Instructions for Conducting Sampling During Underground Storage Tank Closure

Transcription

1 Instructins fr Cnducting Sampling During Undergrund Strage Tank Clsure Permitting and Cmpliance Assistance Prgram Divisin f Waste Management Flrida Department f Envirnmental Prtectin April 2016 [Incrprated by Reference in subparagraph (3)(a)5., F.A.C.] 2600 Blair Stne Rad, MS 4525 Tallahassee, Flrida

2 TABLE OF CONTENTS INTRODUCTION...3 A. Clsure Reprt Summary Narrative Supprting Dcumentatin...3 B. General Sampling Guidelines Gasline and Kersene Analytical Grups Used Oil...5 C. Sampling Requirements fr Strage Tank Remvals [see Sectin E and F fr requirements during clsure f individual system cmpnents] Gasline and Kersene Analytical Grups Used Oil...7 D. Sampling Requirements fr Strage Tanks Clsed in Place [see Sectin E and F fr requirements during clsure f individual system cmpnents] Gasline and Kersene Analytical Grups Used Oil...8 E. Sampling Requirements fr Clsure f Integral Piping in Cntact with Sil Sil Samples Grundwater Samples...9 F. Sampling Requirements fr Clsure f Piping Sumps, Spill Cntainment Devices and Dispenser Sumps Sil Samples Grundwater Samples...10 G. Discharge Reprting Requirements during a Petrleum/Prduct Tank System Clsure H. Hazardus Substance and Other Pllutant Strage Tank Systems... 11

3 INSTRUCTIONS FOR CONDUCTING SAMPLING DURING CLOSURE INTRODUCTION This dcument establishes prcedures fr cnducting and reprting strage tank system clsures t meet the requirements f Chapter , Flrida Administrative Cde (F.A.C.), Undergrund Strage Tank Systems. As an integral part f a system r a system cmpnent clsure perfrmed at an Undergrund Strage Tank (UST) facility, a Clsure Reprt r a Limited Clsure Reprt, as applicable, shall be prepared and submitted t the Department r cntracted Cunty prgram as required in Rule , F.A.C. The reprt is t describe the wrk that was perfrmed at the facility during the system r system cmpnent clsure, and summarize any data cllected at that time. A Site Assessment in accrdance with Chapter , F.A.C., cnducted and apprved by the Department will satisfy the requirements f this guideline. Hwever, these guidelines d nt meet the criteria t qualify fr the issuance f a Site Rehabilitatin Cmpletin Order (SRCO) as specified in Chapter , F.A.C. If a facility intends t demnstrate that all N Further Actin requirements f Chapter , F.A.C., have been met, a Clsure Reprt which meets the Site Assessment requirements f Chapter , F.A.C., must be prepared and submitted, and the reprt must be signed and sealed by a Prfessinal Engineer (PE) licensed in the State f Flrida r a Prfessinal Gelgist (PG) licensed in the State f Flrida. A. Clsure Reprt In cases where an investigatin is required at the time f clsure in accrdance with this dcument and as specified in Rule , F.A.C., a Clsure Reprt with the fllwing elements and dcumentatin shall be prepared and submitted in writing r electrnic frmat t the Cunty within 60 days f cmpletin f clsure. 1. Summary Narrative The Clsure Reprt shall summarize clsure actins and prvide: a. Infrmatin n the prcedures (sil field screening prcedures, analytical sample cllectin, etc.) fllwed during clsure; b. Infrmatin n the dimensins f the excavatin(s), depth t grundwater, vlume f sil excavated, and dispsal methd fr the excavated sil; c. Dispsitin f excavated cntaminated sil; d. Dispsitin f remved system cmpnents; e. Dispsitin f accumulated sludge / liquids remved frm system cmpnents; and f. Recmmendatin fr n additinal actins r fr site assessment under Chapter F.A.C. 2. Supprting Dcumentatin a. A scaled site map shwing the area(s) excavated and apprximate lcatins f all samples cllected; b. Table(s) summarizing all field and analytical results btained, listing the apprximate depth at which Page 1 f 9

