do the migration potential and overall environmental setting the discharge occurs in. Ideally, this review is based on the facts pertaining to each discharge. If this is true, then a random sample of data selected from the main database should provide an even representation of discharges without noticeable differences between the main database and the sample. However, noticeable differences were detected using 95% confidence intervals with a P-value of < 0.005. The data followed a classic normal distribution, thereby facilitating the use of the Student s t-distribution to illustrate the margin of error and mean. Box plots also were used to compare the median or the centermost value among different counties. It was interesting to note that the results showed considerable bias in the reporting of discharges. Counties with higher tax rates consistently ranked higher than the rest of the state and had lower overall scores.
General Note: In the series University of Florida Digital Collections.
General Note: Includes vita.
Bibliography: Includes bibliographical references.
Source of Description: Description based on online resource; title from PDF title page.
Source of Description: This bibliographic record is available under the Creative Commons CC0 public domain dedication. The University of Florida Libraries, as creator of this bibliographic record, has waived all rights to it worldwide under copyright law, including all related and neighboring rights, to the extent allowed by law.
Statement of Responsibility: by Don Lewis.
Thesis: Thesis (Ph.D.)--University of Florida, 2009.
Local: Adviser: Glagola, Charles R.

Record Information

Source Institution: UFRGP
Rights Management: Applicable rights reserved.
Classification: lcc - LD1780 2009
System ID: UFE0024191:00001


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1 DEVELOPMENT OF A SYSTEMATIC APPROACH FOR ANALYZING RISK-BASED CORRECTIVE ACTION PLANS APPLIED AT PETROLEUM RELEASE SITES By DON WINFIELD LEWIS A DISSERTATION PRESENTED TO THE GRADUATE SCHOOL OF THE UNIVERSITY OF FLOR IDA IN PARTIAL FULFILLMENT OF THE REQUIREMENTS FOR THE DEGREE OF DOCTOR OF PHILOSOPHY UNIVERSITY OF FLORIDA 2009

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2 2009 Don Winfield Lewis

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3 To my late father, Hugh Wendell Lewis

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4 ACKNOWLEDGMENTS Most of all, I would like to thank m y parents, Wendell and Jualene Lewis, for their constant support of my higher ed ucation. I would like to also th ank my brother and sister for their strong encouragement during my studies. At this time, I would like to also acknowledge Dr. Ralph Ellis, Dr. Charles Gl agola, Dr. Edward Minchin, an d Dr. Fazil Najafi for being members of my supervisory committee.

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5 TABLE OF CONTENTS page ACKNOWLEDGMENTS ............................................................................................................... 4TABLE OF CONTENTS ............................................................................................................. ....5LIST OF TABLES ...........................................................................................................................9LIST OF FIGURES .......................................................................................................................10ABSTRACT ...................................................................................................................... .............15 CHAP TER 1 INTRODUCTION .................................................................................................................. 17Oil Pollution Overview ...........................................................................................................17Properties of Petroleum-Based Oils ................................................................................19What is crude oil? ..................................................................................................... 21Types of crude oil .....................................................................................................21Non-petroleum Oils ......................................................................................................... 24Fate of Spilled Oil ...........................................................................................................25Intrinsic bioremediation of petroleum hydrocarbons ...............................................25Demonstrating the occurrence of biodegradation ....................................................26What Is Tank and Piping Secondary Containment? ............................................................... 30Facility Response Planning .............................................................................................33Memorandum of Understanding ...................................................................................... 34Floridas Air and Water Pollution Control Act ...................................................................... 34The Clean Water Act ..............................................................................................................38The Love Canal Tragedy .................................................................................................39Comprehensive Environmental Response, Compensation, and Liability Act ................ 40Spill Prevention Control and Countermeasure Plans Task Force ................................... 42Application of CERCLA ........................................................................................................ 46Comprehensive Environmental Response, Compensation, and Liability Act Responsible Parties ......................................................................................................47Degradation of Storage Tanks .........................................................................................48Problems Associated with Internal Corrosion ................................................................. 50Oil Pollution Act .....................................................................................................................51Edible Oil Regulatory Reform Act ......................................................................................... 56Purpose and Scope of SPCC Rule .......................................................................................... 57The Energy Policy Act of 2005 .............................................................................................. 57Floridas Petroleum Cleanup and Discharge Prevention Program .........................................59FDEP Program Statistics ....................................................................................................... .60Summary ....................................................................................................................... ..........60

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6 2 LITERATURE REVIEW .......................................................................................................62Risk-Based Decision Making a nd Underground Storage Tanks ............................................ 62Health Risk Assessment for a Contaminated Site: A Case Study ................................... 62ASTM RBCA Fate and Transport Models: Compendium and Selection Guidance ....... 63Use of Risk-Based Decision Making in UST Corrective Action Programs .................... 63Application of Health Risk Assessment to Derive Cleanup Levels at a Fuel Oil Spill Site .......................................................................................................................64A Foundation for the Risk-Based Treatment of Gasoline-Contaminated Soils Using Modified Fentons Reactions .......................................................................................65Environmental and Health Risk Assessm ent and Management, Principles and Practices .......................................................................................................................66California Leaking Underground Fuel Tank (LUFT) Historical Case Analyses ............ 67A Risk-Based Corrective Action Approach Using Computer Mode ling at an Urban Leaking Underground Storage Tank Site .................................................................... 69The Toxicologic Hazard of Supe rfund Hazardous Waste Sites ...................................... 70Risk-Based Corrective Action, Natural Attenuation, and Cha nging Regulatory Paradigms ..................................................................................................................... 70An Outline of a Guidance Framework for Assessing Hydro-Geological Risks at Early Stages .................................................................................................................71Natural Attenuation of Contaminated Soils .................................................................... 72Survey of States 2001 Soils Cleanup St andards for Petroleum Contamination .............72Managing Subsurface Property Hazards: R eactive Soils and Underground Storage Tanks ......................................................................................................................... ...73Revealed Preferences of a State Bure au: Case of New Mexicos Underground Storage Tank Program .................................................................................................73Recommendations to Improve the Clea nup Process for Californias Leaking Underground Fuel Tanks (LUFT) ................................................................................74Principal Research Questi ons to Be Addressed ...................................................................... 743 RESEARCH METHODOLOGY ...........................................................................................76Learning from Data .................................................................................................................76Defining the Problem ......................................................................................................77Collecting Data ............................................................................................................... .77Sampling Designs for Surveys ........................................................................................80Data Management ............................................................................................................81Summarizing Data on a Single Va riable: Graphical Methods ................................................82The Box Plot ....................................................................................................................85Inferences about for a Normal Population, Unknown ...............................................87The Program Best Suited to Answer the Research Questions ................................................904 ANALYSIS OF FINDINGS ................................................................................................... 93Quantify Sources of Petroleum Product Contamination and Their Impacts on the Environment ................................................................................................................... .....93Florida Department of Environmental Pr otection (FDEP) Facility Statistics ................. 95

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7 Review of Regulations ....................................................................................................97FDEP Statistics ................................................................................................................98Field-erected above-ground storage tank statistics .................................................. 98Shop-fabricated above-ground storage tank statistics .............................................. 99Underground storage tank statistics ....................................................................... 103Piping Statistics .............................................................................................................109Thermoplastic piping .............................................................................................. 109Fiber-reinforced pipe ..............................................................................................114Storage Tank System Leak Autopsy Report Form ............................................................... 117Containment Sumps ....................................................................................................... 118Success of Release Detection Statistics .........................................................................121Findings from the FDEP Scoring Review .....................................................................1215 DISCUSSION .................................................................................................................... ...137Risk-Based Corrective Action .............................................................................................. 138A General Overview of the Data Contained Within the Contaminated Facilities List 139Analysis of Differing Levels of Enforcement Based Upon Local Option Sales Tax .... 148Alachua County Compared to the Rest of the State ......................................................155Reimbursement First Come First Served ........................................................................... 167Total Encumbrance to Date .................................................................................................. 171Current Work Orders/Task Assignments .............................................................................. 1736 CONCLUSIONS .................................................................................................................. 177Comparison of Facility Discharge Scores ............................................................................178Significance of a Facili tys Statewide Ranking .................................................................... 1837 RECOMMENDATIONS FOR FURTHER RESEARCH .................................................... 186Secondary Containment Lining Syst ems for Fuel Storage Tanks ........................................186Compliance with Environmental Regulations ...................................................................... 187How Does the Technology Work? ................................................................................188Leak-detection Options .................................................................................................189Mechanical Properties ................................................................................................... 189Retrofitting Single-Walled USTs with Secondary Containment .......................................... 190 APPENDIX A DISCHARGE REPORT FORM ........................................................................................... 192B FDEP SCORING REVIEW .................................................................................................193C PETROLEUM CLEANUP SITE INSPECTION FORM ..................................................... 194D LOCAL OPTION MOTOR FUEL TAXES ......................................................................... 195E SCORE TRACKING SHEET ..............................................................................................197

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8 F LIST OF REFERENCES ......................................................................................................198G BIOGRAPHICAL SKETCH ................................................................................................202

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9 LIST OF TABLES Table page 1-1 Product Loss Through Small Leaks. .................................................................................. 373-1 List of Points for the FDEP Scoring Review. .................................................................... 794-1 Cleanup Task Information. .............................................................................................. 1264-2 Contaminated Facilities List. ........................................................................................... 1314-3 Contaminated Media Report. ........................................................................................... 1334-4 Facility Score Report. ......................................................................................................134

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10 LIST OF FIGURES Figure page 1-1 Selected Samples of Crude Oil (Photo: Chevron Learning Center). ................................. 221-2 Three-Dimensional Image of a Petroleum Plume. ............................................................. 271-3 Schematic Diagram of Aer obic Biodegradation in Soil. ................................................... 291-4 Tank Farm and Contaminated Soil. ...................................................................................291-5 Bulk Oil Facility Showi ng Concrete Retaining Wall. ....................................................... 311-6 Shop-Built Double-Walled Aboveground Storage Tank. .................................................. 321-7 Flow Chart of Criteria for Substantial Harm. .................................................................... 351-8 Substantial Harm Facility (Photo: East Coast Oil). ...........................................................371-9 Aboveground Storage Tank Failure in Fl oreffe, Pennsylvania (Photo: EPA). ..................441-10 Underground Storage Tank System Th at Meets the SPCC Regulation. ............................451-11 Bulk Storage Prior to 1900 (Photo: Oilmans). ................................................................. 501-12 Holes Caused by Internal Corrosion as a By-Product of Microbial Growth. ....................521-13 Erikas Descent Into the Bay of Biscay. ............................................................................521-14 Shop-Built AST With Alternative Secondary Containment Measures. ............................. 541-15 Vaulted Tanks. ........................................................................................................... ........563-1 Pie Chart of Total Number of Contaminated Facilities. .................................................... 833-2 Bar Chart of Total Number of Contaminated Facilities. .................................................... 843-3 Histogram of Highest Current Score. ................................................................................. 853-4 Box Plot of Statewide Highest Current Score. ................................................................... 873-5 Box Plot of Facility Current Score. ....................................................................................883-6 Individual Value Plot of Current Score. ............................................................................883-7 Interval Plot of Contaminat ed Facilities Current Score. .................................................... 904-1 Smear Zone. ............................................................................................................... ........94

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11 4-2 Sensitive Habitats. ....................................................................................................... .......954-3 Field-Erected AST Sources. ............................................................................................... 994-4 Field-Erected AST Causes. ..............................................................................................1004-5 Shop-Built AST Sources. ................................................................................................. 1024-6 Typical Shop-Fabricated AST. ........................................................................................1034-7 Shop-Fabricated AST Causes. .........................................................................................1044-8 USTs Tanks as the Source. ...........................................................................................1054-9 Autopsy of Double-Walled Storag e Tank Showing Failure Point. ..................................1064-10 Tank Autopsy Showing Internal Corrosion. ....................................................................1074-11 UST Leak Sources. ..........................................................................................................1074-12 USTs Double-Walled USTs as the Source, Cause........................................................ 1084-13 Breach of Integrity of a Polyet hylene-Jacketed Double-Walled UST. ............................ 1094-14 Fiberglass Coating Failures on a Double-Walled Steel Tank. ......................................... 1104-15 Microbial Degradation of the Outer Jacket. ..................................................................... 1114-16 Failures of Thermoplastic Flex Piping. ............................................................................ 1124-17 Thermoplastic Piping Blowout. ....................................................................................1134-18 Fiber-Reinforced Pipe Failure from Impact Damage. ..................................................... 1154-19 Fiber-Reinforced Pipe with Score Damage. .................................................................... 1164-20 USTs Piping as the Source, Type of Piping. .................................................................1184-21 Leak Autopsy Forms. ...................................................................................................... .1194-22 Rippling or Collaps e of Sump Walls. .............................................................................. 1204-23 Success of Leak Detection. ..............................................................................................1224-24 Interval Plot of Contaminated Facility Score When Ranked. .......................................... 1234-25 Individual Value Plot of Score When Ranked. ................................................................ 1244-26 Box Plot of Contaminated Facilities Score When Ranked. ............................................. 125

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12 4-27 All Known Petroleum-Contaminated Discharges Not Yet Cleaned Up. ......................... 1274-28 Storage Capacity in Gallons............................................................................................. 1284-29 Line Plot of Total Number of Discharges and Average Score. ....................................... 1294-30 Line Plot of Capacity in M illion Gallons and Average Score. ........................................1324-31 Line Plot of Discharges per Mi llion Gallons and Average Score. ................................... 1324-32 Histogram of Highest Current Score. ............................................................................... 1344-33 Probability Plot of Ov erall Score Statewide. ................................................................... 1354-34 Probability Plot of St atewide Overall Rankings. .............................................................1354-35 Bar Chart of Discharges per Facility Type for Entire State of Florida. ........................... 1365-1 Pie Chart of Tank Status. ................................................................................................. 1395-2 Pie Chart of Substance. ................................................................................................... .1405-3 Histogram of Storage Capacity in Gallons. ..................................................................... 1415-4 Histogram of Discharge Scores. ...................................................................................... 1425-5 Pie Chart of Information Source. ..................................................................................... 1435-6 Pie Chart of Funding Eligibility Indicator. ...................................................................... 1445-7 Pie Chart of Cleanup Work Status. .................................................................................. 1455-8 Histogram of Rank. ........................................................................................................ ..1455-9 Pie Chart of Contam inated Drinking Wells. .................................................................... 1465-10 Pie Chart of Contaminated Monitoring Wells. ................................................................ 1475-11 Pie Chart of Contaminated Soil. ...................................................................................... 1475-12 Pie Chart of Contaminated Surface Water. ...................................................................... 1485-13 Pie Chart of Contaminated Ground Water. ...................................................................... 1495-14 Pie Chart of Pollutant. .................................................................................................. ....1505-15 Interval Plot of Current Score by Total Tax Imposed...................................................... 1515-16 Box Plot of Current Score by Total Tax Imposed. .......................................................... 152

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13 5-17 Individual Value Plot of Cu rrent Score by Total Tax Im posed. ...................................... 1535-18 Interval Plot of Score Wh en Ranked by Total Tax Imposed. .......................................... 1545-19 Box Plot of Score When Ranked by Total Tax Imposed. ................................................ 1555-20 Interval Plot of Statewid e Ranking by Total Tax Imposed. ............................................. 1565-21 Interval Plot of Current Score of Counties With $0.34 Total Tax Imposed. ................... 1575-22 Box Plot of Current Scores of Counties With $0.34 Total Tax Imposed. ....................... 1575-23 Individual Value Plot of Current Score for Counties With $0.340 Total Tax. ................ 1585-24 Interval Plot of Score When Ranked With $0.34 Total Tax Imposed. ............................ 1585-25 Box Plot of Score When Ranked of Counties With $0.34 Total Tax Imposed. .............. 1595-26 Interval Plot of Rank of C ounties With $0.34 Total Tax Imposed. ................................. 1595-27 Box Plot of Rank of Counties With $0.34 Total Tax Imposed. ....................................... 1605-28 Pie Chart of Cleanup Work St atus within Alachua County. ............................................ 1615-29 Discharges per Facility Type in Alachua County. ...........................................................1615-30 Alachua County Compared to the Re st of the State (Current Score). ............................. 1635-31 Interval Plot of Alachua County Compar ed to the State (Score When Ranked). ............ 1645-32 Box Plot of Alachua County Compared to the State (Score When Ranked). .................. 1645-33 Box Plot of Alachua County Compared to the State (Current Score). ............................ 1655-34 Total Number of Contaminated Facilities by County. ..................................................... 1655-35 Scores of Counties with More Contam inated Facilities than Alachua County. ..............1665-36 Interval Plot of Counties with Mo re Contamination than Alachua County..................... 1665-37 Box Plot of Scores of Counties with More Contamination than Alachua County. ......... 1675-38 Interval Plot of Reimbursement First Come First Served. ............................................ 1685-39 Box Plot Comparing Reimbursement First Come First Served. ................................... 1695-40 Individual Value Plot of Reimbur sement First Come First Served. ............................. 1705-41 Pie Chart of Reimbursement First Come First Served. ................................................. 170

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14 5-42 Bar Chart of Reimbursement First Com e First Served. ................................................ 1715-43 Total Encumbrance to Date. ............................................................................................ 1725-44 Total Amount Encumbered. .............................................................................................1735-45 Work Orders............................................................................................................... ......1745-46 Total Current Work Orders. ............................................................................................. 1755-47 Pie Chart of Total Current Work Orders. ......................................................................... 1755-48 Interval Plot of Work Orders/Task Assignments. ............................................................ 176

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15 Abstract of Dissertation Pres ented to the Graduate School of the University of Florida in Partial Fulfillment of the Requirements for the Degree of Doctor of Philosophy DEVELOPMENT OF A SYSTEMATIC APPROACH FOR ANALYZING RISK-BASED CORRECTIVE ACTION PLANS APPLIED AT PETROLEUM RELEASE SITES By Don Winfield Lewis May 2009 Chair: Charles R. Glagola Major: Civil Engineering This dissertation reviews environmental laws and analyzes the results of risk-based management procedures mandated by Congress. The United Sates Congress ordered that state and federal cleanup funds be disbursed based on a quantifiable, risk-based formula and that information about each discharge be collected and stored in a publicly acce ssible database. After a thorough literature review, no re searcher has examined or documented the results contained therein. Data collected by field inspectors eval uating discharges of vari ous types was evaluated in Minitab, and the results show interesting c ontrasts among various levels of enforcement. Enforcement of environmental laws was shown to be a function of fuel tax rates, particularly the local option sales tax that many counties have imposed to acquire environmentally sensitive lands, enforce state and federal laws regarding protection of the environment, and fund local Departments of Environmental Protection (DEP). Alachua County has historically been on the cu tting edge of passing and strictly enforcing environmental laws. In fact, Alachua County has on several occasions trie d to adopt local codes that are more stringent than st ate law only to have the effort be ruled unconstitutional. A stepwise comparison showed this county to score discharges above the quantified level of risk of

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16 the rest of the state but clearly below the funding threshold. This result is significant in the sense that when discharges do occur in Alachua County, one is more likely to face fines and penalties without cleanup reimbursement from the IPTF trust fund. Another surprising result of this research is that Miami-Dade C ounty, which has adopted its own set of environmental guidelines separate from the rest of the st ate (e.g., vapor recovery), had a much lower overall score mean and a corresponding higher average ranking. These differences compare equally to Alachua County and other counties that have adopted the highest allowable local option motor fuel tax. Add itionally, rural counties tended to have fewer discharges at higher overall scores, above the funding threshold, than more urban counties. A discharge and its corresponding level of c ontamination are scored based on the amount of hydrocarbons released into th e environment and the exposure of the discharge to potable wells. Fire and explosion hazards also figure into the scoring review, as do the migration potential and overall environmental setting the discharge occurs in. Ideally, this review is based on the facts pertaining to each discha rge. If this is true, then a random sample of data selected from the main database should provide an even representation of discha rges without noticeable differences between the main database and the sample. However, noticeable differences were detected using 95% confidence in tervals with a P-value of <0.005. The data followed a classic normal distri bution, thereby facilitating the use of the Students t-distribution to illust rate the margin of error and mea n. Box plots also were used to compare the median or the centermost value among different counties. It was interesting to note that the results showed considerable bias in th e reporting of discharges. Counties with higher tax rates consistently ranked higher than the rest of the state and had lower overall scores.

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17 CHAPTER 1 INTRODUCTION Oil Pollution Overview As a m ajor industrial nation, the United States produces, distributes, and consumes large quantities of oil. Petroleum-based oil is used as a major power source to fuel factories and various modes of transportation and is used in the manufacture of many everyday products such as plastics, nylon, paints, tires, co smetics, and detergents. On average, the U.S. consumes more than 250 billion gallons of oil and petroleum pr oducts each year. Ac cording to the Florida Petroleum Marketers and Conveni ence Store Association (FPMCSA), the state of Florida alone consumes 23 million gallons of regular unleaded gasoline a day. To meet this demand, the U.S. annually produces an average of 125 billion gall ons of crude oil and im ports an average of 114 billion gallons of crude oil and other petrol eum products (U.S. EPA Oil Program 2006). At every point in the oil production, distribution, and consumption process, oil is invariably stored in storage tanks. With billions of gallons of oil being stored throughout the country, the potential for oil spillage is significant, and the effect s of spilled oil can pose serious threats to the environment. In addition to petroleum-based oil, the U.S. consumes millions of gallons of nonpetroleum-based oils such as sili cone, mineral-based oils, and animal and vegetable oils. Due to a national emphasis on reducing dependence on foreign oil, the consumption of non-petroleumbased oil is predicted to double or even triple in the next fe w years. The Aug. 11, 2003, edition of the Chemical Market Reporter stated that demand for high-oleic (HO) vegetable oils is rapidly increasing; therefore, commercially available HO oils such as safflower, HO sunflower, HO canola, and olive oils are experiencing strong demand, and suppliers are responding by increasing production.

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18 HO oils are being investigated for use in i ndustrial applications. HO vegetable oils are being tested as a feedstock fo r the production of various oleo chemical products and as vegetable-based lubricants ( Tribology & Lubrication Technology 2003). Like petroleum products, these non-petroleum oils ar e often stored in storage tanks that have the potential to spill, causing environmental damage just as serious as that caused by petroleum-based oils. The Florida Department of Environmental Pr otection (FDEP) is the lead agency in developing and administering the hazardous wa ste management program in Florida. A hazardous material is defined as any substance or material identified now or in the future as hazardous under any federal, state, or local law or regulation, or any other substance or material that may be considered hazardous or otherwise subject to statutory or regulatory requirement governing handling, disposal, an d/or cleanup (AGC 410 1999). To address the potential environmental th reat posed by petroleum and non-petroleum oils, the U.S. Environmental Protection Agency (EPA) has established a program designed to prevent oil spills. The program has reduced the number of spills to less than 1% of the total volume handled each year (U.S. EPA Oil Program 2006). However, despite the nations best efforts to prevent spills, almost 14,000 oil spills are reported each year, mobilizing thousands of specially trained emergency respons e personnel and challenging the be st laid contingency plans. Although many spills are contained and cleaned up by the responsible parties, some spills require assistance from local and state agencies and occasionally the federal government. Whether or not it manages the response, the EPA tracks all repor ts of oil spills greater than 25 gallons. The responsible party is required by law to report th e spill to the state government using a Discharge Report Form (see Appendix A).

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19 Spilled oil poses serious threats to fresh water and marine environments. It affects resources and a wide range of subsurface organism s that are linked in a complex food chain that includes human food resources. Sp illed oil can harm the environm ent in several ways, including direct physical damage to wildlife and their habita ts, sometimes caused by th e toxicity of the oil itself, which can poison exposed organisms. Properties of Petr o leum-Based Oils Petroleum-based oil includes a broad range of natural, hydrocarbon-based substances and refined petroleum products, each having a differe nt chemical composition. They are refined from crude oil, which was formed from billions of tiny microorganisms that converted over time and pressure to oil. The term hydrocarbon simply describes compounds that are predominately composed of hydrogen and carbon, although there are small amounts of other elements such as sulfur and nitrogen (impurities). The two principle types of petroleum oils are paraffinic and napthenic. Physically, paraffinic oils can be distingui shed from napthenic oils by thei r higher pour points and lower density. The pour point of oil is the lowest temp erature at which it will po ur or flow when it is chilled without disturbance under prescribed cond itions. Paraffinic oils typically weigh between 7.2 and 7.3 pounds per gallon, while napthenic oils ar e slightly heavier. Additives can strongly affect the physical properties of each. White oils are highly refined petroleum oils that meet food and drug requirements for direct food contact. Synthetic oils are mostly derived from petroleum base stocks and are classified into several families. Caltex, a subs idiary of Chevron Corp., define s a synthetic lubricant as one made chemically by reacting materials of a specific chemical composition to produce a compound with planned and predictable physical and chemical properties (Caltex Product Glossary 2007). The following are a fe w of the more common synthetic oils.

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20 PAO (POLYALPHAOLEFIN). These molecules are similar to liquid ball bearings. They are made from olefins, which are long molecule s with a double bond in the alpha position. ALKYLATED AROMATICS. They are often used in conjunction with PAOs. POLYOL-ESTERS. Most are used for fire-resistant hydraulic fluids and refrigeration lubricants. DI-ESTERS. These have excellent biodegradability characteristics and are used as the base for environmentally friendly lubricants. PHOSPHATE-ESTERS. They are used in applications where fire resistance is important. POLYGLYCOLS. These are often mixed with water for fire resistance. SILICONE OILS. Most are used where petroleum oils may react to process chemicals. SILICATE-ESTERS. These are highly specialized products used for their dielectric properties. FLUOROCARBON OILS. They are extremely inert and expensive. PAG (POLYALKYLENE GLYCOLS). They have high viscosity indexes (VI) and low pour points; high temperature stabilit y and biodegradability make thes e synthetics the lubricant of choice for many industrial applications As a result, each type of crude oil and its refined product have distin ct physical properties that affect the way oil spreads and breaks dow n, the hazard it may pose to marine and human life, and the likelihood that it w ill pose a threat to natural and manmade resources. For example, light refined products, such as gasoline and ke rosene, spread on water surface and penetrate porous soils quickly. Fire and toxic hazards are high, but the products evaporate quickly and leave little residue. Alternativ ely, heavier refined oil products may pose a lesser fire and toxic hazard and do not spread on water as readily. However, heavier oils are more persistent and may present a greater remediation challenge. The rate at which an oil spill spreads will dete rmine its effect on the environment. Most oils tend to spread horizontally into a smooth and slippery surface, called a slick on top of the

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21 water. Factors that affect the ability of an oil spi ll to spread include su rface tension, specific gravity, and viscosity. What is crude oil? Crude oil is a m ixture of hydrocarbon molecule s, some large and some small. Crude oil in a laboratory flask will begin boiling at about room temperature (~70 F). As the temperature increases, additional hydrocarbon molecules in the crude oil vaporize, or boil away. Hydrocarbon molecules boil at di fferent temperatures, from -44 F for propane all the way to 1,500 F for asphalt. The words light and heavy describe the density a nd resistance to flow (viscosity) of crude oil. The terms sweet and sour are used to describe the amount of sulfur compounds in the crude oil. Typically, crude o il that is heavy and sour is less expensive than light and sweet cr ude oil because it is mo re difficult to process. Types of crude oil Crude oil, as it com es from the ground, cont ains many substances other than gasoline, diesel fuel, and lubricant base st ocks. The natural gas that is us ed to power many city buses and heat burners can be dissolved in crude oil. The building blocks for plastics and chemicals can be found in its mixture of molecules. It is also a source of wax, asphalt, solvents, petroleum jelly, and many other substances. Fuels, however, are the principle products derived from crude oil. Gasoline is the biggest component followed by diesel fuel and je t fuel. Lubricants and waxes constitute only slightly more than 1% of the crude oil barrel. Crude oil comes in many forms, depending on its s ource. It can be as thin as gasoline or so thick that it needs to be heated or pressurized to flow. The three major types of crude oil are paraffinic napthenic, and asphaltic. Paraffinic crude is the prim ary source of neutral base

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22 oils, while napthenic crude produces coastal pal e oils. Asphaltic crudes are generally highly viscous. The petroleum industry often characterizes cr ude oils according to their geographical source; e.g., Alaska North Slope Crude. Oils from different geographical areas have unique properties; they can vary in consistency from a light, volatile fluid to a semisolid (see Figure 11). The classification scheme provi ded below is useful for classifi cation of types of crude oil for spill response scenarios. Figure 1-1. Selected Samples of Crude Oil (P hoto: Chevron Learning Center). CLASS A: LIGHT, VOLATILE OILS. These oils are highly fluid, are often clear, spread rapidly on solid or water surfaces, have a str ong odor, have a high eva poration rate, and are usually flammable. They penetrate porous surfaces such as dirt and sand and may be persistent in such a matrix. They do not tend to adhere to surfaces; flushing with water generally removes them. Class A oils may be highly toxic to humans, fish, and other biota. Most refined products and many of the highest quality light cr udes can be included in this class. CLASS B: NON-STICKY OILS. These oils have a waxy or o ily feel. Class B oils are less toxic and adhere more firmly to surfaces than Class A oils, although they can be removed from surfaces by vigorous flushing. As temperatures rise, their tendency to penetrate porous

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23 substrates increases, and they can be persistent. Evaporation of volatiles may lead to a Class C or D residue. Medium to heavy paraffi n-based oils fall into this class. CLASS C: HEAVY, STICKY OILS. Class C oils are characteri stically viscous, sticky or tarry, and brown or black. Flushing with water will not readily remove this material from surfaces, but the oil does not easily penetrate porous surfaces. The density of Class C oils may be near that of water, and th ey often sink. Weathering or ev aporation of volatiles may produce solid or tarry Class D oil. Toxicity is low, but wildlife can be smothered or drowned when contaminated. This class includes residua l fuel oils and medium to heavy crude. CLASS D: NON-FLUID OILS. Class D oils are relatively non-toxic, do not penetrate porous substrates, and are usually black or dark brown in color. When heated, Class D oils may melt and coat surfaces, making cleanup very difficult. Residual oils, heavy crude oils, some high paraffin oils, and some weathere d oils fall into this class. These classifications are dynamic for spill ed oils; weather conditions and water temperature greatly influence the behavior of oil and refined petroleum products in the environment. For example, as volatiles evaporate from Class B oil, it may become Class C oil. If a significant temperature drop occurs, Class C oil may solidify and resemble Class D oil. Upon warming, the Class D oil may revert back to Class C oil (U.S. EPA Oil Program 2006). Crude oil is sold by the barrel (42 gallons per barrel), by pipeline, or in tanker ships. From there, it is transported by barge or pipeline to a refinery, where it is processed. When oil comes out of the ground, the first things that are released are gases. These include methane, ethane, propane, and butane, as well as the mixtur e called natural gas. The distillation towers at refineries produce gasoline using the same principl es that were used in stills during Prohibition. Distillate fuels boil at a highe r temperature than gasoline. They include kerosene, jet fuel, and diesels. Heavy fuels are considered resi dual fuels because they are part of the residue from the refining process once the high-value fu els and lubricant stocks are removed. They include bunker fuel for marine use a nd heavy fuels burned by power plants. Petroleum solvents play vital roles in ma ny industries, including coating, adhesives, photocopy, pesticides, and food produc tion. Petroleum solvents are generally divided into two

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24 classes, aromatics and aliphatics. Aromatic solvents have a six-sided benzene ring somewhere in their molecular structure. Consequently, th ey tend to be very reactive and have excellent solvency and high odor. Examples of arom atic solvents are toluene and xylene. Aliphatics have no benzene ring, so they are less reactive. Because they are milder solvents, they are less likely to cause dermatitis, and some even meet food-grade regulations. Examples of aliphatic solvents are he xane, heptane, mineral spirits, and iso-paraffins. Non-petroleum Oils The EPA interprets the definition of oil to include non-petroleum oils as well as petroleum and petroleum-refined products. Non-pe troleum oils include synthetic oils such as silicone fluids and Tung oils, wood-derivative oils such as resin/rosin oils, animal fats and oil, and edible and inedible seed oils from plants Many non-petroleum oils have similar physical properties to petroleum-based oils; for example, their solubility in water is limited, they both create slicks on the surface of water, and they both form emulsions and sludge. In addition, nonpetroleum oils tend to be persistent, remaini ng in the environment for long periods of time. Rapeseed, or canola, oil is often used as a base for biodegradable hydraulic fluids. Biodegradability can be defined as the ability of a substance to degrade over time to carbon dioxide and water in the presence of water, nutrients, and microorganisms; however, there is no universally accepted test for biodegradability of oils. Like petroleum-based oils, non-petroleum o ils can have both immediate and long-term adverse effects on the environment and can be da ngerous or even deadly to wildlife. For example, non-petroleum oils can deplete availa ble oxygen needed by aquatic organisms, foul aquatic biota, and coat the fur or feathers of wildlife. The adverse effects of spilled nonpetroleum oil on wildlife include drowning, mortality by predation, dehydration, starvation, hypothermia, smothering, and suffocation (U.S. EPA Oil Program 2006).

