DERR-2024-009305

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Published by the
Utah Department of
Environmental Quality

Division of Environmental
Response and Remediation

Underground Storage
Tank Branch

Dianne R. Nielson
Executive Director

Brad Johnson
Division Director

Dale Marx
Branch Manager

DeAnn Rasmussen
Editor

INSIDE:

Safe Fuel Delivery
Practices………..Page 1

New Cleanup Levels
Referenced
In Rule…………Page 3

Proposed Changes to the
Corrective Action
Process………...Page 5

Certification Fees
Increase……….Page 6
Safe Fuel Delivery Practices by Gary Astin

1
As we perform yearly
Underground Storage Tank (UST)
inspections, we occasionally find
evidence that fuel deliveries may
have been performed using unsafe
practices. In the past year, we
have found gauging sticks stuck
in fill pipes to disable the overfill
shutoff device, vapor recovery
ports that are jammed open, and
tanks that have been filled to
overflowing.
The Federal UST regulations (40 CFR 280.30) require that UST
owner/operators take responsibility to ensure that releases due to spills
and overfills during product deliveries do not occur.
In addition to the requirement to have spill and overfill prevention
devices, the regulations require that owner/operators do three things:
1) Ensure that the volume in the tank is adequate to hold the fuel to be
delivered.
2) Constantly monitor the transfer operation to prevent spilling and
overfilling.
3) Report, investigate, and clean up spills and overfills.
continued on page 2

Safe Fuel Delivery Practices … continued from page 1

UST owner/operators and delivery personnel have the
responsibility to ensure that product deliveries are
done safely, and make sure no spills or overfills occur.
Here are some do's and don'ts for safe filling practices:
y Don't put a gauge stick or anything else in the tank
fill port to disable the overfill shutoff.
y Don't put a rock or anything else in the vapor
recovery port to keep it open. This results in the tank
venting to the ground surface, which is dangerous and
a violation of the fire codes.
y Do check the product level before and after the
delivery.
y Do monitor the delivery to make sure no problems
occur.
y Do make sure spill buckets are clean, dry, and intact.
A monthly visual inspection for cracks and damage is
a good idea.
y Do make sure the overfill prevention device is
functional.
y Do make sure the overfill alarm, if used, can be seen
and/or heard by the delivery driver, and is identified
with directions on what to do if the alarm goes off.
The Environmental Protection Agency (EPA) UST
office has published an Operations and Maintenance
manual for UST owners and operators. It suggests
several steps you should take when you have a fuel
delivery.
Before:
y Make and record accurate readings for product and
water in the tank.
y Order only the quantity of fuel that will fit into 90%
of the tank capacity.
y Make sure that delivery personnel know what type
of overfill device the tank has, how to tell when it
activates, and what to do when it activates.
y Verify that your spill buckets are clean, empty, and
will contain spills.
During:
y Monitor the entire fuel delivery.
y The delivery driver should be prepared to stop the
flow of fuel into the UST and respond if an unusual
condition, leak, or spill occurs.
y Have response supplies available in case a spill or
leak occurs.
After:
y Make and record accurate readings for product and
water in the tank, and verify the amount of fuel
received.
y Make sure fill ports are properly secured.
y Ensure that spill buckets are free of product and
clean up any small spills.

The EPA manual can be downloaded from the internet
at http://www.epa.gov/OUST/pubs/ommanual.htm, or
you can get a paper or electronic copy from the
Division of Environmental Response and Remediation
(DERR) UST section at [phone].„

Gary Harris and Jason Wilde, two of our UST scientists have been deployed for a one year
overseas tour of military duty. We will miss the contributions that they have made to our
program. Our thoughts will be with them and their families as they serve our country. We
look forward to their safe return.

2

NEW LUST CLEANUP
LEVELS REFERENCED
IN RULE
by Morgan Atkinson
In the past some Underground Storage Tank (UST)
owners, operators and certified consultants have felt there
was some level of confusion when a release occurred at a
facility and cleanup standards were established for that
particular release. Occasionally, some have felt that their
cleanup efforts were aiming at a moving target and
wanted to have a more structured or defined standard for
how cleanup levels are established.

Last year this level of confusion was brought to the
attention of the Utah Division of Administrative Rules
and the Administrative Rules Committee of the
Legislature. In response to the concerns that were
presented, the Legislature recommended that the actual
numeric values and screening criteria for closure of
Leaking Underground Storage Tank (LUST) sites be
established by rule using the public comment process.

