john wagner rehs, cem - neiwpccneiwpcc.org/tanks2010old/presentations/tuesday...
TRANSCRIPT
John Wagner REHS, CEM
Southern Nevada Health District
When the SNHD inspector saw the CSLD PERIODIC
TEST FAIL alarm at the facility’s annual UST
inspection, he quickly asked the owner “how long has
this been on?” Surprised at the inspector’s concern,
the owner calmly responded, “6 Months.”
22nd Tanks Conference and Expo
Boston, MA September 21, 2010
The Emperor's New Clothes
• Technical aspects of CSLD leak detection
• Common technician errors
• Need for additional owner/operator training
• Site characterization protocol
• Inspector testimony before State Petroleum Fund Board
• Final Outcome
Today’s case study will highlight:
The Emperor's New Clothes
• Three single wall 1991 Owens Corning FRP tanks.
• Veeder-Root TLS 350 running CSLD
• Annual Line tightness tests.
Everything was great until…
The Emperor's New Clothes
The alarm goes
off again…
Sep 08
CSLD rate tables are reset
Reset 1
A different technician
responds…
Reset 2
The Emperor's New Clothes
Sep 08
CSLD rate tables are reset
The alarm goes
off again…
A different technician
responds…
Reset 1 Reset 2 Reset 3
The Emperor's New Clothes
Sep 08
SNHD performs inspection
Reset 1 Reset 2 Reset 3 Mar 09
The Emperor's New Clothes
Sep 08
Reset 1 Reset 2 Reset 3 Mar 09
The Emperor's New Clothes
Sep 08
Nevada Petroleum Fund Board
Reset 1 Reset 2 Reset 3 Mar 09
The Emperor's New Clothes
Sep 08
Reset 1 Reset 2 Reset 3 Mar 09
Site characterization and remediation
The Emperor's New Clothes
Some additional insights:
• Proper response to Periodic Failure
• Owner/Operator training
• Normally open/Normally closed
• Rewiring probes to run monthly tests
•The importance of Diagnostic mode to inspectors.