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25 Fate of Spilled Oil Natural p rocesses that may act to reduce the severity of an oil spill or accelerate the decomposition of spilled oil are always at work in the aquatic environment. These natural processes include weathering, evaporation, oxidation, biodegradati on, and emulsification. WEATHERING. This is a series of chemical and physic al changes that cause spilled oil to break down and become heavier than water. EVAPORATION. Usually occurs when the lighter substances within the oil mixture become vapors and leave the surface of the water. This process leaves behind the heavier components of the oil, which may undergo further weathering. OXIDATION. Typically occurs when oil contacts th e water and oxygen combines with the oil to produce water-soluble compounds. BIODEGRADATION. This occurs when microorganisms such as bacteria feed on oil. A wide range of microorganisms is required to significantly reduce the oil. To sustain biodegradation, nutrients such as nitrogen and phosphorus are sometimes added to the water to encourage the microorganisms to grow and reproduce. EMULSIFICATION. This is a process that forms emul sions consisting of a mixture of small droplets of oil and water. Emulsions great ly hamper weathering and cleanup processes. Intrinsic bioremediation of petroleum hydrocarbons Naturally occurring m icroorganisms in soil and groundwater can effectively degrade a range of common petroleum contaminants. At ma ny sites, ambient conditions will be suitable for microorganisms to degrade contaminants w ithout human intervention. In these cases, intrinsic bioremediation can provide an attractive remedial alternative to more costly soil and groundwater cleanup methods (NFESC TM-2185-ENV 1996). Intrinsic bioremediation, also known as na tural attenuation, is a passive remediation method that can effectively reduce petroleum contamination in soil and groundwater to levels that do not pose a risk to human health or the en vironment. Intrinsic bioremediation results from the combined effects of severa l natural processes, including biodegradation, dilution, sorption, dispersion, and volatilization. Fo r petroleum hydrocarbons, biodegrad ation is the most important

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26 process because it transf orms contaminants to innocuous by-products such as water and carbon dioxide and reduces the total mass of the c ontaminants in the subsurface (NFESC 1996). Intrinsic bioremediation is implemented by demonstrating that the native microbial populations have the potential to reduce contam inant levels to meet remediation goals and monitoring to confirm that contaminants do not reach areas of potential concern at unacceptable concentrations. Acceptance of intrinsic bioremediation by the st ates is increasing with updates in rules, regulations, and policies to include more risk-based cleanup standard s. The state of Florida has regulations for intrinsic bioremediation. In general, they allow for intrinsic bioremediation after action has been taken to eliminate sources of contamination (e.g., repair leaks), and free product has been removed to the extent practicable. Demonstrating the occurrence of biodegradation Petroleum hydrocarbons can serv e as the primary substrate (s ource of food or energy) for microorganisms. Thus the first objective of an evaluation of intrinsic bioremediation can be addressed by demonstrating a re duction of contamination in the field due to microbial activity. If sufficient historical sampling data is availabl e to delineate the area of the contaminant plume over time, this information can be used to determine whether ther e has been a loss of contamination due to biodegrada tion. Three characteristic plum e configurations suggest the occurrence of biodegradation (s ee Figure 1-2 for a three-dimens ional image of a petroleum plume): SHRINKING PLUME. The source of contamination has been substantially removed, and biodegradation is occurring faster than cont aminants are being added to the groundwater. STABLE PLUME. A source of contamination is still present and continues to contribute contaminants to the groundwater at a rate a pproximately equal to th e rate of contaminant biodegradation.

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27 EXPANDING PLUME. Biodegradation is occurring but t oo slowly to prevent the spread of contaminants. Natural attenuation makes use of natural processes to contain the spread of contamination from chemical spills and reduce the concentration and amount of pollu tants at contaminated sites (EPA 542-F-96-015 1996). Natural atte nuation also referred to as intrinsic remediation, bioattenuation, or intrinsic bioremediation is an in-situ treatment method. This means that environmental contaminants are left in place while natural attenuation works on them. Natural attenuation is often used as one part of a site cleanup that also includes the contro l or removal of the source of the contamination. Surface Discharge Petroleum Plume Water Table Figure 1-2. Three-Dimensional Image of a Petroleum Plume. At a minimum, there should be a monitoring network of wells at these locations: Up-gradient of the plume to monitor background water quality Within the plume to monitor change s in contaminant concentrations Immediately down-gradient of the plume to detect contaminant migration

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28 At a compliance point (e.g., property boundary) upgradient of any potential receptor to provide early detection of contamina tion before the receptors are reached Many organic contaminants, such as petroleu m, can be biodegraded by microorganisms in the underground environment. For example, biode gradation processes can effectively cleanse soil and groundwater of hydrocarbon fuels such as gasoline and the BTEX compounds benzene, toluene, ethyl benzene, and xylene. Biodegradation also can break down chlorinated solvents such as trichloroethylene (TCE) in gr ound water, but the processes involved are harder to predict and are effective at a smaller percentage of sites compared to petroleum-contaminated sites. The effects of dilution and dispersion ap pear to reduce contaminant concentration but do not destroy the contaminant (EPA 542-F-96-015 1996) See Figure 1-3 for a schematic diagram of aerobic biodegrad ation in soil. Mobile and toxic fuel hydrocarbons are good candidates for natural attenuation. To estimate how well natural attenuation will work a nd how long it will take requires a detailed study of the contaminated site. Natural pro cesses are being used to clean up petroleum contamination from leaking underground storage tanks across the country. Figure 1-4 illustrates a grain cr ude tank spill with a small rele ase of crude soybean oil. The contaminated soil was dug out and placed on a layer of plastic to prevent the oil from infiltrating the groundwater, and a layer of plastic was placed on top to prevent leaching of the product before it was properly disposed. All oil was contained within a grassy, diked area called a secondary containment, and no product was discharged to surface water. To prevent an oil spill from bulk tanks from harming the environment, the EPA requires the dike volume to be 110% of the largest tank.

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29 Figure 1-3. Schematic Diagram of Aerobic Biodegradation in Soil. Figure 1-4. Tank Farm and Contaminated Soil.

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30 What Is Tank and Piping Secondary Containment? For the purposes of this paper, secondary containment refers to a storage tank and/or piping system that have both a release prevention system and a release detection system (i.e., interstitial monitoring). The re lease prevention part of secondar y containment is a tank and/or pipe that has an inner and outer barrier. Be tween these two barriers is a space for monitoring. The release detection part of secondary containment is a method of monitoring the space between the inner and oute r barriers for a leak or release of regulated substances from the primary wall (called interstitial monitoring). Interstitial monitoring must meet the release detection requirements of the code of federal regulations (40 CFR 280.43(g)). Current EPA regulations (see 40 CFR 280.42(b) (1)) for hazardous substance tanks and piping require secondary containment systems that are designed, constructed, and installed to: Contain regulated substances released from the tank system until they are detected and removed. Prevent the release of regulated substances to the environment at any time during the operational life of the storage tank system. Be checked for evidence of re lease at least every 30 days. Therefore, states must have requirements in place to ensure that secondarily contained tanks and piping will prevent a release to the environment at any time during the operational life of the underground storage tank system, and that tanks and piping are checked for evidence of a release at least every 30 days (for example, by pressure, vacuum, or liquid-filled interstitial spaces). Spill Prevention Control and Countermeas ure (SPCC) secondary containment requirements under 40 CFR Part 112.7(c) require that the owner or operator of an oil facility: Provide appropriate containment and/or diversio nary structures or equipment to prevent a discharge as described in section 112.1(b). The entire containment system, including walls and floor, must be capable of containi ng oil and must be constructed so that any

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31 discharge from a primary containment system, su ch as a tank or pipe, will not escape the containment system before cleanup occurs. At a minimum, the engineer shall use one of the following preventive systems or its equivalent (see Figure 1-5 for retaining wall secondary containment): 1. For onshore facilities: a. Dikes, berms or retaining walls suffi ciently impervious to contain oil b. Curbing c. Culverting, gutters, or other drainage systems d. Weirs, booms, or other barriers e. Spill diversion ponds f. Absorbent materials 2. For offshore facilities: a. Curbing, drip pans b. Sumps and collection systems Figure 1-5. Bulk Oil Facility Showing Concrete Retaining Wall. After nearly a decade of eval uation of the construction, perf ormance, and use of certain shop-built double-walled abovegr ound storage tanks (AST) (see Figure 1-6), the EPA believes that they may serve as an equivalent preventive system for the purposes of 112.7(c). In other

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32 words, the EPA recognized that a shop-built double -walled AST with a capacity generally less than 12,000 gallons that was inst alled and operated with protec tive measures other than a secondary containment dike might also meet the secondary containment requirements of 112.7(c). The EPA described those protective measures as when the inner tank is an Underwriters Labo ratory-listed steel tank, the outer wall is constructed in accordance with nationally accepted industry standards (e.g., those codified by the American Petroleum Institute, the Steel Tank Institute, and the American Concrete Institute), the tank has overfill prevention measures that include an overfill alarm and an automatic flow restrictor or flow-shutoff, and all product transfers are constantly monitored. There now has been nearly a decade of experi ence in the construction and performance of shop-built tanks with a capacity of 12,000 gallons or more. In some cases, such tanks provide Figure 1-6. Shop-Built DoubleWalled Aboveground Storage Tank. secondary containment where none existed before or superior environmental protection to alternative containment systems previ ously used (U.S. EPA Oil Program 2006).

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33 Facility Response Planning W hen oil spills into navigable waters or onto adjoining shorelin es, it can harmfully affect the environment, human health, and economic activity. The EPA issued the Oil Pollution Prevention regulation to prevent oil spills and to en sure that oil facility personnel are prepared to respond if a spill occurs. The regulation has two sets of requirements. The first set of requirements is the Spill Prevention, Control, and Countermeasure (SPCC) ru le. The SPCC rule is the basis of the EPAs oil spill prevention program. The second set of requirements is the Facility Response Plan (FRP) rule. The FRP program is designed to ensure that certain facilities have adequate oil spill response capabilities. According to the Clean Water Act (CWA), as amended by the Oil Pollution Act (OPA), certain facilities that store and use oil are required to prepare and submit plans to respond to a worst-case discharge of oil and to a substa ntial threat of such a discharge. The EPA has established regulations that de fine who must prepare and subm it an FRP and what must be included in the plan. An FRP is a plan for responding to the maximum extent practicable, to a worst-case discharge, and to a s ubstantial threat of such a disc harge of oil. The plan also includes responding to small and medium discharges as appropriate (EPA Facility Response Planning Compliance Assistance Guide 2007). According to the OPA, an owner or operator of a substantial harm facility must develop and implement an FRP. A substantial harm facility is a facility that, because of its location, could reasonably be expected to cause substantial harm to the environment by discharging oil into navigable wa ters or onto adjoining shorelines See Figure 1-7 for the flow chart of criteria for substantia l harm (EPA SPCC Compliance Assi stance Guide). The FRP helps an owner or operator develop a response organi zation and ensure the av ailability of response

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34 resources (e.g., response equipment, trained personne l) needed to respond to an oil discharge. The FRP should also demonstrate th at the response resources are available in a timely manner, thereby reducing the impact and severity of a discharge. The facility may be deemed a significant and substantial harm facility if it meets the overwater transfer criterion, has a total oil storage capacity of one million gallons or more, and meets one or more of the other substantial harm factors. Add itional significant and substantial harm factors include: Frequency of past spills. Age of oil storage tanks. Proximity to navigable waters. Local effects on public health. Memorandum of Understanding Some facilities must meet the requirements of two or more federal agencies because they engage in activities that fall unde r the jurisdiction of those agenci es. These agencies include the U.S. Coast Guard, the Department of Transporta tions (DOT) Office of Pi peline Safety, and the EPA. A 1971 Memorandum of Understanding (MOU) between the EPA and the DOT defines which types of activities are regulated by each agency. According to the MOU, the DOT regulates transportation-related activities, while the EPA regulates non-transportationrelated activities. The activities at many facilities may be entirely non-transportation-related and therefore regulated only by the EPA. A f acility with both transportation-related and nontransportation-related activities is regulated by both agencies and, as such, is defined as a complex. See figure 1-8 for a substantial ha rm facility operating as a complex. Floridas Air and Water Pollution Control Act Under the Florida Air an d Water Poll ution Control Act (PCA) (Fla. Stat. 403 (2003)), the FDEP is charged with the power and the du ty to control and prohibit pollution of air and

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35 Figure 1-7. Flow Chart of Criteria for Substantial Harm.

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36 water ( 403.061 (2003)). Under the PCA, the definiti on of pollution includes the alteration of the chemical, physical, [or] biological integr ity of water in quantities or at levels which are or may be potentially harmful or injurious [t o] animal or plant life or which unreasonably interfere with the enjoyment of life or property, including ou tdoor recreation ( 403.061 (7) (2003)). Under this definition, depending on the effects, pollution could be interpreted to include the addition of excess nut rients to groundwater and, consequently, to the water that recharges springs. According to the FDEP, 90% of Floridas water comes from groundwater. Seventy percent of the water used by industry comes from groundwater, and 50% of agriculture water comes from groundwater. A one-gal lon spill of oil can contaminate one million gallons of fresh water a years supply for 50 people. See Tabl e 1-1 for an example of a spill even a small leak can produce (Hose and Nozzle 1981). The Petroleum Cleanup and Discharge Prevention Programs mission is to ensure cleanup, in a health threat priori ty order, of all known petroleu m contaminated sites and reduce or eliminate petroleum discharges in order to ensure that Florida ne ver again experiences a petroleum contamination crisis of the magnitude that was discovered in the late 1980s and early s when petroleum contamination was de tected in groundwater and private wells. The storage tank regulati on section is part of the Bureau of Petroleum Storage Systems in the FDEP Division of Waste Management. In 1983, Florida was one of the first states in the union to pass legislation and adopt rules for underground and aboveground storage tank systems. Since then, more than 28,000 f acilities have reported disc harges of petroleum products from storage tank systems. Florida has some of the most stringent rules in the country regarding oil pollution. All new and replacem ent storage tank systems must have secondary containment,

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37 Figure 1-8. Substantial Harm Fac ility (Photo: East Coast Oil). Table 1-1. Product Loss Through Small Leaks. Size/ Ounces per Gallons per Frequency of Leak Minute Day Month Year One Drop per Second 1/10 1+ 33 410 Two Drops per Second 1/6 2+ 67+ 821 Stream Breaking to Drops 2 24 730 8760

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38 and all remaining single-walled systems must be replaced with secondary containment by 2010. The department contracts with counties to perform annual compliance inspections (FDEP, Bureau of Petroleum Storage 2008). The Clean Water Act The Federal Water Pollution Control Act of 1972, as am ended, or Clean Water Act, is the principal federal statute for prot ecting navigable waters, adjoini ng shorelines, and the waters of the contiguous zone from pollution. Section 31 1 of the CWA addresses the control of oil and hazardous substance discharges and provides the au thority for the program to prevent, prepare for, and respond to such discharges. Specifically, 311(j)(1)(C) mandates regulations establishing procedures, methods, equipment, and ot her requirements to prevent discharges of oil and to contain such discharges. The Spill Prevention Control and Countermeasure (SPCC) rule was initially promulgated in 1973, with modifi cations to the SPCC requirements proposed for public comment on several occasions through 2002, with the final revision published in the Federal Register in July 2002. The original SPCC rule proposal was published in the Federal Register on December 11, 1973, with an effective date of January 10, 1974 (38 FR 34164). The regulation established oil discharge prevention procedures, methods, and equipment requirements for non-transportation-related faci lities with aboveground (unburied) oil storage capacity greater than 1,320 gallons (or greater than 660 gallons aboveground in a single tank) or a buried underground oil storage capacity greater th an 42,000 gallons. Regulated facilities were also limited to those that, because of their location, could reasonabl y be expected to discharge oil into the navigable waters of the United States or adjoining sh orelines. Two early revisions were made to the original SPCC rule. On August 29, 1974, the regulation was amended (39 FR 31602) to set out the EPAs policy on civil penalties for violation of the CWA 311

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39 requirements. On March 26, 1976, the rule wa s again amended (41 FR 12567), primarily to clarify the criteria for determining whether or not a facility was subject to the regulation (such as mobile facilities includ ing onshore drilling or work over ri gs, barge-mounted offshore drilling rigs, and portable fueling facilities). The Love Canal Tragedy Quite simply, Love Canal is one of the most appalling environmental tragedies in American history. It is a cr uel irony that Love Canal was or iginally meant to be a dream community. That vision belonged to the man fo r whom the three-block tract of land on the eastern edge of Niagara Falls, New York, was named William T. Love. Love felt that by digging a short canal between th e upper and lower Niagara Rivers, power could be generated cheaply to fuel the industry and hom es of his would-be model city. But despite considerable b acking, Loves project was unabl e to endure the one-two punch of fluctuations in the economy and Nikola Tesl as discovery of how to economically transmit electricity over great distances by means of an alternating current. By 1910, the dream was shattered. All that was left to commemorate L oves hope was a partial ditch where construction of the canal had begun. In the 1920s, the seeds of a genuine nightmare were planted. The canal was turned into a municipal and industrial chemical dumpsite. La ndfills can be an environmentally acceptable method of hazardous waste disposal, assuming they are properly sited, managed, and regulated. Love Canal will always remain a perfect historical example of how not to run such an operation. In 1953, the Hooker Chemical Company, then the owners and operato rs of the property, covered the canal with earth and sold it to the city for one dolla r. In the late 1950s, about 100

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40 homes and a school were built at the site. Perhap s it wasnt William T. Love s model city, but it was a solid, working-class community. The problems began to occur after a record am ount of rainfall. Shortly thereafter, the leaching began. The EPA visited the canal area at that time (EPA Journal 1978). Corroding waste-disposal drums could be seen breaking up through the ground of backyards. Trees and gardens were turning black and dying. One en tire swimming pool had been popped up from its foundation, afloat now on a small sea of chemicals. Puddles of noxious substances were pointed out by the residents. Some of these puddles were in their yards, some were in their base ments, others yet were on the school grounds. Everywhere the air had a slight, choking smell. Children returned from play with burns on their hands and faces. We knew they put chemicals into the can al and filled it over, said one woman, a longtime resident of the canal area, but we ha d no idea the chemicals would invade our homes. Were worried sick about the grandchildren and their children. On August 7, New York Governor Hugh Care y announced to the residents of the canal that the state government would purchase the home s affected by chemicals. On that same day, President Carter approved emergenc y financial aid for the Love Ca nal area (the first emergency funds ever to be approved for something other than a natural disaster), and the U.S. Senate approved a sense of Congress amendment sayi ng that federal aid should be forthcoming to relieve the serious environmental disaster that had occurred. Comprehensive Environmental Response, Compensation, and Liability Act The Com prehensive Environmental Response, Compensation, and Liability Act of 1980 (42 USC 1995), commonly known as CERCLA or Superfund, is the flagship of environmental liability laws. In addition to the federal laws, states such as Florida have enacted their own

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41 statutory scheme to regulate and assess liabil ity for hazardous waste problems, which was discussed earlier. Regardless of the existence of any specific statutes, liability may also be imposed under traditional civil law theories of to rt, nuisance, and trespass. The consequences of running afoul of this web of environmental liability is not limited to a ci vil penalty payable by a company but can involve fines and criminal pena lties assessed against individuals. CERCLA is generally aimed at addressing liability for clean up costs for past contamination of sites by hazardous wastes. The Resource Conservation and Recovery Ac t of 1976 (RCRA) dealt with the current handling, storage, treatment, and disposal of hazardous wastes. Because contamination may occur in the process of handling, storing, treating, or disposing of hazardous wastes, there can be some considerable overlap between CERCLA and RCRA. Each of these acts the Clean Air and Water Acts, the Safe Drinking Water Act, the Pesticide Act, the Resource Conservation and Rec overy Act, and the Toxic Substances Control Act is an essential link. Unde r the Resource Conservation and Recovery Act, the EPA made grants available to states to help them establish programs to ensure the safe handling and disposal of hazardous wastes. As guidance for such programs, the EPA worked with the states to inventory industrial waste disposal sites, incl uding full assessments of any potential dangers created by these sites. Also, the EPA proposed a system to ensure that the more than 35 million tons of hazardous wastes produced in the U.S. each year, including most chemical wastes, were disposed of safely. Hazardous wastes would be controlle d from point of generation to their ultimate disposal, and dangerous practices resulting in serious threats to health and environment would not be allowed.

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42 Because of RCRA, most waste oil is now recycled by being burned in industrial boilers. This can technically be called recyclin g because energy is recovered. Some waste oil can be cleaned up and reused as a lubricant by reclaiming or reproce ssing with a vacuum dehydrator and/or centrifuge. Th ese federal laws provide incentives to reduce consumption. Spill Prevention Control and Countermeasure Plans Task Force In January 1 988, a 4 million-gallon aboveground storage tank in Floreffe, Pennsylvania, experienced a brittle fracture of the tank shell, which then spli t apart, collapsed, and released approximately 3.8 million gallons of diesel fuel (see Figure 1-9). Of this amount, approximately 750,000 gallons were discharged into the Monogahela River. The spill tem porarily contaminated drinking water sources, damaged the ecosystem s of the Monogahela and Ohio Rivers, and negatively affected private prope rty and local businesses. Following the discharge, an SPCC task force was formed to examine federal re gulations governing discharges from aboveground storage tanks. The task force, consisting of representatives from EPA headquart ers and regions, other federal agencies, and the states, issued its findings and recommendations in May 1988. The findings focused on the prevention of catastrophi c discharges and recommended changes to the SPCC program (EPA, The Oil Sp ill Prevention, Cont rol, and Countermeasures Program Task Force Report, EPA docket OPA-1991-0001 May 1988). Specifically, the task force recommended that the EPA establish additi onal technical requirements for SPCC Plan preparation and implementation, such as: Adopting industry standards for new and relocated tanks. Differentiating SPCC requirements based on facility size. Modifying timeframes for SPCC Plan prep aration, implementation, and review.

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43 Requiring strengthened integrity testing and periodic inspection of tanks and secondary containment. Requiring a more stringent attestation for a professional engi neer to certify an SPCC Plan. Ensuring that employees undergo response training. In response to both the Monogahela River spill and an oil spill at a re finery in Martinez, California, in April 1988, the Ge neral Accounting Office (GAO) examined the adequacy of the federal regulations of aboveground oil storage tanks and the extent to which they addressed the unique problems of inland oil discharges. The GAOs report, Inla nd Oil Spill: Stronger Regulation and Enforcement Needed to Avoid Fu ture Incidents, contained recommendations on regulations, inspections, enforcemen t, and government response that were similar to those of the SPCC Task Force (February 1989, GAO/RCED -89-65, EPA docket OPA-1991-0001). To amend the SPCC regulation, the GAO made recommenda tions to the EPA Administrator that the EPA require: Oil storage tanks and piping to be built and tested in accordance with industry and other specified standards. Facilities to plan how to react to a spill that overflows facility boundaries. Storm water drainage systems to be designe d and operated to prevent oil from escaping through them. Oil escaped through the drainage system during the oil spill in Martinez, California. For inspections, the GAO recommended that the EPA: 1. Strengthen its oil storage facility inspection program by coordinating with state and local authorities. 2. Require facilities to obtain certific ation from an independent engineer that the facility is in compliance with the regulations. In response to the final SPCC amendments, several members of the regulated community filed legal challenges to certain aspects of the rule ( American Petroleum Institute v. Leavitt)

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44 Figure 1-9 Aboveground Storage Tank Failure in Floreffe, Pennsylvania (Photo: EPA). The lead plaintiffs were the American Petroleu m Institute, Marathon Oil Co., and the Petroleum Marketers Association of America. Settlement discussions between the EPA and the plaintiffs led to an agreement on all issues except the definition of navigable waters. The Federal Register notice also clarified statements regarding loadin g/unloading racks and imprac ticability that were challenged by the plaintiffs. In addition, the EP A clarified aspects of th e wastewater treatment exemption and specified which defi nition of facility applies to 112.20(f)(1). The following is an example of tanks that meet the release prevention part of the secondary containment requirement (tanks having secondary containment that meet, at a minimum, a code of practice developed by a nationally recognized a ssociation or independent testing laboratory): Underwriters Laboratories (UL) Standard 58 (Steel Underground Tanks for Flammable and Combustible Liquids) UL Standard 1316 (Glass-Fiber-Reinforced Plastic Underground Storage Tanks for Petroleum Products, Alcohols, a nd Alcohol-Gasoline Mixtures)

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45 Steel Tanks Institute Standard F841 (Standard for Dual Wall Underground Steel Storage Tanks) The following is an example of piping that meets the release prevention part of the secondary containment requirement (piping havi ng secondary containment that meets, at a minimum, a code of practice developed by a nati onally recognized associ ation or independent testing laboratory): UL Standard 971 (Non-Metallic Underg round Piping for Flammable Liquids) Such piping that is 100 percent s econdarily contained or Secondarily contained piping with single-walled piping ends that terminate in tank and dispenser sumps Figure 1-10 shows an underground storage tank (U ST) that meets the re quirements of the amended SPCC regulation. The 2002 final SPCC rule is a performancebased regulation that allows owners, operators, and the certifying Professional Engine er (PE) flexibility in meeting many of the prevention requirements. The environmental equi valence provision allows facilities to deviate Figure 1-10 Underground Storage Tank System That Meets the SPCC Regulation.