4 each sample was cllected; c. DEP Frm (2) Strage Tank Facility Registratin Frm (due within 10 days after clsure); d. DEP Frm (5) Undergrund Strage System Installatin and Remval Frm fr Certified Cntractrs (due n later than 21 days after remval f a strage tank system); e. Cpies f labratry reprts. B. General Sampling Guidelines All samples must be analyzed using apprved methds listed in Chapter , F.A.C., r methds apprved thrugh prtcls described in Chapter , F.A.C. Cmpsite sil samples cannt be used t meet the requirement f Clsure Investigatin sampling. Sil samples cllected during Clsure Investigatin must be discrete grab samples. Cmpsite samples are nly allwed fr analysis f cntaminated sil fr the purpses f dispsal. Benz(a)pyrene equivalents must be calculated fr sil samples as there are n lnger individual direct expsure Cleanup Target Levels (CTLs) fr several f the Plycyclic Armatic Hydrcarbns (PAHs). Sil samples fr vlatile analyses must be cllected pursuant t EPA Methd Hwever, if the substrate t be sampled cnsists f large particles such as pea gravel, cntains debris r is cnslidated, sil samples fr vlatile analyses may be cllected in a bulk jar. Nte: Chapter , F.A.C., allws Level 1 Risk Management alternative clsure ptins fr bth the ttal recverable petrleum hydrcarbns (TRPH) CTLs and leachability CTLs, and in accrdance with these prcedures, further analysis f the sil sample can be run. As such, enugh sil shuld be cllected during sampling effrts s that the labratry can perfrm additinal tests n that sil if necessary. The labratry shuld be advised that in the event that cntaminatin is detected which exceeds the TRPH Direct Expsure Residential CTL r TRPH Leachability Based n Grundwater CTL specified in Table II f Chapter , F.A.C., TRPH fractinatin using either the Massachusetts methd r the Wrking Grup methd shuld be perfrmed n that sil sample. The labratry shuld als be advised that in the event that cntaminatin is detected that exceeds the Department s Leachability Based n Grundwater Criteria Sil CTLs specified in Table II f Chapter , F.A.C., fr any ther cntaminant f cncern, a Synthetic Precipitatin Leaching Prcedure (SPLP) extractin and analysis f that sil sample shuld be perfrmed. Additinally, the acceptable hlding times fr the sil samples need t be met. If TRPH fractinatin r SPLP is utilized, the Clsure Reprt needs t be signed and sealed by a PG r PE. 1. Gasline and Kersene Analytical Grups a. Sil Samples Sil samples btained during clsure f a strage tank system are t be screened in the field using an instrument r methd apprved by the Department. A sample frm the lcatin in each surce area (tank farm, integral piping, dispenser island 1 ), that yields the highest hydrcarbn measurement is t be analyzed fr vlatile rganic armatics (VOAs), PAHs and TRPHs. If n psitive screening results are btained, the sample, frm each surce area, is t be cllected frm the lcatin within each surce area believed t be mst likely t have cntaminatin, such as next t a fill prt. Only ne sample is needed t cnfirm a new discharge and then the facility enters the site assessment Each island is cnsidered a surce area. If there are five islands with tw dispensers n each island, five samples are t be cllected. 1 Page 2 f 9

5 initiatin phase under , F.A.C (1) If an rganic vapr analysis instrument with a Flame Inizatin Detectr (FID) r a Pht Inizatin Detectr (PID) is used, it must be in the survey mde. PIDs shuld nt be used in situatins where humidity will interfere with the instrument s sensitivity (i.e., during rainy perids, measuring mist r wet sil). Readings must be btained frm the headspace f samples in half-filled, 8-unce r 16-unce jars. Each sil sample shuld be btained frm the vadse zne (the area abve the water table), brught (if necessary) t a temperature f between 20 C (68 F) and 32 C (90 F), and the reading btained five t thirty minutes thereafter. If an FID is used, each sil sample must be split int tw jars, and ne f the readings must be btained with the use f an activated charcal filter unless the unfiltered reading is 10 parts per millin (ppm) r less. The ttal crrected hydrcarbn measurement must be determined by subtracting the filtered reading frm the unfiltered reading. Analytical instruments must be calibrated in accrdance with the manufacturer's instructins. (2) If sil that yields psitive field screening results (hydrcarbn measurements greater than 10 ppm) is identified and remains n-site, a grab sample frm the lcatin in each surce area that yields the highest hydrcarbn measurement must be analyzed fr VOAs, PAHs and TRPHs. If the evidence suggests that prducts frm bth the Gasline Analytical Grup and Kersene Analytical Grup were released at different lcatins within a surce area, then the sample frm each distinct prduct area with the highest hydrcarbn measurement is t be cllected fr labratry analyses. (3) If cntaminated sil is identified and excavated, a minimum f fur r five samples (at least ne frm the bttm f the excavatin if the water table was nt reached and at least fur frm the walls f the excavatin) are t be btained fr field screening. The sample that yields the highest hydrcarbn measurement is t be analyzed fr VOAs, PAHs and TRPHs. If n psitive screening results are btained, the sample is t be cllected frm the lcatin believed t be mst likely t have cntaminatin. This sampling is in additin t the sampling required in B.1.a., abve. Remval f sil greater than 20 feet f depth and/r in a 20 ft radius laterally frm the edge f excavatin is allwable prvided that an Interim Surce Remval Reprt is submitted in accrdance with the requirements f Rule , F.A.C., and is signed and sealed by a PE r PG. b. Grundwater Samples 2. Used Oil Grundwater samples btained during clsure f a tank must be analyzed fr all parameters specified in Table C f Chapter , F.A.C. a. Sil Samples (1) Sil samples btained during clsure f a used il tank are t be inspected fr signs f staining r disclratin. If the tank appears t have discharged r if sil cntaminated r saturated with used il is identified and remains n-site, a sample that represents the lcatin believed t be mst likely t have cntaminatin must be analyzed fr all parameters specified fr used il in Table D f Chapter , F.A.C. (2) If sil visually stained r saturated with used il is identified and excavated, at least ne sample is t be btained frm the bttm f the excavatin if the water table was nt reached and at least ne sample is t be btained frm the wall f the excavatin at an equivalent depth f the sil Page 3 f 9

