investigation and characterization of discharges from heating oil tanks

Investigation and Characterization of Discharges from Heating Oil Tanks

Suspected vs. Confirmed Releases heating oil tank discharges are

subject to Article 11, State Water Control Law

Discharges must be reported to DEQ

Article 11 does not recognize “suspected releases”

Confirmed Releases (Discharges) Free product in environment Impacted Receptor Inordinate loss of fuel Sample results indicating a release

TPH conc. > 100 mg/kg during tank removal

TPH conc. >1 mg/l, water collected from tank pit

Threat of a Discharge

Active tank w. > 1” of water in tank Report of problems w. oil furnace Combination of tank age and

location (i.e. subdivision w. history of many leaking home heating oil tanks)

PID/FID reading > background

Conditions Indicating Threat of a Discharge Do not necessarily mean a

discharge has occurred Staff may recommend that tank

operator obtain additional information

Reimbursement not allowed unless actions are required by DEQ

Heating Oil Categories Discharges from heating oil tanks

are assigned one of four categories for characterization

Category is assigned when discharge is reported

Category may change as new information becomes available

Heating Oil Categories Category assignment based on:

Severity and extent of contamination

Risks posed by discharge Tank size (tanks > 1,000 gallons

assigned to category 3 (characterization procedures as used with regulated tanks)

Investigations/Activities Not Directed by DEQ Time and materials used to collect

samples, all other work performed not eligible for reimbursement

Cost of sample analysis indicating confirmed release will be eligible if analytical results reported to DEQ within 24 hrs of their receipt by tank operator or consultant

DEQ Determined No Further Action (NFA) DEQ Case Manager may use

existing information to determine NFA

NFA sites pose low risk, have little/no recoverable FP, minor/no petroleum saturated soil

NFA continued NFA most appropriate where:

area served by public water leaking tank out of service for

extended period no reason to expect receptor

impact

Category 1 Pose low risk to receptors Have little/no free product Minor/no petroleum saturated soil

Category 1 continued Sites generally start here if

Not enough info for NFA No FP or saturated soil found No impacted receptor identified

Not intended to be used if receptors (especially water supplies) are in close proximity to the tank

Category 1 Reporting Generally reported to DEQ due to:

Samples taken during real estate transaction indicate a discharge

Typical Scope of Work – Category 1 Sites Collection of 1 – 4 soil samples

and analysis by TPH DRO Samples usually collected w. soil

auger PM conducts visual receptor

survey of wells within 500 feet and surface water within 200 feet of tank

Category 1 scope of work continued Completion and submission of

Heating Oil Tank Report Form Remove oil and fluids from tank

Fluid removal generally performed after analytical results received

Should not be authorized if only water remains in the tank

Transition from Category 1 to another Category Need for transition based upon risk and

presence of free product and/or saturated soil

Moderate risk to receptors – usually goes to category 2

Presence of recoverable free product or saturated soil – category 2

Imminent threat to a receptor – discharge is close to water supply or surface water – usually will go to category 3

Category 2

Category 2 sites generally have Free product Petroleum saturated soil Are believed to present a moderate

threat to drinking water supply or surface water

Category 2 continued Category 2 may be used if

petroleum vapors are present in non-living spaces (e.g. crawl spaces) and soil removal with short term ventilation can address risks

Category 2 scope of work Usually characterized while excavating

up to 26 cy (39 tons) of petroleum saturated soil

PM conducts visual receptor survey of wells within 500 feet and surface water within 200 feet of tank

Prepare Category 2 narrative report Monitoring wells may be installed at

some sites

Category 2 phases of work Site Characterization Site Characterization Addendum Post SCR Monitoring (if more than

2 quarters needed, elevated to a Category 3)

Closure

Transition from Category 2 to Category 3 More extensive saturated soil or

free product found Imminent threat or high probability

to impact receptor > three monitoring wells needed Corrective actions remaining after

site characterization is complete must be performed in Category 3

Category 3 Have impacted or present high

probability to impact a receptor Used with heating oil tanks > 1000

gallons Characterization procedures as

used w. regulated tanks (work scope agreed to by Case Manager/RP/Consultant)

Activity authorization When a site advances to a higher

category Case manager should collect all

AAFs and verify the work performed with one verification form

The case manager may direct RP/consultant to combine all approved work on one AAF for verification

Activity Authorization Cont. Only one claim prep task allowed

for site characterization phase

Excavation/Intrusive work near structures Damages to buildings/structures

not reimbursable expenses Consultants expected to exercise

all due care If intrusive activities may present

risk to damage building, consultant needs to discuss w. Case manager