Maintaining Conventional Residential Oil-Fired Heating Systems
Proposed Changes to DEQ Heating Oil Guidance. Background Present guidance developed in 2006/early...
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Transcript of Proposed Changes to DEQ Heating Oil Guidance. Background Present guidance developed in 2006/early...
Heating Oil Tank Investigations
Proposed Changes to DEQ Heating Oil Guidance
BackgroundPresent guidance
developed in 2006/early 2007became effective in March 2007
9000+ heating oil discharges have been evaluated since March 2007
Draft Heating Oil Investigation GuidanceUtilize experience gained over the past 7
years and 9000+ casesIncrease flexibility of approachFocus is on environmental concerns.
Guidance not intended to meet needs of:building and fire codesreal estate/property transactionscounty ordinances
Present Guidance Draft Guidance
Automatically placed in Category 3
May be placed in any category
Various factors such as throughput may be considered when deciding category
Discharges from tanks > 1000 gallons
NFAPresent Guidance Draft GuidanceLow riskLittle to no FPLittle to no sat. soilTypically used
area has public water tank out of service for
extended period
Low riskTypically used
area has public water tank out of service for
extended periodNOTE: presence of FP
or sat. soil does not automatically place site in a particular category.
Category 1Present Guidance Draft GuidanceLow riskLittle to no FPLittle to no sat. soilRequire limited field
work and characterization
Scope of work nearly standard in all cases
Tanks usually pumped out
Low riskRequire limited field work
and characterizationScope of work is more
flexible than beforePresence of FP/sat. soil
does not preclude use of this category
If only water in tank, tank may not be pumped out
Transition- Cat 1 to Higher CategoryPresent Guidance Draft GuidanceProbability to impact
receptorHigh Cat 3moderate Cat 2
If FP or significant quantity of sat. soil present Cat 2
Probability to impact receptorHigh Cat 3moderate Cat 2
Communication about transition probably will be handled via email to consultant
Category 2Present Guidance Draft GuidanceCatastrophic releases start
hereHave FPHave sat. soilVapors in non-living spacesBelieved to present risk to
DW and/or surface waterScope of work relatively
standard. Excavation usually
required
Catastrophic releases start here
Believed to present threat to receptors
Vapors in non-living spaces
Scope of work may varyNeed for excavation
decided on case-by-case basis
Transition- Cat 2 to Cat 3Present Guidance Draft GuidanceIf > 3 MWs neededIf > 2 post SCR
monitoring events needed
If additional FP rec. or Sat soil removal needed after site characterization
If > 3 MWs needed If > 4 post SCR
monitoring events needed. Also, will go to CAP.
If additional FP rec. or Sat soil removal needed after site characterization
Draft Guidance – Discusses Threats of Discharge and Confirmed DischargesConfirmed dischargesPresence of visible FP in environmentTPH conc. in soil > 100 mg/kg or in water >
1 mg/l. Samples collected in close proximity to tank.
TPH conc. > det. limit for method if samples collected > 20’ from tank
Confirmed Discharges- continuedImpacted receptor
petroleum contaminated water supplypetroleum in nearby stream
Documented, inordinate loss of fuel from tank
NOTE: petroleum vapors in basement do not constitute a confirmed discharge.
Threat of Discharge“Suspected” release does not exist for Article
11. The term “threat of a discharge” is usedOperators are responsible for managing their
equipmentDischarge has not occurred, therefore, no
VPSTF accessFailure to mitigate threat of discharge may
be interpreted as negligence or willful misconduct
Examples of Discharge ThreatsUST that likely will overflow; especially
during next precipitation eventAST whose support structure is in such poor
condition that collapse is likelyAST w. severely corroded/thinned tank
bottom
Conditions potentially indicating a dischargeActive heating oil UST w. > 1” of waterOperational problems w. furnaceCombination of tank and context of its
locationPID/FID reading > background
DEQ may recommend that operator determine if discharge has occurred, but will not require such action
Heating Oil Discharges into BasementsFound in Chapter 2 of existing technical
manualRevised/clarified and now in heating oil
sectionCatastrophic releases VPSTF eligible.
overfills of tank in basement...not eligible - negligence
Drips/persistent leaks maintenance issue and not covered
Characterization by ExcavationHave added a section discussing
characterization by excavation