Form No. DPP-RFP-PS-68-75

Approved 5/7/75

Revised 3/18/08



GOVERNMENT OF

THE VIRGIN ISLANDS OF THE UNITED STATES



Request for Proposal — Negotiation

Professional Services



df cre aan Ue rire 28 HO oe Be eta es Ne tee J-s LAN rs Date: June 29, 2016



sri eiadeuiaee Gaaiunhemmnarenpaosan’ feitvteic utara tarball RFP No. 024-2016 (P)



Pursuant to 31 V.I.C. 239 (a) (4) and Rules and Regulations thereunder issued,

the Government of the Virgin Islands, Department of Property and Procurement will

receive proposals for the work described below. Proposals will be received until Friday,

July 29, 2016 @ 4:00 o’clock p.m. Atlantic Standard Time.



SCOPE OF SERVICES: ATTACHED

Form No, DPP-RFP-PS-68-75

Approved 5/7/75

Revised 3/18/08



NEGOTIATED PROCEDURES:



The Commissioner of the Department of Property and Procurement will appoint

Selection Committee to assist in the evaluation and selection of the Contractor.

Accordingly current data on qualifications and performance should be submitted with

proposals. After reviewing the qualifications and proposals the Committee will select for

discussions from the firm/s or person/s considered not less than three (3), in order of

preference, deemed to be most highly qualified to provide the services herein

required. Discussions will be conducted successively and severally with the firms or

persons so selected the anticipated concepts and the relative utility alternative methods of

approach for furnishing the services hereunder.



FACTORS FOR DISCUSSIONS



Selection criteria will include (i) Professional qualification, registration and

general reputation of the principals of the firm or person; (ii) the extent to which the firm

or person specializes in or has designed projects of a type and scope similar to the

hereunder; (iii) familiarity with the area in which the project is to be located; (iv)

capability of meeting design schedules; and (v) quality of performance on other projects.



NEGOTIATION:



The Selection Committee shall recommend to the Commissioner the highest

qualified firm or person with whom a contract shall be negotiated. The

Commissioner, with the assistance of the Selection Committee, shall attempt to negotiate

a contract with such firm or person.



Should the Commissioner be unable to negotiate a satisfactory contract with the

firm considered to be the most qualified, at a price he determines to be fair and

reasonable to the Government, negotiations with that firm will be formally terminated.

Negotiations will then be commenced with the second most qualified, the third most

qualified or additional firms, in order to preference and their competence and

qualification, and shall continue until an agreement is reached.



Randolph N. Bennett

Commissioner of Property and Procurement

Form No, DPP-RFP-PS-68-75

Approved 5/7/75

Revised 3/18/08



INSTRUCTION TO PROPOSALS



A. NOTICE



Qualified firm or individual (s) to Develop a Plan to Remove all

Underground Fuel Storage Tanks (UST).



Information provided in the scope of work is to be used only for purposes of preparing a

proposal. It is further expected that each bidder will read the scope of work with care, for

failure to meet certain specified conditions may invalidate the proposal.



The Government of the Virgin Islands, herein after referred to as GVI, reserves the right

to reject any or all proposals or any portion thereof and to accept the proposal deemed

most advantageous to GVI. Price shall not be the sole criterion of awarding this project.

Scope and quality of work proposed and the ability of the bidder to complete this type of

project shall also be considered.



Applicants are requested to submit proposals on the basis of the scope of work.

Alternative proposals recommending new features and technology other than that

requested in the scope of work will receive consideration providing such new features

and/or technology is clearly explained. Any exceptions to the requirements requested

herein must be clearly noted in writing and be included as part of the proposal.



The information contained herein is believed to be accurate, but is not be to consider in

any way as a warranty. Request for additional information clarifying the Scope of Work

should be directed in writing to Deputy Commissioner of Procurement, Ms. Latisha

Blyden at latisha.blyden@dpp.vi.goy. All request will be forwarded to Mr. Dennis

Chance, Territory Senior Strategic Planner- Department of Public Works (Vitran)



B. STATEMENT OF PURPOSE



To assess and remove Underground Fuel Storage tanks (UST) at

the Virgin Islands Transportation (Vitran) operations and

maintenance facility located at 306 Estate Contant, St. Thomas

Form No, DPP-RFP-PS-68-75

Approved 5/7/75

Revised 3/18/08



C,



PROPOSE SCOPE OF WORK

See Attached Scope of Work

TIMETABLE



1. Last day for requests for written clarification will be

Wednesday, July 13, 2016 @ 4:00 p.m.



2. Last day for responses from Department of Public Works will be

Monday, July 18, 2016 @ 4:00 p.m.



3. Proposals will be accepted at Department of Property & Procurement. no later

than Friday, July 29, 2016 @ 4:00 p. m.



SUBMISSION OF PROPOSAL



All interested parties shall submit seven (7) sets of proposals, One (1) original and

Six (6) copies which are to be delivered to the Department of Property and

Procurement during normal business hours, no later than Friday, July 29, 2016

@ 4:00 p. m.



They shall be addressed to:



Randolph N. Bennett



Commissioner



Department of Property & Procurement

Building #1 Subbase, 3rd Floor



St. Thomas, Virgin Islands 00802



The sealed envelope containing the proposal must have the following information

written on the outside of the envelope:



SEALED PROPOSALS-DO NOT OPEN



RFP-024-2016 (P)



(Name of Bidder)



(Mailing Address of Bidder)

(Telephone Number of Bidder)

(Fax Number of Bidder)

Form No. DPP-RFP-PS-68-75

Approved 5/7/75

Revised 3/18/08



Where proposals are sent by mail, the bidder shall be responsible for their

delivery to DOT before the date and time set for the closing of acceptance of

proposals.



F. WITHDRAWALS OF PROPOSAL



A proposal may be withdrawn at any time prior to the time specified as the

closing time for acceptance of proposals. However, no proposal shall be

withdrawn or canceled for a period of thirty (30) days after said closing time for

acceptance of proposals nor shall the successful provider withdraw or cancel or

modify his proposal, except at the request of GVI after having been notified that

said proposal has been accepted by GVI.



G. INTERPRETATION OF SPECIFICATIONS



If any person contemplating submitting a proposal requires clarification of any

part of the scope of work, he/she may submit to the GVI a written request for an

interpretation thereof to the Commissioner of Department of Property and

Procurement Randolph N. Bennett. GVI will not respond to questions received

after the above established date. The person submitting the request will be

responsible for its prompt delivery. Any interpretation of the scope of work will

be made in writing to all prospective providers. Oral explanations will not be

binding.



H. CONSIDERATION OF PROPOSAL



The Commissioner of Property and Procurement shall represent and act for GVI

in all matters pertaining to the scope of work and contract in conjunction

therewith. This RFP does not commit GVI to the award of a contract, nor pay

any cost incurred in the preparation and submission of proposals in

anticipation of a contract. GVI reserves the right to reject any or all

proposals and to disregard any informality and/or irregularity in the

proposal when, in its opinion, the best .interest of GVI will be served by such

action. Proposals failing to provide some of the items in the scope of work shall

not be rejected per se but any deviations from the scope must be clearly noted.



I. ACCEPTANCE OF PROPOSALS

GVI will notify in writing acceptance of one of the proposals. Failure to provide



any supplementary documentation to comply with the vendor's proposal may be

grounds for disqualification.

Form No, DPP-RFP-PS-68-75

Approved 5/7/75

Revised 3/18/08



J. CONTENTS OF PROPOSAL



The following is a list of information to be included in the written proposal.

Failure to comply with all the requirements as outlined, will disqualify the

applicant.



ie Introductory letter about the applicant:



a. Name, address, fax and telephone numbers.

b. Type of service for which individual/firm is qualified.



2 Organization:



Names/addresses of Principals of Finn.



Names of key personnel with experience of each and length of time in

organization.



c. Number of staff available for assignment. (Local & Off-Territory)



d. Copy of Articles of Incorporation

e

f



SP



Copy of Certificate of Resolution

Copy of valid Business License



3 Outside consultants that will be retained for this project and percentage of

work to be sub-contracted.



4. Project experience:

a. List of completed projects and estimated cost of each.

b. Current projects underway; scope; percentage completed to date and

estimated cost of each.

5, Project References: (including a notarized written consent from the

authorized representative which must include: name; telephone number;

email address and facsimile number).



6. Project Approach:



a. Describe how you will approach this project and availability to

perform the services requested.



fe Cost: The Cost Proposal must be submitted in a separate sealed envelope.

Form No. DPP-RFP-PS-68-75

Approved 5/7/75

Revised 3/18/08



K.



CONFLICT OF INTEREST



A proposer filing a proposal hereby certifies that no officer, agent or

employee of GVI has a pecuniary interest in this proposal or has participated in

contract negotiations on behalf of GVI; that the proposal is made in good faith

without fraud, collusion, or connection of any kind with any other Bidder for the

same request for proposals; the Bidder is competing solely in its own behalf

without connection with, or obligation to, any undisclosed person or firm.



LICENSE REQUIREMENT



An award will not be made to any firm or individual doing business in the Virgin

Islands to perform work with the Government of the Virgin Islands until evidence

is submitted that the said firm or individual has a valid V.I. Business License to

do business in the Virgin Islands. Bidders must submit hard copy of a valid V.I.

business license within ten (10) working days after award.



All Bidders bidding as Joint Ventures must be licensed as a Joint Venture in the

Virgin Islands.



REQUIRED DOCUMENTS



1. PUBLIC LIABILITY: The successful bidder will be required to obtain

and have in place public liability insurance and other insurance necessary

as requested in this proposal package. Insurance policy (ies) shall name

the Government of the Virgin Islands as "Additional Insured". The

public liability insurance shall have a minimum limit of not less than one

hundred thousand ($100,000.00) dollars for anyone occurrence for death

or personal injury and one hundred thousand ($100,000.00) dollars for

anyone occurrence for property damage. Bidder must provide public

liability insurance within ten (10) working days after award.



2. WORKERS' COMPENSATION: Within ten (10) working days after

award of project the successful bidder must submit a copy of their

certificate providing that his firm and his agents are covered by Workers’

Compensation Employee's Liability.



3. FAILURE TO PROVIDE THE CERTIFICATED WITHIN THE

STATED TIME PERIOD MAY RESULT IN THE PROPOSAL

DEEMED NON-RESPONSIVE AND MAY BE IMMIDIATELY

DISQUALIFIED WITH NO FURTHER CONSIDERATION GIVEN

FOR POTENTIAL AWARDING OF THE CONTRACT.

Form No. DPP-RFP-PS-68-75

Approved 5/7/75

Revised 3/18/08



N. REQUIREMENTS FOR CORPORATION

1. ARTICLES OF INCORPORATION

2. CERTIFICATE OF CORPORATE RESOLUTION

3. CERTIFICATE OF GOOD STANDING



THESE WILL BE REQUIRED PRIOR TO AWARD OF CONTRACT.

REQUEST FOR PROPOSAL



TO REMOVE STORAGE UST FROM VITRAN ST. THOMAS OPERATION AND

MAINTENANCE FACILITY



The location of this project 3016 Estate Contant St. Thomas, USVI. The site is a part of the St.

