Whether you’re upgrading your tanks, cleaning up a petroleum release, or thinking about property transactions, as a tank owner you face a lot of business decisions. The key to spending money wisely is knowing your options. That’s why the Washington Oil Marketers’ Association (WOMA) and the Department of Ecology are sponsoring a traveling workshop for tank owners and consultants in November.
Topics to be addressed at the workshop will include cleanup technologies, formal and informal processes for conducting and reporting cleanups, ways to reduce liability, and deadlines for tank upgrades -- among others. Of particular interest to many will be a presentation on the status of a new policy on cleanup levels for total petroleum hydrocarbons.
The half-day workshops will be held in Vancouver, Tacoma, Lynnwood, and Bellingham the week of November 11. For the week of November 18, the workshops will be held in Moses Lake, Pasco, and Spokane.
In addition to tank owners, WOMA and Ecology encourages tank service providers and other contractors and environmental attorneys to participate.
You can expect more information about the workshops in early fall. In the meantime, if you have questions or suggestions to offer, please call Mike Sciacca of WOMA at (206) 780-9226 or Emily Ray of Ecology at (360) 407-7174.
Last October, the State of California and Lawrence Livermore National Labora- tory (LLNL) released a report on leaking underground fuel tank sites. This report had been conducted at the request of the California State Water Resources Control Board (SWRCB) UST program. The California SWRCB asked the Lawrence Livermore National Laboratory (LLNL) and the University of California at Berkeley, Davis, Los Angeles, to reevaluate the state’s Leaking Underground Fuel Tank (LUFT) Cleanup Procedure. The US EPA Region IX UST Program provided some financial support for the study. California currently has over 21,000 LUFT sites.
The LLNL study focused on the number of public water supply wells that have been impacted by fuel from leaking tank sites. The LLNL study found that of 12,150 public water supply wells tested statewide, 48 or less than 0.4 % have reported measurable benzene concentrations. Consequently, the LLNL study has recommended that “mother nature” e.g. natural attenuation and biodegredation, be used as the preferred remedial alternative for leaking tank sites greater than 250 feet from a public water supply well.
The recommendation to not actively treat contaminated soil and ground water from leaking tanks sites that are more than 250 feet from a water well has sparked controversy throughout the UST industry. Those who support the LLNL study believe that it is a prudent and cost-effective move. Others feel that the LLNL study is weak scientifically and has little or no merit.
Ecology is currently reviewing the human-health and environmental effects of fuels or total petroleum hydrocarbons (TPH). An interim policy on TPH is currently being reviewed. A final policy on TPH and protocols for leaking tank site cleanup is expected in the near future.
(adapted from Underground Tank Technology Update -Jan/Feb/1996)
The following article summarizes the session entitled 1998 Requirements: Encouraging Early Compliance from the 1996 National UST/LUST Conference held in Savannah, Georgia.
Some important issues discussed during this session included:
EPA’s Strategy: the primary goal of EPA’s strategy is to encourage early compliance. To achieve full compliance in 1998, work must be spread out over the next few years, otherwise vendors and contractors will be unable to meet the demands of owners/operators of UST systems. According to a Petroleum Equipment Institute (PEI) survey of its members, about 400,000 tank systems have been upgraded; another 800,000 need to be upgraded, replaced, or closed. Of these 800,000, PEI estimates that about 300,000 will be upgraded or replaced.
State’s Responsibilities: states must establish a field presence and enforce existing requirements so owners/ operators take the 1998 deadline seriously. In addition to letting owners/operators know that EPA is serious about enforcement, regulators must take every opportunity to educate them about the 1998 requirements. States and EPA must keep repeating the same messages:
Ecology recently added a new section to the Master Business License Underground Storage Tank Addendum. The pink-colored sheet with your Master Business License now requests that you sign a “Terms and Conditions” for obtaining your UST permit. Completion of the UST Addendum is required when there has been a retrofit, change of ownership, or new installation. This new section of the Addendum will help communicate what is required to operate an UST. In the near future, a list of these terms and conditions will also be part of the permit renewal process.
Have you switched from oil to natural gas or electricity as a means of heating your house and don’t know what to do with your old tank? Although Ecology doesn’t regulate the use or operation of home heating oil tanks, we do receive a lot of phone calls from concerned people wanting to know what to do (your local Fire Chief or Fire Marshal is actually responsible for the regulation of heating oil tanks).
The first thing you need to do is find out what’s in your tank. If you have trouble locating your tank, try following the fuel lines from the house; locating the tank vent pipes; or using a hand probe or metal detector. If you find heating oil in your tank, Ecology strongly recommends that you have it removed. Removing the unused oil is the easiest, least costly, and single-most important action you can take to prevent contamination of soil and ground water. Once you’ve removed the heating oil, your next step is to think about having your tank removed or closed in place.
