State Cleanup FAQs
Table of Contents
- Do I need to report a release from a Non-Regulated Underground Storage Tank (UST) or an aboveground storage tank (AST)?
- What happens after I report a release?
- What guidelines do I follow when closing out an unregulated tank?
- What should I sample for and what analytical methods should I use?
- How do I select an Environmental Consultant?
- I have detections of "chemical X" below RISC Residential Default Closure levels; do I have to report it?
- What about electronic data submittal?
- What are State Cleanup’s Quality Assurance/Quality Control Documentation Requirements?
- What Report Format do I follow when submitting a document?
- Are there special instructions to search the Virtual File cabinet for State Cleanup documents?
- Is there any funding available for my site investigation or cleanup?
- Is TPH a contaminant of concern for my Site?
- Is vapor intrusion a concern at my site?
- How do I gain access to a third party property in order to complete contaminant delineation for my site?
- Where can I find the most recent closure levels and guidance?
- What are the submittal guidelines for an Environmental Restrictive Covenant (ERC)?
1. Do I need to report a release from a Non-Regulated Underground Storage Tank (UST) or an aboveground storage tank (AST)?
To report a release from a non-regulated tank, contact the IDEM Spill Line at 888/233-7745. If there are questions about whether a specific tank or tank system is regulated, call: (317) 233-2570. If the release requires additional oversight, the site may be referred to the State Cleanup Program by the Emergency Response Section.
As with other types of spills, releases must be reported consistent with the terms outlined in the Indiana Spill Rule, 327 IAC 2-6
2. What happens after I report a release?
After calling the IDEM Spill Line, an incident number will be assigned to your release. If the release is referred to the State Cleanup Program for project management, the site is prioritized using the Priority Ranking System to determine if the site is a low, medium or high priority. A project manager will be assigned to provide oversight if the priority is a high or medium contaminated with hazardous substances. IDEM will send a letter requesting that you perform an investigation to characterize the nature and extent of the contamination. Sites that are low priorities or medium priorities contaminated with only petroleum may not be assigned to a project manager; however, these sites may be eligible for obtaining closure utilizing the Independent Closure Process. Regardless of the level of oversight provided by the agency, you are required to complete an investigation and cleanup at your site. IDEM will pursue any administrative or judicial actions necessary to ensure appropriate remediation of sites.
3. What guidelines do I follow when closing out an unregulated tank?
When closing an unregulated tank such as a heating oil tank, hydraulic lift tank, or other UST system excluded from 329 IAC 9-1-1, the State Cleanup Section requests that Responsible Parties and Contractors follow the procedures for a removal closure, outlined in 329 IAC 9-6-2.5. This section of the UST Rule outlines the quantity and location of soil and groundwater samples, lists pertinent information that should be included in the Closure Report and/or Site Investigation Report, and states the sampling requirements for excavated areas and backfill. If for some reason the unregulated tank in question cannot be physically removed (i.e. structural impediments), a State Cleanup Section Project Manager should be contacted for closure guidance.
4. What should I sample for and what analytical methods should I use?
The following table summarizes the sampling and analytical requirements for sites contaminated with petroleum and chlorinated solvents. For sites contaminated with sources other than these listed types, a State Cleanup Project Manager should be contacted for Sampling and Analytical Requirements. Note: Method detection limits for all analyses should be low enough to evaluate concentration levels against the appropriate closure levels. Also, please note that Total Petroleum Hydrocarbon (TPH) Extended Range Organics (ERO) should include carbons 8 through 36.
| Source | Contaminant type | Sample Matrix | Parameters | Analytical Method |
|---|---|---|---|---|
| Petroleum Hydrocarbons | Gasoline | Soil | TPH-GRO | SW846-8015D |
| BTEX MTBE | SW846-8260B or SW846-8021B | |||
| Groundwater | TPH-GRO | SW846-8015D | ||
| BTEX MTBE | SW846-8260B or SW846-8021B | |||
| Diesel, No. 2 fuel oil, kerosene, aviation gasoline, and jet fuels | Soil | TPH-ERO Note: C8-C36 |
SW846-8015D | |
| BTEX MTBE | SW846-8260B or SW846-8021B | |||
| PAHs | SW846-8270 SIM or SW846-8310 | |||
| Groundwater | TPH-ERO | SW846-8015D | ||
| BTEX MTBE | SW846-8260B or SW846-8021B | |||
| PAHs | SW846-8270 SIM or SW846-8310 | |||
| Fuel and lubrication oils such as virgin motor oil, fuel oils No. 4, 5, and 6 (bunker oil) | Soil | TPH-ERO | SW846-8015D | |
| PAHs | SW846-8270 SIM or SW846-8310 | |||
| Groundwater | TPH-ERO | SW846-8015D | ||
| PAHs | SW846-8270 SIM or SW846-8310 | |||
| Waste Oil | Soil and Groundwater | TPH-GRO, TPH-ERO, VOCs PAHs, Napthalene (Metals and PCBs are Site Specific ONLY) | ||
