3-3-15 master nh chapter mtbe remediation

Environmental Business Council of New England

Energy Environment Economy

EBC NH Chapter Program:

NHDES MTBE Remediation Efforts and

UST Regulation Changes

Shelley Tamis

Program Chair & Moderator

Regional Manager

TMC Environmental



Introduction

John Pasquale and Gary Lynn

Project Manager and Administrator

MTBE Remediation Bureau

NH DES



Big Picture Overview of the

MTBE Remediation Bureau

Overview of the New

MtBE Remediation Bureau

Presented by Gary Lynn, P.E. &

John Pasquale, P.G.

Pease Tradeport March 2015

Program Overview

Program Created to Manage MtBE Litigation Settlement Funds Manages portion of Settlement funds restricted to

MtBE cleanup ($81.4 million)

Funds available this biennium = $22.2 million

Funds expended this biennium $1 million

DOJ/DES MOU

DOJ with sole discretion on funds but administratively delegated to DES via MOU

> $1 million project requires DOJ approval

MtBE Remediation Bureau Established at DES

Programs

Water Supply Well Sampling

Permanent MtBE Contaminated Water Supply Solutions Infrastructure solutions

Replacement wells

Aquifer Protection and Restoration MtBE Release Prevention

UST removals

MVSY BMPs

Site Investigation and/or Remediation

Private Water Well Testing

Program

DES sampling crews

Focus on vulnerable aquifers with existing

releases

Heavy use of GIS to ID receptors and

potential threats

Private Well Sampling Districts

Initial focus on known high risk sites and

areas w/ high density of water supplies and

potential aquifer threats

Town Invites Future

Sampling

Sampled MtBE Detects

Estimated

+ detects

Belmont 51 0 24 0 3

Derry 154 1 75 8 252

Hampton Falls 38 7 8 1 2

Londonderry 89 1 52 2 8

Pelham 86 0 33 1 9

Salisbury 70 1 40 3 6

Stratham 179 2 73 4 12

Windham 275 9 68 5 16

Totals 942 21 373 20 81 (21.7%)

MtBE Sampling Program Status

Note: 1) Detect means > 0.5 ppb, estimated = 0.1 to 0.5 ppb

2) Four detections of MtBE over standards in Derry (17 to 100ppb)

Sampling District#1 - Dry Cleaner/Gas Station/Ether Site

Phase 1

Funding Eligible

MtBE Site

Potential Infrastructure Project

Water Line Dead Ends

Infrastructure Program

Plaistow Fire suppression system conversion feasibility study

Atkinson Sunoco water line extension

Waterhouse Country Store in Windham water line extension

Little Falls Cooperative water line extension

Lee Circle Mobil FS

LeClairs in Chester FS

Dovers Griffin well relocation

Why UST Removals?

UST/MtBE groundwater contamination correlations

Source: Occurrence of Methyl tert-Butyl Ether (MTBE) in Public and Private

Wells, Rockingham County, New Hampshire: By Joseph D. Ayotte, Brian R.

Mrazik, Denise M. Argue, and Frederick J. McGarry

Richmond Four Corners: Prevention/Cleanup

Soil Excavation

July/August 2014

Three compartment UST

Compromised Enviroflex Pipe

Gulbickis Towing RP Lead

14

Temporary closure USTs filled

with water, residual gas forced

out to pump island area

Contaminated

soil excavation

area

UST Removal Program

Objectives Prevention: Removal of out of service tanks

containing old gas (pre 2007)

Remediation: Removal of tanks to assist with removal of contaminated soil causing MtBE contamination

Investigation: Removal of leak prone tank systems (single wall tanks and piping) for investigation of potential MtBE releases.

UST Removal Eligibility Must be MtBE related

Old gas in temporary closure tanks (post 1977 and pre-2007)

Necessary for MtBE related cleanup (MtBE above standards and UST system area source)

Necessary for MtBE related investigation work UST removal assists in identification of MtBE containing

gasoline release(s)

Funding Prioritization

Risk to receptors Single wall UST systems near water supply, etc.

