Stage I Vapor Recovery Testing

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1 Stage I Vapor Recovery Testing Results of Testing for NESHAP Regulations 40CFR63 Part CCCCCC ASTSWMO Conference March 2, 2011 Brad Hoffman

2 Outline Overview of NESHAP Regulation and Equipment Requirements Stage I Vapor Recovery Testing Requirements Static Pressure (Pressure Decay) Test Pressure Vacuum Vent Valve (PV Vent Cap) Test Results of Tanknology Testing Program in 2010

3 Overview of Regulation National Air Toxic Standards for Gasoline Dispensing Facilities 40CFR63 Subpart CCCCCC This is part of NESHAP National Emission Standards for Hazardous Air Pollutants This presentation covers basic equipment and testing requirements. For complete text of regulation including detailed requirements, definitions, and notification and recordkeeping requirements and deadlines see:

4 Basic Equipment Requirements GDF s with < 10,000 gallons throughput/month Tight fill (Gasketed seal on fill pipe) GDF s with 10,000 gallons throughput/month Tight fill with submerged drop tube No more than 12 from bottom if installed before 11/09/2006 No more than 6 from bottom if installed after 11/09/2006 Diagram from CARB Some tank owners may choose straight cut for safety reasons.

5 Requirements for GDF s with 100K thruput Either comply with Table 1, or Have an existing vapor balance system prior to 1/10/2008 that s in compliance with an enforceable rule that requires 90% emissions reduction.

6 Requirements for GDF s with 100K thruput GDF s with 100,000 gallons throughput/month All of above, and operate a vapor balance (Stage I) system Vapor connections seal upon disconnect (dry-break) Vapor line from tank to tanker truck must be vapor-tight Vapor recovery and product adaptors must prevent overtightening or loosening during deliveries (swivel adaptors or locking collars/clamps?) Vapor balance system designed to not exceed 18 w.c. pressure or 5.9 w.c. vacuum in tank truck during delivery Any separate gauge port must have drop tube as above Must have Dual Point system if installed after 11/09/2006 Requirements from Table 1 OPW 633LC OPW 61SA Swivel Fill and Vapor Adaptors OPW 61VSA

7 Testing Requirements Applies to sites with 100K gal/month throughput P/V Vent Valve Test Pressure Decay Test Revision in January 2011 may allow alternate test ST-30. Currently under review by EPA.

8 Overview of Testing Requirements For GDF s with throughput of 100,000 gallons or more per month Pressure Decay Test (Static Pressure Test) Initially and every 3 years Per CARB TP Determination of 2-Inch W.C. Static Pressure Performance of Vapor Recovery Systems of Dispensing Facilities amended March 17, 1999 Pressure/Vacuum (P/V) Vent Valve Test Initially and every 3 years Per CARB TP-201.1E Leak Rate and Cracking Pressure of Pressure/Vacuum Vent Valves, adopted October 8, 2003

9 Deadline for Testing Test by July 10, 2011 for systems installed before 12/15/2009. Test upon installation for new systems.

10 Pressure Decay Test - Overview Prior to 1998 most tanks had an annual tightness test that included the ullage space. But now most tanks have ATG or SIR and never have the ullage space checked for leaks, which allows the potential releases of fuel and vapors into the environment. The Pressure Decay Test verifies the tightness of the entire vapor recovery system, including tank top fittings, vent and vapor piping, and tank ullage space.

11 Pressure Decay Test Procedure 1. Nitrogen is introduced to the system at a rate between 1 & 5 CFM. 2. Stabilize pressure at 2.0 w.c. 3. The Vapor Manifold Test is conducted by verifying pressure on the PV vent cap, dry breaks or other fittings on the UST. 4. The Pressure Decay test is a 5 minute test with readings taken every minute.

