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E-M:/ LUSTS (Leaking Underground Storage Tanks): A Deadly Sin!



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Enviro-Mich message from joonmck <joonmck@gateway.net>
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Dear Emers,
 
I agree with Alex Sagedy. Jeremy Pearce's Detroit News article on LUSTS
is timely and very good.  All Michigan-based elementary and high school
science teachers should print out a copy of that article and insert it
into their curricula, pronto! 
 
Last year, in my extensive research and writing on Ingham County's
environmental health, I also dug up some not-so-lusty data on the
underground gas tanks in the greater Lansing area. It has yet to see
print, so I'm choosing this venue to give it some visibility. I
encourage all science teachers and environmentalist-oriented folk to
give it a read, and if you find it worthy, add it to Pearce's piece in
your LUST file (no Playboy or Playgirl clips allowed).  

(there is some valuable data I uncovered on the "most serious" sites,
you can scroll below to see the tables). 

Here it is:  
 
Leaking Underground Storage Tanks (LUSTS),
Most are from former Gas Stations
 
"When I got into this business, back in 1984, LUSTS were given little
attention. Since then the state has created an entire division dedicated
to nothing else but tanks. I could never have foreseen this. We've spent
about $800 million, across the state, to address the problem so far."
.....DEQ Storage Tank Worker 
 
We zip into the corner gas station for a tank-full, but unbeknownst to
many of us is the fact that the 10,000-gallon storage tank buried under
the pump may have leaked hundreds of gallons of potentially hazardous
petroleum products into the groundwater. The Michigan Department of
Environmental Quality lists 33 sites in Ingham County -- including one
or more sites owned by Amoco, Total and General Motors -- as Class 1
leaking underground storage tank sites (LUSTS), meaning that they are
"an immediate threat to human health, safety, or sensitive environmental
receptors." The tanks under most gas stations in the county are not
leaking, but the ones that have leaked -- especially the most dangerous
ones -- deserve more public scrutiny than they have so far received.
 
LUSTS Sound Sexy, What are they Exactly?
 
They are a byproduct of the petroleum age. Ingham County uses hundreds
of thousands of gallons of oil and oil byproducts, such as gasoline,
each day. A large amount of this material is stored in tanks and an
estimated 20 to 40% have leaked. Unchecked, they have the potential to
render an area's entire drinking water supply useless. In the U.S. there
are well over six million underground storage tanks. Of these about one
third are large commercial tanks used by gasoline stations, airports and
refineries. Nobody knows how many are leaking but the EPA has estimated
that about 300,000 to 500,000 are leaking. That amounts to about 15 to
25 percent. 
 
Like the Y2K problem, there was little thought given to the
environmental consequences of placing tanks underground in the 1940s
through 1960s. The Michigan Department of Environmental Quality did not
seriously confront the issue until 1984 when it established new
guidelines that were intended to stop the leaks.
 
Across the state 37,000 LUSTS have been closed or removed since 1986 and
at least 48 municipal well systems have been affected. As of January,
2000, Ingham County has more than 1,900 underground storage tank
facilities (USTs) of which 499 have been identified as leaking
underground storage tank sites (LUSTS), about a 25% leakage rate. Of
these LUSTS, 281 are "active," meaning that they are currently
undertaking remediation of the contamination (but are not yet cleaned
up), and 207 are "closed" meaning that the owners or the state completed
the required remediated action.
 
How are LUSTS Prioritized for Clean-Up?
 
In 1995 the Michigan Department of Environmental Quality developed a
four-tiered classification system for assessing LUSTS. Class 4 sites
show no demonstrable long-term threats to human health and include
impacted soils greater than 50 feet above the Aquifer. Class 3 sites are
considered to be a long-term (will not be a problem for at least 2
years) threat to health, safety or the environment. For example,
groundwater might be impacted but it is not expected that contaminants
will impact water supply wells for at least 2 years. Class 2 sites are a
"short-term threat to human health, safety or the environment. For
example, a public water supply may be affected by the contaminants
within the next two years.
 
The greatest attention is paid to Class 1 sites, which are designated to
be an "immediate threat to human health, safety, or sensitive
environmental receptors." For example an active public or private water
supply well is impacted or immediately threatened. Ingham County has 44
Class 1 sites (see below). Significantly, the number of sites designated
as Class 1 facilities has increased by 25% since 1999 (when it was 35
sites). According to Carol Stuht, a Department of Environmental Quality
Official, "it can be safely assumed that many Class 1 sites have
impacted the groundwater."
 