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46 from specified substantive requirements of the SPCC rule (except secondary containment provisions) by implementing alte rnate measures, certified by a PE, that provide equivalent environmental protection. Deviations are not allowed for administra tive provisions and for certain additional requirements such as record keeping and training provisions ( 112.1 through 112.5, 112.7). Additionally, in situations where secondary containment is not practicable, the owner/operator must clearly explain the reason for the determination. Application of CERCLA CERCLA was intended to im pose liability for cleanup costs on those parties responsible for contamination. The parties with whom CE RCLA may impose liability are referred to as potentially responsible parties or PRPs. CERCLA enforcemen t is not left to the federal government. Private individuals who are forced to incur cleanup costs ar e authorized to pursue responsible parties to recover those costs. Under CERCLA, if one is within the statutory definition of responsible party, one is liable. Even if all reasonable precautions were taken and the operation was executed in a legally and a generally acceptable manner, one is at faul t. CERCLA imposes strict liability, which means automatic liability without regard to fault or negligence. Few and very limited defenses are allowed under CERCLA. One of these is to be a response act ion contractor, a contractor specifically engaged to clean up hazardous waste. In addition to strict liabil ity, CERCLA imposes joint and several liability, a relatively simple concept with a significant impact. Joint and several liabil ity means that the responsible party liable for any part of the contamination is also liable for 100% of the cleanup costs. Thus the party seeking to recoup the costs of cleanup can pursue any responsible party for the entire cost, regardless of the relative contributions of the various parties responsible for the

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47 contamination. This joint and several liabilit y provision makes solvent companies with deep pockets even bigger targets for prosecuti on by the government or private litigants. Comprehensive Environmental Response, Compensation, and Liability Act Responsible Parties CERCLA lists four categories of responsible pa rties. If a party falls into one of the catego ries, that party is liable: The current owner or oper ator of the facility The owner or operator of the facility at the time the hazar dous substance was released Any party that, by contract or otherwise, arra nged for the disposal of the hazardous substance owned by them or by another party Any person who accepted any hazardous substance for transport or disposal that results in a release of hazardous substances Liability is imposed without regard to fault or negligence. That means that the contractor who unwittingly stumbles upon and innocently transports hazardous wastes that result in contamination of a site is just as liable for cleanup costs under CERCLA as the party who knowingly handles and purposely disposes of hazardous wastes in an illegal fashion ( Kaiser Aluminum & Chemical Corp. v. Catellus Development Corp 976 F.2d 1338 (9th Cir. 1992)) In the Kaiser case, the court held that a site-work contractor could be liable under CERCLA simply by cutting and filling soil on a site that, unknown to the contractor, had been contaminated by hazardous waste decades earlier. The contractor was hired by the property owne r of the site to grade and prepare the site for a housing development. This required excavation and dispersa l of some of the material onsite. No material was removed from the site, and no material was imported to the site. After the contractors work was under way, it was discovered that the site and some of the material handled by the contractor was contaminated by hazardous chemicals in the 1940s. The court of

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48 appeals found that the contractor could be considered an opera tor of the property and also a transporter of hazardous substances and therefore liable for the cleanup costs under CERCLA. The fact that the original contamination of the site took place in the 1940s, decades before the contractor ever moved a shovel of dirt made no difference to the court. Regrading, or simply moving contaminated soils to uncontaminat ed areas of the same site, was sufficient to constitute disposal under CERCLA. CERCLA was specifically created to deal with the serious need to address environmental damage from hazardous wastes. The tough measures were deemed necessary to fulfill the statutes important remedial purpose, because in the early days of the oil business, it was not uncommon to store crude petroleum in open pits surrounded by earthen dike s without regard to environmental impact. Surplus oil, waste oil, and coal tar were often buried alongside the railroad towns that grew up during the industria l revolution because of the lack of adequate storage. Early tanks were often made of riveted construction, and because of the high sulfur content of the petroleum stored in them, they were notorious for corrosion and leaks. Unprotected steel tanks and piping were often buried without regard to the devastating effects of soil conductivity and co rrosion or the effect a leak could have on the quality of groundwater. This left behind considerable environmental damage and potential for environmental damage that is still being discovered. Figure 1-11 illustrates an early bulk plant used to supply petroleum products at the turn of the twentieth century. Degradation of Storage Tanks Poor operations and im proper maintenance procedures for water monitoring and removal from storage systems can lead to a number of problems. Microscopic bacteria can grow in a moist environment and attack and degrade the entire storage system, including steel and fiberglass reinforced plastic ta nks, tank linings, elastomeric seal s and hoses, low points in the

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49 piping, leak detectors, turbine pump component s, filters, and valves, including overfill prevention devices. In the worst case, product le aks can cause environmental damage, leading to costly cleanup and facility downtim e/lost business (Steel Tank Institute Keeping Water out of Your Storage System 2006). Water can enter a storage system in a number of ways, including: Condensation, caused by air entering via the vents or fuel temperature swings. Damaged spill bucket or fill cap gaskets. Loose fittings or plugs. Water captured in a spill bucket bein g drained into the storage tank. Gasoline chemistry has changed significantly, fr om the removal of lead and MTBE (MTBE is shorthand for a chemical called methyl tertiary butyl ether, a gasoline additive used by oil companies to meet the requirements of the Clean Air Act) to additives such as ethanol. Most of these changes were done to comply with standard s set by the Fuel and Fu el Additive Regulation (40 CFR 79) that became effective in 1996. These new fuels are more susceptible to moisture accumulations, separation, and potential biodegrad ation accelerated by water. Lead was a natural poison to the microbes that can grow in a moist environment in t odays lead-free fuels, microbial growth can more readily occur. In ternal microbial growth can lead to corrosion holidays such as the ones highlighted by arrows in Figure 1-12, which can penetrate a steel tank or degrade a fiberglass reinforced plastic (FRP) tank if the moisture is not removed. Microbial activity is a better understood and more common phenomenon than previously realized. Field detection kits can verify microbial growth, bu t it is suggested that qualified professionals with expertise in microbial cont amination control be contacted to develop a treatment plan. This may include initial tank cleaning to remove the slime and sludge, followed by a treatment with a biocide. The tank ow ner must establish operating and maintenance

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50 Figure 1-11. Bulk Storage Prior to 1900 (Photo: Oilmans). practices to monitor for water and remove it when detected ( Standard Guide to Microbial Contamination in Fuels and Fuel Systems (D-6469) 1999). Problems Associated with Internal Corrosion On Dece mber 12, 1999, the oil tanker Erika spilled approximately 20,000 tons of heavy oil into the Bay of Biscay when it sank off Frances Breton Peninsula (French Ministry for Ecology and Sustainable Developm ent 2000). An investigation following the accident revealed that internal corrosion caused the hull of the ship to break apar t (Bureau Enquete Accident Final Report 2001). It was also learned that the corrosion had not been detected during routine maintenance and inspection activ ities prior to the accident. The photo shown in Figure 1-13

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51 dramatically shows the effect corrosion can have on oil tankers (Photo: Les Abeilles International, Le Harve, France). Such large-scale cases of corrosion are becomi ng easier to detect, thanks to new advances in acoustic emission (AE) testing. Used since the early 1980s to non-destructively detect and frequently locate leaks in tank bottoms and piping systems, AE tes ting more recently has become an established method for locating corrosion. It can be an alternative to more traditional inspection practices such as pressure tests and visu al examinations. AE te sting relies on transient elastic waves that emanate from the sudden releas e of energy produced by the corrosion process. The propagation of these elastic waves may take place in liquid or solid material; therefore, piezoelectric sensors are mounted on the structure to detect AE by converting elastic waves into electric signals (NACE Materials Performance 2004). Oil Pollution Act On March 24, 1989, shortly after m idnight, the oil tanker Exxon Valdez struck Bligh Reef in Prince William Sound, Alaska, spilling more th an 11 million gallons of crude oil. The spill was the largest in U.S. histor y and tested the abilities of local, national, and industrial organizations to prepare for and respond to a disast er of such magnitude. In the aftermath of the Exxon Valdez incident, Congress passed the Oil Pollution Act of 1990. The Oil Pollution Act (OPA) st reamlined and strengthened the EPAs ability to prevent, prepare for, and respond to cat astrophic oil discharges. Sp ecifically, the OPA expanded prevention and preparedness activities, improved re sponse capabilities, and ensured that shippers and owners or operators of facilities that handle o il pay the costs of discharges that do occur. The Oil Pollution Act amended the Clean Water Act to mandate the promulgation of regulations that require owners or operators of certain facilitie s to prepare and submit a Facility

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52 Figure 1-12. Holes Caused by Internal Corrosion as a By-Product of Microbial Growth. Figure 1-13. Erikas Descent Into the Bay of Biscay.

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53 Response Plan (FRP) for responding to a worst-case di scharge of oil and to a substantial threat of such a discharge. In 1991, the Clean Water Act was again amende d to extend the geographic scope of the EPAs authority under CWA 311. Formerly the geographic scope of the rule extended only to navigable waters of the United States and adjo ining shorelines. The final rule extended the geographic scope of the EPAs authority beyond discharges into navigable waters and onto adjoining shorelines to include di scharges into or onto the waters of the contiguous zone, or in connection with activities under th e Outer Continental Shelf Lands Act or the Deepwater Port Act of 1974, or that may affect natural resour ces belonging to, appertaining to, or under the exclusive management authorit y of the United States. On April 29, 1992, the EPA issued guidance on how certain shop-built double-walled ASTs may comply with the seconda ry containment requirements of 112.7(c). The guidance discussed how there should be many situati ons in which protection of navigable waters substantially equivalent to that provided by the secondary containment systems listed in 112.7(c) could be provided by alternative AST systems that have cap acities generally less than 12,000 gallons and are installed a nd operated with protective m easures other than secondary containment dikes. See Figure 1-14 for an illustration of protective measures other than secondary containment dikes for shop-built AS Ts. The specifications are from Use of Alternative Secondary Containment Measures at Facilities Regulated Under the Oil Pollution Prevention Regulation (40 CFR Part 112). Section 112.8(c)(6) requires the owner or operator of an alternative AST secondary containment system to conduct integrity testing on a regular schedule and whenever repairs are made. The owner or operator must also frequently inspect the out side of the container for signs

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54 Figure 1-14. Shop-Built AST With Alternative Secondary Containment Measures. of deterioration, discharges, or accumulation of o il inside the annular space. To comply with the requirements to frequently inspect the outside of the tank, an owner or oper ator of an alternative AST must inspect the inner wall and intersti tial space. The EPA recommended the use of automatic detection devices to detect discharges into this space. In 1993, the EPA proposed changes to the CWA to require that fieldconstructed tanks be evaluated for brittle fracture if t hose tanks undergo repair, alteration, or change in service. Those must be evaluated by adherence to industry standards contained in American Petroleum Institutes (API) Standard 653, entitled Tank Inspection, Repair, Alteration, and Reconstruction. The rationale was to help preven t the failure of field-constructed tanks due to brittle fracture, such as the four milliongallon aboveground Ashland Oil tank failure, which occurred January 1988 in Pennsylvania. Section 112.7(h) requires ta nk car and tank truck loading/unloading racks to have secondary containment where transf ers of oil in bulk to those tanks are from highway vehicles or railroad cars. If such transfers occur, where lo ading/unloading area drainage does not flow into a

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55 catchment basin or treatment facility designed to handle spills, a quick drainage system must be used. The containment system must be designe d to hold at least the maximum capacity of any single compartment of a tank car or tank tr uck loaded or unloaded at the facility. The EPAs Facility Response Plan requirement s were published as a final rule in the Federal Register on July 1, 1994, and codified at 40 CFR 112.20 and 112.21, including Appendices B through F. The EPA publis hed revisions to the rule in the Federal Register on June 30, 2000, which modified the requirements for an owner or operator of a facility handling, storing, or transporting animal fat and vegetable oil to account for new research findings and to reflect new statutory requirements under th e 1995 Edible Oil Regul atory Reform Act. Vaulted tanks are generally excluded from the scope of 40 CFR 280. The definition of an underground storage tank in 40 CFR 280.12(i) excl udes from its scope a storage tank situated in an underground area (such as a basement, cellar, mine working, drift, shaf t, or tunnel) if the storage tank is situated upon or above the surface of the floor. These tanks might reasonably experience a discharge as described in 112.1(b). Therefore, it is reas onable that they be within the scope of 112; however, the National Fire Preven tion Act (NFPA 30:2-3.4.3(b)) specifically indicates that a dike for a vaulted tank need only provide containment for the largest tank, while 112 requires some freeboard for precipitati on. Figure 1-15 illustrate s a typical aboveground vaulted tank. Used in the context of a liquid storage tank, a vault is an es sentially liquid-tight structure that completely surrounds a tank, provides a safe and secure environment for the tank, and meets each of the design and construction requirements set forth by the Petroleum Equipment Institute (PEI). The special enclosures are not backfilled and are constructed of at least six inches of reinforced concrete. They can have openings for inspection only in the top. Means are provided

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56 Figure 1-15. Vaulted Tanks. for removal of vapors or liquids from the inte rstice. The permission of local fire-safety authorities is generally required before special enclosures like this may be installed. Edible Oil Regulatory Reform Act In 1995, Congress enacted the Edible Oil Regul atory Reform Act (EORRA). The statute m andated that most federal agencies differentia te between and establish separate classes for various types of oils; specifical ly, animal fats, oils, and greases; fish and marine mammal oils; oils of vegetable origin; and other oils and gr eases (including petroleu m). The EPA concluded that a worst-case discharge or substantial threat of a discharge of animal fats and vegetable oils to navigable water, adjoining shorelines, or the exclusive economic zone could reasonably be expected to cause substantial ha rm to the environment, including wildlife that may be killed by the discharge. In 2002, the EPA amended the Oil Pollution Prevention Regulation (40 CFR 112), which included requirements for specifi c facilities to prepare, amend, and implement Spill Prevention,

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57 Control, and Countermeasure (SPCC) Plans. Th e regulation is largely performance-based, which allows flexibility in meeting the rule requireme nts to prevent discharges of oil to navigable waters and adjoining shorelines. The Oil Po llution Prevention Regula tion, promulgated under the authority of 311 of the Clean Water Act (CWA), set forth requirements for prevention of, preparedness for, and response to oil discharges at specific non-transporta tion-related facilities. To prevent oil from reaching navigable waters and adjoining shorelines, and to contain discharges of oil, the regulation requires these facilities to develop and implement SPCC Plans and establishes procedures, methods, and equipment requirements. Purpose and Scope of SPCC Rule Focusing on oil spill prevention, preparedness, and response, the SPCC rule is designed to protect public health, public welf are, and the environment from the potential harmful effects of oil discharges. The rule requires facilities that could reasonably be expected to discharge oil in potentially harmful quantities to develop and im plement SPCC Plans. The plans ensure that these facilities put in place c ontainment and countermeasures th at will prevent oil discharges. The Energy Policy Act of 2005 On August 8, 2005, President Bush signed the En ergy Policy Act of 2005. Title XV, Subtitle B of this act (entitled the Unde rground Storage Tank Compliance Act) contains amendments to Subtitle I of the Solid Waste Disposal Act the original legislation that created the underground storage tank (UST) program. This law significantly affected federal and state underground storage tank programs by requiring majo r changes to the programs; it was intended to reduce underground storage tank re leases into the environment. The underground storage tank provisions of th e Energy Policy Act focused on preventing releases. Among other things, it expanded eligib le uses of the Leaking Underground Storage

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58 Tank (LUST) Trust Fund and included provisions regarding inspecti ons, operator training, delivery prohibition, secondary containment and fina ncial responsibility, a nd cleanup of releases that contain oxygenated fuel addi tives. Some of those provisions required implementation in August 2006, while others required implementati on in subsequent years (U.S. EPA Office of Underground Storage Ta nks, EPA-510-D-06-001 2006). Section 9003(d) (Subtitle I) clearly states that a person who manufactures an underground storage tank or piping for an unde rground storage tank system or in stalls an underground storage tank system must maintain evidence of financial re sponsibility in order to provide for the costs of corrective actions directly related to releases caused by impr oper manufacture or installation. In addition, installers must be certified, or they mu st certify the installation of underground storage tank systems they install. These provisions do no t affect or alter the lia bility of any owner or operator of an underground storage tank (Section 9003). Owners and operators must still comply with all technical regulat ions. For example, they must comp ly with the requirements to report a release and perform all necessary corrective actions and to maintain financial responsibility to pay for corrective action and compensate third parties. The Energy Policy Act of 2005 does not specif ically require dispenser sumps to be included as part of the existing secondary cont ainment requirement for piping. However, underdispenser containment is required when installi ng a new motor fuel di spensing system, but the under-dispenser containment requirement does not trigger a secondary requirement for the existing piping system. In states such as Fl orida where piping secondary containment is required, under-dispenser containment is necessary for compliance of the secondary containment for the piping near the dispenser. According to the FDEP, containmen t underneath a dispenser that will prevent leaks from the dispense r from reaching soil or groundwater must:

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59 Be liquid-tight on its sides, bo ttom, and at any penetrations. Be compatible with the substance conveyed by the piping. Allow for visual inspection and access to th e components in the containment system. To ensure that the requirements for s econdary containment and under-dispenser containment are met, the FDEP requires that owners or operators notify the state before installing or replacing a tank, piping, or a motor fuel di spenser system. Currently, the EPA requires notification only within 30 days of bringing a storage tank system into operation. However, the Florida Department of Envir onmental Protection requires: 1. Pre-notification for owners and operato rs before new installation may begin. 2. The installer to notify the state before installation, replacement, or repair. 3. Installer certificat ion where installers must install secondary containment systems where appropriate. Floridas Petroleum Cleanup and Discharge Prevention Program In 1980, Petroleum contamination was detected in groundwater and pr ivate wells in the state of Florida. The drinking water well field for the city of Bellevue in Marion County was contaminated with petroleum from leaking underground storage tanks (UST) in 1982. In 1983, the Florida legislature passed the Water Qualit y Assurance Act, which prohibited petroleum discharges, required owners to clean up discha rges, and instituted insp ection programs for both aboveground and underground storage tanks. The le gislature concluded th at the states water supply was at risk. They established an amne sty program for cleanup (EDI) and established a cleanup trust fund (IPTF). This legislati on, called the State U nderground Petroleum Environmental Response Act (SUPERA), marked e ssentially the beginning of enforcement and data collection for th e state of Florida. Between 1987 and 1994, the legislature established three additional cleanup programs. By the end of 1994, the cleanup reimbursement program had accumulated $550 million in

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60 unfunded obligations. In 1995, th e reimbursement program was shut down by Governor Lawton Chiles and reorganized as the Preapproval Program, and the state acquired $261.9 million through bonding to pay reimbursement debt. Eligib ility applications for the last state-funded cleanup program ended in 1998 with eligible site registration exceeding 17,500. The total number of petroleum-contaminated sites in Florid a now exceeds 22,000. FDEP Program Statistics Cleanup Total number of petroleum-contaminated sites: 24,128 Total number of sites eligible for state funding: 18,035 Total number of private party contaminated sites: 6,983 Total number of state-funded contaminated sites completed: 4,911 Total number of private party cleanups completed: 4,026 Total number of active stat e-funded sites: 4,761 Total number of active private party sites: 1,886 Sites remaining to be cleaned up: State-Funded: 8,363 Private Party: 1,071 Compliance Total number of active petroleum facilities: 19,409 Total number of aboveground storage tanks (AST): 20,274 Total number of underground storage tanks (UST): 28,914 Total number of facility inspections (per year): 29,923 Facilities in total compliance: 53% Facilities in significant compliance 79% Summary A surface oil spill can h arm birds and mamm als by direct physical contact, toxic contamination, and destruction of food sources. The marine environment is made up of complex interrelations between plant and an imal species and their physical environment. Harm to the

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61 physical environment will often lead to harm for one or more species in a food chain, which may lead to damage for other sp ecies further up the chain. The greatest potential hazard from a leaking underground storage tank is that petroleum or other hazardous substances can seep into the soil and contaminate groundwater, the source of drinking water for nearly half of the American population (EPA ). A leaking storage tank can present other health and environmental risks, in cluding the potential for fire and explosion. The following legislative acts a ffect the use, storage, or disposal of oil: RCRA Resource Conservation and Recovery Act TSCA Toxic Substances Control Act SARA Superfund Amendment and Reauthorization Act CERCLA Comprehensive Environmenta l Response, Compensation, and Liability Act EPCA Energy Policy and Conservation Act ORA Oil Recovery Act The following tanks do not need to meet federal requirements: Farm and residential tanks of 1,100 gallons or less capacity for non-commercial use Tanks storing heating oil used on th e premises where it is stored Tanks on or above the floor of underground areas, such as basements or tunnels Septic tanks and systems for colle cting storm water and wastewater Flow-through process tanks Tanks of 110 gallons or less capacity Emergency spill and overfill tanks

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62 CHAPTER 2 LITERATURE REVIEW Risk-Based Decision Making and Underground Storage Tanks Risk-based decision m aking (RBDM) is a proc ess during which decisions are made about sites contaminated by releases from underground st orage tanks according to the actual risk each site poses to human health a nd the environment. The EPA s Office of Underground Storage Tanks (OUST) developed a comprehensive policy that explains the use of risk-based approaches at underground stor age tank sites. The EPA OUST is working with its regional offices and with state and local underground storage tank (UST) programs to encourage the use of risk-based decision making in their corrective action programs. During a literature search, several articles dealing directly with riskbased corrective action and stor age tanks were found. The ASTM Technical and Professional Training Manual for RBCA will be summarized be low along with a few other related texts. Health Risk Assessment for a Contaminated Site: A Case Study Health risk assessm ents are necessary for determining cancer risks and non-cancer hazards associated with contaminated sites. A site exposure model was prepared for a contaminated site where the major routes of e xposure were likely to be ingestion and dermal contact with contaminated soil. Soil contaminants were mainly heavy metals and polycyclic aromatic hydrocarbons (PAH). Health risks were calculated based on a conservative approach, which meant calculating risks for the most sensitiv e receptors onsite (i.e., children). As part of this conservative approach, risk calculations were chosen ba sed on the longest durations and frequencies of exposure that are li kely in the long term and the hi ghest contaminant levels onsite. The results of this quantitative risk assessment i ndicate that the cancer risk due to exposure to PAHs alone was >10-6 based on maximum and average contaminant concentrations. The hazard

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63 index was >0.2 (soil criterion) for exposure to heavy metals alone, based only on maximum concentrations. The quantification of risk for this site did not include cancer risks for heavy metals due to the lack of toxicity values. These results indicate that site remediation is necessary and that topsoil for the entire site will have to be removed and treated prior to disposal. ASTM RBCA Fate and Transport Models: Compendium and Selection Guidance The purpose of this guidance document on fate and transport modeling is to provide a com pendium of commonly used fate and transport models and pertinent information to aid users in the selection of an appropriate model to be us ed in the risk-based corrective action process. Various formulations of fate and transport models have been used for more than twenty years to assess and predict movement and behavior of chem icals in the environment. Over time, more sophisticated fate and transport models have been developed to take advantage of advances in computer hardware and software technologies and improved understa nding of fate and transport processes. There are now many models ranging from the very simple to the very complex. Fate and transport models may utilize simple e quations that require minimal data input or complex equations that require detailed, site-specific informa tion. The RBCA process advocates a gradual process of using models, starting from simple approaches that will produce conservative results and moving, as needed, to complex approaches requiring more data and time. Objectives of modeling should be defined before model selection begins, for it is possible that a simple model will be adequate to provide the desired information. The complexity of selected models should balance th e quantity and quality of availabl e input data (or of data that can be obtained easily) with the desired model output. Use of Risk-Based Decision Making in UST Corrective A ction Programs The primary purpose of this policy statemen t is to encourage the use of risk-based decision making as an integral part of the co rrective action process at sites where leaking

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64 underground storage tank systems have released petroleum products into the environment and thus created risks to human health and the environment. In addition, this policy statement provides guidelines to help UST implementing agencies develop and use risk-based decision making in a manner consistent with federal laws and regulations appli cable to UST corrective action. Some state and local implementing agencies have already taken steps to initiate the use of risk-based decision making in their corrective action programs. In the 1980s, to satisfy the need to star t corrective action programs quickly, many UST implementing agencies decided to utilize re gulatory cleanup standards developed for other purposes and apply them uniformly to UST release sites to establish cleanup requirements. With experience, however, it has become increasingly apparent that applying such standards without consideration of the extent of actual or potential human and environmental exposure is an inefficient means of providing adequate protec tion against the risks associated with UST releases. Similarly, UST implementing agencies have found that applyi ng identical reporting and review procedures to the planning and conduc t of all corrective actio ns is inefficient for them and for UST owners and operators. These problems have become increasingly serious as the number of UST release sites has multiplied. Application of Health Risk A ssessment to Derive Cleanup Leve ls at a Fuel Oil Spill Site RBCA has increas ingly become an accepte d approach for the remediation of contaminated sites. This paper described the application of four different risk assessment approaches, including the North Carolina risk analysis framewor k, Illinois tiered approach to correction objectives, RBCA tool kit for chemical releases (RBCA tool kit), and exposure and risk assessment decision support system, to conduc t a risk evaluation task and demonstrate the application strategy at a fuel oil spill site. After the risk evaluation processes, the soil and groundwater remediation goals for target com pounds (total petroleum hydrocarbon, benzene,

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65 toluene, methylbenzene, and xylenes) were dete rmined. The calculated remediation levels met with the requirements for minimum target risk levels (i.e., cancer risk of 1 X 10\U-6 and hazard quotient of one). After completi on of the RBCA process, the reme diation time and cost could be minimized in some cases due to the adoption of more achievable and flexible remediation goals. Among these applied risk assessment methods, the RBCA tool kit was an appropriate and feasible tool for the future risk assessment application due to its thorough considerations of the exposure pathway and transport model selection. Results from this study provided a streamlined process and guidelines for future risk work at petroleum-hydrocarbon co ntaminated sites in Taiwan. Based on the findings from this st udy, RBCA was believed to be a more sound and defensible basis for site closure. A Foundation for the Risk-Based Treatment of Gasoline-Conta minated Soils Using Modified Fentons Rea ctions The relative oxidation of repr esentative aromatic and a liphatic hydrocarbons found in gasoline was evaluated to provi de the foundation for risk-bas ed treatment of petroleumcontaminated soils and groundwater using modi fied Fentons reagent (catalyzed hydrogen peroxide). Aromatic components of gasoline ar e considered to be more hazardous than the aliphatic fractions due to their mobility in the subsurface and their higher acute and chronic toxicities. Benzene, toluene, and mixed xylen es (BTX) were selected as aromatic compounds representative of unleaded ga soline; while nonane, decane, and dodecane (NDD) were used as model aliphatic compounds. The effects of hydrogen peroxide (H2O2) concentration, iron catalyst concentration, and pH on the degree of treatment of the model compounds were investigated using central compos ite rotatable experimental designs Oxidation of the aromatic compounds required less iron and less H2O2 than did oxidation of the aliphatic compounds, while proceeding more effectively at near-neutral pH. Greater than 95% of the BTX was treated at

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66 nearly neutral pH using 2.5% H2O2 and 12.5 mg iron, while only 37% nonane, 7% decane, and 1% dodecane oxidation was achieved under the same c onditions. The results show that the more toxic and mobile aromatic fraction was more effectively oxidized using less H2O2 and more economical conditions, including near-neutral pH, compared to the aliphatic fraction. A process design based on treating only the aromatic fraction of petroleum may provide significantly lower costs when using modified Fe ntons reagent for the treatment of contaminated soils and groundwater. Environmental and Health Risk Assessment and Management, Principles and Practices This textbook is about the law, econom ics, pr actical assessment, and management of risky activities arising from routine, catastrophic environmental and occupational exposures to hazardous agents. The textbook begins where emission and exposure analysis ends by providing estimates or predictions of delete rious exposures. It deals with determining the nature and form of relations between exposure and response, damage functions, and the principles and methods used to determine the costs and benefits of risk management actions from the vantage point of single and multiple decision makers. Today, nati onal and international laws, conventions, and protocols are increasingly concerned with re ducing environmental a nd health risks through minimized exposure to toxic substances, bacteria, viruses, and other noxious agents. They do so through risk methods. The reason for the now worldwide use of risk assessment and management is that individuals a nd society must decide when, and at what cost, past and future hazardous conditions can be either avoided or minimized. In this process, society must account for the limited resources it can spend to remain sustainable.

