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Risk-Based Corrective Action EPA issued a parity policy in 1996 between the CERCLA (Superfund) and RCRA Corrective Action programs, entitled Coordination Between RCRA Corrective Action and Closure and CERCLA Site Activities (U.S. EPA 1996c). This guidance describes the conditions under which acceptance of decisions made by other remedial programs may be used. It recommends riskbased approaches when developing cleanup levels for RCRA regulated units and establishes the general principle that RCRA and CERCLA cleanups will achieve similar environmental results, thereby establishing a policy that cleanups under one program will be acceptable to the other program. It also identifies situations when deferral of activities to other programs is appropriate, and encourages coordination among the various cleanup programs at the federal and state levels. Risk-based corrective action provides an alternative to the use of strict numeric standards for specific contaminants as endpoints for cleanup activity, which is generally less cost effective. RCRA Cleanup Reforms Through a series of administrative reforms, known as the RCRA Cleanup Reforms, EPA continues to work with the states and stakeholders to develop new results-oriented cleanup guidelines, foster outreach and training to encourage flexible approaches to corrective action, and enhance community involvement. The RCRA Cleanup Reforms are expected to nurture creative, practical approaches which, in the field, means eliminating unnecessary administrative or technical steps, evaluating sites for overall risk, and applying appropriate risk-based facilitywide corrective action measures. Several guidance documents have been issued since 1999 to promote effective cleanup results and enhance public involvement. For instance, EPA's final Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action, issued in 2002, is intended to help regulators, owners and operators of RCRA sites, and the public locate and understand EPA policies on groundwater use, protection, and cleanup within the framework of applicable state requirements (U.S. EPA 2002b). The Results-Based Approaches and Tailored Oversight Guidance for Facilities Subject to Corrective Action Under Subtitile C of the Resources Conservation and Recovery Act encourages technical and administrative innovation to achieve environmentally protective cleanups on a facility-specific basis (U.S. EPA 2003c). The approaches discussed in the document offer regulators flexibility in setting cleanup goals, planning data collection efforts, and letting owners/operators undertake cleanup actions with reduced Agency oversight when appropriate. A January 2001 memorandum discusses a variety of new enforcement approaches, such as reduced agency oversight and flexible compliance schedules, that are available to EPA and authorized states to help accomplish timely, protective, and efficient corrective action (U.S. EPA 2001). EPA has also expanded outreach and developed comprehensive training as part of the 1999 reforms. Some of the training gives EPA and state regulators the opportunity to learn from their peers about successful cleanup approaches. EPA has also begun piloting the most innovative of these approaches at the site level. Twenty-five pilots were launched in the first year. Creating partnerships, training, connecting communities with cleanups, and capitalizing on the redevelop ment potential of RCRA sites are likely to increase the number of cleanups started during this decade.

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4.1.2 Corrective Action Process A rigid process-oriented framework, such as that proposed in Subpart S (U.S. EPA 1990a) and the 1994 Corrective Action Plan (U.S. EPA 1994a), is not always applicable to the wide range of contamination problems at the diverse types of RCRA sites. The 1996 Advanced Notice of Proposed Rulemaking (ANPR), EPA's primary corrective action implementation guidance, emphasizes a performance-based approach and asserts that the elements of the process should not become ends in themselves (U.S. EPA 1996a). EPA recommends that cleanups be guided by several operating principles: Corrective action decisions should be based on risk; Corrective action should focus on results rather than process; Interim actions and stabilization should be used to reduce risks and prevent exposure; Corrective action activities should be phased to focus resources on the areas or exposure
pathways of highest concern;
· Corrective action requirements should be addressed using the most appropriate authority,
including state authorities, for any given facility (In certain cases, the states may rely on
non-RCRA state authorities to satisfy correction action requirements); and
· Corrective action implementation should provide for meaningful inclusion of all
stakeholders through full, fair, and equitable public participation.
Although the implementation of corrective action varies from site to site, it generally begins with an evaluation of existing site conditions, including information from the initial site assessment, called a RCRA facility assessment (RFA). EPA or an authorized state conducts the RFA, which involves examining a facility's SWMUs to determine if a release has occurred or if the potential for a release exists. While site characterization is underway for the final cleanup, the owner or operator of a facility may be required to conduct an interim action, such as stabilizing contaminated waste to prevent the spread of contamination or providing an alternative source of drinking water if actual or potential contamination of drinking water supplies exists. Although an interim action typically occurs early during the investigation of the site, it may take place at any time prior to completion of the final remedy. When additional site information is necessary to support an interim action, cleanup decision, or achievement of environmental indicators, the facility owner or operator may conduct a RCRA facility investigation (RFI). The RFI involves sampling, modeling, and other testing to determine the nature and extent of contamination and to characterize the site's geological and hydrological conditions. If a corrective action is needed, a site owner will conduct a corrective measures study (CMS) to evaluate alternative remediation approaches and select a preferred alternative as the remedy. Sometimes, the CMS, which is the responsibility of the facility owner or operator with oversight from EPA or the state, can be conducted concurrently with the RFI. In cases where EPA or a state is using performance standards or a similar approach, or where the preferred remedy is apparent early in the process, the CMS may be highly focused. Upon approval of a remedy by
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the regulatory agency, the owner or operator may begin corrective measures implementation (CMI), which involves designing, constructing, maintaining, and monitoring the remedial measure. EPA recommends that current and reasonably expected future land uses be considered when selecting corrective action remedies. 4.1.3 Corrective Action Implementation State Authorization States are the primary implementors of the RCRA program, including RCRA Corrective Action. EPA provides several million dollars annually in grants to states for state oversight of cleanup at RCRA sites. As of April 17, 2003, EPA has authorized 48 states, some territories, and the District of Columbia to manage their own base programs for waste management and prevention. Thirty-nine states and one territory are authorized to oversee RCRA Corrective Action. EPA regional offices have the lead responsibility for implementing the program in Indian Territories and in states that have yet to be authorized for corrective action. Many other states have for some time been operating similar corrective action programs under their own authorities. The states have no RCRA universe of their own that is not reported to EPA. EPA's State Authorization Tracking System (StATS) tracks the status of each state and territory in establishing and maintaining RCRA authorized hazardous waste programs, including corrective action (see http://www.epa.gov/epaoswer/hazwaste/state/stats/stats.htm). Prior to granting a state or territory full authorization for corrective action, EPA regional offices may develop grants and cooperative agreements under RCRA §3011 giving the state the lead for corrective action oversight at specific sites. Although authorized state programs must meet the minimum federal requirements, a state may adopt regulations that are more stringent than the federal requirement. Permitting and Enforcement Corrective action may be implemented through the RCRA permit process, state or federal enforcement orders, or voluntarily. All sites that are required to have RCRA permits, such as TSDFs, and those sites where EPA or a state has discretionary authority under RCRA to impose corrective action, are subject to corrective action requirements. About 86 percent of RCRA sites subject to corrective action are TSDFs. Corrective action may be imposed to clean up on-site contamination, offsite contamination, and one-time spills. EPA or an authorized state permits all TSDFs to treat, store, or dispose of hazardous waste. Section 3004(u) of HSWA, which is directed specifically toward controlling releases from SWMUs, is the primary authority requiring corrective action at permitted TSDFs. It compels a facility owner or operator to address SWMU releases due to past disposal or recent contamina tion whenever seeking a RCRA permit. Additional authority is available under §3004(v) of HSWA to require a permitted TSDF to clean up contamination beyond the facility boundary. Thus, HSWA requires all hazardous waste facilities that obtain a RCRA permit after November 8, 1984, to take corrective action for any releases from past disposal or recent contamination from the facility, including all SWMU and off-site releases. For a TSDF operating under interim status rather than a RCRA permit, EPA can invoke HSWA §3008(h), which provides for