Brian Muench, the DEQ inspector for Ingham County, says that indeed,
"Class 1 sites are clearly a serious risk and some have impacted the
groundwater, but adds that "in most cases a Class 1 designation is not a
serious threat to human health or potable water at all." The impacted
groundwater is "most likely a shallow unusable aquifer. . . .It may just
be free product that is localized [around the clay]" and traveling very
slowly. This is the case with Michigan Bell, an Ingham County site
located at 115 West Ionia St. in Lansing. "The leak is contained in a
small place, a shallow unusable aquifer, but any site with free product
must be labeled a Class 1 and abated."
 
Then why are sites like Michigan Bell classified as "immediate threats?"
"Because anytime there is a leak, there must be an immediate response. 
 
Thus a Class 1 site may not be "an immediate threat to human health or
safety," but still be an immediate threat to "sensitive environmental
receptors." If there is a threat of explosion or well water, Muench says
that "emergency monies are available." If there is an acute problem,
"the responsible party will do the testing and supply bottled water" to
nearby well owners.
 
Thus, while all Class 1 sites are serious, they are not all of the same
level of concern. "They run the gamut from the less serious like
Michigan Bell to the sites of greatest concern like General Motor's BOC
Plant 1 (at 920 Townsend St. in Lansing) and Ameritech (at 340 North St.
in Mason). These are the sites with the largest underground plumes.
According to Shaw, "the GM LUST is currently being remediated. They have
put in deep wells and are recovering free product." Americhem -- which
is also being remediated --is considered by some within the MDEQ to be
the most significant site of environmental contamination in the County
because of its proximity to three of Mason's six municipal wells (this
is discussed below).
 
Still, some Class 1 sites are inactive, meaning that nothing is
currently being done to address the contamination. Clean up of a site is
very expensive, often costing in the hundreds of thousands of dollars.
And the responsible party may be long gone. For example, an old
abandoned Action Auto site at 2635 S. Williamston Rd. has been
classified as an "orphan site" because there is no one available to
remediate it. It has been nominated for state monies but there is no
guarantee that it will be addressed any time soon. So, despite the best
efforts of the DEQ storage tank division, the public is left with a
troubling contradiction. On the one hand, we are informed by the State
of Michigan that Class 1 sites are an immediate threat to human health
or the environment. On the other hand, little is being done at some
Class 1 sites to fix the problem.
 
DEQ officials say that clean up is a very time consuming process,
especially when the "responsible party" has failed to do it. They insist
that Class 1 tanks get priority attention, "otherwise we can't seek cost
recovery which we are mandated to pursue." The DEQ first tries to get
the liable parties to do the work, then, if that doesn't work, try other
means including placing them on a list for state-funded clean-up, though
that could take years. There is still a long-way to go. If the leaker is
a wealthy corporation that can afford the clean-up costs, then civic
pressure should be mobilized to make them do go forward with the
mitigation.
 
Leaking Underground Storage Tanks, By Type, Ingham County (April 1999)
 
Total Number of Business Sites with Leaking Underground Storage Tanks
(all classes): 499
 
Total Number of Confirmed Releases from Leaking Underground Storage
Tanks at the above businesses (a facility may have multiple confirmed
releases): 629
 
Number of Business sites with Class 1 Leaking Underground Storage Tanks
("an immediate threat"); see below for locations. (April 2000 figure):44
 
Total Number of Confirmed Releases that resulted in a Class 1
determination. (April 2000 Figure): 74
 
Total number of Class 1 facilities that are currently being remediated:
To find out, please contact the MDEQ's Shiawassee District Office at
(517) 625-4619.
 
Why Should You Be Concerned?
 
Your health is one reason. Benzene has been found to be a major
contaminant of groundwater as a result of leaching from underground
gasoline storage tanks. Still, you must keep in mind that the most
common route of benzene exposure occurs at the gas station when you fill
your tank. However, if you own a private well close to a LUST, you
should be concerned about the quality of your drinking water. There is a
small chance that you could be ingesting volatile organic compounds like
toluene, xylene, phenol, tetrachloroethylene and MTBE, an additive added
to gasoline to reduce carbon monoxide and ozone. A simple VOC test or an
organic solvents screen can confirm if one's well has been impacted.
They cost more than a regular water test but are important if you are on
well water. For information on where to get this test, please contact
the Ingham County Health Department.
 
Economics is another reason. The DEQ has closed a number of municipal
wells in Ingham County because of LUST contamination. At a
quarter-million dollars per well construction, that's more than pocket
change for water consumers. The good news is that if you are on
municipal water, your drinking water is not affected. However, some
leaks continue to drift close to municipal wells, and are a continuing
concern.  State and local officials and residents have established six
"wellhead protection programs" in Ingham County to protect the most
vulnerable municipal wells from contamination of all kinds.
 