The DERR subsequently proposed changes to the Utah
UST rules (R311) that would establish consistent criteria
for UST corrective action cleanup standards, clarify
requirements for establishing cleanup standards, and also
clarify the requirements to obtain a “No further action”
determination from the Executive Secretary (UST).
R311-211-6. UST Facility Clean-up Standards was
created to meet the requirement of the Legislature. A full
version of R311 including the changes is available online:
http://www.rules.utah.gov/publicat/code/r311/r311.htm.

The major implication of the rule change is that the
DERR has modified the current screening process for
petroleum related sites. These modifications consist of
the addition of two distinct screening tables (referenced
in R322-211-6) to be used in conjunction with the
“Guidelines for Utah’s Corrective Action Process for
Leaking Underground Storage Tank Sites”
(“Guidelines”). The “Guidelines” document is generally
referred to as the Tier 2 guidance document. The
screening tables (presented together on page 4) are
identified as the “Initial Screening Levels” table and the
“Tier 1 Screening Criteria” table.

The “Initial Screening Levels” (ISLs) table values were
derived by selecting appropriate ground water standards.
The standards that were selected were Federal/State
Maximum Contaminant Levels (MCLs). MCL values
were available for benzene, toluene, ethylbenzene, and
If there was not a MCL available for a particular
chemical (i.e., naphthalene and MtBE), a risk based
screening level was calculated using the methodology
defined in the “Guidelines.” Total Petroleum
Hydrocarbons (TPH) for gasoline, diesel and oils and
grease used non-risk based screening levels as defined in
the “Guidelines.” The TPH screening numbers for the
“Initial Screening Levels” are based on Tier 1 values that
have been reduced by a factor of 10. Soil screening
levels were developed using an exposure scenario of
contaminated soil leaching to groundwater, which is also
presented in the “Guidelines.”

The “Tier 1 Screening Criteria” table uses risk-based
(i.e., benzene, toluene, ethylbenzene, xylene, naphthalene
and MtBE) and non-risk based (i.e., TPH) screening
levels. The only modifications that have been made to
the “Tier 1 Criteria” table are updates to the toxicological
information known as References Doses (RfD) for
naphthalene and xylene.

Another result of the rule change is the merging of the
former “Tier 1 Document and Guidelines” into the
“Guidelines for Utah’s Corrective Action Process for
Leaking Underground Storage Tank Sites.” All
references to Recommended Cleanup Levels (RCLs)
have been removed and replaced with the ISLs reference.
Also, the RCL document titled “Estimating Numeric
Cleanup Levels for Petroleum-Contaminated Soil at UST
Release Sites” has been removed from the divisions’
website. The new “Guidelines” can be found on the UST
website at www.undergroundtanks.utah.gov/.

Public Comment Process Details
On February 9, 2006, the Utah Solid and Hazardous
Waste Control Board (Board) approved the proposed
changes to the Utah UST rules, for publication and public
comment. The proposed changes were published in the
Utah State Bulletin on March 1, 2006. The public
comment period was held from March 1, 2006 to March
31, 2006, and a public hearing to receive comments on
the proposed changes was held on March 28, 2006. No
comments were received at the hearing, but comments
were received during the comment period. Comments
were addressed, but no changes to the proposed rules
were made. On May 11, 2006, the Board approved the
proposed changes to the UST rules for final adoption.

For more information on LUST Cleanup Levels
and other issues visit the UST website at
www.undergroundtanks.utah.gov/.

3

Tier 1 Screening Levels (SL) and Criteria

Tier 1 Screening Levels are applicable only when the following site
conditions are met:
1.) No buildings, property boundaries or utility lines within 30 feet of
the highest measured concentration of any contaminant that is greater
than the Initial Screening Levels but less than or equal to the Tier 1
Screening Levels AND,
2.) No water wells or surface water within 500 feet of highest measured
concentration of any contaminant that is greater than the Initial
Screening Levels but less than or equal to the Tier 1 Screening Levels.
Contaminant
Tier 1 SL
Groundwater
(mg/L)
Tier 1 SL
Soil
(mg/kg)
Benzene 0.3 0.9
Toluene 3 25
Ethylbenzene 4 23
Xylenes 10 142
Naphthalene 0.7 51
Methyl t-butyl ether (MTBE) 0.2 0.3
Total Petroleum Hydrocarbons
(TPH) as gasoline 10 1500
Total Petroleum Hydrocarbons
(TPH) as diesel 10 5000
Oil and Grease or Total
Recoverable Petroleum
Hydrocarbons (TRPH)
10 10000

