UNDERGROUND STORAGE TANK CLOSURE

Presented by:
Brenda ten Bruggencate Santa Fe Springs Fire-Rescue

David Noren EBA Group

INSPECTORS PERSPECTIVE
Permits Inspections

OTHER TOPICS
clean certifications open excavations

TYPES OF UST CLOSURES

Permanent removal Permanent-in-place Temporary

CLOSURE VS. REMOVAL

careful with the term

closure
when

removal
is meant

PERMIT REQUIRED

Demonstrate UST owners will comply with the law

CUPA or PA H&SC , Title 22 & 23 CCR Fire Dept. 2010 CFC Health Department

OSHA
Air Districts

Building Dept.

PERMIT REQUIRED
2010 CFC

105.7.7 - permit required to remove, close, or place an UST into temporary closure

PERMIT REQUIRED

23 CCR Art. 7

2670(e) apply for UST closure to LIA Be aware of timelines

Ordinance

UST CLOSURE REQUIREMENTS

23 CCR Art. 7

2670(e) apply for UST closure to LIA within 90 days once hazardous substance storage has stopped AND

Submit closure proposal 30 days prior to closure or shorter

Check with LIA

Most want one submittal

Process varies

UST CLOSURE REQUIREMENTS & TYPES

H&SC 25298 - general 23 CCR Art. 7

23 CCR 2670 - general to all UST closures 23 CCR 2671 - temporary closures 23 CCR 2672 (b) - removal 23 CCR 2672 (c) - closure-in-place 23 CCR 2672 (d) - sampling requirements 3404.2.13 - temporary & closure-in-place 3404.2.14 removal

2010 CFC

Ordinance

WHAT DOES AN INSPECTOR LOOK FOR ON A PERMIT?

Tracking of UST and RP
Names & addresses State UST ID# Contents, size, install date etc. State UST Operating Permit Application - Facility and Tank Information forms contain a lot of this info

Application that demonstrate compliance with the law, regs, codes, standards etc.

Safe removal or closure (inerting UST) Liquids, sludge, and residuals managed legally Sampling to demonstrate if release occurred or not

WHAT DOES AN INSPECTOR LOOK FOR ON A PERMIT?

Agency specific

Can be written narrative

Level of detail varies

May be done on prescriptive forms

Some LIAs attach standard conditions Example: SFS Closure Permit

location RP

contractor
Type & procedures for closure

description

Most fields on this form are required by title 22

certification

Attach Forms A&B

PERMANENT UST CLOSURE REQUIREMENTS

LG 48-5, Contractor Licensing A (all) B (construct building) C-36 (service stations) C-61/D-40 (< 20K capacity) and Hazardous Substance Certification issued by CSLB B&P 7058.7

UST CLOSURE

Permit approved now what?

Complete closure within a reasonable amount of time as determined by LIA - 23 CCR 2670(e)

Be aware of Ordinance timelines SFS 6 months, with possible 6 month extension

CFC

1 year for permanent closures 90 days to safe guard temp closures

NEXT STEP

Contractor or owner/operators rep schedules inspection

TO INSPECT FOR?

Permanent Closure removal

Principals apply to other closure type

TO INSPECT FOR?

CFC 106.2

Fire Code Official is authorized to conduct inspections to determine compliance with this code

Permanent closure by removal

Tank inert and remove contents, tank, & pipe

TO INSPECT FOR?

H&SC 25298 & 23 CCR Art. 7

UST owner/operator shall demonstrate/document to the Local Agency

No unauthorized release has occurred, collect samples Proper disposal (i.e. tank destruction cert) or reuse info

BEFORE ARRIVING ON SITE

Read the permit

Know the conditions Know the sampling requirements

UPON ARRIVAL

Assess logistics

Traffic hazards Access in and out How many people are in removal area? Overhead hazards - electrical Tank path from pit to truck Plan ahead

Use common sense

UPON ARRIVAL

Find out whos who

Supervisor Looky-loos Geologist clean certifier Who is the Site Safety Officer?

