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You Found a WHAT?
The short but exciting saga of the removal of a small underground
storage tank
Pamela A. BoatrightOSRHE, RTC Coordinator
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 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
Height
Depth
Gal Remaining = Depth Factor x Tot. VolumeRatio = H/D, use table to get Depth Factor (or call
OCC to calculate)
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
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
Flashpoint $10 Total Lead $15 Total Halogens $75 BTEX $50 Other costs - Bailer $1 Mgr, Tech & Mileage $288 TOTAL $450
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.....
When all else fails, call your colleagues! Melanie Stinnett helped save OU a lot of
money.
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
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 Above or underground storage tanks
that contain: Antifreeze Motor Oil Motor Fuel Gasoline Kerosene Diesel Aviation Fuel
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
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 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 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
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.
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
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
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 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 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 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
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 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 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 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)
Soil Testing Results – Native ISOTEK, LLC (ODEQ #9522)
ResultMDL
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 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
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 $3.63/gallon for 273 gallons ($989.90 total)
Separation and treatment by Permafix in Tulsa
Subsequent fuel blending of flammable portion
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