Presents EPA Compliance Basics Presenters Bill Tobias Director of Sales VeederRoot Carlton Knowles Territory Sales Manager VeederRoot Topics Tank Leak Methods and Testing Maintenance and Inspections ID: 614956
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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-RootSlide2
Topics
Tank Leak Methods and Testing
Maintenance and Inspections
2Slide3
Section 280.40
All 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 DetectionSlide4
Monitoring Methods-monitored every 30 days
Automatic Tank Gauging
Monitoring for Vapor in the Soil
Monitoring for Liquid on the Groundwater
Interstitial Monitoring
Statistical 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 TanksSlide5
Example Equipment:
An ATG that meets regulatory requirements (TLS-450PLUS)
Probes with Leak Detection capability for each tank
Leak 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 activitiesWhat 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 Control
The ATG must be operated in one of the following modes:
Static testing (i.e.
Veeder
-Root’s 0.2 SLD test) conducted every 30 days
Continuous in-tank leak detection (i.e. Veeder
-Root’s CSLD mode) operating on an uninterrupted basis
Magnetostrictive
ProbeATGSlide6
ATG Tank Testing Technology
1990s
1981
Static Leak Detection (SLD ) monthly 0.2
gph
precision test introduced2015CSLD for Manifolded 20,000 gal tanks
1988Static Leak Detection (SLD) annual (0.1 gph) precision test introduced1994Continuous 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 installationsSlide7
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 daysSlide8
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 daysSlide9
Interstitial Monitoring requires secondary containment
Secondary 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 tank
Brine-filled for Wet Monitoring
Dry 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 ConstructionInstallation of Interstitial Sensor
Compliance MethodsSlide10
Method 4: Interstitial Monitoring (cont.)
Sensors for Interstitial Monitoring
Dipstick with Water or fuel paste
Non-Discriminating Liquid Sensors for dry space – detects presence of any liquid
Discriminating Liquid Sensors for dry space – detects presence of hydrocarbons
Hydrostatic 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 sensorsNon-discriminating liquid sensor (fiberglass tank)Non-discriminating hydrostatic sensor
Secondary Containment Vacuum Sensing
Compliance MethodsSlide11
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 ATGSlide12
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 period2) 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/week7) Tank Tightness Testing + Inventory controlSlide13
4) Interstitial Monitoring
best solution, prevents any contamination outside barrier
5) SIR
6) Manual Tank Gauging (< 2,000 gallons only)
7) Tank Tightness Testing + Inventory controlDouble 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, 2018
Owners 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
2015Slide15
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 yearsNo required testing of annular space of tanksNo required testing of annular space of pipingSlide16
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 controllerOwners 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 detectorEnsure 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 inchVacuum pumps and pressure gaugesEnsure there is proper communication with sensors and the controllerHand-held electronic sampling equipment associated with groundwater and vapor monitoringEnsure the device operates properlySlide17
Questions / Contact Information
Technical Support
1-800-323-1799 M-F 8am to 7PM Eastern Time
technicalsupport@veeder.com
www.veeder.com/supportSlide18
Thank You!