Thomas VITRAN Operations Maintenance and Facility.



Issue



The Department of Public Works (VITRAN) is in the process of upgrading its operations and

maintenance facility on St. Thomas. The Department is aware of multiple fuel tanks that

are buried on site. In order to finalize plans for upgrading the facility, the Department

must determine the appropriate method of handling buried fuel tanks at this facility. The

general area where the tanks are buried is known, however the exact location of all but one

of the tanks are to be determined. One tank has been located as the soil surrounding the

tank was unearthed. There are also no maps or any other written documents that

identify the exact locations of the tanks. The Department of Public Works is in need of

services to locate all tanks on the site and determine their conditions and contents. This

information will be used to determine whether the tanks must be removed or whether they



can remain buried as part of the Department's implements its plans to upgrade the

operations and maintenance facility.



Services Required



The Department's is seeking a qualified contactor to develop a plan to remove all UST buried on

the site. The Department of Public Works, Transport Division will establish aggressive timelines

to compete tasks outlined.



The general information and area where the UST are buried is as follows:



Location: Northern Side of the Property going east to west

Amount of Tank: Three (3) Round UST



Size: 6 x 26 ft.



Sample: Soil



This information will be used to determine whether the UST must be removed or whether they

can remain buried as part of the Department's plans to upgrade the operations and maintenance

facility.

Please, provide a cost estimate for the following items:



1



Prepare a work plan describing all work associated with removal and disposal of



three tanks for obtaining a removal permits through the Department of Planning and

Natural Resources (DPNR);



Cost of for the removal of three UST tanks consistent with the requirements of



the Department of Planning and Natural Resources Division of Environmental

Protection;



Process and obtain approval of the work plan and all permits and documents

required by DPNR for tanks removal;



Supervision of all onsite work through the final tank(s) disposal;



The cost for soil testing associated with developing a work plan and obtaining the

appropriate permits (s);



Scope of Work



A. Pursuant to Title 12, Section 910 (b) (2) of the Virgin Islands Code (VIC) contractor will



apply for a permit to close Underground Storage Tank (UST) from DPNR. The activities to

be performed at 3016 Estate Contant, St. Thomas, and USVI 00802. Construction

equipment and materials will be mobilized and stage in a designated area by

contractor. The equipment will be used for the breakage and removal of the slab, UST

and pipelines; extraction of product residues inside the UST; UST degassing, excavation

and UST removal and disposal.



Prepare a work plan describing all work associated with removal and disposal of up to

three UST for obtaining a removal permits through the Department of Planning and

Natural Resources (DPNR)



Develop a work plan for removal of the UST identified consistent with the requirements

of the Department of Planning and Natural Resources, Division of Environmental



Protection;



Process and obtain approval of the work plan and all permits and documents required by

DPNR for UST removal;

. Before field activities begin, pipelines containing product will be drained and UST

contents will be pumped out and disposed of by the contractor.



. Sludge and unusable product remaining in the UST will be pumped out to the maximum

extent using either a hand pump or an intrinsically-safe pump. The pump will be

connected to a suction hose, which will be extended to the bottom of the UST through

the fill pipe.



. Sludge removed from UST will be stored in suitable containers. This product will be

disposed in accordance with any applicable Federal or local regulations.



. The concrete or asphalt slab will be removed to expose the backfill covering the UST.

Debris generated during this activity must be screened with a Photoionization Detector

(PID) or aromatic hydrocarbon detector tubes. If aromatic hydrocarbons levels are lower

than 500 parts per million (ppm), the material will be transported to the Bovoni landfill. If

results are above this level, the material will be stored at site for treatment and future

evaluation. After removing the slab and uncovering the top of the UST, any associated

piping will be disconnected and drained.



Degassing will be conducted in accordance to Section 4 or the American Petroleum

Institute (API) Recommended Practice 1604, “Removal and Disposal of used

Underground Storage Tank (UST).” Before removing each UST, one access pipe at each

end of the UST will be exposed and opened. UST will be purged with air, steam or carbon

dioxide or nitrogen, from one of the ends, leaving open the other end side for exhaust.

The exhausted end will be monitored with an explosive meter until the Lower Explosion

Limit (LEL) is below 10%. Purging will continue until the LEL is reached. After completion

of the degassing process, UST openings will be plugged.



The backfill covering the UST will be excavated with a backhoe or any other adequate

equipment. Soil removed from the excavation will be monitored with a Photoionization

Detector (PID). Soil showing aromatic hydrocarbon concentrations lower than 500 ppm

will be transported to the Bovoni landfill. If excavated soil show volatile organic vapor

concentrations higher than 500 ppm, it will be stock piled on-site for treatment and

future evaluation.



. If free product is observed within the excavated pit, it will be pumped out to the



maximum extent using a pneumatic or intrinsically safe pump. Free product removed

from the excavation will be stored in suitable containers. This product will be disposed in

accordance with applicable federal and local regulations.



. Once removing each UST from the pit, it will be visually inspected by the environmental

technician at site. UST will not be left unattended until removed from the premises. The

excavation will then be backfilled with clean imported material and covered with a

concrete slab.



- Product lines will be removed after the UST removal activities are completed. Soil

samples will be collected, every 20 feet from the tank pit area to the dispensing area,

and at the bottom of the open trenches.



- Soil Samples to be collected from these trenches will be analyzed for the same

parameters proposed for the UST removal activities.



. The removed UST will be disposed in accordance with EPA’s UST regulations for closure,

and all applicable Federal and local regulations. Before disposal, UST will be re-tested for

LEL. UST will be labeled prior to removal from the site. The label will contain, at least, a

warning against reuse, former content, vapor concentrations at disposal and date of

removal. Contractor will submit a written notarized certification for each tank removed.

This certification should include the removal invoice stating that UST were scrapped.

DPNR will be notified by contractor of the final disposal/destination of the tank.



. As established by the Occupational Safety and Health Act (OSHA), the contractor will be

responsible for all safety measures during field activities.



- No person will be allowed to enter an excavation of more than four (4) feet deep, unless

adequate protective measures against collapse of the side walls are provided. For this

purpose the excavation walls may be inclined or protected by structural support or

bracing.



. If no slope protection is provided, samples from the bottom of the excavation may be

collected using a backhoe. Samples will be collected by the environmental technician

from the bucket and identified accordingly.



- Environmental Restoration Technology End User Conference (ERTEC) will monitor

activities related to the UST removal with a Photoionization Detector (PID). Tests



conducted in the field will be used to determine the method of disposal of the excavated

soil.

T. Before each excavation is backfilled, the environmental technician will collect two soil

samples from the bottom of each UST and one sample from each of the four sides of the

open pit. The actual number of samples to be taken from the UST pit will be determined

at the field based on the excavation size.



U. Soil samples collected from the excavation will be analyzed for benzene, toluene,

ethylbenzene and xylenes (BTEX) and for Total Petroleum Hydrocarbons (TPH) content in

the gasoline and diesel range following EPS’s Methods 8021 B and 8015 Modified

respectively. Analyses will be conducted by a Certified Lab.



V. A written report will be submitted to DPNR with a description of field activities, results of

all field tests (PID readings) laboratory chemical results performed on soil samples,

evaluation of data collected and recommendations, if any.



W. Contractor is responsible for supervision of all onsite work activities through the final

tank(s) disposal;



NOTE: One Underground Fuel Storage Tank (UST) has been unearthed and sits in an open

hole.



Credentials: Please, provide your credentials, license, certifications and information on any



prior experience you may have with the removal and disposal of UST, UST sites, and their

closure.

US Virgin Islands



May 25, 2016



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UNDERGROUND STORAGE TANK CLOSURE



GUIDANCE DOCUMENT



Bt



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GOVERNMENT OF THE VIRGIN ISLANDS OF THE UNITED STATES



DEPARTMENT OF PLANNING AND NATURAL RESOURCES



DIVISION OF ENVIRONMENTAL PROTECTION



EFFECTIVE DATE — August 19, 2015



wv ov AAW v— hr:



Norman Williams, Jr.



Director

UNDERGROUND STORAGE TANK CLOSURE GUIDANCE DOCUMENT



TABLE OF CONTENTS



SECTION 1 — GENERAL INFORMATION .............2:0c0cceccessseccsccessscesecscesaneesosscceasenseenenes 1



DD. VE UOIOM cava caraistd cscs ecu Spa Sep ip ORs ee ew eo Slant SOs wee ok bas need aay dethiccad a nphhnaceneceelocs al

ded TEMDOTary ClOSUNG: ...<.c.s<s2-cnoderitl ace ewe M cee ery ean fee ee ate udeed

1.3 POPMANENt CIOSUPE scum, Sigg hulle ahaa cet stairs eave hagas Faxes waers todd cout ccvaslvaivervuaviveemeacnee

1.3.1 Prior to PermanenitlyiGlosing a USI ccs press: civics connect). 2e--.cesereeccesvenesarconecseerscasevserneeneess 2

1.3.2 Permanent Closure Procedures and Qualified Personnel



L.A RECON: KO CDI E: ccc die eee te casucatgsnce tres deg Mune em nen Goa, Ne Lv rate akeenieRen TEED

SECTION 2 — REPORTING REQUIREMENTS .............::cccsccccssrecessstscessecsesenerecsneeseneneens 4



2.1 UST Registrations. 0c. -.cgi:.c eee Se eee ee Ce i Och oa uideieh arened taevawwebsaweevaees

2.2 Permit to Close Underground Storage Tank System oho. s.cteceicdalvcccascesccssesceocssesecstecesesenesieesseee

2.3 UST Closure Work:Plans......22..005.4225 5,



2.4 Thirty-Day NotificatiofivPrion tals ane mem eer mere Pe a akc aceedeeeneeencdenocanesueneesesancnnnereecess



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3.4 UST Disposal and UST Re-Use

UNDERGROUND STORAGE TANK CLOSURE GUIDANCE DOCUMENT



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UNDERGROUND ne TANK CLOSURE GUIDANCE DOCUMENT



LIST OF FIGURES AND TABLES



Figure 1-1:



Se ne ay



Potential migration pathways from a leaking UST



Figure 3-1:



UST Release Detection



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15



Figure 5-1:



Site cleanup options



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27



Table 4-1



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Sampling Requirements



20



Table 4-2



Analytical Requirements & Detection Limits



ee er er |



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Table 5-1



Hydrocarbon Fractions for TPH Mixtures



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Table 5-2



Soil Cleanup Standards



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23



LIST OF APPENDICES



Appendix A:



Tank Closure



Recommended Industry Codes and Standards for Underground Storage



Appendix B:



Application form for “PERMIT TO CLOSE UNDERGROUND STORAGE



TANK SYSTEM”



Appendix C:



UST Closure Checklist

UNDERGROUND STORAGE TANK CLOSURE GUIDANCE DOCUMENT



SECTION 1 - GENERAL INFORMATION



1.1 Introduction



The USVI Department of Planning and Natural Resources (DPNR) manages hazardous substance



underground storage tanks (UST) through a permitting system under Virgin Islands Code (VIC) Title

12, Chapter 16,§ 651 et seg.