12 Pressure Decay Test Requirements No fuel delivery within 3 hours before starting a test. The minimum ullage for each individual tank shall be 1000 gallons or 25% of the tanks capacity. The maximum total ullage for all manifolded tanks shall not exceed 25,000 gallons. No dispensing is allowed within 30 minutes of the the test. There should be no A/L testing within 24 hours of the test. Caps must be removed from fill and vapor adaptors. Referenced alternate ST-30 (1994) test procedure allows for testing with fill caps on. The current version (2002) requires testing with caps off. Currently under review by EPA Air Toxics Group.

13 Pressure Decay Test Equipment A Vapor Coupler Test Assembly (poppet adaptor) can be used to hook the hose to the UST. There is a bolt on the inside of the adaptor that depresses the check valve in the dry break to allow nitrogen into the system. 1 PSI Relief Valve

14 Pressure Decay Test Pass/Fail Criteria Measure product level in USTs to calculate the amount of allowable decay for the test. The allowable decay rate is calculated by the total amount of ullage space in the combined USTs and quantity of nozzles on site (for Stage II systems). Example: Use the tank charts or ATG system for this calculation. 3 tanks all are 10,369 gallons with 20 balance nozzles. Regular tank has 9125 Gallons; Midgrade has 8085; Premium has The ullage space is calculated by subtracting the amount of product in the tank from its total capacity = 1244; = 2284; = 770 Total Ullage space = 4298 ( ) Look up on the chart for balance systems the allowable decay for 4298 gallons of ullage with 20 nozzles. This criteria applies to systems with Stage II Vapor Recovery. For GDF s with only Stage I use the chart for (1-6) Assist Nozzles.

15 Pressure Decay Test Balance Criteria This chart is from the TP Test Procedure for Balance Systems. When the ullage space does not match exactly round up to the closest value on the chart. The chart gives the allowable decay for the example from the prior page. In this case the pressure can fall from 2 w.c. to 1.65 w.c. For sites without Stage II use the chart for Assist Systems With 1-6 Nozzles on the next page.

16 Pressure Decay Test Assist Criteria This chart is from the TP Test Procedure for Assist Systems. For Stage I sites without Stage II use the chart for Assist Systems With 1-6 Nozzles. When the ullage space does not match exactly round up to the closest value on the chart. For a Stage I system with 4500 gallons of ullage, the pressure may drop from 2.0 w.c. to 1.79 w.c.

17 Pressure Decay Test - Troubleshooting Troubleshooting is the key to the test. It is always good to have a vapor detector to detect vapors. Step 1 in troubleshooting is to use the vapor detector and or soapy water to begin searching for a leak. The soap and water when sprayed on a leak will bubble and allow you to visibly see where the leak is located. It is important to double check each fitting since the air movement may effect the leaking vapor.

18 Pressure Decay Test - Troubleshooting Spill Containers Drain valves and cracks PV Vent Caps & connections Fill Adaptors (gaskets) Dry Break Adaptor for Stage I Gasket and Poppet Valve Drop Tube Leaks and o-rings Remote Fills STP Packer Manifold O-ring ATG Caps and Cord Grips Fill/Vapor Caps Vent stack joints Vent and Vapor Recovery Piping Tank Manway gaskets Tank Tops (bungs, fittings, risers) Dispensers Nozzle (Internal Check Valve) Hose Breakaway Whip Hose Dispenser piping Vacuum Pumps

19 Pressure Decay Testing Results Results for Tanknology s 2010 Testing Program *Many tests require troubleshooting to locate and repair leaks. 72% of sites were able to pass during the first visit after troubleshooting and minor repairs were completed. 28% of sites failed and required additional repairs, even after troubleshooting and minor repairs. Includes manifolded and individual tests. Number of Tests 3412 Number that Passed* (* includes minor repairs) 2465 Percent that Passed* (* includes minor repairs) 72% Number with Failures 947 Percent with Failures 28%

20 Pressure Decay Failures STP Sump Possible leaks in STP Sump Manway Vent Piping LD Vent Tube Extractor Fitting STP O-Ring