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enforcement orders, or state orders in an authorized state, to address any release of hazardous waste. The corrective action process for both permitting and enforcement orders is similar. For actual or potential releases not originating from a SWMU, such as a one-time spill from a vehicle traveling across a facility, or for releases at RCRA sites with permits that pre-date HSWA, EPA may impose its omnibus permitting authority pursuant to HSWA §3005(c)(3). This provision allows EPA to modify the facility's permit as necessary, requiring corrective action for any potential threat to human health or the environment. Also, HSWA §7003 gives EPA broad authority to seek injunctive relief in the appropriate U.S. District Court or to issue administrative corrective action orders for any waste from any source, including SWMUs, where the handling, storage, treatment, transportation, or disposal of solid or hazardous waste may pose an imminent and substantial danger to public health or the environment. To minimize the regulatory burden of RCRA Corrective Action without endangering public health or the environment, EPA created exemptions and special permits. For example, EPA conditionally exempts from the Subtitle C hazardous waste regulations any waste samples collected solely for the purpose of monitoring or testing the characteristics or composition of RCRA facility contamination. Referred to as the Treatability Studies Sample Exemption Rule (CFR 261.4(e) and (f)), the exemption places limits on the quantity of contaminated media than can be shipped, stored at a laboratory or testing facility, and treated there (U.S. EPA 1994b). The exemption rule also limits the amount of time the contaminated media may be retained for analysis or treatment. Although EPA encourages authorized states to adopt exemptions and special permits, the states are not required to adopt them because they are less stringent than existing federal requirements. Special permits and modifications are available to facilitate the development and application of innovative technologies. For example, facility owners or operators may obtain RCRA research, development, and demonstration (RD&D) permits for pilot-scale evaluations of treatment tech nologies. EPA, in collaboration with the state, has the authority to modify a permit or enforce ment order to allow on-site technology demonstrations at corrective action sites. In this case, EPA may grant a site-specific treatability variance for contaminated soils and debris when the facility cannot achieve the stringent technology-based treatment standards in the land disposal restrictions. Other permitting options are available through the Subpart X rule of RCRA, titled "Miscellaneous Units," which addresses hazardous waste management units that do not fit the current RCRA definition of container, tank, surface impoundment, pile, land treatment unit, landfill, incinerator, boiler, industrial furnace, or underground injection well (U.S. EPA 1987). For instance, EPA and the Department of Defense have worked together to dispose of munitions using the permitting options available for pilot-scale RD&D and the Subpart X rule. The remedial action plan (RAP), a special type of RCRA permit, made available in the final HWIR-media rule (1998) as an alternative to traditional permits, can be used for the treatment, storage, or disposal of waste generated during remediation activities. RAPs can be used for cleaning up contaminated areas or areas in close proximity to the contamination, and they may be used for cleaning up offsite locations when treating, storing, or disposing of the waste off site is more protective than on site.

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4.2 Factors Affecting Demand for Cleanup
The extent and timing of the cleanup of RCRA Corrective Action sites is significantly influenced by the regulatory and site-management refinements that EPA and the states have been building into the cleanup process; federal funding of state oversight; and improvements in field tech nologies that better characterize contamination, improve remedy design, lower overall cleanup costs, and improve the quality and pace of site cleanups. These factors create incentives for owners and operators in the broader market to consider actual cleanup over containment. · The RCRA Cleanup Baseline sites that are striving to meet their 2005 interim GPRA goals represent the most immediate actions to be taken at RCRA sites. While these sites represent the readily identified, near-term market for cleanup, many other RCRA sites with less immediate human health concerns will also need to be cleaned up. · Revisions to the Subtitle C requirement for cleaning up some hazardous waste implemented over the past decade are likely to encourage treatment and removal as compared to leaving waste in place. As described in section 4.1.1, the revisions most likely to impact the market include introducing alternative standards for CAMUs, temporary units, and staging piles specifically to handle remediation waste that is no longer considered newly-generated hazardous waste; defining LDR alternative treatment standards for cleanups; harmonizing the sometimes duplicative closure and corrective action requirements; streamlining permit requirements for cleanup activities; and removing the obligation for facility-wide corrective action. Before these changes occurred, the stringent Subtitle C requirement was frequently counter productive when applied to the cleanup of individual sites because it imposed unnecessary costs and delays and limited cleanup options. Even if treating or permanently removing the waste was the preferred option, parties sometimes decided not to clean up certain sites or sought to leave the waste in place at others. Such actions may lead to increased long-term risk of human exposure to contamination and the potential that the contamination will spread offsite or to groundwater. · The 1999 and 2001 cleanup reforms are intended to increase the number and efficiency of cleanups and establish aggressive national cleanup goals. The reforms established more flexible, facility-specific approaches to account for the variety of conditions at RCRA sites. · Refinements in field technologies and methods used to characterize site contamination and its likely movement in the environment and to improve remedy design are changing the cleanup market. Refinements in these technologies during the last five to ten years have begun to decrease site-assessment costs, improve data quality, and expand the applicability of less traditional remedies. For instance, in the past, a semi-permanent well had to be instal led to sample groundwater quality and a drill rig was needed to obtain soil borings at depth. While these technologies still have their place, newer technologies, such as the hydropunch and cone penetrometer, are available at a dramatically lower cost. Also available are geo physical technologies, such as remote sensing, to determine subsurface conditions. Almost 30 percent of all sites EPA sampled in a study of RCRA Corrective Action implementation
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used some type of innovative characterization approach (U.S. EPA 2002c). Low-priority sites were more likely than medium and high priority sites to employ these approaches. Site characterization, conducted at less cost, often results in better designed remedies for particu lar site conditions, rather than in over-designed remedies intended to account for the many unknowns associated with a site. · The pace of the cleanups is affected by the availability of funds to pay for state and federal oversight. Many states have been facing budget deficits in 2003 and 2004 and, on average, state staffing levels and budgets for hazardous waste remediation has not increased in about a decade. Section 9.4 (State and Private Party Sites) includes a description of trends in state capabilities. · Land development trends are also likely to affect the pace and nature of RCRA cleanups. If there is demand for the redevelopment or transfer of commercial and industrial properties, they will require site assessments and, if necessary, remediation. The 2002 brownfields law, titled "The Small Business Liability Relief and Brownfields Revitalization Act (P.L. 107-118)," the Superfund Redevelopment Program, and the RCRA Brownfields Initiative are encouraging the reuse of former industrial and other properties. These programs have implemented policy changes and demonstrated many approaches and ideas that foster the cleanup and redevelopment of contaminated properties, including a number where waste has been left on site. By publicizing the potential for reusing tainted properties, these activities may have the impact of increasing the pace of cleanup of corrective action sites. (See Section 9.1.2, Voluntary Cleanup and Brownfield Programs).