The purpose of this document is to provide guidance for conducting a petroleum Underground Storage

Tank (UST) system closure that meets the requirements of DPNR. This document is intended to be

used in conjunction with the UST rules and regulations, and industry codes and standards. Appendix A

contains a list of industry codes and standards that pertain to UST closures.



Closing other hazardous substance UST systems will be addressed on a case-by-case basis.

Owners/operators should seek guidance for appropriate closure procedures by referring to the Code of

Federal Regulations, 40 C.F.R. §280.71-280.74. The regulations and additional Environmental

Protection Agency (EPA) guidance on UST closure may be obtained by calling the Agency's toll-free

RCRA/Superfund Hotline at (800) 424-9346.



An electronic copy of this UST Closure guidance document, and a copy of the VI UST

Rules and Regulations (12 V.I.R&R.) can be uploaded from

http:/ /dpnr.vi.gov/environmental-protection/underground-storage-tanks/



1.2 Temporary Closure



You may temporarily close your UST for up to 12 months by following these requirements for temporary

closure:



e Continue to monitor for leaks by maintaining the UST's release detection. If your UST is empty,

you do not need to maintain release detection. An UST is considered empty if no more than one

inch of residue is present or not more than 0.3 percent by weight of the total capacity of the

UST system remains in the system. Also, continue to monitor and maintain any corrosion

protection systems. If a release is discovered, quickly stop the release, immediately notify DPNR,

and take appropriate action to clean up the site.



e If the UST remains temporarily closed for more than 3 months, leave vent lines open, but cap

and secure all other lines, pumps, man-ways, and ancillary equipment.



After 12 months of temporary closure, you have three options:



1. You must permanently close your UST if it doesn't meet the applicable requirements for new or

upgraded USTs (except for spill and overfill).



2. You can ask DPNR for an extension beyond 12 months, if you provide an assessment that

determines whether contamination is present at your site.



Page 1 of 28

UNDERGROUND STORAGE TANK CLOSURE GUIDANCE DOCUMENT



3. Your UST can remain temporarily closed without needing an extension granted by DPNR if the



UST meets the applicable requirements for new or upgraded USTs (except for spill and overfill)

and the requirements noted above.



1.3 Permanent Closure



If you decide to close your UST permanently, there are two UST CLOSURE OPTIONS:

e Closure “in place” i.e. Abandonment in Place

© Closure by Removal from the Ground



Removal is recommended unless there are obstructions to access.



In both cases, the tank must be emptied and cleaned by removing all liquids, dangerous vapor levels,

and accumulated sludge. These potentially very hazardous actions need to be carried out carefully by

trained professionals who follow standard safety practices. If you leave the UST in the ground, have it

filled with a harmless, chemically inactive solid, like sand.-



1.3.1 Prior to Permanently Closing a UST



At least 45 days prior to closing a UST system, a “Permit to Close Underground Storage Tank System”

must be obtained from DPNR. A copy of the application form for a “Permit to Close Underground

Storage Tank System” is provided in Appendix B. The permit application form can also be found on the



DPNR website at http://www.dpnr.vi.gov. The permit fee is $500.00. A UST Closure work plan must

be submitted in support of the permit application.



Coordination should be made with local authorities prior to closing tanks in place. The VI Fire Services

must be contacted prior to performing closure of USTs. Other permits may be applicable such as (not

all inclusive):



e Coastal Zone Management Permit if site location is within the coasta! zone;



e An excavation permit for land excavation/ground-breaking activities;



e A demolition permit if other ancillary structures are removed.



1.3.2 Permanent Closure Procedures a ualified Personnel



In most cases, the DPNR recommends removal of the entire UST. It is recommended that in-place

closure should be reserved for situations in which a structure, such as the foundation of a building or

roadway, would be jeopardized by removal of the UST(s). If piping is to be closed in place, it should

be capped at the ends. For additional guidance on closure of UST’s, refer to 12 V.IL.R&R. §654-9 and

40 CFR Part 280.71



Because of the inherent dangers in handling tanks (explosive vapors and potentially hazardous

petroleum residuals), the DPNR recommends that only qualified and experienced personnel close

UST systems. Knowledge of and experience with DPNR and EPA sampling procedures, industry

standards, and OSHA regulations (29 CFR Part 1910 and Part 1926) are essential. Fatalities have

resulted from mistakes made during tank closures. In addition, improper handling of the material in

the UST’s and piping can result in releases that require costly cleanups.



Page 2 of 28

UNDERGROUND STORAGE TANK CLOSURE GUIDANCE DOCUMENT



It is the responsibility of the UST owner and/or operator to ensure that environmental sampling is

conducted and that a UST Closure Report is completed & submitted to the DPNR. Sampling should

be conducted as soon as possible; DPNR recommends within 48 hours of UST removal. The UST



Closure Report, along with all supporting documentation, should be submitted within 30 days of

receiving the laboratory data.



All closure notifications, site investigations, sample results, reports, etc. are to be

submitted to DPNR, Division of Environmental Protection, Underground Storage Tank

Program, 45 Mars Hill, Frederiksted, VI 00841.



1.4 Record keeping



You must maintain all records in accordance with 12 VIR&R §654-9(c) and 654-20 for at least 3 years

after completion of the permanent closure.



I 1 | |

Separate Dilution Anaerobic Aerobic

phase fuel biodegradation biodegradation



Figure 1-1: Potential migration pathways from a leaking petroleum UST



Page 3 of 28

UNDERGROUND STORAGE TANK CLOSURE GUIDANCE DOCUMENT

SECTION 2- REPORTING REQUIREMENTS



2.1 UST Registration



Prior to performing a UST closure, the UST owner must verify that the UST system has been registered

with DPNR. Tank registration information can be verified by contacting the DPNR UST Program at (340)

773-1082. Please be prepared to provide the facility’s name and address and UST owner’s name. If

the “Notification of Underground Storage Tanks” form (EPA Form 7530-1) has not been filed, then the



UST owner must submit the form to DPNR, prior to obtaining a “Permit to Close Underground Storage

Tank System”.



2.2 Permit to Close Underground Storage Tank System



A “Permit to Close Underground Storage Tank System” must obtained at least 45 days prior to UST

closure. The application form for a “Permit to Close Underground Storage Tank System” must be

completely filled out and submitted to DPNR (Appendix B). Once approved, a permit is issued by DPNR,

and UST closure may proceed after providing DPNR with a 30-day notification. The permit becomes

invalid if the closure is not initiated within one year after approval.



2.3 UST Closure Work Plan



Pursuant to 12 V.I.R&R. §654-9(c), a site assessment must be performed in accordance with a DPNR-

approved UST Closure work plan. The UST Closure work plan must be submitted for DPNR approval in

support of the application for a “Permit to Close Underground Storage Tank System” (see Section 2.2).

The UST Closure work plan must follow the format and address the required elements of the UST

Closure report described in Section 2.5.



2.4 Thirty-Day Notification Prior to Closure



Once a “Permit to Close Underground Storage Tank System” has been obtained, the UST owner must

notify DPNR by fax, email, or telephone 30 days prior to the scheduled date of the UST closure. A

representative designated by the UST owner or the closure contractor may make the notification for

the owner. Failure to notify DPNR at least 30 days prior to implementing the closure is a violation of

the “Permit to Close Underground Storage Tank System”. The purpose of the notification is for DPNR

to schedule inspections during closure-critical juncture activities at the site.



2.5 UST Closure Report



2.5.1 General



The goal of any closure assessment is to determine if a leak or release from the UST system has

occurred. This is done by measuring for potential releases from the UST system in locations at which



Page 4of 28

UNDERGROUND STORAGE TANK CLOSURE GUIDANCE DOCUMENT



releases would most likely occur. In addition, a proper assessment makes use of all readily available

and pertinent information for the site, including background information on leak detection.



The following elements should be included as part of the site assessment and be included in the UST

Closure report. :



(1) Background description of the site: location, use of facility, etc., and summary of leak detection

results where available. Include a detailed diagram of the site showing location of removed tank(s),



pump(s), lines, buildings, monitoring wells, locations of soil screening and sampling, and other pertinent

site features.



(2) Description of the closure actions to be taken, e.g. number, size, construction type and stored

material of USTs closed. Include a brief description of closure method including final disposition of the

tanks and any wastes generated by tank cleaning operations. Note that Copies of manifests generated

for the site should be included in the closure report.



(3) Description of the condition of each tank removed or closed. Including the extent of corrosion and

presence of holes in the tank or piping. Describe the conditions of piping/tank connections. This may

require that compacted soils be removed from the tank prior to a visual inspection. A photograph

documenting the condition of each removed UST is required.



(4) Description of the soil conditions in and surrounding the UST system excavation. Including soil

types, gradation (where applicable), extent of compaction and any other notable physical

characteristics. The soil classification system used to describe the soil must be stated in the closure

assessment.



(5) Description of soil conditions relative to contamination with petroleum products or hazardous

materials. The quality of the soils must be assessed by field or analytical sampling methods in several

locations throughout the excavation area. Field screening instruments such as the photo-ionization

detector (PID) or the flame ionization detector (FID) may be used at sites with USTs used to store

gasoline, diesel and #2 fuel oil. A standard operating procedure, documentation of calibration of field

equipment shall be made available to the DPNR upon request and must be included in the closure

report. All of the soil screening results from the sidewalls, tank bottom, lines, pump island and fill pipe

are to be recorded and tabulated in the closure report. When a release is observed during the tank

closure, the DPNR must be notified.



(6) Description of the presence of groundwater at the site, including the distance between the tank

bottom and the groundwater table. Depth to the water table shall be noted where encountered. Also

describe the quality of groundwater based on visual and field screening observation methods and,

where appropriate, laboratory analysis of water samples. The presence of any sheen or amount of free

product shall be noted. During excavation an attempt to reach the groundwater table shall be made.

The reach of the backhoe is considered the acceptable limit of this excavation effort. If groundwater

monitoring wells are present, they should be gauged for the depth to groundwater and for the presence

of free product.



Page 5 of 28

UNDERGROUND STORAGE TANK CLOSURE GUIDANCE DOCUMENT



(7) All soil and water samples should be collected and handled according to proper chain of custody

requirements and accepted sampling protocols. With the report, documentation of chain of custody and

adherence to appropriate quality control and quality assurance measures shail be provided. Samples

must be analyzed at laboratories approved by the DPNR or via reciprocity if located out of state.



(8) For sites located in the wellhead protection areas of community wells and non-transient non-



community wells, as designated by DPNR, samples of the groundwater at the site are mandatory, unless

the requirement is waived in writing by DPNR.



(9) Include identification of the groundwater use for the site/ surrounding area and characterize the

use of groundwater resources in the site vicinity; e.g. private wells are in use nearby. The groundwater

use shall be considered by DPNR in decisions regarding the extent of soil removal and/or other remedial

efforts to be undertaken at the site.



(10) If contamination is identified on the site, note any other receptors, e.g. private wells, surface

waters, storm drains, basements, which may be affected. Receptors should be evaluated to the extent

feasible for indications of a release...



(11) The closure report must include a finding as to whether or not a release has or is likely to have

occurred and caused contamination of the environment. It is the responsibility of the professional

writing the report to clearly make this conclusion. Information such as depth to groundwater, soil type,

soil screening and laboratory analytical results, etc. should be used in making this conclusion.

