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Leaking Underground Storage
Tanks in Rhode Island
DO THI THIEN HUONG
NGUYEN THI MINH THUAN
DUONG THI TAM
1
Picture source:...
OUTLINE
¤  Executive Summary
¤  Summary of Decision
¤  Description of Context
¤  Stakeholder Analysis
¤  Decision Criteria...
LUSTs in a nutshell
¤  Background: The case represents the intergrated impact of
LUSTs in Rhode Island and how to address ...
How we choose workable option?
¤  We weighed our indices of performance (Economic values, Human
health and safety, Environ...
How the case began?
¤  1980: A family in Canob Park in Rhode Island reported problem
with their tab water
¤  1983: Their s...
¤  1988: EPA promulgated 165 pages of Federal Register guided on
the management of UST
¤  1996: Rhode Island became the 31...
7
Issues Behind Underground Storage Tanks
Silent threat - LUSTs
¤  LUSTs posed serious impact on human health:
¤  High rat...
Who plays with LUSTs?
Groups Representatives Objectives
Federal authorities Congress,
President, EPA,
GAO
Provide Rhode Is...
Economicvalues
Environmental Protection
ConflictsPositively interact
9
Community
Media
Scientists
•  Oil industry
USTs
own...
Criteria	 Jus+fica+ons	 Metrics		
Economic	values	 -  Cost	of	opera,ng	LUSTs	and	cleanup	
-  Land	and	property	value	affecte...
11
Decision Tree
Human	Health		
	
Well	being	of	
Environment		
•  Economic	values	
•  Human	health	
and	safety	
•  Environ...
DATA talks about impact of LUSTs
12
¤  Three most products stored in USTs are Gasoline (42%), Heating
oil (39%), Diesel fu...
13
¤  A tiny hole in an UST can leak 400 gallons of fuel per year.
¤  One gallon of petroleum can contaminate one million
...
14
Total active tanks (2003)
15
¤  Rhode Island: Top 13 highest cancer incidence
¤  About four out of ten people in Rhode Island will develop cancer in...
16
Mapping and
analysing
Underground water
quality vs LUST in
Rhode Island
GIS data achieved from http://
www.edc.uri.edu/...
17
Closeup: Population potentially in danger by living with LUSTs in 4 towns.
Hundreds of LUSTs are found in an densely po...
18
REGRESION: We ran the regression to see there is any relationship between the cancer
incidences and other variables: Pe...
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 C...
Three main approaches for LUSTs
20
No Alternatives Description
1 Effectively use
EPA Fund
•  Increase EPA fund
•  Improved...
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)
Authoritie...
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...
How Could We Enforce the State Law?
¤  Short term
¤  Consider the Residential Tanks and Farm Tanks (below 1,100 Gallon)
to...
How Could We Enforce the State Law?
¤  Long term
¤  Continue to promote enforcement authorities and
resources
¤  There sho...
Risk assessment
¤  There is not enough data to link the causes of non-support to
actual sources of the pollutant.
¤  Confl...
¤  Rhode Island does not have statewide data on historic
freshwater or coastal wetland loss.
¤  Possible hard backlash of ...
27
References
¤  Chicago: 46-12.9-5 - State of Rhode Island General Assembly, http://
www.rilin.state.ri.us/Statutes/TITLE46/...
Choose	100%	as	our	base	result
Enforce	State	Laws Low High Delta
IP1 Number	of	Underground	Storage	Tanks 90 110 20
IP2 Cos...
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Leaking Underground Storage Tanks (LUSTs) in Rhode Island

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Background: The case represents the integrated 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 strengthen the law, policy gap will be filled, health impact on community would be minimised and the environment will be better saved from being contaminated.

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Leaking Underground Storage Tanks (LUSTs) in Rhode Island

  1. 1. Leaking Underground Storage Tanks in Rhode Island DO THI THIEN HUONG NGUYEN THI MINH THUAN DUONG THI TAM 1 Picture source: Internet
  2. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 14 Total active tanks (2003)
  15. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 27
  28. 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. 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

Background: The case represents the integrated 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 strengthen the law, policy gap will be filled, health impact on community would be minimised and the environment will be better saved from being contaminated.

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