Heating Oil Tank Investigations

Proposed Changes to DEQ Heating Oil Guidance

BackgroundPresent guidance

developed in 2006/early 2007became effective in March 2007

9000+ heating oil discharges have been evaluated since March 2007

Draft Heating Oil Investigation GuidanceUtilize experience gained over the past 7

years and 9000+ casesIncrease flexibility of approachFocus is on environmental concerns.

Guidance not intended to meet needs of:building and fire codesreal estate/property transactionscounty ordinances

Present Guidance Draft Guidance

Automatically placed in Category 3

May be placed in any category

Various factors such as throughput may be considered when deciding category

Discharges from tanks > 1000 gallons

NFAPresent Guidance Draft GuidanceLow riskLittle to no FPLittle to no sat. soilTypically used

area has public water tank out of service for

extended period

Low riskTypically used

area has public water tank out of service for

extended periodNOTE: presence of FP

or sat. soil does not automatically place site in a particular category.

Category 1Present Guidance Draft GuidanceLow riskLittle to no FPLittle to no sat. soilRequire limited field

work and characterization

Scope of work nearly standard in all cases

Tanks usually pumped out

Low riskRequire limited field work

and characterizationScope of work is more

flexible than beforePresence of FP/sat. soil

does not preclude use of this category

If only water in tank, tank may not be pumped out

Transition- Cat 1 to Higher CategoryPresent Guidance Draft GuidanceProbability to impact

receptorHigh Cat 3moderate Cat 2

If FP or significant quantity of sat. soil present Cat 2

Probability to impact receptorHigh Cat 3moderate Cat 2

Communication about transition probably will be handled via email to consultant

Category 2Present Guidance Draft GuidanceCatastrophic releases start

hereHave FPHave sat. soilVapors in non-living spacesBelieved to present risk to

DW and/or surface waterScope of work relatively

standard. Excavation usually

required

Catastrophic releases start here

Believed to present threat to receptors

Vapors in non-living spaces

Scope of work may varyNeed for excavation

decided on case-by-case basis

Transition- Cat 2 to Cat 3Present Guidance Draft GuidanceIf > 3 MWs neededIf > 2 post SCR

monitoring events needed

If additional FP rec. or Sat soil removal needed after site characterization

If > 3 MWs needed If > 4 post SCR

monitoring events needed. Also, will go to CAP.

If additional FP rec. or Sat soil removal needed after site characterization

Draft Guidance – Discusses Threats of Discharge and Confirmed DischargesConfirmed dischargesPresence of visible FP in environmentTPH conc. in soil > 100 mg/kg or in water >

1 mg/l. Samples collected in close proximity to tank.

TPH conc. > det. limit for method if samples collected > 20’ from tank

Confirmed Discharges- continuedImpacted receptor

petroleum contaminated water supplypetroleum in nearby stream

Documented, inordinate loss of fuel from tank

NOTE: petroleum vapors in basement do not constitute a confirmed discharge.

Threat of Discharge“Suspected” release does not exist for Article

11. The term “threat of a discharge” is usedOperators are responsible for managing their

equipmentDischarge has not occurred, therefore, no

VPSTF accessFailure to mitigate threat of discharge may

be interpreted as negligence or willful misconduct

Examples of Discharge ThreatsUST that likely will overflow; especially

during next precipitation eventAST whose support structure is in such poor

condition that collapse is likelyAST w. severely corroded/thinned tank

bottom

Conditions potentially indicating a dischargeActive heating oil UST w. > 1” of waterOperational problems w. furnaceCombination of tank and context of its

locationPID/FID reading > background

DEQ may recommend that operator determine if discharge has occurred, but will not require such action

Heating Oil Discharges into BasementsFound in Chapter 2 of existing technical

manualRevised/clarified and now in heating oil

sectionCatastrophic releases VPSTF eligible.

overfills of tank in basement...not eligible - negligence

Drips/persistent leaks maintenance issue and not covered

Characterization by ExcavationHave added a section discussing

characterization by excavation