RP900: Recommended Practices for the Inspection and Maintenance of UST Systems

Transcription

1 RP900: Recommended Practices for the Inspection and Maintenance of UST Systems Brad Hoffman VP Engineering and R&D Tanknology PEI/NACS 2017: Fuels & Fuel Equipment October 19, 2017

2 Overview Comprehensive guide for inspecting and maintaining UST s. RP900 is the only code of practice listed in the 2015 EPA regulations as alternate procedure for walkthrough inspections. More thorough than the minimum EPA requirements. Drawn from the collective experience of equipment manufacturers, contractors, regulators, and owner/operators. Represents the consensus of the committee members Not 100% unanimous - some decisions were made by majority vote.

3 PEI s Recommended Practices for the Inspection and Maintenance of UST Systems have been developed and published as an industry service by the PEI UST System Inspection & Maintenance Committee, composed of the following members: Brad Hoffman, Chairman Tanknology, Inc. Austin, Texas Scott C. Boorse Wawa Inc. Wawa, Pennsylvania Laura Fisher California SWRCB Sacramento, California Ron Fulenchek 7-Eleven Stores Dallas, Texas Ryan Haerer U.S. Environmental Protection Agency Washington, D.C. Eric Hick CGRS, Inc. Fort Collins, Colorado Jim Howard Speedway LLC Edison, New Jersey Wes Loflin NE Louisiana Wholesale Oil and Gas Monroe, Louisiana David J. Piercey JD2 Environmental, Inc. West Chester, Pennsylvania Ed Rachins Mutual Oil Company Brockton, Massachusetts Ben Thomas UST Training Clinton, Washington Sonny Underwood Mid-South Steel Products, Inc. Cape Girardeau, Missouri Brian Wiegert R&A Risk Professionals Urbandale, Iowa Jeff Lexvold Xerxes Corporation Minneapolis, Minnesota John C. Scandurra WMRS Brewster, New York

4 Updates from 2008 Edition Meets 2015 EPA requirements for Walkthrough Inspections Considered over 100 comments submitted by industry Moved many testing procedures to RP1200 Appendix: Water Management in Storage Systems Inspect for corrosion on shutoff valves, ball float valves, and tank top sumps. New annual inspection checklist can be easily adapted for each facility. Two new tables were added to clarify which inspection steps apply to specific UST components.

5 RP900: Daily Inspection Leak Detection ATG functional & no alarms Daily Inventory o.k. No Complaints (Slow-Flow) Tank Area Fill cover in good condition Spill bucket clean & dry Fill cap tight Fill pipe not blocked Not required part of EPA walkthrough inspections. Don t forget dispensing equipment.

6 RP900: Monthly Inspection Leak Detection Results Tank Equipment At-grade inspection of fill equipment (covers, spill buckets, drop tubes) Tank gauge stick* Water in tanks Vents Spill Kit St. I V.R. Cover/Adapters Observation Wells CP Rectifier Unmonitored Dispensers & STP s Similar to EPA requirements. New to RP900 *more frequent than EPA

7 RP900: Annual Inspection Sump Inspections (STP, Fill, Other) ATG Equipment & Functionality Leak Detection Devices Tested Overfill Prevention (inspect, verify, and look for corrosion)* Other Test Results (CP, St. I or II Vapor Recovery) Under Dispenser Inspection Similar to EPA requirements. New to RP900 *more frequent than EPA

8 Comparison to EPA Regulations

9 IN-DEPTH INFORMATION FROM WEBINAR: One-hour video from webinar held 9/19/ Search YouTube PEI RP900 Webinar

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11 Recommended Practices for the Testing and Verification of Spill, Overfill, Leak Detection and Secondary Containment Equipment at UST Facilities Ed Kabinsky PEI/NACS 2017: Fuels & Fuel Equipment October 19, 2017

12 Initial Document Timeline May 2010: Initial committee appointed by PEI January 2011: 1 st face-to-face meeting June 2011: 2 nd face-to-face meeting Jan. 24 March 26, 2012: Comment period open April 2012: 256 comments reviewed by committee August 2012: Document published

13 Document Revision Timeline Open comment period once a document is published (August 2012) Comment period ended 01/29/ comments received December 2016: Face-to-face meeting to review all comments May 2017: Document published

