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Spill and Overfill Prevention

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1 Spill and Overfill Prevention
The next slides discuss general requirements for spill buckets including exemptions and product identification overfill prevention devices including ball float valves and alarms, employee training, corrosion protection, and what to do about suspected releases or spills. Spill and Overfill Prevention

2 General Requirements Must have a spill bucket to prevent small spills during delivery, Must have an overfill prevention device to prevent a large overfill, Must prepare for and monitor deliveries to prevent overfilling in the first place, and Must cleanup overfills and report large ones. The equipment alone will not prevent an overfill. Someone must be paying attention before, during and after the delivery. This slide discusses why spill buckets are required. A catchment basin is a bucket sealed around the fill pipe. To protect against spills, the basin should be large enough to contain what may spill when the delivery hose is uncoupled from the fill pipe. A typical delivery hose can hold about 14 gallons of fuel. Basins range in size from those capable of holding only a few gallons to those that are much larger--the larger the catchment basin, the more spill protection it provides. Sumps, including the sumps beneath dispensers, sumps around the submersible pump (turbine) head, transition/intermediate sumps, and spill buckets are common sources of releases. Releases of even small volumes of product can seep into the ground and contaminate soil and groundwater. Inspecting and maintaining your sumps can prevent or minimize such releases.

3 Overfill Exemption Not required on UST systems like waste oil tanks that receive less than 25 gallons at a time. This slide explains that used oil USTs are exempt from the requirement to have a spill bucket because the amount of material delivered is so small. Many releases at UST sites come from spills. Spills often occur at the fill pipe when the delivery truck's hose is disconnected. Although these spills are usually small, repeated small releases can cause big environmental problems. Human error causes most spills. These mistakes can be avoided by following industry standard practices for tank filling. For example, you must make sure there is room in the UST for the delivery so that when the delivery hose is disconnected, the hose is empty. If you and the delivery driver follow standard practices, nearly all spills can be prevented. If an UST never receives more than 25 gallons at a time, the UST does not have to meet the spill protection requirements. Many small used oil tanks fall into this category.

4 Spill Buckets Should Be
Compatible with petroleum. Able to keep out water. Designed to catch small amounts of fuel. Properly ID’ed. Routinely cleaned out. Secure. Liquid tight. This slide discusses the basic parts of a spill bucket. Not all of the points discussed in the slide are required but it’s all a good idea. Items you should check on your spill bucket are: Are The Lids Tight And Sealed Correctly? Are The Sump Walls Intact? Is The Sump Free Of Debris, Liquid, Or Ice? Is The Sump Free Of Cracks Or Holes? Are All Penetrations Into The Sump In Good Condition? Are Sump Components Leak-Free? Is The Sump Free Of Staining/New Staining? Are The Sensors Positioned Correctly?2 Are All Penetrations Into The Sump In Good Condition? Are The Test Boots Positioned Correctly And In Good Condition? Is The Piping And Other Equipment In Good Condition? (Graphic courtesy of PEI)

5 Which one is the spill bucket?
This slide discusses which opening goes where on an UST Spill Buckets are defined as contained sumps installed at the fill and/or vapor recovery connection points to contain drips and spills of fuel that can occur during delivery. Spill buckets are located where the delivery driver connects the product and/or vapor recovery hoses to your tank. Spill buckets can be found directly above your UST, at a location that is away from your UST (remote), or both. They typically range in size from 5 to 25 gallons, and lids range from 1 to 2 feet in diameter. Spill buckets may also be installed within a larger sump, similar in construction to a turbine sump, for secondary containment.

6 Check the Drain Plug This slide discusses drain plugs in spill buckets. While they are not required, drain plugs have pros and cons. Some spill buckets have drain valves. Check to ensure the drain valve is free of debris and operational (e.g., it can close tightly and be opened to drain fuel in the spill bucket). If the drain valve is left open: It will act as a vent, or, It can allow water and debris to enter your tank.