4.3 Number and Characteristics of RCRA Sites
All RCRA sites requiring permits and those where EPA or a state has discretionary authority to impose corrective action are subject to corrective action requirements. However, not all of these sites will actually require corrective action, and until further study is conducted, the number of RCRA sites that will require cleanup can only be estimated. Nevertheless, EPA's RCRAInfo electronic database and two previous EPA studies, can be used to estimate the potential extent of future cleanups. 4.3.1 Number of RCRA Sites As of March 31, 2003, EPA's RCRAInfo database, a national program management and inven tory system on hazardous waste handlers, contained information on 6,677 RCRA sites where EPA has discretionary or statutory authority to impose corrective action when necessary (U.S. EPA 2003b). Exhibit 4-1 shows the distribution among the states of the RCRA sites subject to corrective action. Exhibit 4-2 contains the current numbers of sites in this universe in EPA's ten regions. EPA and the states have identified approximately 29 percent high-priority sites, 24 percent medium-ranked sites, 29 percent low-ranked sites, and have not ranked 19 percent of the sites. A RCRA facility investigation (RFI) has been imposed at 38 percent of the sites subject to

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corrective action. The RFI involves sampling, modeling, and other testing to determine the nature and extent of environmental contamination and to characterize the site's geological and hydrological conditions. A RFI has been imposed at 79 percent of the high-priority sites, 38 percent of the medium-priority sites, and 20 percent of the low-priority sites. While about 20 percent of the sites in this universe are implementing stabilization measures, only 10 percent of them have selected a remedy.

Exhibit 4-1. Location of RCRA Sites Subject to Corrective Action by State and EPA Region

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Exhibit 4-2. Priority Ranking of RCRA Sites Subject to Corrective Action
EPA Region 1 2 3 4 5 6 7 8 9 10 Total Ranking High 176 188 308 272 355 236 99 58 140 78 1,910 Medium 85 208 46 196 445 204 146 68 123 46 1,567 Low 43 267 62 151 691 228 126 126 236 29 1,959 Unranked 83 23 87 268 486 114 19 108 45 8 1,241 Total Facilities 387 686 503 887 1,977 782 390 360 544 161 6,677

Source: U.S. EPA, Office of Solid Waste, RCRAInfo database, March 28, 2003

A subset of this universe represents 3,829 sites that are required to undergo further site investiga tion and or cleanup. These sites are most likely to require some sort of remedial action in the near term and already may be involved in some phase of corrective action. Approximately eight percent of these sites are federal facilities. Exhibit 4-3 shows the distribution among the states of the RCRA sites in this universe, which is called the "corrective action workload universe." Most states have fewer than 100 of these sites. 4.3.2 Types of RCRA Sites The type of activities that have occurred at a site may lend insight into the nature of the cleanup needed. A TSDF may operate one or more types of hazardous waste management processes. Typical management processes include land disposal, such as landfills, land treatment units, surface impoundments, waste piles, and underground injection wells; incineration; treatment, storage in tanks; and boilers and industrial furnaces. A waste pile is any non-containerized accumulation of solid, nonflowing hazardous waste that is used for treatment or storage. The definitions of the other processes may be found in 40 CFR §260.10 (U.S. EPA 1980).

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Exhibit 4-3. Location of RCRA Sites Likely to Require Corrective Action by State and EPA Region

Exhibit 4-4 presents the major processes operated now or in the past by RCRA facilities in EPA's RCRAInfo database. Because each facility may be performing more than one process, the total number of processes exceeds the number of facilities. Storage and treatment account for 72 percent of the processes reported, followed by land disposal at 23 percent, and incineration at four percent.