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67 California Leaking Underground Fuel Tank (LUFT) Historical Case Analyses This histo rical leaking underground fuel tank (LUFT) case study report was submitted to the State Water Resources Control Board (S WRCB) Underground Storage Tank (UST) Program and the California Senate Bill 1764 LUFT Advisory Committee. The primary historical LUFT case study goa l was to support revision of the LUFT corrective action process. LUFT case historical data had been collected for about ten years. Analysis of this data provided information a bout the fate and transport of fuel hydrocarbons (FHC) released into Californias diverse hydro-ge ological settings and the impacts these releases had on groundwater resources. This historical LUFT case analysis data set is perhaps the largest ever compiled that dealt with the impacts of FH C releases over an extended geographic area. The initial objective of the analysis of this best-available data was to answer several key questions: Do FHC plumes behave in predictable ways? What factors influence the le ngth and mass of FHC plumes? To what extent are FHC plumes affec ting Californias groundwater resources? The answers to these questions would aid in the identification of risk and resource management approaches that balanced the cost of performi ng remediation against the anticipated benefits. Because there must be a pathway to a receptor to result in an impact to human health, one of the primary historical LUFT case analysis indices of potential risk impact was an estimation of benzene plume concentration and length. A further objective of the data analysis was to provide information about additional data that may be required to support improved risk and resource management decisions. The historical LUFT case analysis data collection effort involved transcribing data, copying written documentation from LUFT case file s, and entering data into an established

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68 electronic database. The variatio ns of FHC fate and transport parameters between sites were summarized using simple, non-parametric graphical and numerical techniques. Well locations were used in conjunction w ith groundwater time series sampling of FHC and water level measurement to calculate benzen e plume average concentrations and lengths as well as groundwater gradients. Th e data had resulted in a series of plume average concentrations and lengths for each site, which allowed the anal ysis of changes in plume length, as well as groundwater gradients, with time. Average results of LUFT site water chem istry and hydro-geologic characteristics were summarized in this document. One of the most striking geologi c characteristics of the LUFT cases analyzed in this study was the tendency fo r the sites to have shal low groundwater. Nearly half the sites have mean groundwater depths of less than 15 ft. Most sites had multiple soil layers, and clay was fairly widespread. The analyses of temporal changes in plume length and mass at each site were summarized. In general, plume lengths changed slow ly and tended to stabili ze at relatively short distances from the FHC release sites. Plume lengt h estimations showed that averaged site plume lengths rarely exceeded about 250 ft. Benzene plum e length tended to change slowly with time. Benzene plume average concentrations tended to decrease much more rapidly than plume lengths. While active remediation may help reduce plume benzene concentrations, significant reduction in benzene concentrations can occur with time, even without active remediation. Individual or combinations of other hydro-ge ologic variables, such as groundwater depth or range, had little relationship to benzene plume lengths. This indicates that the plume length may not be predicted by consid eration of hydro-geologic settings alone and that there may be strong controlling variables that were not measured. These hypothetical plume length

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69 controlling variables may be source mass and passive bioremediation rate. The data indicated that if FHC sources are significantly reduced or removed, plumes will likely heal themselves through passive remediation even if no active remediation is being performed. The resulting estimated tota l volume of groundwater that may be affected above a concentration of 1 ppb benzene is about 7,000 acre-feet. This volume of groundwater affected by LUFT benzene plumes was a very small proportion of Californias total groundwater resource (0.0005%). A Risk-Based Corrective Action Approach Using Computer Modeling at an Urban Leaking Underground Storage Tank Site Leaking underground storage tanks (LUST) at gasoline service stations are a major source of groundwater contamination in urban ar eas. Application of a risk-based corrective action (RBCA) approach at a gaso line-contaminated underground stor age tank site indicated that implementation of extensive soil and groundwater remediation was not warranted, nor was it always the most effective method of addressing soil and groundwater contamination problems. Data collected at an urban site in Queens, New York, were used to model contaminant transport to predict the impact of known gasoline contamination of so il on the underlying groundwater. Computer models were calibrated with known site characteristics and es timates of contaminant mass loading to groundwater. Down-gradient recep tor concentrations were also obtained. The results of the RBCA approach utilizing computer modeling indicated that minimal risk of future groundwater contamination exists at the site and that additional i nvestigation and/or remediation is unnecessary. Given the staggering number of documented pe troleum release sites in the United States and the fact that the majority of state regulat ory agencies are understaffed, the Environmental Protection Agency (EPA) has endorsed the Ameri can Society of Testing and Materials (ASTM)

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70 risk-based corrective action (RBCA ) as an alternative tool to address sites based on potential risks. RBCA was conceived so that sites can be expe ditiously mitigated, especially in areas of low risk, while ensuring that human health and the environment are adequately protected. The EPAs current position on RBCA was outlined in a recent directive issued by the Office of Solid Waste and Emergency Response (EPA OSWER Directive 9610.17). The impetus for the directive was the need to help in dividual states build corrective action programs that are based on both sound science and common sense and are flexible and cost-effective. The Toxicologic Hazard of Superfund Hazardous Waste Sites Uncontrolled hazardous waste sites are a m ajo r environmental and public health concern in the United States and elsewher e. The remediation of and public health responses to these sites are mandated by the federal Superfund statute. Approximately 40,000 uncontrolled waste sites have been reported to U.S. federal agencies. About 1,300 of these sites constitute the current National Priorities List (NPL) of sites for remediation. Findings from a national database on NPL sites show approximately 40% present comple ted pathways. Eighteen of the substances are known human carcinogens or reason ably anticipated to be carcinogenic. Many of the 30 substances also possess systemic toxicities. The high percentage of sites with completed exposure pathways and the toxicity potential of substances in these pathways show that uncontrolled hazardous waste sites are a major envi ronmental threat to human health. Findings from the U.S. governments experience in respondi ng to uncontrolled waste sites are relevant to other countries as they address similar e nvironmental and public health concerns. Risk-Based Corrective Action, Natural Attenuat ion, and Changing Regulatory Paradigms Since the late 1980s, more than half of all known underground storage tanks (UST) in the United States have been closed. Many of these tanks are known to have leaked, and new

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71 releases are still being reported. Correcting the resulting soil and groundwater contamination has turned out to be an expensive undertaking. In re sponse, regulations and in terested parties have worked together to adopt risk -based approaches to setti ng cleanup goals and to promote innovative cleanup technologies such as natural attenuation. These changes have dramatically affected the way in which leaking USTs are regulated and cleaned up. An Outline of a Guidance Framework for As sessing Hydro-Geological Risks at E arly Stages The prevalent and straightforward routine of impulsively collecting masses of new data for studies relating to groundwater contamination can be inefficient and costly as it does not provide optimal value from existing hydro-geolog ical and other information. A preliminary guidance framework is outlined for early stage monetary risk assessments prior to any new measurement. This framework considers both th e probability and the economical consequences of contamination and is aimed at providing a basis for cost-eff ective decision making regarding groundwater protection and management actions It centers on improved conceptual hydrogeological site descriptions ba sed on existing information and professional judgments prior to any new measurements. A key aspect of th e framework is to derive maximum possible quantitative understanding of risks from lim ited prior available qua litative information. The framework has a dual-site approach, assuming a situation of a contaminant source site and a receptor site. A two-st ep procedure leads to the moneta ry risk assessment with respect to existing compliance levels: 1. Conceptual model development 2. Quantitative model realization This procedure addresses the proba bility of contaminant release at the contamination source, the hydraulic connection between the source and th e receptor, and the contaminant transport conditions. The purposes of the framework are twofold:

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72 To provide a risk assessment framework that optimizes use of professional judgment for studies where data are limited To give synergistic interpretive values that complement field measurements and that can be used as prior estimates in more detailed studies Natural Attenuation of Contaminated Soils Natural attenuation is increasing in use as a low-cost means of remediating contaminated soil and groundwater. Modeling of contaminant mi gration plays a key role in evaluating natural attenuation as a remediation opt ion and ensuring that there will be no adverse impact on humans and the environment. During natural attenuation, the contamination must be characterized thoroughly and monitored throughout the process. In this paper, atte nuation mechanisms for both organic and inorganic contam inants, the use of models and protocols, and the role of monitoring and field case studies were reviewed. Survey of States 2001 Soils Cleanup St andards for Petroleum Contamination With the implementation of the EPA Office of Underground Storag e Tanks final rules for regulating underground storag e tanks in 1988 and the existing state of confusion regarding policies, rules, and regulations for the cleanup of petroleum-contam inated soils (PCS) at the state level, the Association for Environmental Health and Science (AEHS) began conducting state-bystate surveys of environmental regulatory agencies in 1990 to determine PCS cleanup standards for use in the regulated community. The survey was conducted by telephone intervie ws and submission of written information by the appropriate listed agencies. Many of th e states programs have changed or are in the process of changing to risk-based corrective action (RBCA) approach es. Thus the format of the summaries is less standardized than past survey s in order to accurately reflect the states programs.

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73 Every attempt has been made to accurately represent states cleanup standards; however, users should be cautioned to th e limitations of compiling complex regulatory information into tabular form. The information should be used on ly as a reference guide; legal, economic, or technical decisions should be based on speci fic information obtained directly from the appropriate agency in each st ate for each specific site. Managing Subsurface Property Hazards: Reacti ve Soils and Undergr ound Storage Tanks Fuels stored in underground tanks often cont aminate urban soil and water. A geographic information system (GIS) mapped 1,068 underground fuel tanks in Denton County, Texas. Tank locations were compared with soil shrink-swell a nd corrosivity potentials. Higher percentages of reported leaking tanks were observed in expansive and corrosive soils. This study illustrates the utility of GIS for overlaying laye rs of data that affect undergr ound tank integrity. Such overlays could find appropriate locations for new tanks, survey existing tanks for potential leak hazards, and assess hazards posed by leaking tanks based upon soil permeability. Revealed Preferences of a State Bureau: Case of New Mexicos Underground Storage Tank Program Leaking underground storage tanks (LUST) are a pervasive national environmental problem. Cleanup of leaking USTs is largely fi nanced publicly and under the control of state agencies. In the transition to new compliance st andards, individual states have taken advantage of provisions in federal regulations to implement their own programs. This raises the policy question of environmental federalism and the appropriate focus of government control. The objective of this study was to examine the reve aled preferences of a state UST bureau. New Mexico was one of the firs t state programs to use risk assessments in setting funding priorities. They analyzed the st atistical determinants of funding decisions and found strong evidence that risk information was used.

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74 Although this case study provided a measure of support for state control, the argument was strengthened when public financing was limited to the cleanup of historical pollution rather than a means for providing insuran ce for prospective pollution. Recommendations to Improve the Cleanup Pr ocess for C alifornias Leaking Underground Fuel Tanks (LUFT) This document summarizes the findings, conc lusions, and recommendations resulting from an 18-month review of the regulatory framew ork and cleanup process currently applied to Californias leaking underground fuel tanks (LUFT). This review was conducted by the Lawrence Livermore National Laboratory (LLNL) a nd the University of Californias -Berkley, Davis, -Los Angeles, and -Santa Barbara at the request of the State Water Resources Control Board (SWRCB), Underground Storage Tank Progr am. The recommendations are made to improve and streamline the LUFT cleanup decision-making process. Principal Research Questions to Be Addressed The principle research questions to be addres s ed in this dissertati on are centered around quantifying the sources of petroleum contamination, evaluating the results of the FDEP Scoring Reviews (see Appendix B), summarizing the FDEP discharge report form (see Appendix A), and the Petroleum Cleanup Site Inspection Form (see Appendix C). This dissertation will try to address the following questions: 1. Are there any correlations within th e FDEP Scoring Review database? 2. Are the results of a review depende nt upon location within the state? 3. What role does the local option sales tax play on a contaminated facil itys discovery and/or cleanup enforcement funding? 4. Which counties rank highest in level of cont amination and environmental exposure risk? Why? 5. How does Alachua County compare to the rest of the state in cleanup priority score?

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75 6. How does the additional burden of vapor recovery as enforced in Miami-Dade and Broward Counties, affect a facilitys overall score? First, an overall view of th e sources of petroleum contamin ation will be completed. This autopsy will be performed by summarizing in Mi nitab the discharge report form. This will explain the equipment problems that lead to a di scharge, explain how to adequately prevent a failure that leads to a discharg e, and give a better understanding of the problems that are being faced in the field. Then statewid e facility data will be reviewed in order to grasp the magnitude of the problem and the role enfo rcement plays in preventing it. Finally, differing levels of en forcement will be compared on a county-by-county basis to try to determine which Departments of Environm ental Protection tend to produce a more or less favorable score for an owner facing cleanup. This type of analysis has not, to my knowledge, ever been done even though the database ha s been available for publ ic download since 1996. Countless millions of state, priv ate insurance (PLIRP), and fede ral dollars have been spent on mandatory cleanups since the mid-1990s with no form al look at the information contained in the statewide FDEP database. Instead, the state of Florida has adopted an RBCA-based ranking system that depends on the facts of each case as listed on the FDEP Scoring Review form. As will be shown, this can lead to an unequal distribution of these funds.

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76 CHAPTER 3 RESEARCH METHODOLOGY Learning from Data In the bro adest sense, statistic s can be defined as a set of principles and techniques that are useful in solving real-life, practical problems base d on limited, variable data. As such, it has wide applicability in almost all areas of lif e including business, government, science, and personal lives. We approach the study of statistics by using a four-step process that closely parallels the scientific method: 1. Defining the problem 2. Collecting data 3. Summarizing data 4. Analyzing data, interpreting the an alysis, and communicating results Throughout this dissertation, the read er will be provided with a vari ety of graphical displays that are essential to the evaluation of the critical assumptions underlying th e application of such statistical procedures. These will include norma l probability plots, box plots, scatter plots, and residual plots. Furthermore, the results will be emphasized using graphica l displays in order to provide tools the reader can us e to distinguish treatment differences. These types of plots provide a method for making a distinction betw een statistically different treatments and practically different treatments. For example, when comparing a more environm entally conservative county with the rest of the state of Florida, sideby-side box plots and interval plots will be used to compare the median and mean using 95% confidence intervals. A p-value will be calculated to show the level of confidence in each result. A residual plot will also be calculated to show the closeness of the data to a normal distribution. S catter plots will be drawn for each comparison so that the raw data can be observed unobstructed. When multiple comparisons are made, the random sampling will be sorted by county, current score, score when ranked, etc., to reveal any sort of trend.

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77 Defining the Problem The statistical aspect of th is paper has three major goals: 1. Provide information 2. Build a model 3. Apply this model The model will be built on the FDEP Scoring Re view, the Petroleum Cleanup Site Inspection Form, and the statewide facility ranking. The re sults that are to be analyzed are from data collected over a ten-year period from 1996 to 2006. Some results, however, such as the discharge report form data, were taken from 2008 to ensure that the latest information on discharges was provided for the di scussion on how to prevent them. The goals of this research are to determine the effectiveness of incr eased local funding of environmental protection in leading to stronger enforcement; to attempt to detect any differences that may exist on a county-by-county basis; to compare and contrast the most contaminated counties in the state to see where each county, including Alachua County, fits in; to determine what effect, if any, vapor recove ry has on a facilitys score and number of discharges; and to determine the closeness of the data to a normal approximation, since the type and amount of discharge is an independent, random variable. Collecting Data The first step in learning from data is to define the problem. The design of the data collection process is the crucial step in intelligent data gathering The process takes a conscious, concerted effort focused on the following steps: Specifying the objective of the study, survey, or experiment Identifying the variables of interest Choosing an appropriate design for the survey or scientific study Collecting the data

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78 To specify the objective of the study, one must understand the problem being addressed. For example, when petroleum discharges occur, threats to potable water also occur and an owner of a facility may face considerable penalties if pr oper procedures are not followed, both before and after the discharge. Since discharges are ra ndom events that require extensive documentation, the contaminated facility database is filled with detailed information normally distributed that can be summarized to make several important points. The Petroleum Cleanup Site Inspection Form provides another basis for comparison and is filled out by the compliance officer with the FDEP. It contains a wealth of information including general comments, recommendations, a nd task observations. The owner is usually contacted two weeks prior to the inspection to give him or her a chance to make incidental improvements before the inspection. System pe rformance information is optional and is only collected if access to the compound is safely obtained from the contractor or site manager. A separate form is used for each site and site visit. A site map illustrating the monitor well locations and/or system layout is also included with this form. The purpose of this document is for a general description. The next source of data that will be used for this study is the York FDEP Scoring Review. This document generates a relative score that has a theoretical highest score of 100. However, in a worst-case discharge scenario, such as a hurri cane, tornado, or other catastrophic event that would cause a discharge to have free product on surface waters, a score of 120 or above is possible. The FDEP Scoring Review contains the facility ID numb er, which until 1996 was based on the year of discharge discovery, as well as the date and relative latitude and longitude of the facility. Table 3-1 summarizes the scoring procedure followed by the FDEP compliance officer.

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79 Table 3-1. List of Points for the FDEP Scoring Review. Description Points Fire/Explosion Hazard 1. Free product or volatized petroleum products at or above 20% of the lower explosive limit (LEL) in existing utility conduits or vaults, buildings, or othe r inhabited confined spaces 60 2. Ignitable free product on surface waters or impoundments 60 Threat to Uncontaminated Drinking Water Supplies 1. Uncontaminated municipal or community well fields of greater than 100,000 gallons per day permitted capacity with a well within mile of the site a. If the well fields 1-foot draw-down contour is known to encompass the site regardless of the well fields distance from the site b. If the well field is located down-gradient of the site 2. Uncontaminated private wells c onstructed prior to date of contamination discovery, or uncontaminated public water system well field with less than 100,000 gallons per day permitted capacity with a well within mile of the site a. 10 or more wells b. If the well fields 1-foot draw down contour is known to encompass the site regardless of the well fields distance from the site c. If the well field is located down-gradient of the site 3. Uncontaminated surface water body used as a public water system supply within mile of the site Migration Potential 1. Source Characteristics (only one selected). a. Recent spills or free product found in wells/boreholes b. Free product of 2 inches or more in 2 or more wells/boreholes. 30 20 15 20 10 10 5 10 4 6 c. Recent product loss or wells/groundwater contaminated but no free product 2. Product Type (only one selected) a. Light petroleum product (kerosene, gasoline, aviation fuel, and similar petroleum products) with water-soluble additives or enhancers (MTBE, ethanol and similar substances) b. Light petroleum product with no additives or enhancers c. Heavy petroleum product (fuel oil, diesel, and similar petroleum products) Environmental Setting 1. Site located in G-1 aquifer 2. Site located in G-2 aquifer 2 3 2 1 4 2 3. Site located in a high-recharge permeability geological area 4. Site located within m ile of an Outstanding Florida Water 4 1

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80 Note that each year, spending procedures ar e published that outline various criteria and exceptions to the basic priority score funding pro cess. They are too numerous to list here but generally include imminent threats and emergencies, executed contracts, approved bankruptcy court order sites, free product recovery init iative sites, source removal with UST upgrade initiative sites, well abandonment requirement, re moval and disposal of industrial waste, certain agreements, certain milestone authorizations, and department discre tion special projects. Effective July 1, 1995 (beginning of the Prea pproval Program), the priority score funding threshold was set at 70 points, wi th statutory exceptions for former reimbursement sites that had initiated the Remedial Action program task prior to March 29, 1995, or were required to continue cleanup pursuant to a cour t order. Over the years, the funding threshold has been moved up and down depending on the amount of money collected in the trust fund. Effective July 1, 2008, the priority score funding threshold was raised from 37 to 45 (Source: Bureau of Petroleum Storage Systems, Division of Waste Management). Sampling Designs for Surveys A crucial element in any survey is the manner in which the sample is selected from the population. If the individuals in cluded in the survey are sele cted based on convenience alone, there may be bias in the sample survey, which would prevent the survey from accurately reflecting the population as a whole. The basic design ( simple random sampling ) consists of selecting a group of n units in such a way that each sample of size n has the same chance of being selected. Suppose, however, that the data consists of counties in two or more distinct areas; we can divide the populati on elements into groups, or strata, according to county and select a simple random sample from each group. The resulting sample is called a stratified random sample. Note that stratification is accomplis hed by using knowledge of an auxiliary variable, namely the facilitys current score, high est overall score, and statewide facility ranking.

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81 Ratio estimation is a second method for using the informa tion contained in an auxiliary variable in this case, discharges per million gallons, scor e per number of contaminated facilities, etc. Ratio estimators not only use measurements on th e response of interest but also incorporate measurements on an auxiliary variable. Ratio esti mation can also be used with stratified random sampling. Data Management In this section, we concentrate on some impor tant data management procedures that are followed between the time the data are gathered and the time they are available in computerreadable form for analysis. The procedures fo r processing data for summarization and analysis are: 1. Receive the raw data source. 2. Create the database from the raw data source. 3. Edit the database. 4. Correct and clarify the raw data source. 5. Finalize the database. 6. Create data files from the database. RECEIVING THE RAW DATA SOURCE. For each study that is to be summarized and analyzed, the data arrive in some form, which we will refer to as the raw data source CREATING THE DATABASE FROM THE RAW DATA SOURCE. For most studies that are scheduled for a statistical analysis, a machine-readable database is created. The steps taken to create the database and its eventual form vary from one operation to a nother, depending on the software systems to be used in the statistical analysis. EDITING THE DATABASE. The types of edits done and th e completeness of the editing process really depend on the type of study and how concerned one is about the accuracy and completeness of the data prior to the analysis. For example, in using a statistical software package (such as SAS or Minitab), it is wise to examine the minimum, maximum, and frequency distribution for each variable to make certain nothing looks unreasonable. CORRECTING AND CLARIFYING THE RAW DATA SOURCE. Questions frequently arise concerning the legibility or accuracy of the raw data during any of the steps from the receipt of the raw data to the communication of the results from the statistical analysis. FINALIZING THE DATABASE. Some may have been led to believe that all data for a study arrive at one time. This, of course, is not always the case.

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82 CREATING DATA FILES FROM THE DATABASE. Generally, there are one or two sets of data files created from the machin e-readable database. The first set, referred to as original files reflect the basic structure of the databa se. A second set of data files, called work files was created from the original files. These work files were designed to facilitate the analysis. Summarizing Data on a Single Variable : Graphical Methods After the measurements of interest have b een collected, ideally the data are organized, displayed, and examined using various graphical techniques. As a general rule, the data are arranged into categories so that each measurement is classified into one, and only one, of the categories. This procedure eliminates any ambiguity that might ot herwise arise when categorizing measurements. When data are organized according to this guideline, there are several ways to display the data graphically. The first and simplest graphica l procedure for data organized in this manner is the pie chart. It is used to display the percentage of the total number of measurements falling into each of the categories of the variable by partitioning a circle (similar to slicing a pie). Figure 3-1 shows a breakdown of the total number of contaminat ed facilities categorized by county for north-central Florida. A second graphical technique for data orga nized according to the recommended guideline is the bar chart or bar graph. There are many variations of the bar chart. Sometimes the bars are displayed horizontally, and they can be used to display data across time. Bar charts are relatively easy to construct. Figure 3-2 s hows another breakdown of the total number of contaminated facilities by county, on ly this time a bar chart is used. The next two graphical techniques that we are going to discuss are the frequency histogram and the relative frequency histogram. Both of these graphical tech niques are applicable only to quantitative (measured) data. As with the pie chart, we must organize the data before constructing a graph. Figure 3-3 is a histogram of the highest current FDEP review score

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83 Clay Other Duval Orange Brevard Volusia Alachua Marion St. Johns Putnam Columbia Category Other 207 Clay 76 Columbia 88 Putnam 91 St. Johns 117 Marion 215 Alachua 228 Volusia 359 Brevard 396 Orange 835 Duval 895 North-Central Florida by County Figure 3-1. Pie Chart of Total Numb er of Contaminated Facilities. for the entire state of Florida. A histogram compares the number of o ccurrences of individual data values and compares the re sult with a normal distribution. Numerical descriptive measures are commonly used to convey a mental image of pictures, objects, and other phenomena. There are two main reasons for this. First, graphical descriptive measures are inappropriate for statistic al inference because it is difficult to describe the similarity of a sample frequency hist ogram and the corresponding population frequency histogram. The two most common numerical descri ptive measures are measures of central tendency and measures of variability ; that is, we seek to describe the center of the distribution of measurements and also how the measurements vary about the center of the distribution. We will draw a distinction between numerical de scriptive measures for a population, called parameters, and numerical descriptive measures for a sample, called statistics The mode of a set of

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84 L a f a y e t t e G i l c h r i s t D i x i e L e v y F l a g l e r B r a d f o r d H a m i l t o n B a k e r C l a y C o l u m b i a P u t n a m S t J o h n s M a r i o n A l a c h u a V o l u s i a B r e v a r d O r a n g e D u v a l 900 800 700 600 500 400 300 200 100 0 CountiesNumber Figure 3-2. Bar Chart of Total Numb er of Contaminated Facilities. measurements is defined to be the measurement that occurs most often. The median of a set of measurements is defined to be the middle value when the measurements are arranged from lowest to highest. The arithmetic mean or mean, of a set of measurements is defined to be the sum of the measurements divided by the total number of measurements. The range of a set of measurements is defined to be the difference between the largest and the smallest measurements of the set. The pth percentile of a set of n measurements arranged in order of magnitude is that value that has at most p% of the measurements below it and at most (100 p)% above it. The inter-quartile range (IQR) of a set of measurements is defined to be the difference between th e upper and lower quartiles; that is, IQR = 75th percentile 25th percentile.

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85 1089072543618 0 -18 3000 2500 2000 1500 1000 500 0 Highest Current ScoreFrequency Mean28.87 StDev21.34 N11983 Normal Figure 3-3. Histogram of Highest Current Score. The variance of a set of n measurements y1, y2, yn, with mean ybar is the sum of the squared deviations divided by n 1. The standard deviation of a set of measurements is defined to be the positive square root of the variance. The Box Plot A stem-and-leaf plot provides a graphical representation of a set of scores that can be used to exam ine the shape of the distribution, the range of scores, a nd where the scores are concentrated. The box plot which builds on the information disp layed in a stem-and-leaf plot, is more concerned with the symmetry of the distri bution and incorporates numerical measures of central tendency and location to study the variab ility of the scores and the concentration of scores in the tails of the distribution. The box plot uses the median and quartiles of a distribution. The skeletal box plot is constructed by drawing a box between the lower and upper quartiles with a solid line drawn

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86 across the box to locate the me dian. A straight line is then drawn connecting the box to the largest value; a second line is dr awn from the box to the smallest va lue. These stra ight lines are sometimes called whiskers, and the entire graph is called a box-and-whiskers plot. Figure 3-1 below illustrates a typical box-a nd-whiskers plot of the state of Floridas statewide highest current score as shown on the FDEP Scoring Revi ew. Outliers are marked with an asterisk. What information can be drawn from a box plot? Fi rst, the center of the di stribution of scores is indicated by the median line in th e box plot. Second, a measure of th e variability of the scores is given by the inter-quartile range, the length of the box. Recall that the box is constructed between the lower and upper quartiles so it co ntains the middle 50% of the scores in the distribution, with 25% on either side of the median line inside the box. Third, by examining the relative position of the median lin e, we can gauge the symmetry of the middle 50% of the scores. For example, if the median line is closer to th e lower quartile than the upper, there is a greater concentration of scores on the lo wer side of the median within the box than on the upper side; for a symmetric distribution of scores, the median line is located in th e center of the box. Fourth, additional information about skew ness is obtained from the length of the whiskers; the longer one whisker is relative to the other, the mo re skewness there is in the tail with the longer whisker. Fifth, a general asse ssment can be made about the presence of outliers by examining the number of scores classified as mild outliers and the number classified as extreme outliers. Box plots provide a powerful graphical technique for comparing samples from several different treatments or populations See Figure 3-4 for an example of a side-by-side box plot of facility current score for north-central Fl orida; comparisons can be made regarding what score is most likely in each county.

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87 120 100 80 60 40 20 0 Statewide Highest Current Score Figure 3-4. Box Plot of Stat ewide Highest Current Score. An individual value plot or scatter plot in Minitab attempts to map each data point as a separate point based on a selected category. Figure 3-6 shows a scatter plot of the same information contained in Figure 3-5 above. When th e same data point occurs more than once, it is drawn beside the previous one to give the illusion of density. Inferences about for a Normal Population, U nknown In this section, we present a test that can be applied when is unknown, no matter what the sample size, provided that the population distribution is approximately normal. W. S. Gosset faced a similar problem around the turn of the twentieth century. As a chemist for Guinness Breweries, he was asked to make judgments on the mean quality of various brews but was not supplied with large sample sizes to reach his co nclusions. Gosset thought th at when he used the test statistic z (Equation 3-1) z = (ybar 0) / / n1/2 (3-1)

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88 B r e v a r d B a k e r C l a y D u v a l P u t n a m M a r i o n A l a c h u a V o l u s i a O r a n g e S t J o h n s D i x i e 100 80 60 40 20 0 Current Score Figure 3-5. Box Plot of Facility Current Score. B r a d f o r d B a k e r C l a y D u v a l P u t n a m M a r i o n A l a c h u a V o l u s i a O r a n g e S t J o h n s D i x i e 100 80 60 40 20 0 Current Score Figure 3-6. Individual Valu e Plot of Current Score.

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89 with replaced by s for small sample sizes, he was falsely rejecting the null hypothesis H0: = 0 at a slightly higher rate than that specified by The problem intrigued him, and he set out to derive the distribution and percentage points of the te st statistic (Equation 3-2) t = (ybar 0) / s / n1/2 (3-2) for n < 30. For example, suppose an experimenter sets at a nominal level say, .05. Then he or she expects falsely to reject the null hypothesi s approximately 1 time in 20. However, Gosset proved that the actual probability of a Type I e rror for this test was somewhat higher than the nominal level designated by He published the results of hi s study under the pen name Student, because at that time it was against company po licy for him to publish hi s results in his own name. The quantity (Equation 3-3) (ybar 0) / s / n1/2 (3-3) is called the t statistic, and its distribution is called the Students t distribution or, simply, Students t. In addition to being able to run a statistical test for when is unknown, we can construct a confidence interval using t The confidence interval for with unknown is identical to the corresponding confidence interval for and is known, with z replaced by t and replaced by s (Equation 3-4). ybar t /2 / s / n1/2 (3-4) Note: df = n 1 and the confidence interval coefficient is (1 ). When the population distribution is highly skewed or very heavily tailed, the median is more appropriate than the mean as a representation of the center of the population. Furthermore, the t procedures for constructing confidence interv als and for tests of hypotheses for the mean are not appropriate when applied to random sample s from such with small sample sizes. Figure

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90 3-7 is a confidence interval plot of the same in formation contained in Fi gure 3-5 and Figure 3-6, a county-by-county comparison of the current FDEP score for north-central Florida. The Program Best Suited to Answer the Research Questions In this sec tion, we will readdress the research question postulated at the end of the Literature Review and propose statistical met hods for proving or disproving them. 1. Are there any correlations within th e FDEP Scoring Review database? The database will be sorted and organized based on location and whether the county in question is rural or urban. Confid ence intervals using the Students t distribution will be used to compare average current review score, highest overall review score, and overall countywide ranking within the state for each contaminated facility. Trends should avail themselves especially when combined with side-by-side box plots of the same geographical sampling. A scatter plot of individual cont aminated facility scores will verify the results, if any. B r a d f o r d B a k e r C l a y D u v a l P u t n a m M a r i o n A l a c h u a V o l u s i a O r a n g e S t J o h n s D i x i e 60 50 40 30 20 Current Score95% CI for the Mean Figure 3-7. Interval Plot of Contam inated Facilities Current Score.

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91 2. Are the results of a review depende nt upon location within the state? The FDEP Scoring Review centers around the pr oximity of the contamination to potable wells, agricultural retention ponds, and surface waters. Counties with inter-coastal waterways and drinking water wells of 100,000 gallon and higher capacity, therefore, should score on average higher than the more centr ally located rural counties. On ce again, confidence intervals, box plots, and scatter plots will be used to ma ke widespread comparisons of urban and rural county differences. 3. What role does the local option sales tax play on a contaminated facility s discovery and/ or cleanup enforcement funding? Counties will be selected for each of the five local option sales taxe s that are collected throughout the state: $0.340, $0.320, $0.290, $0.280, and $0.259. Side-by-side interval plots, box plots, and scatter plots will be used to determine which tax bracket creates the lowest overall discharge score. Conclusions can then be reached as to which ta x rate produces the best result for protecting the environment at the lowest cost. 4. Which counties rank highest in level of cont amination and environmental exposure risk? Why? All 67 counties in the state of Florida will be given a confidence interval and then sorted based on the arithmetic mean of current score, score when ranked, and statewide ranking. The counties with the highest levels of contaminati on will be isolated and analyzed for any sign or symptom as to why the county is considered to be so contaminated. 5. How does Alachua County compare to the rest of the state in cleanup priority score? Alachua County has historically been on the cutting edge of passing and enforcing environmental laws. The effect of this county s treatment of contam inated sites will be compared to the entire state of Florida to see wh at effect this increased level of enforcement has had on the review score.

