UNDERGROUND STORAGE TANK

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11th Annual California Unified Program Training
Conference
UST Removal Sampling and ReportingCourse M-F1
Time 800-1000amJanuary 26, 2009
Moderator Ben Wright State Water Resources
Control Board, UST Cleanup Program (916)
323-9690 bwright_at_waterboards.ca.gov
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California USTs

• Active USTs 37,300
• Confirmed Releases 42,900
• Confirmed Releases For 2008 260
• LUST/DOD Case Closures For 2008 870
• April 1, 2008 through September 30, 2008

www.epa.gov/oust/cat/camarchv.htm
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Goals

• Get Familiar With the Tank Removal Process at UST
  Sites
• Review the Requirements of One of the Regulatory
  Agencies (Santa Fe Springs)
• Suggest Some of the Important Information that
  Can be Gained During UST Removal
• Present Case Studies and Discuss Considerations
  for Clean and Dirty Sites

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Presenters
Brenda ten Bruggencate, Environmental Protection
Specialist Santa Fe Springs Department of
Fire-Rescue [phone] brendanelson_at_santafesp
rings.org Kelly Brown, Principal
Geologist Stantec [phone] kelly.brown_at_stant
ec.com
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UST REMOVAL SAMPLING AND REPORTING

• Presented by
• Brenda ten Bruggencate
• Santa Fe Springs Fire-Rescue

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PRESENTATIONOUTLINE

• Overview of permanent closure requirements
  report requirements
• 23 CCR Art. 7
• Brenda ten Bruggencate, Santa Fe Springs FD
• Sampling collection and analysis
• Kelly Brown, SECOR
• 23 CCR 2672 (d)
• Case Studies
• Clean dirty sites

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CLOSURE VS. REMOVAL

• careful with the term closure
• when
• removal
• is meant

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PERMANENT UST CLOSURE REQUIREMENTS

• 23 CCR Art. 7
• 23 CCR 2670 - General to all UST closures
• 23 CCR 2671 - Temporary closures
• 23 CCR 2672 - Permanent closure
• 23 CCR 2672 (d) - Sampling requirements
• 23 CCR Art. 4
• 23 CCR 2649 - Boring Requirements
• HSC 25298 - general

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PERMANENT UST CLOSURE REQUIREMENTS

• LG 48-5, Contractor Licensing
• A
• B
• C-36
• C-61/D-40
• Hazardous Substance Certification issued by CSLB
  BP 7058.7

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PERMANENT UST CLOSURE REQUIREMENTS

• Two types
• Removal 23 CCR 2672(b)
• Closure-in-place 23 CCR 2672(c)

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PERMANENT UST CLOSURE REQUIREMENTS

• 23 CCR Art. 7
• Time between cessation of hazardous substance
  storage and application for closure shall not
  exceed 90 days
• Closure shall be completed within a reasonable
  amount of time as determined by LIA
• SFS 6 months, with possible 6 month extension

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PERMANENT UST CLOSURE REQUIREMENTS

• 23 CCR 2670 requires
• UST owner or operator must submit to the LIA for
  approval, a proposal for compliance with closure
  requirements
• At least 30 days prior to closure or shorter is
  allowed by LIA

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PERMANENT UST CLOSURE REQUIREMENTS

• Variety of Processes for UST Closure Permits
  (handouts)
• Workplans, no written guidance
• One inspector issues removal permit, another
  witnesses removal
• Prescriptive forms

SFSFR
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PERMANENT UST CLOSURE REQUIREMENTS

• Owner/Operator requirements applicable to all
  permanent UST closures
• Handle residual contents removed as hazardous
  wastes or recyclable materials
• Inert possible flammables vapor at STP to levels
  that preclude explosion
• lower if required by agency
• SFSFR requires a clean certification

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PERMANENT UST CLOSURE REQUIREMENTS

• Document to LIA disposition of UST
• If disposed
• Documentation to LIA within their required time
  frame
• If destined for reuse
• Check with LIA for local requirements
• Document to LIA within their required time frame
• Name of new owner and new operator of UST
• Location of intended use
• Nature of intended use

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verify info on site
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UST CLOSURE-IN-PLACE

• What justifies leaving UST in place?
• Check with Building Dept. LIA policy
• SFSFD requires UST be within a 45 angle of
  footing of permanent structure

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UST CLOSURE-IN-PLACE
BUILDING
UST 2
UST 1
45

