5-Years Later Low-Threat Petroleum UST Closure Policy Presented - PowerPoint PPT Presentation

Jan 29, 2024 •246 likes •354 views

5-Years Later Low-Threat Petroleum UST Closure Policy Presented by: Kevin Heaton Sean McClain Geologist, P.G., CHG Geologist, P.G. County of San Diego, Department San Diego Regional Water of Environmental Health, Site Quality Control

5-Years Later Low-Threat Petroleum UST Closure Policy Presented by: Kevin Heaton Sean McClain Geologist, P.G., CHG Geologist, P.G. County of San Diego, Department San Diego Regional Water of Environmental Health, Site Quality Control Board, San Assessment & Mitigation Diego Region
SWRCB Low-Threat Petroleum UST Closure Policy  Focus on high-priority cases (such as impacted drinking water wells, human health, and sources of free product)  Provide consistent regulation of the Policy throughout the state  Path to Case Closure Plans for each open case, including specific milestones and timelines
LTC Policy Criteria Difficulties
Site Conceptual Model  Extent of release in both soil and groundwater  Definition of areas impacted by free product  Data analysis of dissolved plume stability  Quantify volume of residual impacted soil remaining  Maps of dissolved plumes (BTEX and MTBE) and estimated time to reach MCLs
Free Product Removed to the Maximum Extent Practicable  Free Product Removal  Bailers are not effective  Dedicated skimmers or hydrophobic bailers have been effective in sandy soils not silty or clayey soils  Vapor Extraction and Dual Phase Extraction  Effective where free-product is present  High Vacuum Dual Phase Extraction  Effective in tight formations
Free Product Removed to the Maximum Extent Practicable  Free product removed to the maximum extent practicable in a manner that minimizes the spread of contamination into previously uncontaminated zones  Migration shall be the predominant objective in the design of the free product removal system  To make these evaluations the following methods shall be considered  Monitoring the extent of the LNAPL body (usually using the apparent product thickness in monitoring wells) at a certain water level elevation over time  Bail-down test  Pilot testing (vapor extraction or DPE)
Free Product Removed to the Maximum Extent Practicable  Additional removal or active remedial actions shall not be required by regulatory agencies unless  Necessary to abate a demonstrated threat  Dissolved phase plume is not stable  Free product is migrating
UST Cases Closed with Free Product  Non-beneficial use aquifers that posed no threat to human health  Free-product under roads or near freeways that posed no threat to human health or the environment  Free-product in beneficial use aquifers greater than 30 feet bgs that posed no threat to water supply wells, future groundwater use, human health, or the environment
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