This document discusses leaking underground storage tanks (LUSTs) in Rhode Island and options to address the issue. It provides background on LUST regulations since the 1980s. Data shows LUSTs release hazardous substances that contaminate groundwater and increase cancer rates. Three alternatives are analyzed: increasing EPA funding, enforcing state LUST laws, or banning underground tanks. Metrics to evaluate the alternatives are identified. Regression analysis shows a relationship between LUSTs and pollution levels. After weighing performance indices and stakeholder utilities, recommending enforcing state LUST laws is concluded to minimize health and environmental impacts.

1. Leaking Underground Storage
Tanks in Rhode Island
DO THI THIEN HUONG
NGUYEN THI MINH THUAN
DUONG THI TAM
1
Picture source: Internet

2. OUTLINE
¤ Executive Summary
¤ Summary of Decision
¤ Description of Context
¤ Stakeholder Analysis
¤ Decision Criteria and Metrics
¤ Data/Model
¤ Alternative Analysis
¤ Recommendations
¤ Sensitivity Analysis
¤ Q&A
2
Map of Rhode Island
Map author: Thien Huong

3. LUSTs in a nutshell
¤ Background: The case represents the intergrated impact of
LUSTs in Rhode Island and how to address the issue.
¤ Recommendations: We highly recommend that the state and
EPA should continue law reinforcement.
¤ Implication: When the authorities try to strenghthen the law,
policy gap will be filled, health impact on community would be
minimised and the environment will be better saved from being
contaminated.
3
What can be done to minimize the impact of LUSTs on
human health and environment?

4. How we choose workable option?
¤ We weighed our indices of performance (Economic values, Human
health and safety, Environmental Sustainability, media and public
attention, political and legal framework) and considered the utility
of each IP based on our perspective.
¤ We came up with 3 different alternatives:
¤ Effectively use EPA Fund
¤ Enforce state Law about LUSTs
¤ No USTs
¤ Our decision to support the enforcement of state law about LUSTs
¤ We came to this conclusion after simply adding utilities with weights
across three alternatives.
4

5. How the case began?
¤ 1980: A family in Canob Park in Rhode Island reported problem
with their tab water
¤ 1983: Their story on air on CBS show called “60 minutes” and
became national hot spot
¤ 1984: President Reagan signed amendments to the Resources
Conservation and Recovery Act
5
¤ 1985: EPA disseminated regulations
about: prevent Underground Storage
Tanks (UTS) from leaking and clean up the
leaks
¤ 1986: LUSTs Trust Fund was established
Picture source: Internet

6. ¤ 1988: EPA promulgated 165 pages of Federal Register guided on
the management of UST
¤ 1996: Rhode Island became the 31th state to comply with LUSTs
regulations
¤ 2005: EPA was given the authority to regulate USTs
¤ 2011: Rhode Island issued the Rules and Regulations for
Underground Storage Facilities Used for Petroleum Products and
Hazardous Materials
6Picture source: Internet

7. 7
Issues Behind Underground Storage Tanks
Silent threat - LUSTs
¤ LUSTs posed serious impact on human health:
¤ High rate of cancer incidence
¤ Hazardous substances released
¤ LUSTs contaminated the water sources and environment
¤ Harmful substances leaking into soil
¤ Contaminate water sources
There is bad need to continue reinforcing law to keep
people safe and protect the environment

8. Who plays with LUSTs?
Groups Representatives Objectives
Federal authorities Congress,
President, EPA,
GAO
Provide Rhode Island funds to improve training, inspections, and
enforcement efforts;
• Provide EPA and RI additional enforcement authorities
• Prevent leaks from tanks
• Find leaks and clean them up
• Support for state and local level successful in detecting and
implementing program
Environmental
group, scientists
• Protect the environment: groundwater quality, air, soil
• Protect people health
• Collect data and do research to gain evidence
Local authority DEM, DOH • Improve the quality of public drinking water system
• Prevent public health
• Keep Rhode Island safety
• Ensure the business activities
Members of the
petroleum industry
Tank owners and
operators
• Maintains their business activities
• Ensure the revenue streams
• Job creation
Community groups • Prevent health risks and keep safety
• Ensure economic values (property and land)

9. Economicvalues
Environmental Protection
ConflictsPositively interact
9
Community
Media
Scientists
• Oil industry
USTs
owner and
operators
Environmentalist
Congress
How they are interacting in the LUSTs game?
Local
Authority

