Hazardous Waste

Stephen Cullen

Lorne Everett

03/01/95-12/31/95 $64,997

Lawrence Livermore National Laboratory, B283614

Evaluation of California's Leaking Underground Fuel Tank Program

Dr. Stephen J. Cullen (Principal Investigator) and Lorne G. Everett (Co-Principal Investigator) recently co-authored two reports produced by the University of California under contract to the California State Water Resources Control Board. The reports have seriously impacted traditional approaches to groundwater remediation in California and have had substantial national impact on the cleanup of petroleum hydrocarbons which have been released to the subsurface environment.

The University of California team is made up of members from Lawrence Livermore National Lab, UC Los Angeles, UC Berkeley, UC Davis and UC Santa Barbara. Dr. Cullen and Dr. Everett represented the Institute for Crustal Studies (ICS) as a part of the UC Santa Barbara team. Joel Michaelsen and Steve Cluster, Department of Geography, also made substantial contributions to the two reports. On October 16, 1995, the University of California report entitled -Recommendations to Improve the Cleanup Process for California's Leaking Underground Fuel Tanks (LUFTs)- recommended that: 1) passive bioremediation be considered as a remediation alternative wherever possible; 2) ASTM Risk Based Corrective Action (RBCA) framework be modified based on California's historical LUFT case data; 3) modified ASTM RBCA framework be applied as soon as possible to LUFT cases were fuel hydrocarbons have effected soil but do not threaten groundwater; 4) the California LUFT regulatory framework be modified to allow consideration of risk based cleanup goals higher than the currently accepted maximum contaminant limits; and 5) a series of LUFT demonstration sites be identified and that an Expert Committee be formed to oversee the use and application of techniques described in the University of California report.

On November 16, 1995, University of California team released a companion report entitled -California Leaking Underground Fuel Tank (LUFT) Historical Case Analysis-. Data was collected from the case files of all nine Regional Water Quality Control Boards in the State of California. Based on a statistical analysis spearheaded primarily by members of the Institute for Crustal Studies, the data showed that the dissolved phase hydrocarbon plume length changes slowly and tends to stabilize at a relatively short distance from an underground storage tank release site. Plume length analysis showed that site plume lengths rarely exceed about 250 feet. It was further shown that only one-half of one percent of the underground storage tank groundwater contamination sites caused a drinking water problem and that the potential volume of groundwater impacted by LUFT plumes greater than one part per billion benzene was estimated to be .0005% of California's total groundwater basin storage capacity. It was concluded that current LUFT decision-making processes do not result in cost effective site closures and that fuel hydrocarbons have limited impacts on human health, the environment, or California's groundwater resources. Further, allocation of over $3 Billion dollars required to complete the program should be reconsidered.

In December 1995, the California Water Resources Control Board released a state policy letter stating that the University of California study found that the impacts to the environment from LUFTs were not as severe as once thought. The letter went on to state that, based on the study, the Regional Board should proceed aggressively to close low-risk soil only cases. The State Board also advised its nine regional offices to halt active remediation at sites more than 250 feet from drinking water wells and that active remediation strategies should be replaced with monitoring to make sure fuel constituents do not eventually imperil groundwater resources.

The University of California report has resulted in substantial policy changes which will allow scarce remediation dollars to be applied to more immediate and serious problem sites. The policy changes will clearly result in a major reduction in regulatory control throughout California, and will no doubt dramatically reduce a major component of the environmental remediation and consulting market in California. LUFT sites can now be evaluated according to risk. While some environmental groups including the Sierra Club are not comfortable with the implications of leaving petroleum hydrocarbons in soil and water to naturally degrade, other environmental groups such as California Communities Against Toxics have expressed supportive opinions and applaud the redirection of environmental protection dollars to more serious and immediate threats to human health and the environment.

