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  1. 1. Releases Detecting, Preventing, Reporting
  2. 2. NOTICE Ecology will “RED TAG” any UST system that does not have required spill prevention, overfill prevention, leak detection, or corrosion protection equipment
  3. 3. 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
  4. 4. 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.
  5. 5. Release Detection Equipment
  6. 6. 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).
  7. 7. 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.
  8. 8. 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
  9. 9. 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
  10. 10. 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
  11. 11. Release Detection  Both a suspected or confirmed release from tanks/piping must be reported to the EcologyWITHIN24 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:
  12. 12. 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
  13. 13. 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 leaking Information must be sent in monthly and Report kept on site The vendor uses sophisticated computer software to conduct a statistical analysis of the data and provides you with a test report Equivalent 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
  14. 14. 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.
  15. 15. Automatic Tank Gauge Alarm
  16. 16. Automatic Tank Gauge Reports
  17. 17. 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
  18. 18. 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
  19. 19. 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
  20. 20. 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