You found a WHAT

You Found a WHAT?: 

You Found a WHAT? The short but exciting saga of the removal of a small underground storage tank Pamela A. Boatright OSRHE, RTC Coordinator

View of UST: 

View of UST

Initial Characterization : 

Initial Characterization History Probably Jet Fuel/Aviation Gas Some talk about “oil” disposal Tank and Fluid Volume Calculation Initial Fluid Sample Testing Results Determine Cost of Fluid Disposal

Tank and Fluid Volume Calculation: 

Tank and Fluid Volume Calculation

Tank Measurements: 

Tank Measurements Top of vent pipe to bottom of tank 86 inches Top of vent pipe to top of tank 38 inches 86-38 = 48 inches diameter Depth of liquid at initial characterization 18 inches Slight kerosene odor (jet fuel)

Fluid Volume Calculation: 

Fluid Volume Calculation Height Depth Gal Remaining = Depth Factor x Tot. Volume Ratio = H/D, use table to get Depth Factor (or call OCC to calculate)

Fluid Volume: 

Fluid Volume 18”/48” = ratio of 0.375 Depth Factor of 0.3486910 0.3486910 x 550 = 192 gallons 3.5 barrels It looked like just oily, dirty water, but test results indicated otherwise

Initial Fluid Sample Results: 

Initial Fluid Sample Results Flashpoint < 108 °F (140°F)261.21 Total Lead 0.32 mg/L (5 mg/L)TCLP Benzene 685 µg/L (0.5 mg/L)TCLP Ethylbenzene 2482 µg/L Toluene 9608 µg/L Xylene 14859 µg/L TOX 28.9 mg/L (halogens)

Cost of Characterization: 

Cost of Characterization Flashpoint $10 Total Lead $15 Total Halogens $75 BTEX $50 Other costs - Bailer $1 Mgr, Tech & Mileage $288 TOTAL $450

About liquid disposal..... : 

About liquid disposal..... More Phone calls You won’t believe the prices! $1800-$2000 ($10.40/gallon) When they returned my calls, that is… OU contractor (PCI) stated that it could be profiled as “non-regulated”, but I did not pursue this issue since they would not be pumping the tank anyway (would have been an additional cost).

About liquid disposal..... : 

About liquid disposal..... When all else fails, call your colleagues! Melanie Stinnett helped save OU a lot of money.

About that liquid...... : 

About that liquid...... Secondary Characterization Clearwater Environmental, Inc. Additional test showed water with only a slight film of petroleum liquid Submitted proposal of $1250 for removal of the tank and its destruction Fluid disposal would be a separate cost Some of the Oklahoma contractors who can handle petroleum contaminated fluid disposal January Environmental Services FER (January subcontractor) SQG Services

Next, the dry stuff…: 

Next, the dry stuff… Regulations Paperwork Reports

Regulations: 

Regulations DEQ Storm Water Oklahoma Corporation Commission (OCC) 2101 North Lincoln Blvd. OKC., Jim Thorpe Bldg., 2nd Floor http://www.occ.state.ok.us/ http://www.occ.state.ok.us/TEXT_FILES/Rulesfrm.htm Word, HTML, WordPerfect EPA 40 CFR Part 261 for hazardous waste disposal

OCC Jurisdiction : 

OCC Jurisdiction Above or underground storage tanks that contain: Antifreeze Motor Oil Motor Fuel Gasoline Kerosene Diesel Aviation Fuel

Exclusions from OCC Regulations: 

Exclusions from OCC Regulations Agricultural and residential tanks with a capacity of 1100 gallons or less used for noncommercial purposes Heating oil tanks UST systems storing hazardous wastes Certain pipeline facilities Flow-through process tanks Certain oil and gas operations Tanks with a capacity of less than 110 gallons Swimming pools Coffins Tanks that serve as emergency backup for storage provided they are emptied promptly

OCC UST Regulations: 

OCC UST Regulations Title 165; Chapter 25 Underground Storage Tanks Effective 6.13.2002 Title 165, Chapter 29 Remediation of Petroleum Storage Tanks Effective 5.11.2001

Title 165; Chapter 25: 

Title 165; Chapter 25 Part 7 Incorporated Codes and Standards Part 9 Notification and Reporting Requirements Part 11 Recordkeeping Part 13 Removal and Closure of UST Systems Part 15 Corrective Action Requirements (*see Ch. 29)

Part 11 Recordkeeping: 

Part 11 Recordkeeping 165:25-1-55 Report within 25 days of removal to OCC to include: Owner’s name and address Drawings Disposition of soils removed Disposition of tank(s) Copies of lab results Records must be retained for at least 3 years

Part 13; Removal and Closure165:25-3-64.1 : 

Part 13; Removal and Closure 165:25-3-64.1 USTs must be removed by a licensed UST Remover (all UST installers are also licensed removers) Closure in place is rare, but may be granted under certain circumstances Any sampling at tank closures must be under the supervision of a licensed Remediation Consultant

UST Certified Consultants, etc. : 

UST Certified Consultants, etc. List of Licensed Consultants, Installers, and Removers Available at OCC, but not their website Person’s Name Company Address Type of certification License number Effective and Expiration Dates

Part 13; Removal and ClosureChapter 165:25-3-65 : 

Part 13; Removal and Closure Chapter 165:25-3-65 Assessing Site Closure Samples must be analyzed by an “ODEQ certified laboratory” List of “wastewater” labs at DEQ, but not specific for soils If contaminated soils, contaminated ground water, or free product as a liquid or vapor is discovered, the owner must begin a corrective action in accordance with 165:29.

