Perspective on Petroleum Fuel Storage Systems

•2

UST Program- Where Are We ?

Presented by Ray Leather

In the beginning …..There were leaks. Lots

of them.

4

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

10

Tanks/Piping/Dispensing

11 techshout.com

Breakaway

Shear/Crash Valve

Corrosion Protection

12

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)

13

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.

14

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

23

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

27

• 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?

28

29

Inventory Control?

30

Least Utilized Capital Asset Device ?

31

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

32

> 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

34

How did this staining occur?

39

Unused Tank Bung………

40

Spill & Overfill Protection

42

nationalpetroleum.net

DW Spill Bucket

43

44

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;

45

Spill & Overfill Protection

46opwglobal.com

Spill & Overfill Protection

47

epa.gov

95%

(B) Flapper DropTube

uga.org

Spill & Overfill Protection

48

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?)

49

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

50

> 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.

51

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

52

For Underground Piping:

Leak Detection

Product present in pan?

Remove debris

Why is product here?

Check the dispenser pans!!

54

> So what does a passing test mean to you?

> 0.1 GPH

> 95% Probability of detection

> 5% Chance of false alarm

55

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

56

57

58

59

Petroleum and Biofuels: What’s the

Difference

60

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

61

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

62

• 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

63

65

Effects of water table on precision tank

testing

66

Vacuum Tank Testing

67

Vacuum Tank Testing

68

Leak rate – what does it mean

70

71

Same Sump in 6 years

72

Some sumps get it and some don’t

73

Concentration

74

75

Summary

76

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

78

79

80

81

Common UST Problem Areas

82

How Tight Should Systems Be?Tracer Tight Method certified to 0.005 GPH

83

Questions and Answers