Laboratory analytical results of any soil samples taken during the tank closure may be compared to the

USVI Target Cleanup Levels. When the results of the closure assessment indicate that soil and/or

groundwater has or likely has been impacted by a release, a site investigation should be recommended.



It is not necessary in the closure report to characterize the full extent of any significant

contamination found during the closure process since such sites will be expected to

conduct a full site assessment/ investigation. The closure assessment shall include



recommendations for further action, where necessary. If no further action is required, it



must be clearly stated in the report.



A completed Closure Report must be submitted to DPNR within 60 days following

permanent closure. Consistency in reporting will expedite DPNR’s review and response to

the UST owner. An electronic copy as well as two separate hard copies of the Closure

Report must be submitted in a format no larger than 8 /2”x14”".



Closure Reports that do not contain all of the required information will be rejected and

returned to the UST owner for corrections or completion

2.5.2 Site Drawing



A site drawing, drawn to scale, must include the following information:

1. General site layout.

2. Tank locations, sizes, and the substance(s) stored.

3. Location/distribution of pipings.



Page 6 of 28

UNDERGROUND STORAGE TANK CLOSURE GUIDANCE DOCUMENT



. Dispenser locations.



. Depth to groundwater (if encountered).



. Dimensions of the excavation (when excavation occurs).



. North arrow.



. Near-by structures such as buildings, landmarks, streets, etc.



. Sample locations; Identifiers must be placed on the map for each sample location, and

those identifiers must match the analytical table provided for all samples.



won nuns



Note: Sample identification on the drawing must match the label on each sample container and chain-

of-custody record.



2.5.3 Laboratory Analvtical



A Laboratory Analytical Results Table must be included with all Closure Reports. The Laboratory

Analytical Results Table must include a sample number, the date collected, the constituents analyzed,

the sample depth, the concentration of each constituent analyzed in mg/kg (for soils) and mg/L (for

groundwater) units. Detected concentrations of constituents exceeding applicable soil target cleanup

levels and groundwater MCLs must be highlighted.



A copy of the final laboratory analytical report, including all sample results, QA/QC data and the chain-

of-custody record, must be included in the Closure Report.



2.5.5 Manifesis



A copy of all manifests, bills of lading or receipts for the disposition of the tank(s), tank contents, sludge

and contaminated soil and/or fluids must be included in the Closure Report



2.6 Reporting Evidence of a Release



All owners, operators, employees, agents, contractors, or assigns having knowledge that evidence

exists indicating a release from a UST system must report the contamination to the DPNR within 24

hours of discovery as per 12 V.I.R&R. §654-17(b). For UST closures, the UST owner or UST closure

contractor must call DPNR within 24 hours of discovery in order to discuss all options that are available

to close the site.



If any of the constituents analyzed exceeds the soil and water cleanup levels listed in 12 V.I. R&R.

§654-34: Target Cleanup Levels or if free-phase product is discovered during the closure, the UST

owner or UST closure contractor must notify the DPNR.



In cases where a release results in an emergency condition, the release must be reported to DPNR

immediately, but in no case later than one hour, regardless of the amount released. For clarity,

“emergency condition” is defined as “any condition which could reasonably be expected to endanger

the health and safety of the public, cause significant adverse impact to the land, water or air

environment, or cause severe damage to property”.



Page 7 of 28

UNDERGROUND STORAGE TANK CLOSURE GUIDANCE DOCUMENT



SECTION 3 - GENERAL CLOSURE GUIDELINES



3.1 General Information



Proper work practices will keep contractors, employees, passers-by, and the environment safe. This

section should be used for informational purposes only, as it does not contain all of the rules or

reference documents required by DPNR regulations. A list of industry codes and standards that are



referenced in the UST regulations relating to closing USTs can be found in Appendix A. The DPNR UST

Closure Checklist is provided in Appendix C.



3.1.1 Si et



All personnel working in the UST closure area should be familiar with the potential hazards and be

aware of the appropriate health and safety measures needed to ensure a safe working environment.

Employees must be advised of the chemical, physical, and toxicological properties of each substance

that is known or expected to be present in the UST. Due to the nature of the flammable or combustible

liquids stored in the UST, hazardous conditions should be expected to exist in the UST closure area.



Some recommended site safety practices are:



e Keep the UST closure area free of all sources of ignition. Confirm that all electrical service going

to, under, or through the UST closure area is disconnected.



e Plan a safe working area by providing sufficient space for workers and equipment. Erect and

maintain brightly colored barricades around the work space. The American Petroleum Institute

(API) recommends placing barricades 50 feet in all directions from the edge of the excavation

where possible. Consider traffic flow when barricading your work space. Since many locations

are open for business during UST closures, arrange barricades to direct traffic away from the

work space.



e Make sure anyone entering the work space is wearing a brightly colored safety vest and is

wearing OSHA Level D personal protective equipment.



e A site-specific Health and Safety Plan (HASP) should be prepared and kept on-site to address

potential safety and health hazards encountered in the work space. The HASP should include

emergency telephone numbers and locations of the nearest medical facilities. The HASP should

designate a site safety and health supervisor who has the authority to stop the project should

worker health or safety become jeopardized. The HASP should be reviewed with the workers

prior to any site activities and should be evaluated and updated as changing conditions warrant.



.1.2 Sloping or Shoring the Excavation



The UST closure should be conducted so that no one has to enter the excavation. Entry into an

excavation is not only dangerous; it is also considered confined space entry. OSHA requires specific



Page 8 of 28

UNDERGROUND STORAGE TANK CLOSURE GUIDANCE DOCUMENT



training for employees who must work in a confined space situation. A confined space is a space with

limited ventilation, potential to accumulate or contain a hazardous atmosphere, exits that are not readily

accessible, and not meant for continuous human occupancy. This includes excavations and trenches. If

workers must occasionally enter an excavation, they should be properly trained in OSHA regulations for



confined space entry and self-rescue. Compliance with all OSHA regulations for confined space entry

and activities is required.



If workers are going to be working within the excavation, then sloping or shoring the excavation is

required by OSHA. The OSHA Standard 29 CFR 1926.650-652 requires that employees in an excavation

be protected from cave-ins.



There are four sloping options available:



1. Slope the excavation at an angle no steeper than 1¥2 feet horizontal to 1 foot vertical —

expressed 12:1 (29 CFR 1926.650-652, Subpart P, Appendix B).



2. Slope the excavation in accordance with the OSHA simplified soil classification system, which

ranks soils according to their stability (29 CFR 1926.650-652, Subpart P, Appendices A and B).



3. Use a design created and sealed by a VI registered professional engineer.

4. Use a site-specific design sealed by a VI registered professional engineer.

An excavation that will be entered can be sloped 12:1, if it meets these criteria:



e the excavation is in Type A soil (the most stable soil type and is composed of cohesive clay, silty



clay, clay loam, and sandy clay with an unconfined compressive strength of 1.5 tons per square

foot or greater);



e the excavation will not be open more than 24 hours; and

e The excavation is no deeper than 20 feet.



Even in stable soils, however, if the excavation will be open longer than 24 hours, the sides must be

sloped at least 34:1.



Refer to the OSHA standard on excavation (29 CFR 1926, Subpart P) for more detailed guidance on

sloping and shoring requirements.



3.1.3 P ing or Inerting the UST



All underground storage tanks must be emptied, cleaned, and purged or inerted prior to removing the

tank from the excavation. Caution must always be exercised when handling or working around USTs

that have stored flammable or combustible liquids.



Purging is the removal of flammable vapors from a tank. Inerting is the removal or displacement of

oxygen from a tank. Both purging and inerting cause flammable vapors to be expelled from the tank.



Page 9 of 28

UNDERGROUND STORAGE TANK CLOSURE GUIDANCE DOCUMENT



Whether purging or inerting a UST, these recommended safety practices should be followed:



Immediately before beginning work in the UST area or on the UST, check for vapor

concentrations with a combustible gas indicator (CGI).



Keep the UST closure area free of all sources of ignition. Vent all vapors at least 12 feet above

grade and 3 feet above any adjacent roof lines.



Dry ice (carbon dioxide [CO2] in solid form) can be used to inert a UST. API recommends adding

a minimum of 11 to 2 pounds of dry ice per 100 gallons of tank capacity. The dry ice should



be shaved or crushed and must be distributed evenly over the greatest possible area of the

tank.



Never enter a tank that has been inerted with CO2 or nitrogen (N2) as both of these methods

will displace the oxygen inside the tank. If a tank has been inerted, a CGI will be misleading.

Most CGI's require 10% by volume of oxygen to operate properly. Use an oxygen indicator to

assess a tank that has been inerted. Be extremely careful when using an inert gas to displace



the oxygen inside a tank. Inerting can affect the work space by displacing the oxygen outside

the tank also.



When inerting, the only way to know that a tank is safe for removal is to verify with an oxygen

meter that the oxygen level in the tank is below 5%.



Never use exhaust gas from an internal combustion engine to inert a tank.

Ground all equipment and use low air or gas pressures to prevent a buildup of static electricity.

Never discharge a CO2 fire extinguisher into tanks containing a flammable vapor and air mixture.



Never let the pressure inside a tank exceed 5 pounds per square inch gauge (psig) when

introducing compressed air or gases.



Fiammable vapors can regenerate inside a UST even after purging or inerting. Check often for

vapor concentrations with a CGI.



For more specific information of purging or inerting a UST, refer to API Publication 1604 and NFPA

Publication 30.



3.1.4 Testing Equipment



The tank atmosphere and the excavation area must be tested regularly for flammable or combustible

vapor concentrations until the tank is removed from the site.



A properly calibrated combustible gas indicator (CGI) or explosion meter must be used.



Page 10 of 28

UNDERGROUND STORAGE TANK CLOSURE GUIDANCE DOCUMENT



e The person doing the testing must be completely familiar with the instrument and what the

readings represent.



e Always test the environment for oxygen content first to be sure you can rely on the instrument.

CGI's are inaccurate if a tank atmosphere contains less than 10% oxygen, as would happen if

you inert a tank.



e If a tank is inerted, use an oxygen indicator to determine the oxygen concentration. Readings

that show a tank to be oxygen-deficient should be safe. A fire needs air with at least 11%

oxygen to burn.



e Do not take readings through a drop tube.



e Take readings at each end and in the middle of the tank and at a minimum of three levels in

the tank: the bottom, center, and top.



e Readings of less than 10% of the lower explosive limit (LEL) must be obtained before a tank is

safe to remove from the ground.



3.2 Accredited Laboratories



All closure samples must be submitted to an accredited laboratory for analysis. Documentation must be

provided to show that the laboratory is certified in the Virgin Islands or via reciprocity. Laboratory must

be able to conduct analyses for the applicable parameters listed in the closure work plan as specified

by EPA SW-846 protocol for the appropriate analytical method.



ATTACH ALL ORIGINAL LABORATORY DATA, INCLUDING THE QUALITY CONTROL (QC)

INFORMATION AND CHAIN OF CUSTODY, TO THE UST CLOSURE REPORT. ONLY AN

ACCREDITED LABORATORY SHOULD ANALYZYE ENVIRONMENTAL SAMPLES. THE

LABORATORY SHOULD USE EPA SW-846 SPECIFIED METHODS.