Also, you should be aware that not all USTS are monitored by the DEQ,
meaning that Michigan residents do not have to register a wide range of
smaller tanks, such as a tank used exclusively for home heating oil for
consumptive purposes on the premises where the tank is located. However
some tanks, such as farm and residential tanks holding less than 1,100
gallons of motor fuel, might have impacted shallow drinking wells and
caused human health problems. According to a DEQ official, the danger is
more in rural areas than in urban areas and in private water supplies.
"A tank is a tank is a tank," said one official. Any spills, no matter
what the size of the tank must be reported to the DEQ.
 
The good news is that in 1987 the EPA put in new guidelines that were
intended to stop the leaks. They had three essential elements: 1) new
underground tanks needed to be made of non-corrosive materials (such as
fiberglass, which degrades more slowly), 2) all new tanks must be
equipped with leak detector systems. In addition, owners of commercial
tanks must carry at least $1 million in liability insurance to help pay
for clean-up efforts (a requirement that caused many small operators to
go out of business). Operators were given a decade to comply with the
new regulations.
 
The compliance date was December 22, 1998. Everyone who was out of
compliance were subject to a $11,000 fine per day, according to EPA
guidelines. In Ingham County there were 93 facilities that did not meet
the EPA guidelines by of December 1999. About 30% of these facilities
were "red tagged" meaning that that tank essentially was not permitted
to be used commercially anymore. Fortunately, through DEQ enforcement
action, as of June 7, 2000, only 18 sites remain non-compliant with EPA
guidelines. Still, despite the threat of fines, to date only two owners
have been fined in all of Michigan. The DEQ prefers to seek voluntary
compliance and avoid timely court battles. However, with the new
guidelines in effect that percentage of leakers should decline
substantially from the 25% rate, though some critics still expect a
10-15% leak rate.
 
But The Number of UST sites (and by implication LUSTS) may be seriously
underestimated.
 
New USTS keep popping up. According to Bill Haun, a former UST
inspector, "they are like potatoes, once you dig up one another one
appears." When an assessment was conducted for a new Rite Aid recently,
(at Greenlawn and North Cedar in Lansing,) the new owners found a tank
that nobody had known was there. Many empty corners in 
Lansing once harbored a gas station, but records proving their existence
are often lost. "Many of these corners have never been assessed," said
Haun. Carol Stuht, a DEQ official, agrees, "every year abandoned tanks
are found when property is assessed prior to a sale."
 
According to Bob Godbold, Environmental Health Director at the Ingham
County Health Department, we do not yet have enough evidence to
characterize the scope of the problem at many LUST sites. Godbold says
that, in order to properly assess the horizontal and vertical extent of
soil and groundwater contamination, the owner must conduct a
hydro-geological investigation of the Saginaw Formation aquifer. He said
that this is not always done. Ben Shaw, with the DEQ argues that such an
assessment is not always required. Muench said that "if it is a small
release, we can assess whether the plume extends to the Saginaw Aquifer
using other scientific methods."
 
Although Ingham is blessed with clay soils (which provide some
protection against the movement of these contaminants down from the
surface), we have a high water table (of about 10 feet). Thus there is a
high potential for water pollution. There are roughly 12,000 drinking
wells in the County, 281 active LUST sites, and hundreds of unregulated
small tanks, in addition to countless unknown LUST sites that can impact
well water.
 
Who is Responsible for the Worst Sites?
Businesses that Own (or have Owned) LUST Sites that are an 
Immediate Threat to Health, Safety or the Environment (Class 1)
In Ingham County
Michigan Department of Environmental Quality
(April 2000)
 
Company // Business // # of facilities // # of Confirmed Releases

General Motors// Car Manufacturer // 1 // 14
Total // Gas Station // 7 // 9
Amoco // Gas Station // 4 // 7
Action Auto // Gas Station // 4 // 6
Shell Oil // Gas Station // 2 // 4
Bay // Gas Station // 2 // 3
Admiral Petroleum // Gas Station // 2 // 2
Americhem Corporation // Chemical Company // 1 // 2
Checker // Gas Station // 1 // 2
Citgo // Gas Station // 1 // 2
Clark // Gas Station // 1 // 2
Muggs & Bopps // Gas Station // 1 // 2
Quality Dairy // Food store // 1 // 2
Waverly Service Building // Service // 1 // 2
Aeroquip Corporation // Aircraft Supplier // 1 // 1
Campus Marathon // Gas Station // 1 // 1
Fresh Up Car Wash // Car Wash // 1 // 1
Lansing Board of Water and Light // Utility // 1 // 1
Michigan Bell // Communications // 1 // 1
Michigan State University // Education // 1 // 1
Miller Oil Company // Petroleum // 1 // 1
Mobil // Gas Station // 1 // 1
MSI // Gas Station // 1 // 1
Paul's marathon // Gas Station // 1 // 1
Subway (formerly Fuller Service station) // Gas Station // 1 // 1
Superstop // Gas Station // 1 // 1
University Service Center // Service // 1 // 1
Vacant Lot east of Tan Faster // Unknown // 1 // 1
VFW National Home // Cultural Institution // 1 // 1
 
IF ANYONE WOULD LIKE THE ADDRESSES FOR THESE CLASS 1 SITES PLEASE
CONTACT ME!