Stephen Cullen

Lorne Everett

03/08/96-09/30/96 $30,000

Lawrence Livermore National Laboratory, B291841

Evaluation of California's Leaking Underground Fuel Tank Program: Phase II

Dr. Stephen J. Cullen has received follow-up funding to act as Principal Investigator to conduct continuation research to evaluate and recommend changes to the LUFT cleanup decision-making process in California. The purpose of the research effort is to identify, for the use of regulatory agencies and responsible parties, methodologies and approaches for dealing with leaking fuel tank problems. The goal of the resulting LUFT cleanup decision-making process is to determine the appropriate degree of regulatory response to leaking fuel tank cases that will ensure the protection of health and environment, including beneficial uses of the State's water resources. The developed methodologies are intended to avoid unwarranted expense, analysis, or delays while ensuring that adequate site characterization analysis is done to identify the extent of and design appropriate response to subsurface contamination problems. Previous research, in which Dr. Cullen and other ICS researchers participated, identified a modified risk-based corrective action approach to systematically meet this goal.

The work to be performed under the Phase II research will accomplish three objectives. the first objective is to propose detailed customizations necessary to apply the American Society of Testing and Materials (ASTM) Risk-Based Corrective Action (RBCA) decision-making process to California environmental conditions under which LUFT cleanups take place. These proposed customizations to ASTM RBCA will reflect California's site-specific exposure pathways and quantify the uncertainty in the assumptions that are used during the LUFT cleanup decision-making process. The second objective is to perform ongoing data analysis of historical LUFT case data to support a customized RBCA approach, including the analysis of soils chemistry data, the application of a customized RBCA decision-making to historical LUFT case data, and the evaluation of passive bioremediation at active LUFT sites within California. The third objective is to evaluate the cost savings that may be realized to California's economy as a result of using a RBCA approach to LUFT cleanup.

Lorne Everett

12/01/94-11/30/95 $26,343

FERMCO, 95PP156958

Technical Support for Field Investigation Design

Dr. Everett won a national competition to provide hydrogeology technical support for the Department of Energy activities at Fernald, Ohio. After the Manhattan Project was completed in Chicago, all of the radioactive material was transported to Fernald where it was buried in large vertical concrete tanks. The areas surrounding these tanks have not been monitored for 50 years, and as such, Dr. Everett participated in identifying, technologies which would provide insights into unsaturated flow characteristics. In addition, Dr. Everett provided technical designs associated with the use of pore liquid samplers and indirect soil moisture measurement technologies. A clean area has been identified adjacent to the Fernald site wherein radioactive waste will be ultimately disposed. These disposal cells will be underlined with monitoring systems designed by Dr. Everett. Further discussions were held with the Fermco people relative to the instrumentation associated with barrier designs, and as such, techniques developed within the Vadose Zone Monitoring Lab now will be integrated into the barrier program used by the Department of Energy at Fernald.

Lorne Everett

05/20/96-08/20/96 $3,530

Office of Naval Research, ONR BPA N47408-96-A7023

Vegetative Analysis for the Landfill Cover Demonstration

Lorne G. Everett, directed research conducted in the Vadose Zone Monitoring Laboratory related to landfill and hazardous waste cap design. In particular, soils from Hawaii were sent to the Vadose Zone Monitoring Lab and 30 separate test chambers were developed to calibrate time domain reflectometry probes. The TDR probes are used to determine leakage rates associated with the landfill barrier cap designs. This research is funded by the United States Navy. The calibration chambers and testing procedures developed at the lab are expected to be utilized by the Navy at landfill sites throughout the world.

Lorne Everett

03/15/95-09/30/96 $39,934

US Navy, IPA A95002

United States Navy National Test Site Fuel Hydrocarbon Remediation Program

Lorne G. Everett participated as a member of the United States Navy Science Advisory Panel in support of the Navy National Test Site Program. The program focuses on developing hydrocarbon remediation technologies that will be used by the United States Navy throughout the world. Contributions from the Vadose Zone Monitoring Laboratory focused on selecting monitoring strategies to optimize the remediation activity. Remediation technologies such as heap biopile programs, hot air vapor extraction, and the German UVB recycling system were demonstrated.

Lorne G. Everett was invited by the World Lab to identify successful remediation strategies that could be used by East block countries. This invited paper was given at Erice, Trapany in Sicily. Following the Erice presentation, Dr. Everett was asked by NATO to tour NATO bases in the Mediterranean to make recommendations on remediation strategies. As a result of substantial international exposure, Dr. Everett was elected to the Russian Academy of Sciences in 1995 and awarded an Honorary Doctor of Science by a Canadian University in May 1996.