• Closure-in-place allowed for UST 2

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UST CLOSURE-IN-PLACE

• UST shall be filled with an inert solid
• Except if owner intends to reuse tank for
  storage of a non-haz substance
• Non-haz substance must be compatible with
  previous UST use and construction
• Check with LIA and Fire Departments on their
  requirements

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UST PIPING CLOSURE-IN-PLACE

• Remove all piping unless it will damage
  structures or other pipes
• Piping to remaining in place must be emptied of
  contents and capped
• Piping does not have to be filled with an inert
  solid, only the UST does

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SOIL SAMPLING REQUIREMENTS

• Must demonstrate no unauthorized release has
  occurred
• Must be performed during or immediately after
  UST closure activities
• Based on soil and (if present in excavation)
  water analysis
• Analyze for previously stored substance(s) and
  breakdown products or transformation products.

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SOIL SAMPLING REQUIREMENTS

• Must analyzed in a State-certified lab 23 CCR
  2649(f)(6)
• Lower detection limits must be verified by the
  lab
• Be aware of dilution
• Raises detection limits
• May miss low conc. contaminants

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SOIL SAMPLING REQUIREMENTS

• Geological logs shall be prepared by a
  Professional Geologist or Civil Engineer
• technician working under the direct supervision
  of one can do this provide the professional
  reviews the logs and assumes responsibility for
  them. 23 CCR 2649 (b)(1)(D)

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SOIL SAMPLING LOCATIONS

• Removal
• Minimum 2 below the UST bottom in native soil at
  each end of tank
• SFSFD suggests 2 4, sometimes also 10 bgs
• Every 20 linear feet of piping
• May include vent and vapor for VPH systems based
  on change in piping definition
• This include sampling under the dispenser
• Stockpile sampling (not specified in 23 CCR 2672)

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2
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SOIL SAMPLING REQUIREMENTS

• Closure-in-place
• One slant boring as close as possible to the
  midpoint of the UST OR
• Vertical borings drilled along each long
  dimensional side of UST OR
• Other method as approved by LIA

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MTBE testing required
25296.15
Confirm sample location analysis with PG on site
Typical sampling for 1-12K gas 1-12K diesel
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SOIL SAMPLING REQUIREMENTS

• Prescribed on SFSFD UST Closure Permit
• Subject to change based on field observations
• SFSFR witnesses all UST removals
• Contaminated dispenser excavation confirmation
  sampling
• Encourage businesses to do limited excavation
• If contamination fails to visually clear up in
  several scoops, discontinue and initiate site
  characterization

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REPORTING REQUIREMENTS
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REPORTING REQUIREMENTS

• 23 CCR Art. 5 Release Reporting
• Closure (Removal) Report
• URF
• Geotracker Entry
• Fee Title Holder Notification
• Public Participation

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LEAK DISCOVERYRELEASE REPORTING

• Recordable release
• Does not
• Escape secondary containment
• Increase fire or explosion hazard
• Deteriorate the secondary containment
• Cleaned up in lt 8 hours

• Reportable release
• Does
• Escape secondary containment
• Increase fire or explosion hazard
• Deteriorate the secondary containment
• Cleaned up time irrelevant

• Other
• HSC reqmts.
• Check w/ LIA

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REPORTING TIME FRAMES

• Recordable release
• Document on company records (23 CCR 2651)

• Reportable release
• Notify LIA within 24 hours
• Full report within 5 days to LIA (23 CCR
  2652)

• Refer to Response Plan in LG 133-2
• URF contains most info for reportable releases
• LIAs may have their own Response Plans

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RESPONSE PLANShttp//www.waterboards.ca.gov/water
_issues/programs/ust/leak_prevention/lgs/docs/133_
2.pdf
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UNAUTHORIZED RELEASE FORMhttp//www.waterboards.c
a.gov/water_issues/programs/ust/forms/docs/unauth_
release.pdf
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2670(f)
SFSFD requirement
2670(f)
piping dispensers
2672(b)(3) (4)
2649(f)(5) (g)
2672(c)(1)
Bus. Prof. Code 7835
Professional
2649(f)(5) (g)
2649(f)(6) HSC 25298.5
2649(f)(5) (g) HSC 25298.5
Needed to de-termine if further action is needed
2672(b)(2) (c)(2)
Bus. Prof. Code 7835
Professional
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GEOTRACKER REPORTING REQUIREMENTS

• The Electronic Reporting Regulations (Chapter 30,
  Division 3 of Title 23 Division 3 of Title 27,
  CCR) require electronic submission of any report
  or data required by a regulatory agency from a
  cleanup site.
• http//www.waterboards.ca.gov/ust/cleanup/electron
  ic_reporting/report_rqmts.html

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FEE TITLE HOLDER NOTIFICATION

• AB681, HSC 25296.20 25297.15
• Agency/Board cannot is NFA at a UST site that had
  an unauthorized release unless all current record
  owners of fee title to the site have been
  notified of the proposed action by Agency/Board.
• Agency/Board must accommodate responsible
  landowner participation in the cleanup or site
  closure process and shall consider all input and
  recommendations from any responsible landowner
  wishing to participate.

