heating oil tank program update

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www.eworksnw.com Oregon DEQ Heating Oil Tank Program Update By: Matthew Lowrance

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Matt Lowrance from Environmental Works presented one credit hour on heating oil tank requirements.

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Page 1: Heating Oil Tank Program Update

www.eworksnw.com

Oregon DEQ Heating Oil Tank Program Update

!By: Matthew Lowrance

Page 2: Heating Oil Tank Program Update

www.eworksnw.com

ODEQ Heating Oil Tank Program

!• Developed in 2000 !• Set standards for Soil Samples, Decommissioning and

Cleanups !• Purpose is to Protect Human Health and Environment

– Contaminating Groundwater – Indoor Air Quality !

• 20,000 closed files • ~ 50,000 open files

Page 3: Heating Oil Tank Program Update

www.eworksnw.com

DEQ Requirements

Soil Samples• One sample from each

end of the tank • Within 6” of the end of

the tank and from 1-2’ below

Decommissioning• Must have Soil Samples • Fill and Vent Pipes

removed • Cleaned and Filled • *Voluntary Certification !

Clean Soil Samples may be used for DEQ Certification if decommission takes place within 90 days

!Contaminated Samples (>50 ppm) must be reported to DEQ

within 72 hours Leaking Underground Storage Tank Database (LUST): www.deq.state.or.us/lq/

tanks/LUST/LustPublicLookup.asp !

Page 4: Heating Oil Tank Program Update

www.eworksnw.com

DEQ Requirements….!

DEQ considers who ever owns the property when contamination is identified as the responsible party

!Source of contamination must be removed immediately (tank

pumped & cleaned)

Page 5: Heating Oil Tank Program Update

www.eworksnw.com

Three options for DEQ Cleanup & Certification

• Soil Matrix (50 – 500 ppm)**most often seen after excavation has taken place

– Depth to groundwater

– Annual precipitation

– Native soil or rock type

– Sensitivity to upper most aquifer

– Potential receptors

• Generic Remedy (500 – 2500 ppm)

– Contamination limited to soil – No free product

– No ecological risk posed by release

– Volume of soil >2,500 ppm doesn't exceed 65 cubic yards

– At least 3 feet of non contaminated soil above contamination

– Contaminated soil above seasonal high groundwater

• Risk Based (2,500 – 39,000 ppm) (air sampling)

– No free product

– Full vertical and lateral extent of contamination has been delineated

– Representative sample has been evaluated for BTEX (benzene) and PAH (ethylbenzene & naphthalene) – Exposure pathways of constituents of concern are explored and no human or ecological risk is present !

If Soil Samples > 2,500 ppm new regulations come into play

Page 6: Heating Oil Tank Program Update

www.eworksnw.com

In The Past

• Diesel levels up to ~40,000 ppm could be left in place

!• Benzene was the driving factor determining if a site

meet DEQ Standards !

• Under most circumstances contamination could be left in place !

• Only a small portion of sites required soil removal or further investigation

Page 7: Heating Oil Tank Program Update

www.eworksnw.com

New DEQ Regulations!• In 2008 EPA changed the classification of two constituents contained

in Diesel (ethylbenzene & naphthalene) from non - carcinogenic to carcinogenic

!• Created new screening levels for evaluating the effects on human

health from volatilization and vapor intrusion into indoor air

!• Recently the DEQ’s Heating Oil Tank Program adopted these

screening levels for residential heating oil tank projects

!• Ethylbenzene and Napthalene will be the driver determining cleanup

activities

!• Ethylbenzene must be < .82ppm

!• Napthalene must be < 6.5ppm

Page 8: Heating Oil Tank Program Update

www.eworksnw.com

Evaluating Risk from Vapor Intrusion!!!• Ethylbenzene must be < .82ppm (in soil) • Napthalene must be < 6.5ppm (in soil) !Extremely overprotective of

human health due to uncertainties associated

with environmental modeling

! Excavation or Soil Gas Sampling is the next

step

Page 9: Heating Oil Tank Program Update

www.eworksnw.com

Excavation vs. Air Sampling

Many variables to consider • volume of soil • depth to groundwater • concentration • potential impacts to property • projected costs • Overall likelihood to meet

DEQ requirements

Page 10: Heating Oil Tank Program Update

www.eworksnw.com

Soil Gas Sampling!

• Valuable in situations where excavation is not an option

!• Collect air samples from soil pore

space ~5ft below ground surface

!• 1-2 samples needed

!• More direct evaluation of risk

!• $1,800 - $2,500.00

Page 11: Heating Oil Tank Program Update

www.eworksnw.com

What does this mean for your clients?

• Only sites with minimal contamination will meet Risk Based Standards and not require further evaluation !

• Many more residential heating oil tank sites will require additional work (air sampling or excavation) !

• More Expensive !

• More impact to property (removal of fences, landscaping, decks and porches) !

• Take more time

Page 12: Heating Oil Tank Program Update

www.eworksnw.com

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