Release Prevention Through Compliance/Remediation Integration How a UST Site May Become Contaminated -- Even When The Leak Detection is Passing National Tanks Conference Phoenix, AZ September 14, 2015 10:30 AM-12:00 PM Environmental Compliance for Petroleum Systems
Overview Typical UST Leak Detection How the Leak Detection May Not Detect a Leak Alternate Ways to Detects Leaks Possible Sources of Contamination not covered by LD Spill Protection Overfill Protection Secondary Containment Vents and Ullage Space of Tanks Surface Drips and Spills Impact of Revised UST Regulations Inspections and Testing of Spill/Overfill Prevention, Sumps, & Release Detection Systems
Typical UST Leak Detection Component SW Tank SW Piping DW Tank DW Piping Typical Leak Detection ATG or SIR ALLD; Annual Line Test or ELLD or SIR Interstitial Monitoring ALLD and Interstitial Monitoring
Possible UST Leak Detection Concerns LD system not installed or not operational ATG or ELLD not programmed to run test Sensor pulled up out of position Secondary not tight leak goes into ground The UST wasn t leaking at time of passing result Passing result was long ago No results during period that leak occurred LD detects a leak that has already occurred for a while LD didn t find the leak or leak was too small to detect Maybe leak rate below threshold Release was from a portion of the UST System that was not monitored by LD method
ATG Not Programmed To Run Tests Site in Virginia Inspected on July 21, 2015 Last test performed on July 6, 2011 Tanks aren t being tested by ATG
ATG Sensors Not Programmed Site in Wisconsin Inspected Diesel was sump contained 12 water. All sensors associated with Diesel Tank were disabled. Other corrosion issues with Diesel Tank. All other tanks at location set up and working o.k.
ATG Sensors Pulled Out of Position Fuel in Sump. Sump sensor pulled up so alarm won t sound.
ATG Threshold Higher Than Leak Some ATG s have relatively high threshold Will likely not detect leak smaller than threshold
Alternative Leak Detection Methods Pressure Decay Tests can find leaks in ullage, vent & vapor piping Tank Tightness Test Tests ullage as well liquid portion Some methods apply additional pressure or vacuum Tracer Gas Leak Helium Leak Location P.I.D. or FLIR to detect vapor leaks
Other Sources of Contamination Possible Sources of Contamination not covered by LD Overfill Protection Spill Protection Secondary Containment Vents and Ullage Space of Tanks Surface Drips and Spills Impact of Revised UST Regulations Inspections and Testing of Spill/Overfill Prevention, Sumps, & Release Detection Systems
Overfill: Biloxi, MS. August 9, 1998 An estimated 550 gallons of gasoline spilled and drained into street. Gasoline ignited and engulfed 3 vehicles and 5 people died. Site used remote fill for deliveries and ball float valves for overfill protection. The delivery driver left the cap off the direct fill pipe during delivery. See NTSB Report PB99-917007 for more details. One of the sedans and the pickup after emergency responders extinguished the blaze. The tanker truck is in the background.
Overfill: Bennington, NE 7/30/2015 An estimated 1,000 gallons of gasoline spilled at a Bennington gas station. Bennington Fire Chief Robert Rayman told WOWT 6 News a 5,000-gallon tanker was filling the underground reservoir when it overfilled. Rayman says staff wasn't sure why safety equipment didn't stop the overfill and that operator error is likely to blame. Equipment Malfunction or Operator Error?
Overfills Dayton, IN July 14, 2015 July 14, 2015 A tanker spills 75 gallons of gasoline. The gas spill spread nearly 125 feet. The tanker was unloading fuel in the station s underground storage and miscalculated how much could be filled.
Overfills Stillwater, OK - April 2015 Monday, April 13, 2015 Spilled 95 gallons of fuel A tanker truck reported to be making a delivery
Overfills Belton, TX - March 2015 March 23, 2015 Firefighters worked to contain a gasoline spill estimated around 75 gallons. The spill occurred as storage tanks were being filled.
Overfills Greenwood, AR March 2015 The overflow valve popped off of the tanker refilling gas tanks at the station, spilling gallons of gas, according to Greenwood Fire Chief Stewart Bryan.
Overfills Battlecreek, MI Feb. 2015 February 23, 2015 Between 200 to 300 gallons of gasoline spilled at a gas station at 321 Emmett Street The spill came as the tanker was making a fuel delivery to a gas station.
Overfills Bryant, AR - January 2015 January 12, 2015 About 20 gallons of fuel spilled during delivery. Described as Accidental Gas Spill by local news
Failed Overfill Protection
Failed Overfill Protection
Failed Overfill Protection Heavily corroded. Broken spring. Uncertain operation.
Failed Overfill Protection Heavily corroded. Broken spring. Stuck float.
Failed Overfill Protection? Heavily corroded (ULSD) Sticky float.
Failed Overfill Protection
Failed Overfill Protection
Failed Overfill Protection Is that 95%? Looks more like 100%!
Failed Overfill Protection Drop tube so short that flapper doesn t even reach the tank!
Failed Overfill Protection Ball Floats
Failed Overfill Protection Ball Floats Ball fell out of valve housing.
Failed Overfill Protection Ball Floats Valve too short. Much higher than 90% level.