We need to have better information about: 1) the extent of residential
knowledge about local LUST sites in their communities; 2) the number of
domestic wells that are within 500 feet of LUST site; 3) the level of
remediation at the Class 1 sites; and 4) the number of LUSTS that are
close to abandoned wells, particularly if they are in a wellhead
protection area. Priority must be given to the fourth area.
Unfortunately, we don't know where most abandoned wells are located.
Research is still in its infancy (see below).
 
What Should Be Done to Address the Problem?
 
The 1987 EPA guidelines have gone a long way in addressing the problem.
However that is not sufficient. According to one observer, we must place
tanks into a "secondary containment" (basically a bathtub beneath the
tank or a double walled system around the tank) in wellhead protection
areas. Wellhead protection is a planning and management program to
protect the groundwater from contamination by managing or controlling
all potential sources of contamination within an area surrounding a well
field. 
 
The EPA does not require secondary containment on new tanks. Secondary
containment is, according to the Environmental Defense Fund, the only
technical fix that might prevent USTs from leaking directly into soil
and water. Instead the new EPA regulations require tanks that are
cathodically protected (a corrosion protection method) steel, or
fiberglass, or a steel tank clad with fiberglass. According to Liz
Browne, a DEQ official, one reason that the EPA did not require
secondary containment on all tanks was because of lobbying pressure from
petroleum industries. 
 
DEQ officials assert that all new tanks in wellhead protection areas
already have secondary containment. However there is dispute by the
Ingham County Health Department, about whether the DEQ is even aware of
where the wellhead protection areas are located. 
 
The dispute centers around the definition of a "wellhead protection
area." Apparently the DEQ does not include a wellhead "delineation" area
as a regulated area. But the law says that it must. Delineation is the
first step towards achieving the formal distinction of being a wellhead
protection area. If the DEQ properly enforces this law, they must insist
upon secondary containment in 6 wellhead delineation regions (East
Lansing, Lansing Township, the City of Lansing, Delhi Township, Meridian
Township, and Michigan State University). But there is reason to believe
that the DEQ is only enforcing the law in two areas of Ingham County,
those who have achieved the official status completed a long process of
approval as a "wellhead protection area." These are Lansing Township and
Delhi Township. We are currently investigating the matter.
 
If you want to view a map of the delineation areas, and find out whether
your home is within a wellhead protection area, go to the DEQ's Surface
Water Division web site at: http://www.deq.state.mi.us/dwr/wpu/wpu.html
 
What you can do
 
If you live in a rural area, have a shallow well under 150 feet, or your
private well is located near a LUST site, by all means get your water
tested. Do not worry about the expense. According to Brian Muench, the
good news is that the potential responsible party (ex. Americhem in
Mason) will usually do this for free, "or their insurance company [will
do so] if [your home] is down gradient because they don't want to be
sued."  
 
If you live in an urban area -- the most immediate threats are Class 1
sites in urban areas -- learn about the Class 1 LUST sites in your
neighborhood and contact your local public official to spur remediation
of the site. 
 
Another thing you should do, if you live in a wellhead protection area,
is to find out whether or not there is an old abandoned well on your
property. If so you can get it quickly plugged at no expense to you. The
next section tells you more about the problem.

To find out more about LUSTS in Ingham County visit the MDEQ's web site
at: http://www.deq.state.mi.us/dwr/wpu/wellhead/wellhd.html
 
LUSTS should be restricted to the Red Light district! But the deadly sin
is lurking beneath us nearly everywhere we go. Given the ubiquity of
Michigan's carnivorous car culture - which demands a feeding at nearly
every corner - LUSTS could be ruin of the huge sections of the Saginaw
Aquifer if un-addressed. 
 
In Solidarity, 
 
Brian McKenna, Ph.D.
Environmentalist &
Anthropologist

"If there are connections everywhere, why do we persist in turning
dynamic, interconnected phenomena into static, disconnected things?" 
        -- Eric R. Wolf, Anthropologist (1923-1999)


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