investigation and characterization of discharges from heating oil tanks
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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”. - PowerPoint PPT PresentationTRANSCRIPT
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