Presentation6

Releases Detecting, Preventing, Reporting

NOTICE

Ecology will “RED TAG” any UST system that does not have required spill prevention, overfill prevention, leak detection, or corrosion protection equipment

Release Detection Methods/Equipment

Tank Release Detection Automatic Tank Gauging (ATG) Interstitial Monitoring Inventory Control Manual Tank Gauging

Piping Release Detection Automatic Line Leak Detector Annual Line Tightness Testing Interstitial Monitoring or Sump Sensors

One form of release detection must be performed. Example: If ATG is not operating you must use another from of detection such as

SIR to stay operational

Cathodic Protection System

• Performance standard requirement for a steel UST

• Coated with a dielectric• External corrosion protection• Must be designed by a field corrosion

expert • Current then flows through the soil to the

UST system and returns to the rectifier through an insulated wire attached to the UST. The UST system is protected because the current going to the UST system overcomes the corrosion-causing current normally flowing away from it.

• Must be tested when installed every 3 years thereafter.

Release Detection Equipment

Dispenser

This is a typical gasoline-product dispenser. A containment basin is located underneath to collect any product that is released due to a malfunction in or below the dispenser . Any liquid in the catch basin must be removed and disposed of properly. Tanks must be monitored every 30 days for leak detection (frequent testing is encouraged for early leak detection).

Spill Bucket

This photos shows a typical fill sump. Surrounding the fill is a spill bucket that collects small releases of fuel during delivery and rainwater. Fill sumps should be kept free of debris and dry.

Release Detection

UST owners/operators must be able to detect a release from tanks or connected piping. Systems must be monitored every 30 days for releases

You must keep 5 years of release detection records Equipment must have 95% confidence of detecting a leak from any

portion of the system routinely containing product Equipment must be installed, calibrated, operated, and maintained per

manufacturer’s specifications , including routine maintenance It must meet certain performance claims You must use approved equipment, and it may only be installed and

serviced by certified technicians

Release Detection

Tanks of 1,000 gallons or less may use weekly tank gauging Emergency generator tanks of less than 2,000 gallons may use monthly

tank gauging in conjunction with annual tightness test, over 2,000 gallons must use weekly testing in conjunction with annual tightness test

tightness testing every five years, daily inventory control, automatic tank gauging, vapor monitoring, ground water monitoring, can be used as a form of tank leak detection in performance requirements of section

WAC 173-360-345 An automatic line leak detector or line tightness testing conducted by a

citified UST supervisor can be used as a form of pipe leak detection for pressurized or suction piping in performance requirements of section

WAC 173-360-350

Release Detection

Keep all records and paperwork onsite or readily available on release detection methods, including:

Performance Claims Third-Party Evaluations Testing Results Calibration, Maintenance, and Repair

Release Detection Both a suspected or confirmed release from tanks/piping must be reported to the Ecology WITHIN 24

HOURS (see regional contact numbers for your area on map below) Suspected releases must be investigated within 7 days of discovery If you have a tank with a confirmed release, product cannot be delivered to that tank. It is highly recommended that the leaking tank be emptied You must lock the fill pipe Emergency spills to waterways like catch basins contact number is 1-800-258-5990 (Emergency Operations Center of the Dept of Management) Reference: https://fortress.wa.gov/ecy/publications/91br11.pdf

Checking Product Level

A tank-gauging stick is one method for daily inventory control to determining level of product in the UST. Use the stick daily to cross-reference with sales and delivery volume as one method of UST leak detection. (measure to 1/8 of an inch)

At least two forms of leak detection is recommended such as tightness testing and automatic tank gauging if tank is larger than 1000 gallons

Statistical Inventory Reconciliation (SIR)

An outside vendor that analyzes inventory, delivery, and dispensing data collected over a period of time to determine whether or not a tank system is leakingInformation must be sent in monthly and Report kept on siteThe vendor uses sophisticated computer software to conduct a statistical analysis of the data and provides you with a test reportEquivalent to tank tightness testing, a SIR method must be able to detect a leak at least as small 0.1 gallons per hour and meet the federal regulatory requirements SIR meets federal leak detection requirements for new and existing USTs as follows with a:

0.2 gallon per hour leak detection capability meets the federal requirements for monthly monitoring for the life of the tank and piping

0.1 gallon per hour leak detection capability meets the federal requirements as an equivalent to tank tightness testing

Automatic Tank Gauging

A method of leak detection is automatic tank gauging. An ATG machine like the one pictured here has sensors that provide information like UST product levels and also detects leaks and water in the system. Sensors are located throughout the UST system. Most ATGs have a loud, audible alarm to notify facility personnel when a release is detected.

Automatic Tank Gauge Alarm

Automatic Tank Gauge Reports

Automatic Tank Gauge Reporting

Daily ATG performs a leak test and will alarm if not in compliance with federal

requirement leak rate of 0.2 gph from any portion of the tank

Monthly Recommended - keep one passing leak test printout per month for each tank

Annually ATG equipment inspected and calibrated Must be placed in test mode and report kept on file at site

Automatic Tank Gauge Reporting

Keep the following records for 5 years

Monthly ATG leak-test results printouts All calibration, maintenance and repair records for the ATG

Record Keeping ALL PERFORMANCE CLAIMS, TESTING RESULTS, CALIBRATIONS, AND

MAINTENANCE, ETC., MUST BE KEPT FOR 5 YEARS Report suspected and confirmed releases within 24 hours Keep records of the following:

Released substances Product found in soil Unexplained water in tanks, pipes, and spill buckets Alarm logs and response Erratic behavior in equipment unless found to be defective, not

leaking

Record Keeping

You must keep records of all written performance claims pertaining to any release-detection system used and the 3rd party evaluation and approval

Keep results of any sampling, equipment testing, or monitoring for 5 years

Keep written documentation of all calibration, maintenance, and repair of release detection equipment permanently located onsite or readily available

Any leak test results or other observations or results indicating a release must be reported within 24 hours as a suspected release