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92 6. How does the additional burden of vapor recovery as enforced in Miami-Dade and Broward Counties, affect a facilitys overall score? Miami-Dade and Broward counties will be isolated and compared to similar counties to see what effect vapor recovery has had on the cu rrent score, score when ranked, and state contamination facility ranking. Before any of the above analysis is performe d, a systematic overview of the data will be performed by taking random samples and summariz ing the results. Leak autopsy forms and the discharge report form will provid e the basis for the overview, which follows in Chapter 4. The first step involved in summarizing the various data bases available is to fi rst quantify sources of petroleum product contamination and their impacts on the environment.

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93 CHAPTER 4 ANALYSIS OF FINDINGS Quantify Sources of Petroleum Product Contamination and Their Impacts on the Environment The m ost common sources of petroleum contam ination from stationary petroleum storage systems are: Leaks in piping and joints. Leaks from corroded tanks. Various equipment failures upon startup of newly installed storage systems. Overfills and spills while filling tanks. When released to the environment, petrol eum and petroleum produc ts can contaminate: Soil. Groundwater. Surface Water. Air. The type, amount, and duration of the discharge, th e length of time elapse d since the discharge, and the hydro-geologic conditions underlying the s ite will determine the size, length, and depth of the contaminant plume. Many factors will determine how quickly a plume will migrate, including: Groundwater flow rate. Adsorption (adherence) to soils. Dispersion. Biodegradation (microbes usi ng the contaminate as food). Volatilization (vaporiza tion of contaminates). Preferential pathways through highl y permeable zones and channels. Because petroleum is lighter than water, free (undissolved) product and the most dissolved contamination are usually concentrated near the top of the groundwater table. As the water table rises and falls with seasonal variat ions and drought or flood conditions, contaminants concentrate in smear zones above and below the mean water table. Adequately treating these smear zones plays a key role in the remediation process (see Figure 4-1).

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94 Figure 4-1. Smear Zone. Threats from contamination in the environment, though relativ ely rare, are the explosive vapors from discharged petroleum products that can accumulate in confined spaces such as an abandoned tank, a subsurface cable vault, sewer pipes, or beneath buildings. Ignition of these vapors can cause an explosion with potentia lly catastrophic results. Human exposure to petroleum contaminants can occur through: Ingestion of contaminated dr inking water and soil residues. Inhalation of vapors and airborne soils. Contact of contaminants with skin (dermal exposure). More information regarding toxicity of petroleu m chemicals is available from the Agency for Toxic Substances and Diseases Registry, an ag ency of the U.S. Department of Health and Human Services. The agency homepage address on the Worldwide Web is www.atsdr.cdc.gov.

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95 Petroleum contamination may also adversely affect nearby plants and animals, from the smallest to the largest members of the natural f ood chain. Plants growing in contaminated soils or water may die or appear distressed. Anim als may drink contaminated water or feed upon plants or other animals that have been exposed to contaminants. Although not visible to the naked eye, subsurface elements of ecosystems, such as these in which microorganisms are present, may be overwhelmed by contaminants. Sensitive habitats, such as wetlands and marine ecosystems, are particularly susceptible to petroleum chemical s (see Figure 4-2). Figure 4-2. Sensitive Habitats. Florida Department of Environmental Protection (FDEP) Facility Statistics According to the FDEP Division of Waste Management, as of January 2008 there were more than 186,000 registered storag e tanks in the state of Florida. Of these, about 120,000 were

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96 closed or removed. There are 55,76 1 active registered facilities in the state, with 20,018 being actively regulated. Among the regulated faci lities, there are 10,909 w ith underground storage tanks (UST), 9,644 with aboveground storage tanks (AST), and 514 with both. According to Chapter 762, the materials used for secondary containment shall be: Impervious to the regulated substance and ab le to withstand deterioration from external environmental conditions. Non-corrosive or of corrosion-protected materials. Capable of containing regulated s ubstances for at least 30 days. Of sufficient thickness and stre ngth to withstand hydrostatic forces at maximum capacity to prevent a discharge duri ng its operating life. Storage tank system equipment with closed interstitial spaces, such as double-walled USTs and double-walled integral piping in contact with the soil that is c onnected to USTs, shall be designed, constructed, and inst alled to allow for the detection of a breach of integrity in the inner or outer wall by the monitori ng of the interstitial space in accordance with the chapter. A breach of integrity test shall be performed before the storage tank system is put into service. Secondary containment systems shall be designed a nd installed to direct any release to one or more monitoring points. All components of a storage tank system sh all be installed in accordance with the manufacturers instructions. Furthermore, all st orage tank systems shall be installed according to the applicable provisions of NFPA 30 and 30A, PEI/RP 100-97, and API RP 1615. A certified contractor shall perform the inst allation of storage tank systems containing pollutants, including tanks, integral piping, overfill protection and sp ill containment equipment, internal release detection equipment, cathodic protection syst ems, secondary containment systems, and dispensing systems, if the installa tion of the storage tank system co mponent disturbs the back fill or where the integral piping is connect ed or disconnected during installation.

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97 A tightness test shall be performed on any st orage tank and integral piping before it is placed into service unless the systems equipm ent approval specifies otherwise. Fiberglassreinforced plastic tanks shall be constructed in accordance with UL 1316 and ASTM Standard D4021-86 or certified by a nationally recognized laboratory that these standards are met. Tanks shall be constructed or installed to provide for interstitial monitoring. All tanks installed or constructed at a f acility after July 13, 1998, shall have secondary containment and overfill protection, and, at a minimum, fill box cove rs shall be marked in accordance with API RP 1637. Tightness tests for underground small diameter piping connected to USTs are subject to paragraph 62-761.500(2)(d), F.A.C. Fiberglass-re inforced plastic piping or other non-metal piping installed at a facility shall be listed with UL 971, UL 567, certified by a nationally recognized laboratory that these standards are met, or approved in accordance with subparagraph 62-761.500(8)(b)3., F.A.C Review of Regulations The regulation of oil-containing aboveground storage tanks is a function of federal, state, and local governments. The regulations generally focus on environmental issues such as oil spill prevention and fire prevention. One area of c onfusion is the concept of environmental requirements versus fire code requirements for oil storage containers. There is some overlap between the two fields. A tank l eak is generally considered an environmental issue, but it could also lead to oil reaching an i gnition source. A tank with insufficient emergency venting capacity is both a fire hazard and an environmental spill ri sk if the tank ruptures form over-pressurization. The unclear overlap between environmental and fi re code requirements is a source of confusion. Provided below is a summary of Florida storage tank statistics.

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98 FDEP Statistics The next few pages and figures summ arize th e Florida Division of Waste Managements Pollutant Storage Systems statistics for the y ear 2008. Since the mid-1990s, there has been an increased level of interest, or perhaps just more active repor ting and sharing of information, among state and federal UST inspectors regardin g the deterioration of storage tank systems components, specifically non-metal underground pi ping and containment sumps, as will be discussed later. Field-erected above-ground st orage tank statistics Field-erected storage tan ks are shop-fabricat ed and field-welded together. They are primarily used in refineries and other bulk storage facilities where aboveground storage is practical. Below (Figure 4-3) is a pie chart illu strating 100 discharges selected at random from field-fabricated ASTs as of January 20, 2008. Bulk product piping consisted of 48% or nearly half of all discharges regarding this type of tank. As for the ta nk itself, a collapse of the main shell accounted for about 26% of the discharges. The rest of the discharges came from the appurtenances in other words, the valves, hydrant piping, small diameter piping, or other similar accessories. Figure 4-4 shows a breakdown of AST discharg es for all causes, including human error and causes unrelated to the storage tank itself, from a pool of 100 randomly selected discharge notification forms (DNF). See th e appendix for a copy of the offici al state of Florida discharge reporting form. Notice that corrosion, or proba bly more specifically internal corrosion, is responsible for approximately 18% of field-fabricated AST tank fa ilures. The next most likely cause is unknown to the investigator, most probably another form of human error.

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99 Bulk Product Piping Small Diameter Piping Vehicles Valves Hydrant Pits Pumps Field-Erected Tanks Other Hydrant Piping Category Hydrant Piping 4, 4.0% Other 4, 4.0% Field-Erected Tanks 26, 26.0% Pumps 4, 4.0% Hydrant Pits 2, 2.0% Valves 9, 9.0% Vehicles 2, 2.0% Small Diameter Piping 1, 1.0% Bulk Product Piping 48, 48.0% 100 Discharges Figure 4-3. Field-Erected AST Sources. Although failures of field-fabr icated aboveground storage tank s are relatively rare, when failures do occur, the environmenta l damage can be tremendous. Mo st storage tanks of this type are protected from internal and external co rrosion by highly effec tive cathodic protection systems. This corrosion preventa tive technique uses either sacrificial anodes or an impressed current to combat the effects of galvanic corr osion. The main drawback to cathodic protection systems is the regular maintenance that they require and the fact that a specially trained technician is required to service th e electrical circuit that is used. Shop-fabricated above-ground storage tank statistics Shop-fabricated aboveground storage tanks are m anufactured in a number of different styles, including fire-resistant and concrete-encased designs. C oncrete-enclosed designs may not

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100 Flanges Loose Component Pressure Relief Valves Material Failure Weld Failure Spill Physical Damage Overfill Unknown Human Error Gauges Gaskets Weather Tank Bottom Leaks Mechanical Failure Other Corrosion Category Overfill 8, 8.0% Physical Damage 5, 5.0% Spill 5, 5.0% Weld Failure 2, 2.0% Material 6, 6.0% Relief Valves 6, 6.0% Loose Comp. 8, 8.0% Flanges 2, 2.0% Corrosion 18, 18.0% Other 4, 4.0% Mechanical 3, 3.0% Tank Bottom 5, 5.0% Weather 2, 2.0% Gaskets 4, 4.0% Gauges 2, 2.0% Human Error 4, 4.0% Unknown 16, 16.0% 100 Discharges Figure 4-4. Field-Erected AST Causes. be U.L. listed with 110% secondary containment on certain models. In other words, it may be necessary to provide secondary containment on so me concrete-encased models. These tanks are generally referred to in the industry as impact -resistant models. A 12,000-gallon tank, which is the smallest practical working volume for a retail tank, can weigh upwards of 100,000 pounds! Even if the shop-fabricated tank is provided with a secondary containment that meets the 110% requirement, the exposed concrete outer wa ll is susceptible to cracking, spalling, and weathering problems that are expensive to co rrect and are usually not covered by warranty. The secondary containment on certain designs of concreted shop-built ASTs may require elaborate and expensive procedur es to be tested on-site. Fire-resistant, steel, double -walled, shop-built ASTs are typically U.L. listed, and the secondary containment is testable on-site using standard, economical procedures. The steel outer

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101 wall of fire-resistant steel s hop-built ASTs provides low-cost maintenance and protects the insulation material from weathering. An average 12,000-gallon, fire-resistant, st eel, double-walled AST weighs less than 40,000 pounds well within the legal lo ad limit for trucking. Fire-res istant tanks such as these were the first ASTs to obtain a U.L. listing for secondary containment. Figure 4-5 shows a breakdown of the reasons for 188 total discharges from aboveground shop-fabricated tanks. Tank overfills and spills account for more than half the discharges. Loose fittings, human error, physical damage, and vehicle overfills appear to be responsible for the rest. Fire-resistant, shop-built, aboveground st orage tanks are availabl e in capacities ranging from 186 to 50,000 gallons (see Figure 4-6). These tanks enjoyed a renewed interest dur ing the drinking water scares of the 1980s. Shop-fabricated ASTs have the main benefit of be ing fire resistant and eas y to maintain. Visual inspection combined with pressure or vacuum te sting can be performed on the interstice that satisfies the field testing requirements for doublewalled tanks. Originally, these tanks were an engineered alternative to conventional ASTs with concrete or steel secondary containments. These tanks tend to cost substantially more th an similar single-walled tanks that could be installed within a concrete dike therefore, they tend to not be as practical for bulk storage at refineries or terminals. Figure 4-5 illustrates a breakdown of the s ources of discharges that were recorded for shop-built aboveground storage tanks considering just th e storage tank system itself. Shop-fabricated storage tanks are manufactured off-site, transporte d by truck, and placed surrounded by bollards (protective st ructures). These tanks, as of 2008, have failed 36% of the time. The product piping and dispensers acc ount for most of the re maining discharges

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102 Other Improper Installation Tank Overfill Material Failure Physical Damage Vehicle Overfill Spill Valve Failure Unknown Gauges Corrosion Loose Component Human Error Category Material Failure 6, 3.4% Tank Overfill 49, 28.0% Installation 6, 3.4% Other 4, 2.3% Human Error 8, 4.6% Loose Component 21, 12.0% Corrosion 8, 4.6% Gauges 2, 1.1% Unknown 19, 10.9% Valves 2, 1.1% Spill 16, 9.1% Vehicle Overfill 11, 6.3% Physical Damage 23, 13.1% 188 Discharges Figure 4-5. Shop-Built AST Sources. from these tanks. As will be mentioned several times in the following discussion, human error involving loading and unloading th e tank is largely responsible fo r most of the non-mechanicalrelated discharges resulting from storage tanks Very little can be done beyond training, strict safety programs, and reliable inventory controls to prevent simple human error. The author has personally been responsible for the cleanup of lite rally dozens of spills over the years as a result of this. Regular maintenance can prevent most of the smaller leaks that are reported for the shopbuilt ASTs. A failure of an engineered, shop-bui lt, double-walled storage tank is defined as a failure of the interstice, or the space between th e inner and outer tanks. Therefore, a discharge for a double-walled tank usually does not actua lly involve the release of a product into the environment.

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103 Figure 4-6. Typical Sh op-Fabricated AST. The product is contained within the secondary containment, a nd most of the time the free product can be recovered or r ecycled, depending on the product, by minimizing the impact on the environment. Figure 4-7 represents the total number of discharges reported by tanks of this sort, or 188 total discharges as of January 20, 2008. It is interesting to note that up to 6% of discharges involve the failure to follow proper fueling guidelines. Underground storage tank statistics Early doubleand single-walled underground st orage tanks (UST) were notorious for prem ature failure. This was the result of ma ny factors including, but not limited to, poor construction techniques (mainly the use of incorrec t back fill material), internal corrosion as a result of the by-products of hydr ocarbon, utilizing micro-organisms digestive processes, and the unnatural decomposition of the thermoplastic and thermosett ing plastic containments. Figure 4-8 illustrates USTs as th e source of the discharge by type of tank. Note that as of January 2010, single-walled tanks, which ar e statistically responsible for more

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104 Other Valves Pumps Small Piping Fuel Filters Vehicles Day Tanks Shop-Fab. Tanks Bulk Piping Dispensers Fill Pipes Delivery Vehicles Category Pumps 6, 3.1% Valves 6, 3.1% Other 6, 3.1% Delivery Vehicles 14, 7.2% Fill Pipes 2, 1.0% Dispensers 25, 12.8% Bulk Piping 2, 1.0% Shop-Fabricated Tanks 67, 34.4% Day Tanks 7, 3.6% Vehicles 11, 5.6% Fuel Filters 6, 3.1% Small-Diameter Piping 43, 22.1% 188 Discharges Figure 4-7. Shop-Fabr icated AST Causes. discharges and have no built-in secondary containment to control the release, will no longer be in compliance. Such tanks will be re quired to be removed or closed. Figure 4-9 exposes the inside of a thermoplastic double-walled storage tank that failed as a result of incorrect back fill material. The out er wall of the tank was punctured by debris. After repeated attempts at patching the tear, eventually the tank was taken out of service. The next few photographs are from the tank autopsy that was pe rformed. One can clearly see from Figure 4-9 where water was filling into the interstice. The ru st stain has a distinct inverted V-shape at the point of infiltration. During the autopsy, the tank was carefully cut open to reveal substantial internal corrosion as seen in Figure 4-10. This type of excessive intern al corrosion can be caused only by extreme tank neglect; i.e., failure to check and remove water from the inside the tank or the tank bottom as required. In this case, the storage tank system had been closed because of

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105 Single-Wall Sacrificial Anod e Single-Wall Composite Single-Wall Internally Lined Single-Wall Impressed Double-Wall Composite Double-Wall Fiberglass Single-Wall Fiberglass Category Single-Wall Fiberglass 14, 26.4% Double-Wall Fiber. 9, 17.0% Double-Wall Composite 2, 3.8% Single-Wall Impressed Current 7, 13.2% Single-Wall Internally Lined 13, 24.5% Single-Wall Composite 6, 11.3% Single-Wall Sacrificial Anodes 2, 3.8% 46 Tanks Figure 4-8. USTs Tanks as the Source. the failure of the secondary tank for around six months, but even this does not explain the extreme level of corrosi on found inside the tank. There were 373 leak autopsy forms attributed to USTs in the state of Florida as of January 1996 (see Figure 4-11). Spill buckets were by far the primary source for discharges, primarily because of the constant abuse of traffi c driving over the fixtur e, causing it to crack and become compromised. Most of the time, the sp ill bucket can be repair ed, usually by breaking out and removing the damaged bucket and replacing it with a new one. This can usually be done unless there is damage to the tank fitting. When considering only double-walled tanks, overfill and physical damage account for the vast majori ty of failures. One misleading point about Figure 4-12 is that with a doubl e-walled tank, a failure is repo rted if either the primary or the secondary wall fails. So far, the data indi cates that it is the secondary tank that is failing. In most cases, polyethylene-jacketed tanks appear to be failing at an abnormally high rate.

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106 Figure 4-9. Autopsy of Double-Walled Storage Tank Showing Failure Point. Figure 4-13 shows a failed polyethylene jacket that was removed during the tank autopsy. The water level that infiltrated into the interstice can be clearly seen. Physical damage to the outside of a fiberg lass double-walled storage tank can readily occur if proper tank handling techniques are not followed. Most minor damage to the tank can be repaired with field repair kits; this involves reapplying the fiberglass coating that has been damaged. A more important concern is that of moisture penetrating the fi berglass outer shell and causing pockets of rust to form. These local corrosion holidays are difficult to prevent. They are usually the result of poor manufacturing techniques in wh ich the fibergla ss thickness is incorrectly or inadequately applied.

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107 Figure 4-10. Tank Autopsy Showing Internal Corrosion. Dispensers Line Leak Detectors Submersible Turbine Pump Piping Delivery Vehicles Tanks Spill Buckets Other Category Other 23, 6.2% Spill Buckets 159, 43.1% Tanks 46, 12.5% Delivery Vehicles 11, 3.0% Piping 60, 16.3% Pumps 13, 3.5% Line Leak Detectors 11, 3.0% Dispensers 46, 12.5% 373 Forms Figure 4-11. UST Leak Sources.

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108 Fiberglass-protected, steel, double-walled storage tanks are co nsidered to be the best investment in storage tank t echnology. However, the tanks cost 30% more than comparable double-walled fiberglass tanks; th erefore, many owners are re luctant to invest beyond the minimum requirement to meet the secondary cont ainment specifications. These tanks are not without fault, however, as Figure 4-14 shows corrosion holidays that formed underneath a protective fiberglass coating. Th is tank had been completely burie d for 15 years until a dispute between the owner of the tank a nd the convenience store owner re sulted in the tank being dug up from its underground position. Overfill (Fiberglass) Overfill (Composite) Overfill (Polyethylene-Jacket) Breach of Integrity (Comp) Unknown (Fiberglass) Weather (Fiberglass) Physical Damage (Fiberglass) Category Physical Damage (Fiberglass) 2, 18.2% Weather 1, 9.1% Unknown (Fiberglass) 2, 18.2% Breach of Integrity (Composite) 1, 9.1% Overfill (Polyethylene-Jacketed) 2, 18.2% Overfill (Composite) 1, 9.1% Overfill (Fiberglass) 2, 18.2% 10 Discharges Figure 4-12. USTs Double-Walled USTs as the Source, Cause. The fiberglass-protected, steel, double-wall ed tanks had performed well underground on the outside even with the holidays that are show n in Figure 4-14. The fiberglass coating appears to have held the corrosion to a few isolated place s. However, after exploring the inside of the

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109 Figure 4-13. Breach of Integrity of a Polyethyl ene-Jacketed Double-Walled UST. tank with a remote-controlled camera, major inte rnal corrosion was found as a result of HUM (hydrocarbon-utilizing microorga nisms) bugs and moisture. A thorough SONAR evaluation was required in order to bring the tank back into certification. Piping Statistics Thermoset or rigid fiberglass-reinforced plas tic (FRP) piping has been around for at least as long as the petroleum industry. Typically, someone has to do something foolish or deliberate (e.g., step on it, drill through it, score it, impact it), improperly install it, or subject it to ground movement (i.e., shearing) to creat e a problem. No deterioration of thermo-set materials from exposure to petroleum products has been observe d by the author. Thermoplastic piping, on the other hand, is experiencing a sooner-than-predicted failure rate. Thermoplastic piping is a relatively new technology that ga ined rapid acceptance in the i ndustry because of its ease of installation. Thermoplastic piping Thermoplastic piping, especially the polyur ethane and early polyethylene flexible compositions, has been subjected to intense scruti ny over the past several years. Following the introduction of polyurethane-based piping in the early 1990s, Florida began seeing microbial

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110 Figure 4-14. Fiberglass Coating Failures on a Double-Walled Steel Tank. growth and degradation in the outer jacket of some piping within three to five years of installation (see Figure 4-15). Ma nufacturers typically replaced the affected sections and often the entire run at a given stati on with the latest version of th e pipe. There was no mandatory recall of the initial pipe. Re placement was apparently based on the individual behavior or response of the pipe. Approximately 10 years from installation, an increasing number of thermoplastic piping systems at facilities in Florida have been expe riencing a variety of pipe -deterioration conditions. In retrospect, most of the init ial product line manufactured ha d a 10-year warranty. A warranty indicates the expected life span of any given product. This is not to say that the pipe has to

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111 experience problems, but at this time the warran ty has expired. The photo on the upper left of Figure 4-16 illustrates a failure of the primary and the thermoplastic secondary. Fuel is literally pouring out of the pipe into the sump. The photo on the upper right sh ows the thermoplastic hose split and not able to hold pre ssure. Some other reported ther moplastic flex pipe failures are listed below: Exterior and interior co lor change in the pipe Mold growth on the outside of the pipe Softening or jelling of the pipe Blowout, a term used to describe the ruptur e of the outer jacket of the primary pipe (see Figure 4-17) Figure 4-15. Microbial Degrad ation of the Outer Jacket. Cold growth or lengthening of the pipe, in cluding backing off fitti ngs, and movement of equipment out of position

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112 Brittle interior core and crack ing of the carrier portion, crack ing of the secondary wall, and loss of internal integrity of the pipe Loss of communication within the interstice of a coaxial pipe Alligatoring or rippling of the outer layer Fitting failure Initially, manufacturers response to the pipi ng problems was to direct the blame to the installation contractors. Howeve r, all contractors are required to be manufacturer-trained in piping installation, so this logic was somewhat circular. As states began sharing information about a widening pool of incidents at various types of facilities, th is rationale became implausible. Certainly some leve l of responsibility could be due to contractor error, as problems do occur because of deviations from standard practices. Figure 4-16. Failures of Thermoplastic Flex Piping.

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113 Also at fault were the facility owners. Manuf acturers insisted that the exteriors of their products were not designed to be in contact w ith petroleum for extended periods of time (e.g., beyond 72 hours). They implied that the initial de signs assumed pristine, well-maintained piping runs that were not subject to long-term exposur e to petroleum products. Failure to maintain these conditions was obviously a failure in pipi ng maintenance on the pa rt of the owners, though the requirement that these products be maintained in such a pristine environment is not stated on any known manufacturers sales literature. There are two areas of concer n associated with post-exposur e cleaning. Thermoplastics typically have a corrugated chase th at has the potential to retain li quids within the separate cells of the corrugation. Second, with th e coaxial style of pipe, there is a question of how to flush the Figure 4-17. Thermoplastic Piping Blowout.

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114 interstice of the product once expos ure has occurred. Furthermore, how can the cleanliness of the interstice for either type of pipe ever be verified? Fiber-reinforced pipe Fiber-reinforced pipe and fittings are manufactured from chemically inert thermosetting epoxy resins reinforced with hightensile-strength fiberglass filame nts. The pipe is produced by filament winding. The pipe incorporates a resin-ri ch inner liner that is resilient and holiday free and a resin-rich outer coating th at protects the resinglass bond of the structural wall from UV radiation during storage and in stallation. Fittings are manuf actured by filament winding or compression molding. Injection molding is not employed. Over the past three decades, fiber-reinforced pipe (FRP) has become the system of choice for an increasing number of applications. This growing acceptance is la rgely due to the proven performance of FRP and lower life cycle cost wh en compared to other piping systems. This lower life cycle cost is achiev ed through speed and ease of in stallation, reduced maintenance, and improved hydraulic considerations. Acceptance is well documented, since FRP is covered by American Society of Testing Materials (ASTM), American Society of Mechan ical Engineers (ASME), American Petroleum Institute (API), American Water Works Associ ation (AWWA), and others. However, if not installed correctly (i.e., use of incorrect back fill material) the pipe may suffer impact failure due to the brittle nature of the product. See Figure 418 below; this pipe failed due to impact from incorrect back fill. The performance of FRP is unmatched, consid ering the combined benefits of durability, strength, and corrosion resistance. The need for interior linings, exte rior coatings, and/or cathodic protection is eliminated for the vast majority of fluid-handli ng applications. FRP systems offer greater design flexibility through th e wide range of standard pipe diameters and

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115 fittings available, as well as th e inherent ability for custom fabrication to meet special needs. The pipe can be scratched from handling during shipment, and this can lead to abrasion damage. Below, Figure 4-19 illustrates shipping damage th at led to a failed vacuum test on the secondary wall. Many industries have the need to effectiv ely and efficiently conve y chemicals and related fluid materials. FRP is often the system of choice for its ability to handle corrosive materials. Figure 4-18. Fiber-Reinforced Pipe Failu re from Impact Damage. The main drawbacks to FRP are that the pipe is relatively brittle and can be cracked or scratched unknowingly if proper construction techniques are not caref ully followed. FRP secondary containment systems employ pipe one size larger than the primary and specially designed fittings. The system provides complete enclosure of U.L.and U.L.C.-listed primary piping used in product lines and vapor recovery lines from the sump at the product storage tank

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116 to the shear valve at the dispen ser and vent lines from the tan k. Features of FRP containment systems include: Filament-wound, fiberglass-reinforced pipe with integral liner. Compact fittings dimensions to minimize trench excavation. Smooth exterior pipe surface that eliminates the need for special end preparation tools. Ready accessibility to and complete inspect-abilit y of primary fittings prior to closure of the containment. Complete testability during insta llation and at any time thereafter. Rapid joint makeup with pop-rivet cl osure and ambient cure adhesive. Figure 4-19. Fiber-Reinforced Pipe with Score Damage.

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117 Figure 4-20 illustrates the severity of the material failure problem; the material failure category accounts for a larger-than-normal 38% cause of discharges. Puncture, loose components, and other mechanical damage are responsible for the re maining discharges. Because piping is double walled, the discharge should theoretically be contained within the interstice. But as we have seen, the secondary can sometimes fail at the same time as the primary, creating a reportable incide nt. That is a discharge into the containment sump or even the surrounding soil. Figure 4-20 illustrates the evaluation of piping as the source of discharge broken down by type of piping; double-walled flex-pipe accounts for a larger-than-normal 43% of the piping discharges when compared to th e other types. Most of the si ngle-walled fiberglass failures can be attributed to impact damage within a conc rete containment area or UV breakdown if the pipe is exposed to sunlight. FRP has a UV-resistant coating on the pipe, but it is intended only for temporary exposure to the sun. Many contract ors do not understand th is and often install fiberglass pipe within reach of sunlight. Storage Tank System Leak Autopsy Report Form The results of 941 storage tank leak autops y forms are diagrammed in Figure 4-21. There were as many as 38% of UST discharges shown to be invalid. A phenomenon known as vacuum migration could be responsible for many of the false positives. Vacuum migration occurs when the vacuum applied to the tank gradually dissipates from what are thought to be irregularities in the tank walls. In other words, pockets of higher and lower pressures form within the interstice and over time give a false drop in vacuum (or pre ssure). The solution to the problem is to be patient and let the vacuum level settle before brin ging the level up to testi ng conditions. Vacuum migration is a problem that is not very we ll understood among the environmental engineering community.

