Underground Storage Tank Regulatory Changes
By Edward S. Kubinsky Jr.
How many of us would purchase a new service truck for our fleet and never get the oil changed? How many of us would purchase a house and never perform any routine maintenance to protect our investment? There are things that need to be done to maintain these investments to make them last. A person cannot expect to purchase a car or a home and expect things to remain in like-new condition forever without some work. Then why would anyone expect an owner of a fuel dispensing facility to purchase and install equipment designed to protect his/her investment and never periodically verify that the equipment is functioning as designed, especially when so much is at stake if that equipment is faulty, fails or malfunctions?
UST equipment that fails to perform as designed can cause human health issues, environmental disasters, significant cleanup costs and, with the cost of fuel and slim margins these days, lost profits due to fuel that is released from the system. Nothing lasts forever. The idea of “install it and forget about it” is not a realistic concept. Federal regulations were written and upgrade requirements were put into place years ago to require owners of UST systems to do what they can to prevent releases of fuel into the soil or groundwater and protect our health and the environment. This was a good first step for our industry as well as for people and the environment. It provided many opportuni-ties for service companies. At that point in time, there was a serious need for owners of these facilities to
be more diligent about their equipment and preventing the fuel from being released from the system. With advancements in petroleum equipment, technology and resources, we are now at a point where the old regulations have left us with some voids that now need to be filled. After 20 years of implementation, the U.S. Environmental Protection Agency (EPA) has now opened up 40 CFR 280 (code of federal regulations for UST systems) for comment on how the regulations can be enhanced.
Below are some suggestions that I believe would help us all in meeting the end goal of providing the best overall protection of human health, the environment and our customers' investments in the equipment that they install at their UST facilities.
ATG Certification
On the federal level, there is no requirement to periodically verify that this equipment is functioning as designed and programmed if the manufacturer of the equipment states that the system is self-diagnostic. If the UST owner is knowledgeable and fully understands the value-added benefits of periodically checking the performance of their ATG systems and identifying and rectifying the problems, they'll do it as a “best practice.” However, for many owners/operators, if they're not required by law to test it, they will not do it, no matter what the benefit. Periodic maintenance and testing should not be “recommended” as they are by the manufacturer but should be “required” by regulation; otherwise there is a good chance that they will not be done and leaks may continue to go undetected. Periodic testing and inspection of these systems are integral parts of operating a tight UST system.
Containment Testing/Inspections
We are all aware now that spill buckets, tank sumps and dispenser pans were much needed and great ideas. They have prevented spills and leaks from getting into the ground for years, but this equipment was not designed to last forever. These integral system components in many cases are designed to be the last line of defense from a leak entering the environment. Yet this equipment has not been regulated. Based on experience and studies, it can be concluded that additional steps need to be taken to provide added protection from releases, including periodic maintenance and testing to verify that these components will contain a release from reaching the environment.
Spill buckets are the most used and abused pieces of equipment on a UST system and are probably the number one cause of petroleum releases even on the most sophisticated UST system designs. Some studies have shown that the useful life of a spill bucket may be as little as three to five years. Periodic testing of spill buckets to verify that they are liquid-tight should be the standard on a national level. In addition, manufacturers should make readily available the approved testing methodologies and procedures for verifying the performance of their equipment.
Verification of Operability/Compatibility of Overfill Protection Equipment
Similar to containment structures, overfill equipment is often installed in a tank and then forgotten. On a periodic basis, this equipment should be removed from the UST and inspected for any defects, and records of the inspection should be readily available. Also, the system should be evaluated to determine that the overfill device(s) installed meets current industry standards. It is not unusual to find overfill equipment that is improperly installed, broken or not functioning properly. Again, this service should be performed on a regular basis. The following should be checked:
 Overfill flapper valves - These should be removed from the tank and inspected to verify that the flapper is intact and still functional. They should be measured to verify that they are not set above 95 percent tank capacity.
Ball float valves - These should be removed from the tank and inspected to verify that the ball is still intact and moves freely up and down in the cage assembly. They should also be measured to verify that they are not set above 90 percent tank capacity. Ball float shall not be installed in certain UST configurations (per PEI and API):
- Where a suction system is installed with an air eliminator
- Where a coaxial stage I system is being utilized
- Where remote fills are used to fill the UST
- In USTs that receive a pressurized delivery
- If a ball float valve is installed as a secondary method of overfill protection and a flapper valve is installed as the primary method of overfill protection, the ball float must be installed at a height in the tank that is higher than the shut off of the flapper valve. If it is installed lower, the flapper valve will not function properly.
Electronic high level overfill alarms - Verify by removing the tank probe and sliding the float up the probe shaft that the overfill audible and visual alarms are operational. This service should be performed in conjunction with an annual
ATG certification.
Tightness Testing of All
Single-wall Tanks and Piping
Older existing single-wall tanks and piping represent a significant threat to human health and the environment. All single-wall tanks should be required to undergo a manual precision tightness test. This would greatly reduce the possibility of liquid or vapor releases going undetected for long periods of time. It can also prevent the possibility of water intrusion into tanks, which is of great concern especially with the infusion of ethanol additives in our fuels. Automatic tank gauges and statistical inventory analysis only reflect the status of the part of the tank that routinely contains product. With fuel prices nowadays, how many owner/operators are keeping a lot of inventory in their tanks? What about monitoring the rest of the tank that does not contain product? Shall we only monitor the bottom third of the tank?
All single-wall pressurized piping should be required to undergo an annual manual precision tightness test. Systems using annual tightness testing for their piping release detection would already be meeting this requirement; however, single-wall piping being monitored electronically (0.2 monthly test) does not undergo a manual precision tightness test that could identify leaks smaller than what is capable of being detected by the equipment monitoring it. If we can easily test for leaks with a threshold of .0100 gallons per hour with a great deal of confidence, why are we settling for a 0.2 monthly test to meet compliance? To put this into perspective, a pressurized line that continually passes a 0.2 gallon per hour test but leaks at 0.19 gph (1,664.4 gallons per year into the ground) is technically in compliance. Are we okay with this?
Testing of Tank and Piping Interstitial Spaces that Are
Not Continuously Monitored
Tank and piping interstitial spaces that are not continuously monitored by vacuum, pressure or brine solution should routinely be tested to ensure that the dry space will contain a release. Most of the time, these spaces are tested at installation only, and no follow-up testing is ever conducted to verify the integrity of the interstitial space until it's too late. There are double-wall piping systems that have releases to the environment due to the interstitial space not being tight and the liquid never reaching the interstitial sensor in the sump. These systems are not guaranteed forever either. If the piping system was checked periodically for tightness and the sensors were checked periodically for functionality, there would be a much higher probability of catching these releases before they get out. We now have the opportunity to make some significant changes to what is required to maintain our UST facilities in the best operating condition we can. We must embrace this opportunity and make some of these much needed and common sense changes. It might not be for another 20 years before this window will open up again.
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