2012 Cupa Ust Closure Presentation Revised

8/13/2019 2012 Cupa Ust Closure Presentation Revised

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UNDERGROUNDSTORAGE

TANKCLOSURE


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Presented by :

Brenda ten BruggencateSanta Fe Springs Fire-Rescue

David NorenEBA Group


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INSPECTORS

PERSPECTIVE

Permits Inspections


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OTHER TOPICS

open excavationsclean certifications


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TYPES OF UST CLOSURES

Permanent removal

Permanent-in-place

Temporary


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CLOSURE VS. REMOVAL

careful with the termlosure when

rem ov l is meant


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2010 CFC

105.7.7 - permitrequired to remove,

close, or place an USTinto temporary closure

PERMIT REQUIRED


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UST CLOSUREREQUIREMENTS

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 priorto closure or shorter

Check with LIAMost want one submittal

Process varies


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H SC 25298 - general

23 CCR Art. 723 CCR 2670 - general to all UST closures23 CCR 2671 - temporary closures23 CCR 2672 (b) - removal23 CCR 2672 (c) - closure-in-place23 CCR 2672 (d) - sampling requirements

2010 CFC 3404.2.13 - temporary & closure-in-place 3404.2.14 removal

Ordinance

UST CLOSUREREQUIREMENTS TYPES


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WHAT DOES AN INSPECTORLOOK FOR ON A PERMIT?

Tracking of UST and RP

Application that demonstrate compliance withthe law, regs, codes, standards etc.

Names & addressesState UST ID#Contents, size, install date etc.State UST Operating Permit Application - Facilityand Tank Information forms contain a lot of this info

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


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WHAT DOES AN INSPECTORLOOK FOR ON A PERMIT?

Agency specific

Can be written narrativeLevel of detail varies

May be done on prescriptive formsSome LIAs attach standard conditionsExample: SFS Closure Permit


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Most fieldson this form

are requiredby title 22

Attach Forms A & B

location

Type &proceduresfor closure

description

contractor

certification

RP


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PERMANENTUST CLOSURE

REQUIREMENTSLG 48-5, Contractor Licensing

A ( all)

B ( construct building)C-36 ( service stations)C-61/D-40 ( < 20K capacity)

andHazardous SubstanceCertification issued by CSLB

B&P 7058.7


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UST CLOSURE

Permit approved now what?

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

Be aware of Ordinance timelinesSFS 6 months, with possible 6 monthextension

CFC1 year for permanent closures90 days to safe guard temp closures


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TO INSPECT FOR?

PermanentClosure removal

Principalsapply to otherclosure type


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CFC 106.2

Fire Code Official is authorized to conductinspections to determine compliance with thiscode

Permanent closure by removalTank inert and remove contents, tank, & pipe

TO INSPECT FOR?


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H SC 25298 23 CCR Art. 7

UST owner/operator shalldemonstrate/document to the Local

Agency

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

TO INSPECT FOR?


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UPON ARRIVAL

Assess logisticsTraffic hazards

Access in and outHow many people are in removalarea?

Overhead hazards - electricalTank path from pit to truckPlan ahead

Use common sense


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UPON ARRIVAL

Find out whos who SupervisorLooky-loosGeologistclean certifier Who is the SiteSafety Officer?

Report safety

concerns to SSO


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UPON ARRIVAL

Ask where they are in the removal processWhen 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?


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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


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UPON ARRIVAL

Ask the contractor their plan and logistics

Is it consistent with the approved permit?

Does it appear reasonable?

Assess and record differences


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UPON ARRIVAL

Look around the site

Size of crane appropriate?

Condition of lifting cablesor straps


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Look around the site (cont.) Are the excavation walls stable or loose?

Where are people standing?


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TALK TO GEOLOGIST

Do they know the sampling plan?

Do they have the right sampling equipment?No glass jars for VOCsEPA Method 5035Ice in their chest?

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


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NOW WHAT?