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PUBLIC PARTICIPATION

• Comply with public notification regulations
• 23 CCR 2728
• Publication in a regulatory agency meeting agenda
• Public notice posted in a regulatory agency
  office
• Public notice in a newspaper
• Block advertisements
• A public service announcements
• Letters to individual households
• Personal contacts with affected parties by
  regulatory agency staff

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LEAKING USTREPORTING REQUIREMENTS
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SAMPLING ANALYSIS COLLECTION
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UST Removal and Sampling
Kelly C. Brown January 26, 2009
Photo Optional
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UST Removal Process

• Dispensers are removed
• Product is removed from the USTs
• Gasoline, waste oil, etc.
• Product/vent lines are cleaned and drained back
  to USTs

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UST Removal Process

• Concrete caps and islands are removed
• UST and piping locations are excavated
• Piping removed (and sampled in some cases)

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UST Removal Process

• Removal of turbines from USTs
• UST freed and tilted for rinsing and cleaning
• Dry ice applied to USTs to inert them and to
  displace vapors
• USTs certified as clean by Marine Chemist

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UST Removal Process
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UST Removal Process

• USTs removed and transported for disposal

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Sample Collection

• Sampling is performed under the supervision and
  direction of the lead agency
• Permits usually dictate sampling requirements and
  analyses
• Collect soil samples at each dispenser location
  (2 to 4 feet bgs)
• Collect soil samples approximately every 20
  linear feet of piping
• Some agencies require samples at elbows and
  Ts

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Sample Collection

• Collect soil samples beneath each end of USTs (15
  to 18 feet bgs)
• Collect soil sample beneath waste oil UST (8 to
  10 feet bgs), and excavation sidewalls (if
  requested)
• Collect soil stockpile samples for disposal
  purposes
• If groundwater is encountered in UST excavations,
  collect groundwater samples
• Is product or a product sheen observed?

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Sample Collection Equipment

• Soil samples are collected at dispenser and
  piping locationsusing hand auger, drive sampler
  or backhoe bucket

Hand Auger
Drive Sampler
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Sample Collection
Soil samples in UST excavations are collected
using excavatorbucket due to excavation/confined
space issues
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Sample Collection
When groundwater is encountered in the UST
excavation, at least one groundwater sample
should be collected If product or a product
sheen is identified on groundwater, then try to
collect a product sample Groundwater samples are
usually collected using a new disposable Teflon
bailer lowered into the excavation water The
groundwater sample is then decanted into the
appropriate sample containers
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Soil Sample Containers

• Sample collection is based on agency directives
• Soil samples are collected in accordance agency
  directives, or EPA 5035A (LARWQCB jurisdiction)
• Sample containers for soil are either
• Encore type sampling devices
• Stainless steel rings
• 4 oz glass jars
• TerraCore sampler and 40 ml VOAs (1) with
  sodium bi-sulfate and methanol preservatives
  (2-3)

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Soil Sample Containers
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Groundwater Sample Containers

• Sample containers for groundwater are either
• 40 ml VOA with HCL preservative
• 500 ml plastic bottle with HNO3 preservative
• 1 L amber glass bottle, with no preservative
• 40 ml VOA with no preservative for product
  samples

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Groundwater Sample Containers
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Sample Containers and Analytical Methods

• Soil Samples
• GRO/VOCs (EPA 8260B/8270C) Encore or
  TerraCore type sample containers
• GRO, DRO, ORO (EPA 8015M), TRPH/OG (EPA
  418.1) Stainless steel rings or glass
  jars
• CAM 17 Metals (EPA 6010B/7470) - Stainless
  steel rings or glass jars
• Groundwater Samples
• GRO/VOCs 40 ml VOA, HCL preservative
• DRO/ORO/TRPH/OG 1 liter amber,
  non-preserved
• CAM 17 Metals 500 ml plastic, HNO3
  preservative

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Sample Identification
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Common Sampling Errors

