Cracked spill buckets are commonly reported to the Petroleum Program as a suspected release condition.
Owners/Operators are required to either repair or replace a cracked spill bucket and appropriately assess whether it has resulted in a confirmed release to the environment. Pea gravel and tank backfill materials have a poor retention capacity to sorb petroleum and should not be submitted for laboratory analysis for closure assessment or No Further Action Requests. However, if detectable concentrations of chemicals of concern are measured in backfill material, those detections can be used to confirm a release from the tank system. The tank backfill material can also be utilized to determine the appropriate next steps. Use the steps identified below to assess for a release when replacing a spill bucket.
Tank backfill material should be visually inspected and field-screened with a photoionization detector during the spill bucket replacement. If there are no indications of a release (i.e., visual inspection and field screening do not identify a release), then no additional assessment is required and the observations should be reported to the Petroleum Program. The Minor Equipment Repair/Replacement Notification form and Tightness Testing for Secondary Containment form are required within 30 days of completing the repair or replacement.
Additional assessment is warranted if there are indications of a release based on the inspection of the tank backfill material. Collect native soil and groundwater samples at a safe distance from all four directions around the tank basin to an appropriate depth to assess for the presence of a release. You may not need to collect groundwater samples if the depth to groundwater is known and if you can demonstrate that the vertical extent of contamination has been defined prior to encountering groundwater.
If you have questions about this information, please call the OPS Technical Assistance Line at (303) 318-8547.
Colorado Division of Oil and Public Safety
633 17th Street, Suite 500, Denver, CO 80202
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