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”

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

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

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

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

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

13. Category 1 Reporting • Generally reported to DEQ due to: • Samples taken during real estate transaction indicate a discharge

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

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

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

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

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

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

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)

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

24. Activity Authorization Cont. • Only one claim prep task allowed for site characterization phase

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