10. Criteria Jus+fica+ons Metrics
Economic values - Cost of opera,ng LUSTs and cleanup
- Land and property value affected
- Number of underground storage tanks
- Cost of opera,ng, cleanup and complying with LUSTs
regula,ons
- Number of land and property value affected
Human health and
safety
- Indirect and direct harms on human
health, and safety
- Encourage more research into the
hazardous substances to people health
and environment
- Rate of asthma, and benzene-related diseases
- Number of fire and explosion
- Number of research about the hazardous substances
Environmental
sustainability
- Leaking underground storage tanks
release hazardous components that
contaminate water, soil and air.
- Number of gallons of groundwater protected /1year
- Number of Clean-ups completed
- Grams of hazardous components of gasoline leaks
(benzene, toluene and ethyl benzene..) in soil,
groundwater and air
Media and public
a8en9on
- It is important to arouse more public
aNen,on to effect of leaking underground
storage tanks. Involvement of mass media
plays key role in dissemina,ng
informa,on.
- Ensure the public transparency
- Number of news coverage (publica,on, review, ar,cles..)
- Number of people par,cipated in campaigns
- Number of tanks registered and non-registered
Poli9cal and legal
framework
- Ensure the stricter regula,on on LUSTs - Number of programs suppor,ng clean up ac,vi,es
- Amount of Superfund allocated
- New rules/regula,ons passed
10
What to measure?

11. 11
Decision Tree
Human Health
Well being of
Environment
• Economic values
• Human health
and safety
• Environmental
sustainability
• Media and public
aNen,on
• Poli,cal and legal
framework
IP1: Number of Underground Storage Tanks
IP2: Cost of opera,ng, cleanup and
complying with LUSTs regula,ons
IP3: Number of benzene-
related diseases
IP4: Number of gallons of
groundwater protected
IP5: Number of Clean-ups backlog
IP6: Number of people par,cipated in campaigns
IP7: Number of programs suppor,ng clean up
ac,vi,es
IP8: Amount of Superfund allocated
IP9: Number of tanks registered and non-
registered

12. DATA talks about impact of LUSTs
12
¤ Three most products stored in USTs are Gasoline (42%), Heating
oil (39%), Diesel fuel (12%).
¤ Petroleum contaminants
have unfavorable impacts
on heath. Some are known
as cause or suspected to be
the cause of cancers, almost
all are harmful to the
immune, nervous and
respiratory system.
¤ All of them are known with
moderate to very high
mobility in soil when leaking.
Gasolin
e
42%
Heating
Oil
39%
Diesel
Fuel
12%
Others
7%
What is in USTs?
Data source: STATE OF RHODE ISLAND AND PROVIDENCE
PLANATIONS 2006 Section 305(b) Report

13. 13
¤ A tiny hole in an UST can leak 400 gallons of fuel per year.
¤ One gallon of petroleum can contaminate one million
gallons of groundwater.
¤ The direct cost to clean up a leaking UST on average is
$125,000
¤ Budget for clean up approved by Congress was $72 mil
annualy. Cost estimated by GAO:12 billion
¤ In 2006, estimated there are 705,000 underground storage
tank systems nationwide and about 9,000 new leaks are
discovered annually.
¤ Nationally, there are 3.8 million non-federally regulated USTs
buried across the US.

14. 14
Total active tanks (2003)

15. 15
¤ Rhode Island: Top 13 highest cancer incidence
¤ About four out of ten people in Rhode Island will develop cancer in
their lives and half of them will die. Close to 43,000 people suffer
from cancer at any one time.
¤ Estimated cost for Rhode Island of cancer is about $993 million per
year, including: $379 million in direct medical costs, $77 million in lost
productivity due to illness, and $477 million in lost productivity due
to premature death.
Direct
Medical
Cost
42% Lost
Productivity
(Illness)
8%
Lost
Productivity
(Death)
50%
Annual Cost
Data source: The American Cancer Society

16. 16
Mapping and
analysing
Underground water
quality vs LUST in
Rhode Island
GIS data achieved from http://
www.edc.uri.edu/rigis
Mappning & GIS Analyst: ThienHuong

17. 17
Closeup: Population potentially in danger by living with LUSTs in 4 towns.
Hundreds of LUSTs are found in an densely populated area (upto about 95,000
people per square mile). Total population 124,082
All four towns are with higher than a thousand cancer incidence per 100,000.
(Foster (1123,6), Johnton(1072.8) , Cranston (1023,1) and Sciatute (1040.2)
GIS data achieved from http://www.edc.uri.edu/rigis
Mappning & GIS Analyst: ThienHuong

