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

2. View of UST

3. 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

4. Tank and Fluid Volume Calculation

5. 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)

6. 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)

7. 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

8. 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)

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

10. 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).

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

12. 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

13. Next, the dry stuff…  Regulations  Paperwork  Reports

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

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

16. 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

17. 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

18. 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)

19. 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

20. 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

21. 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

22. 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.

23. 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

24. 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)

25. 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

26. 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

27. 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)

28. 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

29. 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

30. 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)

31. Vacuum Truck

33. Placarding

35. Fluid Removal

36. Vacuum Truck

37. Dry Ice for Blanketing

38. Excavation

41. Looking for the eyebolt

42. Removal

45. Note the icy spot

46. Yep, there were holes

47. The Pit

48. Looking for Native Soil

49. Sampling Native Soil

50. Soil Testing Results – Native  ISOTEK, LLC (ODEQ #9522) ResultMDL BenzeneND5 ug/kg TolueneND5 ug/kg EthylbenzeneND5 ug/kg Total XylenesND5 ug/kg TPH (GRO)10 mg/kg1 ug/kg (50 mg/kg)

51. Soil Testing Results – Backfill  ISOTEK, LLC (ODEQ #9522) Result MDL BenzeneND 5 ug/kg TolueneND 5 ug/kg EthylbenzeneND 5 ug/kg Total XylenesND 5 ug/kg TPH (GRO)ND 1 ug/kg Total Lead 0.1 mg/kg 89.4mg/kg* * ODEQ guidelines 400 mg/kg (ppm)

52. 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)

53. 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

54. The Cover-Up

55. 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

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