Exhibit 4-4. Major Waste Management Processes at RCRA Facilities

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In one study, EPA's Technology Innovation Office obtained information on a total of 275 TSDFs in 1992 and 1993 for the purpose of identifying relationships between site characteristics and the use of innovative technologies at RCRA Corrective Action sites (U.S. EPA 1994c). At the 214 TSDFs where contamination data were available, halogenated volatile organic compounds (VOCs), the most prevalent of all contaminant groups reported, were present at a majority of the TSDFs, followed by heavy metals, and nonhalogenated VOCs. Groundwater contamination was reported at 82 percent and soil contamination at 61 percent of the 256 TSDFs for which media data were available. A second study is EPA's 1993 regulatory impact analysis (RIA), developed to support the corrective action rule, Subpart S (U.S. EPA 1993b). EPA analyzed information on a sample of 79 TSDFs to estimate contamination likely to be present in soil or groundwater at concentration levels that would require action. Of the 2,600 facilities, estimated at the time of the 1993 RIA to require corrective action, about 80 percent appeared to have significant releases to on-site groundwater and 30 percent were likely to have significant off-site groundwater contamination. This estimate is close to the 82 percent observed in EPA's study of 275 TSDFs (U.S. EPA 1994c). Contaminants in groundwater and soil at RCRA facilities were estimated in the RIA. The top ten contaminants expected in groundwater at concentrations that were high enough in 1990 to trigger concern are, in order of frequency, chromium, benzene, methylene chloride, arsenic, lead, tetrachloroethylene, trichloroethylene, naphthalene, 1,1,2-trichloroethane, 1,1-dichloroethylene. Based on this data on-site soil contaminant concentrations above EPA action levels are expected to occur at about 68 percent of the 2,600 facilities estimated at the time of the study to require corrective action. In soil, tetrachloroethylene, trichloroethylene, chromium, and arsenic were expected to be at concentration levels above EPA's 1990 action levels. In 1997, EPA developed a snapshot on corrective action implementation nationwide based on a statistically representative sample of 84 facilities among 889 corrective action sites that had final remedies selected or stabilization measures in place. The site data reflected the universe of RCRA facilities subject to corrective action in 1990. EPA surveyed Agency regional and state regulators responsible for the selected facilities and received 62 responses. The survey results were compiled into the RCRA Corrective Action Implementation Database (RCAID) (U.S. EPA 2002c). The majority of facilities in the extrapolated RCAID universe were manufacturing industries. Although spills were estimated to be a major concern at over half of the facilities, landfills, surface impoundments, and underground storage tanks also contributed significantly to facility contamination. Nearly all of the facilities had both soil and groundwater contamination, and the contamination had migrated beyond the facility boundary at about half of the sites. Using the extrapolated data, OSW estimated that 84 percent of the facilities with a final remedy and/or stabilization measure in place had VOCs, 41 percent had SVOCs, 23 percent had metals, 10 percent had polychlorinated biphenyls, 5 percent had pesticides, and 20 percent had other types of contaminants, such as radionuclides and phenol.

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Another study of treatment experiences at RCRA corrective actions involved 30 sites identified from readily available information sources in 2000 (U.S. EPA 2000a). EPA's Technology Innovation Office, which conducted the study, selected sites that were illustrative of the types of cleanups conducted at RCRA corrective actions. They were not necessarily representative of the entire universe of RCRA cleanups. The sites, which varied in size and complexity, had chlorinated solvents, polycyclic aromatic hydrocarbons (PAHs), benzene, toluene, ethylbenzene, and xylenes (BTEX), other VOCs and SVOCs, and petroleum hydrocarbons. Information on contaminants and contaminated media at 99 RCRA sites was found in the statements of basis completed before 2000 (most were signed before 1995). A statement of basis is similar to a Superfund ROD. The number of sites reporting groundwater contamination exceeded 70 percent and was similar to the number reporting soil contamination. Nearly 70 percent of the sites in the database reported VOCs, about 40 percent reported SVOCs (including halogenated, nonhalogenated, PAHs, PCBs, phenols, and pesticides), and nearly 50 percent reported metals. Dense non-aqueous phase liquids (DNAPLs) were found at 53 sites; the most common were 1,1,1-trichloroethane (1,1,1-TCA), 1,1-dichloroethene, tetrachloroethylene and (PCE), and 1,1-dichloroethane.

4.4 Estimated Cleanup Costs
All known estimates of the ultimate cost of the RCRA Corrective Action program are subject to uncertainties inherent in predicting the course of a large multi-year program. The types and sizes of sites are quite diverse, and detailed data are available on only a sample of sites. The most appropriate estimate was prepared in the background work for the proposed amendments to the CAMU Rule in 2000 (U.S. EPA 2000b). This estimate is based on the RCAID survey data described in Section 4.3.3. EPA surveyed EPA regional and state regulators responsible for the selected facilities and received 62 responses. The cleanup cost varied widely from site to site, from under $1 million to over $50 million. Over half the facilities had cleanup costs under $5 million, and 9 percent had costs over $50 million. The data were reported in terms of ranges and precise average cost per site was not provided. However, by taking the upper and lower cost value of each range, a reasonable approximation of an upper and lower limit of the estimated costs were developed. These calculations appear in Exhibit 4-5. Based on these estimates, cleanup of the 3,829 sites that are likely to require corrective action will cost between $31 billion and $58 billion, with a middle-value of $44 billion, or $11.4 million per facility. Approximately 41 percent of the total cost will be incurred by nine percent of the facilities. These estimated corrective action costs do not include those of the very large DOD and DOE facilities, although it may include some smaller ones. This estimated average cost per site is about 20 percent lower (in 2003 dollars) than that estimated in the 1993 Regulatory Impact Analysis for Subpart S. This difference reflects a variety of changes since that RIA, including more efficient site characterization and cleanup approaches, the use of risk-based cleanup approaches, and savings due to the CAMU policies described in Section 4.1. Over the past few years, implementation of the Corrective Action program has shifted toward more flexible, risk-based cleanups and away from the regulatory approach modeled
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in the 1993 RIA. In addition, the near-term costs of the program are likely to be reduced due to the program's emphasis in the short-term on stabilization remedies rather than permanent remedies. Exhibit 4-5. Estimated RCRA Corrective Action Costs ($Millions)
Cost Per Site Cost < 1.0 1-5 5 - 10 10 - 25 25- 50 > 50 Total
a b c
a

Total Cost c No. of Sites 1,225 919 498 766 77 345 3,829
b

% of Sites 32 24 13 20 2 9 100

Low 0 1 5 10 25 51

High 1.0 5.0 10.0 25.0 50 .0 70 .0

Low 245 919 2,489 7,658 1,915 17,575 30,800

High 1,225 4,595 4,978 19,145 3,829 24,123 57,895

Average 735 2,757 3,734 13,402 2,872 20,849 44,347

The lowest ($200,000) and highest ($70 million) values are conservative assumptions Sites likely to require corrective action, from Section 3.4.3. Number of sites multiplied by cost per site

Source: U.S. EPA, 2000c, Economic Analysis of the Proposed Amendments to the Corrective Action Management Unit Rule (Background Document), Office of Solid Waste, August 7, 2000.

