Presentation to Municipal Officials

1. Understanding Home Heating Oil &
Other Time - Critical Releases
Presented By
Jonathan Kitchen, PG, LSP
Molly Cote, LSP
Civil & Environmental Consultants, Inc.
Dan Crafton, Chief - Emergency Response
MassDEP – Southeast Regional Office
September, 2019
Massachusetts Municipal Officials

2. Topics to be Covered
►Types & Causes of Time-Critical Releases
►Prominence in Massachusetts
►MassDEP Emergency Response
►Responding to Releases
►Communications

3. Time Critical Releases - Spills
► Types of Spills:
▪ Residential Heating Oil Spills
Interior - Exterior
▪ Roadway Spills – Vehicle Accidents
▪ Underground Storage Tanks
▪ Boats – Surface Water Spills
▪ Releases to Stormwater Systems
▪ Dumping
► Every Spill/Release is UNIQUE

4. Time Critical Releases – Residential Heating Oil Spills

5. Time Critical Spills - Releases
UST Removals
Dumping

6. Time Critical Spills - Releases
Surface Water Spills

7. Time Critical Spills - Releases
Roadway Spills

8. Time Critical Spills - Releases
Fires – Residential & Industrial

9. Where Do Releases Go?
► Heating oil gets through cracks in basement floor
► Gets into a sump
► Discharges to soil
► Catch basins
► Ends up in/on groundwater (free product)
► Surface water
► Bedrock
► Neighbor’s yard
► Drinking water wells
► Indoor air

10. Responding to Releases

11. MassDEP Emergency Response
• Emergency Response 24/7/365
• All after hours emergencies
• Familiar with other MassDEP Programs:
• Wetlands
• Waste water
• Drinking water
• Generally responsible for releases in the first year
• Authorized to commit MassDEP resources to
address Imminent Hazards (IH) and other risks to
public health and safety

12. MassDEP Emergency Response
• Operate under Incident Command System
• Joint response with Fire Departments, State HazMat Teams
• USEPA & Coast Guard
• Incident Preparedness Planning
• All Hazards Planning
• FEMA Emergency Management Assistance Compact
• Massachusetts Oil Spill Prevention and Response Act
 Trailers, GRP development, testing and training

13. MOSPRA Spill Trailer

14. Coastal Spill Trailer Locations

15. Local Responder Boom Training

16. Oil and Hazmat Spill Exercises

17. All Hazards Planning - Tornado Response

18. What is the Environment?
Environment means waters, land, surface or subsurface strata, or
ambient air of the Commonwealth, including:
• Impervious surfaces
• Surface water
• Containment Areas

19. 2 Hour Notifications
Special Considerations
Secondary containment areas
Is the level
dropping?

20. 2 Hour Notifications
Special Considerations
• Contained within a building
• Sheen/petroleum on surface water
• Any release to environment with acute
human health impacts - Imminent
Hazard
• Fish kill from a release - Imminent
Hazard
North River, MA
September, 2019

21. 2 Hour Notifications
Releases to Sanitary Sewer Systems
• Not immediately reportable under MCP - Notify
WWTP immediately
• Oil and hazmat pass through - sheen on discharge or
fish kill – Report to MassDEP
• Was combined sewer overflow operational at time of
spill
• Response actions priority - limit impacts to biological
processes

22. Threats of Release - 2 Hour Conditions
• Buried drums
• Abandoned drums, facilities, tanks
• Tanker truck accidents
 Potential tank and piping structure compromised
• Boat sinking
• Commercial & Industrial Fires

23. Things That Are Not Reportable
Iron Bacteria Sheen Algal Bloom

24. 72 Hour Notifications
• MCP definition of UST:
• Structure of any size or capacity
• Including ancillary piping
• used or designed to be used for the storage of oil and/or
hazardous materials
• 10% or more of the volume of such structure and piping is
below the ground surface
• UST Removals & 100 PPM
 Measured within 24 hours after removal
 Must be measured prior to backfill
 Pre-characterization counts as part of removal

