The National Program, State Programs, and Standards of Practice

Dynamic work strategies incorporate the ability to adapt project activities to site conditions as better information becomes available while work is underway.

Other than in a few states, EPA has agreements where the state is the primary implementing agency of the national UST program, which includes the administration of a fund to reimburse eligible tank owners and operators for costs associated with the assessment and remediation of eligible releases from underground storage tanks (EPA 2007c). As discussed below, states such as South Dakota, Missouri, and Virginia replenish and administer such funds in different ways. State and Tribal programs are in various stages of approval, with 36 states plus the District of Columbia and Puerto Rico having fully approved programs. The EPA maintains some responsibility for program implementation in some states and on lands owned by some Indian Tribes (GAO 2007).

State petroleum release-related UST programs have been shaped by both the national regulations for release detection, prevention, and cleanup regulations and national standards of practice (See National Standards table below). One of the more influential standards of practice is the American Society of Testing and Materials (ASTM) Risk-Based Corrective Action (RBCA) Standard for remediating contaminated sites (RBCA Standard Guide ASTM E Standard Guide E 1739-95 (reapproved in 2002). State programs have tended to build upon the RBCA Standard Guide and create risk-based but uniquely state-specific customized UST corrective action programs.

Two standards of practice, ASTM E 1739-95 and ASTM E 1912-98 (reapproved in 2004) [Standard Guide for Accelerated Site Characterization for Confirmed or Suspected Petroleum Releases], have an "accelerating" or "streamlining" component. ASTM E 1912 principles and Triad principles overlap considerably. For example, Section 5 of the Accelerated Site Characterization Process of E 1812-98 describes the following activities to be performed on-site:

5.1.1 Interpretation and evaluation of field-generated data as it is collected
5.1.2 Continuous refinement of the conceptual model
5.1.3 Modification of the sampling and analysis program to address any necessary adjustments, and
5.1.4 Collection of additional data necessary to complete the characterization.

**National Standards of Practice**
American Petroleum Institute (API) API Publication 1628, "A Guide to the Assessment and Remediation of Underground Petroleum Releases." API Publication 1629, "Guide for Assessing and Remediating Petroleum Hydrocarbons in Soils." American Society of Testing and Materials (ASTM) ASTM E 1599, "Standard Guide for Corrective Action for Petroleum Releases" ASTM International, West Conshohocken, Pa., www.astm.org. ASTM E 1739, "Standard Guide for Risk-Based Corrective Action Applied at Petroleum Release Sites." ASTM E 1912, "Standard Guide for Accelerated Site Characterization for Confirmed or Suspected Petroleum Releases." ASTM E 1943, "Standard Guide for Remediation of Ground Water by Natural Attenuation at Petroleum Release Sites." ASTM E 2600-08, "Standard Practice for Assessment of Vapor Intrusion into Structures on Property Involved in Real Estate Transactions." National Fire Protection Association (NFPA) NFPA 329, "Recommended Practice for Handling Releases of Flammable and Combustible Liquids and Gases."

The EPA Office of Superfund Remediation and Technology Innovation Technology Integration and Information Branch (EPA TIIB) continues to look for opportunities to leverage Triad expertise with assessment/characterization/cleanup activities at active and abandoned UST sites. To date, EPA TIIB has gained experience working with petroleum release site stakeholders in several states. The results of Triad implementation efforts in South Dakota, Missouri, and Virginia are discussed under Case Studies.