4.5 Market Entry Considerations
The responsibility for RCRA corrective action at individual sites lies with the owners and operators who contract directly with commercial vendors for services. RCRA requires that owners and operators be aware of technologies that may be used and those that are subject to restrictions or are banned. Although vendors interested in the corrective action market can obtain some information about specific sites by querying RCRAInfo on line, they will have to contact specific owners or operators to obtain information on an individual facility's corrective action requirements, waste characteristics, and cleanup needs. The RCRAInfo query form is at http://www.epa.gov/enviro/html/rcris/rcris_query_java.html. Many state hazardous waste agencies, and to a lesser degree EPA regional offices, have additional information about the corrective action needs of sites in their areas.

4.6 Remediation Technologies
Remedies selected for a given site may attain media cleanup standards through various combina tions of removal, treatment, engineering, and institutional controls. While EPA maintains current information on the general characteristics of RCRA sites in the RCRAInfo database, it has not compiled information on remedial action decisions at sites undergoing cleanup.
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Data on technology applications for 186 RCRA facilities are available from an EPA study completed in 1994 (U.S. EPA 1994c). Of 133 facilities treating groundwater, pump and treat was selected for 116 sites (87 percent) and innovative technologies were selected for nine sites (seven percent). The innovative technologies were in-situ bioremediation at four sites, ex-situ bioremediation for two sites, and unspecified bioremediation, thermal desorption, and chemical treatment for one site each. Of 86 sites Exhibit 4-6. Remedies Selected for Soil requiring soil treatment, at 86 RCRA Corrective Action Facilities established technologies were selected for 55 sites (64 percent), including capping and off-site disposal at 51 sites, incineration for one site, and other technologies for three sites. Innovative technologies, such as soil vapor extraction (SVE), bioremediation, and chemical treatment, were selected for 31 (39 percent) of the sites requiring soil treatment. Of the innovative technologies selected for contaminated soil, most were likely to be used to remediate halogenated and non-halogenated VOCs. Exhibit 4-6 summarizes specific innovative and established technologies applied or likely to be applied to soil contamination at the 86 sites requiring soil treatment. Another EPA study is available on remedies selected for 30 RCRA Corrective Action sites, 18 of which had ongoing cleanups while 12 had completed cleanups (U.S. EPA 2000c). EPA selected these sites from information readily available in 2000 on cleanups that had occurred or were underway between 1986 and 2000. The selected sites include a wide range of industries, such as wood treaters, chemical plants, refineries, paper mills, manufacturing facilities, and waste treatment plants, that vary in size, complexity, and contaminants. Seven of these sites selected soil vapor extraction--the most frequently used soil cleanup technology. Far less frequently selected in-situ technologies were bioremediation of soil and groundwater, bioventing, chemical oxidation, permeable reactive barriers, and air sparging. The ex-situ technologies selected included pump and treat, bioremediation, and thermal desorption. Projected remedies selected for facilities in the RCAID database were based on site characteri zation data collected in 1992 and 1993 (U.S. EPA 2002c). The final remedy information on 78 solid waste management units in RCAID showed that pump and treat (15 percent) and cap/cover (31 percent) were selected most often. Barrier walls were selected for 13 percent of the units, and

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soil vapor extraction was selected for nine percent. Pump and treat and cap/cover were also the most common stabilization measures taken at many facilities prior to selecting the final remedy. Information on final remedies selected for RCRA sites was found in 99 statements of basis. Most of the remedy or stabilization decisions reported in these documents were made in the mid 1990s. The most frequently selected remedies or stabilization measures for soil were excavation with off-site disposal, capping or cover, and in-situ soil vapor extraction. The remedies selected most frequently for groundwater were pump and treat and containment wall.

4.7 References
U.S. EPA (Environmental Protection Agency), 1980. 40 CFR Part 260.10, U.S. Environmental Protection Agency, 45 Federal Register, p. 33066, May 19. U.S. EPA, 1987. Hazardous Waste Miscellaneous Units, Applicable to Owners and Operators; Final Rule, U.S. Environmental Protection Agency, Office of Solid Waste, 52 Federal Register, p. 46946, December 10, 1987. U.S. EPA, 1990a. Corrective Action for Solid Waste Management Units (SWMUs) at Hazardous Waste Management Facilities; Proposed Rule (40 CFR Parts 265, 265, 270, and 217), U.S. Environmental Protection Agency, Office of Solid Waste, 55 Federal Register 145, pp. 30798 30884, July 27, 1990. U.S. EPA, 1990b. The Nation's Hazardous Waste Management Program at a Crossroads: The RCRA Implementation Study, U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response, EPA/530-SW-90-069. U.S. EPA, 1991. RCRA Stabilization Strategy, U.S. Environmental Protection Agency, Office of Solid Waste, October 25, 1991. U.S. EPA, 1993a. Corrective Action Management Units and Temporary Units; Corrective Action Provisions Under Subtitle C; Final Rule, U.S. Environmental Protection Agency, Office of Solid Waste, 58 Federal Register, p. 8658, February 16, 1993. U.S. EPA, 1993b. Draft Regulatory Impact Analysis for the Final Rulemaking on Corrective Action for Solid Waste Management Units Proposed Methodology for Analysis, U.S. Environmental Protection Agency, Office of Solid Waste, March 1993. U.S. EPA, 1994a. RCRA Corrective Action Plan (Final), U.S. Environmental Protection Agency, Office of Solid Waste, Directive 9902.3-2A, May, 1994. U.S. EPA, 1994b. Hazardous Waste Management System: Identification and Listing of Hazardous Waste; Treatability Studies Sample Exclusion, Final Rule (40 CFR Part 261), U.S. Environmental Protection Agency, Office of Solid Waste, 59 Federal Register 34, p. 8362, February 18, 1994.