| Chlorinated Solvents | Tetrachloroethylene | Soil | VOCs | SW846-8260B |
| Groundwater | VOCs | SW846-8260B or SW846-8021B | ||
5. How do I select an Environmental Consultant?
IDEM cannot endorse or recommend a contractor. The phone directory is a good source to start looking for a contractor. IDEM recommends that you solicit bids from at least three different consultants. Make sure the consultant can perform the investigation and cleanup in accordance with the guidance and laws. It may be helpful to ask other business owners (i.e. gas station owners or dry cleaning operators) about consultants that they may have hired. While the lowest bid may be appealing, finding an experienced contractor that performs quality work can often save money in the long run.
6. I have detections of “chemical X” below RISC Residential Default Closure levels; do I have to report it?
Yes. Consistent with the Indiana Spill Rule, 327 IAC 2-6, all contaminant detections must be reported. A release of contaminants at concentrations greater than the reporting limit may have occurred nearby, and an investigation must be conducted to determine if the reported concentrations are the worst case and to determine the extent of the release.
7. What about electronic data submittal?
IDEM requests that all sampling analytical data (air, soil, and water analytical sampling results) be submitted electronically to olqdata at idem.in.gov. Guidance on formatting analytical results for electronic submittal is posted at IDEM - Land - Electronic Data Submittal Guidelines for Sampling & Analysis Data. IDEM is requesting electronic submission to improve the quality and timeliness of technical reviews.
8. What are State Cleanup’s Quality Assurance/Quality Control Documentation Requirements?
The IDEM established Minimum Data Documentation Requirements (MDDRs) should be followed for all State Cleanup non-regulated petroleum related projects, excluding Manufactured Gas Plant (MGP) projects and projects utilizing Total Petroleum Hydrocarbon (TPH) fractionation, which require all applicable QA/QC documentation (including raw data). The full QA/QC package should remain available for submission to IDEM upon request. OLQ Chemistry highly recommends submitting full QA/QC documentation at closure of all projects.
The MDDRs may be found in Chemistry Services.The MDDRs and the MDDR document are discussed in the draft Chapter 3 for the Leaking Underground Storage Tank Program, of the RISC User’s Guide in Section 3.4.4, Data Submission Requirements.
In general, the State Cleanup Section requires that all other sites submit level IV QA/QC data for all data submitted for nature and extent determination, and for data used for closure. The level IV QA/QC requirements are outlined in the RISC Technical Guide, Appendix 2 [PDF]. Any questions on the required QA/QC submittals should be directed to a State Cleanup Program Project Manager.
9. What Report Format do I follow when submitting a document?
The general report outline formats are discussed in detail in the RISC User's Guide, Appendix 1 [PDF]. The following list of Reports will be expected as part of the investigation and cleanup process:
- Site Investigation Report (SIR): This report is due within 180 days of reporting the release to IDEM, after full delineation of contamination has been completed. The Site Investigation Report must provide background or historical information about the site and contaminant sources and should summarize and include all data collected to verify delineation of the contamination. The SIR must include all of the elements contained in the investigation report outline included in RISC User's Guide, Appendix 1 [PDF].
- Site Investigation Progress Report (SIPR): Site Investigation Progress Reports must be submitted every sixty (60) days throughout completion of the site investigation or upon completion of investigation phases; whichever is earlier. SIPRs can be used in lieu of Further Site Investigation Reports in order to speed up the investigation process. SIPRs must include the following minimum information:
- summary of site investigation work performed to date including detail regarding sampling and data collection procedures used;
- site plans depicting all source areas, borings, wells, structures and preferential pathways/utilities;
- data box figures depicting vertical and horizontal contaminant distribution;
- ground water flow direction and gradient figures;
- summary tables for contaminant concentrations, ground water well gauging, surrounding high/low capacity water wells;
- soil boring logs and monitoring well construction diagrams;
- laboratory data summary reports;
- brief work plan for additional investigation, including map depicting proposed boring/monitoring well locations.
