Yes I Have My Permit What Now Call the Petroleum Tank Cleanup Section PTCS Are there petroleum releases at the facility Coordination Coordination w PTCS Minor Repairs UST wants to help you get the system running again ID: 752177
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Slide1
IT’S A DIRTY JOB…
And You Get To Do It!Slide2
Yes! – I Have My Permit, What Now?
Call the Petroleum Tank Cleanup Section (PTCS):
Are there petroleum releases at the facility?
Coordination!Slide3
Coordination w/ PTCS
Minor Repairs:
UST wants to help you get the system running again;
PTCS wants to see if there has been a release to the environment.
Example: Libby School
Photo from: www.commtank.comSlide4
Coordination w/ PTCS
Major Upgrades:
Successful Coordination
Kalispell
Hungry Horse
Worst CaseI’ve excavated, now what?I left it there, what is DEQ going to do about itSlide5
Who are we?-DEQ PTCS Contacts:
Section Supervisor – Amy Steinmetz (444-6781)
Helena Office:
Shannon Cala (444-6377)
Heidi Barnes (444-6424)
Donnie McCurry (444-6584)Allen Schiff (444-6728)William Bergum (444-0216)Marla Stremcha (444-6419)Brandon Kingsbury (444-6547)Bozeman Office:Latysha Pankratz (586-2779)Billings Office:Jay Shearer (247-4451)Kalispell Office:
Reed Miner (755-8982)
Dean Kinney (755-8983)Slide6Slide7
Soil Sampling During Closure
What are you doing?
Why are you doing it?
What do I need from the lab?
Taking the sample
Submitting to the lab
How to interpret the results
Who do you callSlide8
WHAT ARE YOU SAMPLING FOR?
What was stored? Billings site – gasoline UST converted to diesel
Refer to the Risk Based Corrective Action (RBCA) Guidance
Table B — Testing Procedures for SoilsSlide9
RBCA Guidance Table BSlide10
THE LAB…
They have stuff
Jars
Coolers
Custody Seals
Chains of CustodyPrepaid Shipping LabelsSlide11
So you’re removing some stuff…
Please notify the DEQ Petroleum Tank Cleanup Section (PTCS) when you are going to a facility
to remove or up-grade tanks/piping/dispensers
(a couple days notice would be awesome
.)We want to make friends!We want to be there when the ground is open.We want to help you make quick on-site decisions.Slide12Slide13
Soil Sampling Purpose
“Measure for the Presence of a Release”
ARM 17.56.703
Collect Samples as Soon as Possible
Collect from “suspected worst-case locations”
Obviously Contaminated Soils“Determine the Extent and Magnitude of Contamination”ARM 17.56.602Extra Samples Are Allowed
Can Save Your Client $$$$Slide14
Where Do I Collect My Samples
Suspected worst-case locations, which may include:
Highest vapor readings,
Stained or discolored
Tank meets piping
Beneath fill linesSlide15
Taking the Sample
Soils APPEAR CleanPermit required samples:
Equal parts soil
Mix the sample
Remove large pebbles
Composite into jarRemember to decontaminate your tools
Photo: It’s a Google image
Sample soils as required
by your permit
Hey, it’s a union!Slide16
Soil Sampling Techniques
Discrete Soil Samples:
Sidewalls
Base of Excavation
Obviously Contaminated SoilsPID >100 ppm
(rule of thumb)Composite Soil Samples:Piping TrenchesOver-excavated SoilsLandfarmsSlide17
Taking the Sample
Soils DO NOT APPEAR
Clean
DISCRETE Soil Samples:
Soils from one point
Documentation: LocationDepthMap of Layout
Photo: Conrad and Ennis
(Can you find the Blue Golf Ball?)Slide18
Soil Sampling Protocol
Gloves
Protect self and sample
Separate from Field Screen Sample
Composite
Piping trench: every 20 feet, composite up to 5. Don’t just start filling a jar from 5 different locationsOR
www.kixcereals.com
www.gemplers.comSlide19
Soil Sampling Protocol
Simplify Your Composite Sample:
Have the lab do it!
