Investigation and Characterization of Discharges from Heating Oil Tanks

1. Investigation and Characterization of Discharges from Heating Oil Tanks

2. 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� Change title to Suspected Versus Confirmed releases? Bullet 3 - Should �address� be changed to �recognize�; �unlike the regulations for regulated tanks such as gas tanks.� Therefore DEQ does not begin any reimbursement until a release has been confirmed.Change title to Suspected Versus Confirmed releases? Bullet 3 - Should �address� be changed to �recognize�; �unlike the regulations for regulated tanks such as gas tanks.� Therefore DEQ does not begin any reimbursement until a release has been confirmed.

3. 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

4. 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 Reverse this silde with Slide #7Reverse this silde with Slide #7

5. 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

6. 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

7. 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)

8. 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 MOVE THIS SLIDE to the beginningMOVE THIS SLIDE to the beginning

9. 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 Clarify first bullet �if characterization is believed to be satisfactory�Clarify first bullet �if characterization is believed to be satisfactory�

10. 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 Reiterate that the soils are not anticipated to be saturated, and that characterization is adequate.Reiterate that the soils are not anticipated to be saturated, and that characterization is adequate.

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

12. 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 Last bullet � explain that there may be exceptions, such as a deep well in a coastal plain properly grouted, near a leaking tank, that might not be considered at risk.Last bullet � explain that there may be exceptions, such as a deep well in a coastal plain properly grouted, near a leaking tank, that might not be considered at risk.

13. Category 1 Reporting Generally reported to DEQ due to: Samples taken during real estate transaction indicate a discharge Bullet 1 is a suspected release, not a confirmed � what would make a furnace malfunction a Cat 1?Bullet 1 is a suspected release, not a confirmed � what would make a furnace malfunction a Cat 1?

14. 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 May need to give examples of bullet 1; Bullet 3 do we expect them to tell us if a well is in use for a cat 1? Well type (shallow or drilled)?May need to give examples of bullet 1; Bullet 3 do we expect them to tell us if a well is in use for a cat 1? Well type (shallow or drilled)?

15. 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 last bullet � what if water is contaminated?last bullet � what if water is contaminated?

16. 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 Should title be Transition from one category to another? Move last bullet to next slideShould title be Transition from one category to another? Move last bullet to next slide

17. 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 Instead of �moderate� use �reasonable�Instead of �moderate� use �reasonable�

18. 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 I would put �Catastrophic release (documented by records, oil company)�I would put �Catastrophic release (documented by records, oil company)�

19. 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 Bullet 2 � if DW wells, we expect well type, if in use/out of useBullet 2 � if DW wells, we expect well type, if in use/out of use

20. 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

21. 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

22. 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) Put bullet #2 under Cat 2. Here on this slide recognize that catastrophic releases from ASTs AND USTs should be categorized as a CAT 3 when going under a crawl space, potential high impact to receptor.Put bullet #2 under Cat 2. Here on this slide recognize that catastrophic releases from ASTs AND USTs should be categorized as a CAT 3 when going under a crawl space, potential high impact to receptor.

23. 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 Bullet 1 and 2 � switch orderBullet 1 and 2 � switch order

24. Activity Authorization Cont. Only one claim prep task allowed for site characterization phase Explain last bulletExplain last bullet

25. 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 Discuss utility identification?Discuss utility identification?