6 visually stained r saturated with used il that was remved, and analyzed fr thse cntaminants detected in the sample cllected frm the mst visibly stained area r during preburn analyses. b. Grundwater Samples Grundwater samples must be analyzed fr all parameters specified fr used il in Table D f Chapter , F.A.C. C. Sampling Requirements fr Strage Tank Remvals [see Sectin E and F fr requirements during clsure f individual system cmpnents] 1. Gasline and Kersene Analytical Grups a. Sil Samples During the remval f an undergrund strage tank system, field screening f sils in accrdance with B.1.(a), abve shall be cnducted inside the area f the tank pit. The screening lcatins are t be spaced n a five (5) ft grid pattern, beginning at the edge f the undisturbed sil, with sil cllectin frm grund surface at discrete pints at a depth f tw feet and five feet belw land surface (bls), then cntinuing at five ft intervals t 20 feet bls, unless grundwater is encuntered. Nte: If it is anticipated that a very large excavatin will be required and if an alternate sil sampling frequency is requested, a prpsal under subsectin (1), F.A.C., (Alternative Prcedure Requirements) can be submitted t the Department fr apprval under that rule. b. Grundwater Samples Grundwater samples must be btained frm a prperly cnstructed temprary mnitring well r a direct push well as discussed belw whenever the depth t the grundwater table is less than 20 feet. If the depth t the grundwater table is greater than 20 feet, a grundwater sample is nt required if: the screening and labratry results indicated that cntaminated sil was nt present, r cntaminated sil was identified and was left in place requiring the discharge t be reprted and a site assessment t be cnducted in accrdance with Rule , F.A.C., r cntaminated sil was identified, excavated and results demnstrated that grundwater shuld nt have been affected based n the: degree f cntaminatin, hrizntal and vertical extent f cntaminatin in the excavated sil, type f prduct believed t have been discharged, and site stratigraphy Subsequent t backfilling, the temprary mnitring well is t be installed in the area that represents the lcatin believed t be mst likely t have cntaminatin as determined by the sil field screening results. If n sil cntaminatin is fund, the well is t be installed near the center f the frmer tank lcatin. Minimum well cnstructin details fr a temprary mnitring well require a Page 4 f 9

7 2. Used Oil sand pack placed arund the well screen prir t sampling and the well screen intercepting the grundwater table. a. Sil Samples When a used il tank is being remved, a visual inspectin f the excavatin, f the tank cnditin and f the remved sil is t be perfrmed t dcument the integrity f the tank. If the tank appears t have discharged r if sil staining is dcumented, a sil sample is t be btained in accrdance with Sectin B.2.(a) abve. b. Grundwater Samples Grundwater sampling is nt required if visual bservatins r labratry results frm sampling indicate that cntaminated sil is nt present. Hwever, if the tank appears t have discharged r if sil staining is dcumented, and the depth t the grundwater table is less than 20 feet, a temprary mnitring well is t be installed in the area that represents the lcatin believed t be mst likely t have cntaminatin as determined by the visual bservatins f the sil samples. If the depth t the grundwater table is greater than 20 feet, a grundwater sample is nt required if: the visual bservatins r labratry results frm sampling indicated that cntaminated sil was nt present, r cntaminated sil was identified and was left in place requiring the discharge t be reprted and a site assessment t be cnducted in accrdance with Rule , F.A.C., r cntaminated sil was identified, excavated and results demnstrated that grundwater shuld nt have been affected based n the: degree f cntaminatin, hrizntal and vertical extent f cntaminatin in the excavated sil, type f prduct believed t have been discharged, and site stratigraphy. D. Sampling Requirements fr Strage Tanks Clsed in Place [see Sectin E and F fr requirements during clsure f individual system cmpnents] 1. Gasline and Kersene Analytical Grups a. Sil Samples A minimum f fur sil brings must be placed arund each undergrund strage tank, with a maximum distance f 20 feet between brings. Each bring is t be placed as clse t the tank as pssible, with ne f the brings placed as clse t the fill prt as pssible while still being beynd the edge f the tank s that the bring can cntinue t the grundwater table r 20 feet, whichever is less. Sil must be screened at tw ft intervals t a depth f 10 feet belw land surface and then at 5 ft intervals t the grundwater table, r t a depth f 20 feet belw land surface if the water table is nt encuntered. b. Grundwater Samples Page 5 f 9

