ABSTRACT

The proposed federal regulations for underground storage tanks (UST) reflect the scientific uncertainty of many aspects of the contaminated soil problem, and the ways of solving this problem. In the initial response action phase of the proposed regulations, the cleanup of contaminated soil is addressed in the requirement that the owner or operator “remove and properly dispose of visibly contaminated soil from the excavation zone.” In testimony presented at the public hearings and written comment submitted during the comment period, commenters expressed concern that this requirement revealed a preference for removal and offsite disposal of large amounts of soil. Evidence indicates that this process is capable of collecting hydrocarbons from the unsaturated zone, but little evaluation of its level of performance has been done. The application of long-term corrective action technologies requires further refinement of the mechanisms for the removal of leaked products from underground storage tanks.