21 Pressure Decay Failures - Tank Crack in fiberglass tank view from inside

22 Pressure Decay Failures - Tank Leaking tank manway gasket

23 Pressure Decay Failures - Riser Severely Corroded Riser Pipe

24 Pressure Decay Failures - Riser Severely Corroded Riser Pipe

25 Pressure Decay Failures Riser Severely Corroded ATG Riser and Bad Cap

26 Pressure Decay Failures - Riser Severely Corroded Vapor Recovery Riser

27 Pressure Decay Failures LD Vent Tube Leak Detector Vent Tube on STP

28 Pressure Decay Failures LD Vent Tubes Leaking Vent Tubes from Leak Detectors

29 Pressure Decay Failures Vent Piping Cracked Vent Line. Had been damaged by installation of anode for C.P. system. Anode

30 Pressure Decay Failures Vent Piping Leaking Vent Pipe Flex Connector inside boot

31 Pressure Decay Failures St. II Piping Stage II Vapor Recovery Piping

32 Pressure Decay Failures Vent Piping Vent Pipes cut by concrete saw

33 Pressure Decay Failures Vent Pipe cut by concrete saw

34 Pressure Decay Failures Vent Pipes cut by concrete saw during upgrade. Shown during repair.

35 Pressure Decay Failures Vent Pipe cut by concrete saw. Patched with tape???

36 Pressure Decay Failures Vent Pipe with slot cut by concrete saw during upgrades. Patched with tape and buried.

37 Pressure Decay Failures Vent Risers Holes in vent pipe during installation of cover sleeve

38 Pressure Decay Failures Dry Break Dry Break Poppet Valve Stage I V.R. Adapter

39 Pressure Decay Failures ATG Cap Corroded ATG Riser and Cap

40 Pressure Decay Failures ATG Cap Corroded ATG Riser and Cap

41 Pressure Decay Failures ATG Cap Leaking ATG Cap Compression Fitting

42 Pressure Decay Failures ATG Cap ATG Cap Broken Cord Grip

43 Pressure Decay Failures Spill Container Leaking drain valve in spill container (soap test)

44 Pressure Decay Failures Spill Container Spill Container cracked at riser threads

45 Pressure Decay Failures Spill Container Cracked Spill Container Note the crack at the spill bucket drain blank location. Seems as though the bucket is thinner where the drain bore is, and if someone overtightens a 4 inch nipple, then a crack appears.

46 Pressure Decay Failures Spill Container Cracked Spill Container

47 Pressure Decay Failures Drop Tube Drop Tube mangled

48 Pressure Decay Failures Drop Tube Coaxial Poppeted Drop Tube Spring Broken

49 Pressure Decay Failures Drop Tube Drop Tube flange is broken off

50 Pressure Decay Failures Drop Tube Drop Tube incorrectly installed

51 Pressure Decay Failures Drop Tube Extra holes drilled in drop tube When tubes were assembled in field, the installer drilled 3 separate holes in top of tube and collar instead of using factory supplied holes. As a result, all four factory holes leaked in all six tubes. I did as customer asked, and filled holes with epoxy and retested. All repaired tubes passed.

52 Pressure Decay Failures Drop Tube Field Fabricated Drop Tube (for E-85) Leaking

53 Pressure Decay Failures Drop Tube Drop Tube Weep Holes Repaired with Seal-Fast?

54 Pressure Decay Tests Minor* Repairs Many minor repairs are performed during testing Replace Parts Gaskets on fill/vapor adaptors Caps on fill/vapor adaptors Gaskets in caps on fill/vapor adaptors Drain valves in Spill Container PV Vent Caps Caps on ATG riser Cord grips on ATG cap O-rings on STP O-rings in Drop Tubes Vent tubes on Leak Detectors Drop Tubes Repair weep holes in Drop Tubes with epoxy Hoses/Nozzles/Breakaways for Stage II Locations *Minor Repairs may add up to significant cost