- Further Site Investigation (FSI) Report: The purpose of a FSI Report is to supplement the information submitted in a SIR Report, and to complete delineation of the nature and extent of soil and/or groundwater contamination. The FSI Report is typically used to document results of investigation when a phased approach is used. The content of the FSI Report is the same as the SIR, and must follow the outline for investigation reports found in RISC User's Guide, Appendix 1 [PDF].
- Remediation Work Plan (RWP): This report provides IDEM with an evaluation of the proposed remedy to clean up the site. When IDEM determines that the RWP is appropriate and ready for design and implementation, IDEM will grant approval of the Work Plan and may request an Implementation Report.
- Monitoring Reports: Progress Reports are generally submitted four times a year and will present IDEM a summary of sampling and monitoring results. The quarterly sampling schedule is as follows: January to March quarterly reports are due April 30th, April through June are due July 31st, July through September are due October 31st, and October through December are due by January 31st of the following calendar year.
- Closure Report: At the end of a project, a final report must be submitted to document that closure goals have been achieved. When IDEM has determined that the Site poses no risk to human health or the environment, No Further Action status will be granted.
10. Are there special instructions to search the Virtual File cabinet for State Cleanup documents?
When arriving at the Virtual File Cabinet Facility Search window, you will see an option in the upper left for “Document Search.” Click this link.
- On the Document Search page, use the arrow to select State Cleanup in the Program dropdown box. The screen will refresh.
- Select Site# in the Index dropdown box. The screen will refresh.
- In the blank box to the right of Site#, type in the nine digit site number that was assigned to the Site.
- All documents currently available through VFC will be displayed.
Please note: Some sites have been listed twice with both 7 and 9 digit numbers. If the site # begins with a series of zeros, add or subtract zeros as needed and perform search for both numbers. For example, #0000021 and #000000021 will reference the same site.
11. Is there any funding available for my site investigation or cleanup?
Currently there is no state-provided funding (i.e. grants or loans) available from the State Cleanup Program. However, current or historical insurance policies may provide coverage for your environmental release or spill. Your contractor or insurance agent may be able to assist you in determining your coverage.
12. Is TPH a contaminant of concern for my Site?
When investigating a petroleum release from any source, including heating oil tanks, hydraulic lift tanks, and aboveground or underground storage tank systems, soil and ground water samples should be analyzed for total petroleum hydrocarbons (TPH) in addition to any associated contaminants of concern. The Total Petroleum Hydrocarbon (TPH) non-rule policy document is now available in Chapter 8 of the RISC Technical Guide [PDF]. Chapter 8 details the procedures for achieving default and non-default closures for TPH.
13. Is vapor intrusion a concern at my site?
If ground water concentrations of volatile contaminants are above the established screening levels found in the Draft Vapor Intrusion (VI) Pilot Program Guidance [PDF], investigation of the vapor intrusion pathway must be conducted. Detailed procedures for soil gas, sub-slab and indoor air sampling are outlined in the VI Guidance. Indoor air contaminant concentrations exceeding the action levels will require immediate corrective action to reduce occupant exposure. Although initial indoor air sampling may yield analytical results below the action levels, additional samples should be collected during the winter season to evaluate the worst-case scenario associated with frozen soils and limited ventilation.
14. How do I gain access to a third party property in order to complete contaminant delineation for my site?
If contamination appears to have migrated from your site to a neighboring property, you will need to obtain access to the third party property to complete contaminant delineation. When possible, access should be requested as soon as the need becomes evident. Occasionally, a third party property owner may deny access for the investigation. The IDEM non-rule policy document (NPD), Access to Third Party Property, details the procedures for requesting access. Generally, IDEM does not intervene in access disputes unless the conditions outlined in the NPD have been met and access is considered vital for adequate investigation and remediation of the site.
15. Where can I find the most recent closure levels and guidance?
The most recent guidance and closure levels can be found in the guidance documents. The RISC Technical guide outlines the requirements for conducting site characterization and achieving closure.
16. What are the submittal guidelines for an Environmental Restrictive Covenant (ERC)?
The ERC Submittal Preparation Guidelines [PDF] detail the requirements for preparing and submitting an ERC for IDEM review. A template ERC is available online [DOC]. Following IDEM’s review and approval of the draft ERC, it will need to be recorded on the deed and a copy of the recorded Notice must be submitted, along with a signed and notarized affidavit verifying that the Notice is valid.
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