• Improper decontamination of equipment
• Sampling equipment
• PPE Nitrile/latex gloves
• Improper sample containers
• Not enough sample quantity for analysis
• Not enough sample containers for required
  analysis
• Mis-interpretation of agency sampling, COC,
  and/or analytical requirements
• Inexperienced regulator and/or field staff
• Missed analytical hold times

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CASE STUDIES
CLEAN DIRTY SITES
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CASE STUDY DIRTY SITE

• Former Sunco Equipment Company
• History of non compliance
• Failed tank integrity testing
• Did not upgrade in 1998
• No response to enforcement
• Steps to prosecute civilly initiated

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• Former Sunco Equipment Company

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• Former Sunco Equipment Company

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• Former Sunco Equipment Company

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CASE STUDY DIRTY SITE

• Former Sunco Equipment Company
• SFSFR applied to the EAR account and was granted
  40,000
• Company went bankrupt
• Property was foreclosed
• Bank quickly sold to new RP
• Obtained closure permit and removed tank

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(No Transcript)
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• Clayey soil
• Pasty texture
• Limited excavation discontinued

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TPHg 400 mg/kg TPHd 3900 mg/kg High
Ethylbenzene, naphthalene, TMB ND Benzene
MTBE
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CASE STUDY DIRTY SITE

• SFSFR issues directive
• Corrective Actions Plans submitted, reviewed, and
  approved
• assessment and excavation
• lateral vertical extent of contamination
  defined
• RP excavated but incompletely

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(No Transcript)
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N
Extent of excavation
UST
B-1 (contaminated)
LEGEND
Samples collected in Round 2
Samples collected in Round 3
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TPHg 900-4000 mg/kg B 15 mg/kg TEX high
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CASE STUDY DIRTY SITE

• Remaining contamination in B-1 exceeds screening
  levels
• SFSFR requires additional remediation a
  determination if groundwater is threatened
• RP refuses additional excavation SFSFR
  determines GW is threatened without additional
  remedial action
• Case is referred to RWQCB
• Current remediation plan with RWQCB is to HSA
  excavate

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NFA LETTERS

• Uniform UST Closure Letter
• LIA/Board is responsible to issue a Closure in
  accordance with HSC 25296.10 for site that have
  undergone corrective action
• Standardized verbiage

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CLEAN SITE

• Clean
• site where risks are low enough to close without
  corrective action
• Approach to screening varies among agencies
• Check with LIA up staff and your Regional Board
• SFSFR uses Superfund PRGs LARWQCB Closure
  Criteria

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EXAMPLE

• UST removal
• All samples ND except one which has hits of 3
  contaminants
• Individual concentrations are below Superfund
  PRGs
• What about the cumulative risk?

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EXAMPLE

• Superfund PRGs contain guidance for screening at
  sites with multiple contaminants
• http//www.epa.gov/reg3hwmd/risk/human/rb-concentr
  ation_table/usersguide.htm
• Link to calculator

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EXAMPLE

• Separate the carcinogenic from non-carcinogenic
  contaminants
• Determine the screening level for each
  contaminant
• Screening levels are not clean up numbers
• But you can screen out to the point of closure

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SCREENING SITES WITH MULITPLE CONTAMINANTS
If cancer risk is lt1,000,000 you may screen out
that contaminant
If Hazard Index is lt1 you may screen out that
contaminant
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UST CLOSURE LETTER

• SFSFR issues a modified version of a closure to
  site where no corrective action was required
• Similar to HSC 25296.10 except were remove
  references to citations regarding corrective and
  replace them with
• 23 CCR 2672
• HSC 25298

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SAFETY PLANNING
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TIPS FOR INSPECTORS

• Before arriving on site
• Review the approved permit
• Know sampling locations and analyses

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JOB SITE TIPS FOR INSPECTORS

• Upon arriving on site
• Scan for immediate hazards
• Discuss overall removal plan logistics with the
  contractor
• Who is the site safety officer?
• Confirm tank disposition and destination
• Review sampling requirements with geologist
• Document differences on permit vs. actual

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JOB SITE TIPS FOR ALL

• Stop and look
• Assess the staging of the area
• What are the hazards?
• Traffic Heavy equipment
• Electrical
• Crane size
• Lift strap/cable
• Tank pit
• Tank path
• Where is the transport truck located?

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CONTACT INFO

• Brenda ten Bruggencate
• Santa Fe Springs Fire Rescue
• [phone]
• brendanelson_at_santafesprings.org