Owner lacks financial resources

Process DES reviewing sites

Active LUST sites for remedial needs

List of UST systems requiring 2015 upgrade

DES contacting site owners to explain program

DES receiving project applications from online form for reimbursement projects

DES scheduling some removals w/ contractors or

DES requesting work scopes and budgets for ODD fund/MtBE Bureau project

Results to date USTs Removed: 11 tanks at 7 facilities

Remedial Reimbursement Projects: 2 Contaminated Soil Removed: 1,000 tons

Scheduling underway: ~17 facilities

Ongoing Leaks Observed and Stopped: 3 Environflex pipe at Richmond Four Corners & Gilford Village

Store

Piping release from temp. closed tanks at Gulbickis

Unique Project Challenges

Tight alley

Underwater

Shutdown

street

Funding: Option 1

Direct Services DES Response Contract Amended

Cyn, TMC, Enpro and Clean Harbors $250k each

Focused on UST closures

$70K funded to date

Consulting Contract Procurement Contracts under negotiation

Contract to start with new FY (July 1, 2015)

UST closure reports and related assistance included

POE Contract Existing Secondwind contract to be extended

with MtBE funding included

External Laboratory Services Contract to be submitted to Governor & Council

Funding: Option 2 -

Reimbursement Reimbursement or direct application for

payment process (not a grant or loan) Match not required for eligible work

Costs unrelated to MtBE cleanup ineligible (piping and tank replacement, etc)

Must be a DES approved eligible activity

Preapproved work scopes and budgets required

Claims process similar to ODD fund

$530K in approved project budgets and $230K in claims already paid

Contact Information:

Gary Lynn, P.E

MtBE Remediation Bureau Administrator

NHDES Waste Management Division

29 Hazen Drive, P.O. Box 95

Concord, New Hampshire 03302-0095

Phone: (603) 271-8873

E-mail: [email protected]

John Pasquale, P.G.

Project Manager

Phone: (603) 271-7179

E-mail: [email protected]

mailto:[email protected]

Matt Jones

Compliance and Enforcement

Subsection Chief

NHDES



Underground Storage Tanks:

Upgrade Requirements and

Deadlines

Underground Storage Tank Upgrade

Requirements and Deadlines

Matt Jones, NHDES

Oil Compliance and Enforcement Subsection Chief

EBC New Hampshire Chapter Program: NHDES MTBE

Remediation Efforts and UST Regulation Changes - March 3, 2015

2015 Deadline Overview

What is the rule and what does it mean?

How many sites affected?

Closure Process

Upgrade Process

Resources for Owners, Contractors and

Consultants

Other Deadlines

EBC New Hampshire Chapter Program:


UST Regulation Changes - March 3, 2015

What is the rule?

Env-Or 408.05(c), originally Env-Wm

1401.18(c), adopted April 22, 1997

With the exception of vent piping, any

part of an existing single wall UST system

that routinely contains regulated substance

without secondary containment and leak

monitoring shall be permanently closed by

December 22, 2015. EBC New Hampshire Chapter Program:



What does the rule mean?

By December 22, 2015 every tank system

should be:

Double Wall Tank

w/Sensor




Double Wall Tank w/Sensor




Tank

Interstitial

Sensors



should be:

Double Wall Piping,

Sump w/Sensor




Double Wall Piping and Piping Sump w/Sensor




Sump Sensor



should be:

Dispenser Pan

(where applicable)




Dispenser Pans




Sump Sensor


Double Wall Tank

w/Sensor

+

Double Wall Piping,

Sump w/Sensor

+

Dispenser Pan

(where applicable)




Compliant

with

December

22, 2015

Deadline

How many sites are affected?

478 Sites

993 Tank Systems

Gasoline 570

Diesel 207

Heating Oil 170

186 Single Wall Tanks

807 Piping and/or

Dispenser Pans




Closure Process

Notify DES at least 30 days prior

InternationalCode Council U2 Certification

Closure Report Within 30 Days




Upgrade Process

Plan Approval

New Hampshire P.E. Stamped Plans and Specifications

Application

$100 Fee

Up to 90 Days for Approval

Recommend Submittal by End of August 2015

Installer - International Code Council U1Cert.

EBC New Hampshire Chapter Program: NHDES MTBE Remediation Efforts and UST Regulation Changes - March 3, 2015

Owner, Contractor, and Consultant

Resources

OneStop Contractor and Consultant Lists

Certified Companies

http://www2.des.state.nh.us/WasteReport

s/Menu.aspx




http://www2.des.state.nh.us/WasteReports/Menu.aspxhttp://www2.des.state.nh.us/WasteReports/Menu.aspxhttp://www2.des.state.nh.us/WasteReports/Menu.aspxhttp://des.nh.gov/onestop/index.htm

Other Deadlines

Stage II Decommissioning

December 22, 2015

Spill Containment Integrity Testing

December 22, 2017

Overfill Prevention Device Testing

December 22, 2017

Primary Containment System Testing

December 22, 2017




Contact Information

Matthew Jones, Oil Compliance and Enforcement Subsection Chief

(603) 271-2986

[email protected]

Michael Juranty, P.E., Supervisor Oil Compliance Section (603) 271-6058 [email protected]

Chuck Corliss, P.E., Design Review Chief (603) 271-0686 [email protected]




mailto:[email protected]:[email protected]:[email protected]



Networking Break

Tom Healey, P.E.