3.3 UST System Removal and Labeling



Unless permanently closing a UST system in place, all tanks and piping must be removed from the

ground. Ensure that all residues remaining in the tanks and piping are removed and prevented from

reaching the soil. Tanks and piping must be emptied and purged or inerted prior to removing from the

ground. Plug any openings in the tank, leaving a 1/8 inch hole to prevent over-pressuring due to

temperature changes.



Tanks must be labeled prior to removing from the site. API recommends the following information:

e TANK HAS CONTAINED LEADED GASOLINE (use applicable designation, i.e., GASOLINE,



LEADED GASOLINE, DIESEL, USED OIL)

e NOT VAPOR-FREE



Page 11 of 28

UNDERGROUND STORAGE TANK CLOSURE GUIDANCE DOCUMENT



e NOT SUITABLE FOR STORAGE OF FOOD OR LIQUIDS INTENDED FOR HUMAN OR ANIMAL

CONSUMPTION



e DATE OF REMOVAL: MONTH/DAY/YEAR



Tanks that have held leaded gasoline, or if the history is unknown, should also be clearly labeled with

the following information:



e TANK HAS CONTAINED LEADED GASOLINE

e LEAD VAPORS MAY BE RELEASED IF HEAT IS APPLIED TO THE TANK SHELL



Tanks should be cut up, crushed, or removed from site as soon as possible. Always retest the tank to

ensure that the LEL level is below 10% or the oxygen level is below 5% before the tank leaves the site.

Be sure the tank is properly secured before transporting.



3.4 UST Disposal and UST Re-Use



Although the VI UST Rules and regulations do not disallow re-use of UST’s, DPNR discourages this

practice. All used tanks to be reinstalled, are subject to VI and federal requirements for new UST

systems. Prior to re-use, all used tanks must be recertified by the manufacturer, a manufacturer's

representative, or VI registered Professional Engineer.



Tanks must be properly disposed in accordance with all applicable federal, state, and local regulations

when they are no longer suitable for storing flammable or combustible liquids. Approval from the VI

Fire Marshal and DPNR should be obtained prior to re-using tanks as aboveground storage tanks.



Either a proof of disposal or a bill of sale when transferring ownership is required in the UST Closure

Report.



3.5 Closing UST Systems in Place



Underground storage tanks should only be closed in place whenever removal wouid potentially damage

adjacent equipment or structures or may be physically impossible. Another factor to consider is whether

or not excavation is required in order to remediate contamination from the site.



Tanks must be emptied and cleaned prior to closing in place. All product, liquids, and accumulated

sludge must be removed from the tank(s) and must be properly recycled or disposed. Once the tank

has been determined vapor free, filling the tank with a solid inert material through openings in the top

of the tank can begin. It is important to fill the tank completely with a solid inert material, such as

concrete or sand. After the tank is filled with solid inert material, all tank openings must be covered,

plugged, or capped. If excavation was required around the tank to locate tank openings, then the

excavation should be backfilled. Disconnect and remove the vent line(s) if accessible. If the vent lines

are not accessible, remove the portion above the surface and cap both ends.



When closing UST systems in place, the product piping must be rendered unusable. Piping can be



rendered unusable by removing as much piping as possibie or filling as much of the piping as possible

with a solid inert material. Any accessible piping should be capped.



Page 12 of 28

UNDERGROUND STORAGE TANK CLOSURE GUIDANCE DOCUMENT



If laboratory analytical results indicate that further corrective action is warranted, the UST owner,

property owner, UST closure contractor, and DPNR staff should discuss all available remediation and

closure options prior to closing in place.



3.6 Sample Collection Procedures



Gener equi ents



Sample handling should not result in cross-contamination or loss of contaminants. Since gasoline and

some other petroleum products consist largely of volatile organic compounds, special care in the sample

collection is required due to the high potential for loss of these volatile compounds from the sample.

EPA SW-846 Method 5035 must be followed when collecting samples for volatile analysis.



All samples must be collected in the container specified by EPA SW-846 protocol for the appropriate

analytical method. Care should be exercised to ensure that the samples are received by the laboratory

within the recommended holding times.



Written documentation in the form of a chain-of-custody record must accompany all samples from the

time of collection to the time of delivery to the lab. The possession or custody of samples must be

traceable from the time of collection until the time the sample is submitted to the laboratory for analysis.

The sample containers must be either secured to prevent tampering and placed ina designated, secured

area or kept in the actual physical possession of the sampler.



If chain-of-custody procedures are not followed, the integrity of the samples is compromised and the

analysis is considered invalid.



3.6.2 Quality Assurance Project Plan



The Quality Assurance Project Plan (QAPP) must be submitted as an attachment to the Closure

Workplan. At a minimum, the QAPP must address the following:



Follow the format and include elements of EPA QA/R-5.



Signatures of all key individuals involved in the project



Organizational chart as it relates to the decision making process.



List all the individuals involved in the project along with their duties.



Documents lab’s certification and ability to analyze applicable parameters; and analytical

method detection limits.



Describe how the field instruments (CGI, PID, FID, etc) will be maintained and calibrated.

Describe the dimension for the sample area, the number of samples to be taken, and

the holding time and preservation techniques used for each contaminant.



° Describe the type of observations that will be recorded in notebooks.



° Describe the process and identify the person responsible for validating all data.



® @ @® @ @



Page 13 of 28

UNDERGROUND STORAGE TANK CLOSURE GUIDANCE DOCUMENT



3.6.3 Sample Labeling



The sampler must label the sample container with a sample tag (usually an adhesive label) using

waterproof ink at the time of sample collection. The sample tag must include the following information:



1. Sampie identification



2. Collection date and time

3. Analysis required



4. Sampler’s initials



Note: The sample identification on the site drawing must match the label on the sample container.



-6.4 Chain-of-Cu R



A chain-of-custody record must be compieted for all samples that will be analyzed by the laboratory.

This record must be filled out in the field at the time of sampling. The chain-of-custocy must accompany

the samples as they are transferred to the laboratory. Upon transfer of the samples, each person

handling the samples must sign, date, and note on the record the time they received the samples.



Each chain-of-custody record must include:



. Sample identification



. Name and address of the site



. Date and time of sample collection



. Location of each sample



. Number of samples



. Analysis to be performed



. Comments or remarks section (e.g., field conditions)



- Appropriate places for signatures of sampler and person(s) assuming custody of sample and

the identification of common carriers



Oona fb WN ee



Completed chain-of-custody records must be submitted for all samples and included with the UST

Closure report.



3.7 Contaminated Soil Disposal



Contaminated soil generated during UST closure activities must be managed properly. Contaminated

soil may be either re-used either on-site or off-site; or properly disposed.



Contaminated soil that is disposed is subject to solid and hazardous waste regulations. Non-hazardous

contaminated soil may be disposed at solid waste disposal facilities permitted to receive industrial solid

waste.



Contaminated soil that has been determined to be hazardous must be disposed at a hazardous waste

disposal facility. Contact the appropriate disposal facility to determine the applicable waste profile

requirements. For information about hazardous waste accumulation time, transporters, disposal, and

disposal facilities, contact DPNR at (340) 774-3320 for St. Thomas/St. John district, or (340) 773-1062

for St. Croix district.



Page 14 of 28

UNDERGROUND STORAGE TANK CLOSURE GUIDANCE DOCUMENT



3.8 Contaminated Water Disposal



Contaminated water may be generated during tank cleaning activities and during tank hold de-watering



activities. Contaminated water generated during any UST closure activity must be managed properly.

Contaminated water may be



a. discharged if a water discharge permit is obtained or

b. properly disposed at a permitted waste disposal facilities.



3.8.1 Wi ischar



A permit from DPNR Water Pollution Control Program must be obtained prior to discharging ground or

surface waters which have accumulated in the tank hold. For information regarding water permits,

contact the TPDES Permit Section of DPNR at (340) 774-3320 for St. Thomas/St. John district, or (340)

773-1062 for St. Croix district.



8.2 [ d Water Di. at permi ilities



Tank wash water generated during tank cleaning operations or water that accumulates in a tank hold

is subject to solid and hazardous waste regulations.



Non-hazardous contaminated water may be disposed at solid waste disposal facilities permitted to

receive industrial solid waste. Contaminated water that has been determined to be hazardous must be

disposed at a hazardous waste disposal facility. Contact the appropriate disposal facility to determine

the applicable waste profile requirements. For information about hazardous waste accumulation time,

transporters, disposal, and disposal facilities, contact DPNR at (340) 774-3320 for St. Thomas/St. John

district, or (340) 773-1062 for St. Croix district.



Underground Storage Tank Release Detection



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Page 15 of 28

UNDERGROUND STORAGE TANK CLOSURE GUIDANCE DOCUMENT



SECTION 4- CLOSURE SAMPLE LOCATIONS



4.1 General Requirements



For all tanks removed from the ground, soil samples should be collected from native soil beneath the

tank bottom, and at least one of the samples should be collected beneath the fill port end. If bedrock



is encountered during excavation activities, collect the appropriate number of samples just above

bedrock (at the soil/bedrock interface).



For tanks closed in place, a minimum of two soil samples are required (one at each end); samples are

to be collected as close to the tank as possible. For tanks closed in-place that are greater than 10,000



gallons, one additional sample (collected adjacent to and beneath the middle of the tank) is required

for every 10,000 gallons greater than 10,000 gallons.



If groundwater is encountered in the excavation, a groundwater sample MUST be collected. In general,

one groundwater sample can be collected from beneath a single tank pit. However, if the tank pit is

very large and one groundwater sample will not adequately characterize the groundwater conditions

beneath the tank pit, then two groundwater samples may be necessary. Groundwater samples should

be collected beneath the most contaminated soils.



4.2 Required Number of Soil Samples



Table 4-1 lists the required number of soil samples. If groundwater is encountered, then only one soil

sample is required beneath each tank. Additional soi! sampling is required if initial soil samples contain

detectable concentrations of BTEX, PAH’s, and/or TPH-GRO/DRO. Sampling must continue at depth



(referred to as vertical delineation) until BTEX and PAH’s are below detection limit and TPH-GRO/DRO

is below 460 mg/kg.



If the dispensers are not located over the tanks, then piping and dispenser samples will be necessary.

One soil sample is required for every 10 feet of closed piping, and one soil sample is required for every

10 feet of contiguous dispenser island. Samples should be collected from native soi! and at worst-case

locations (joints, elbows, fittings, visible contamination, etc.).



4.3 Target Constituents & Analytical Methods



Table 4-2 lists the Analytical Requirements & Detection Limits. For tanks, piping and/or dispenser

island associated with gasoline, soil samples should be analyzed for BTEX (using EPA Method 5035-

8021B or 5035-8260B) and TPH-GRO (using EPA Method 8015B-GRO). Groundwater samples should

only be analyzed for BTEX (using EPA Method 5030-8021B or 5030-8260B).



For tanks, piping and/or dispenser island associated with substances other than gasoline or if there is

uncertainty as to what the tanks historically stored, soil samples should be analyzed for BTEX, PAH’s

(using EPA Method 8270C or 8310), TPH-GRO, and TPH-DRO (using EPA Method 8015B-DRO).