55 Pressure Decay Test Major Repairs Vent Piping Risers (Fill Pipe, ATG Pipe, Vapor Recovery) Tank Top Fittings Tank Manway Gaskets Tank Leaks Remote Fill Piping and Drop Tubes Vapor Recovery Piping (for St. II areas) Dispenser Vapor Piping (for St. II areas) These major repairs usually require the services of a pump and tank contractor and may require excavation

56 Unusual Vapor Recovery System Vapor Balance System? Dual Point System? Dry Break is in the STP sump under a 36 manhole cover. How would this ever be utilized?

57 Unusual Vapor Recovery System Dry Break frozen under ice. Dual Point system? Has this been maintained? How would this be utilized?

58 PV Vent Valve Testing - Overview Pressure/Vacuum (PV) Vent Valves are installed at the top of the vent pipe for a gasoline storage tank. They are also called PV Vent Caps. The PV Vent Caps are designed to hold a slight pressure to prevent gasoline vapors from escaping and a slight vacuum to prevent excess outside air from entering the tank. For safety reasons, the PV vent caps have valves that open at predetermined settings if excessive pressure or vacuum builds up in a tank. Some tanks have an independent PV vent caps and sometimes the vent pipes are manifolded together (either above or below grade) and there s only one vent cap installed.

59 PV Vent Valves - Specifications Table 1 to Subpart CCCCCC of Part 63 Applicability Criteria and Management Practices for Gasoline Dispensing Facilities With Monthly Throughput of 100,000 Gallons of Gasoline or More (g) Pressure/vacuum (PV) vent valves shall be installed on the storage tank vent pipes. The pressure specifications for PV vent valves shall be: a positive pressure setting of 2.5 to 6.0 inches of water and a negative pressure setting of 6.0 to 10.0 inches of water. The total leak rate of all PV vent valves at an affected facility, including connections, shall not exceed 0.17 cubic foot per hour at a pressure of 2.0 inches of water and 0.63 cubic foot per hour at a vacuum of 4 inches of water.

60 Models of PV Vent Caps Only precision PV Vent Caps will be able to meet these requirements. Rain Caps that are open to atmosphere won t hold any pressure or vacuum. Some PV Vent Caps have the wrong pressure and vacuum settings. Some PV Vent Caps have been certified by CARB but certification isn t required in most other states. The following pages show some of the available models of PV Vent Caps with ratings that may meet the requirements.

61 PV Vent Caps (EBW & Emco) EBW Emco Wheaton A0084 Should be available with proper pressure and vacuum settings. New samples tested tight but older models didn t pass. New Part No A Screw-on A Clamp-on

62 PV Vent Caps (OPW) OPW 523V OPW 623V (old) OPW 623V (new) 523V " Size Thread-on. 3" wc pres., 8" wc vac. 523V " Size Slip-on. 3" wc pres., 8" wc vac. 623V " Thread-on 623V " Thread-on Some older versions of these caps may have cracking pressures from w.c. but current OPW specs are w.c. Some existing caps might be able to pass tests. Not recommended as replacements. 623V was been de-certified by CARB for EVR but should be o.k. in most other states.

63 PV Vent Caps (Husky and Morrison) Husky 4885 or 5885 Morrison Bros. 749-CRB 4885 may be used anywhere except in CA is certified by CARB. Should be available with proper pressure and vacuum settings.

64 Four tests required for each PV Vent Cap 1. Positive Leak Rate Test at 2.0 w.c. Measures how much air (vapor) can leak past the valve before it cracks open. 2. Positive Cracking Pressure at 120 ml/min Measures the amount of pressure it takes to cause the valve to open up. After the valve cracks it won t hold quite as much pressure. 3. Negative Leak Rate Test at 4.0 w.c. Measures how much air can leak past the valve before it cracks open. 4. Negative Cracking Pressure at 200 ml/min Measures the amount of vacuum it takes to cause the valve to open up when vacuum is building up. After the valve cracks it won t hold quite as much vacuum.

