Veeder-Root Company

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Veeder-Root Company - Description

Presents: EPA Compliance Basics. Presenters: Bill Tobias, Director of Sales, Veeder-Root. Carlton Knowles, Territory Sales Manager, Veeder-Root. Topics. Tank Leak Methods and Testing. Maintenance and Inspections. ID: 614956 Download Presentation

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Veeder-Root Company




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Slide1

Veeder-Root Company

Presents: EPA Compliance Basics

Presenters: Bill Tobias, Director of Sales, Veeder-Root

Carlton Knowles, Territory Sales Manager, Veeder-Root

Slide2

Topics

Tank Leak Methods and TestingMaintenance and Inspections

2

Slide3

Section 280.40All regulated tanks must have release detection so that leaks are discovered quickly before contamination spreads from the UST site. You must provide a method of release detection (often also called leak detection) that allows you to meet four basic requirements:You can detect a leak from any portion of the tank that routinely contains petroleum; andYour leak detection is installed and calibrated in accordance with the manufacturer's instructions; andYour leak detection is operated, maintained, and tested in accordance with the manufacturer's instructions; andYour leak detection uses one of the seven methods described in the federal regulations (section 280.43).

EPA Requirements for Tank Leak Detection

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Monitoring Methods-monitored every 30 daysAutomatic Tank GaugingMonitoring for Vapor in the Soil Monitoring for Liquid on the Groundwater Interstitial MonitoringStatistical Inventory Reconciliation (SIR)or Weekly Manual Tank Gauging*Annual Tank Tightness Testing + (Daily Inventory Control or Manual Tank Gauging)**

For tanks installed after April 11, 2016, Interstitial Monitoring will be the only permissible method

* Limited applicability, tanks under 2,000 gallons

** Limited applicability, tanks installed < 10 yrs

State and local regulations may differ from the federal requirements. Contact your local agency to ensure you meet those requirements.

Release Detection

Methods for Tanks

Slide5

Example Equipment: An ATG that meets regulatory requirements (TLS-450PLUS)Probes with Leak Detection capability for each tankLeak testing software for CSLD

Compliance Methods

Method 1: Automatic Tank Gauging Systems

An ATG system detects leaks through highly accurate inventory measurements combined with the tracking of delivery & dispensing activities

What are the regulatory requirements?ATG must be able to detect a leak of 0.2 gallons per hour with a 95% probability of detection and with a false alarm rate of 5%.The ATG must perform Inventory ControlThe ATG must be operated in one of the following modes:Static testing (i.e. Veeder-Root’s 0.2 SLD test) conducted every 30 daysContinuous in-tank leak detection (i.e. Veeder-Root’s CSLD mode) operating on an uninterrupted basis

Magnetostrictive

Probe

ATG

Slide6

ATG Tank Testing Technology

1990s

1981

Static Leak Detection (SLD ) monthly 0.2 gph precision test introduced

2015CSLD for Manifolded 20,000 gal tanks

1988Static Leak Detection (SLD) annual (0.1 gph) precision test introduced

1994Continuous Statistical Leak Detection (CSLD) introduced for single tanks3.0 gph gross test added to ATG

2010s

2000s

1980s

1994

CSLD for

Manifolded

10,000 gal tanks

2000’s

Interstitial monitoring grows in popularity

2016

Interstitial monitoring required for all new installations

Slide7

Demonstrating Compliance with an ATG

Method 1: ATG System using SLD

A Tank Leak Test History – PASSED TEST RESULTS

should be printed or archived every 30 days

Slide8

Demonstrating Compliance with an ATG

Method 1: ATG System using CSLD

A Tank Leak Test History – PASSED TEST RESULTS

should be printed or archived every 30 days

Slide9

Interstitial Monitoring requires secondary containmentSecondary containment provides a barrier between the tank or piping system from the environment The barrier holds the leak between the tank and the barrier so that the leak is detected. Barriers include:Double-walled USTs, in which an outer wall completely surrounds the primary tankBrine-filled for Wet MonitoringDry Space (annulus) for Dry MonitoringImpermeable excavation liners that partially or completely surround the tank.Internally fitted liners (bladders)

Method 4: Interstitial Monitoring

Example - Double-Walled Tank Construction

Installation of

Interstitial Sensor

Compliance Methods

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Method 4: Interstitial Monitoring (cont.)