Groundwater samples must be analyzed for BTEX and PAH’s (using EPA Method 8270C).



Page 16 of 28

UNDERGROUND STORAGE TANK CLOSURE GUIDANCE DOCUMENT



In the rare case that the tanks/piping/dispensers contained a substance other than a type of petroleum,

the owner must define those target constituents and detection limits that would best determine if a

release from the piping/dispensers impacted the soil and/or groundwater.



Please note that method 8260B is preferred over method 8021B when analyzing samples for BTEX, and

method 8270C is preferred over method 8310 when analyzing samples for PAH’s. Using method 8021B

and/or 8310 may result in the misidentification of compounds or matrix interference.



ATTACH ALL ORIGINAL LABORATORY DATA, INCLUDING THE QUALITY CONTROL (QC) INFORMATION

AND CHAIN OF CUSTODY, TO THE UST CLOSURE REPORT. ONLY AN ACCREDITED LABORATORY

SHOULD ANALYZYE ENVIRONMENTAL SAMPLES. THE LABORATORY SHOULD USE EPA SW-846

SPECIFIED METHODS.



4.4 Soil Vertical Delineation Sampling



4.4.1 Tank Sampling



If any of the initial soil samples collected beneath a tank have detectable concentrations of BTEX, PAH’s,

or TPH-GRO/DRO, then sampling must continue vertically (at depth) until BTEX and PAH’s are below

detection limit and TPH-GRO/DRO is less than 460 mg/kg. When collecting delineation samples, it is

not necessary to analyze for a constituent that was below detection limit in the initial soil sample(s). If

PAH’s were detected in the initial soil samples, but there is no applicable soil threshold for the PAH’s

detected, then delineation samples do not have to be analyzed for PAH’s.



If groundwater is encountered before soil contamination can be delineated to below detection limits,

then a groundwater sample must be collected. In lieu of collecting multiple soil samples for vertical

delineation, a groundwater sample may be collected. In most cases, the collection of one groundwater

sample beneath the tank pit eliminates the need for vertical delineation of soil contamination at all

sampling locations within the tank pit. For example, if vertical delineation is required at three soil

sampling locations within the tank pit, then only one groundwater sample would need to be collected

(instead of 3 or more soil samples) in order to satisfy the requirements for vertical delineation of soil

contamination. However, for a very large tank pit, two groundwater samples may be needed to

adequately characterize groundwater conditions beneath the tank pit.



If bedrock is encountered when removing the tanks and the initial soil samples collected at the

bedrock/soil interface have contamination above appropriate detection limits, a boring/monitoring well

will need to be installed into bedrock. If groundwater is not encountered within 24 hours after drilling

twenty (20) feet into bedrock, drilling may be stopped and the boring may be abandoned. The soil

contamination is considered vertically delineated and no additional sampling is required. However, if

groundwater is encountered within the first twenty (20) feet, it will be necessary to install a monitoring

well and collect a groundwater sample.



4.4.2. Required Tank Sampling W tion is Not Available (System Previously Closed



If the tank pit locations can be identified, then collect one soil sample and one groundwater sample

from beneath each tank pit. If it is unclear where the tank pit(s) were located, then use all available



Page 17 of 28

UNDERGROUND STORAGE TANK CLOSURE GUIDANCE DOCUMENT



resources to best determine where the tanks may have been located and collect the samples at the



down gradient edge of each suspected tank pit. Soil samples should be collected above the water table

and at the depth where PID/FID readings were the highest.



4.3 Pipi Di er Island Sa ]



If any of the initial soil samples collected beneath the piping and/or dispensers have detectable

concentrations of BTEX, PAH’s, or TPH-GRO/DRO, then sampling must continue vertically (at depth)

until BTEX and PAH’s are below detection limit and TPH-GRO/DRO is less than 450 mg/kg. When

collecting delineation samples, it is not necessary to analyze for a constituent that was below detection

limit in the initial soil sample(s). If PAH’s were detected in the initial soil samples, but there is no



applicable soil threshold for the PAH’s detected, then delineation samples do not have to be analyzed

for PAH’s,



In lieu of collecting multiple soil samples for vertical delineation, a groundwater sample may be collected

at each location requiring vertical delineation. If any two sampling locations requiring vertical

delineation are less than 10 feet apart, then the collection of one groundwater sample will suffice for

the vertical delineation of soil contamination at both locations.



If the UST system was previously removed but locations of the former dispenser islands can be

determined, then collect one soil sample and one groundwater sample beneath each former dispenser

island. If it is unclear where the former dispenser islands were located, then use all available resources

to determine where they may have been located and collect one soil sample and one groundwater

sample at the down gradient side of each suspected island. Soil samples should be collected above the

water table and at the depth where PID/FID readings were the highest.



4.5 Stockpile Sampling



One soil sample is required for every 100 cubic yards of stockpiled soil generated during closure

activities. Samples should be analyzed for the same constituents as the tank, piping, and dispenser

samples. The DPNR does not recommend stockpiling soils on-site for more than 90 days, and stockpiled

soil should be placed in drums or wrapped in plastic sheeting.



Stockpiled soil can only be placed back into the excavation if one of the following criteria is met:



a. The analytical results of samples from the stockpiled soil are less than the applicable Soil

Target Cleanup Levels and TPH-GRO or DRO is less than 460 mg/kg, and no visible free

product is present in the soil.



b. The analytical results of samples from the stockpiled soil exceed applicable Threshold Levels,



but a Soil Pile Management Plan is approved by DPNR that will address in-situ remediation

of the contaminated soil.



Page 18 of 28

UNDERGROUND STORAGE TANK CLOSURE GUIDANCE DOCUMENT



c. Groundwater contamination has been identified above regulatory standards, and the

Remedial Action Work Plan is approved by DPNR to address the in-situ remediation of the

contaminated soil and groundwater.



A copy of all manifests for the disposition of the contaminated soil must be included in the Closure

Report.



4.6 Over-excavation Sampling



Over-excavation is defined as any soil excavation beyond three (3) feet from the outermost sides and

ends of any UST, beyond one (1) foot from the bottom of the deepest UST, or beyond one (1) foot

from the piping or dispensers. If more than one UST is present in the pit, and the UST’s are laid side-

by-side, measurement will extend from the sides of the outermost UST’s and the ends of the UST’s. If

the UST’s are laid end-to-end, measurement will extend from the ends of the outermost UST’s and the

sides of the UST’s. If over-excavation is performed in order to remove contaminated soil, then the

following confirmatory samples must be collected in addition to the required tank, piping, and dispenser

sampling discussed in Section 4.2 above:



a. one soil sample every 10 linear feet along the base of the sides (within 1 foot of the

bottom of the excavation),



b. one soil sample per 100 square feet along the bottom of the excavation,



C. one soil sample per 100 cubic yards of stockpiled soil (see “Stockpile Sampling” above).



4.7 Groundwater Sampling



If groundwater is encountered in the excavation, a groundwater sample MUST be collected. In general,

one groundwater sample can be collected from beneath a single tank pit. However, if the tank pit is

very large and one groundwater sample will not adequately characterize the groundwater conditions

beneath the tank pit, then two groundwater samples may be necessary. Groundwater samples should

be collected beneath the most contaminated soils. Please refer to Table 4-1, Sampling Requirements

and Table 4-2, Analytical Requirements & Detection Limits for additional information.



Page 19 of 28

UNDERGROUND STORAGE TANK CLOSURE GUIDANCE DOCUMENT



Table 4-1: Sampling Requirements



Tanks Piping Dispensers

Minimum Number of | If piping is

Capacity (gallons) Soil Samples not located

Required* directly If the dispenser

<1,000 i (2 if tank was closed | above the islands are not

: in place) tanks, then | located directly above

1 soil tanks, then 1 sample

1,000-10/000 ‘ sample is is required for every

| 2 +1 additional sample | required for | 10 feet of contiguous

> 10.000 for every 10,000 every 10 dispenser island**

, gallons greater than feet of

12,501 piping**



NOTES:



*If groundwater is encountered, then only one soi! sample is required beneath each tank. Additional

soil sampling is required if initial soil samples contain detectable concentrations of BTEX, PAH’s, and/or

TPH-GRO/DRO. Sampling must continue at depth (referred to as vertical delineation) until BTEX and

PAH’s are below detection limit and TPH-GRO/DRO is below 460 mg/kg.



**This may not apply if only closing piping and/or dispensers above an active tank system



Page 20 of 28

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UNDERGROUND STORAGE TANK CLOSURE GUIDANCE DOCUMENT



SECTION 5 - SAMPLE RESULTS INTERPRETATION



5.1 General Information



If any of the constituents analyzed exceeds the soil and water cleanup levels listed in 12 V.I.

R&R. 8654-34: Target Cleanup Levels or if free-phase product is discovered during the closure,

the UST owner or UST closure contractor must immediately notify the DPNR.



If any of the COCs exceed the USVI standards and/or EPA RSL, further evaluation is required.

Further evaluation can consist of additional analysis (TPH fraction, etc.), limitecl excavation or

placing institutional controls on the property.



5.2 Total Petroleum Hydrocarbon Fraction Analysis



If the Total Petroleum Hydrocarbon (TPH) mixture (TPH-GRO, TPH-DRO, and/or TPH-ORO)

concentration exceeds the soil standard, then analyzing for TPH fractions is required. TPH fraction

analysis is only required on the sample that exhibits the highest specific TPH mixture

concentration. The analytical methods suggested for the identification of the designated

hydrocarbon fractions include the Massachusetts Department of Environmental Protection’s

VPH/EPH (volatile petroleum hydrocarbons/extractable petroleum hydrocarbon) Method and the

Texas Commission on Environmental Quality Method 1006. When requesting these analyses, the

data user must specify that the carbon ranges to be reported as shown in Table 5-1, and that the

results be reported on a "wet-weight" basis.