Ecology recommends that you have your tank removed. If the tank has leaked, it will be easier to find and clean contaminated soil. Tank removal allows visual inspection of the area under the tank and allows more accurate soil sampling. You should get several price quotes for the work you are having done. Make sure the contractor has a Washington contractor’s license and is properly bonded. Require the contractor to provide you with a customer reference list and an itemized estimate of costs. Costs vary within the state, but it is reasonable to expect excavation of one tank (1,00 gallon); disposal of the tank, including cleaning and salvage; and backfilling of the hole to cost between $900 and $1,100. If the tank is buried under a driveway or deck, the cost of removal, etc., will be more. If contamination is found, you will need to hire a cleanup contractor. The cost of removing contaminated soil costs about $80 to $90 per cubic yard and includes excavation, backfill, loading, transportation, disposal, and taxes.
Closing your tank in place is a popular option for residential tanks -- especially if removal isn’t possible. Before choosing this alternative, consider the future of your property. Potential buyers or lenders may require you to remove the tank, and a filled tank is harder to remove. Again, costs vary within the state, but removing oil and sludge from your tank should cost no more than $200. It should take no more than 4.5 cubic yards of inert solid material, such as sand or foam, to fill a 1,000 gallon UST.
But before you close or remove your tank, talk to your local Fire Marshal/ Chief and city or county building department. Ask about permits, inspections, or other requirements that may apply to residential heating oil tank closure or removal in your area.
It is not uncommon in Washington state to find old wells which are no longer usable. These are called abandoned wells.
Abandoned wells can pose safety and environmental problems. Perhaps the greatest danger associated with abandoned wells is injury or death of people and animals who fall into the well. Abandoned wells also act as direct conduits, or paths, for contaminants to reach ground water. Contaminants entering the ground water through the well may harm the quality of your drinking water.
Knowing the history of the property you own or are considering buying may help you determine where to look for abandoned wells. It is not uncommon to find as many as three or four wells on an old homestead property. Wells are often constructed in basements of houses, under porch steps, or near cisterns or windmills.
Here are some general tips you may follow when looking for abandoned wells:
For more information, call 1-800-468-0261.
TANK RACER is a windows-based PC software that provides fast, accurate, and comprehensive cost estimates for cleanups at leaking underground storage tank (LUST) sites. State agencies and consultants can use TANK RACER to determine reasonable costs for cleanups on a site-specific basis. The software is designed to enable all parties to avoid paying inflated costs.
TANK RACER estimates costs for all phases of remediation: site assessment, remedial design, remedial action, operations and maintenance, tank closure, site work and utilities. It also estimates costs for alternative technologies, such as: bioremediation, soil vapor extraction, thermal desorption, ground water extraction wells, air sparging, and landfarming.
TANK RACER can also enable the user to answer key questions, such as:
TANK RACER was produced through an Interagency Agreement between the US Air Force and the US Environmental Protection Agency. For more information, please contact Delta Research Corporation (904) 897-5380.
Eight out of ten cleanups are completed independent of Ecology oversight. Ecology encourages independent cleanups. This allows hundreds of smaller or less complex sites to be cleaned up quickly without having to go through the final process.
A property owner or potentially liable person (PLP) can choose to do an independent cleanup when the site is not under an order or decree, and when the site is not subject to cleanup negotiations.
In 1993, Ecology began the voluntary Independent Remedial Action Program (IRAP) in order to offer a timely review of independent cleanup reports and give a written determination of the result of the review. This benefits property owners by expediting the sale, transfer, or development plans for their property.
Ecology staff review IRAP reports and provide written determination indicating whether the cleanup meets Model Toxics Control Act (MTCA) standards. If the cleanup is considered satisfactory, the property owner is provided with a written determination of “No Further Action.” If the report is incomplete or the site requires further cleanup, the client is sent a letter identifying the specific remedial actions needed at the site. Eighty percent of the IRAP reports reviewed have resulted in a determination of no further action. Figure 5 shows the number of IRAP reports received and results of the completed reviews.
Over $35 million dollars have been spent on cleaning up the environment at 324 IRAP sites. Figure 6 shows that about half of these cleanups cost less than $50,000 to complete. A review fee is charged based on the cost of the cleanup and reports are reviewed on a first-come, first-served basis. Over half of the clients have been charged the minimum $1000 review fee.
As a follow-up to our February ‘96 Tank Bulletin article, we’d like to list those owners of operating underground storage tanks who have participated in Ecology’s Technical Assistance Program and have been found in COMPLIANCE! They are:
Map of Ecology's Regional Offices
UST/LUST Information: 1-800-826-7716