8 Grundwater samples must be btained whenever the depth t the grundwater table is less than 20 feet. If the depth t the grundwater table is greater than 20 feet, a grundwater sample is nt required if: the screening and labratry results indicated that cntaminated sil was nt present, r cntaminated sil was identified and was left in place requiring the discharge t be reprted and a site assessment t be cnducted in accrdance with Rule , F.A.C., r cntaminated sil was identified, excavated and results demnstrated that grundwater shuld nt have been affected based n the: degree f cntaminatin, hrizntal and vertical extent f cntaminatin in the excavated sil, type f prduct believed t have been discharged, and site stratigraphy. 2. Used Oil When cmpliance mnitring wells are present, ne sample can be btained frm each cmpliance mnitring well (if nly ne tank f 2,000 galln capacity r less is being clsed in place, nly tw temprary mnitring wells are t be installed, at lcatins suspected t be dwngradient and upgradient frm the tank). If it is determined that the cnstructin f the cmpliance wells is nt adequate (that is, if the water table des nt intersect the screened interval), temprary mnitring wells are t be installed, as specified belw. If there are n cmpliance mnitring wells present, fur temprary mnitring wells are t be installed arund the tank field and sampled (if nly ne tank f 2,000 galln capacity r less is being clsed in place, nly tw temprary mnitring wells are t be installed, at lcatins suspected t be dwngradient and upgradient frm the tank). Minimum well cnstructin details fr a temprary mnitring well require a sand pack placed arund the well screen prir t sampling and that the screened interval intercepts the grundwater table. a. Sil Samples Sample as specified in Sectin D.1.a. abve, with the samples visually inspected t determine if the tank appears t have discharged. If the tank appears t have discharged r if sil staining is dcumented, a sil sample is t be btained in accrdance with Sectin B.2.(a) abve. b. Grundwater Samples If the depth t the grundwater table is less than 20 feet, a temprary mnitring well is t be installed in the area that represents the lcatin believed t be mst likely t have cntaminatin as determined by the visual bservatins f the sil samples. If n sil staining is dcumented, the temprary mnitring well is t be installed next t the tank, as clse t the fill prt as pssible. If the depth t the grundwater table is greater than 20 feet, a grundwater sample is nt required if: visual bservatins r labratry results indicated that cntaminated sil was nt present, r cntaminated sil was identified and was left in place requiring the discharge t be reprted and a site assessment t be cnducted in accrdance with Rule , F.A.C., r Page 6 f 9

9 cntaminated sil was identified, excavated and results demnstrated that grundwater shuld nt have been affected based n the: degree f cntaminatin, hrizntal and vertical extent f cntaminatin in the excavated sil, type f prduct believed t have been discharged, and site stratigraphy. E. Sampling Requirements fr Clsure f Integral Piping in Cntact with Sil 1. Sil Samples One sil bring must be placed apprximately every 20 feet f prduct transfer line (piping), with the spacing determined by any evidence f cntaminatin and lcatin f ptential surces f leaks, such as fixtures, cnnectins and jints. The bring(s) is/are t be lcated as clse t the transfer line as pssible, with the sampling pint ne ft belw the line level, r immediately abve the grundwater table, whichever is first encuntered. 2. Grundwater Samples A grundwater sample is nt required if: the screening and labratry results indicated that cntaminated sil was nt present, r cntaminated sil was identified and was left in place requiring the discharge t be reprted and a site assessment t be cnducted in accrdance with Rule , F.A.C., r cntaminated sil was identified, excavated and results demnstrated that grundwater shuld nt have been affected based n the: degree f cntaminatin, hrizntal and vertical extent f cntaminatin in the excavated sil, type f prduct believed t have been discharged, and site stratigraphy. If the results cannt demnstrate that grundwater shuld nt have been affected, then a temprary mnitring well is t be installed in the area that represents the lcatin believed t be mst likely t have cntaminatin as determined by the sil samples. F. Sampling Requirements fr Clsure f Piping Sumps, Spill Cntainment Devices and Dispenser Sumps 1. Sil Samples a. One sil bring must be placed next t each submersible pump r fill prt. Samples fr field screening are t be cllected apprximately every tw feet belw land surface until the tp f the strage tank, r the grundwater table, whichever is first encuntered. b. A minimum f ne sil bring must be placed directly under each prduct dispenser r less than Page 7 f 9

