Field Guide For Reportable Surface Releases of Crude Oil in Non-Sensitive Areas

To assure persons meet the goals established by Statewide Rules 8, 20, and 91, all spill responses should include:

1. notice to the RRC as described in Statewide Rule 20(a)(1) and (b)
2. removal of all free liquids immediately as described in SWR 91(c)(1)
3. horizontal and vertical delineation of all areas with more than one percent by weight of total petroleum hydrocarbons (TPH) - If analytical testing for TPH is used, available methods include, but are not limited to, 418.1, modified TNRCC 1005 (to include carbon fractions up to C-35), TNRCC 1006, Massachusetts VPH/EPH. Additional methods may be used provided that the interested party demonstrates that the method is appropriate to characterize the specific crude oil.
4. proper reporting as described in Statewide Rule 91(e)
5. one confirmation sample at the base of an excavation to verify that all soil containing over one percent by weight TPH is brought to the surface for disposal or remediation, if spill excavation is concurrent with delineation

Delineation and reporting of spills over 5 barrels but less than 25 barrels

1. If spill excavation is not performed, delineation horizontally and vertically will be required to verify that all soil containing over 1% by weight TPH is brought to the surface for disposal or remediation. In most cases horizontal delineation will require a minimum of four samples.
2. For spills in this category, all delineation sampling may be performed with TPH field test kits. These TPH results should be submitted with the H-8 and the signature of the operator will verify that the sampling was performed in accordance with the proper procedures of the specific test kit.
3. Final closure (compliance of RRC regulations) of the spill will require at least one laboratory TPH analysis to confirm that the impacted soil is less than 1% by weight TPH.

Delineation and reporting of spills over 25 barrels

1. If spill excavation is not performed, delineation horizontally and vertically will be required to verify that all soil containing over 1% by weight TPH is brought to the surface for disposal or remediation. In most cases, horizontal delineation will require a minimum of four grab samples (not composite samples).
2. For spills in this category, horizontal delineation sampling may be performed with TPH field test kits. These TPH results should be submitted with the H-8 and the signature of the operator will verify that the sampling was performed in accordance with the proper procedures of the specific test kit.
3. Any sample used for vertical delineation of the spill must be analyzed by a laboratory using an appropriate TPH methodology.
4. Final closure (compliance of RRC regulations) of the spill will require at least one laboratory TPH analysis to confirm that the impacted soil is less than 1% by weight TPH.

All reportable spills

1. If spill delineation indicates that the spill site may be in a sensitive area, additional delineation with site-specific criteria will likely be required once the operator consults with the appropriate District Office about proper cleanup standards and methods, reporting requirements and other special procedures.
2. A topographic map of the spill or GPS coordinates of the area may be requested to assist in locating the spill site, determining the location relative to streams, residences, wetlands etc. and determining the potential for off-site migration.
3. Site-specific information may result in additional sampling requirements on a case-by-case basis.

Remediation of soil

1. If on-site bioremediation is chosen to meet Commission compliance goals, soil mixing with ambient or clean soil must achieve a uniform mixture that is no more than 18 inches in depth and contains no more than 5.0% by weight TPH.
2. A final level of 1.0% by weight TPH should be achieved for all spills in non-sensitive areas as soon as it is technically feasible but no later than on year after the spill.
3. For larger spills, compliance sampling may require one sample for each 50 cubic yards.

Preventative Measures

1. If a spill is within a properly bermed area and the operator has preventatively lined the area of the spill with an impermeable material and no spilled fluids breach the liner, then soil sampling will not be required.