Failed Overfill Protection Ball Floats Heavily corroded (and too short).
Spill Containment Problems Cracks
Leaking Spill Containers - Cracks Cracks
Leaking Spill Containers - Tears Tears in the bellows. Allows fuel to drain directly into ground.
Secondary Containment Is It Functional?
Fuel in Sump. Detected But Not Reported. I found the leak during annual testing. Funny thing is, the site has PLLD and there was a periodic line test failure active when I arrived that had occurred about 10 days prior. I guess it was never called in. Service Technician
Fuel in Sump. Detected during routine service. This is a sump at a site in Dallas. It is full of DSL fuel. This is the second time I have been on site to do a FuelPure and found this sump full of fuel. They said a contractor had come out and fixed it between my visits, obviously not very well. - Service Technician What if the sump was leaking?
STP Sumps Cracked Penetration Boots
STP Sumps Is this containment?
STP Sumps Is this containment?
STP Sumps Is this containment? Trying to pump out sump to fix small leak. Slight sheen on water. Water recharges as fast as pump will operate.
STP Sumps Leaking Primary Piping Drains into Sump
STP Sumps Is this containment? Water ingress into tank. Discovered hole in bottom of STP riser.
Failed Pressure Decay Test Leak in Tank Ullage Tank failed P.D. Test Discovered crack. Car had driven over STP. Vapors escaping, and product if any overfill occurs.
No STP Sumps Seeps & Leaks Go Directly Into Soil
No STP Sumps Seeps & Leaks Go Directly Into Soil
No STP Sumps Seeps & Leaks Go Directly Into Soil STP buried in mud, and sheen on water.
No STP Sumps Seeps & Leaks Go Directly Into Soil
No STP Sumps Seeps & Leaks Go Directly Into Soil
STP Sumps Full of Water Leak Found During PD Test Bubbles from leaking O-ring on STP during PD Test.
Vent, Vapor, & Ullage Leaks Pressure Decay Test Failed a Pressure Decay Test Broken Extractor Fitting and Cracked Riser
Leak Under Dispenser No Containment Stream of fuel from solenoid valve when pump runs.
Leaking Suction Pump Leaking Pump Drips fuel into ground while pump is running. No UDC.
Leaks Under Dispenser Seeps and Water Found dripping. Spilling out from under dispenser.
Leaks Under Dispenser Used Filters Filters disposed under dispenser.
Leaks Under Dispenser Seeps Found seeping during routine LD test.
Leaks Under Dispenser No UDC
Drip From Ball Valve in STP Sump PLLD (has passing history) Annual LLD test (passed) Sump Sensors pulled up No sump test done
Hole in Fill Riser Fuel in Spill Container Failed P.D. Test Found holes in fill riser for C.P. wires. Fuel in spill buckets.
Hole in Vent Pipe Severe corrosion and hole in vent pipe coming off side of extractor housing. Allows water to enter tank but could allow product to escape in case of overfill.
Drips Around & Under Dispenser Staining from Diesel drips. Damp dirt under dispenser.
Shear Valve Not Functional Discovered during inspection. Control arm bent and won t trip to close valve. Won t function as designed.
Failed Secondary Containment Piping Would allow leak into ground if primary piping failed.
Inspections and Testing PEI RP-900 and RP-1200
Surface Drips and Small Spills Infiltration and evaporation of small hydrocarbon spills at gas stations Markus Hilpert, Patrick N. Breysse Journal of Contaminant Hydrology Volume 170, 1 December 2014, Pages 39 52 Small gasoline spills at gas stations have not been studied sufficiently. Infiltration of gasoline droplets into concrete may exceed evaporation. Gasoline evaporation is estimated with Penman's equation. Environmental regulations often neglect subsurface contamination. http://www.sciencedirect.com/science/article/pii/s0169772214001417 he estimates that at a typical gas station, you re talking about 1,500 liters being spilled over a 10-year period http://www.nbcnews.com/science/environment/gas-station-spills-could-pollute-water-drips-drops-study-n221736
Surface Spills Jacksonville, FL - Aug 2015 Jacksonville, FL August 12, 2015 20 Gallon Fuel Spill Man walked away from car while refueling Automatic Shutoff on Nozzle Didn t Work
Surface Spills Illinois - April 21, 2015 Arlington Heights, IL 4/21/2015 Estimate 80 gallons of gasoline leaked Authorities blamed the spill on a pump left running overnight at the gas station. A passer-by saw the leak at 5:45 a.m. and hit the emergency shut-off switch.
Surface Spills Mississippi - Jan 13, 2015 Collinsville, Mississippi - Jan 13, 2015 A driver filled up his tank then drove off with the hose still in the car. This caused about 40 to 50 gallons of gas to spill all over the ground. The fire department arrived and they got the leak stopped and the pumps turned off.
Cracked Top of Monitoring Well Cover not sealed no bolts or gasket Lid on well pipe doesn t seal tightly Allows direct access for spill into groundwater
Missing Cover and Cap on Monitoring Well Missing manhole cover and cracked rim No Lid or Cap on Monitoring Well Allows direct access for spill into groundwater
Various Fittings with direct access to backfill Often ATG s or other risers are direct bury No gaskets around manhole covers
Brad Hoffman Bhoffman at Tanknology dot com