Table 5-1: Hydrocarbon Fractions for TPH Mixtures



TPH-GRO C.,-Cs | TPH-DROCio—Cog | TPH-ORO Cus



indicator Compound (Purgeable) (Extractable) (Extractable)

X



Aliphatics C.. - Ce

Aliphatics C.3 - Cio x

Aliphatics C.45 - C42

Aliphatics C...5 - Cas

Aromatics C.s - Cio x

Aromatics C.1, - Cr

Aromatics C.42 - Cis

Aromatics C..1, - Co,

Aromatics Cra . Cas | X



>|><|></

Ide



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5.3 USVI soil cleanup standards versus EPA RSLs



The following table provides the USVI soil cleanup standards and the corresponding EPA RSLs for

TPH, VOCs and PAHs. An electronic copy of 12 V.I. R&R. §654-34 is available at:

http://dpnr.vi.gov/environmental-protection/underground-storage-tanks/



Page 22 of 28

UNDERGROUND STORAGE TANK CLOSURE GUIDANCE DOCUMENT



Table 5-2: Soil Cleanup Standards



USVI DPNR



Parameters (mg/kg) EPA RSL (mg/kg)

Total Petroleum Hydrocarbons (SW8015C)

TPH-Diesel 460 -

TPH-Gasoline 460 -

Volatile Organic Compounds (SW8260B)

1,1,1-TRICHLOROETHANE - 8700

1,1,2,2-TETRACHLOROETHANE - 0.56

1,1,2-TRICHLOROETHANE -- La

1,1-DICHLOROETHANE - 3.3

1,1-DICHLOROETHENE - 240

1,2,3-TRICHLOROBENZENE - 49

1,2,4-TRICHLOROBENZENE - 22

1,2-DIBROMO-3-CHLOROPROPANE - 0.0053

1,2-DIBROMOETHANE (EDB) - 0.034

1,2-DICHLOROBENZENE - 1900

1,2-DICHLOROETHANE 0.5 0.43

1,2-DICHLOROPROPANE - 0.94

1,3-DICHLOROBENZENE - -

1,4-DICHLOROBENZENE - 2.4

2-HEXANONE - 210

ACETONE - 61000

BENZENE 12 1.1

BROMOCHLOROMETHANE - 160



Page 23 of 28

UNDERGROUND STORAGE TANK CLOSURE GUIDANCE DOCUMENT



BROMODICHLOROMETHANE =



| 0.27

BROMOFORM oe | 62

BROMOMETHANE * | 7.3



|

CARBON DISULFIDE ee 820

CARBON TETRACHLORIDE S 0.61

CHLOROBENZENE " 290

CHLOROETHANE = 15000

CHLOROFORM a 0.29

CHLOROMETHANE Fe | 120

cis-1,2-DICHLOROETHYLENE e : 160

cis-1,3-DICHLOROPROPENE = | 4.7

CYCLOHEXANE - 7000

DIBROMOCHLOROMETHANE = 0.68

DICHLORODIFLUOROMETHANE Bie 94

ETHYL BENZENE 1500 rsa

FREON 113 ee 43000

ISOPROPYLBENZENE “ Po

M,P-XYLENES | 130 | 590

METHYL ACETATE Pos es | 78000

METHYL ETHYL KETONE (2-BUTANONE) er a "28000

METHYL ISOBUTYL KETONE (4-METHYL-2-PENTANONE) 7 ~~ ‘| 5300

METHYL TERT-BUTYL ETHER (MTBE) 4400 43

METHYLCYCLOHEXANE - hope

METHYLENE CHLORIDE = earneg

O-XYLENE (1,2-DIMETHYLBENZENE) 130 690

STYRENE ee 6300

TETRACHLOROETHENE (PCE) xs 22



Page 24 of 28

UNDERGROUND STORAGE TANK CLOSURE GUIDANCE DOCUMENT



TOLUENE



5000



trans-1,2-DICHLOROETHENE



150



trans-1,3-DICHLOROPROPENE



TRICHLOROETHENE (TCE)



0.91



TRICHLOROFLUOROMETHANE



790



af



VINYL CHLORIDE



0.06



XYLENES, TOTAL



130



630



Polynuclear Aromatic Hydrocarbons (SW8270DSIM)



1-METHYLNAPHTHALENE



200



16



2-METHYLNAPHTHALENE



210



230



ACENAPHTHENE



2400



3400



ACENAPHTHYLENE



1800



ANTHRACENE



21000



17000



0.15



BENZO(a)ANTHRACENE



BENZO(a)PYRENE



0.1



0.015



0.15



BENZO(b)FLUORANTHENE



BENZO(g,h,i)PERYLENE



2500



1.5



BENZO(k)FLUORANTHENE



CHRYSENE



15



0.015



DIBENZ(a,h)ANTHRACENE



FLUORANTHENE



3200



2300



FLUORENE



2600



2300



INDENO(1,2,3-C,D)PYRENE



0.15



NAPHTHALENE



55



3.6



PHENANTHRENE



2200



PYRENE



2400



1700



Page 25 of 28

UNDERGROUND STORAGE TANK CLOSURE GUIDANCE DOCUMENT



5.4 No Further Action Determination



Based on the findings of the Closure Report, DPNR will either:

e issue a No Further Action (NFA) determination letter or

e require additional site investigation and remediation.



Please note that DPNR uses soil cleanup criteria of 460 mg/kg Total Petroleum Hydrocarbons;

and soil direct exposure target cleanup levels listed in 12 V.I.R&R. §654-34. Groundwater results

will be evaluated using the national primary drinking water standards or MCLs. .



The DPNR will consider your conclusion for no further action (NFA) status if one of the following

criteria is met:



i; Soil samples were collected from beneath the UST system and stockpile(s), and samples

were below detection limit for BTEX and PAH’s and TPH-GRO and/or DRO was less than

460 mg/kg.



a Soil samples were collected from beneath the UST system and stockpile(s), and



contamination was identified in some, or all of the samples collected. Soil contamination

is below applicable Target Cleanup Levels, and those samples requiring vertical delineation



were properly delineated to below detection limit for BTEX and PAH’s and below 10 mg/kg

for TPH-GRO and/or DRO.



3; Soil samples were collected, and contamination was identified in some, or all of the

samples collected. Soil contamination is below Target Cleanup Levels. However, soil

samples requiring vertical delineation were not delineated because groundwater was

either voluntarily collected or encountered before vertical delineation could be achieved.

BTEX and PAH’s in groundwater were below applicable drinking water stendards (MCL’s).



In some rare cases, the site may not meet the conditions for no further action listed above but

may still be eligible. The most common examples are sites in which contamination is the result

of a previous release or sites in which groundwater contamination slightly exceeds drinking water

standards or MCLs but no receptors are in close proximity (as verified by a risk-based site

assessment).



Please note that it is at the sole discretion of the DPNR if no further action (NFA) status is granted.

The DPNR will review all available information and data presented in the UST Closure Report to

make a decision. Under no circumstances should the above conditions be modified in order to

receive NFA status.



Page 26 of 28

UNDERGROUND STORAGE TANK CLOSURE GUIDANCE DOCUMENT



5.5 No Further Action with Institutional Controls



Based on a site specific risk based site assessment, restrictions on use and development may be

imposed in lieu of requiring complete cleanup of contaminated soil or groundwater, through the

use of Institutional Controls. Institutional controls are non-engineered instruments, for example

administrative and legal controls that minimize the potential for human exposure and/or protect

the integrity of the remedy. Institutional controls limit land or resource use and guide human

behavior at a given site.



Institutional controls, imposed as part of risk-based cleanup to prevent disturbance or minimize

exposure, may include the following:

e Prohibit of groundwater wells for potable water due to contaminants exceeding

drinking water standards,

e Impose construction techniques for buildings to prevent vapor intrusion, or exposure

to construction workers, or

e Limit construction in, under or over remedial caps.



The required Institutional Controls will be implemented through property records via the

following method (not all inclusive):



e Deed restrictions



e Environmental easements



e Environmental covenants



The goals of the Institutional Controls are:

e To put future purchasers on notice of contamination on the property,

e To restrict uses of designated areas on the property

e To restrict disturbance of remedies



The DPNR will review all available information and data presented in the UST Closure Report

and the required supporting Site Specific Risk Based Assessment Report to make a decision.



Dual-Phase

Soil Vapor Extraction

Extraction Conventional

Pump & Treat Excavation And

Al i

it Sparging a meals Source Removal



. Alr Compressor Vacuum Blower | \



seemed



u



Figure 5-1: Site cleanup options



Page 27 of 28

UNDERGROUND STORAGE TANK CLOSURE GUIDANCE DOCUMENT



SECTION 6 - RECORD KEEPING



The owner and operator must keep permanent records of the UST closure and should document

the UST closure procedure. You must maintain all records in accordance with 12 V.LR&R §654-

9(c) and 654-20 for at least 3 years after completion of the permanent closure.



Permanent records include (not all inclusive):



DPNR approved UST Closure Work pian



DPNR approved UST Closure Report; and all accompanying documents/records, such as

site drawings, analytical results, etc.



all correspondence with DPNR



photographs of the tank closure activities (recommended)



certificate of UST disposal

soil, water, and sludge disposal manifests



DPNR “No Further Action” letter



Page 28 of 28

APPENDIX A

Recommended Industry Codes and Standards for UST Closure



“Removal and Disposal of Used Underground Storage Tanks” American Petroleum Institute

Recommended Practice 1604



“Cleaning Petroleum Storage Tanks” American Petroleum Institute Publication 2015



“Interior Lining of Underground Storage Tanks” American Petroleum Institute Publication 1631



American Petroleum Institute

12220 L Street, Northwest,

Washington, D. C. 20005

(202) 682-8000



“Criteria for a Recommended Standard...Working in Confined Space”



The National Institute for Occupational Safety and Health

Superintendent of Documents



U.S. Government Printing Office



Washington, D. C. 20402



“Flammable and Combustible Liquids Code”

NFPA 30



“Code for Motor Fuel Dispensing Facilities and Repair Garages”

NFAP 30A



National Fire Protection Association

1 Batterymarch Park

Quincy, MA 02169-7471



“29 Code of Federal Regulations (CFR) 1926 Subpart P — Excavations”.

http://www.osha.gov

APPENDIX B

APPLICATION FOR PERMIT TO CLOSE

UNDERGROUND STORAGE TANK FACILITY



DEPARTMENT OF PLANNING AND NATURAL RESOURC

DIVISION OF ENVIRONMENTAL PROTECTION



45 Mars Hill Cyril E. King Airport

Frederiksted Terminal Building, 2" Floor

St. Croix, VI 00840 St. Thomas, Vi 00802



(340) 773-1082 (340) 774-3320



APPLICATION FOR PERMIT TO CLOSE

UNDERGROUND STORAGE TANK FACILITY



1. PROPOSED METHOD OF CLOSURE: C] REMOVAL LJ CLOSURE IN PLACE



SAMPLING PROTOCOL: The tank owner/authorized representative is responsible for all sampling analyses and associated costs.



e For tank systems that are to be removed. The excavation shall be exposed prior to the scheduled inspection and sampling points

identified by the Department of Planning and Natural Resource-Division of Environmental Protection (DPNR-DEP) inspector.

Sampling is required for both tank and piping. The tank and piping must remain in the excavation until the DEP Inspector

approves the removal.



e tank systems to be closed in place. Submit an alternate plan, which must include soil sampling, reason for closing the tank system

in place and type of material to be used to fill the tank. Soil sampling and/or hydrostatic testing is also required for piping closures.