65 Thresholds for Individual Tests 1. Positive Leak Rate Test at 2.0 w.c. Must be 23.6 ml/min (0.05CFH) 2. Positive Cracking Pressure at 120 ml/min Must be between w.c. 3. Negative Leak Rate Test at 4.0 w.c. Must be 99.1 ml/min (0.21 CFH) 4. Negative Cracking Pressure at 200 ml/min Must be between 6.0 and 10.0 w.c. (unless other manufacturer specifications apply) Caps must meet total leak rate requirements for the entire site as well. See next page for details. These thresholds are based on Federal EPA rules for tests required every 3 years. Other standards may apply for other tests done per local Stage II Vapor Recovery regulations.

66 Threshold for All Valves at one site In addition to passing the individual tests, the leak rates for all valves at each site must be added together. The total leak rate of all valves must meet following: 1. Positive Leak Rate Test at 2.0 w.c. Must be 80.2 ml/min (0.17 CFH) 3. Negative Leak Rate Test at 4.0 w.c. Must be ml/min (0.63 CFH) Caps must meet individual specifications as well. See prior page for details. Conversion Factors: 1 CFH = ml/min 1 ml/min = CFH

67 PV Vent Cap Tester Front View Digital Manometer 0 20 w.c. range with at least 0.5% accuracy ml/min Flow Meter for Vacuum Tests ml/min Flow Meter for Pressure Tests Directional Valve

68 A. Positive Leak Rate Test 1. Open valve on pressure flow meter slowly until pressure stabilizes at 2 w.c. on digital manometer. 2. Stabilize for 10 seconds (+/ w.c.) 3. Record flow rate in ml/min from flow meter. 4. Multiply by to get flow rate in CFH. Example: 13 ml/min x = CFH PASS Record flow in ml/min Stabilize pressure at 2 w.c. INWC 2.00 Must be 23.6 ml/min or 0.05 CFH to pass (unless other manufacturer requirements apply) AND total of all caps must be 80.2 ml/min (0.17 CFH)

69 B. Positive Cracking Pressure 1. Open the by-pass valve. 2. Open valve on pressure flow meter until flow stabilizes at 120 ml/min. 3. Close by-pass valve. 4. Observe manometer. 5. Record highest pressure achieved (cracking pressure) before pressure drops. Set flow to 120 ml/min Then record cracking pressure INWC 3.20 Must measure between w.c. to pass (unless more stringent manufacturer requirements listed on cap)

70 C. Negative Leak Rate 1. Connect nitrogen hose to venturi vacuum generator. 2. Open vacuum flow valve slowly until manometer stabilizes at -4 w.c. 3. Stabilize vacuum for 10 seconds (+/ w.c.) 4. Record flow rate in ml/min from flow meter. 5. Multiply by to get flow rate in CFH Example: 27 ml/min x = CFH PASS Stabilize vacuum at -4 w.c. INWC Record flow in ml/min Must be 99.1 ml/min or 0.21 CFH to pass (unless other manufacturer requirements apply) AND total of all caps must be ml/min (0.63 CFH)

71 D. Negative Cracking Pressure 1. Open the by-pass valve. 2. Open valve on vacuum flow meter until flow stabilizes at 200 ml/min. 3. Close by-pass valve. 4. Observe manometer. 5. Record highest pressure achieved (cracking pressure) before pressure drops. Then record cracking pressure Set flow to 200 ml/min INWC Negative pressure is the same as Vacuum Must be between -6.0 and w.c. to pass (unless more stringent manufacturer requirements listed on cap)

72 Field Data Sheet Record the Manufacturer s specified leak rates on the form. Record readings in ml/min and then calculate CFH. Each valve must pass all 4 tests in order to pass, AND The total leak rate for the site must be under the limits (0.17cfh and 0.63cfh)

73 PV Vent Valve Tests Findings Most old Non-EVR caps won t be able to pass test. New EVR-type caps should be able to pass test. Sites with 4 or more vents may have trouble passing for total leak rate. These sites may need to have vents manifolded in order to pass, or else have vent valves with very low leak rates.?

