Like a bear in hibernation near the end of a long winter, ready to wake at the wrong time, a long out-of-compliance and possibly illegal underground oil storage tank (UST) at Harvard Elementary School has many watchful eyes upon it. It is 9 feet in diameter, 25-feet-long, and holds 10,000 gallons of oil. It is eight years overdue for re-certification. As-built plans seem not to exist.
What are the liabilities of having an uncertified underground tank? What needs to be done to bring the tank into compliance with regulations? Should a different system be implemented? What are the costs associated with the various solutions? How did this situation develop? For the past few months, town officials have been tackling these questions.
Several months ago, one of the Harvard water commissioners asked Mark Force, facilities manager for the schools, for information on the storage tank due to concerns about several wells in the area. Force, who is fairly new in his position, had been having the tank’s oil-level monitoring gauge checked and logged daily (to track consumption), but knew nothing about the actual tank because no records had been left behind. There was a monitoring system on a wall of the boiler room for the tank, but at the time of the water commissioner’s question no one knew what it was monitoring; there was no documentation associated with it.
The water commissioner’s single inquiry cascaded into a series of questions as the larger picture emerged, and today the efforts to get at the root of the problem and its solution involve the School Committee, the Fire Department, the Board of Health, the Harvard Energy Advisory Committee (HEAC), engineering consultants, and anyone who can be found who had anything to do with the school’s renovation in 1988, when the tank was installed. By law, it was to be re-certified in 15 years, but there is no record that that was ever done.
The School Committee asked HEAC to lend its expertise in the matter. HEAC studies energy consumption, and part of that involves examining heating systems in town buildings. HEAC member Rene Roy volunteered to look into the system and the properties of the tank. Since then, he has been working as much as detective as engineer, uncovering a complex patchwork of people and information, and piecing it together like a giant puzzle.
The first thing Roy set out to find were the as-built plans to determine what kind of tank was installed. State regulation requires all single-wall tanks to be removed by 2017, so the type of tank was a concern. Normally storage tanks come under the jurisdiction of the Fire Department, but Roy found that the fire chief had no record of the tank’s existence. He found that the Board of Health and the building department also had no documentation. In 1981, the board of selectmen took responsibility for oversight on underground storage tanks from the fire chief and gave it to the Board of Health. However today’s BOH is not aware of having this responsibility. The selectmen had the minutes to meetings traced to the 1981 article, however no subsequent documentation was found to show that the BOH conducted any UST inspections or evidence of any permit issued (as is required) for the installation and storage of fuel oil.
The hunt was on for documentation. While searching town records for clues, Roy explored the boiler room as well. Monitors in the tank are connected through a conduit to the control panel in the boiler room. This was as close to the tank that he could get because all of the inspection ports had been buried below grade. When unearthed, they were found to have been sealed shut. Roy speculates they were glued shut for fear of children removing the covers and falling in. Roy discovered the leak-monitoring alarm system on a wall, and in researching it found this system is used only for double-walled tanks. That was good news (as was the fact that its lights were green, meaning no leaks were detected). He also was able to locate documentation on how to use the system, despite the fact that its manufacturer has been out of business since 1995.
Roy began calling one company after another in a search for an engineer who could assess the entire system. Eventually, he found someone who knew the design engineer of the leak-monitoring system, a man in his eighties who referred him to other companies he could call, where at last he found Dana Hall of DM3 Petrol Services in North Brookfield. Hall had been certified by the manufacturer of the monitoring system in 1981. He was invited to do an assessment, and determined that the system had in fact been working since it was installed 1988. The bad news was this system no longer meets today’s requirements for monitoring and must be replaced. He also looked at how the tank was situated and determined that in order to obtain certification, the fill pipe, vent, and all inspection wells would have to be located and made accessible. Hall is working on a cost estimate for this and related work.
While Roy was searching for plans at Town Hall, HEAC member Jack Spero recalled someone in town, John Lee, that had been involved in the schools renovation. In Lee’s attic, a bid document was found that contained descriptions of a tank but there was no clue as to the relevance of what exists. However, it was a lead. Eventually Roy did find a roll of pre-construction drawings in one of many large boxes stacked on the stage of the second floor of what he referred to as Town Hall’s “random-access filing system.” These were proposal plans, showing the tank in a different location from where it was placed. After an exhaustive search that did not turn up as-built plans, the assumption for now is that they were not done, possibly to save money.
The School Committee considered several scenarios and associated costs presented by Roy for resolving this crisis. One solution was to bring the tank up to code; another was to remove the tank and bring in a new gas line. (The current gas pipe serves only the cafeteria and is not big enough.) Yet another solution was to use both gas and oil, replacing the burners with a dual gas/oil burner. At the April 13 School Committee meeting, there seemed to be unanimous agreement that spending upward of $30,000 to bring an aging tank up to code was not the best solution, and that converting to natural gas was. An engineering design study for the conversion was approved for $5,600, from which a bid document can be created. It will cost less to remove the tank than to update it. A cost-benefit analysis is needed to determine the payback period for switching to natural gas, but it was acknowledged that gas is plentiful in North America, is cheaper than oil, and burns more efficiently. Roy is looking to have actual costs by mid-May, and the committee would like to see installation of the new system begin in the summer.
As for the responsibility for oversight, the committee is reviewing the Massachusetts Fire Marshal’s Rules and Regulations, which state that oversight of underground storage tanks is in the fire chief’s domain.
