Underground Storage Tank Removal and Limited Removal Action
Contents
CommTank provided a Limited Removal Action (LRA) service for this residential property located in Dedham, Massachusetts after the removal of a 4,000-gallon No. 2 fuel oil underground storage tank (UST). A change order was issued for the transportation and disposal of petroleum contaminated soil (PCS) after a leak was discovered at the fill pipe. These remedial actions were initiated and completed under the provisions of a LRA which is outlined in the Massachusetts Contingency Plan (MCP) at 310 CMR 40.0318.
Limited Removal Action
Prior to UST removal, petroleum staining was observed near the UST fill pipe. CommTank excavated and stockpiled this soil for proper disposal. After removal of this PCS, a grab soil sample was collected for laboratory analysis and was screened for total organic vapors (TOVs) using a Thermo Electron Model 580B Organic Vapor Meter (OVM) via the Massachusetts Department of Environmental Protection (MassDEP) jar headspace screening method (described in MassDEP BWSC Policy No. WBC-400-89 entitled Management Procedures for Excavated Soils Contaminated with Virgin Petroleum Oils). The OVM was calibrated to measure TOVs, as isobutylene, in parts per million per volume (ppmv). A TOV concentration of 90 ppmv was measured for this grab sample.
Underground Storage Tank Removal
After removal of PCS identified above the UST, CommTank removed the 4,000-gallon No. 2 fuel oil UST and associated piping from the beneath the grassy area on the southern side of the residence. Approximately 150 gallons of fuel oil remaining in the UST was removed and the UST was cleaned prior to removal. The UST was transported and disposed at a licensed scrap yard.
Once the UST was removed, CommTank collected soil samples from sidewalls and from the base of the excavation. No TOV concentrations above background (0 ppmv) were recorded during the screening of soil samples collected from sidewalls and the bottom of the UST excavation.
One soil sample identified as Pb2 10’ was collected from the bottom of the excavation for submittal for laboratory analysis. The soil sample collected for laboratory analysis was submitted under proper COC to ChemServe of Milford, New Hampshire for laboratory analysis for MassDEP EPH including target PAHs.
Two days later, 15.24 tons of PCS stockpiled next to the UST, was transported by CommTank to Environmental Soil Management, Inc. (ESMI) in Loudon, New Hampshire under BOL completed by Kevin J. Kavanaugh, LSP (LSP No. 7610) for thermal recycling.
Dan Hoag has worked in the environmental and tank storage industry for 16 years. Dan’s range of expertise includes designing systems for oil spill clean-ups, treating soil contamination through "in situ" oxidation and testing, and inspecting underground storage tank systems. As head of Marketing and Information Technologies at CommTank, Dan draws from field experience to write about fuel, water and chemical storage technologies, and the regulations that affect them. He has developed training courses in home inspection, underground storage tank operator, ultrasonic thickness and tank tightness testing. Over the past decade, Dan has published over 60 articles about industry trends and has documented commercial, residential, and environmental projects through illustration, videos, and photography. When Dan unplugs from technology, he spends his time backyard farming, hiking, and kayaking, while masquerading as a hockey player during the wee hours of the morning.