Report safety concerns to SSO

UPON ARRIVAL

Ask where they are in the removal process

When does your agency require the inspector to be present?

For excavation? For cold cutting? For cleaning? During the clean certification? During removal? During sample collection?

UPON ARRIVAL

Verify info submitted on permit

What info is different than site conditions

Has the contractor or subs changed? Where are they taking the UST?

confirm with driver

Where are they taking rinseate?

Manifest # or copy

UPON ARRIVAL
Ask the contractor their plan and logistics

Is it consistent with the approved permit? Does it appear reasonable? Assess and record differences

UPON ARRIVAL

Look around the site

Size of crane appropriate? Condition of lifting cables or straps

Look around the site (cont.)

Are the excavation walls stable or loose? Where are people standing?

UPON ARRIVAL

Look around the site (cont.)

Any other concerns?

Discuss with Site Safety Officer before removal CFC 111.1 has stop work authority if unsafe

Alternatives: walk off job site Do not sign off permit

TALK TO GEOLOGIST

Do they know the sampling plan? Do they have the right sampling equipment?

No glass jars for VOCs EPA Method 5035 Ice in their chest?

Ask early - may to allow time to acquire these things should they not have them

NOW WHAT?

At this point SFSFR arrives on site to witness the clean certification

PRE-REMOVAL REQUIREMENTS

Residual liquids, sludges, or solids SHALL be removed from tank and piping and handled hazardous wastes or recyclable materials

Inert possible flammables vapor at STP to levels that preclude explosion 22 CCR requires Hazardous Waste Tank Closure Certification

clean UST or comply with all applicable HW requirements

WHAT IS A CLEAN CERTIFICATION?

Clean is defined:

The removal of all product, vapor, sludge, and residue from a tank and washing, rinsing, and drying a tank so that no product or residue remains on any tank surfaces.

API Publication 2015

API 2015
This standard does not apply to USTs
Many safe tank cleaning principals are applicable Also see API 2016

WHAT IS A CLEAN CERTIFICATION?

Cleaning procedures are references in 22 CCR 67383.3(b)

API Publication 2015

NFPA 327, 1993 edition

API Publication 1604 Procedures approved by the CUPA

WHAT IS A CLEAN CERTIFICATION?

API Publication 2015

Intro says this standard does not apply to USTs Safe cleaning principals apply Refers to API 2016 Vapors and degassing Removing sludge and residues Tank cleaning Control of ignition sources Atmospheric monitors

WHAT IS A CLEAN CERTIFICATION?

NFPA 327, 1993 edition

You wont find it Replaced by NFPA 326, 1999 edition

326 intended as an update to 327 and incorporate entry to tanks

WHAT IS A CLEAN CERTIFICATION?

NFPA 326

Atmospheric Testing

Combustible gas indicator reading can be incorrect if taken in oxygen deficient environment Check instrument specs
Triple rinse (low pressure water) High pressure steam Physical removal (vacuuming, shovel, absorbing)

Cleaning Methods

Qualifications of person certifying tank atmosphere All work stops if >10% LEL

WHAT IS A CLEAN CERTIFICATION?

API Publication 1604

Recommended Practice for the Closure of Petroleum USTs

WEB ADDRESSES FOR CLEANING PROCEDURES

API Publication 2015

http://publications.api.org/ Register or log in for free Under Read-Only Documents select Fire and Safety Protection Not all API Publications are accessible without an account

API 1604 is not free

WEB ADDRESSES FOR CLEANING PROCEDURES

NFPA 326, 1999 edition

Formerly NFPA 327, 1993 edition www.nfpacodesonline.org

Need a subscription

NEXT STEP TANK CLEANING

UST must be certified if non-haz or managed as hazwaste - CCR 22 67383.3 If hazardous waste (not clean)

comply with all hazwaste requirements

Hazwaste hauler Uniform Hazwaste Manifest

NEXT STEP TANK CLEANING

If tank is clean (non-haz)

submit the Hazardous Waste Tank Closure Certification Piping and appurtenances must be clean so no pourable contents come out when inverted UST must be free of product, sludge, debris etc.

