Reporting Spills and Releases

Written by: Brian Pottebaum, Director of Training Services

Owners and operators of petroleum storage tank systems must be prepared to respond to a release before it happens. Proper preparation and due diligence can help prevent releases to the environment and save you money. These basic release response steps should be taken to minimize damage to the public, environment, and your business:

• Employees must have a basic understanding of the UST system, including overfill prevention and spill protection devices;
• Employees must know the location of the Emergency Shut-off (ESO) switch;
• Spill response equipment and supplies must be readily accessible;
• Maintain personal protective equipment (PPE) on site and ensure employees know how to properly use this equipment;
• Employees must be trained on how and where to identify and respond to alarms; and
• Emergency contact information and instructions must be appropriately located onsite.

What Needs To Be Reported?  Iowa law requires facility owners and operators to report “suspected” and “confirmed” petroleum releases to the DNR within 24 hours of discovery, or within 6 hours of discovery if a “hazardous condition” exists.  If a release is suspected, the owner or operator must immediately investigate and determine whether a confirmed release to the environment has occurred. The confirmation results must be reported to the DNR within seven (7) days.

What is a “suspected petroleum release”?  A release is “suspected” if you or a UST professional discovers evidence to suggest that a petroleum release to the environment may have occurred. Examples include:

• The discovery of petroleum outside of the UST system such as the presence of free product or vapors in soils, basements, sewer and utility lines, and nearby surface water;
• Unusual UST system operating conditions such as the erratic behavior of product dispensing equipment or submersible pump/line leak detector, the sudden or unexplained loss of product from the UST system, or an unexplained presence of water in the tank, unless system equipment is found to be defective but not leaking, and the defective component is immediately repaired or replaced;
• Internal tank inspection results reveal perforations, corrosion holes, weld failures, or other similar defects; and
• Monitoring results from a release detection method that indicate a release may have occurred unless it is disproved by another acceptable means.

What is a “confirmed petroleum release”?  A release is “confirmed” if subsequent findings indicate that a petroleum release to the environment has occurred, such that petroleum or other regulated substances have breached the UST system or touched the surface material (concrete/asphalt), backfill material, soil, groundwater, or surface water. This includes:

• Soil or groundwater sample analytical results for any petroleum constituent exceed the DNR’s contamination corrective action levels;
• There is a spill or overfill from the UST system (exceeding 25 gallons);
• There is an affected receptor (e.g., petroleum discovered in a utility trench, which can be attributed to the UST facility or the UST facility cannot be ruled out as a source);
• Drinking water supplies are contaminated, which can be attributed to the UST facility or the UST facility cannot be ruled out as a source;
• Vapors are observed in buildings or structures which can be attributed to the UST facility or the UST facility cannot be ruled out as a source;
• Free product is observed in the environment or in monitoring well used for release detection or LUST monitoring;
• Stained soil is observed; and
• Sheen is observed on surface water.

How do I report this to the DNR?  The DNR has a helpful guidance and the required spill/release report forms available on the internet at http://www.iowadnr.gov/InsideDNR/RegulatoryLand/UndergroundStorageTanks/USTOwnersOperators/USTReleaseReporting.aspx. This information is also available in the DNR guidebook called “Underground Storage Tanks – The Basics”, which is provided to all participants of the Iowa Class A/B Operator Training Seminars presented by R&A Risk Professionals/PMMIC.

To report a release, you must first contact the DNR Emergency Response, then the DNR field office in the region where the release occurred, and then the UST Section at the DNR central office. Contact information is as follows:

What about my insurance?  Contact PMMIC IMMEDIATELY if you suspect a release has occurred.  The 24-hour number is (515) 334-3001.  It is very important to stop the source of a release and to determine the cause of a release as soon as practical.  If you contact a UST service company to repair any part of a UST system that is suspected of leaking or allowing a release, it is very important that the condition of the component be photo-documented before and after any repair. Take the pictures yourself if your service company does not.  Take pictures before the repair has begun.  Do not allow any damaged or repaired component to be removed from the site; you should retain any component that has been replaced.Once the release is stopped, you will need to take action to minimize the impact from the release.  PMMIC will work with you and your groundwater professional to take immediate steps as necessary.