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U.S. EPA, 1994c. Draft Analysis of Facility Corrective Action Data, U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response, Technology Innovation Office, January 1994. U.S. EPA, 1996a. Corrective Action for Releases from Solid Waste Management Units at Hazardous Waste Management Facilities; Advanced Notice of Proposed Rulemaking, ANPR, 40 CFR, U.S. Environmental Protection Agency, Office of Solid Waste, 61 Federal Register 85, pp. 19431-19464, May 1, 1996. U.S. EPA, 1996b. Hazardous Waste Identification Rule; Proposed Rule, U.S. Environmental Protection Agency, 61 Federal Register, p. 18780, April 29, 1996. U.S. EPA, 1996c. Coordination Between RCRA Corrective Action and Closure and CERCLA Site Activities, U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response, September 24, 1996. http://ww.epa.gov/swerffrr/doc/924memo.htm U.S. EPA, 1998a. Hazardous Remediation Waste Identification Rule (HWIR-Media) Final Rule, 40 CFR Parts 260, 261, 264, 265, 268, 270 and 271, U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response, 63 Federal Register 229, p. 65874, November 30, 1998. U.S. EPA, 1998b. Land Disposal Restrictions Phase IV: Final Rule Promulgating Treatment Standards for Metal Wastes and Mineral Processing Wastes; Mineral Processing Secondary Materials and Bevill Exclusion Issues; Treatment Standards for Hazardous Soils, and Exclusion of Recycled Wood Preserving Wastewaters, U.S. Environmental Protection Agency, 63 Federal Register 100, p.28555-28604, May 26, 1998. U.S. EPA, 1998c. Standards Applicable to Owners and Operators of Closed and Closing Hazardous Waste Management Facilities: Post-Closure Permit Requirement and Closure Process; Final Rule (40 CFR Parts 264, 265, 270, and 271), U.S. Environmental Protection Agency, Office of Solid Waste, 63 Federal Register 204, pp. 56710-56714, October 22, 1998. U.S. EPA, 1998d. Risk-Based Clean Closure, memorandum, U.S. Environmental Protection Agency, Office of Solid Waste, March 16, 1998. U.S. EPA, 2000a. Treatment Experiences at RCRA Corrective Actions, U.S. Environmental Protection Agency, EPA 542-F-00-020, Office of Solid Waste and Emergency Response, December 2000. U.S. EPA, 2000b. Economic Analysis of the Proposed Amendments to the Corrective Action Management Unit Rule (Background document), Office of Solid Waste, August 7, 2000. U.S. EPA, 2001. Transmittal of Guidance on Enforcement Approaches for Expediting RCRA Corrective Action, U.S. Environmental Protection Agency, Office of Enforcement and Compliance Assurance, January 2, 2001.

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U.S. EPA, 2002a. Amendments to the Corrective Action Management Unit Rule, U.S. Environmental Protection Agency, Office of Solid Waste, 67 Federal Register 14, p. 2961-3029, January 22, 2002. U.S. EPA, 2002b. Handbook of Groundwater Protection and Cleanup Policies for RCRA Corrective Action for Facilities Subject to Corrective Action Under Subtitle C of the Resource Conservation and Recovery Act, U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response, EPA/530/R-01/015, October 17, 2001, 66 Federal Register, pp. 52762-52763, September 2002. U.S. EPA, 2002c. A Study of the Implementation of the RCRA Corrective Action Program, and Highlights from A Study of the Implementation of the RCRA Corrective Action Program, Environmental Protection Agency, Office of Solid Waste, April 9, 2002. U.S. EPA, 2003a. Final Completion of Corrective Action Activities at RCRA Facilities, U.S. Environmental Protection Agency, Office of Solid Waste, 68 Federal Register 37, p. 8757, February 25, 2003. U.S. EPA, 2003b. RCRAInfo electronic database, U.S. Environmental Protection Agency, Office of Solid Waste, March 2003. U.S. EPA, 2003c. Results-Based Approaches and Tailored Oversight Guidance for Facilities Subject to Corrective Action Under Subtitle C of the Resource Conservation and Recovery Act, U.S. Environmental Protection Agency, Office of Solid Waste, September 2003.

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Chapter 5 Underground Storage Tank Sites
Underground storage tanks (USTs) are used by a wide variety of industries, such as petroleum and chemical manufacturing and distribution, transportation, agriculture, and government. About 680,000 active tanks are currently subject to federal regulations. Ninety-six percent of these contain petroleum products, including used oil. Less than four percent contain hazardous substances. In addition, more than 1.5 million federally regulated USTs have been closed. Subtitle I of the Hazardous and Solid Waste Amendments to the Resource Conservation and Recovery Act (RCRA) was enacted in 1984 to control and prevent leaks and spills from USTs. Subtitle I governs USTs storing regulated substances, including gasoline, aviation fuel, diesel fuel, other petroleum products, and hazardous substances defined under the Superfund program. Pursuant to Subtitle I, EPA has promulgated regulations requiring, among other things, that leaks and spills be remediated and future releases be prevented. These regulations have compelled cleanup activities at many UST sites, providing opportunities for the application of a variety of remediation technologies. Releases of petroleum or hazardous substances can result from a spill during tank filling operations, leaks in the tank or pipes attached to the tank due to corrosion, structural failure, or faulty installation. As of March 31, 2004, more than 443,000 releases from federally regulated USTs had been confirmed (U.S. EPA 2004). These releases can contaminate soil and groundwater and cause fire or explosions. While considerable progress has been made in cleaning up contamination from underground storage tanks during the last decade--more than 311,000 contaminated sites have been cleaned up--many more remain to be remediated.
Highlights
· Although considerable progress has been made

·

·

·

·

·

· ·

in cleaning up UST sites over the past decade, it is estimated that 95,000 to 155,000 UST sites will require cleanup under the RCRA underground storage tank regulations. This estimate includes 35,000 already identified sites that have not yet been cleaned up plus an estimated 60,000-120,000 sites that may have future releases over a 10-year period. Although new reported releases of contaminants from tanks may continue beyond 10 years and tank leakage rates may decline, these scenarios are not included in this report because of uncertainties in predicting these trends. The cost of these cleanups could reach $12-19 billion. This estimate does not include costs related to replacing, testing, or upgrading tanks, pipes, and related equipment. The year-to-year fluctuations in the number of cleanups will depend on the availability of funds from public and private sources; the failure rate of tank systems; cleanup cost savings through the growing use of newer site management approaches; and additional site characterization and remediation costs that may result from sites that are difficult to remediate (e.g., MTBE). Since 1998, the number of confirmed releases reported to EPA has been declining. Nevertheless, it is expected that there will always be some additional releases in the future. UST tank sites account for over 43% of all waste sites estimated in this report to be cleaned up. The average UST site is typically smaller and less costly to remediate than those of most