UST must be visually inspected

NON-HAZARDOUS REMOVAL

Visually inspect

Through manway or Cut opening on site Use non-sparking tools, cold cutting techniques

NON-HAZARDOUS REMOVAL

If a cleaned tank is cut and has potential to generate flammable vapor

Use CGI to measure interior atmosphere Record top, center, and bottom

Oxygen must be atmospheric

LEL must be 0%

NON-HAZARDOUS REMOVAL

If a cleaned tank is NOT cut and has potential to generate flammable vapor

Visually inspect by

Use Class I, Div. 1 light with mirror to see inside tank Other method approved by CUPA

Inert with CO2 or other inert gas

Dry ice

DRY ICE

How much?

22 lbs dry ice per 1000 gals UST

What does that look like?

50 lb. blocks are approximately 12" x 12" x 12" 10K UST requires 220 lbs dry ice

= 4.4 50 lbs blocks of dry ice Sublimates at a rate of 5 to 10 pounds every 24 hours when stored in a typical cooler

Much faster on hot days in metal UST

10 lb

50 lb

DRY ICE

Allow sublimation to generate CO2 Use CGI to measure LEL top, center, bottom

Careful! Whats the oxygen conc.?

Plug all hole except 1/8 vent

NON-HAZARDOUS REMOVAL

Use Hazardous Waste Tank Closure Certification or acceptable alternative containing specific information

Required by 22 67383.3 (g)

Atmosphere at top, center, bottom Certify free of product, sludge, etc. Qualifications of certifier Date, time, signature Cert good only at time of monitoring

UST REMOVAL

Ensure clear path from pit to truck Remove loose dirt Transport off-site

UST REMOVAL

Document to LIA disposition of UST

If disposed Documentation i.e. tank destruction cert

If destined for reuse Check with LIA for local requirements Document to LIA within their required time frame
Name of new owner and new operator of UST Location of intended use Nature of intended use

SOIL SAMPLING REQUIREMENTS

Must demonstrate no unauthorized release has occurred

Must be performed during or immediately after UST closure activities

Based on soil and (if present in excavation) water analysis and consistent with approved work plan Analyze by State-Certified lab for previously stored substance(s) and breakdown products or transformation products.

SOIL SAMPLING REQUIREMENTS

Geological logs shall be prepared by a Professional Geologist or Civil Engineer

technician working under the direct supervision of one can do this provided the professional reviews the logs and assumes responsibility for them. 23 CCR 2649 (b)(1)(D)

SOIL SAMPLING REQUIREMENTS

Removal

Minimum 2 below the UST bottom in native soil at each end of tank Every 20 linear feet of piping

May include vent and vapor for VPH systems based on change in piping definition This includes sampling under the dispenser

Stockpile sampling (not specified in 23 CCR 2672)

SOIL SAMPLING REQUIREMENTS

If contaminated Change or increase sampling based on field observations Consider encouraging businesses to do limited excavation If contamination fails to visually clear up in several scoops, discontinue and initiate site characterization

OPEN EXCAVATION

Not regulated by CUPA regs or CFC

Check with other agencies

Building Dept. Air issues? Agency policies

Business decision Ensure area is secure

May be OK to leave open

2670(f)

2670(f)
piping & dispensers

SFSFR requirement 2672(b)(3) &(4) 2672(c)(1)

2649(f)(5) & (g)

Bus. & Prof. Code 7835 & 2649(f)(5) & (g) 2649(f)(5) & (g) HSC 25298.5 2672(b)(2) & (c)(2)

Professional

2649(f)(6) & HSC 25298.5

Needed to determine if further action is needed

Professional

Bus. & Prof. Code 7835

PERMANENT UST CLOSURE 2 TYPES

Removal 23 CCR 2672(b) Closure-in-place 23 CCR 2672(c)

UST CLOSURE-IN-PLACE

What justifies leaving UST in place?