74 PV Vent Valve Testing - Findings Vent pipes must be threaded to accept EVR type PV Vent Valves. Slip-on adapters may be acceptable in some areas, but not in CA. Vent Valves may need to be cleaned prior to testing in order to pass (with soapy water no oils or lubricants). PV Vent Valves are precision devices and may need annual maintenance to remain functional. Follow manufacturer s recommendations. OPW 523V-1150 or 523V-3100

75 PV Vent Cap Testing Results - Overall Overall Results for Tanknology s 2010 Stage I Testing Program 39% of vents had caps that passed the test, including some that were installed by tank owner in preparation for test. 61% of vents had caps that failed the test. The number of Failed tests includes vents with rain caps and other non-evr type caps that weren t rated for 3 w.c. pressure and 8 w.c. vacuum. TOTAL NUMBER OF EXISTING VENT CAPS 9552 Number Passed 3755 Percent Passed 39% Number Failed 5797 Percent Failed 61%

76 PV Vent Cap Testing Results by Make/Model Test results for the most commonly found newer-style PV Vent Caps Doesn t include rain caps or wrong-model type caps Doesn t include results of new replacement caps Some vent caps had been installed prior to the testing program, while other caps may have been installed for many years. Some caps may have been cleaned prior to testing as allowed by the inspector or regulatory agency. Make of Cap Husky Husky Morrison OPW OPW Model of Cap CRB 523V Series 623V Series Total Existing Caps Number Passed Percent Passed 85% 94% 78% 51% 95% Number Failed Percent Failed 15% 6% 22% 49% 5%

77 PV Vent Cap Testing - Failures Rain Caps Don t have Pressure or Vacuum Poppet Valves No Caps Present Not able to be tested Very common at GDF s that have never been tested. Must install and test new caps

78 PV Vent Cap Testing - Failures Wrong Model or Older Version PV Caps Wrong pressure and vacuum settings. Usually won t hold proper amount of pressure or vacuum. Usually leak more than allowable leak rate. Sometimes have red or blue or gray decal instead of yellow. Older Caps Gaskets hardened Springs rusted or broken Filled with dust/debris Examples of some older OPW vent caps. Model Number Pressure/Vacuum Settings Label 523V oz pres., 1/2 oz. Vac. Red 523V oz pres., 1/2 oz. Vac. Blue 523V oz pres., 1/2 oz. Vac. Silver

79 PV Vent Cap Testing - Failures Multiple Vents Will probably exceed the total allowable leak rate for site Especially for existing older style caps Will need to have vent pipes manifolded together

80 PV Vent Cap Failures Found empty shell with internal valves missing. How? Why?

81 PV Vent Cap Failures Vent Cap contains sawdust of some type???

82 Overall Results of Testing Program Stage I Vapor Recovery System that won t release vapors into the atmosphere. Tight tank-tops and vapor piping to prevent leaks into the tank backfill Cleaner environment for everyone.

83 Final Points & Questions If Stage II systems are abandoned due to widespread-use then GDF s will need to comply with Stage I regulations. Which agencies will enforce and interpret regulations (Region EPA Air Offices or State Agencies)? Will the alternate ST-30 Test Procedure be allowed? Deadline for testing has been extended to July 10, 2011.

84 For Further Information Brad Hoffman VP Engineering and R&D Tanknology N. Mopac Expressway Suite 500 Austin, TX (800) (512) bhoffman at tanknology dot com Credits have been given whenever possible for references to other companies or photos from outside sources. Please contact me with any concerns.

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