14 Current Committee Members

15 2017 Changes to Original Document Affirmation that in hydrostatic testing of sumps, the test water should be a minimum of 4 inches above the uppermost sump penetration or sump sidewall seam (whichever is higher). This group is a great cross section of industry experts who almost unanimously believe this is the best procedure for ensuring containment sumps are liquid-tight. Affirmation of the 2012 recommendation that ball float valves should be removed and replaced with another type of overfill prevention device. Vacuum testing standards for double-walled tanks in Chapter 4 have been changed to bring greater consistency to the procedures for interstitial integrity testing of fiberglass and steel tanks (both 10 Hg vacuum instead of 6 Hg for steel and 10 Hg for FRP). Definitions in Chapter 2 are reworded to match language used in other PEI recommended practices. Comment now at:

16 Overfill Prevention Inspection Ball Float Valve RP1200 Pass/Fail Criteria

17 Overfill Prevention Inspection Ball Float Valves - What if I can t remove? Knock out ball and install drop tube device. Really? Unexpected shower

18 Containment Sump Testing

19 PEI/RP 1200 Section 6 Spill Bucket and Containment Sump Testing Complements PEI/RP Section 8.5. Provides directions and guidance to achieve compliance with the amended EPA regulations. Took into consideration spill bucket and containment sump manufacturers testing requirements along with testing requirements that have been used by a state agency since 2005.

20 PEI/RP 100 Section 8.5: Containment Sumps All containment sumps, regardless of location or construction, must be liquid-tight, both to contain spilled or leaked product and to prevent groundwater or surface water intrusion. Wait a minute! These sumps are supposed to be liquid-tight?

21 PEI RP 1200 Pre-Test Procedure for Testing Containment Sumps Thoroughly inspect, clean and make any necessary repairs to the containment sump to be tested. Install test boots on secondary piping so as not to introduce water into the secondary piping. Remove any sensors from the containment sump.

22 PEI RP 1200 Test Procedure for Testing Containment Sumps Add water to the containment sump to a minimum of 4 above the highest penetration or sidewall seam. Place a measuring stick in the water to allow for accurate measurement. Prevent sump from being disturbed. Take an initial measurement. Wait 1 hour. Take a final measurement.

23 PEI RP 1200 Pass/Fail Criteria for Testing Containment Sumps If the water level changes 1/8 or greater over the 1-hour test period, the test is considered a fail.

24 PEI RP 1200 Post Test Procedures for Testing Containment Sumps Remove all water and properly dispose (test water may be reused in most cases consult AHJ). Reinstall any sensors that may have been moved to perform the test. Remove any test boots from secondary piping. Inspect and reinstall all containment sump lids, gaskets and covers.

25 What About Regulations? Some states require (by rule) a containment sump to be liquid-tight on all sides, bottoms and penetrations. If this is the case, what s the best way to determine this? Several states have already commented that low-level testing will not be acceptable in their states. Additionally, some states require containment sumps be completely filled in order to test. On the other hand, some states have said that they will consider low-level testing. CONSULT THE AHJ BEFORE CONDUCTING ANY CONTAINMENT TESTING!!!!! The vast majority of the PEI RP 1200 committee believes that what is in the document is the best way to ensure containment sumps are maintained liquid-tight. The committee feel that if a state wishes to allow some form of alternative or low-level testing to occur, that is their business. However, the committee did not believe that low-level testing is the best practice for performing containment sump testing and confirming sump integrity. Many comments were received on this issue, and it was thoroughly discussed in the meetings.

26 New Regulations Are Coming, Be Ready! WA OR NV CA ID UT MT WY CO ND SD NE KS MN IA MO WI IL MI OH IN KY WV NY PA MD VA NC VT NH NJ DE ME MA RI CT Washington D.C. AZ NM OK AR MS TN AL GA SC AK TX LA FL HI Green = SPA State that still needs to update current regs BLUE = Non-SPA State where EPA regs are effective now Red = new state regs are now effective!!!

27 Manuch Nikanjam, Ph.D., PE PEI/NACS 2017: Fuels & Fuel Equipment October 19, 2017

28 Fuels & Fuel Equipment John Eichberger October 19, 2017

29 Future of Fuels John Eichberger Executive Director

30 The Fuels Institute is Disclaimer: The opinions and views expressed herein do not necessarily state or reflect those of the individuals on the Fuels Institute Board of Directors and the Fuels Institute Board of Advisors, or any contributing organization to the Fuels Institute.