25. UST Threats of Release
• UST- includes tank, piping and appurtenances
• Leak > 0.05 gallons per hour
single-walled tank
inner or outer wall of double-walled tank

26. Notification Exemptions
Note that exempt “releases” may still be subject to MCP
• May not require reporting BUT
• Not exempt from cleanup

27. Immediate Response Actions
• Required for 2 and 72 hour notifications
• MassDEP approval required unless directed by Local
Fire Official
• Could include assessment, containment, fluid recovery,
absorbents, berm with shovel

28. Special Notes for Highway Spills
• Incident Command System in place
• Massachusetts quick clearance agreements - stabilize
and come back for additional work
• Appropriate emergency lighting for vehicles and PPE
(level D and high visibility) required for responders
• Contractors pre-permitted
• Follow-up work performed under MassDOT-issued
roadway work permit with specified work zone setup
 MassDOT (800) 227-0608

29. Residential Heating Oil Releases
Causes & Response

30. Imagine If This Were Your Home?

31. Types of Spills – Residential Heating Oil
Homeowner Oil Heating System Upgrade and Insurance Law, MassDEP, February 2011

32. Residential Heating Oil Spill Causes
Heating Oil Tanks & Fill/Vent Pipes

33. Residential Heating Oil Spill Causes
Oil Lines – Tank Legs

34. Residential Heating Oil Spill Causes
Tank Gauges, Whistles, Safety Valves & Filters

35. Heating Oil Release Causes
AST
35%
Fuel Line
24%
UST
19%
Delivery error
11%
Filter
6%
Natural cause
3%
Fill line
1%
Unknown
1%
Corrosion
Rupture
Toppled Tank (roof collapse)
Floor gave way
Corrosion
Ditch Witch
Improper Installation
Corrosion
Wrong House
Right House (no tank)
Overfilling
Cracked
Improper Threading
Flooding
Ice
Rainwater displaced oil

36. Heating Oil Release Causes
► Release Causes are Numerous:
▪ Holes in tank - ice (inside out or vice-versa, the big thaw!)
▪ Overfills / Overpressurization
▪ Failure to remove fill and vent pipe / Misdelivery
▪ Line corrosion
▪ Weakened legs (toppling)
▪ Poor floor construction (toppling)
▪ Poor engineering
▪ Cable guys & Teenagers
▪ Vandals (disgruntled ex-spouses & disgruntled contractors)
▪ Fire
▪ Flooding (floating tanks, displacement of oil)
▪ Demolition
▪ Falling objects
▪ Poor tank construction
▪ Cross threaded or defective filter
▪ Installation error (nicked line, etc.)
▪ Ditch witch

37. Responding to Heating Oil Releases
Who’s In Charge?
► Follows incident command
► May be different at different release
▪ fire, crime scene, etc.
► May change over time

38. Responding to Heating Oil Releases
Immediate Actions to Take or Recommend
► If possible:
▪ Turn off power to furnace/hot water heater
▪ Catch/contain oil
▪ Stop the leak (plug hole)
▪ Apply absorbents
▪ Open windows – set up fans
▪ Call a cleanup contractor &/or LSP
▪ Unplug sump pumps – cover floor drains
▪ Contact fuel oil service company (pump out remaining contents)
▪ Deploy booms if surface water affected
▪ Take actions to prevent migration – Be creative, if necessary
▪ Cover catch basins (plastic bag/soil berm)
► Notify MassDEP - 24 hour release reporting line: (888) 304-1133
► Contact Insurance Company
► Think about “evidence”

