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Temporarily Out-of-Service Underground Storage Tank Systems: Site Check Requirements

Underground storage tank (UST) facilities can use these requirements to know how to perform a site check so that they are no longer subject to financial assurance requirements.

Per 30 Texas Administrative Code (TAC) §334.54(e)(5)(b) , an owner/operator who intends to place a UST system temporarily out-of-service (TOOS) must empty the UST system in accordance with 30 TAC 334.54(d)(2) and perform a “site check” as defined by 30 TAC 334.74(2) to be released from financial assurance requirements.

The purpose of a site check is to determine if a release has occurred from the portion of the UST system that is to be placed TOOS. Site checks must conform to the American Society for Testing and Materials (ASTM) guidance ASTM E1903, Standard Practice for Environmental Site Assessments: Phase II Environmental Site Assessment Process and be conducted by qualified personnel following recognized industry practices. The TCEQ recommends contacting an environmental consulting firm registered as a Corrective Action Specialist (RCAS) to conduct these activities. Find a list of these companies on the TCEQ website.

 According to 30 TAC 334.74(2) , site checks must:

  • Be capable of detecting and measuring the presence of a release where contamination is most likely to be present.
  • Include the inspection of any existing tank hold observation wells for the presence of non-aqueous phase liquid (NAPL)
  • Include sampling where releases are most likely to occur from the UST system.

 The following are the minimum requirements for assessing releases at the UST system: 

Tank Hold

  • Advance at least two soil borings as close to the tank hold as possible, to a depth of at least 1 foot lower than the bottom of the tank hold. One of the borings must be placed close to the fill port; the other boring(s) may be placed on other side(s) of the tank hold.
  • If the tank hold has more than 2 tanks or if any of the tanks in the tank hold are greater than 2,000 gallons in capacity, additional borings may be needed with at least one along each side of the tank hold.
  • Collect two soil samples from each boring:
    • one at the interval with the highest indication of contamination (staining, odors, field instrument reading); or between the midpoint of the maximum tank diameter and total depth (TD) (if no obvious contamination is present); and
    • a second sample at the bottom of the boring.
  • If groundwater is encountered before reaching the bottom of the boring, collect a groundwater sample by installing a temporary monitor well. 

Dispenser(s)

  • Advance one soil boring adjacent to each dispenser, at least one foot into the native soil below the depth of dispenser sump and collect one sample from the bottom of each boring.
  • Separate dispenser samples are not required if the dispensers are located directly above the tank hold.

Analytical requirements for petroleum substances and associated chemicals of Concern for Analysis in Groundwater and Soil are included in Table 1. Petroleum Storage Tank (PST ) action levels can be located of the TCEQ webpage at TCEQ Remediation Division - PST Program Action Levels (texas.gov),

Site Check Completion: Next Steps

  • Facilities that conduct a site check and do not identify a release should complete and submit the Temporarily Out of Service UST Site Check Certification Form (TCEQ Form 21014). Facilities also must keep records on-site and those records must be made available upon request to demonstrate that the facility has conducted the site check, and no release was documented.
  • Facilities that conduct a site check and identify a release must submit the site check documentation on Release Determination Report Form (TCEQ Form 00621) and any corrective action documentation to the Remediation Division PST Program (MC-137), TCEQ, P.O. Box 13087, Austin, TX 78711-3087.

Contact Information

For any questions about these site check requirements, contact the Remediation Division PST Program at:

Table 1: Petroleum Substances and Associated Chemicals of Concern for Analysis in Groundwater and Soil

Petroleum Substance

Constituents 

Analytical Methods a,b

Automotive and industrial lubricants

Liquid asphalt and dust-laying oils

Transformer oils and cable oils

Hydraulic fluid, lubricating oils, Nos. 5-light, 5-heavy, and 6 fuel oils

TPH

TCEQ Method 1005: Report results for boiling point ranges nC6 to nC12, >nC12 to nC28, >nC28 to nC36, and nC6 to nC36.