31 Major Trends Affecting Fuels Market Projected Population Increase Million Metro % of US Population 56% 63% 69% 75% 77% 80% 84% Source: Urbanization, Fuels Institute

32 Flight to urban areas on its seventh decade U.S. Metropolitan Development ( ) 60% Suburbs U.S. POPULATION (PERCENT) 50% 44% 40% 33% 30% 20% 23% Central City Nonmetro 51% 33% 16% 10% 0% Source: Urbanization, Fuels Institute

33 Younger generations heading to cities 45% Age Groups Living in MSA Central Cities RATIO OF EACH AGE GROUP (PERCENT) 40% 35% 30% 25% 20% 15% 10% 33% 33% 35% 36% 40% 5% 0% to to to to Linear (20 to 34) Source: Urbanization, Fuels Institute

34 Younger generations delay growing up PERCENT OF AGE GROUP WITH DRIVERS LICENSES 100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% 91.4% 95.7% 93.3% 92.5% 89.1% 86.4% 81.5% % Source: Driver Demographics, Fuels Institute

35 Headlines and Projections

36 Autonomous, EV ridesharing services will be 10x cheaper than personally owned vehicles The economics will drive rapid, disruptive consumer adoption Within 10 years of AV approval, 95% of US VMT will be via new AV, EV ridesharing services est Oil will drop to low $20 s per barrel OEMs, dealerships, gas stations, etc. will all disappear

37 How do you change the market?

38 Race for market share has not even begun

39 Where are we starting? U.S. Registered LDVs % of LDVs = Liquid Fueled FFV, 7.8% Diesel, HEV, 1.5% Gasoline, 87.6% PHEV, 0.1% BEV, 0.1% FCV, 0.0% CNG, 0.0% PAGV, 0.1% Gasoline FFV Diesel HEV PHEV BEV FCV CNG PAGV Source: Navigant Research

40 Back-to-Back Record Sales Years U.S. LDV Sales U.S. LDV Sales Diesel, 3.2% Diesel, 2.8% Gasoline, 94.0% Electric, 0.4% Gasoline, 94.4% Electric, 0.5% PHEV, 0.3% PHEV, 0.4% Hybrid, 2.1% Nat Gas, 0.0% Fuel Cell, 0.0% Hybrid, 1.9% Nat Gas, 0.0% Fuel Cell, 0.0% Gasoline Diesel Electric PHEV Hybrid Nat Gas Fuel Cell Gasoline Diesel Electric PHEV Hybrid Nat Gas Fuel Cell Source: WardsAuto

41 Interest in alternatives wanes 90% Would you consider the following types of vehicles? 3.5% Market Share of LDV Sales % 3.0% 70% 2.5% 60% 50% 2.0% 40% 1.5% 30% 20% 1.0% 10% 0.5% 0% Hybrid electric Flex fuel All-electric Diesel Fuel cell CNG Propane 0.0% Diesel Electric PHEV Hybrid Nat Gas Fuel Cell Jan-13 Apr-14 Oct-15 Feb-16 Feb Source: Fuels Institute, PSB

42 Turnover takes a very long time Blinking Orange Light Share of Registered Vehicles 100% 90% 80% Assumptions EIA Forecast LDV Fleet Size (2017 = million) EIA Forecast LDV Sales (Avg 16.6 million/year) Orange Light: All units from Jan 1, % 82% 87% 70% 64% 70% 60% 52% 58% 50% 45% 40% 33% 39% 30% 27% 20% 14% 20% 10% 7% 0% Source: Fuels Institute

43 Forecasts for EV market growth vary widely Diversity of EV Sales Forecasts 12% 10% 8% Bloomberg predicts: 40% by % by 2040 % OF SALES 6% 4% 2% 0% Navigant Research U.S. EIA Bloomberg New Energy Finance* Edison Electric Institute* * Estimated

44 Even with strong growth, EV market is limited Three Scenarios for EV Sales and Market Share 35% 32.55% 30% 25% 20% 15% 10% 8.02% 5% 0% % 12% 20% 5% 12% 20%

45 Fuel efficiency standards drive gallon loss 60 CAFE Standards and Expected On-Road Efficiency MPG New Car- On Road Performance New Light Truck- On Road Performance New Car - CAFE Standard New Light Truck- CAFE Standard

46 EVs are A part of threat to gasoline demand BILLION GALLONS CONSUMED Three Scenarios for Gasoline Demand BILLION GALLONS LOST TO EVS Lost at 5% Lost at 12% Lost at 20% Demand at 5% Demand at 12% Demand at 20%

47 High Octane Fuels how? What is the composition of the fuel? What is production feasibility and cost? Is it compatible with infrastructure? Is it compatible with legacy fleet? Will vehicles tolerate lower octane fuels? What are regulatory requirements? Can it be competitively priced? How will consumers react?