39. Responding to Heating Oil Releases – Who Pays
► Insurance ?
▪ Over 700,0001
homes in MA heated by oil, most not currently
covered
▪ Approximately 44,0002
homeowners (6%) have specialized liquid
fuel release insurance riders
▪ 1172
residential home heating oil spills were reported to
MassDEP in 2017
▪ Current law only requires insurers to “make” insurance
“available” but does not require them to inform homeowners
 Homeowners must ASK for it and OPT IN
 Average cost is about $100 / year
 Cleanup costs can range from $20,000 to $500,000
3
, depending
on complexity
 Bills S594, H1008 & H2835 seek to require insurance coverage
 Hearing was held at Beacon Hill yesterday afternoon
1 https://www.mass.gov/service-details/how-massachusetts-households-heat-their-homes
2 MassDEP July 16, 2018 “Report to the Joint Committee on Environment, Natural Resources and Agriculture”
3
http://www.mass.gov/eea/agencies/massdep/cleanup/regulations/homeowner-oil-spill-cleanup-guide.html

40. Responding to Heating Oil Releases
Communications
► Affected parties most often don’t know where to begin
► Rely on others present to guide them & looking for sound
advice
► Be reassuring
► Avoid alarming statements
► Be careful about risk comparisons
► Be honest about what is known and unknown
► Help them understand that it is a process (not cured
overnight)
► Try to speak as a team (talk among other responders too)

41. Responding to Heating Oil Releases
Communications
► Is it safe to stay here?
▪ No single standard or criteria
▪ Consider individual occupants (elderly, children)
▪ Is mitigation in place (vapor barriers, fans, etc)
▪ Time of year
▪ Who makes that decision (Occupants? Board of Health?)
► Where will we go? Who will pay for us to stay?
► Who can we call?
▪ Local Red Cross (help find tenants lodging)
▪ If elderly, Council on Aging
► Is City/Town water available or is it a private well?
▪ Can we drink it?
► How do we heat the home/hot water?

42. Responding to Releases
Initial Actions Have an Impact
►If done well, initial actions taken can:
▪ Help prevent migration
▪ Minimize the number of parties affected
▪ Minimize media (soil, groundwater, surface water,
indoor air) affected
▪ Help control the cost of cleanup
▪ Minimize the time to closure

43. What’s Next – After the Initial Response
► A key message on cleanups: the sooner the contaminant
mass is removed, the less costly the cleanup is likely to
be
► Regulatory process – submittals and timelines
▪ Immediate Response Action (IRA)
▪ Limited Removal Action (LRA)
► Assessment will be required: soil, groundwater, indoor
air, surface water
► Achieve specific cleanup standards
► Time to closure varies on amount released, media
impacted, specific site conditions
▪ type of foundation/construction

44. What’s Next – Cleanup
►Excavation
▪ Shoring
►In-situ Treatment
►Exposure Mitigation

45. 1
10
100
1000
10000
0 50 100 150
Volume(gal)
Length (ft)
What’s Next – Does Spill Volume Matter?
Volume(gal)
Time (years)

46. What’s Next – How Far Do Spills Travel
►Average groundwater contaminant plume for home
heating oil spill <40 feet, with <25 foot length
exceeding standards
►75% of plumes from home heating oil spills <50 feet

47. 0 - 60 days:
9%
60 - 120 days:
15%
120 days - 1 year:
33%
1 - 3 years:
28%
3+ years:
15%
Time = Money 9% <60 days
24% <120 days
57% <1 year
Time To Closure – Heating Oil Spills

48. Conclusions
► The main factors affecting the severity of a spill are:
▪ Volume spilled
▪ How long it has been going on
▪ Previously undiscovered releases
▪ Building construction
▪ How quickly the spill is discovered and acted upon
▪ The soil permeability
▪ The presence of NAPL
▪ The applicable groundwater standards
▪ How quickly it was responded to and managed
▪ Insurance coverage / funding
► Your help is valuable and can make a big difference!

49. Questions

50. Contacts
Molly Cote, LSP
Project Manager III
Mobile: (508) 802-3063
Email: mcote@cecinc.com
Civil & Environmental Consultants, Inc.
31 Bellows Road
Raynham, MA 02767
Toll-Free: (866) 312-2024
www.cecinc.com
Jonathan D. Kitchen, PG, LSP
Principal
Mobile: (508) 326-8727
Email: jkitchen@cecinc.com