Initial Screening Levels (ISL)

Contaminant
ISL
Groundwater
(mg/L)
ISL
Soil
(mg/kg)
Benzene 0.005 0.2
Toluene 1.0 9
Ethylbenzene 0.7 5
Xylenes 10.0 142
Naphthalene 0.7 51
Methyl t-butyl ether (MTBE) 0.2 0.3
Total Petroleum Hydrocarbons
(TPH) as gasoline 1 150
Total Petroleum Hydrocarbons
(TPH) as diesel 1 500
Oil and Grease or Total
Recoverable Petroleum
Hydrocarbons (TRPH)
10 1000

UTAH LUST PROGRAM SCREENING LEVELS FOR SOIL AND GROUNDWATER

Effective Date: May 15, 2006
4

These changes to the corrective action process will expedite the selection of an agreeable solution for site
cleanups between the owner and the UST program. It will also save time (and money) that in the past was
spent on viewing, and modifying several versions of CAPs, until one could be approved.

The UST program plans to have these changes in place by late summer 2006. When they are available, the
changes will be announced by email and on our website: http://www.undergroundtanks.utah.gov/. If you have
any questions concerning this article, please contact Paul Zahn at [phone].„

Proposed Changes to the Corrective Action Process

by Paul Zahn
5
www.undergroundtanks.utah.gov

In an effort to better serve owners, while at the same time meeting the requirements in state and federals
regulations to protect human health and the environment, the UST program is in the process of changing how
site cleanup plans are reviewed and approved. When an UST system has a release, it is generally necessary to
clean it up. In the past, the state would send a letter to the owner requiring them to submit a plan outlining how
the contamination will be removed. These plans are called Corrective Action Plans (CAPs). Typically, a
consultant hired by the owner prepares the CAP in a format provided by the UST Program. These CAPs can be
costly, and there is no guarantee the plan will be approved once it has been submitted.
One major change to the corrective action
process involves a meeting prior to
submitting a CAP. The UST Program
will be requesting a meeting with the
owner, their consultant and other directly
interested parties to discuss the history of
the release and evaluate cleanup options.
The objective of the meeting is to
mutually agree on one preferred cleanup
strategy for the site. The results of the
meeting would be documented by the
owner (or their consultant) in a 2-3 page
“CAP Summary Letter” and submitted to
the UST program for review. Following
a public comment period, more technical
details of the corrective action method
may need to be presented to the UST
program.

UTAH DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF ENVIRONMENTAL RESPONSE AND REMEDIATION
P.O. BOX 144840
SALT LAKE CITY, UTAH 84114-4840
PRSRT STD
US POSTAGE
PAID
SALT LAKE CITY, UT
PERMIT #4621
^ C E R T I F I C A T I O N C O R N E R ^
http://www.undergroundtanks.utah.gov/cert_program.htm
UST Consultant Certification Program
A Certified UST Consultant must perform any UST release
management, abatement, investigation, or corrective action.
Consultants must renew their certification every 2 years. The
renewal courses begin promptly at 9:00 a.m. and finish at 1:00 p.m.
The comprehensive exams begin at 2:00 p.m. For more
information contact Melissa Turchi at [phone] or at
[e-mail].
Initial Exam & Renewal Course Schedule
Friday, September 8, 2006
Friday, December 8, 2006
Friday, March 9, 2007
Friday, June 8, 2007
Groundwater and Soil Sampler
Certification Courses

Environmental Contractors Inc. (ECI)
[phone]
Utah Valley State College (UVSC)
[phone] or [phone]
Renewal tests are given the first Tuesday of each
month and begin promptly at 9:00 a.m. The
July test will be held on Wednesday, July 11th
due to the 4th of July holiday. For more
information contact David Wilson at
[phone] or at [e-mail].
~~ Increase in UST Certification Fees ~~
As of July 1, 2006, the fees for initial certification and certification
renewal will increase from $150.00 to $225.00. The certifications
that this fee applies to are; UST testers, groundwater and soil
samplers, tank removers, tank installers, and consultants.
* * * PLEASE
NOTE * * *
6
Certification exams and courses take place at the Division of Environmental Response & Remediation office
building located at 168 North 1950 West, Salt Lake City, Utah 84116.