18. 18
REGRESION: We ran the regression to see there is any relationship between the cancer
incidences and other variables: Permitted Water Polluters, Business Releasing Toxics,
Superfund site, Landfill active and closed and specially LUSTs
As you can see F-test<0.95, we do not have evidence to reject the null hypothesis or it
seems there is no relationship between cancer incidences and other causes of pollution
in Rhode Island.
_cons 1010.725 27.52769 36.72 0.000 954.7197 1066.731
LUSTs 1.030812 .6985016 1.48 0.149 -.3903007 2.451924
LandfillsActiveandclosed .786389 10.66383 0.07 0.942 -20.90933 22.48211
Superfundsite .9350475 5.191618 0.18 0.858 -9.627379 11.49747
BusinessReleasingToxics -3.681516 1.877226 -1.96 0.058 -7.500761 .1377283
PermittedWaterpolutters 2.372659 3.798344 0.62 0.536 -5.355129 10.10045
ALL Coef. Std. Err. t P>|t| [95% Conf. Interval]
Total 239487.054 38 6302.2909 Root MSE = 79.675
Adj R-squared = -0.0073
Residual 209488.33 33 6348.13122 R-squared = 0.1253
Model 29998.7241 5 5999.74482 Prob > F = 0.4651
F( 5, 33) = 0.95
Source SS df MS Number of obs = 39
> ndclosed LUSTs
. regress ALL PermittedWaterpolutters BusinessReleasingToxics Superfundsite LandfillsActivea
Data achieved from RI DEM, Pollution Sources, EPA, RI Division of Planning, Toxic
Action Center. Analyst: Duong Thi Tam

19. 19
_cons 1.30747 1.203293 1.09 0.284 -1.130634 3.745573
LUSTs .0794783 .0195847 4.06 0.000 .039796 .1191605
TotalPollu~e Coef. Std. Err. t P>|t| [95% Conf. Interval]
Total 1440.01393 38 37.8951035 Root MSE = 5.1896
Adj R-squared = 0.2893
Residual 996.476556 37 26.9317988 R-squared = 0.3080
Model 443.537377 1 443.537377 Prob > F = 0.0002
F( 1, 37) = 16.47
Source SS df MS Number of obs = 39
. regress TotalPollutionSquaremile LUSTs
HOWEVER, when we run the regression of total pollution square mile
and LUSTs as independent variable, we have the evidence to reject
the null hypothesis at 5% and 10% significant level.
The F test is large, p-value is significant; there would be evidence to
say there is strong relationship between LUSTs and the total pollution
per square in Rhode Island.
Data achieved from RI DEM, Pollution Sources, EPA, RI Division of Planning, Toxic
Action Center. Analyst: Duong Thi Tam

20. Three main approaches for LUSTs
20
No Alternatives Description
1 Effectively use
EPA Fund
• Increase EPA fund
• Improved a regulated community’s compliance
• Allocate more fund to strengthen staffing and inspectors
Drawback:
• Inconsistency in designing and spending fund
• Inadequate funding
2 Enforce state
Law about LUSTs
Enforce state law with Lusts in the short term and long term
implementation plan
e.g:
• Double-walled tanks,
• Formulate the baseline for data,
• Make leaking known to community
Drawback:
• This will trigger strong opposition from tank owners and
operators
3 No USTs • Advantages of above ground tanks
• Remove all the underground tanks to above ground tanks
Drawback:
• Too costly to do and pose challenges for the new regulation
for above ground tanks

21. IPs, Utility and Weight across Stakeholders
21
IP weights IP(1) IP(2) IP(3) IP(4) IP(5) IP(6) IP(7) IP(8) IP(9)
Authorities 0.9 0.3 0.9 0.9 0.8 0.7 0.9 0.8 0.9
Tank owner and operators 0.9 0.9 0.2 0.2 0.1 0.2 0.7 0.2 0.8
Citizen/Community 0.7 0.2 1 0.8 0.7 0.5 0.7 0.4 0.9
IP(1) IP(2) IP(3) IP(4) IP(5) IP(6) IP(7) IP(8) IP(9)
A1-Increase EPA fund 0 1 0 0 0 1 0.8 1 0.5
A2-Enforce state laws 0.8 0.7 1 1 0.7 0.8 1 0.7 1
A3-No UTS 1 0 0.5 0.5 1 0 0 0 0
Utilities
IP1
IP2
IP3
IP4
IP5
IP6
IP7
IP8
IP9
Cost of operating, cleanup and complying with LUSTs regulations
Number of Underground Storage Tanks
Number of benzene-related diseases
Number of gallons of groundwater protected
Number of Clean-ups completed
Number of people participated in campaigns
Number of programs supporting clean up activities
Amount of Superfund allocated
Number of tanks registered and non-registered

