PRODUCT LINE LEAK PRODUCT LINE LEAK DETECTIONDETECTION

(including a summary of the 2015 UST (including a summary of the 2015 UST regulations)regulations)

Katie SeabornKatie SeabornAMERICAN CONTAINMENT SERVICES, AMERICAN CONTAINMENT SERVICES,

INC.INC.®®

Annual GTEC Underground Storage Annual GTEC Underground Storage Tank Management & Compliance Tank Management & Compliance

Seminar – 2015Seminar – 2015

NEWNEW

Angle Check Valve

OR Foot Check Valve

SUCTION PUMP

Under Pump Check Valve

UST

1. Common Method

Product Pipe

2. Safe-Suction Method

Suction SystemsSuction Systems

SUCTION SYSTEM Leak SUCTION SYSTEM Leak Detection Requirements:Detection Requirements:

For COMMON systems (one is required):For COMMON systems (one is required): Product Pipe Tightness Test Every 3-YearsProduct Pipe Tightness Test Every 3-Years Monthly Interstitial MonitoringMonthly Interstitial Monitoring Monthly Groundwater OR Vapor MonitoringMonthly Groundwater OR Vapor Monitoring Monthly Statistical Inventory ReconciliationMonthly Statistical Inventory Reconciliation

For SAFE-SUCTION systems (all are required):For SAFE-SUCTION systems (all are required): Piping must slope back to the tank.Piping must slope back to the tank. Only one check valve, and it must be Only one check valve, and it must be

installed as close as practical to the pump.installed as close as practical to the pump. The above must be verifiable. The above must be verifiable.

Dispenser

Shear Valve

UST

Double-WallProduct Pipe

Submerged Turbine

PumpPump Motor

Pump Head

Pressurized SystemsPressurized Systems

Must be equipped with an Must be equipped with an automatic line leak automatic line leak detectordetector which must be which must be tested annuallytested annually, , ANDAND use use oneone of the following: of the following:

Annual Line Tightness TestingAnnual Line Tightness Testing Monthly Secondary Containment MonitoringMonthly Secondary Containment Monitoring Monthly Vapor or Groundwater MonitoringMonthly Vapor or Groundwater Monitoring Monthly SIR Monthly SIR

Additionally, the following is also required:Additionally, the following is also required: Annual Tank Gauge System InspectionAnnual Tank Gauge System Inspection Monthly Walk-Through Insp. w/ATG CheckMonthly Walk-Through Insp. w/ATG Check

PRESSURIZED SYSTEM PRESSURIZED SYSTEM Leak Detection Leak Detection Requirements:Requirements:

NEWNEWNEWNEW

Federal EPA Requirements for Automatic Federal EPA Requirements for Automatic Line Leak Detectors (LLDs):Line Leak Detectors (LLDs):

Can detect a 3-gallon per hour leak, at a line Can detect a 3-gallon per hour leak, at a line pressure of 10-psi, within 1-hour.pressure of 10-psi, within 1-hour.

When a leak is detected, LLDs must shut off When a leak is detected, LLDs must shut off the product flow, restrict the product flow, or the product flow, restrict the product flow, or trigger an audible or visual alarm.trigger an audible or visual alarm.

Must have a Third Party Certification.Must have a Third Party Certification. Must be tested for proper operation annually. Must be tested for proper operation annually.

More PRESSURIZED More PRESSURIZED SYSTEM Leak Detection SYSTEM Leak Detection

Requirements:Requirements:

Requirements for containment sumps Requirements for containment sumps used for interstitial monitoring of piping:used for interstitial monitoring of piping:If double-walled, the integrity of both sump If double-walled, the integrity of both sump walls must be monitored monthly.walls must be monitored monthly.Must be visually inspected annually.Must be visually inspected annually.Must be tightness tested every 3-years, using Must be tightness tested every 3-years, using pressure-decay or hydrostatic method, in pressure-decay or hydrostatic method, in accordance with the manufacturer, a nationally accordance with the manufacturer, a nationally recognized industry standard, or other method recognized industry standard, or other method determined by the implementing agency.determined by the implementing agency.

