Post on 28-Jul-2020
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UST Program- Where Are We ?
Presented by Ray Leather
In the beginning …..There were leaks. Lots
of them.
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UST Compliance - Background> 1984 - Congress created Underground Storage Tank Program
The UST Program was developed in response to problems created by the over 2 Million Operating UST’s identified in 1984, many old and leaking, threatening groundwater
> 1988 – New Regulations Passed – Under RCRA
> 1989 – New Requirements Start• Phase-In of Leak Detection Begins, including Tank/Line
Tightness Testing (Annual/5Yr) • New tanks must have spill/overfill, corrosion protection
> 1998- Existing Tanks Upgrade Deadline• Spill, Overfill Prevention• Monthly Leak Detection• Corrosion Protection• Many upgrades were little more than “Band-Aids”
> 2005 Energy Act
> 2015 – New EPA Regulations (40CFR280)
EPA UST Leak Sources
Study of 473 Releases
> Spill Buckets: 43%
> Dispensers: 12%
> Tanks: 9%
> Piping: 16%
> STP: 3%
> Delivery Vehicles: 3%
> Flex Connectors: 2%
> Other: 12%
Tanks/Piping/Dispensing
Today Two Major Types of Underground Tanks:
(with third hybrid )
> Double-walled Steel
> Double-walled Fiberglass reinforced plastic (FRP)
tanks, using materials compatible with the product
to be stored therein.
Note: Single-walled steel tanks must be removed by
8/7/2017, but there are exceptions-consumptive tanks
Note: Massachusetts Required DW system on January 1989
Tanks/Piping/Dispensing
nationalpetroleum.net
Tanks/Piping/Dispensing
npnweb.com
DW Piping
Suction vs. Pressure Piping System
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Tanks/Piping/Dispensing
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Breakaway
Shear/Crash Valve
Corrosion Protection
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epa.govchemline.net
bushman.cc
Buried steel tanks and piping will corrode if not protected
or replaced by non-corrodible (FRP/Synthetics)
components.
Lots of Paperwork
Registrations/Notifications/Permits
• FP 290 (Now FDR - DEP DMS online reporting)
• FP2A Application to store (Township)
• FP2 License for Storage (Township)
• FP5 Registration (Township)
• FP 289 Third Party Inspection Reports – Now TPIR
• License to Sell Motor Fuel ( Div. of Standards)
• FP 290 part 3 – Permit to maintain storage facility (No longer required)
• FP290 R – Notification to remove UST (Now DEP DMS online reporting)
• FP 291 – Receipt of disposal of UST formerly used for motor fuel
• FP 292 – Application for removal/transportation of UST
• Self-Service Motor Fuel Facility Applications (State and Local FD)
• COC (Certificate of Compliance) or other Financial Assurance
• FP 6 – Application for Standard Permit(s) and Flammable Storage Permit (Fire Department)
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Regulatory/Environmental/ABC’s
310 CMR 80.02 CLASS A/B Knowledge Areas1. Tanks and piping;
2. Regulated substances stored;
3. Leak detection;
4. Spill prevention;
5. Overfill prevention;
6. Corrosion protection;
7. Emergency response procedures;
8. Product compatibility;
9. Financial responsibility documentation requirements;
10. Registration and other notification requirements;
11. Reporting and record keeping requirements;
12. UST testing requirements;
13. Temporary and permanent closure requirements;
14. The Class B operator qualifications, training and examination requirements and Class C operator qualifications and training requirements.
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Inspections
Tank Stick broken off in Drop Tube
Dispenser Sump & Shear Valve
Tank Top Sump
Poor Examples
Poor Examples
Where is the
submersible pump?
Poor Examples
Water in spill bucket Product in spill bucket
Mechanical Leak Detector
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Shear Valves
•Required on all pressurized systems
•Shut off the flow of gasoline in the event of an accident
•Shear plane must be mounted flush with top of dispenser island
•Must be anchored to dispenser island
Location of Shear Valves
Shear Valves
Shear valve not anchored
Shear valve held open with socket wrench
Shear valve held open with piece of wood
Shear valve held open with wrench
Inventory
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• Massachusetts Now 1% plus 130 gallons (over/short)
Was previously ½ of 1% of throughput reconciliation
• Based on actual daily measurement and of tank
product and water levels and actual sales, use, and
receipts.
– Measurement by gauge, gauge stick, or readout from
automatic tank gauging system.
– Include daily computation of gain or loss.
Inventory
> Abnormal Loss:
• Loss not explainable by spillage, temperature variations, or
other causes, in excess 1% + 130 gallons of the volume of
product dispensed over a period of a calendar month.