Sensors for Interstitial MonitoringDipstick with Water or fuel pasteNon-Discriminating Liquid Sensors for dry space – detects presence of any liquidDiscriminating Liquid Sensors for dry space – detects presence of hydrocarbonsHydrostatic Sensors for Brine-filled wet space – detects a change in the level of a monitoring liquid between the walls of a double-walled tank.Secondary Containment Vacuum Sensing - checks for a change in condition that indicates a hole in the tank, such as a loss of vacuum What are the regulatory requirements?The interstitial monitor must be checked at least once every 30 days.

Example Equipment: Interstitial SensorATG for continuously monitoring sensors

Non-discriminating liquid

sensor (fiberglass tank)

Non-discriminating hydrostatic sensor

Secondary Containment Vacuum Sensing

Compliance Methods

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Method 4: Interstitial Monitoring

A Sensor Status Report should be printed or archived every 30 days

Method 2: Vapor Monitoring

Method 3: Groundwater Monitoring

Demonstrating Compliance with an ATG

Slide12

What is the right compliance method for your site?

Single Wall Tank Applications (Must choose one)

1) Automatic Tank Gauging System

CSLD – best solution for high throughput sites with little/no quiet period

SLD – best solution for sites with quiet period

2) Vapor Monitoring for low water tables

not recommended due to delay in detection and potential for

wet sensors.

3) Groundwater Monitoring for high water tables

not recommended due to delay in detection. Contamination

has already occurred

5) SIR

Best solution for sites with monthly throughput above CSLD maximums and no quiet time

6) Manual Tank Gauging (< 2,000 gallons only)

not recommended as tank is out of use >36 hours/week

7) Tank Tightness Testing + Inventory control

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4) Interstitial Monitoring  best solution, prevents any contamination outside barrier5) SIR 6) Manual Tank Gauging (< 2,000 gallons only)7) Tank Tightness Testing + Inventory control

Double Wall Tank Applications (Must choose one)

What is the right compliance method for your site?

Slide14

Revised EPA Regulation Timeline

2016

July 15, 2015

EPA published the 2015 underground storage tank regulation

Oct 13, 2018Owners and operators must conduct the first test or inspection:Spill prevention equipment testing Overfill prevention equipment inspections Containment sump testing for sumps used for piping interstitial monitoring Release detection equipment testing Walkthrough inspections

Oct 13, 2015Flow restrictors in vent lines may no longer be used to meet the overfill prevention requirement at new installations and when an existing flow restrictor is replaced

April 11, 2016Owners and operators must begin meeting the requirement for:Secondary containment and interstitial monitoring for new and replaced tanks and piping Under-dispenser containment for new dispenser systems

2018

2017

2015

Slide15

Changes to Operation & Maintenance

Beginning Oct 13, 2018 owners and operators must…Inspections: Conduct walkthrough inspections at their UST Facility every 30 daysTesting: test electronic and mechanical components of release detection equipment annuallyTesting: test overfill prevention equipment every 3 yearsTesting: test spill prevention equipment every 3 yearsTesting: test containment sumps every 3 years

No required testing of annular space of tanks

No required testing of annular space of piping

Slide16

Release Detection Equipment Testing

No later than October 13, 2018 owners and operators must perform their first annual test to make sure release detection equipment is working properly. Test electronic and mechanical components for proper operation using one of the following options:

Automatic tank gauge and other controllersTest the alarmVerify the system configurationTest the battery backupProbes and sensorsInspect for residual buildupEnsure any floats move freelyEnsure any shafts are not damagedEnsure the cables are free of kinks and breaksTest the alarm operability and communication with the controller

Owners and operators must maintain records of release detection equipment testing for at least (3) three years. The record must include each component tested, whether each component passed the test or needed to have action taken, and any action taken to correct an issue.

Automatic line leak detector

Ensure the device activates (alarms, restricts flow, or shuts off flow) within an hour when simulating a release equivalent to 3 gallons per hour at 10 pounds per square inch

Vacuum pumps and pressure gauges

Ensure there is proper communication

with sensors and the controller

Hand-held electronic sampling equipment associated with groundwater and vapor monitoring

Ensure the device operates properly

Slide17

Questions / Contact Information

Technical Support

1-800-323-1799 M-F 8am to 7PM Eastern Time

technicalsupport@veeder.com

www.veeder.com/support

Slide18

Thank You!


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