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5.1 Federal Program Description
The federal regulatory program is implemented by EPA's Office of Underground Storage Tanks (OUST). The federal UST technical requirements and state program approval regulations were promulgated in September 1988 and became effective on December 22, 1988 (U. S. EPA 1988). These regulations, to a large extent, determine the size of the market for cleanup services. The regulations apply to any UST, except those specifically exempted, excluded, or deferred, used to store petroleum products or substances defined as hazardous under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). The regulations do not apply to tanks storing hazardous wastes regulated under Subtitle C of RCRA. An UST is defined as any tank that has at least 10 percent of its volume buried below ground, including piping connected to the tank. Generally, the requirements for tanks containing chemicals are somewhat more stringent than those containing petroleum products. The basic federal requirements include: · A tank owner must register his or her tank(s) with the state authority by completing a
notification form about the characteristics and contents of the UST.
· A tank owner must institute a periodic leak detection program to actively seek out releases. For tanks installed after December 1988, leak detection requirements become effective at the time of installation. For older tanks, the requirements were phased in over time with a final completion date of December 1993. · A tank owner must maintain records of leak detection activities, corrosion protection system inspections, repair and maintenance activities, and closure site assessments. · A tank owner must notify the appropriate regulatory authority of all suspected or confirmed releases as well as follow-up actions taken or planned. Suspected leaks must be investigated immediately to determine if they are real. If evidence of environmental damage is the cause for suspicion, it must be reported immediately to the regulatory authority. · If a leak or spill is confirmed, tank owners must: (a) take immediate action to stop and contain the leak or spill; (b) notify the regulatory authority within 24 hours or other reasonable time period specified by the implementing agency; and (c) take action to mitigate further damage to people and the environment. · All USTs must be protected from corrosion and have devices that prevent spills and
overfills, in accordance with EPA's upgrade and new tank standards.
· A tank owner closing an UST must notify the regulatory authority 30 days before permanent closure.

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The following kinds of tanks are currently exempt or excluded from the regulations: · Farm and residential tanks holding 1,100 gallons or less of motor fuel used for non
commercial purposes.
· Tanks storing heating oil for use on the premises. · Storage tanks on or above the floor of areas such as basements or tunnels. · Septic tanks. · Storm-water and waste-water collection systems. · Flow-through process tanks. · Tanks holding 110 gallons or less. · Emergency spill and overflow containment UST system. · Certain pipeline facilities, including gathering lines regulated under other federal or state
statutes.
· Surface impoundments, pits, ponds, or lagoons. · Liquid traps or associated gathering lines directly related to oil or gas production and
gathering operations.
· UST systems holding hazardous substances listed or identified under Subtitle C of RCRA. · Any wastewater treatment tank system that is part of a wastewater treatment facility
regulated under Section 401 or 307(b) of the Clean Water Act (CWA).
· Equipment or machinery that contains regulated substances for operational purposes, such as hydraulic lift tanks and electrical equipment tanks. · Any UST system that contains a de minimis concentration of regulated substances. In addition, certain categories of tanks, known as deferred USTs, are not yet subject to the full federal UST regulations. Until EPA decides how to regulate these USTs fully, the only regulations that apply are Subpart A (Interim Prohibition) and Subpart F (release, response, and corrective action). Examples of deferred tanks include underground, field-constructed, bulk storage tanks, and UST systems that contain radioactive wastes. Changes in the types of tanks covered by the regulations could significantly impact the potential size of the market. However, EPA is not contemplating any such changes at this time. Although these categories of tanks are currently excluded from federal regulations, some of them may be subject to state regulations. EPA designed the UST program to be implemented by the states. Authority to implement the program is delegated to states through either the formal process of obtaining state program approval (SPA) or a cooperative agreement. Thirty-three states, the District of Columbia, and Puerto Rico have all been approved to act in lieu of the federal program. Most of the other states operate their own program under their own laws with limited federal oversight. The Act also allows for states to have more stringent requirements than that of the federal regulations. For example, some states may include home heating oil tanks in their program. EPA supports state programs by providing resources from the federal Leaking Underground Storage Tank Fund (LUST Trust Fund), grants to states and tribal programs, technical assistance, training, and information exchange.

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5.2 Factors Affecting Demand for Cleanup
The demand for remediation services at contaminated UST sites primarily will be influenced by federal regulations, state requirements, and the number of releases occurring at old and new tanks. The timing of these cleanups will be influenced by the availability of state and federal funds for site assessment and cleanup of UST sites and the pace of economic development. 5.2.1 General Trends In October 2002, EPA established a national goal of completing between 18,000 and 23,000 cleanups each year for the fiscal years 2003-2007. If EPA is able to meet this goal, the backlog of sites needing remediation, which has remained steady over the past decade, will be halved by 2007. Exhibit 5-1 shows the number of sites in the backlog since 1991 (U.S. EPA 2003c). Exhibit 5-1. Backlog of UST Site Cleanups to be Completed

A number of factors led to an increase in the number of confirmed releases in 1997 and 1998, including the implementation of leak detection requirements (which became effective in 1993); tank upgrading requirements to prevent spills, overfills, and corrosion (which became effective in 1998); and reporting requirements. Since 1998, the Exhibit 5-2. Confirmed Releases at UST Sites number of confirmed releases has almost steadily declined from 29,600 to 12,000 (Exhibit 5-2). During the last three years, they have ranged from 6,000 to 12,000 and averaged 9,000. As more tanks come into compliance, the number of new releases is expected to continue to drop. However, it is expected that there will always be releases in the future. Many older tanks still exist and many older, as well as upgraded tanks, are not in full compliance.