22. Final option is…
22
Authorities
IP(1) IP(2) IP(3) IP(4) IP(5) IP(6) IP(7) IP(8) IP(9) Total
A1-Increase EPA fund 0 0.3 0 0 0 0.7 0.72 0.8 0.45 2.97
A2-Enforce state laws 0.72 0.21 0.9 0.9 0.56 0.56 0.9 0.56 0.9 6.21
A3-No UTS 0.9 0 0.45 0.45 0.8 0 0 0 0 2.6
Tank owners and operators
IP(1) IP(2) IP(3) IP(4) IP(5) IP(6) IP(7) IP(8) IP(9) Total
A1-Increase EPA fund 0 0.9 0 0 0 0.2 0.56 0.2 0.4 2.26
A2-Enforce state laws 0.72 0.63 0.2 0.2 0.07 0.16 0.7 0.14 0.8 3.62
A3-No UTS 0.9 0 0.1 0.1 0.1 0 0 0 0 1.2
Citizen and community
IP(1) IP(2) IP(3) IP(4) IP(5) IP(6) IP(7) IP(8) IP(9) Total
A1-Increase EPA fund 0 0.2 0 0 0 0 0.56 0.4 0.45 1.61
A2-Enforce state laws 0.56 0.14 1 0.8 0.49 0.35 0.7 0.28 0.9 5.22
A3-No UTS 0.7 0 0.5 0.4 0.7 0.5 0 0 0 2.8
ALTERNATIVES SCORE RANK
Increase EPA fund 6.84 2
Enforce state law 15.05 1
No UTS 6.6 3
AGGREGATE SCORE
(AUTHORITIES+CITIZEN+TANK OWNERS)

23. How Could We Enforce the State Law?
¤ Short term
¤ Consider the Residential Tanks and Farm Tanks (below 1,100 Gallon)
to report/register
¤ Simplify the application for registration the tanks
¤ Formulate the baseline data for registered and unregistered tanks
¤ Investigate the impact of LUSTs on people health, property,
underground water quality
¤ Make the leaking incidence known to community and press to
ensure the transparency
¤ Make polluters pay to clean up contamination from leaking USTs
¤ Provide more training to the staff to be more competent
¤ Higher fines for violators
¤ Double-walled tanks
23

24. How Could We Enforce the State Law?
¤ Long term
¤ Continue to promote enforcement authorities and
resources
¤ There should be federal mandate for states to inspect
periodically.
¤ Promote the development and possible replacement
of the alternative energy to gas
¤ Base on the geographical features of Rhode Island
¤ State of Rhode Island was awarded a grant of
$9,593,500 for developing renewable energy
24

25. Risk assessment
¤ There is not enough data to link the causes of non-support to
actual sources of the pollutant.
¤ Conflicts between data available about the impact of LUSTs
and the cancer incidence in Rhode Island (based on the
regression results)
25

26. ¤ Rhode Island does not have statewide data on historic
freshwater or coastal wetland loss.
¤ Possible hard backlash of tank owners and operators
when fee increases
¤ Tornado Diagram:
26
Risk assessment

27. 27

28. References
¤ Chicago: 46-12.9-5 - State of Rhode Island General Assembly, http://
www.rilin.state.ri.us/Statutes/TITLE46/46-12.9/46-12.9-5.HTM (accessed November
27, 2012).
¤ Environmental Defense, Scorecard.org (2005), Michigan DEQ, RPD Operational
Memo. #2 (2004), ATSDR, Toxicological Profiles (various).
¤ 2011 RI Underground Storage Tank Financial Responsibility Fund Annual Report
¤ Leaking Underground Storage Tanks-Remediation with Emphasis on In Situ Bio
restoration EPA, Robert S. Kerr, 1987
¤ Underground Storage Tanks: Building on the Past to Protect the Future, US
Environmental Protection Agency, March 2004
¤ Ibid
¤ United States Code of Federal Regulations, 40 CFR 280. Technical Standards and
Corrective Action
¤ Requirements for Owners and Operators of Underground Storage Tanks
¤ IR Underground Storage Tank Review Board, retrieved at
http://www.dem.ri.gov/ustboard/index.htm on 26 Nov 2012
¤ Rules and Regulations For Underground Storage Facilities Used for Petroleum
Products and Hazardous Materials, DEM, Rhode Island, April 2011
28

29. Choose 100% as our base result
Enforce State Laws Low High Delta
IP1 Number of Underground Storage Tanks 90 110 20
IP2 Cost of operating, cleanup and complying with LUSTs 95 110 15
IP3 Number of benzene-related diseases 85 105 20
IP4 Number of gallons of groundwater protected 95 105 10
IP5 Number of Clean-ups completed 95 105 10
IP6 Number of people participated in campaigns 95 110 15
IP7 Number of programs supporting clean up activities 90 105 15
IP8 Amount of Superfund allocated 90 110 20
IP9 Number of tanks registered and non-registered 90 115 25
Appendix for Tornado Diagram
29
Alternative IP1 Utility Weight IP2 Utility Weight IP3 Utility Weight IP4 Utility Weight
Enforce State Laws 8 0.8 0.7 8 0.2 0.8 8 1 1 7 1 0.8
Alternative IP5 Utility Weight IP6 Utility Weight IP7 Utility Weight IP8 Utility Weight IP9 Utility Weight Results
Enforce State Laws 6 0.7 0.7 7 0.8 0.5 7 1 0.7 8 0.7 0.4 9 1 0.9 5.29