At this point SFSFR arrives on site towitness the clean certification


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Residual liquids, sludges, or solids SHALL beremoved from tank and piping and handledhazardous wastes or recyclable materials

Inert possible flammables vapor at STP to levelsthat preclude explosion

22 CCR requires Hazardous Waste Tank ClosureCertification

clean UST or comply with all applicable HWrequirements

PRE-REMOVALREQUIREMENTS


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API 2015

Thisstandarddoes notapply toUSTs

Many safetankcleaning

principalsareapplicable

Also see API2016


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WHAT IS ACLEAN CERTIFICATION

API Publication 2015Intro says this standard does not apply to USTsSafe cleaning principals applyRefers to API 2016Vapors and degassing

Removing sludge and residuesTank cleaningControl of ignition sources

Atmospheric monitors


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NFPA 326 Atmospheric Testing

Combustible gas indicator reading can be incorrect if taken inoxygen deficient environmentCheck instrument specs

Cleaning Methods

Triple rinse (low pressure water)High pressure steamPhysical removal (vacuuming, shovel, absorbing)

Qualifications of person certifying tank atmosphere

All work stops if >10% LEL


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API Publication 1604

Recommended Practice for the Closure ofPetroleum USTs


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WEB ADDRESSES FORCLEANING PROCEDURES

API Publication 2015http://publications.api.org/ Register or log in for freeUnder Read -Only Documents select Fire andSafety Protection

Not all API Publications are accessible withoutan account

API 1604 is not free
http://publications.api.org/http://publications.api.org/


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WEB ADDRESSES FORCLEANING PROCEDURES

NFPA 326, 1999 edition

Formerly NFPA 327, 1993 edition

www.nfpacodesonline.org

Need a subscription
http://www.nfpacodesonline.org/http://www.nfpacodesonline.org/


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If tank is clean (non-haz)

submit the Hazardous Waste Tank ClosureCertification

Piping and appurtenances must be clean so nopourable contents come out when inverted

UST must be free of product, sludge, debris etc.

UST must be visually inspected

NEXT STEPTANK CLEANING

NON HAZARDOUS


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NON-HAZARDOUSREMOVAL

Visually inspectThrough manway orCut opening on siteUse non-sparking tools, cold cutting techniques


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NON HAZARDOUS


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

Visually inspect byUse Class I, Div. 1 light with mirror to see inside tan

Other method approved by CUPA

Inert with CO 2 or other inert gasDry ice



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50 lb bl k i t l 12" 12" 12"


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50 lb. blocks are approximately 12" x 12" x 12"

10 lb 50 lb

10K UST requires 220 lbs dry ice= 4.4 50 lbs blocks of dry iceSublimates at a rate of 5 to 10 pounds every 24hours when stored in a typical cooler

Much faster on hot days in metal UST
http://www.continentalcarbonic.com/dryicelocations/map.php


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DRY ICE

Allow sublimation to generate CO 2

Use CGI to measure LEL top, center,bottom

Careful! Whats the oxygen conc.?

Plug all hole except 1/8 vent

NON HAZARDOUS


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Use Hazardous Waste Tank ClosureCertification or acceptable alternativecontaining specific information


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Required by 2267383.3 (g)

Certify free of product,sludge, etc.

Atmosphere at top,center, bottom

Qualifications of certifier

Date, time, signature

Cert good only at time ofmonitoring


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UST


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USTREMOVAL

Ensure clear path frompit to truck

Remove loose dirt

Transport off-site


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UST REMOVAL

Document to LIA disposition of UST

If disposedDocumentation i.e. tank destruction cert

If destined for reuseCheck with LIA for local requirements

Document to LIA within their requiredtime frame

Name of new owner and new operator of USTLocation of intended use

Nature of intended use

SOIL SAMPLING


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SOIL SAMPLINGREQUIREMENTS

Must demonstrate no unauthorized release hasoccurred

Must be performed during or immediately after USTclosure activities

Based on soil and (if present in excavation) water

analysis and consistent with approved work plan

Analyze by State-Certified lab for previously storedsubstance(s) and breakdown products or transformationproducts.