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118 Containment Sumps There are no standard state (let alone federal) requiremen ts for containment sumps. Florida has specific language requiring dispense r sumps or at least a method of sub-dispenser containment; but the typical piping sump is not a requirement. The facility just has to have a Double-Wall Fiberglass/Flex Single-Wall Fiberglass Other Single-Wall Single-Wall Protected Steel Double-Wall Flexpipe Double-Wall Fiberglass Category Double-Wall Fiberglass 8, 9.6% Double-Wall Flexpipe 36, 43.4% Single-Wall Protected Steel 11, 13.3% Other Single-Wall 3, 3.6% Single-Wall Fiberglass 24, 28.9% Double-Wall Fiberglass/Flex Combo 1, 1.2% 83 Discharges Figure 4-20. USTs Piping as the Source, Type of Piping. method of providing access to the piping intersti ce for monitoring. Granted, most new facilities have some form of sump, but many existing facilities have earthen or gravel pits beneath a traffic lid pits that serve as excellent conduits to groundwater. What do inspectors see when they look into a containment sump? There are facilities with discrete sumps and facilities with factorymated units. Factory-mated means that the sumps are heat welded to the tank shell or have a mating co llar as an integral part of the tank shell. The factory-mated units can be made of thermoset or thermoplastic materials. Again, the thermoset

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119 types are most likely to suffer from impact damage or contractor error. They do not appear to deteriorate from contact with pe troleum or deform from external ground or water-table pressures. Thermoplastic sumps have exhibited the following types of problems: Rippling, collapse, or inward m ovement of walls from external pressure (see Figure 4-22) Distortion of the floor from appare nt long-term exposure to petroleum Groundwater upwelling pressures or lack of backfill support, causing some of the floor distortion (more of a concern for the factory-mated type since it is typically the tanks secondary containment that is undergoing this deformation) Sump penetration boot failures Invalid AST Forms Invalid UST Discharges Valid UST Discharges Valid AST Discharges Category Valid AST Discharges 138, 14.7% UST Discharges 412, 43.8% Invalid UST Discharges 359, 38.2% Invalid AST Forms 31, 3.3% 941 Forms Figure 4-21. Leak Autopsy Forms. Discrete sumps have their share of contractor errors, especi ally by electrical contractors, who are not typically concerned w ith maintaining the liquid-tightness of sumps. These errors are all readily visible to the expe rienced and patient inspector du ring the installation oversight

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120 process. Thermoset sumps require foreknowledg e by the inspector of the correct angle of penetration of piping through the sump walls and the use of appr opriate penetration fittings. Thermoplastic sumps, especially older thin-w alled models, can deform in response to soil movement and/or shallow groundwater levels. As mentioned, bulgi ng of the walls is a readily noticeable event, along with cracking of structural features. In addition, th ere is the reaction of Figure 4-22. Rippling or Collapse of Sump Walls. the plastic to long-term exposure to petroleum, whether it is free pr oduct, petroleum contact water, or vapor. Manufacturers have failed to provide sufficient guidance on how these structures can be cleaned after exposure. Complica ting the issue is the designation of most of these sub-grade

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121 structures as confined-space entry points. An additional concern from the facility owners perspective is the waste disposal cost of flushing a secondary-cont ainment unit with water or an emulsifying agent. When thermoplastic sumps are damaged, there does not appear to be a manufacturers recommendation on how to repair them. Success of Release Detection Statistics Storage tank systems shall have a met hod, or combination of methods, of release detection that: Can detect a new release from any po rtion of the storage tank system. Is installed, calibrated, operated, and mainta ined in accordance with the manufacturers instruction, including routine main tenance and service checks for operability to ensure that the device is functi oning as designed. Meets the applicable performance standards in Rule 62761.640, F.A.C. All manufacturers instructions, as well as the performance claims and their manner of determination described in writing by the equipment manufacturer, shall be retained for as long as the storage tank system is used. A release detection response leve l shall be described in writing for each method or combination of methods of release detection used for a stor age tank system. A releas e detection method shall be established and provided for all storage tank sy stems upon installation. The release detection method or combination of methods used at a fac ility shall be performe d at least once a month, but not exceeding 35 days, to determine whether a release from the storage tank system has occurred. Figure 4-23 illustrates the relative success of these leak detection sensors. Findings from the FDEP Scoring Review In this sec tion, we will readdress the resear ch questions postulated at the end of the Literature Review and try to prove or disprove them. We will use the same techniques discussed in the Methodology chapter, only this time we will take a much broade r look at the state of

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122 Florida and evaluate the FDEP Scoring Review for contaminated f acilities. The Scoring Review is an important step in evaluating a facilitys el igibility for funding throu gh the IPTF trust fund. When evaluating various levels of enfor cement on a countywide basis, north-central Florida was selected at first to determine whet her there were any trends in the data. After completing the confidence intervals using the tinterval, the data were sorted based upon arithmetic mean as defined earlier. The results are shown in Figure 4-24. It is clear from the figure that more rural Detected Failed Unable or Unknown Category U nable or Unknown 29.0% Failed 32.0% Detected 39.0% Figure 4-23. Success of Leak Detection. counties such as Lafayette, Clay, Gilchrist, Bake r, Columbia, Bradford, etc., tend to score higher than more urban ones such as Orange, Brevard, Vo lusia, Duval, etc. A box plot (see Figure 426) shows that in the more urban areas, higher sc ores tend to be outliers when compared to rural counties.

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123 The individual value plot or scatter plot shows how a rural county such as Lafayette County can score so high with respect to the other counties. There are so few data points, only two discharges in ten years, that the mean is artific ially high with respect to the other counties and the confidence interval much wider. Since there are so few data points, a comparison of the median provides a better picture of any tr ends we are trying to detect. The side-by-side box plot reveals that the more urban counties tend to score lower than the rural counties as well, however, and a score that is considered a normal sc ore in a rural setting is usually an outlier in the urban setting. B r a d f o r d C o l u m b i a B a k e r G i l c h r i s t C l a y L a f a y e t t e H a m i l t o n L e v y D u v a l P u t n a m M a r i o n S t J o h n s A l a c h u a D i x i e V o l u s i a O r a n g e F l a g l e r B r e v a r d 80 70 60 50 40 30 20 10 Score95% CI for the Mean Figure 4-24. Interval Plot of Contam inated Facility Score When Ranked. Table 4-1 is a sample of the cleanup task information associated with each contaminated facility. The most important piece of information is the score, which is compared to a funding threshold to decide if money can be withdrawn from the IPTF trust fund to help pay for any cleanup. The score is also used to determine what, if any, fines, penalties, or suspensions will be handed down as a result of the di scharge. This is going to be the center of our focus when

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124 comparing the different county levels of enfo rcement that petroleum storage takes place in. By once again considering only north-central Florida, a look at all known petroleumcontaminated discharges not yet cleaned up s hows that the highly populat ed counties such as B r a d f o r d C o l u m b i a B a k e r G i l c h r i s t C l a y L a f a y e t t e H a m i l t o n L e v y D u v a l P u t n a m M a r i o n S t J o h n s A l a c h u a D i x i e V o l u s i a O r a n g e F l a g l e r B r e v a r d 120 100 80 60 40 20 0 Score Figure 4-25. Individual Valu e Plot of Score When Ranked. Duval, Orange, Brevard, Volusia, etc., have a higher number of discharges; in other words, discharges seem to increase with respect to th e population size of the co unty. Figure 4-25 breaks down the total number of discharges per county, a nd one can clearly see that highly dense urban areas pose the greatest risk of having a disc harge; whether it requires a cleanup funded by the IPTF trust fund will be answered later when we w ill look at the most contaminated facilities in the state. When taking a look at all storage facilities across north-central Florida, the relative storage capacity of each county seems to be a func tion of the number of discharges. Figure 4-27 is a bar chart illustrating the stor age capacity of each county in the north-central region; it almost

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125 parallels the bar chart above. As we have seen, however, the smaller, more rural counties with less storage capacity seem to score higher overall for the discharges that do occur. Next we are going to combine the variable total number of discharges and average score to see if there are any noticeable trends. Figure 4-37 shows the two variables plo tted on the same graph, and one can see that as the number of to tal discharges goes down, the aver age score of the discharge goes up. Figure 4-28 clearly shows that the fewer the number of discharges, the higher the score; while the greater the capacity, the lower the score. B r a d f o r d C o l u m b i a B a k e r G i l c h r i s t C l a y L a f a y e t t e H a m i l t o n L e v y D u v a l P u t n a m M a r i o n S t J o h n s A l a c h u a D i x i e V o l u s i a O r a n g e F l a g l e r B r e v a r d 120 100 80 60 40 20 0 Score Figure 4-26. Box Plot of Contamin ated Facilities Score When Ranked. Table 4-2 below is a sample of the contaminated facility list, complete with the discharge review score, the score when ranked (which we will further investigat e later), and the ranking. Figure 4-30 illustrates the trend of total storage ca pacity per county and average score. One can see that the arithmetic mean score tends to go up as capacity decreases. This is significant

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126 because it emphasizes the fact that in more poor ly enforced environmental protection areas, a higher discharge score can result. Table 4-1. Cleanup Task Information. District County Name County Facility ID Facility Status Facility Type Score SED PALM BEACH 50 8514427 OPEN A Retail Station 61 SED PALM BEACH 50 8514427 OPEN A Retail Station 61 SED PALM BEACH 50 8514427 OPEN A Retail Station 61 SED PALM BEACH 50 8514427 OPEN A Retail Station 61 SED PALM BEACH 50 8514432 CLOSED A Retail Station 30 SED PALM BEACH 50 8514432 CLOSED A Retail Station 30 SED PALM BEACH 50 8514433 OPEN A Retail Station 43 SED PALM BEACH 50 8514433 OPEN A Retail Station 43 SED PALM BEACH 50 8514434 OPEN A Retail Station 31 SED PALM BEACH 50 8514434 OPEN A Retail Station 31 SED PALM BEACH 50 8514434 OPEN A Retail Station 31 SED PALM BEACH 50 8514434 OPEN A Retail Station 31 SED PALM BEACH 50 8514435 OPEN A Retail Station 30 SED PALM BEACH 50 8514435 OPEN A Retail Station 30 SED PALM BEACH 50 8514435 OPEN A Retail Station 30 SED PALM BEACH 50 8514435 OPEN A Retail Station 30 SED PALM BEACH 50 8514436 OPEN A Retail Station 62 SED PALM BEACH 50 8514436 OPEN A Retail Station 62 SED PALM BEACH 50 8514436 OPEN A Retail Station 62 SED PALM BEACH 50 8514438 OPEN A Retail Station 75

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127 L a f a y e t t e G i l c h r i s t D i x i e F l a g l e r L e v y H a m i l t o n B a k e r B r a d f o r d C l a y C o l u m b i a P u t n a m S t J o h n s A l a c h u a M a r i o n V o l u s i a B r e v a r d O r a n g e D u v a l 1200 1000 800 600 400 200 0 CountyTotal Number of Discharges(Eligible and Ineligible) As of June 5, 2008 Figure 4-27. All Known Petroleum-Contam inated Discharges Not Yet Cleaned Up. Figure 4-31 shows the trend that as discharges per million gallons of storage capacity goes dramatically down, the average score remain s about the same. This means that as the number of incidents per storage capacity goes down, the score rema ins steady; therefore, smaller capacity counties tend to score the same as much larger counties with much better enforcement measures. Table 4-3 is a sample of the data that was used to re ach this conclusion. It contains the facility ID number, name, county, district, cleanup work stat us, score, and statewide ranking for cleanup priority. Figure 4-32 is a histogram of th e highest current score for contaminated facilities across the state of Florida. The funding threshold, as described earlier, is now set at 45, and one can see clearly from the figure why that might be the cas e. A much larger portion of the data falls below

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128 L a f a y e t t e D i x i e G i l c h r i s t H a m i l t o n B a k e r B r a d f o r d L e v y F l a g l e r P u t n a m C o l u m b i a C l a y S t J o h n s A l a c h u a M a r i o n V o l u s i a B r e v a r d D u v a l O r a n g e 18000000 16000000 14000000 12000000 10000000 8000000 6000000 4000000 2000000 0 CountyStorage (Gal) Figure 4-28. Storage Capacity in Gallons. 45, thereby limiting access to the trust fund to onl y those rare cases where a discharge scores above 45. The number of data points in the sample was 11,983, with the mean score being 28.87, well below the funding threshold. It is interesting to note th at the data appears from the histogram to follow a normal distribution; this w ill be proven when we look at the residual plot. Table 4-4 is a sample of the f acility score report that was used to compute the highest current score used in this analysis. The residual or probability plot (Figure 4-33) shows the relativ e closeness of the data to a normal distribution. The closer the plot is to a straight line, the mo re normal the data. As can be clearly seen from Figure 4-33, w ith a P-value of <0.005, the data used to compute the overall facility score is normally di stributed. The sample size is a healthy 13,667, well above the

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129 L a f a y e t t e G i l c h r i s t D i x i e F l a g l e r L e v y H a m i l t o n B a k e r B r a d f o r d C l a y C o l u m b i a P u t n a m S t J o h n s A l a c h u a M a r i o n V o l u s i a B r e v a r d O r a n g e D u v a l 1200 1000 800 600 400 200 0 CountyData Total Discharges Average Score Variable Figure 4-29. Line Plot of Total Numb er of Discharges and Average Score. minimum sample size for use of the t -distribution. The t -distribution was used to compute the confidence intervals in Minitab that were descri bed earlier. Figure 4-34 s hows that the statewide facility rankings also follow a normal distribution nearly as well as the facil itys current score. The plot seems to indicate that the facility ranking cannot go above 15,000 or below zero. With these two limitations, the plot of facility ranking trails away from the normal confidence interval only slightly with a sample size of 12,838 and a P-value of 0.005. Facility type is an important variable to be considered when review ing the data used in this study. The vast majority of discharges occur at retail stations as shown in Figure 4-35. The majority of the rest of the discha rges are considered to be at non -retail/fuel user sites. Local government, county government, agriculture, etc., make up the rest of the disc harges. In the next chapter, we will break the data down into more detailed categories based upon location and fuel

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130 tax rates, etc., to try to find any differences in level of funding, which leads to better enforcement and facility score. In this chapter, sources of contaminati on were quantified and compared to a normal distribution. Confidence intervals were computed, and box plots were drawn to try to find trends in the statewide database. Local trends were disc overed that indicated that some bias exists in the evaluation of discharges, depending on where or in what county the discharge occurs in. More rural counties tended to sc ore higher than more urban ones, with much fewer discharges. Regulated facilities within the state face unprecedented scrutiny. The industry is struggling to develop effective means and methods to properly contain di scharges and prevent contamination in the first place. The FDEP re view process involves assigning a contaminated facility a relative score that is used to determine eligibility fo r cleanup funding. This score, as shown by the preceding analysis, is highly dependent on the number of contaminated facilities within the county, th e relative number of discharges that occur within the county, and the storage capacity of the county in millions of gallons. The data analyzed appears to be normally distributed, which is understan dable since the data points we re based on a random sample.

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131 Table 4-2. Contaminated Facilities List. County Name Facility ID Facility Status Facility Type Score Score When Ranked Rank BREVARD 8500819 OPEN A Retail Station 77 12568 BREVARD 8500820 OPEN A Retail Station 58 12280 BREVARD 8500821 OPEN A Retail Station 88 12280 BREVARD 8500823 OPEN A Retail Station 4136 4370 BREVARD 8500826 OPEN A Retail Station 77 12568 BREVARD 8500828 OPEN A Retail Station 66 12937 BREVARD 8500829 OPEN A Retail Station 87 12568 BREVARD 8500833 OPEN A Retail Station 66 12937 BREVARD 8500838 OPEN A Retail Station 66 12937 BREVARD 8500842 CLOSED C Fuel user/Non-retail 77 12568 BREVARD 8500853 OPEN A Retail Station 76 12937 BREVARD 8500854 OPEN A Retail Station 515 14364 BREVARD 8500855 CLOSED A Retail Station 66 12937 BREVARD 8500856 CLOSED A Retail Station 78 12280 BREVARD 8500862 OPEN A Retail Station 69 11086 BREVARD 8500869 OPEN A Retail Station 78 12280 BREVARD 8500879 OPEN A Retail Station 78 12280 BREVARD 8500883 OPEN A Retail Station 65 14364 BREVARD 8500890 CLOSED A Retail Station 68 12280 BREVARD 8500903 CLOSED A Retail Station 66 12937 BREVARD 8500907 CLOSED A Retail Station 77 12568 BREVARD 8500908 CLOSED A Retail Station 4141 3987 BREVARD 8500919 OPEN A Retail Station 99 11086 BREVARD 8500923 OPEN A Retail Station 55 14364 BREVARD 8500924 OPEN A Retail Station 55 14364 BREVARD 8500925 OPEN A Retail Station 88 12280 BREVARD 8500933 CLOSED A Retail Station 7171 1109 BREVARD 8500934 CLOSED A Retail Station 266 12937 BREVARD 8500937 OPEN A Retail Station 66 12937 BREVARD 8500938 OPEN A Retail Station 5151 3014 BREVARD 8500945 CLOSED A Retail Station 66 12937 BREVARD 8500955 OPEN A Retail Station 68 12280 BREVARD 8500956 OPEN A Retail Station 66 12937

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132 L a f a y e t t e G i l c h r i s t D i x i e H a m i l t o n B r a d f o r d B a k e r L e v y F l a g l e r P u t n a m C o l u m b i a C l a y S t J o h n s A l a c h u a M a r i o n V o l u s i a B r e v a r d D u v a l O r a n g e 60 50 40 30 20 10 0 CountyData Capacity (Mgal) Average Score Variable Figure 4-30. Line Plot of Capacity in Million Gallons and Average Score. L a f a y e t t e F l a g l e r G i l c h r i s t M a r i o n C l a y S t J o h n s C o l u m b i a L e v y V o l u s i a B r e v a r d B a k e r O r a n g e A l a c h u a B r a d f o r d H a m i l t o n P u t n a m D i x i e D u v a l 90 80 70 60 50 40 30 20 10 CountyData Discharges per MGal Average Score Variable Figure 4-31. Line Plot of Discharges per Million Gallons and Average Score.

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133 Table 4-3. Contaminated Media Report. County Name Information Source Score Rank BREVARD E EDI 7 12568 BREVARD E EDI 5 12280 BREVARD D DISCHARGE NOTIFICATION 8 12280 BREVARD E EDI 8 12280 BREVARD E EDI 41 4370 BREVARD D DISCHARGE NOTIFICATION BREVARD E EDI BREVARD D DISCHARGE NOTIFICATION BREVARD E EDI 7 BREVARD E EDI 7 12568 BREVARD D DISCHARGE NOTIFICATION 6 12937 BREVARD E EDI 6 12937 BREVARD E EDI 6 12937 BREVARD D DISCHARGE NOTIFICATION 8 12568 BREVARD E EDI 8 12568 BREVARD E EDI 6 12937 BREVARD E EDI 6 12937 BREVARD D DISCHARGE NOTIFICATION 8 BREVARD D DISCHARGE NOTIFICATION 6 12937 BREVARD D DISCHARGE NOTIFICATION 6 12937 BREVARD D DISCHARGE NOTIFICATION 6 12937 BREVARD E EDI 6 12937 BREVARD A ABANDONED TANK RESTORATION 7 BREVARD A ABANDONED TANK RESTORATION 7 BREVARD Z OTHER 7 12568 BREVARD E EDI 7 12937 BREVARD D DISCHARGE NOTIFICATION 51 14364 BREVARD E EDI 6 12937 BREVARD E EDI 7 12280 BREVARD E EDI 6 11086 BREVARD E EDI 6 11086 BREVARD D DISCHARGE NOTIFICATION 7 12280 BREVARD D DISCHARGE NOTIFICATION 7 12280 BREVARD E EDI 7 12280 BREVARD D DISCHARGE NOTIFICATION 7 12280

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134 1089072543618 0 -18 3000 2500 2000 1500 1000 500 0 Highest Current ScoreFrequency Mean28.87 StDev21.34 N11983 Normal Figure 4-32. Histogram of Highest Current Score. Table 4-4. Facility Score Report. FACILITY_ID NAME ADDRESS1 CITY SCORE 8500001 7-ELEVEN FOOD STORE #16233 7627 NW 8TH AVE GAINESVILLE 30 8500002 GATE #1445 506 NW 13TH ST GAINESVILLE 10 8500003 7-ELEVEN FOOD STORE #10172 8307 NE 15TH ST GAINESVILLE 26 8500004 ODYSSEY (III) DP XVI LLC 3310 SW 35TH BLVD GAINESVILLE 30 8500005 TEXACO #100796 1206 W UNIV AVE GAINESVILLE 41 8500015 BP-EASTSIDE 1224 E UNIV AVE GAINESVILLE 32 8500016 AMOCO-NICKS 730 W UNIVERSITY AVE GAINESVILLE 35 8500017 SEAN EXPRESS 220 NW 39TH AVE GAINESVILLE 50 8500019 AMOCO STATION 3417 SW ARCHER RD GAINESVILLE 6 8500020 AMOCO #653 1550 NE WALDO RD GAINESVILLE 56 8500021 A & J BENEFIT CORP 1750 SW 13TH ST #400 GAINESVILLE 10 8500023 MOBIL #1314 CAMPUS 1255 W UNIVERSITY AVE GAINESVILLE 43 8500028 TEXACO #549MICANOPY 17107 CR 234 SE MICANOPY 55

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135 125100755025 0 -25-50 99.99 99 95 80 50 20 5 1 0.01 ScorePercent Mean28.99 StDev21.38 N13667 AD540.184 P-Value<0.005 Normal 95% CI Figure 4-33. Probability Plot of Overall Score Statewide. 2 5 0 0 0 2 0 0 0 0 1 5 0 0 0 1 0 0 0 0 5 0 0 0 0 5 0 0 0 1 0 0 0 0 99.99 99 95 80 50 20 5 1 0.01 RankPercent Mean7147 StDev4038 N12838 AD183.491 P-Value<0.005 Normal 95% CI Figure 4-34. Probability Plot of Statewide Overall Rankings.

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136 Z O t h e r R e g u l a t e d F a c i l i t y X C o n t a m i n a t i o n S i t e W W a t e r f r o n t F u e l S t o r a g e V M a r i n e / C o a s t a l F u e l S t o r a g e Q E m e r g e n c y R e s p o n s e S p i l l S i t e P U S T R e s i d e n t i a l ( U S T > 1 1 0 0 g a l s ) M A g r i c u l t u r a l J C o l l e c t i o n S t a t i o n I C o u n t y G o v e r n m e n t H L o c a l G o v e r n m e n t G S t a t e G o v e r n m e n t C F u e l u s e r / N o n r e t a i l B R e s i d e n t i a l A R e t a i l S t a t i o n 5 C o i n L a u n d r y 4 U n i f o r m L i n e n s e r v i c e 1 D r y c l e a n e r 8000 7000 6000 5000 4000 3000 2000 1000 0 Facility TypeCount Figure 4-35. Bar Chart of Discharges per Facility Type for Entire State of Florida.

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137 CHAPTER 5 DISCUSSION Regulation of underground storage tanks began in the early 1980s with the recognition that Floridas groundwater, which provides 90% of the states drinking water, 70% of the states industrial water, and 50% of its agricultural water needs, was at risk of becom ing contaminated. In 1982, petroleum contamination from a leak ing underground petroleum storage tank was documented in a well field for the city of Belle vue in Marion County. The legislative response to the problem was the passage of the Water Quality Assurance Act of 1983. The law provided for: Prohibition against pe troleum discharges. Required cleanup of petroleum discharges. State-mandated cleanup if not done expeditiously. Strict liability for pe troleum contamination. Required tank inspections and monitoring. The provisions of the 1983 act were implem ented by rule under the former Florida Department of Environmental Regulation (FDER) but by 1985, the situation made it clear that an incentive program was needed to accelerat e the assessment and cleanup process for petroleum-contaminated sites. The legislature co nsidered the alternatives and created the State Underground Petroleum Environmental Respons e Act of 1986. The fiscal analysis that accompanied the legislation in 1986 predicted as many as 2,000 contaminated sites throughout the state. As of January 2006, the total number of contaminated sites exceeded 23,102, of which 18,038 are eligible for state funding (Petrole um Contamination Cleanup and Discharge Prevention Programs 2008). The 1986 legislation also created the Inland Protection Trust Fund ( 376.3071, Florida Statutes) to pay for the exped ited cleanup of petroleum-contaminated sites. The Inland Protection Trust Fund (IPTF) is a non-lapsing, re volving trust fund with revenues generated from

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138 an excise tax per barrel of pe troleum products currently produced or imported into the state as defined in 206.9935, Florida Statutes. The amount of the excise tax coll ected per barrel is dependent upon the unobligated balance of the IPTF according to the formula: thirty cents if the balance is between $100 and $150 million; sixty cents if the unobligated balance is between $50 and $100 million; and eighty cents if the unoblig ated balance is less than $50 million. Risk-Based Corrective Action Legislation in 1996 required form alization of risk-based corre ctive action (RBCA) procedures at petroleum contamination sites. RB CA considers the actual risk to human health, public safety, and the environment in determinin g whether alternate cleanup strategies can be utilized to provide for more co st-effective cleanups. RBCA allo ws for using alternative cleanup target levels, institutional and e ngineering controls, and remediati on by natural attenuation in lieu of using conventional cleanup technologies on a case-by-case basis. These RBCA strategies allow the FDEP to make cleanup decisions that can reduce costs while protecting human health and the environment. RBCA concepts and strategies were folded into the FDEPs petroleum cleanup rule, Chapter 62-770, F.A.C., in 1997. What follows is a broad overview of the database s that formed the basis for the Analysis of Findings chapter. The data will be stratified based on total imposed tax (see Appendix D) and one particular county, Alachua County, will be comp ared with the rest of the state to determine whether there are differences among the score, highest score when ranked, and ranking. Each county charging the highest possible local option sa les tax will be sorted and compared to see where Alachua County fits in, because Alachua C ounty is one of the counties that levies the highest local option sales tax. Miami-Dade and Broward Counties will also be discussed because of their higher-than-average le vels of environmental enforcement.

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139 A General Overview of the Data Contained Wi thin the Contaminated Facilitie s List The vast majority of tanks considered in this analysis are in servic e. Figure 5-1 breaks down the current tank status statewide. Only a small percentage of the tanks scored during the FDEP review are out of service. An even smaller number still ar e unmaintained or are temporarily out of service. The primary substa nce discharged into the environment considered for review is unleaded gasoline, with gasoline oxygenated with ethanol being the next largest category; they are combined as illustrated in Figure 5-2. In Service Out of Service Other Category Other 0.9% Out of Service 4.3% In Service 94.9% Figure 5-1. Pie Char t of Tank Status. Tank substance is broken down in Figure 5-2. With the ever-i ncreasing demand for independence from foreign oil, more storage of et hanol E10 is anticipated in the future. Diesel fuel accounts for the second most stored substanc e in storage tanks statewide according to Figure 5-2, with lube oils and mineral acids following not far behind.

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140 Emerg Generator Diesel Unleaded Gas Vehicular Diesel Other Category Other 1071, 4.1% Vehicular Diesel 3832, 14.8% Unleaded Gas 19806, 76.7% Emerg Generator Diesel 1128, 4.4% Figure 5-2. Pie Chart of Substance. The most common storage tank size accordi ng to Figure 5-3 is approximately 10,000 gallons. This is understandable if one consider s the fact that the nor mal transport load of gasoline or diesel fuel is be tween 6,500 gallons and 8,200 gallons depending on the weight of the type of fuel being carried by the transport and weight limitations of the road. There is a 90% maximum fill capacity limit for stationary storage tanks. Most other storage capacities that are greater than 10,000 gallons are in locations with multiple tanks or terminals with field-erected aboveground storage tanks. These tanks, as disc ussed earlier, are more prone to catastrophic piping failure than a failure of the tank shell. There is a trend toward using singular multicompartmental tanks for tax and insurance reason s, because one single multi-compartmental tank is considered one tank by regulators. Therefore, more facilities are using one multicompartmental tank instead of the conventi onal tank farm of multiple smaller tanks.

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141 38500 33000 27500 22000 16500 11000 5500 0 12000 10000 8000 6000 4000 2000 0 GallonsFrequency Mean10198 StDev4555 N25786 Normal Figure 5-3. Histogram of St orage Capacity in Gallons. The histogram of discharge scor es compares the statewide discharge review score with a normal distribution (see Figure 5-4). The sample size for the histogram was 18,089 and the results show the data to be skewed toward the left or away from the funding threshold of 45. A slight gap can be detected at the current funding threshold of 45 with the mean clearly below that level at 34.00. The plot displays the relative probability that a particular scor e will be received by the owner or operator of the facility when a discharge occurs. As one can see from Figure 54, the relative probability of sc oring above the funding threshold is relatively small and getting smaller as the FDEP continues to raise it. Befo re the trust fund was fully funded, the score was set at 70, and that number dropped and conti nued to drop until it was 35 during the drinking water scares of the late 1980s and early 1990s, as discussed. The Abandoned Tank Restoration Program was one source of information for this study, as well as closure reports, discha rge notification forms, and the Early Detection Incentive (EDI)

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142 14412096724824 0 3000 2500 2000 1500 1000 500 0 Discharge ScoreFrequency Mean34.00 StDev23.37 N18089 Normal Figure 5-4. Histogram of Discharge Scores. programs. Other contributors of information to this report were PLIRP (insurance) data and emergency response reports. Figure 5-5 break s down how much each source of information contributed to the machine-readable database that was used to produce the graphical results contained in this and other chapters. In all cases, as expected, there were missing data and obvious outliers that could not be attributed to anything but ty pographical errors; however, this appears to be the exception rather than the rule since the P-value in all cases was <0.005. The large sample size used for this research contri buted greatly toward a strong P-value and narrow confidence intervals. Figure 5-6 is the relative elig ibility indicator for the state of Florida. The graph clearly shows that the major ity of contamination distributed throughout the stat e is eligible for state-funded cleanup, but whether the site scores high enough to qualify has been shown in this paper to be more problematic.

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143 A ABANDONED TANK REST. D DISCHARGE NOTIFICATION E EDI OtherCategory Other 14.5% E EDI 30.4% D DISCHARGE NOTIFICATION 42.0% A ABANDONED TANK RESTORATION 13.1% Figure 5-5. Pie Chart of Information Source. Figure 5-7 shows the cleanup work status for contaminated facilitie s across the state. As indicated by the pie chart, s lightly less than half of cleanups are comp lete; active and inactive cleanups compose the next larges t group. The histogram shown in Figure 5-8 is a comparison of the statewide contaminated faci lity rankings and a normal dist ribution. The statewide ranking does not appear to be normally distributed. This s eems reasonable since each facility is supposed to have its own unique facility ranking. This rank ing shows the relative position of each site in question with respect to one anothe r, in order of health threat priority. Fi gure 5-9 illustrates the probability of drinking water we lls being exposed to a discharge; out of 37,750 incidents, no drinking water wells were considered threatened from petroleum-related discharges 99.2% of the time. There were only 284 discharges in the st ate in which drinking wa ter wells were exposed. Figure 5-10 below breaks down the exposure of monitoring wells to contamination. As one can see, contamination of monitoring wells ha s occurred about one-third of the time, with

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144 E ELIGIBLE I INELIGIBLE Category I INELIGIBLE 15469, 41.0% E ELIGIBLE 22296, 59.0% Figure 5-6. Pie Chart of F unding Eligibility Indicator. cases of monitoring wells present and no contam ination of monitoring wells making up the rest of the distribution by approximately equal thir ds. Figure 5-11 breaks down the exposure of soil to contamination. Contaminated soils, as show n in the figure, make up the vast majority of exposure at the site to petroleum and petroleum -related spills. Exposure of surface waters, as illustrated in Figure 5-12, to discharges occurs much less often than exposure of soils. Exposure of surface waters to free product will net the owner at least a score of 60 on the FDEP Scoring Review. This result is significant because it wi ll trigger an automatic qualification for funds since the threshold is currently at 45. Even if the discharge is fully contained, a score of 60 will be imposed when there is free product anywhere at or above the lowe r explosive limit (LEL). The LEL, also called the flammable limit or explosive limit gives the proportion of combustible gases in a mixture, between which limits this mixture is flammable. The LEL describes the

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145 ACTIVE COMPLETED INACTIVE Other Category Other 979, 2.6% INACTIVE 8231, 21.8% COMPLETED 17322, 45.9% ACTIVE 11233, 29.7% Figure 5-7. Pie Chart of Cleanup Work Status. 15600 13000 10400 7800 52002600 0 -2600 4000 3000 2000 1000 0 RankFrequency Mean6868 StDev4046 N23490 Normal Figure 5-8. Histogram of Rank.