Nothing to
decon
No pinch of this dash of that, equal distribution
www.kixcereals.comSlide20
Not All Samples Are Created Equal
“Department may reject . . . test results, if it has reasonable doubt as to the quality of the data ”
Chain of Custody
Receipt temperature
Holding time
(Billings Site)Slide21
A Picture is worth a 1,000 words
Source: A Leaking Pipe Fitting
Extent of Contamination: Soil Staining
Extent of Cleanup
Photo: 1989 Helena Tank PullSlide22
When Do I Call DEQ?
17.56.502
“Within 24 Hours of discovery of:”
Visual or olfactory
Failed (or inconclusive) Tightness test
Erratic behavior that can’t be diagnosed and repairedProduct in secondary containmentWater in the tankSlide23
When Do I Call DEQ?
17.56.502
“Within 24 Hours of discovery of:”
Visual or olfactory
Failed (or inconclusive) Tightness test
Erratic behavior that can’t be diagnosed and repairedProduct in secondary containmentWater in the tankSlide24
Soils
DO NOT APPEARClean
Contact the DEQ PTS
Within 24-Hours
1-800-457-0568
This system removal offers a great opportunity to over-excavate source contamination and reduces potential clean-up costs and time!Photo provided by:S. Cala (Great Falls)Slide25
Who Should Call DEQ?
17.56.502
“… any person who installs or removes and UST …. Any person who performs a tank tightness test or line tightness test”
YOU
Information commonly lacking:
Coordinates (It’s a big site)Contact info for Owner/OperatorTank IDsPictures (before, during, after cleanup)Slide26
How to Interpret the Results…
Clues you can use to help review the results:
Check the Qualifiers Column and look for an * or
Look at the result column for numbers in
BOLD Slide27
http://deq.mt.gov/lust/rbca.mcpx
RBCA Guidance
(pg 18)
Table 1
—
Tier 1 Surface Soil RBSLs Column 1(or check pocket reference)Slide28
Who do you call?
Are any of the results above RBCA RBSLs, the MCL number listed on the analytical report, or the pocket reference?
No-contact the owner/operator and DEQ Permitting and Compliance UST Section to report the results
If you had previously reported the site as a suspected release during the removal process to DEQ PTCS, please contact the PTCS staff member you had previously contacted to report the results as below RBSLs.
Yes-contact the owner/operator, DEQ UST, and PTCS to report the results
DEQ PTCS 1-800-457-0568 and ask to speak with the Leak OfficerPlease be prepared to provide the following information:Facility Name, Address, Facility ID, Facility Owner/Operator, and a Contact for the Facility, along with the site information associated with the removal.Slide29
The LUST web page:
http://deq.mt.gov/LUST/default.mcpxYOU MUST SPEAK TO A PERSON…voicemails/e-mails are unacceptable
Hotline for reporting leaks:
1-800-457-0568
After hours and holidays:
1-406-324-4777Slide30
Questions…Slide31
Quiz Time
Do I have to call Petroleum Tank Cleanup Section?
No, It’s not required, but it is recommended:
Coordination of remediation
DEQ prepared to help you address found contamination
QUESTIONSANSWERSSlide32
Quiz Time
When should you take a Discrete Soil Sample?
When you suspect a petroleum release has occurred:
Visual
Olfactory
Field Screening Results PID etc.QUESTIONSANSWERS
2006 Oil Spill – The PhilippinesSlide33
Quiz Time
Can I collect more than the permit required samples?What is the best/ easiest way to composite samples?
Yes, Permit requirements are minimum requirements.
Let the lab do it.
Mixed in controlled environment
Better precisionNo decon QUESTIONSANSWERSSlide34
Quiz Time
If you smelt it then you must
Me?
CONTACT PTCS
Yes
QUESTIONSANSWERSSlide35
Quiz Time
A suspected release (or an obvious release) must be called in within
24 HOURS
QUESTIONS
ANSWERSSlide36
Quiz Time
The samples must reach the lab within days.The lab must receive the sample at what temperature?
7 days
Trick Question:
Between 2° and 6° C
QUESTIONSANSWERSSlide37
Quiz Time
A confirmed release through laboratory analysis must be called in within
7 CALENDAR DAYS
QUESTIONS
ANSWERSSlide38
THANK YOU