Tank system closure in place will only be considered after evaluating the risks and hazards if the tank system were removed,



__1. FACILITY /SITE INFORMATION



2. SCHEDULED CLOSURE DATE LJ APPLICATION FEE $500 (Acct No. RV

4421}

(Must be submitted 45 days prior to installation)



PARCEL ID #4. ; FACILITY [D#:



=



BUSINESS NAME PHONE

mee)

ms ee a et Il. PROPERTY OWNERINFORMATION

| 3. PROPERTY OWNER NAME “| PHONE

MAILING ADDRESS

cona 4 Wed ao RSTALE 5) ZIPCODE

]

II. TANK OWNER INFORMATION



4. TANK OWNER NAME



PHONE



MAILING ADDRESS iia



CITY — STATE “| ZIPCODE —S

5. CJ Notification Form (EPA Form 7530-1) Attached

6. Total number of tanks to be closed Pad

NOTE: UST SYSTEMS INCLUDE TANK AND ALL ASSOCIATED PIPING. :

(__) APPROVED ( )DISSAPPROVED Date permit issued: =

MATERIALS

DATE TANK TANK PRESENTLY

TANK NO. | CAPACITY | iwsTALLED | COMPOSITION IN USE? SY ORED IN

TANK

8. Has the tank system ever failed or leaked? CL] yes CL] No



9. Reason for tanks to be closed:



C) Failure to meet current USVI/Federal requirements

C Replacement of existing tanks

C) Tank system failure, describe



O Other, describe

10. Previous owners and operators of the tanks:



Dates



Owner/Operator



11. Is the UST site located in an area deemed extremely vulnerable to groundwater contamination, such as Wellhead



Protection Areas?



CI yes



C] No



12. Are there any public water wells or private water wells or other source of groundwater within 1000 ft. of the UST



site?



C1 ves



CJ No



13. Provide the results of a 1,000 ft. survey for water supply wells in the following table. (Contact Groundwater



Program at DPNR-DEP for information (340) 773-1082-St. Croix, (340) 774-3320-St. Thomas/St. John)



Distance from UST Site



Name of Owner of Public Water Supply



i



Depth of Well



Status: Active



Well



or Inactive?

14. Indicate the current on-site land use and the most likely future land use. (Contact Comprehensive & Coastal Zone

Planning at DPNR for information (340) 773-1082-St. Croix, (340) 774-3320-St. Thomas/St. John)



Current On-Site Land Use Most Likely Future On-Site Land Use

Residential [ | Residential 4

Commercial [tal Commercial []

Other [] Other LJ

Describe: Describe:



15. Disposal site of tank:



Note: You must inform DEP of the physical address of where the tank and piping is to be disposed. Plans will not

be approved without this information.



16. Attach (3) Copies of Plans Showing The Following:



Property lines, site address, scale, north arrow



Location of all existing structures.



Location of all existing underground storage tank facilities.

Location of underground storage tanks and piping to be closed.

Location of underground utility lines and vaults.



fr de ES i

General Requirements

Application for Permit to Close

UST Facility



1, Required Inspection-Permit To Close: (A representative from DEP must be on site at the time the tank(s) are



closed)



A. TANK SYSTEM CLOSURE BY REMOVAL:



Oo



d.



The excavation shall be exposed prior to the scheduled inspection. The tank owner/authorized

representative on site must submit a uniform hazardous waste manifest demonstrating that the tank has

been properly decontaminated. A combustible gas instrument and soil sampling equipment must be on

site. The DEP Inspector will identify sampling points. The tank and piping must remain in the

excavation until DEP approves the removal.



Attach a topographic map showing the location of the facility and a general site map showing the area

surrounding the UST site.



b. Attach plan and sectional views of the excavation and include the following:

|. All appropriate excavation dimensions.

2. All soil sample locations and depths using an appropriate method of identification.

3. Location of areas of visible contamination.

4. Former location of tank(s), including depth, with tank Identification Number,

c. Is the groundwater more than 5 feet below the bottom of the excavation? [J YES L] NO

ifno provide the depth from the ground surface to the groundwater table Feet:

indicate method used to determine water table depth:

1. Excavation extended 5 feet below base of pit: LI YES [J No

2. Boring or monitoring well: C] YES CJ] No

3. Topographic features (Method must be approved by ADEM prior to use): CJ Yes LI No

Was there a notable odor found in the excavation? LI ves [] No

If yes,



il) The odor was (mild)(strong)(other)describe



(2) The odor indicates what type of product: (gasoline (diesel)

(waste oil)(kerosene)(other) describe:

e. Was there water in the excavation? LJ YES CJ] No

If yes, how was it handled?

1. One time discharge to sanitary sewer with local approval? LJ YES L] No

2. Hauled to facility capable of treating constituents of petroleum products in water?

Cl) YES C] No

3. Hauled to local POTW with local approval? CJ YEs CL] No

4. Treated on-site with NPDES approved discharged? CJ YES L] No

5. Other? Explain:

f. Was free product found in the excavation? CL] YES CL] No

If yes,

(1) How was free product handled? Describe:

(2) What was the measured thickness of free product?

g. Were visible holes noted in the tank(s)? LJ YES L] No



If yes, indicate which tanks(s) by the Unique Tank Number:



Also, describe the location(s) and provide general description as to the size and number of holes for



above noted tanks, (Example: 3 square feet of pinholes or 3 inch diameter hole):



h. Describe the soil type and thickness of all soil layers encountered in the excavation:



i. Was the excavation backfilled? 1 Yes



If yes, provide the date of backfilling:



L] No

B. TANK SYSTEM CLOSURE IN PLACE:



Soil sampling for tank(s) and piping.



After approval of the alternate plan. the tank owner/authorized representative on site shall submit a

uniform hazardous waste manifest demonstrating that the tank has been properly decontaminated. The

DEP Inspector shall verify that the tank system has been properly emptied and will witness the filling

with an approved inert substance. Piping must be closed at the same time as the tank.



a. Attach a topographic map showing the location of the facility and a general site map showing the

area surrounding the UST site.



b. Attach plan and sectional views of the excavation and include the following:



1. All appropriate excavation dimensions.



to



All soil sample locations and depths using an appropriate method of identification.

3. Location of areas of visible contamination.

4. Former location of tank(s). including depth, with tank Identification Number.



c. Attach groundwater sampling data. if required based on depth to groundwater.

Refer to Closure Site Assessment Guidance for further details regarding

requirements for groundwater sampling.



d. fs the groundwater more than 5 feet below the bottom of the tank? CI YES CI No

Provide the depth from the ground surface to the groundwater table.

Feet: =e



Refer to Closure Site Assessment Guidance for further details regarding



requirements for determining groundwater elevation.



e. Was there a notable oder found in the bore holes? LI yes LI No

If ves,

(1) The odor strength was (mild) (strong) (other) describe

(2) The odor indicates what type of product: (gasoline) (diesel) (waste oi!) (kerosene) (other)



Describe:



f. Was free product found in the bore holes? Li yes LI No

If ves,



(1) How was free product handled? Describe;



(2) What was the measured thickness of free product? —__

g. Describe the soil type and thickness of all layers encountered in the bore holes and provide boring

logs:



h. Specify the inert solid material used to fill tanks(s):



i. Provide the date the tank(s) were filled:



j. Were the bore holes properly sealed with bentonite/soil? L] YES C1 No

If yes, provide the date:



2. DECLARATION



I declare that to the best of my knowledge and belief, the statements and information provided are correct and true. |

understand that information in addition to that provided above may be needed in order to obtain final approval by the

Department of Planning and Natural Resources —Division of Environmental Protection (DPNR-DEP).



[ understand that tests and procedures that may be required by other departments and agencies to demonstrate adequate

site safety or suitability for further development (e.g. soil compaction testing) are in addition to the requirements.



I will make contact with an Environmental Specialist (DPNR-DEP) at least two (2) working days to schedule the

required inspections. | understand that no work is to commence on the proposed project until a permit has been issued.

I understand that site and worker safety are solely the responsibility of the property owner or his agent and that this

responsibility is not shared or assumed by the DPNR-DEP. | further understand that a closure must be submitted to



the DPNR-DEP within 30 calendar days of completion of UST closure following the guidelines/format prescribed.



SIGNATURE & TITLE:



PRINT NAME:



TELEPHONE: (_) DATE

APPENDIX C



UST Closure Checklist



= Submit the application for Permit to Close USTR System to DPNR at least 45 days prior to

the UST closure or change-in-service.



CJ Notify any agencies as required such as local fire department, and obtain any local permits

as required.



LJ Notify DPNR- UST Program by fax, email, or telephone at least 30 days prior to the

scheduled date and time of the UST closure or change-in-service.



J Call VI WAPA, VI WMA and VI DPW at least 48 hours prior to any excavation activities and

arrange for all underground lines and utilities to be located and marked.



CJ Conduct a site inspection prior to commencement of UST closure or change-in-service



activities to observe site for any overhead obstructions or nearby buildings that may interfere

with UST closure or change-in-service.



= On the day of and prior to conducting the UST closure or change-in-service activities

review the Health and Safety Plan (HASP) and obtain signatures of all workers present.



C] Locate UST system and prepare scaled site plan sketch (Note tank and line locations, tank

sizes, product types, dispenser islands, buildings, streets, etc.), .



CJ Identify and barricade sufficient work space for workers and equipment (50 feet from

edge of excavation).



C] Excavate to top of tank, drain and flush piping, cap piping ends if left in place. Remove

drop tube, submerged pump if present, and any fittings from UST. Leave vent line in place.



= Leave the tank in the excavation during all cleaning and vapor freeing activities. The tank

may be removed from the excavation only after the tank in clean and vapor free.



= Remove all product and residue from tank and lines by vacuum truck or explosion-proof

pump.

L] — Remove vapors from tank by:

O Purging



* Venturi Eductor Method - pulls air into the tank through the vent line, up the drop

tube and out the Venturi eductor.



Diffused Air Blower Method - pushes compressed air into the tank through the

opening with drop tube removed, through an air diffuser, and out the vent line.



Ground the equipment and tank. After purging take CGI readings at several

openings and at different levels in tank until the readings are below 10% LEL.



O Inerting



" Dry Ice (CO2) — use a minimum of approximately 12 to 2 pounds per 100 gallons



of tank capacity. Distribute evenly over the greatest possible area of the tank. All

Openings except the vent line are plugged. Caution: This is only an estimate amount

of dry ice. The only way to determine if enough dry ice was used to make the

atmosphere safe from ignition is to have less than 5% oxygen when measuring with an

oxygen meter.



* Nitrogen (N2) — use approximately one 50 Ib. bottle per 2500 gallons of tank capacity.

All openings except the vent line are plugged.



* Ground the equipment and tank. Do not apply more than 5 psig to the tank. After



inerting take oxygen readings at several openings until the readings are below 6% to

7%.



L] A purged or inerted tank can return to flammable status, so readings should be taken



regularly during the entire time tanks are on site. Include areas lower than grade and in the

immediate vicinity of the tank(s).



L] Once the tank is vapor free, remove all purging or inerting equipment, and close all

openings with threaded plugs. Disconnect the vent line. Close the vent opening with a threaded

plug that has a 1/8” (API) or V4” (NFPA) hole pre-drilled through it to allow tank to breathe in

response to temperature changes.



CO Lift tank from excavation with equipment capable of lifting tank (never drag or roll it). Set

tank on trailer for transport.



CJ Properly label tank for transport as recommended by API.



CJ Obtain soil samples as described in the —Underground Storage Tank Closure Document.



Place soil samples on ice, complete chain-of-custody, and transport/ship samples to DPNR

accredited laboratory for analysis.



L] Submit the Closure Assessment Report to the DPNR at least 60 days following permanent

closure or change-in-service.



This is intended as a checklist and does not provide instruction on every procedure

for proper UST closure or change-in-service. It is the owner/operator responsibility

to ensure all applicable rules, regulations, and recommended industry practices are

followed during UST closure or change-in-service.