Streamlining the Remediation of Leaking Underground Fuel Tank (LUFT) Sites: Revising the California LUFT Manual
The State Water Resources Control Board (State Water Board) is in the process of drafting a revised California LUFT Manual (LUFT Manual), a manual intended to provide technical guidance to all stakeholders on the investigation and remediation of LUFT sites in the State of California.
It is State Water Board’s hope that the drafting of the manual will be a collaborative effort and have taken many measures to invite input from all stakeholders. The process began with State Water Board hosting four public meetings across the state to collect information and ideas for updating the LUFT Manual and to invite discussions on how to improve the overall process of LUFT site remediation within the state.
Raw input received at each of the four public meetings was compiled. The input was consolidated into major topic areas, a Table of Contents was developed, and a Wiki site was created that enabled interested persons to contribute to the content of the revised LUFT Manual. The Wiki site was open for five months and much information was contributed.
Background
Since the inception of the UST Program in 1984, more than 43,000 leaking USTs have been discovered. Having remediated approximately 32,000 of these sites, the Underground Storage Tank (UST) Program has been very successful. Nonetheless, approximately 11,000 leaking UST sites remain to be remediated.
The LUFT Field Manual
Guidelines for Site Assessment, Cleanup, and Underground Storage Tank Closure was introduced in 1989 as an attempt to outline best management practices and procedures for corrective action. Many lessons have been learned about successful and efficient investigation and remediation of LUFT sites in the past 20 years. It is time that we incorporate what has been learned into a revised LUFT Manual.
The LUFT Manual is envisioned as a guidance document, and is not meant to supersede existing regulations on cleanup levels, regulatory processes, or other directives. Therefore, the manual will be constrained in scope.
What is the LUFT Manual?
LUFT Manual Mission Statement: The mission of the revised LUFT Manual is to provide guidance to all stakeholders in order to make good decisions regarding the investigation and cleanup of unauthorized releases of fuels from USTs in the State of California. The manual content is designed to be user-friendly, “state of the science”, non-prescriptive, unbiased, and to guide its users towards common-sense solutions for fuel-impacted sites.
- Purpose, Intended Use, Constraints
- Purpose
The LUFT Manual is intended to be a “state of the science” document that will provide practical guidance for the remediation of LUFT sites. The manual will describe: “best practices” for the remediation process from discovery to closure, and why these practices should be used in site assessments; sampling and sample analysis; interim remedial measures; feasibility studies; remedial designs; remediation system instrumentation, data collection, and reporting; risk assessments (for human health and beneficial uses); monitoring; and site closures.
- Intended Use
As in the past, the LUFT Manual will provide Regulators, UST Cleanup Fund, Responsible Parties, and Consultants with “best practice” information designed to provide a flowchart of alternatives (“road map”) whereby LUFT sites can move through the remediation process. The manual is intended to provide this information without using specific numeric contaminant goals and without being regulatory in nature. It is intended that the manual will provide information that will allow those involved with the cleanup of LUFT sites to determine how best to meet the goals they wish to achieve.
- Constraints on guidance documents
There are three broad levels of directive documents in the UST Program: Statutes, Regulations, and Guidance Documents.
- Statutes (laws) are written by the legislature and are the primary authority requiring cleanup at UST sites. UST cleanup laws are contained in the Health and Safety Code and the Water Code.
- Regulations are written by regulatory agencies (such as the State Water Board) when provided that authority by the legislature. Regulations are subject to the Administrative Procedures Act and are prepared using a very detailed and prescriptive process.
- Guidance documents are more informal than either statutes or regulations, and are easier to create or amend. But they also have limitations. Guidance documents have no force of law and, therefore, cannot compel someone to take a particular action. Guidance documents are advisory only; however, they can provide suggestions about common management practices provide training materials, describe common situations that occur and describe common alternatives for handling these situations, etc.
The LUFT Manual is a guidance document. Because of the constraints on guidance documents, the LUFT Manual will have inherent limitations on the types of topics it can include.
Potential topics for inclusion
- Description of the physical transport of chemicals in the subsurface
- Description of technologies for investigation and remediation
- Description of strategies for investigation and remediation
- Pros and cons of different actions and strategies
- Information about how to perform a risk assessment
- Information about how to analyze the relative costs of different strategies
- …other informative and descriptive topics
Topics that cannot be included
- Setting cleanup levels
- Predetermining a process to be followed
- Requiring particular technologies, designs, or construction methods to be used
- Requiring consistency of action in a particular situation
- Requiring actions
- Prohibiting actions
- Background Information - History of the 1st Edition State Water Board, LUFT Field Manual Revision
In 1985, the State Water Board initiated the development of the first LUFT Field Manual, a guidance document intended to provide consistent and systematic procedures for the characterization and remediation of soil and groundwater contamination from USTs. The final version of the document was released in October 1989 and, with expert and public involvement, represented as close to a consensus document as was possible at that time.
- A “Living” Manual
Since the LUFT Manual’s original release in 1989, many years of practice, together with scientific and technological changes and advances, have contributed to an evolution of the best procedures and practices utilized for LUFT cleanups today. In addition, there has been discussion among many LUFT professionals that a revised LUFT Manual illustrating current experiences and scientific techniques would help the industry to consistently improve efficiency, control costs, and reduce the overall time required for site remediation. For these reasons, the U.S. Environmental Protection Agency (EPA) and the State Water Board have initiated the process of developing a revised LUFT Manual.
As in the past, the State Water Board would like to ensure that the manual will be useful for Regulators, the UST Cleanup Fund, Responsible Parties, and Consultants, and that the document will be created through a collaborative process so that it will be as much a consensus document as is possible. For this reason, the State Water Board hosted a series of public meetings with a variety of stakeholders from across the state and hosted a Wiki site open to the public. In addition, the document will be designed in such a way that amendments can easily be made when additional advances are made. The manual is intended to be a “living” document. See more information about the LUFT Manual Wiki Site.
Public Meetings
The LUFT Manual Planning Team held meetings in October and November 2008 in Sacramento, Los Angeles, Oakland, and Orange County. The LUFT Manual Planning Team appreciates the time and input of all those who attended one or more of the meetings.
The input from the meetings is linked under the LUFT Manual Documents section of this page
- LUFT Manual Public Meeting goals were:
- To gather input regarding the technical/physical content and the process for revising the LUFT Manual.
- To gather additional information that could be used for streamlining corrective action processes for LUFT sites within the State of California.
- LUFT Manual Meeting Process
To make your time worthwhile and produce the best manual possible, these meetings were being designed by a planning team of LUFT stakeholders guided by consultants who are experts in designing and facilitating meetings that provide for maximum participation and collaboration. We intended to go beyond the standard public meeting, providing a meeting framework that allowed all parties to explore together collaboratively what is needed in a new LUFT Manual in a way that is effective, satisfying and, hopefully, enjoyable.
- LUFT Manual Public Meeting agenda
The agenda included a variety of small group exercises, Open Space sessions managed by the participants on topics of their choice, and large group meetings. At the end of the day the group arranged ideas for the LUFT Manual table of contents into groups for use as sections in the revised manual.
- Specific information for public meetings
Meetings were open to all interested parties but the rooms had a limited capacity. Therefore, it was requested that participants register for the specific meeting they wished to attend. Registration and attendance were confirmed based on availability.
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