PAHsc when TPH >nC12 is detectedd

Low level SW-8270d  (if applicable)

Gasoline, aviation gasolines, diesel, aviation jet fuels, and Nos. 1, 1-D 2, 2-D, 4, 4-D, 4-light fuel oils, and gas-turbine fuel oils

Illuminating oils (kerosene, mineral seal oil, long-time burning oils, 300 oil, mineral colza oil)

Motor fuels (including motor gasoline, aviation gasoline, No. 1 or 2 diesel fuels, biodiesel, gasohol)

Benzene, Toluene, Ethylbenzene, Xylenes (BTEX) and Methyl tert-butyl ether (MTBE)

SW-8021 or SW-8260: For release determination, use Method SW-8260.

TPH

TCEQ Method 1005: Report results for boiling point ranges nC6 to nC12, >nC12 to nC28, >nC28 to nC36, and nC6 to nC36.

PAHsc when TPH >nC12 is detectedd 

Low level SW-8270d   (if applicable)

Solvents (e.g., Stoddard solvent, petroleum spirits, mineral spirits, petroleum ether, naphthas)

Volatile Organic Compounds (VOCs) including BTEX and MTBE

Initially use SW-8260 to analyze for all solvent related VOCs including BTEX and MTBE. Then other methods, such as SW-8011 or SW-8021, can be used during corrective action.

TPH

TCEQ Method 1005: Report results for boiling point ranges nC6 to nC12, >nC12 to nC28, >nC28 to nC36, and nC6 to nC36.

PAHsc when TPH >nC12 is detectedd 

Low level SW-8270d  (if applicable)

Waste oil or unknown petroleum substance

Volatile Organic Compounds (VOCs) including BTEX and MTBE

Initially use SW-8260 to analyze for all solvent related VOCs including BTEX and MTBE. Then other methods, such as methods SW-8011 or SW-8021, can be used during corrective action.

TPH

TCEQ Method 1005: Report results for boiling point ranges nC6 to nC12, >nC12 to nC28, >nC28 to nC36, and nC6 to nC36.

PAHsc when TPH >nC12 is detectede

Low level SW-8270d   (if applicable)

Metalsf (in soil only) when TPH is detectede

SW-6010 or SW-6020

SW-7471 – Mercury

a The MQLs for the analytical methods used must be less than or equal to the ALs, or the most sensitive standard method available must be used for the COC. The MQL for a chemical is the lowest nonzero standard used in the laboratory's initial calibration curve, as described in Method SW-846 8000. Report analytical responses detected at or above the laboratory sample detection limit (SDL) as detected results. For responses detected below the MQL (adjusted for sample specific factors like dilution, sample size, or percent dry weight for soils) but at or above the SDL, report the results at the concentration estimated by the laboratory and flagged with a qualifier (e.g., “J”) indicating the value is an estimate.

b EPA SW-846 methods, except where noted. Use a laboratory accredited under the Texas Laboratory Accreditation Program to analyze the samples. Use the latest version of the method for which the laboratory is accredited.

c PAH analysis will include the following COCs: Acenaphthene, Anthracene, Acenaphthylene, Benz-a-anthracene, Benzo-a-pyrene, Benzo-b-fluoranthene, Benzo-g,h,i-perylene, Benzo-k-fluoranthene, Chrysene, Dibenz-a,h-anthracene, Fluoranthene, Fluorene, Indeno-1,2,3-cd-pyrene, Naphthalene, Phenanthrene, and Pyrene.

d At each tank system, select the sample with the highest concentration of TPH in the >nC12 range and analyze the sample for PAHs. If analytical interference is observed or suspected in the PAH analysis, sample extract should undergo cleanup—i.e., using Method 3611.

e The MQLs for TPH must be less than or equal to 50 mg/kg for soil and 5 mg/L for water for each boiling point range (i.e., nC6–nC12, >nC12–nC28, and >nC28 to nC35 or nC36). Report analytical responses detected at or above the laboratory sample detection limit (SDL) as detected results. For responses detected below the MQL (adjusted for sample specific factors like dilution, sample size, or percent dry weight for soils) but at or above the SDL, report the results at the concentration estimated by the laboratory and flagged with a qualifier (e.g., “J”) indicating the value is an estimate.

f Metal analysis will include the following Resource Conservation and Recovery Act (RCRA) 8 metals: Arsenic, Barium, Cadmium, Chromium, Lead, Mercury, Selenium, and Silver.