10 three feet frm each prduct dispenser. Samples fr field screening are t be btained apprximately every tw feet belw land surface t a minimum depth f fur feet, r t the grundwater table, whichever is first encuntered (if the apprpriate District r cntracted Cunty prgram determines based n screening results that there is a need t extend any bring belw 10 feet, subsequent samples may be cllected every five feet). The depth f the sil bring(s) will be dependent upn the hydrcarbn vaprs encuntered. The ideal lcatin fr evaluating sil cnditins is directly under the dispenser if the dispenser has been remved and the area is large enugh t be accessible. 2. Grundwater Samples A grundwater sample is nt required if: the screening and labratry results indicated that cntaminated sil was nt present, r cntaminated sil was identified and was left in place requiring the discharge t be reprted and a site assessment t be cnducted in accrdance with Rule , F.A.C., r cntaminated sil was identified, excavated and results demnstrated that grundwater shuld nt have been affected based n the: degree f cntaminatin, hrizntal and vertical extent f cntaminatin in the excavated sil, type f prduct believed t have been discharged, and site stratigraphy. If the results cannt demnstrate that grundwater shuld nt have been affected, then a temprary mnitring well is t be installed in the area that represents the lcatin believed t be mst likely t have cntaminatin as determined by the sil samples. G. Discharge Reprting Requirements during a Petrleum/Prduct Tank System Clsure The Department must be ntified by the facility wner r peratr f the discvery f an unreprted discharge n the Discharge Reprt Frm [Department Frm (1)] within 24 hurs f the discvery r befre the clse f the Department's next business day. If any ne f the fllwing reprting criteria is met, then the Clsure Investigatin may be terminated, a Clsure Reprt (prepared accrding t the guidelines described in Sectin A Dcumentatin Requirements, describing the wrk that was perfrmed at the site and summarizing the data cllected at that time) is t be submitted and a frmal site assessment initiated in accrdance with Chapter , F.A.C.: 1. Sil cntaminated with prducts classified in the Gasline Analytical Grup r in the Kersene Analytical Grup, that exceeded the default sil CTLs specified in Chapter , F.A.C., remains n-site; r 2. Sil cntaminated with used il, that exceeded the default sil CTLs specified in Chapter , F.A.C., remains n-site; r Nte: Fr G.1. and G.2. abve, a DRF des nt need t be submitted when the default sil CTLs are exceeded while level 1 alternative clsure ptins (Fractinatin and SPLP) are being evaluated. Once the evaluatin is cmplete, if it is demnstrated that the sil is cntaminated, then a DRF must be submitted; 3. Free prduct r a sheen f petrleum prducts is detected in a mnitring well r in the tank r tank Page 8 f 9

11 system cmpnents excavatin area; r 4. Any f the grundwater CTLs specified in Chapter , F.A.C., has been exceeded. H. Hazardus Substance and Other Pllutant Strage Tank Systems Owners r peratrs f hazardus substance USTs and ther pllutant USTs are required t perfrm a Clsure Investigatin. The Clsure Reprt must address the particular regulated substance stred in the strage tank system. Sampling methdlgy must be submitted t the District r cntracted Cunty prgram fr apprval 30 days befre the strage system clsure. If the sampling methdlgy prpsed by the Owner r Operatr will accurately detect any discharges that may have ccurred, the District r cntracted Cunty prgram will ntify the wner r peratr f the apprval within 14 days f receipt f the sampling methdlgy. Clsure Investigatin may be cnducted in accrdance with existing Department-apprved clsure evaluatin prtcls and related crrective actin prtcls apprved under ther Department prgrams [e.g., Heavy Fuel Oil Discharge Respnse Actins (FDEP April 2007)]. Page 9 f 9