SOIL SAMPLING


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Geological logs shall be prepared bya Professional Geologist or Civil

Engineer

technician working under the directsupervision of one can do this

provided the professional reviewsthe logs and assumes responsibilityfor them. 23 CCR 2649 (b)(1)(D)

SOIL SAMPLING


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Removal

Minimum 2 below the UST bottom in native soil ateach end of tank

Every 20 linear feet of piping

May include vent and vapor for VPH systems based onchange in piping definitionThis includes sampling under the dispenser

Stockpile sampling (not specified in 23 CCR 2672)


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2670(f)

Bus. Prof.

Code 7835

2672(b)(2)(c)(2)

2672(b)(3)(4)

2649(f)(6)HSC

25298.5

2672(c)(1)

Bus. Prof.Code 7835

2649(f)(5) (g)

2649(f)(5) (g)HSC 25298.5

2649(f)(5) (g)

2670(f)

SFSFRrequirement

Needed to de-termine if furtheraction is needed

Professional

Professional

piping & dispensers

PERMANENT UST CLOSURE


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2 TYPES

Closure-in-place23 CCR 2672(c)

Removal23 CCR 2672(b)

UST


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USTCLOSURE-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


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USTCLOSURE-IN-PLACE

Closure-in-place allowed for UST 2

UST 2

BUILDING

UST 1

45

UST


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Process similar to removal

Clean tank

Legally manage waste

Sampling borings required

Fill with inert solidexception

USTCLOSURE-IN-PLACE

UST


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USTCLOSURE-IN-PLACE

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

Non-haz substance must be compatible withprevious UST use and construction

Check with LIA and Fire Departments on theirrequirements


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UST CLOSURE-IN-PLACE

Filling with inert solid

Provide proper openings to filling tank withinert material

Use concrete slurry, sand, flowable ash, orfoaming agentEnsure UST buoyancy is offset

UST PIPING


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UST PIPINGCLOSURE-IN-PLACE

Remove all piping unless it willdamage structures or other pipes

Piping to remaining in place must beemptied of contents and capped

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

Remove ventBackfill

SOIL SAMPLING


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Closure-in-place

One or more slant boring as close as possible to themidpoint of the UST OR

Vertical borings drilled along each long dimensionalside of UST OR

Other method as approved by LIACheck approve permit/workplan


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TEMPORARY

USTCLOSURE


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TEMPORARY

UST CLOSURE

23 CCR 2010 CFC

When storage of HS has ceasedbut the UST will be used again

within 12 months

When UST is taken out of service

Submit proposal 30 days prior toclosure

Safeguard within 90 days


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TEMPORARY

UST CLOSURE23 CCR 2010 CFCRemove liquid and properly manage it same

Cap and secure pipe, fill line, gauge openings,vapor recovery

same

maintain vents same

Disconnect power to pumps but not cathodicprotection system

Inert to levels that preclude explosions OR lower ifrequired by LIA

UST may be filled with a non-corrosive liquid thatis not a hazardous substance


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TEMPORARY

UST CLOSURE23 CCR 2010 CFCRemove liquid and properly manage it same

Cap and secure pipe, fill line, gauge openings,vapor recovery

same

maintain vents same

Disconnect power to pumps but not cathodicprotection system

Inert to levels that preclude explosions OR lower ifrequired by LIA

UST may be filled with a non-corrosive liquid thatis not a hazardous substance

TO FILL OR NOT TO FILL?


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TO FILL OR NOT TO FILL?

Decidingfactors

High

groundwater?Intent andtime frame forreuse?

Consideramount ofwastegenerated


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TEMPORARY UST


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TEMPORARY USTCLOSURE

f filled

Non corrosive liquid

Not a hazardous substance

Test liquid and submit results to LIA priorto removing it from UST at end of tempclosure period

UST TEMPORARY


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CLOSURE

Monitoringrequirements

Can be modifiedby LIA based onneed to detectunauthorizedrelease

Cathodicprotection mustbe maintained


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UST TEMPORARY


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CLOSURE

Continue compliance with the followingrequirements:

Repair and record keeping

Release reporting and investigations

Release response and corrective actions

TEMPORARY


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UST CLOSURE

Options at end of permit term

23 CCR 2010 CFC

12 month extension may begranted if site assessmentperformed

Removal from ground within oneyear for USTs out of service


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