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146 0 Other Category Other 284, 0.8% 14911, 39.5% 0 22555, 59.7% Figure 5-9. Pie Chart of C ontaminated Drinking Wells. leanest mixture that is still flammable. Figur e 5-13 breaks down the exposure of contaminated groundwater to the discharge, wh ich is a much greater threat. According to Figure 5-14, the most common pollutant is unleaded gasoline. This is understandable considering the high demand for th e product and the role that human error plays in the handling and storage. Most of the sour ces of pollution illustrated in Figure 5-14 can be attributed to overfilling small gene rator tanks or agriculture farm fu el tanks, overflows of process oil storage tanks, etc., that are c onsidered incidental when compared to free product discharges at major terminals and bulk storage plants. Most of these incidental spills are cleaned up by the owner/operator of the storage tank. Since the qua ntity of the discharge is usually less than 25 gallons, a discharge report often is not filed. The contamination leve ls analyzed in this research

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147 N Y Category Y 14510, 38.4% N 10822, 28.7% 12433, 32.9% Figure 5-10. Pie Chart of C ontaminated Monitoring Wells. N Y Category Y 21240, 56.2% N 7012, 18.6% 9513, 25.2% Figure 5-11. Pie Chart of Contaminated Soil.

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148 apply mainly to discharges that are 25 gallons or more in quantity; discharges of 25 gallons or less in quantity are not generally required to be reported. Analysis of Differing Levels of Enforcemen t Based Upon Local Option Sales Tax Differing counties within the state opt for higher or lower local option sales tax on motor fuels. This section will analyze the corre lation between the local option sales tax and environmental enforcement and overall facility scor e, highest current score, and ranking within N Y Category Y 639, 1.7% N 24069, 63.7% 13057, 34.6% Figure 5-12. Pie Chart of Contaminated Surface Water. the state. Counties use the local option above the minimum tax to better fund infrastructure improvements, county programs, and often enfor cement of the very environmental laws that govern the facilities that generate the tax. A charge of $0.259 per gallon is collected at the terminal; part of this is for the Federal Highw ay Administration fund that finances the local

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149 Departments of Transportation, ro ads and bridges, etc., and is applied across th e board to all dealers and consumers, whether government or not Of this amount, $0.156 is for state taxes, the rest being federal taxes. N Y Category Y 16740, 44.3% N 10373, 27.5% 10652, 28.2% Figure 5-13. Pie Chart of Contaminated Ground Water. One county within the state, Franklin County, chose not to add any local taxes to their motor fuel sales. This county will serve as a re ference to compare the other counties that opt for a local sales tax on motor fuel. The local opt ion tax above the minimum is collected and remitted by the licensed wholesaler and term inal supplier upon each sale, delivery, or consignment to retail dealers, resellers, and end users. The minimum local option tax is collected by terminal suppliers at the point of removal thr ough the terminal loading r ack. There is a small collection allowance taken by wholesalers and terminal suppliers (currently $0.00333 for 2008).

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150 Other A LEADED GAS B UNLEADED GAS D VEHICULAR DIESEL L WASTE OIL M FUEL OIL P GENERIC GASOLINE Y UNKNOWN Z NON REGULATED Category Other 2209, 5.8% NON REGULATED 3500, 9.3% UNKNOWN 3946, 10.4% GAS 1410, 3.7% FUEL OIL 1823, 4.8% WASTE OIL 1727, 4.6% VEHICULAR DIESEL 5586, 14.8% UNLEADED GAS 12285, 32.5% LEADED GAS 3902, 10.3% 1377, 3.6% Figure 5-14. Pie Chart of Pollutant. Lee, Manatee, Martin, Okeechobee, Palm B each, Polk, St. Lucie, Sarasota, Suwannee, Volusia, Alachua, Broward, Charlotte, Citrus, Col lier, De Soto, Hardee, and Highlands Counties all opt to impose the maximum allowable total ta x. These counties will be considered as one group for the analysis that follows as those counties with $0.340 total mo tor fuel tax imposed. Miami-Dade County is the only county within the state that imposes a $0.320 total motor fuel tax. Miami-Dade County, along with Broward Count y, also enforces vapor recovery, which is an increase in environmental comp liance within the area. The rest of the 67 counties within the state impose either a $0.310, $0.290 or $0.280 total tax, depending on the 9th cent local additional option and the additiona l local option tax. These countie s will be looked at separately and categorized whether the count y opted for or against the 9th cent additional option. Figure 515 compares the confidence intervals of current sc ores within taxation groups; the counties with a higher local option sales tax tend to show that better enforcement leads to lower scores on the

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151 health threat priority lis t. Both the box plot and the interv al plot show that Miami-Dade County scores are significantly lower than the rest of th e state. This indicates that vapor recovery procedures during the loading and unloading of products seem to improve the chance of a lower score. The more rural Franklin County, which chooses not impose any local option tax, appears to score much higher than the rest of the state, with a much broader confid ence interval than the other counties. The box plot of facility current scores indica tes that within the counties that impose the highest local option tax, scores above about 80 are considered ou tliers. In Miami-Dade County, $0.259 $0.280 $0.290 $0.310 $0.320 $0.340 45 40 35 30 25 20 15 Current Score95% CI for the Mean Figure 5-15. Interval Plot of Current Score by Total Tax Imposed. scores as low as 60 are considered outliers. By cont rast in the rest of the state, scores of between 60 and 80 are considered normal maximums. The exception is Franklin County, where 60 is the upper quartile and the whisker does not reach 80. This box plot is significant because it shows that within counties that impos e a $0.340 total tax, the upper quartile is a score of 40, while the

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152 funding threshold is at 45 for 2008. That means that funding for a discharge at a facility within a county where the highest local option taxes are imposed is less likely than a county with a lower local option tax. The individual va lue plot (Figure 5-17) shows th e relative density of the data with respect to the total tax imposed. The highest score when ranked is usually the sc ore that is given when a discharge occurs and before cleanup. The results of the comparis on between current score and high score appear almost identical even though the hi ghest score is usually determined at the moment of discharge. The mean of the score when ranked for counties with $0.340 total tax imposed is lower than the rest of the state except for the $0.320 tota l tax category imposed by Miami-Dade County. Figure 5-18 breaks down the differences betw een the counties and their respective tax rates. The box plot shown in Figure 5-19 indicat es that the median score when ranked for the $0.259 $0.280 $0.290 $0.310 $0.320 $0.340 120 100 80 60 40 20 0 Current Score Figure 5-16. Box Plot of Curre nt Score by Total Tax Imposed.

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153 counties with the highest total tax imposed is much lower than the rest of the state and comparable to Miami-Dade County. The box plot (Figure 5-19) clearly indicates that outside the highe r taxation zones, facilities tend to score higher than those counties that have a lowe r tax rate, with rural Franklin County scoring even higher. Therefore, stronger enforcement measures tend to produce lower $0.259 $0.280 $0.290 $0.310 $0.320 $0.340 120 100 80 60 40 20 0 Current Score Figure 5-17. Individual Value Plot of Current Score by Total Tax Imposed. overall scores at the moment of discharge and at the point of cleanup than counties with lower levels of enforcement. The Early Detection In centive (EDI) program is probably responsible for this result; it encourages owners and operators of substantial harm facilities to be proactive in the prevention and early detection of discharges. M onthly inspections are requi red by state law. To what extent these inspections find potentia l problems depends upon how thoroughly they are

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154 $0.259 $0.280 $0.290 $0.310 $0.320 $0.340 50 45 40 35 30 25 20 15 Score When Ranked95% CI for the Mean Figure 5-18. Interval Plot of Score When Ranked by Total Tax Imposed. performed. Most environmentally conscious areas require that a trained inspector be present during the monthly inspection to make sure a ll aspects of the storag e system are thoroughly reviewed. The statewide ranking system attempts to list co ntaminated facilities within the state in a health threat priority order. Figure 5-20 break s down the statewide ranking confidence intervals based on total tax imposed. Counties with a higher total tax imposed tend to rank their facilities higher on a risk-based level than the rest of the state. MiamiDade County, with its $0.320 total imposed tax rate, ranks their violatio ns the highest in the state. Figures 5-21 through Figure 5-27 isolate the counties with the highest local option sales tax and compare the relative scores, score when ranked, and statewide ranking. Once again, the more rural counties tended to sc ore higher for a fewer number of di scharges than the more urban counties.

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155 $0.259 $0.280 $0.290 $0.310 $0.320 $0.340 120 100 80 60 40 20 0 Score When Ranked Figure 5-19. Box Plot of Score When Ranked by Total Tax Imposed. Alachua County tended to score right in the middle of coun ties that collect the same amount of tax per gallon. Martin, De Soto, Hardee, and Citrus Counties tended to score higher than Collier, Manatee, Lee, a nd Charlotte Counties. The box plot s indicate that these counties, which assess the highest local option sales tax on motor fuel, tended to score contaminated facilities right at or below the IPTF funding th reshold with an occasional outlier or maximum above it. In the next section, the more environmentally conservative Alachua County will be isolated and compared with the rest of the state. Alachua County Compared to the Rest of the State Alachua County is one of the m ost environmen tally conscious counties within the state. The local authorities have been consistently on the cutting edge of environmental enforcement

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156 $0.259 $0.280 $0.290 $0.310 $0.320 $0.340 8000 7000 6000 5000 4000 Ranking95% CI for the Mean Figure 5-20. Interval Plot of St atewide Ranking by Total Tax Imposed. and regulations. Inspectors take an active role in cooperating with facility owners and attempt to educate the industry with respect to the types of problems th at have been experienced throughout the state. Alachua County has imposed the highes t local sales tax on motor fuel allowable in the state as well. Figure 5-28 breaks down the clean up work status of facilities within the county. The vast majority of discharges within Alachua County are at retail servic e stations, according to Figure 5-29. Figure 5-30 compares Alachua County to the rest of the state with re spect to facilities current scores. Alachua County scor es contaminated facilities at a higher score than the rest of the state but below the funding th reshold of 45 with a 95% conf idence interval. In Alachua County, when discharges do occur according to Figure 5-31, the m ean score is 28.5 as compared

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157 C h a r l o t t e M a n a t e e L e e C o l l i e r B r o w a r d O k e e c h o b e e V o l u s i a S t L u c i e S u w a n n e e A l a c h u a P a l m B e a c h H i g h l a n d s P o l k S a r a s o t a C i t r u s H a r d e e D e s o t o M a r t i n 50 40 30 20 10 Score95% CI for the Mean Figure 5-21. Interval Plot of Current Sc ore of Counties With $0.34 Total Tax Imposed. C h a r l o t t e M a n a t e e L e e C o l l i e r B r o w a r d O k e e c h o b e e V o l u s i a S t L u c i e S u w a n n e e A l a c h u a P a l m B e a c h H i g h l a n d s P o l k S a r a s o t a C i t r u s H a r d e e D e s o t o M a r t i n 100 80 60 40 20 0 Score Figure 5-22. Box Plot of Current Scores of Counties With $0.34 Total Tax Imposed.

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158 C h a r l o t t e M a n a t e e L e e C o l l i e r B r o w a r d O k e e c h o b e e V o l u s i a S t L u c i e S u w a n n e e A l a c h u a P a l m B e a c h H i g h l a n d s P o l k S a r a s o t a C i t r u s H a r d e e D e s o t o M a r t i n 100 80 60 40 20 0 Current Score Figure 5-23. Individual Valu e Plot of Current Score for Counties With $0.340 Total Tax. C h a r l o t t e M a n a t e e L e e C o l l i e r B r o w a r d O k e e c h o b e e V o l u s i a A l a c h u a P a l m B e a c h H i g h l a n d s S u w a n n e e H a r d e e P o l k S a r a s o t a C i t r u s D e s o t o M a r t i n 50 40 30 20 10 Score When Ranked95% CI for the Mean Figure 5-24. Interval Plot of Score When Ranked With $0.34 Total Tax Imposed.

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159 C h a r l o t t e M a n a t e e L e e C o l l i e r B r o w a r d O k e e c h o b e e V o l u s i a A l a c h u a P a l m B e a c h H i g h l a n d s S u w a n n e e H a r d e e P o l k S a r a s o t a C i t r u s D e s o t o M a r t i n 120 100 80 60 40 20 0 Score When Ranked Figure 5-25. Box Plot of Score When Ra nked of Counties With $0.34 Total Tax Imposed. D e s o t o M a r t i n C i t r u s S a r a s o t a H i g h l a n d s H a r d e e P o l k P a l m B e a c h S u w a n n e e B r o w a r d A l a c h u a O k e e c h o b e e S t L u c i e C o l l i e r V o l u s i a M a n a t e e L e e C h a r l o t t e 12000 11000 10000 9000 8000 7000 6000 5000 4000 3000 Rank95% CI for the Mean Figure 5-26. Interval Plot of Rank of Counties With $0.34 Total Tax Imposed.

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160 D e s o t o M a r t i n C i t r u s S a r a s o t a H i g h l a n d s H a r d e e P o l k P a l m B e a c h S u w a n n e e B r o w a r d A l a c h u a O k e e c h o b e e S t L u c i e C o l l i e r V o l u s i a M a n a t e e L e e C h a r l o t t e 16000 14000 12000 10000 8000 6000 4000 2000 0 Rank Figure 5-27. Box Plot of Rank of Counties With $0.34 Total Tax Imposed. to the statewide mean of 27.0. The box plot of Figur e 5-32 indicates that scor es that occur within the normal maximum are outliers for the rest of the state, even though there is very little difference between the current scor e and the current score for the en tire state of Florida. The score when ranked is significantly different for Alac hua County compared to the rest of the state. Figure 5-33 diagrams the current score for Alachua County and the rest of the state of Florida; apart from the outliers, a score within Alachua Count y is more likely to be an outlier in any other location within the state of Florida. Figure 5-34 lists all counties with more contam inated facilities than Alachua County. The results are interesting due to the fact that a score in Alachua County often times is an outlier for the rest of the state. The significance of this result is that within the more environmentally

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161 ACTIVE COMBINED COMPLETED INACTIVE Category INACTIVE 86, 28.5% COMPLETED 90, 29.8% COMBINED 8, 2.6% ACTIVE 118, 39.1% Figure 5-28. Pie Chart of Cleanup Wo rk Status within Alachua County. Retail Station Fuel User/Non-Retail State Government County Government Contamination Site Other Category Other 9, 3.9% Contamination Site 10, 4.4% County 6, 2.6% State 6, 2.6% Non-Retail 67, 29.4% Retail Station 130, 57.0% Figure 5-29. Discharges per Faci lity Type in Alachua County.

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162 sensitive county of Alachua, a violation is more likely to score higher and rank higher than the rest of the state but score below the funding threshold. The score when ranked, which is determined at the moment of discharge, is not iceably higher in Alachua County (as indicated in Figure 5-31) than the average for the rest of the st ate. The local FDEP representative attributed the difference in the score when ranked to the greater risk of potable wa ter wells being exposed to discharges in Alachua County than elsewhere. As indicated by the following figures, the score given at the moment of discharge tends to be higher in Alachua County than the re st of the state. The box plots indicate that one is more likely to receive funding when the discharge occurs outside Alachua County. Out of the 67 counties, Figure 5-34 clearly indicates that only 16 counties are cons idered to be more contaminated than Alachua County. This result is interesting because Alachua County does not have the industrial base that the other counties have, such as bulk terminals, refineries, or blending plants. Miami-Dade County, from the fi gure, is by far the most contaminated county within the state. But what is considered contamination in Miami-Dade County may not necessarily be considered contamination in the rest of the state because of the local vapor recovery ordinance. The box plot of Figure 5-35 is interesting due to the fact that with so many discharges that occur in the most contaminated counties, they tend to score above the funding threshold. These are indicated by the high number of outliers that exist within the data set. It is also interesting to note how Alachua County tends to score these cont aminated facilities; in essence, the upper quartile is below 45, the funding threshold.

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163 State of Florida Alachua County 33 32 31 30 29 28 Current Score95% CI for the Mean Figure 5-30. Alachua County Compared to the Rest of the Stat e (Current Score). The more data points within the county, th e narrower the 95% conf idence interval. Therefore, the more contaminated counties reveal themselves in the preceding interval plots as narrow points. More rural counties with fewer contaminated facilities manifest themselves at broader confidence intervals in order to include th e relative uncertainty that exists when there are fewer data. The individual value plots show the raw data and its comparative density with respect to one another. The box plots and their corresponding representation of outliers show the data in ways that help one understand the probability of receiv ing a certain score. These graphical techniques have been used to show trends and explain the findings of this research. Some interesting anomalies were found. This was expected because of the broad differences that exist among differing levels of enfo rcement across the state. A direct correlation was established between the total tax imposed with in a particular county and the relative score received by the cont aminated facility.

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164 State of Florida Alachua County 32 31 30 29 28 27 26 25 Score When Ranked95% CI for the Mean Figure 5-31. Interval Plot of Alachua County Compared to the State (Score When Ranked). State of Florida Alachua County 120 100 80 60 40 20 0 Score When Ranked Figure 5-32. Box Plot of Al achua County Compared to the State (Score When Ranked).

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165 State of Florida Alachua County 120 100 80 60 40 20 0 Current Score Figure 5-33. Box Plot of Alachua County Compared to the Stat e (Current Score). M I A M I D A D E H I L L S B O R O U G H P I N E L L A S D U V A L O R A N G E B R O W A R D P A L M B E A C H P O L K B R E V A R D L E E V O L U S I A E S C A M B I A B A Y M A N A T E E L E O N S A R A S O T A A L A C H U A 1600 1400 1200 1000 800 600 400 200 0 County NameCountCounties With More Contaminated Facilities Than Alachua County Figure 5-34. Total Number of Contaminated Facilities by County.

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166 A l a c h u a B a y S a r a s o t a P o l k P i n e l l a s M a n a t e e H i l l s b o r o u g h P a l m B e a c h M i a m i D a d e B r o w a r d L e e L e o n E s c a m b i a D u v a l V o l u s i a O r a n g e B r e v a r d 100 80 60 40 20 0 Score Figure 5-35. Scores of Counties with More Contaminated Facilities than Alachua County. B r e v a r d M a n a t e e P i n e l l a s M i a m i D a d e L e e B a y H i l l s b o r o u g h B r o w a r d O r a n g e V o l u s i a A l a c h u a P a l m B e a c h E s c a m b i a P o l k S a r a s o t a L e o n D u v a l 45 40 35 30 25 20 15 10 Score95% CI for the Mean Figure 5-36. Interval Plot of Counties w ith More Contamination than Alachua County.

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167 B r e v a r d M a n a t e e P i n e l l a s M i a m i D a d e L e e B a y H i l l s b o r o u g h B r o w a r d O r a n g e V o l u s i a A l a c h u a P a l m B e a c h E s c a m b i a P o l k S a r a s o t a L e o n D u v a l 100 80 60 40 20 0 Score Figure 5-37. Box Plot of Scores of Counties with More Contamination than Alachua County. Reimbursement First Come First Served The Petroleum Cleanup Funding Cap Encumbrance to Date Report is offered to the public as a database to assist in determining the to tal amounts encumbered from the Inland Protection Trust Fund for FDEP registered facilities with one or more eligible discharges. The report is based solely on data availabl e in several current and form er Petroleum Cleanup Program databases. These databases include: Reimburseme nt First Come First Served (FCFS); State Cleanup Super Act Site Management (SPASM & LPSPASM); Cleanup Utility Bill Tracking; NPDES Permit Fee Tracking; and Storage Ta nk and Petroleum Contamination/Cleanup Monitoring (STCM) for Preapproval Work Orde rs, Task Assignments and Change Orders. Note these data have not been 100% verified and may contain errors and omissions and should not be used for official pu rposes without complete file revi ew and database reconciliation. These data exclude costs encumbered in associat ion with the Limited Source Removal Initiative

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168 in conjunction with an early underg round storage tank upgrade pursuant to 376.3071(5)(C) 2, F.S., which are not counted toward the eligib ility funding cap. The total encumbrance amounts are at the facility level only and not associated with a particular discharg e. While many of the facilities have co-mingled contamination addres sed concurrently in the same area for which combining multiple funding caps is appropriate, there are also a number of sites where the appropriate allocation of costs among multiple discha rges can only be determined after a detailed file review. Figure 5-38 shows an interval plot of reimbursement (FCFS) for the North Central Florida area. It appears that locally funds have been made availabl e in approximat ely one hundred thousand dollar increments. In the figure, no single county appears to receive more appropriations than the other on the First Come First Serve basis. L a f a y e t t e G i l c h r i s t D i x i e F l a g l e r L e v y H a m i l t o n B a k e r B r a d f o r d C l a y C o l u m b i a P u t n a m S t J o h n s A l a c h u a M a r i o n V o l u s i a B r e v a r d O r a n g e D u v a l $400,000.00 $300,000.00 $200,000.00 $100,000.00 $0.00 ($100,000.00) 95% CI for the Mean Figure 5-38. Interval Plot of Reim bursement First Come First Served.

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169 Figure 5-39 shows that Duval County received a maximum one-time FCFS payment of two million dollars more than tw ice the amount of any other county in the region. This can be partially explained by the fact that Duval County is heavily industrialized and located on an inner-coastal waterway. It is interesting that Duval County te nds to score higher than most other counties in the state as well. Figure 5-40 shows an individual value plot of reimbursement (FCFS) for the North Central Florida area. The box plot and the individual value plot clearl y show that most discharges require only a minimum amount of reimbursement in other words, ordinary manpower and equipment is all that is required to clean up the spill. Figure 5-41 and Figure 5-42 show a breakdown of the total amount of reimbursement received by each county from the IPTF trust fund and the relative percentages of each. L a f a y e t t e G i l c h r i s t D i x i e F l a g l e r L e v y H a m i l t o n B a k e r B r a d f o r d C l a y C o l u m b i a P u t n a m S t J o h n s A l a c h u a M a r i o n V o l u s i a B r e v a r d O r a n g e D u v a l $2,000,000.00 $1,500,000.00 $1,000,000.00 $500,000.00 $0.00 Figure 5-39. Box Plot Comparing Reim bursement First Come First Served.

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170 L a f a y e t t e G i l c h r i s t D i x i e F l a g l e r L e v y H a m i l t o n B a k e r B r a d f o r d C l a y C o l u m b i a P u t n a m S t J o h n s A l a c h u a M a r i o n V o l u s i a B r e v a r d O r a n g e D u v a l $2,000,000.00 $1,500,000.00 $1,000,000.00 $500,000.00 $0.00 Figure 5-40. Individual Va lue Plot of Reimbursement First Come First Served. Duval Orange Brevard Volusia Marion Alachua Columbia Other Category Other $28,857,277.98, 11.4% Columbia $9,998,786.21, 3.9% Alachua $21,996,420.53, 8.7% Marion $20,543,733.44, 8.1% Volusia $25,487,980.78, 10.0% Brevard $28,518,549.18, 11.2% Orange $55,195,141.99, 21.7% Duval $63,232,960.67, 24.9% Figure 5-41. Pie Chart of Reimburse ment First Come First Served.

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171 L a f a y e t t e G i l c h r i s t D i x i e F l a g l e r L e v y H a m i l t o n B a k e r B r a d f o r d C l a y C o l u m b i a P u t n a m S t J o h n s A l a c h u a M a r i o n V o l u s i a B r e v a r d O r a n g e D u v a l $70,000,000.00 $60,000,000.00 $50,000,000.00 $40,000,000.00 $30,000,000.00 $20,000,000.00 $10,000,000.00 $0.00 County Figure 5-42. Bar Chart of Reimburse ment First Come First Served. Total Encumbrance to Date Total Encumbrance to Date is broken out for North Central Florida in Figure 5-43. It is obvious from the bar chart that Duval County an d Orange County have encum bered the State more than any other county in that region. Looking at Figure 5-44, the total amount encumbered listed by the most contaminated counties within the state, Miami-Dade, Duval, Polk, and Hillsborough counties are by far and away the most heavily encumbered within the state. The total amount encumbered for those counties is between 150 million and 200 million dollars. This dollar figure represents how much money has be en withdrawn from the IPTF trust fund by the most frequent offenders. Alachua County is listed as having receive d over 50 million dollars in trust fund money since the program was reorganized as the Preapproval Program. Relative score and ranking determine which counties receive compensation from the trust f und, since most discharges in

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172 Alachua County occur within mile of the potable well for the City of Gainesville, cleanups in this county are more likely to receive compensa tion. Referring again to the most contaminated counties within the state, those Counties such as Miami-Dade, Duval, H illsborough, etc, threaten inner coastal waterways with th e possibility of having free produc t on the surface of the water. This explains, in part why thos e counties are reimbursed by the trus t fund more than the others. Also, the more contaminated counties are heavily industrialized and ther efore store and process more oil related products than any other area with the state. Therefor e the possibility of a discharge and the severity of that discharge tend to be somewhat hi gher in those counties. The total amount encumbered for the more ru ral counties is minisc ule compared to the urban ones. Lafayette County only encumbered around $500 dollars from th e trust fund since its reorganization. Levy, Flagler, Dixie, and Gilchr ist counties also encumbered very small amounts of money from the trus t fund, even though discharges in thes e counties threaten impoundments. L a f a y e t t e G i l c h r i s t D i x i e F l a g l e r L e v y H a m i l t o n B a k e r B r a d f o r d C l a y C o l u m b i a P u t n a m S t J o h n s A l a c h u a M a r i o n V o l u s i a B r e v a r d O r a n g e D u v a l $200,000,000.00 $150,000,000.00 $100,000,000.00 $50,000,000.00 $0.00 County Figure 5-43. Total Encumbrance to Date.

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173 M a n a t e e B a y L e e S a r a s o t a V o l u s i a B r e v a r d A l a c h u a L e o n P i n e l l a s E s c a m b i a P a l m B e a c h O r a n g e P o l k H i l l s b o r o u g h B r o w a r d D u v a l M i a m i D a d e $200,000,000.00 $150,000,000.00 $100,000,000.00 $50,000,000.00 $0.00 County Figure 5-44. Total Amount Encumbered. Current Work Orders/Task Assignments Current work orders and task assignm ents represents the latest ongoing cleanup operations funded by the IPTF. Once again the more ur ban counties show an increased level of reimbursement for current work orders. Figure 5-45 illustrates the magnitude of the difference between the costs of discharges that occur in urban areas along the coas t and discharges that occur in the more rural areas of the State. Figure 5-46 breaks down the current expenditures for the most contaminated counties within the state. It is obvious from the figure that once again the cost associated with petroleum related cleanups occurs mainly in the areas of the state that contain the more industrialized ar eas. Figure 5-47 breaks down the current total work orders by county and the respective percentage of each, a nd once again, the most contaminated counties within the state consume the la rgest portion of the trust fund

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174 Figure 5-48, the interval plot of work orders /task assignments, indicates which of the most contaminated counties in the State of Florida have the most active reimbursement contracts. It is surprising that Leon County leads the way in current or active reimbursement contracts, with Polk, Palm Beach, and Alachua County following close behind. Tallahassee/Leon County has the highest level of current funding, Even though Miami-Dade, Hillsborough, and Orange County are major metropolitan areas that meet the over the water criterion a nd transfer oil to and from offshore vessels. The significance of these figures is that the significant and substantial harm facilities tend to receive more IPTF funding than the substantia l harm facilities. This is understandable when you consider the fact that discharg es at those facilities deemed significant pose a greater risk than those discharges that occur at ordinary facilities. The importance of an ef fective cleanup is more important in those counties th an the rest of the State. L a f a y e t t e G i l c h r i s t D i x i e F l a g l e r L e v y H a m i l t o n B a k e r B r a d f o r d C l a y C o l u m b i a P u t n a m S t J o h n s A l a c h u a M a r i o n V o l u s i a B r e v a r d O r a n g e D u v a l $120,000,000.00 $100,000,000.00 $80,000,000.00 $60,000,000.00 $40,000,000.00 $20,000,000.00 $0.00 County Figure 5-45. Work Orders.

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175 M a n a t e e L e e B r e v a r d B a y P i n e l l a s V o l u s i a M i a m i D a d e S a r a s o t a A l a c h u a P a l m B e a c h L e o n E s c a m b i a O r a n g e B r o w a r d H i l l s b o r o u g h P o l k D u v a l $120,000,000.00 $100,000,000.00 $80,000,000.00 $60,000,000.00 $40,000,000.00 $20,000,000.00 $0.00 County Figure 5-46. Total Current Work Orders. Brevard Lee Other Duval Polk Hillsborough Broward Orange Palm Beach Miami-Dade Volusia Pinellas Category Other $94,113,895.58, 12.4% Lee $27,125,113.41, 3.6% Brevard $28,518,549.18, 3.8% Pinellas $54,475,159.45, 7.2% Volusia $25,487,980.78, 3.4% Miami-Dade $155,391,013.09, 20.5% Palm Beach $43,601,624.33, 5.8% Orange $55,195,141.99, 7.3% Broward $90,221,333.31, 11.9% Hillsborough $77,390,393.55, 10.2% Polk $42,205,896.16, 5.6% Duval $63,232,960.67, 8.4% Figure 5-47. Pie Chart of Total Current Work Orders.