Title 165, Chapter 25: 

Title 165, Chapter 25 Penalties $10,000 each day of a violation Failure to comply with orders may result in $25,000/day for each tank for each violation Failure to submit tank closure report $250 Failure to notify OCC of a release $250 Failure to measure for contaminants $500 Failure to maintain closure records $250

Chapter 29; Part 3 (165:29-3-65)Release Investigation Action Levels: 

Chapter 29; Part 3 (165:29-3-65) Release Investigation Action Levels Benzene Native soil – 0.5 mg/kg Groundwater – 0.005 mg/l Toluene Native Soil – 40.0 mg/kg Groundwater – 1.0 mg/l Ethyl Benzene Native Soil – 15.0 mg/kg Groundwater - 0.7 mg/l Xylene Native Soil – 200 mg/kg Groundwater – 10.0 mg/l TPH* Native Soil – 50.0 mg/kg Groundwater – 2.0 mg/l Total Lead, if appropriate *Total Petroleum Hydrocarbon: Gasoline Range Organics (GRO) and/or Diesel Range Organics (DRO)

The Removal Process: 

The Removal Process Find (reasonable) contractors Call OKIE to find buried lines, piping Remove the fluid (just prior to tank removal) Remove the tank Sample native soil and backfill Wait for results to refill, if a large hole is dug Close up hole Wait for results Approve final report, paperwork, and invoice

Consultant Requirements: 

Consultant Requirements Liability Insurance Workers’ Compensation Insurance Notify OKIE Subcontract for licensed tank remover Subcontract for acceptable waste hauler Schedule with OCC (2-week notice required) and give OU 48-hours notice of intent to remove

Consultant Requirements: 

Consultant Requirements Remove and dispose of tanks and lines/piping to meet OCC rules Collect and analyze soil samples from tank pit as required by OCC Backfill tank pit with excavated materials and select material to grade Prepare and submit UST closure reports to OCC (2 copies for OU)

Contractor Requirement: 

Contractor Requirement Final Closure Report must include: Tank Destruction Paperwork Soil Lab Results and Lab QA/QC data sheets Waste material destruction paperwork Does NOT generally cover: Additional soil samples Removal of dispensers, islands, etc. Soil compaction tests Disposal of contaminated soils, water Damages to private utility lines not identified by the property owner

OCC Pays: 

OCC Pays OCC Fund Clearwater applied and was approved for reimbursement for soil testing (42 cubic yards – backfill and native soil) before work started OCC agreed that one sample each for backfill and native soil would be sufficient

Chapter 29; Part 3 (165:29-3-65)Release Investigation Action Levels: 

Chapter 29; Part 3 (165:29-3-65) Release Investigation Action Levels Benzene Native soil – 0.5 mg/kg Groundwater – 0.005 mg/l Toluene Native Soil – 40.0 mg/kg Groundwater – 1.0 mg/l Ethyl Benzene Native Soil – 15.0 mg/kg Groundwater - 0.7 mg/l Xylene Native Soil – 200 mg/kg Groundwater – 10.0 mg/l TPH* Native Soil – 50.0 mg/kg Groundwater – 2.0 mg/l Total Lead, if appropriate *Total Petroleum Hydrocarbon: Gasoline Range Organics (GRO) and/or Diesel Range Organics (DRO)

Vacuum Truck: 

Vacuum Truck

Vacuum Truck: 

Vacuum Truck

Placarding: 

Placarding

Fluid Removal: 

Fluid Removal

Vacuum Truck: 

Vacuum Truck

Dry Ice for Blanketing : 

Dry Ice for Blanketing

Excavation: 

Excavation

Excavation: 

Excavation

Excavation: 

Excavation

Looking for the eyebolt: 

Looking for the eyebolt

Removal: 

Removal

Removal: 

Removal

Removal: 

Removal

Note the icy spot: 

Note the icy spot

Yep, there were holes: 

Yep, there were holes

The Pit: 

The Pit

Looking for Native Soil: 

Looking for Native Soil

Sampling Native Soil: 

Sampling Native Soil

Soil Testing Results – Native: 

Soil Testing Results – Native ISOTEK, LLC (ODEQ #9522) Result MDL Benzene ND 5 ug/kg Toluene ND 5 ug/kg Ethylbenzene ND 5 ug/kg Total Xylenes ND 5 ug/kg TPH (GRO) 10 mg/kg 1 ug/kg (50 mg/kg)

Soil Testing Results – Backfill: 

Soil Testing Results – Backfill ISOTEK, LLC (ODEQ #9522) Result MDL Benzene ND 5 ug/kg Toluene ND 5 ug/kg Ethylbenzene ND 5 ug/kg Total Xylenes ND 5 ug/kg TPH (GRO) ND 1 ug/kg Total Lead 0.1 mg/kg 89.4mg/kg* *ODEQ guidelines 400 mg/kg (ppm)

Soil Test Results: 

Soil Test Results OCC agreed (in writing) that site conditions at the time of tank removal that there was no contamination of concern TPH below level of concern Lead locked into soil of backfill (no solvent to carry it away)

Final Cost of Fluid Disposal: 

Final Cost of Fluid Disposal Final cost $3.63/gallon for 273 gallons ($989.90 total) Separation and treatment by Permafix in Tulsa Subsequent fuel blending of flammable portion

The Cover-Up : 

The Cover-Up

Final Paperwork: 

Final Paperwork Final Report OCC Report Copy Soil Sample Results Tank Destruction Approved OCC Purchase order to Clearwater Approve the Bill UST Removal (as proposed) $ 1250.00 Final Fluid Removal $ 989.80 TOTAL COST $ 2239.80

Other Resources: 

Other Resources DEQ http://www.deq.state.ok.us/ECLSnew/Fact%20Sheets%20ECLS/diesel%20spills.html Bioremediation of Excavated Petroleum Contaminated Soil Procedures for the Remediation of Diesel and Gasoline Spills