To create a context for developing the new manual, the following is offered as an initial framework for the new, updated LUFT manual. The actual shape and content of this manual will grow from the information received from you during the four public meetings and from other input, comments, and participation.
a. Purpose and Use

i. Purpose
The updated California Leaking Underground Fuel Tank (LUFT) Manual is intended to be a “state of the science” document that will provide practical guidance for the remediation of leaking underground fuel tanks. 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.

ii. Intended Use
As in the past, the updated LUFT Manual will provide regulators, the UST Cleanup Fund, responsible parties, and consultants with “best practice” information designed to provide a flowchart of alternatives (“road map”) whereby LUFT cases can move through the remediation process. The updated manual is intended to provide this information without using specific numeric contaminant goals and without being regulatory in nature. It is intended that the updated manual will provide information that will allow those involved in LUFT cases to determine how best to meet the goals they wish to achieve.

b. Background Information

i. History of the 1st Edition CA LUFT Manual
In 1985, the California State Water Resources Control Board (SWRCB) initiated the development of the first California LUFT 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 1989 and, with expert and public involvement, represented as close to a consensus document as was possible at that time.

ii. The LUFT Manual Update
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 an updated 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 SWRCB have initiated the process of developing an updated LUFT Manual.

As in the past, the SWRCB 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 SWRCB will kick off the process of updating the LUFT Manual by conducting a series of four public meetings with a variety of stakeholders from across the state to solicit input on the content, identification of accepted professional resources, and the process for developing the updated LUFT Manual. In addition, the document should be designed in such a way as to make amending it as easy as possible when additional advances are made. The manual is intended to be a “living” document.

iii. Link to the previous document
The original version of the California LUFT Manual (link to download the PDF)

iv. Link to the SWRCB website
For more information about the California State Water Resources Control Board’s Underground Storage Tank Program, please visit: http://www.waterboards.ca.gov/ust/

v. 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

ADDITIONAL INFORMATION:
Public Meeting Invitation Flyer