• If so, must be investigated
• What could be causes?
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Inventory Control?
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Least Utilized Capital Asset Device ?
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WHY?
> Typical average cost of ATG system $10,000+
> Primarily used as a stand-alone device
> Primarily used as a glorified dip stick
> Primarily used only by store clerk/manager for inventory
> Typically, release conditions are often ignored –WHY?
> Full capabilities of system untapped
Purpose of ATG System
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> As a dipstick: Determines product volume and water
> Performs periodic tank tightness testing
> Performs interstitial and secondary containment sensor
monitoring
> Piping with ELLD (Electronic Line Leak Detection)
> Overfill Alarm Annunciation
> Facilitates Fuel Management (Throughput/Deliveries)
> Alarm Communication
> Provides for recordkeeping (ATGs with printer)
Sensor out alarm Fuel alarm
Liquid Sensor alarm
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How did this staining occur?
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Unused Tank Bung………
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Spill & Overfill Protection
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nationalpetroleum.net
DW Spill Bucket
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Spill & Overfill Protection
Overfill Prevention
• Automatic shut off (flapper) at 95% full
• High level alarm or flow restriction (ball float valve) set at
no more than 90% full;
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Spill & Overfill Protection
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Spill & Overfill Protection
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epa.gov
95%
(B) Flapper DropTube
uga.org
Spill & Overfill Protection
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peijournal.org
90%
(A) High Level Alarm
Leak Detection
> What is a leak?
» A release of product from an Underground Storage Tank.
» Loss of 0.1 gallons per hour during a Tank Tightness Test
» Loss of 0.2 gallons per hour measured by a continuous tank
monitoring system. (ATG – Static Test or via CSLD)
* Continuous Statistical Leak Detection (what is it?)
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Note: Test methods must meet a probability of detection
of 0.95 and probability of false alarm of 0.05.
Leak Detection
> On Site Consumptive Use
fuel oil tanks
> Tanks for emergency power
generators and tanks used
for both consumptive use
and emergency power
> Waste oil tanks
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> All other tanks
Requirements (what is wrong with this slide)
• Exempt Tanks • Non-Exempt Tanks
Leak Detection
Line tightness test must be able to detect a leak of 0.1
gallons per hour at 1.5 times the normal operating
pressure.
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For Underground Piping:
Leak Detection
Pressurized Piping:
Each Pressurized Piping run must have an Automatic Line Leak Detector and one other method of leak detection
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For Underground Piping:
Leak Detection
Product present in pan?
Remove debris
Why is product here?
Check the dispenser pans!!
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> So what does a passing test mean to you?
> 0.1 GPH
> 95% Probability of detection
> 5% Chance of false alarm
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Product Compatibility/Regulated
Substances> Blended fuels must be compatible:
Tank or internal tank lining;
Piping;
Pipe adhesives and glues;
Line leak detectors;
Flexible connectors;
Fill pipe;
Spill and overfill prevention equipment;
Submersible turbine pump and components;
Fittings, gaskets, bushings, couplings, and boots;
Containment sumps
> O-rings, gaskets, filters and sealants
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Petroleum and Biofuels: What’s the
Difference
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In general, petroleum fuels:
• Are not electrically conductive, and therefore not
corrosive
• Do not significantly swell or permeate thermoset
plastics (FRP tanks, piping, sumps)
• Do swell and permeate some elastomeric
materials
• Do not mix with water
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In General, Alcohol Fuels:
•Are electrically conductive and therefore more
corrosive
•Are capable of permeating some thermoset,
thermoplastic, and elastomeric materials
•Contain chemical groups that increase
chemical activity, reactivity
•Significantly increase rate of biodegradation
•Mix with water (but phase separation will
occur)
Water Solubility
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• Petroleum fuels hold about 100 ppm water,
beyond that, water settles out as a separate
phase
• Alcohol fuels hold 4,000 - 40,000 ppm (E10
–E85), beyond that, alcohol & water mixture
settles out as a separate phase
E10 (or greater) Questions &
Concerns
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Effects of water table on precision tank
testing
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Vacuum Tank Testing
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Vacuum Tank Testing
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Leak rate – what does it mean
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Same Sump in 6 years
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Some sumps get it and some don’t
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Concentration
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Summary
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The accelerated corrosion in STP
sumps can mostly be explained by
biological degradation of fugitive
ethanol in vapors to acetic acid
Must have three things in sump:
Ethanol
Water
Bacteria
Alternative Testing Methods- Tracer
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Common UST Problem Areas
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How Tight Should Systems Be?Tracer Tight Method certified to 0.005 GPH
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Questions and Answers