Leak Detection for Leak Detection for SECONDARY CONTAINMENT SECONDARY CONTAINMENT

/ INTERSTICES:/ INTERSTICES:NENEWW

No leaks at the STP or leak detectorNo leaks at the STP or leak detector No reduced flowNo reduced flow No liquids in secondary containment No liquids in secondary containment or or containment interstices containment interstices No alarms on electronic monitoring No alarms on electronic monitoring devicesdevices

PRESSURIZED SYSTEMPRESSURIZED SYSTEMLeak Detection Summary Leak Detection Summary

Checklists:Checklists:

MonthlyMonthly

AnnuallyAnnually

Leak Detector Functionality TestingLeak Detector Functionality Testing Product Line Tightness TestingProduct Line Tightness Testing Visual Inspection of all accessible piping, Visual Inspection of all accessible piping,

fittings, and secondary containmentfittings, and secondary containment ATG System Inspection and Functionality ATG System Inspection and Functionality TestTest

(Electronic Sump (Electronic Sump Sensor)Sensor)

FE Petro MLLDFE Petro MLLD

Mechanical Pressurized Line Mechanical Pressurized Line Leak Detectors Leak Detectors (MLLDs)(MLLDs)

Red JacketRed Jacket MLLDMLLD

Electronic Pressurized Line Electronic Pressurized Line Leak Detectors Leak Detectors (PLLDs)(PLLDs)

Incon PLLD’sIncon PLLD’sV/R PLLD’sV/R PLLD’s

ElectronElectronic Line ic Line Leak Leak Test Test

ReportReport

(Wireless (Wireless PLLD)PLLD)

Should be tested annually for proper detection of Should be tested annually for proper detection of a leak ata leak at

3-Gallons-Per-Hour (GPH), 0.2-GPH, and 1.0-GPH.3-Gallons-Per-Hour (GPH), 0.2-GPH, and 1.0-GPH.NEWNEW

MORE 40 CFR 280 MORE 40 CFR 280 RegulationsRegulations

Emergency Generator Tanks are no longer Deferred!Emergency Generator Tanks are no longer Deferred! Must perform walkthrough inspections every 30-days. Must perform walkthrough inspections every 30-days.

PEI RP 1200 “Recommended Practices for the Testing and PEI RP 1200 “Recommended Practices for the Testing and Verification of Spill, Overfill, Leak Detection and Secondary Verification of Spill, Overfill, Leak Detection and Secondary Containment Equipment at UST Facilities” and Containment Equipment at UST Facilities” and

PEI RP 900 “Recommended Practices for the Inspection and PEI RP 900 “Recommended Practices for the Inspection and Maintenance of UST Systems”Maintenance of UST Systems”

It is recommended that all records related to It is recommended that all records related to walkthrough inspections, periodic tests, repairs, and walkthrough inspections, periodic tests, repairs, and maintenance be maintained for a minimum of 3-years.maintenance be maintained for a minimum of 3-years.

Important revisions to 40 CFR 280.50 and 280.52, Important revisions to 40 CFR 280.50 and 280.52, regarding response to interstitial/secondary regarding response to interstitial/secondary containment alarms and suspected release reporting.containment alarms and suspected release reporting.

NENEWW

POP QUIZ!POP QUIZ!What kind of system is it, and what is required?What kind of system is it, and what is required?

Common Suction Method

Safe-Suction Method Pressurized

Line PTT Every 3-yrs, ORLine PTT Every 3-yrs, ORInterstitial Monitoring, OR Interstitial Monitoring, OR

Stat. Inv. ReconciliationStat. Inv. Reconciliation

No Leak Detection No Leak Detection Required for the Required for the

Product PipingProduct Piping

PUMP

UST

PUMP

UST

PUMP

UST

Annual LD Test AND Annual LD Test AND Annual Line PTT, OR Annual Line PTT, OR

Interstice Monitoring, OR Interstice Monitoring, OR Stat. Inv. ReconciliationStat. Inv. Reconciliation

POP QUIZ!... continued POP QUIZ!... continued What kind of system is it, and what is required?What kind of system is it, and what is required?

Annual Line PTT OR Annual Line PTT OR Stat. Inv. Reconciliation Stat. Inv. Reconciliation

AND AND Interstice Monitoring Interstice Monitoring

(if piping is double-wall)(if piping is double-wall)

Note: an anti-siphon valve Note: an anti-siphon valve is also a really good idea is also a really good idea

in this configuration! in this configuration!

UST

GRAVITY/SIPHONGRAVITY/SIPHON

SOLENOID VALVE

POP QUIZ!... POP QUIZ!... (last question)(last question)What kind of system is it, and what is required?What kind of system is it, and what is required?

UST

PUMP

EMERGENCY POWER

GENERATOR

SOLENOID VALVES

ATTENTION!!ATTENTION!!Leak Detection is no Leak Detection is no longer deferred for longer deferred for Emergency Power Emergency Power

Generator SystemsGenerator Systems

GRAVITY/SIPHONGRAVITY/SIPHONRequirements are Requirements are the same as the the same as the previous slide.previous slide.

Examples of what not to Examples of what not to do…do…

… … what is what is leak leak

detection detection reallyreally all all about?about?

At the end At the end of the of the day….day….

Any questions?Any questions?

Photograph courtesy of Mike Moreland PhotographyPhotograph courtesy of Mike Moreland Photography

Photograph courtesy of Mommy with her cameraPhotograph courtesy of Mommy with her camera