You’ve just discovered that your underground storage tank (UST) and/or associated underground piping has been leaking petroleum products into the environment. The difference between this becoming an expensive nightmare and “just” a response activity may depend on your measured response. Certainly, you need to make sure you are doing everything you can to minimize your release and the subsequent impact to human health and the environment while maintaining compliance.
While you will likely be in “emergency mode,” remember to document everything you do. This may be critical should questions arise later regarding the timing of the discovery of the release, type of product released, the cause of the release, the exact location of the product loss, etc.
One of thousands of USTs Dragun has worked since 1988 (Photo Credit: Dragun Corporation).
You’ve Discovered a Leaking UST – Now What?
With that said, here are three steps that will help you stay in compliance with the Technical Standards and Safety Authority (TSSA), Fuels Safety Program (FSP) as well as help minimize your short- and long-term liability.
- Report the leak to the TSSA-FSP Director. This is accomplished by contacting the MOECC Spills Action Centre (SAC) at 1-800-268-6060. Reportable leaks include spills of
- 25 litres or more at sites with public access (e.g., gas bar)
- 100 litres or more at sites restricted from public access
- A lesser quantity if the spill could impact public health, safety, water source, storm sewer system, or “interfere with the rights of any person.”
- As quickly as possible, implement mitigative actions to repair/replace the leaking component(s) of your system. The sooner you can stop the source of the leak, obviously, the better. This is where doing your homework and having your qualified emergency contractors in place will pay dividends. You need to get them to your site so they can implement emergency procedures.
If you have multiple USTs/product lines, it can complicate the issue further. After all, how can you mitigate if you don’t know the source? Your fuel-management company can run tests to determine the location of your leak, and the leak rate will make it easier to repair/replace the leaking component(s) and, potentially, estimate the volume of product lost.
- Working closely with your contractor will be your environmental consultant. Again, long before your emergency occurs, you should know your consultant and know that they have Qualified Persons (P.Eng/P.Geo) on staff with experience on these types of projects.
Depending on the situation, you can expect your environmental consultant to conduct some or all of the following:
- Assist in directing the recovery of the escaped product from a monitoring well(s), observation well, or an excavation(s).
- Determine the extent of contamination on site and off site (if applicable). Depending on the size of the release, this may involve screening and sampling excavation limits, advancing soil borings, installing monitoring wells, and collecting soil and groundwater samples.
- Conduct a vapour intrusion investigation. This will depend on the proximity of buildings to the release.
- Implement a remediation program to restore soil and groundwater to the applicable MOECC standards.
- Implement a contaminant management plan.
- Provide documentation for reporting to the TSSA’s Fuel Safety Program, as applicable.
As with any issue involving a release to the environment, the devil is in the details! And it’s worth saying again… document, document, document.
Leaks from tanks, piping, or other components, such as dispensers, can become costly environmental problems. Ensuring that proper product tracking, inventory control, and routine equipment inspections and maintenance are conducted can identify problems early on, thereby saving you an environmental headache.
Contact the Environmental Consulting Experts
Hopefully, you don’t need to contact us; however, if you need help, we have over 26 years of experience working on assessment and remediation of leaks at hundreds of fuel-storage sites. If you have questions about the potential for leaking USTs or remediation of a previous leak, please feel free to contact me (krey@dragun.com) or Christopher Paré, P.Geo. (cpare@dragun.com) at 519-979-7300.