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176 B r e v a r d M a n a t e e P i n e l l a s M i a m i D a d e L e e B a y H i l l s b o r o u g h B r o w a r d O r a n g e V o l u s i a A l a c h u a P a l m B e a c h E s c a m b i a P o l k S a r a s o t a L e o n D u v a l $300,000.00 $250,000.00 $200,000.00 $150,000.00 $100,000.00 $50,000.00 $0.00 95% CI for the Mean Figure 5-48. Interval Plot of Work Orders/Task Assignments.

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177 CHAPTER 6 CONCLUSIONS Sm all discharges of oil that reach the environment can cause significant harm. Sensitive environments, such as areas with diverse and/or protected flora and fauna, are vulnerable to even small spills. The EPA noted in the Federal Register 2002, Small spills of petroleum and vegetable oils or animal fats can cause significa nt environmental damage. Real-world examples of oil spills demonstrate that spills of petroleu m oils and vegetable oils or animal fats do occur and produce deleterious environmenta l effects. In some cases, sma ll spills of vegetable oils can produce more environmental harm than numerous la rge spills of petroleu m oils (62 FR 54508). The EPA, when describing the outcome of one sm all spill of 400 gallons of rapeseed oil into Vancouver Harbor, noted that . 88 oiled birds of 14 species were recovered after the spill, and half of them were dead. Oiled birds usually are not recovered for three days after a spill, when they become weakened enough to be captured. The number of such casualties from oil spills is usually higher than the number of birds recove red, because heavily oiled birds sink, and dying or dead birds are captured quickly by raptors and scavengers (62 FR 54525). A small discharge may also cause harm to human health or life through threat of fire or expl osion, or shortor longterm exposure to toxic components. The Clean Water Act (33 USCA 2001) makes it unlawful for any person to discharge any pollutant unless a permit for such a discharge is issued under the act itself. The EPAs general permit does not apply in states th at have opted to administer th e permit process on their own, but the federal requirements constitute the minimu m requirements of such state-administered programs. Oil spills occur despite prevention effort s. They vary in size from just a few hundred gallons to millions of gallons. Preparing a timely and coordinated response to such an

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178 emergency of undefined magnitude that can happen anywhere, at any time, and in any kind of weather is an enormous challenge that requires significant planning and training. The environmental and economic effects of o il spills can best be avoided by preventing and containing them in the first place. For more than two decades, the EPAs Spill Prevention, Control, and Countermeasures program has wo rked at several hundred thousand oil storage facilities, preventing discharges of all kinds of oil into the waters of the United States. The EPAs approach to preventing oil spills combines planning and enforcement measures. Comparison of Facility Discharge Scores In this sec tion, the principal research questions that were asked in th e literature review will be addressed and the results evaluated. It is clear from the preceding analysis that a discharge score varies with location within the state. To determ ine how and why it is different and to what extent those differences can be attributed to stronger local en forcement and cooperation by local officials was the primary goal of this paper. Many differences can be attributed to the proximity of drinking water wells and surface waters to the discharge as well as varying levels of local motor fuel tax. Since discharges continue to occur across the state, there was a large body of data from which to compare and contrast. Each analysis performed exceeded the minimum sample size as determined by re quirements of the t-distribution. Discovery of a discharge usually means the observance or detection of free product in boreholes, wells, open drainage ditches, open excavations or trenches, or on nearby surface water, or petroleum or petroleum products in excess of 0.01 foot in th ickness in sewer lines, subsurface utility conduits, or vaults, unless the product has been removed and it was confirmed that a release into the environment did not occur. Observance means visually stained soil or odor or petroleum products resulting from a discharge of used oil equa l to or exceeding 25 gallons on a pervious surface.

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179 The results of the analysis do not apply to any discharge of petroleum or petroleum products of less than 25 gallons onto a pervious surface, as long as the discharge is removed and properly treated or disposed, or otherwise remediated, so th at no contamination from the discharge remains on-site. The analysis also did not consider liquefied petroleum gas and American Society for Testing and Materials grades no. 5 and no. 6 residual oils, bunker C residual oils, intermediate fuel oil with a vi scosity of 30 and higher used for marine bunkering, asphalt oils, and petroc hemical feed stocks. Are there any correlations within the result s of the FDEP Scoring Review database? It is understandable that the score a facility receives when a discharge occurs depends upon the local jurisdiction. It appears that the more rural a county in which the discharge occurs, the higher the health risk priority cleanup score. Agricultural-related discharges that threaten impoundments, or waters stored for crop irrigation, score a mini mum of 60 points. This is significant because although rural counties have fa r less storage capacity and a much lower total number of discharges, the problems that do occu r tend to score above the funding threshold of 45 initially. Indeed, this is the intent of the scoring review: to protect the surface waters and impoundments from the effects of a discharge. The ability of local governments to have wate rways declared an Outstanding Florida Water can lead to an increased score on the review. The proximity to aqui fers can also have the effect of increasing the relative discha rge score. However, the highest scores are achieved when there is ignitable free product on a surface water or wate rshed. This usually takes place in industrial areas that load and unload from tanker ship s or store large quan tities of oil.

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180 Are the results of a review depende nt upon location within the state? The structure of the scoring review emphasizes the importance of protecting surface waters and agricultural retention ponds fr om the effects of free product fl oating on the surface. This situation will score an automatic 60 points and trigger an automatic release of funds from the IPTF. Counties that have shorel ines, have extensive agricultural development, or are located on top of one of three designated aquifers will usually score higher per discharge because of their relative proximity to these geographic features. The review goes one step further and tallies the exposure of drinking water wells exposed to the discharge. Therefore, counties with a higher number of private potable wells will also score higher on the review. The relative closenes s of the discharge to municipal water wells also can have a dramatic effect on the discharge score. This can be seen when reviewing discharges in Alachua County. Discharges th at occur there tend to score hi gher because of the exposure to the aquifer and munici pal water supplies. Upon discovery of contamination (unless the co ntamination is the result of a previously reported discharge for which site rehabilitation has not been completed or the contamination is known to be from a non-petroleum product source) or upon a discharge of petroleum or petroleum products no matter where it is locate d, notification shall be submitted using the Discharge Report Form (Form Number 62-761.900(1)). If the discharge was from a storage tank system regulated pursuant to Chapter 62-761 or 62-762, Florida Administrative Codes, the discharge shall be reported by the facility owner or operato r pursuant to the applicable requirements of Chapters 62-761 and 62-762. For all other discharges of pe troleum or petroleum products, th e discharge shall be reported within one week of discovery; however, discha rges of reportable quantities onto the surface

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181 lands or into surface waters shall be reported to the State Warning Point or Department of Environmental Protection, Bureau of Emergency Response as soon as possi ble but no later than 24 hours after occurrence. The discharge shall be reported by the discharger or the owner or operator if the discharger is unknown or if the discovery was the result of a previously unre ported discharge. Because of this, there should be no variation between when the discharge occu rs and the time it is reported. However, where the discharge occurs appears to have a dramatic effect on the facility score, particularly the relative closenes s of the discharge to a potable we ll, watershed, or surface water. The total number of wells exposed to the discharge has an additive effect; the more wells that are exposed, the higher the score. What role does the local option sales tax play on a contaminated facil itys discovery and/or cleanup enforcement funding? It appears from the previous analysis and di scussion that counties that adopt the highest local option sales tax produce lowe r overall scores per discharge than counties that have lower sales taxes. This is interesting since most counties fund their respective Departments of Environmental Protection through th e local option. In the case of Alachua County, this increased level of funding has led to a stronger environmen tal partnership between industry and the local authorities. Problems in the fiel d are more likely to be handled using alternative measures than the traditional state-funded cleanup. Counties that have adequate local environmen tal enforcement usually inspect each facility with a representative of the owner on a monthly basis. Any problems that may exist are well documented and repairs are made. Therefore, most discharges that occur within these areas of stronger local enforcement are results of human e rror and can still be qu ite severe. That may explain the numerous outliers th at exist within the areas of stronger local enforcement.

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182 Which counties rank highest in level of cont amination and environmental exposure risk? Why? The counties that rank highest in exposure ri sk are the counties that lie on inner coastal waterways and rural counties that serve as watersheds for agricultu ral irrigation. Each of these two areas scores the highest on the FDEP Scori ng Review form. Exposure of surface waters and retention ponds is considered to be the most im portant resource to be protected according to the department. This explains why c ounties that have major terminals located at ports tend to score so high when compared to urban areas. How does Alachua County compare to the rest of the state when it comes to cleanup priority score? Alachua County tends to score discharges higher than the rest of the state. It is interesting to note that although this is the case, this scor e is usually below the funding threshold. This means that the discharges which occur outside Al achua County are more like to trigger a statefunded cleanup. Within Alachua C ounty, alternative measures are more likely to be adopted, such as bio-attenuation or owner-funded cleanup. In establishing a risk-based corrective action pr ocess, it is applied to the maximum extent feasible to achieve protection of human health, public safety, and the environment in a costeffective manner. This provides a phased risk-b ased corrective action process that is iterative and that tailors site tasks to si te-specific conditi ons and risks. To facilitate such a phased ri sk-based corrective process, the responsible party is encouraged to have discussions with the department or the FDEP local program to establish decision points at which risk management decisions will be made. These various decision points include the scope and methodology of the site as sessment, applicable exposure factors, the

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183 remedial strategy for the site, and risk manage ment options based on reasonable, ascertainable future land uses at the site. When requested by the responsible party, site information provided by the department or the FDEP local program uses al l reasonable efforts to provide early decisions regarding these decision points based on the current and future la nd uses at the site and the site information provided by the responsible party. For petroleum products contamin ants of concern found at the site about which information re garding the actual circumstance s of exposure has been provided to the responsible party by the department, a lo cal government, or the pu blic, the cleanup target levels (CTL) for the affected medium or media, except where a state water quality standard is applicable, shall be adjusted to take into acc ount the site-specific expos ure conditions, including multiple pathways of exposure that affect the sa me individual or sub-population. Site-specific CTLs shall be calculated taking into account, th rough apportionment, the potential additive toxic effects of different contaminants. How does the additional burden of vapor recovery as enforced in Miami-Dade and Broward Counties, affect a facilitys overall score? Miami-Dade and Broward Counties score consid erably lower than any other county within the state. This is interesting since they have adopted the most stringent environmental protection rules in the country. Vapor recovery is an added step involved in the loading and unloading process. It must be properly executed and the system carefully maintained in order to work properly. This added level of protection appe ars to have the added benefit of producing discharges of a lower overall severity. Significance of a Facilitys Statewide Ranking At petroleum contam ination sites eligible for state funding assist ance under the Inland Protection Trust Fund (IPTF), soil removal for tr eatment or disposal, if warranted and cost

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184 effective, shall commence in accordance with the ranking established pursuant to Chapter 62771, F.A.C. and shall be performed in accordance with the departments preapproval program procedures pursuant to a preapproval agreement. Within three days of discovery of free product, the responsible party shall take steps to obtain cleanup services fo r product recovery or initiate product recovery. The department acknowledges that site rehabilitation ca nnot be compelled for a discharge that is eligible for state restoration funding assistance, in advance of commitment of restoration funding in accordance with a sites priority ranking, or to pay for the costs of rehabilitation. Real property owners of site s where active remediation or monitoring is being performed in accordance with a Remedial Action Plan Approval Order, a Monitoring Only or Natural Attenuation Monitoring Plan Approval Orde r, or a Risk Assessment Approval Order may voluntarily elect to complete site rehabili tation using the appropria te provisions of the chapter that were in effect at the time the order was issued, as long as the approved active remediation or monitoring is continued to comp letion pursuant to the pr ovisions of the order. If contaminated soil exists at a site, excavat ion of contaminated soil for proper treatment or proper disposal may be performed. Consistent with these goals, the department encourages treatment over disposal options to address contam inated soil. The treatment or disposal of contaminated soil may be performed prior to de partment or FDEP local program approval of a Remedial Action Plan submitted. Contamination shall not be spread into previously uncontaminated or less contaminated areas through untreated discharges improper treatment, improper disposal, or improper storage. If one of the objectives of the interim source removal is to excavate all the contaminated soil, confirmatory soil samples shall be collected at the bottom of the excavation (unless the bottom is below the water table) and walls or perimeter of the excavation.

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185 When excavated soil is temporarily stored or stockpiled on-site, the so il shall be placed on an impermeable surface to prev ent leachate infiltration and secu red in a manner that prevents human exposure to contaminated soil and prevents soil exposure to preci pitation that may cause surface runoff, and any excavation shall be secu red to prevent entry by the public. Excavated contaminated soil may be returned to the or iginal excavation when petroleum storage tank systems have been removed or replaced, or if contaminated soil was encountered during construction activities.

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186 CHAPTER 7 RECOMMENDATIONS FOR FURTHER RESEARCH Secondary Containment Lining Sy stems for Fuel Storag e Tanks If underground storage tanks need to be re placed but site conditions make removal and replacement costly and difficult, then retrofitting the tanks with a cost-effective, corrosionresistant, secondary, contained li ning system may be the best alte rnative. This is a unique, manufactured, on-site, internal fiberglass system that allows the owner to upgrade in-service steel or fiberglass single-walled tanks to a s econdary contained lining system. The surrounding area and equipment are left undist urbed as the tank retrofit is completed without removing the tanks from the ground. A brand-new secondary contained fiberglass lining system is manufactured right on-site by tr ained and certified installers. This relatively new technology needs further study. The system can give more than twice the prot ection of any single-wall ed tank if installed properly. Two new corrosion-resistant layers are applied using a three-dimensional glass fabric, cured with a thermosetting resin and using a propri etary curing system, to create an interstitial space (sandwich laminate). The primary layer contains the product. The annular space between the new inner and outer layers pr ovides continuous leak detection. If there is a breach of the primary layer, the product will be contained by the secondary layer and prevent a leak to the environment. Unlike other tank-lining approaches, this system is custom manufactured on-site with the fiberglass layers bonded to the existing walls of each tank. This eliminates differential forces within the converted tanks. The independent st ructural integrity of the new systems enables installation within an in-service steel or fiberglass tank. To ensure the integrity of the system, an air tightness test of 35 kpa is ap plied to the interstitial space.

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187 Now U.L. listed (double-containment fiber-reinforced plastic linings for flammable and combustible liquid storage tanks) and manufactur ed with corrosion resistant materials, it provides long-term, rust-proof, corrosion-free service. The new structure is not affected by future corrosion of the original tank. Proven to be compatible with all existing petroleum products, alcohol-blended fuels, and a variety of ch emicals, fiberglass can give the owner proven permeation protection, corrosion and chemical resistance, and structural performance. The major benefit of the system is that it c onverts single-walled steel or fiberglass tanks to a secondary contained lined system. This approa ch minimizes site disruption and downtime. It eliminates costly excavation and replacement of existing tanks. It conforms to existing steel and fiberglass tanks. It is capable of monitoring th e tanks integrity using hy drostatic, air pressure, vacuum, or dry sensor monitoring of annular space. The manufact urers offer a 30-year warranty, which helps guarantee long-term pr otection. After retrofit, a ne wly installed man way provides future access. Optional collar and turbine enclos ure allows easier access to the piping and its maintenance. The system is manufactured on-s ite by trained and certified installers, ensuring quality workmanship. Some typical applications are: Retail service stations. Fleet fueling locations. Bulk plants with underground tanks. Office buildings. Chemical plants. Compliance with Environmental Regulations The system conforms to government guidelines for secondary containment. It can provide safe, long-lasting technology that greatly reduces the owners ri sk of expensive leak-related cleanups. With todays emphasis on leak detection and spill preventi on, there are a growing number of authorities implementi ng statutes and codes that make it mandatory for tank owners to

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188 install some type of secondary containment system. There are products and solutions available that may do the minimum that these laws suggest, but do they really protect the tank owner from the potentially high costs of cleaning up contaminated soils? Storage tank owners and operators need to be aware of the potential liability that may arise in the course of managing hazardous liquid storage tank facilities. Often, liabilities occur as a result of spills or leaks, particularly if the h azardous cargo escapes off-site, pollutes an aquifer, or causes a fire hazard. When problems like these ar ise, the liabilities, damages and enforcement penalties can be astonishing. Until recently, tank owners who opted to install an impermeable liner, coat the interior, or rework the bottoms rather than replace th em with a double-walled tank had to accept an important fact: They did not have the added a ssurance that would have come from installing tanks with secondary containment and continuous leak detection; that is, double-walled tanks. With the 3-D glass fabric tank lining system a relatively new technology, the tank owners can transform their existing si ngle-walled tanks into tanks wi th secondary containment and continuous leak detection, without reworking or replacing thei r single-walled storage tanks. How Does the Technology Work? This tank conversion technology consists of a composite m at of (100 percent solids) epoxy and 3 mm-thick three-dimensional (3-D) glass fabr ic that is bonded to th e inside wall of an underground storage tank or, in the case of an aboveground storage tank, the tank floor. The matrix is then top-coated with a layer of 100 percent solids epoxy specifically formulated to provide corrosion resistance against the cargoes st ored. The fabric in the matrix, which is constructed from glass yarn into the 3-D glass fabric that is trademarked Parabeam was developed in Europe in 1989 ( http://www.tanktech.com/secondary.php ).

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189 This 3-D glass fabric consists of two iden tical parallel fabric decks (upper and lower planes), woven integrally and mechanically together by means of vertical pile threads. There is a preset interstitial space between the two deck surfaces or planes. The 3-D glass fabric is available in interstitial space thickness ranging from three to 17 millimeters (0.12 to 0.67 inch). The upper and lower decks of this system are imp ermeable. In the event of a leak in the interior surface, the inte rstice will contain the product so that a monitor can detect the leak and sound an alarm. Similarly, water entering the interstitial space from outside the tank will be contained inside the space so that it can be detected and appropriate steps can be taken. In underground tanks, the technology provides a 360 degree double wall with an interstitial space that combines high strength and an appropri ate degree of bending stiffness. The 3-D glass fabric-epoxy system is non-corrosive. Leak-detection Options Many perm anent leak-detection techniques can be applied with this 3-D lining to provide continuous leak detection. In practice, the most common leak-detection techniques that can be employed include hydrostatic, air pressure, vacuum, or electronic liquid sensing. Continuous air pressure is the most reliable and cost-effective method employed to date. Mechanical Properties Besides its leak-detectio n capabilities, the fa st-curing 3-D laminate has several properties not found in standard fiberglass mat laminates. These include: The majority of the woven glass fabric is at the extreme surfaces of the 3-D laminate, which is separated by the capillary s upport columns, giving the lamina te high tensile strength and good flexural modulus. The interstitial space also helps by safely ab sorbing impacts that would otherwise cause fractures or holidays in standa rd tank lining, therefore protec ting the substrate from contact with the corrosive cargoes stored.

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190 Parabeam 3-D glass fabrics are easy to use with most thermosetting resins; particularly good results can be achieved with pol yester, vinyl ester, or epoxy re sins. However, it is widely known and demonstrated by immersion test data that certain resins deliver better corrosion resistance and structural performance than othe rs; therefore, it is important to select an appropriate resin for th e application at hand. Retrofitting Single-Walled USTs w ith Secondary Containment Before applying any lining, the condition and integrity of a tank must be carefully determined, and the tank must be cleaned and prepared according to applicable codes and standards. This work and the lining applic ation itself must be pe rformed only by qualified applicators. The tank lining process is designed for corro sion protection and leak prevention and is typically used to protect stor age tanks, process vessels, secondary containment structures, concrete process areas, and floors against con tinuous or intermittent chemical attack and degradation. The work is executed by contractors governed by standards authorized by API 1631 and NLPA 631. These standards provide minimum r ecommendations for the interior lining of existing steeland fiberglass-re inforced plastic underground ta nks and periodic inspection of steel underground tanks used for the storage of petroleum-based motor fuels and idle distillates. These recommendations include procedures to be followed and operating conditions to be maintained by contactors, workers, and engineers preparing, inspecting, testing, and lining the interiors of existing underground storage tanks. Requirements fo r vapor-freeing tanks, removing sediment, and cleaning interior surfaces of stee l and fiberglass tanks as well as guidelines to identify tanks that are suitable for lining are also included.

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191 The methods in this standard are applicable to steeland fiberglass-re inforced plastic tanks used for the storage of petroleum-based motor fuels and middle distillates. The procedures are applicable to tanks installed in typical retail serv ice station outlets but may also be used for tanks installed at other types of facilities.

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192 APPENDIX A DISCHARGE REPORT FORM

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193 APPENDIX B FDEP SCORING REVIEW

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194 APPENDIX C PETROLEUM CLEANUP SITE INSPECTION FORM

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195 APPENDIX D LOCAL OPTION MOTOR FUEL TAXES

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196

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197 APPENDIX E SCORE TRACKING SHEET

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198 LIST OF REFERENCES Watts, Richard J., Haller, Daniel R., Jones, P. Teel, Am y L. (2000). A Foundation for the RiskBased Treatment of Gasoline-Contaminated Soils Using Modified Fentons Reactions Department of Civil and Environmental Engineering, Washington State University, Pullman, Washington. Journal of Hazardous Materials, Volume 76, Issue 1, pp. 73-89. ASTM International Designation E 1739 95 (2002). Standard Guide for Risk-Based Corrective Action Applied at Petroleum Release Sites. ASTM International, West Conshocken, PA. ASTM Technical and Professiona l Training Manual (1999). RBCA Fate and Transport Models: Compendium and Selection Guidance. AS TM International, West Conshocken, PA. OSWER Directive 9610.17 (1995), Use of Risk -Based Decision-Making in UST Corrective Action Programs, http://www.epa.gov/oust/directive/od961017.htm USEPA, Office of Solid Waste and Emergency Response, Washington, DC. Krauthammer, Theodor (2007). Mod ern Protective Structures Center for Infrastructure and Physical Security, University of Florida, University Copy and More, Gainesville, Florida. Steel Tank Institute (2004). ACT 100 FRP Fibe rglass Reinforced Plastic Composite Steel Underground Storage Tanks. R913-02, www.steeltank.com Lake Zurich, IL. Florida Departm ent of Environmental Protection (2006). Aboveground Storage Tank Systems. Chapter 62-762 FAC. FDEP, Tallahassee, Fl. Technical Standards and Corrective Action Requirements for Owners and Operators of Underground Storage Tanks (UST). 40 CFR Ch apter 1 (7-1-05 Edition), Part 280 (2005). Washington, DC. Harry, Todd C. (2005). Chevron Learning Center, G eneral Overview of Refining. Chevron. San Francisco, CA. Petroleum Equipment Institute (1999). Recommended Practices for Inst allation of Aboveground Storage Systems for Motor Vehicle Fueling, PEI/RP200-99. Tulsa, OK. Petroleum Equipment Institute (1997). Recommended Practices for Inst allation of Underground Liquid Storage Systems, PEI/RP100-97. Tulsa, OK. Florida Department of Environmental Protection (2004). How to Get the Most out of the DEP Public Internet Reports. Tallahassee, FL. USEPA (2006). UST Systems: Inspec ting and Maintaining Spill Buckets. http://www.epa/gov/oust/pubs W ashington, DC.

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199 Fahnline, Ed, PE (2006). Confusion for Tank Ow ners: When Integrity Testing Finds Tanks Deficiencies Not Directly Referenced in th e SPCC Rule. Freshwater Spills Symposium, URS Corporation. Boulder, CO. Ott, R. Lyman, Longnecker, Michael T. (2004). A First Course in Statis tical Methods, Texas A&M University. Duxbury Press, Belmont, CA. Ricci, Paolo F. (2006). Envir onmental and Health Risk Assessment and Management, Principles and Practices, University of Queensland (NRCET), University of San Francisco. Springer, San Francisco, CA. Littell, Ramon C., Milliken, George A., Stroup, Walter W., Wolfinger, Russell D., Schabenberger, Oliver (2006). SAS fo r Mixed Models, Second Edition. SAS Publishing, Cary, NC. Underwriters Laboratory (1997) 58. IHS Inc., Englewood, CO. Florida Department of Environmental Protection (2004). Chapter 62-761, Underground Storage Tank Systems. FDEP, Tallahassee, FL. Khire, Millind V., Alshawabkeh, Akram N., Reddy, Krishna R. ( 2009). GeoCongress 2008: Geotechnics of Waste Management and Reme diation (GSP 177). ASCE Publications, Reston, VA. Goel, Sudha (2006). Health Risk Assessment for a Contaminated Site: A Case Study, Practice Periodical of Hazardous, Toxic, and Radioactive Waste Management, Vol 10, No. 4 Pp. 72-79. Chen, Zhen (2005). EnvironalPlanning: Analytic Network Process Model for Environmentally Conscious Construction Planning, Journal of Construction Engineering and Management, Vol. 131, No. 1. Pp. 18-26. Chen, Ku-Fan, Wu, Long-Chuan, Kao, Chih-Min g (2004). Application of health risk Assessment to Derive Cleanup Levels at a Fuel-Oil Spill Site, Practice Periodical of Hazardous, Toxic, and Radioactive Wa ste Management, Vol. 8, No. 2 Pp. 51-58. Gudoy, Luis A. (2007). Performance of Storage Tanks in Oil Facilities Damaged by Hurricane Katrina and Rita, Journal of Performance of Constr ucted Facilities, Vol. 21, No. 6, December. Pp. 13-24. Office of Solid Waste and Emergency Response ( 1995). Use of Risk-Based Decision-Making in UST Corrective Action Programs OSWE R Directive 9610.17, Memorandum. U.S. Environmental Protection Agency (2007). Office of Underground Storage Tanks, Grant Guidelines to States For Implementing The Inspection Provisions of The Energy Policy Act of 2005, EPA 510-R-07-004. www.epa.gov/oust

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200 U.S. Environmental Protection Agency ( 2008). Office of Underground Storage Tanks, Operating And Maintaining Underground Stor age Tank Systems,. Tallahassee, FL. U.S. Environmental Protection Agency (1995). Office of Underground Storage Tanks, Musts for USTs, A summary of Federal Regulations for Underground Storage Tank Systems, EPA 510-K-95-002. Washington, DC. 2.3 ASTM RBCA Fate and Transport Models: Compendium and Selection Guidance (ASTM Technical and Professional Training). AS TM International, West Conshocken, PA. Rice, David W., et al. (1995). Californi a State Water Resources Control Board, California Leaking Underground Fuel Tank (LUF T) Historical Case Analyses, (University of California, Davis). Davis, CA. Chilton et al. (1997). A risk based corrective action approac h using computer modeling at an urban leaking underground storage tank site, Groundwater in the Urban Environment: Problems, Processes and Management. British Geologic Survey, Walinford, UK. Johnson, Barry L, DeRosa, Christopher T. (1997). Agency for Toxic Substances and Disease Registry, Public Health Service, The Toxicologic Hazard of Superfund Hazardous Waste Sites Freund Publishing House, Atlanta, GA. Small, Matthew C. (1998). Risk-Based Corrective Action, Natural Attenuation, and Changing Regulatory Paradigms, Bioremediation Journal, Vo lume 2, Number 3. Pp. 38-44. Rosen, Lars, LeGrand, Harry E. (1996). An Outline of a Guidance Framework for Assessing Hydro-geological Risks at Early Stages Wiley Interscience, John Wiley and Sons, Hoboken, NJ. Mulligan, Catherine N., Yong, Raymod N. (2003). Natural Attenuation of Contaminated Soils, Department of Building, Civil and Environmen tal Engineering, Concordia University. Elsevier Ltd. Cordiff Ales, UK. Kostecki, P. T., Calabrese, E., Nascarella, M. (2002). Survey of States 2001 Soils Cleanup Standards for Petroleum Contamination, Journal of Soil Contamination Vol. 11, no. 2, pp. 117-239. Hudak, Paul F., Wachal, David J., Hunter, Bruce A. (2002). Managing Subsurface Property Hazards: Reactive Soils and Underground Storage Tanks Department of Geography and Environmental Science Program, Un iversity of North Texas. Urban Water Volume 1, Issue 3, pp. 237-241. Berrens, Robert P., Bohara, Alok K, Baker, Amy, Baker, Ken (1999). Revealed Preferences of a State Bureau: Case of New Mexicos Underground Storage Tank Program, Journal of Public Policy Analysis and Management, Vol. 18, Issue 2. Pp. 71-79.

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201 Rice, David W. (1995). Recommendations to Improve the Cleanup Process for Californias Leaking Underground Fuel Tanks (LUFTs), Submitted to the California State Water Resources Control Board, Underground Storage Tank Program. UCRLAR, Los Angeles, CA.

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202 BIOGRAPHICAL SKETCH Born in Live Oak, Florida, in 1966, Don W Lewis graduated from the University of Florida with a Bachelor of Sc ience degree in Civil Engineeri ng (BSCE) in 1990. After working in the private sector for two years, he went b ack to school and earned a Master of Engineering (ME) in 1993. Don W. Lewis has served as a Subject Matter Expert (SME) for the Construction Industry Licensing Board (CILB) certifica tion exams covering the subject areas of general/builder/residential and pollutant storage specialty contractor for more than ten years. Don W. Lewis has been a discipline-free state certified contractor for more than 20 years. While working in the private sector, Don W. Lewis was chosen by Chevron to be a Signature Class Jobber, covering much of northern Florida, after achieving record sales growth in the area of heavy/industrial lubricants. D on W. Lewis is a Certified Lubrication Specialist (CLS) Certified Building Contractor (CBC) Certified Pollutant Storage Contractor (PSC) and Engineer Intern (EIT) He is an active member of Tau Be ta Pi, the National Engineering Honor Society, and Chi Epsilon, the National Civil a nd Environmental Engin eering Honor Society. Don W. Lewis is also an active member of the American Society of Civil Engineers (ASCE), and the Society of Tribol ogists and Lubrication Engineers (STLE). As a Ph.D. candidate, Don W. Lewis taught Construction Methods and Management, an ABET accredited engineering undergraduate course at the University of Florida. While a graduate student, he helped establish an undergraduate scholarship in his fathers name. A lifelong Gainesville resident, Don W. Lewis attended Gain esville High School (GHS), Westwood Middle School and Littlewood Elementary and stil l has contact with many of his childhood schoolmates. He received his letter of appointment to the upper level graduate program at the University of Florida in the fall of 2006.