=======================Electronic Edition========================
RACHEL’S HAZARDOUS WASTE NEWS #24
—May 11, 1987—
News and resources for environmental justice.
——
Environmental Research Foundation
P.O. Box 5036, Annapolis, MD 21403
Fax (410) 263-8944; Internet: erf@igc.apc.org
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NEW UNDERGROUND STORAGE TANK RULES ARE UNLIKELY TO PROTECT NATION’S
DRINKING WATER SUPPLIES.
There are 1.4 million underground storage tanks containing petroleum products or other hazardous
chemicals in the United States, says the EPA (U.S. Environmental Protection Agency) and about 20% of
these (or 280,000 tanks) are leaking today, the agency estimates. The other 80%, of course, will leak some
time in the future, since all human creations are subject to the ravages of time.
EPA has studied the tanks that are leaking today and has concluded that 60% leak because of corrosion,
25% because of improper installation and structural failure, 10% from loose fittings, and the remaining 5%
because of spills and overfills.
To combat this clear and present danger to the nation’s supply of clean water, the EPA in April issued
proposed rules that all tank owners/operators will have to follow (after the rules are finalized, after a lengthy
process of public hearings, rewriting and reissuance).
Under the proposed rules, owners or operators of underground storage tanks (USTs) will have to install leak
detection systems and to demonstrate the financial ability to clean up any messes their tanks make.
The EPA’s proposed regulations are particularly tough on 54,000 tanks (4% of the total) that contain any of
701 specific toxic chemicals listed in the Superfund law (CERCLA, the Comprehensive Environmental
Response, Compensation and Liability Act). NEW tanks built to hold any of these 701 chemicals must be
supplied with a “secondary containment” system aimed at preventing leaks into the general environment. A
“secondary containment” system could be a second tank inside the first tank, or it could be a concrete tank
built around the first tank, or it could be some kind of “impervious” plastic liner installed around the first
tank. Leak detection systems will be required between the first tank and the secondary containment system.
Existing tanks holding any of these 701 chemicals must, within 10 years, comply with the same requirements
as new tanks. But the EPA has already announced that variances will be available at the end of ten years for
those owners who demonstrate that their tank is protected against corrosion and equipped with an effective
leak detector.
Editorial comment: The EPA’s proposed regulations seem certain to contaminate the nation’s underground
water supplies. Even the “secondary containment” systems required for hazardous chemical tanks will not
prevent environmental contamination though they will reduce the rate at which contamination occurs. or
many of the same reasons that double-lined landfills will all eventually leak, double-lined underground
storage tanks will all leak sooner or later. A double-lined tank will leak later, rather than sooner, meaning that
our grandchildren will pick up the tab, not we. But leak they will.
However, the most glaring problem with the EPA’s proposed regulations is its clear failure to keep gasoline
out of the nation’s water supply. Half the nation’s underground storage tanks (700,000 of them) contain
gasoline; every service station today has an underground gasoline tank, if not more than one. Gasoline is a
rich mixture of toxic chemicals. For example, gasoline is 2% to 5% (or more) benzene, 6% to 8% toluene, 1%
to 1.5% ethyl benzene, 2% to 5% xylene, and so on. Even the additives to gasoline are themselves often
toxic, such as ethylene dibromide, which the government recently banned as a fumigant for much of the
nation’s grain supply because it is carcinogenic. No doubt the most famous additive is lead, which is now
being phased out because of its toxicity to humans and other forms of life. Unfortunately, as lead is phased
out, the benzene content of gasoline is being increased to keep the gasoline’s octane rating up.
Benzene is a potent human carcinogen. The EPA has set a “criteria level” for benzene in drinking water,
based on the agency’s estimate of benzene’s ability to cause cancer. The EPA estimates that one cancer
would be caused among a million people if they drank water for a lifetime contaminated with 0.66 micrograms
of benzene in each liter of water.
How much water could be contaminated up to the EPA’s “criteria level” if a single gallon of benzene spilled
from an underground tank? Knowing that benzene has a specific gravity of 0.879, using arithmetic we can
figure out that five billion liters of water would be contaminated to the 0.66 microgram/liter level by spillage
of a single gallon of benzene. Since most people drink two liters of water per day, or 730 liters of water in a
year, we can see that a single gallon of benzene is sufficient to contaminate a water supply that 68.5 million
people would drink in a year. That’s how much water the people of Los Angeles County (all 7.9 million of
them) would drink in a nine year period–and it could ALL be contaminated up to the EPA’s “criteria level”
for benzene by a single gallon of spilled benzene.
We estimate that, at any given moment, there are at least two billion gallons of gasoline stored underground
in the U.S. and that about 100 million gallons of this is pure benzene.
The EPA is not requiring double-lined tanks for the nation’s 700,000 gasoline tanks. It is, instead, requiring
leak detection systems. Leak detection systems are devices that tell you it’s time to lock the barn door
because the horse left some time ago. The EPA’s proposed underground storage tank regulations are a
prescription for disaster.
EPA plans public hearings in late May and in June, in DC, in Dallas, and in San Francisco. For further
information, contact Robin Woods, EPA; phone: (202) 382-4377.
–Peter Montague, Ph.D.
Descriptor terms: regulations; water pollution; water; leaks; epa; hazardous chemicals; storage tanks;
superfund; ground water; editorials; gasoline; benzene; emergency preparedness; lust; ust; underground
storage tanks; benzene; cancer; carcinogens; drinking water; statistics;