Director of Technical Services

Nouria Energy Corporation



Industry Challenges:

UST Upgrade Requirements and

Deadlines

Industry Challenges - UST Upgrade Requirements and Deadlines

March 3, 2015 - EBCNE

Tom Healey, P.E.

Director of Technical Services

Nouria Energy Corporation

About Nouria Energy is a wholesaler and retailer of major branded motor fuels.

Operate 85 retail fueling facilities with convenience stores and car washes throughout 4 New England states.

Approximately 800 employees

Supply branded motor fuels to another 40 customers

Tom Healey involved in retail petroleum industry for 24 yrs.

Engineering and project management at Exxon, Shell and smaller firms. In current position with Nouria Energy for past 8 years.

Worcester Polytechnic Institute, B.S. Civil Engineering University of Massachusetts, M.B.A.

Industry Challenges - UST Upgrade Requirements and Deadlines - March 3, 2015 - EBCNE

UST Regulations

UST regulations have continued to evolve since Subtitle I was added to the Solid Waste Disposal Act in 1984 and amended in 1986.

Technical standards for design and installation

Corrosion protection

Spill & overfill prevention

Leak detection

UST closure

Corrective actions

Financial Responsibility

Leaking Underground Storage Tank (LUST) Trust Fund

First major upgrades completed for 1998 Federal deadline


UST Regulations (cont.)

Energy Policy Act of 2005 further amended the Solid Waste Disposal Act. Imposed operational and facilities requirements

Inspections by third parties and operators

Operator training standards

Leak detection

Secondary containment

State agencies established state specific regulations

NHDES has demanding regulations relative to the permit and inspection process

NHDES and retail petroleum UST owners collaborate primarily through IOMA


What are the Challenges for the Retail Petroleum Industry?

Immediate challenge for UST owners/operators that are impacted by December 22, 2015 double wall & monitoring upgrades:

Overall cost of upgrades

Construction

Environmental

Business Interruption

Securing financing

Availability of qualified contractors & consultants


Construction Cost

UST system replacement for a typical retail service station $200K-$250K

Pipe replacement/tank top upgrade $125K-$175K

Other costs

Dispensing systems/POS upgrades

Electrical upgrades

Pavement

Other NHDES conditions of plan approval

Stormwater

Fire Code


Environmental Cost

Soil and groundwater costs can span a wide range

Expect higher costs with removal of older UST systems

Potential to lengthen project duration

Pre-construction planning is crucial amongst owner, design engineer, contractor and environmental consultant

Pre-classify for waste disposal

Designated soil stockpile & frac tank areas

Groundwater treat & discharge or haul to disposal facility

Have contingency plan for unexpected conditions

Owner must understand reimbursement process - private insurance and NH Petroleum Reimbursement Fund Program


Business Interruption Cost

UST system replacement: 4 to 6 weeks of business downtime

Potential loss of employees due to project downtime

May take weeks to gain back lost business volume once reopened

Underground work is not seen by customers. Must wow them back with other improvements


As December 22, 2015 Deadline Approaches

UST owners need to act now

Work scopes, budgets

NHDES and local permitting

Bidding & contracting

Equipment ordering

Environmental planning

Construction

NHDES post construction submittals

Opportunities for Consulting Firms to reach out to UST owners/operators

Turnkey approach vs. limited services

Ongoing environmental compliance services


Beyond 2015 UST owner will continue upgrades and repairs of full UST systems and components Regulatory Driven

NHDES 2017 deadline for Spill Containment, Overfill Prevention Device and Primary Containment Testing Integrity Testing

Many UST operators are already conducting most or all of the testing required by 2017

UST Owner Operations and Maintenance Programs

Capital Programs scheduled upgrades based upon UST system age and environmental risk


Nouria Energy Contacts Tom Healey, P.E. Director of Technical Services 508-762-3727 [email protected] Bob Farr Compliance Manager 508-762-3784 [email protected] Mailing address: 326 Clark Street Worcester, MA 01606 www.nouriaenergy.com


mailto:[email protected]:[email protected]://www.nouriaenergy.com/



Panel Discussion

Moderator: Shelley Tamis, TMC Environmental

Panel Members

Gary Lynn, NH DES

John Pasquale, NH DES

Matthew Jones, NH DES

Tom Healey, Nouria Energy Corporation

3-3-15 master nh chapter mtbe remediation

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