Check with Building Dept. & LIA policy City of SFS requires UST be within a 45 angle of footing of permanent structure Consider requiring Engineering Report if not obvious

UST CLOSURE-IN-PLACE
BUILDING

UST 1

UST 2

45
Closure-in-place allowed for UST 2

UST CLOSURE-IN-PLACE

Process similar to removal Clean tank Legally manage waste Sampling borings required

Fill with inert solid

exception

UST CLOSURE-IN-PLACE

Exception: if owner intends to reuse tank for storage of a non-haz substance

Non-haz substance must be compatible with previous UST use and construction Check with LIA and Fire Departments on their requirements

UST CLOSURE-IN-PLACE

Filling with inert solid

Provide proper openings to filling tank with inert material Use concrete slurry, sand, flowable ash, or foaming agent

Ensure UST buoyancy is offset

UST PIPING CLOSURE-IN-PLACE

Remove all piping unless it will damage structures or other pipes

Piping to remaining in place must be emptied of contents and capped

Piping does not have to be filled with an inert solid, only the UST does

Remove vent Backfill

SOIL SAMPLING REQUIREMENTS

Closure-in-place

One or more slant boring as close as possible to the midpoint of the UST OR Vertical borings drilled along each long dimensional side of UST OR Other method as approved by LIA

Check approve permit/workplan

SOIL SAMPLING REQUIREMENTS

Closure report required

Will not contain tank destruction certificate

TEMPORARY UST CLOSURE

TEMPORARY UST CLOSURE

23 CCR
When storage of HS has ceased but the UST will be used again within 12 months Submit proposal 30 days prior to closure

2010 CFC
When UST is taken out of service

Safeguard within 90 days

TEMPORARY UST CLOSURE

23 CCR
Remove liquid and properly manage it Cap and secure pipe, fill line, gauge openings, vapor recovery maintain vents Disconnect power to pumps but not cathodic protection system Inert to levels that preclude explosions OR lower if required by LIA UST may be filled with a non-corrosive liquid that is not a hazardous substance

2010 CFC
same same same

TEMPORARY UST CLOSURE

23 CCR
Remove liquid and properly manage it Cap and secure pipe, fill line, gauge openings, vapor recovery maintain vents Disconnect power to pumps but not cathodic protection system Inert to levels that preclude explosions OR lower if required by LIA UST may be filled with a non-corrosive liquid that is not a hazardous substance

2010 CFC
same same same

TO FILL OR NOT TO FILL?

Deciding factors
High groundwater? Intent and time frame for reuse? Consider amount of waste generated

4 - 10,000 gal. USTs = 40,000 gal. of waste!

waste mgmt costs Impact to enviro?

Diagram from South Dakota Department of Environment and Natural Resources

TEMPORARY UST CLOSURE

If filled

Non corrosive liquid Not a hazardous substance Test liquid and submit results to LIA prior to removing it from UST at end of temp closure period

UST TEMPORARY CLOSURE

Monitoring requirements
Can be modified by LIA based on need to detect unauthorized release
Cathodic protection must be maintained

UST TEMPORARY CLOSURE

Inspection requirements

Every 3 months by owner/operator

Inspect caps/plugs/locks

remove one to verify UST is still empty

If UST was filled, check for change in liquid level

UST TEMPORARY CLOSURE

Continue compliance with the following requirements:

Repair and record keeping Release reporting and investigations Release response and corrective actions

TEMPORARY UST CLOSURE

Options at end of permit term

2010 CFC
Removal from ground within one year for USTs out of service

23 CCR
12 month extension may be granted if site assessment performed

CONTACT INFO
Brenda ten Bruggencate Santa Fe Springs Fire Rescue (562) 906-3812 brendanelson@santafesprings.org