Technical/ASTM BDG Call

Overview of UST System Components and Leak Detection Methodology

Presented By:

Rick Turner – Jones & Frank

Michael Phelps – NCDEQ

February 11, 2016

EBA Tech/ASTM UST Call

Rick Turner – Retail Sales

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Piping Overview

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Piping runs to Dispenser Sumps

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Under Dispenser Containment

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Underground Piping system

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Underground piping – Main and Chase 

Main

Chase 

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Underground tank and piping system

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Spill Bucket and Overfill

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Tank Top equipment

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OPW EDGE Spill Container

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OPW 71SC Overfill Prevention Valve

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OPW 10BF Emergency Shutoff Valve 

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Department of Environmental QualityFebruary 11, 2016

Inspection Checklist

• Spill Buckets – look for cracks or other damage• Containment Sumps – Check for sump damage, fuel, condition of components• Corrosion Records for Steel UST systems

• Review last 2 Cathodic Protection Tests

• Leak Detection Records• Tank - Check last 12 monthly tank leak detection results. • Piping

• Pressurized Pipe – Annual Line Tightness Test or Monthly Monitoring and Annual Automatic Line Leak Detector (ALLD) functionality check

• Standard Suction Pipe – Line Tightness test every 3 years or Monthly Monitoring• Safe Suction Pipe – No Leak detection required

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Department of Environmental Quality

Basic UST operation requirements

• Spill Prevention Equipment at fill ports• Overfill Prevention

• Auto shut-off device (Flapper valve) – Set at 95% capacity or less• Ball Floats and Alarms – Set at 90% capacity or less

• Corrosion Protection – 3 main methods to comply• Made of materials that do not corrode

• Steel/CLAD or FRP Tanks• Flexible or FRP Piping

• Isolation from earthen materials• Cathodic Protection using sacrificial anodes or impressed current

• Corrosion Test every 3 years• Check the rectifier volts and amps every 60 days and record in log

• Leak Detection (In NC installations prior to 11/1/07)• Tanks

• Monthly Tank Leak detection that can detect a 0.2 gph release• Methods: ATG, SIR, Interstitial, Ground Water, and Vapor

Monitoring

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Department of Environmental Quality

Basic UST operation requirements

• Piping• Pressurized

• Annual Automatic Line Leak Detector check (3.0 gph operability check)• Annual Line Tightness Test (detect 0.1 gph) or a monthly monitoring method (detect

0.2 gph)• Suction

• Safe Suction - Exempt from Leak detection if meets certain requirements• Standard Suction – Line Tightness Test every 3 years or Monthly Monitoring (detect

0.2 gph)

• Leak Detection in NC for components installed after 11/1/07• 12 Months of Sensor Status and Alarm history reports

• Tanks: Double Wall with electronic Interstitial Monitoring• Hydro Static - Brine filled Interstice• Vacuum monitored • Pressure monitored• Liquid Detecting Sensor in interstice: Must also complete a 3rd party certified tightness

test every 3 years• Piping: Double Wall with electronic Interstitial Monitoring

• Open interstice to a containment sump with a sump sensor• First 3 tank methods listed above (no sites have used them in NC though)

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Department of Environmental Quality

Basic UST operation requirements

• Leak Detection in NC for components installed after 11/1/07• Piping: Double Wall with electronic Interstitial Monitoring

• Annual Automatic Line Leak Detector check (3.0 gph operability check for pressurized pipe)• Primary Line Tightness Test (detect 0.1 gph) every 3 years• Secondary interstice test every 3 years

• Containment Sumps: Do not need to be double wall• Annual Visual Check• Tightness Test every 3 years

• Spill Buckets: Double wall with electronic Interstitial Monitoring• Monitoring Methods: Hydro static, Pressure, Vacuum, or Liquid Float Sensor• Tightness Test every 3 years if using a Liquid Float Sensor

• Overfill Protection Equipment• Annual Operability Check

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Department of Environmental Quality

Leak Detection Overview

• Automatic Tank Gauging -Most common method of tank leak detection

• Statistical Inventory Reconciliation and Interstitial Monitoring –Next most common methods

• Fails, Inconclusive, Increase all must be investigated even if you get a passing result after the Fail.

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Department of Environmental Quality

Pipe ELLD

IM Sensor Status and Alarm History Reports

Tank ATG LD

Non-Compliance and Releases

• Primary areas of Non-compliance• Leak Detection

• Not implementing an LD method• No records to demonstrate LD being conducted• Not investigating failing results

• Cathodic Protection Systems• Not conducting 3 year test• Cathodic Protection system inoperative

• Primary areas for releases• Piping and fittings• Dispenser components• Spill buckets

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Department of Environmental Quality

Suspected Releases and defective equipment

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• In states without state program approval (SPA) and in Indian country• the new requirements will apply according to time frames specified in the 2015 UST

regulation.

• In states with SPA• none of the new requirements will apply until the state adopts the federal

requirements or if a state does not adopt the requirements, until EPA withdraws approval of SPA for that state. Owners and operators in states with SPA must continue to meet the state UST requirements.

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Federal UST Regulation ChangesWhat do these new requirements mean for owners and operators?

States with Approved UST Programs (SPA States)

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Federal UST Regulation Changes

• Operator Training and Secondary Containment• Operation and Maintenance Requirements• Walk through inspections

• Every 30 days• Spill Equipment and release detection equipment

• Annually• Release detection equipment operability testing• Containment Sumps and handheld release detection equipment

• Every 3 years • Spill Prevention Equipment Integrity Test• Overfill Prevention Operability Check• Containment Sump Testing

• Ball Float no longer allowed for new installation• Removes deferral from Release Detection for Emergency Generator Tanks

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Department of Environmental Quality

Federal UST Regulation Changes

• Removes deferral from Release Prevention and Release Detection for Field Constructed tanks and Airport Hydrant Systems

• Added specific requirements for notification and demonstration of fuel compatibility.• Added Groundwater and Vapor Monitoring Site Assessment Requirements• Internally Lined USTs must be permanently closed if the fail the lining inspection and cannot be

repaired.• Added requirement to do tightness testing following repairs for other parts of UST system other than

just the tank.

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Department of Environmental Quality

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Department of Environmental Quality

Questions?