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The failure rate of tank systems is determined by such factors as tank age, material of construction, corrosion protection systems in place, and other design and site-specific factors such as soil type, weather, and operations and maintenance practices. Because information on these factors is limited, estimates of market size are subject to some uncertainty. The following observations have been made about some of the factors that influence tank failure rates. · While none of the states Exhibit 5-3. Compliance Status of USTs by Region are in full compliance
with EPA's leak
detection and upgrading
requirements, most of the
tanks that states monitor
had the required leak
prevention and detection
equipment installed as of
September 2003. The
compliance rates were 79
percent for release
prevention and 72 percent
for leak detection. Region
9 had the highest
percentage of operational
compliance with release
prevention requirements
(93%), while Region 3
had the lowest (69%). For
leak detection
requirements, the range
was from 89 percent (Region 9) to 55 percent (Regions 1 and 10). However, there is
variation in the reporting by the states, since some states' reports are based on more
stringent requirements. (Exhibit 5-3)
· According to a 2003 GAO report (based on data collected in 2001 and 2002), 29 percent of tanks are not operated and maintained properly, thus increasing the chance of leaks and posing health risks. In addition, over half of the states are not inspecting all of their tanks at the minimum rate of at least once every three years recommended by EPA (U.S. GAO 2001, and 2003). This implies that even if the backlog of all known sites is eliminated, there are likely to be additional releases at some sites in the future. · GAO also estimates that 11 percent (76,000) of the active regulated tanks that states monitor and 30 percent of tanks on tribal lands, may not be upgraded (U.S. GAO 2003). Most of these tanks are believed to be empty or inactive. States reported to GAO that they generally do not discover tank leaks or contamination around tanks until the empty tanks are removed from the ground during replacement or closure. Thus, there is a backlog of potentially contaminated sites that may be discovered over a period of time as they are replaced or removed.
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· Despite the upgraded equipment, a number of states reported to GAO that upgraded tanks leaked. GAO cites that researchers have concluded that tanks with upgraded equipment and monitoring systems do not provide complete protection against leaks. However, the extent of this problem is unknown. 5.2.2 State Regulations and Funding Sources Some states have promulgated requirements that are more stringent than the federal standards, such as a requirement for double-lined tanks, more stringent monitoring procedures, or earlier upgrading compliance dates. The pace of the cleanups is affected by the availability of funds to pay for cleanups and oversight. UST cleanups are primarily financed from three sources: · The federal Leaking Underground Storage Tank Fund (LUST Trust Fund). Revenues from the fund are derived from a gasoline tax of 0.1 cent per gallon. Appropriations from the fund have been about $70-80 million annually.1 · State tank trust funds or direct appropriations are generally used to assist owners and PRPs in paying for cleanups. A number of these are also financed by gasoline taxes. Between 1999 and 2003, the annual revenues of these funds averaged $1.3 billion and they paid out an average of about $1.1 billion annually. · PRPs and site owners. State Tank Funds 1999-2003 (Billions of Dollars)
1999 Revenues Approximate amount paid 1.38 0.70 2000 1.19 1.49 2001 1.21 0.68 2002 1.34 1.49 2003 1.37 1.16 Average 1.30 1.10

Source: Association of State and Territorial Solid and Hazardous Waste Management Officials, State Fund Survey Results 2003.

EPA regulations that limit the liability of lenders for corrective action in many situations help to encourage the extension of credit to credit-worthy UST owners. The availability of credit to UST owners, especially the many small businesses that operate USTs, is necessary to assist them in meeting their obligations to upgrade, maintain, and otherwise comply with RCRA Subtitle I and

The gasoline tax is scheduled to expire in 2005. The federal LUST Trust Fund helps states oversee corrective action and pay for cleanups at UST sites where the owner or operator is unknown, unwilling, or unable to respond, or which require emergency action. Most of the money appropriated from the fund goes to states, which use the funds to oversee corrective action by responsible parties, to clean up sites where no responsible party can be found, and for enforcement and administration. As of the end of 2003, the balance was $2.1 billion. Chapter 5: Underground Storage Tank Sites Page 5-6

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related environmental requirements. Under these regulations, which were promulgated in 1995, any person or lending institution that guarantees loans secured by real estate containing an UST or UST system may not be liable for the required corrective action, so long as the lender is not otherwise engaged in petroleum production, refining, or marketing (U.S. EPA 1995b). 5.2.3 2002 Brownfields Legislation and EPA's USTfields Initiative The 2002 brownfields law, titled "The Small Business Liability Relief and Brownfields Revitalization Act (P.L. 107-118)," and EPA's USTfields initiative may lead to an increase in the total number of UST sites identified as needing cleanup as well as the pace of cleanups. This potential increase would result from the increased number of site assessments completed. The increased pace of cleanups could result from additional funds made available under the new law. As many as 200,000 of the estimated 500,000 brownfield sites across the country are impacted by petroleum leaking from USTs, and many of these sites are gas stations that have shut down because they could not comply with the 1998 federal UST upgrade requirements (NEMW 2001). These properties pose threats to public health and the environment, and pose challenges for the redevelopment plans of the communities in which they are located. Many UST cleanups are funded using state assurance funds, which usually do not have sufficient money to clean up all of the eligible sites in a given year. This scarcity of money has contributed to the backlog of over 136,000 sites nationwide that have not completed cleanup. The new brownfields law may help address this backlog. This law expands the current EPA Brownfields program and for the first time, allows "low-risk" petroleum sites to be eligible for assessment and cleanup grant funding under the Brownfields program. Prior to the new law, petroleum contamination was not eligible for Brownfields funding. The law authorizes up to 25 percent in grant awards annually through 2006 for the assessment and cleanup of brownfields contaminated with petroleum. In FY 2003, EPA awarded 103 new Brownfield Petroleum grants totaling $22.3 million. This new authority builds upon and complements EPA's USTfields Initiative, which addressed "high-priority" petroleum-contaminated properties and awards funds to states, tribes, and intertribal consortia. Under the USTfields Initiative, $4.8 million in grants were awarded to 36 states and three tribes to cleanup properties contaminated from leaking USTs. Although no further USTfields grants are planned, the petroleum grants under the Brownfields program continues to encourage further site assessments, cleanup, and redevelopment. 5.2.4 MTBE Contamination and the Remediation Market Concerns about methyl tertiary-butyl ether (MTBE) contamination may influence the amount and timing of UST cleanups in some states. According to a 2003 survey of 50 states conducted by The New England Interstate Water Pollution Control Commission (NEIWPCC 2003), MTBE is detected in gasoline releases to groundwater 60 percent of the time, averaged among the states. Most states do not intend to open closed sites to look for MTBE or tertiary-butyl alcohol (TBA), unless they have reason to suspect a problem. Most states say there are very few cases where MTBE is the only concern. Thirty-three states say that MTBE drives cleanup and investigative efforts less than 20 percent of the time, or never. BTEX and free-product is the primary

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remediation driver in these states. In most states, less than 10 percent of the sites have situations where BTEX has been successfully remediated but MTBE remains. Nevertheless, some states, such as California and New York, indicated that MTBE contamination drives remediation at LUST sites more than 80 percent o