48 What about diesel?

49 Consumer interest has not declined How likely are you to consider a diesel vehicle? 100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% May-13 Apr-14 Oct-15 Feb-16 Feb-17 Very likely Somewhat likely Somwhat unlikely Very unlikely Combined Likely Source: Consumers and Alternative Fuels, Fuels Institute, PSB

50 Scandals have not diminished interest Why are you unlikely to consider a diesel vehicle? Lower performance than gas engines Recent scandals with emissions levels Diesel pumps are dirty Harder to start on cold days Requires more maintentance than gas engine harder to find fuel Type of vehicle I want doesn t use diesel Diesel engines are noisy Diesel vehicles are more expensive Smell/fumes from diesel exhaust Diesel fuel is more expensive 0% 10% 20% 30% 40% 50% 60% 70% 80% May-13 Apr-14 Oct-15 Feb-16 Feb-17 Source: Consumers and Alternative Fuels, Fuels Institute, PSB

51 Diesel is not as expensive relative to gasoline $5.00 Retail Fuel Prices (Jan Feb 2017) $4.00 $3.00 $2.00 $1.00 $0.00 Jan-13 Apr-13 Jul-13 Oct-13 Jan-14 Apr-14 Jul-14 Oct-14 Jan-15 Apr-15 Jul-15 Oct-15 Jan-16 Apr-16 Jul-16 Oct-16 Jan-17 Gasoline Diesel Source: OPIS

52 Light duty diesel will remain a niche market U.S. Registered LDVs 2025 FFV, 7.6% Gasoline, 83.5% HEV, 2.6% Diesel, 3.0% PHEV, 1.5% BEV, 1.8% FCV, 0.0% CNG, 0.1% PAGV, 0.0% Source: Tomorrow s Vehicles, Fuels Institute, Navigant Research

53 Commercial will remain diesel dominant MD/HD Vehicles in 2016 MD/HD Vehicles in 2025 HEV Gasoline, Diesel, 63.61% HEV Gasoline, Diesel, 60.86% HEV Diesel, 0.65% PHEV Gasoline, 0.10% HEV Diesel, 0.13% PHEV Gasoline, 0.01% PHEV Diesel, 0.21% PHEV Diesel, 0.01% BEV, 0.29% BEV, 0.02% FCV, 0.01% FCV, 0.00% CNG, 0.56% CNG, 1.44% LNG, 0. LNG, 0.27% Gasoline, 35.10% PAGV, 0.31% Gasoline, 35.29% PAGV, 0.69% FuelsInstitute.org FuelsInstitute.org Source: Tomorrow s Vehicles, Fuels Institute, Navigant Research

54 Diesel fuel quality a major issue It s not just corrosion it goes much further than that New high pressure engines have lower tolerances than earlier technologies and U.S. fuel standards may not be sufficient Fuel Quality Council Evaluate extent of engine-fuel challenges Foster collaboration to develop a common approach to improvements Calculate cost of remediation options Lead by combination of fuel providers, marketers, engine manufacturers, fleet operators, additive and fuel quality providers

55 Final Observations Consumers resist change cost, familiarity, convenience, etc. Consumers must be educated, but don t want to learn Retailers need demand to invest fuel will follow vehicles Auto industry needs fuel availability to deliver vehicles fuel must precede vehicles Solutions that benefit one sector will fail it is an interconnected, co-dependent market The market changes slowly, even with strong growth Disruptive change is possible, but this is not the smartphone market even disruption will take a very long time Cross-industry collaboration is critical to new product success

56 Fuels Institute focused on market issues High Octane Fuels feasibility, scalability, marketability Electric vehicle recharging behavior and infrastructure needs Low Carbon Fuel Standards Biodiesel performance and availability Consumer behavior Fuel Quality Council

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