7 Product ID U Make sure the colors match the actual product type.
RED Product ID BLUE WHITE Make sure the colors match the actual product type. RED BLUE WHITE A product ID – following API standards – is not currently required at the federal level but is a good idea. Why? Labeling and painting identifies the fill port and paint access covers. It helps to make sure that the transport driver cannot make the mistake of delivering the wrong fuel to the wrong fill pipe. ORANGE Used Oil U

8 Product ID Make sure the ID tags match the actual product type.
This slide discusses that tank ID tags are another way to ID the opening so that the wrong fuel is not delivered.

9 Spill Buckets: What’s Wrong Here?
This slide discusses various wear and tear issues Photo 1 – Spill bucket Photo 2 – Damaged spill bucket and product in bucket Photo 3 – Rusting bucket and water Photo 4 – Rusting, corroded seal

10 Spill Bucket Problems Cracked lids, bad seals.
Compatibility with petroleum. Integrity of bucket not tested. Holes, cracks, wear. Drain plug sticks. Full of debris, water, sorbents. Surface damage. This slide discusses common problems found with spill buckets.

11 Overfill Prevention The next set of slides discusses overfill prevention options including an automatic shut-off device, ball float valves, overfill alarms, monitoring, and preparation. Overfilling UST systems is a common source of petroleum and hazardous substance USTs releases onto the surface of the ground. EPA studies have found that UST owners and operators without overfill prevention equipment on their USTs often inadvertently force product into the environment through tank bung holes, vent lines, or fill ports when the volume of liquid delivered exceeds the tank's storage capacity.

12 Overfill Prevention Options
Automatic shut-off device (at 95% full) Ball float valve (at 95% full) High-level alarm (at 90% full) This slide discusses the three basic methods of overfill protection, where they sit in the tank, and at what point they activate. Requirements for spill and overfill prevention are that equipment will (1) alert the transfer operator when the tank is no more than 90 percent full by restricting the flow into the tank or triggering an alarm, or (2) automatically shut off flow into the tank when the tank is no more than 95 percent full. Many releases at UST sites come from spills. Spills often occur at the fill pipe when the delivery truck's hose is disconnected. Although these spills are usually small, repeated small releases can cause big environmental problems. Human error causes most spills. These mistakes can be avoided by following industry standard practices for tank filling. When a delivery is being made to fill an UST, the owner and operator has the responsibility to: Ensure that the volume available in the tank is greater than the volume of product to be transferred to the tank before the transfer is made. Ensure that the transfer operation is monitored constantly to prevent overfilling and spilling. (Graphic courtesy of PEI)

13 Automatic Shut-Off Device
This slide illustrates how you look down a fill pipe to see the flapper arm. This is part of an automatic shut-off device. The automatic shutoff device is a mechanical device installed in line with the drop tube within the fill pipe riser. It slows down and then stops the delivery when the product has reached a certain level in the tank. It should be positioned so that the float arm is not obstructed and can move through its full range of motion. When installed and maintained properly, the shutoff valve will shut off the flow of fuel to the UST at 95% of the tank’s capacity or before the fittings at the top of the tank are exposed to fuel.

14 Automatic Shut-Off Device
Don’t ever store your stick in the drop tube. Can cause an overfill. Can damage overfill device. This slide illustrated a bad management practice for automatic shut-off devices.

15 Ball Float Valve Located in vent pipe or vapor recovery pipe.
Cage can rusting out, ball floats away. Incompatible with Pressurized deliveries, Suction piping with air eliminators, Remote fills, Coaxial Stage I VR. Ball float valves (also known as float-vent valves) are fitted on the bottom of the vent line and hang down several inches below the top of the UST. When the product level is below the cage, the ball rests at the bottom of the cage and the vent line is open. As the level of the product rises above the bottom of the cage, the ball floats on the product and rises in the cage. As the delivery continues, the ball eventually seats in the vent line and restricts vapor flowing out the vent line BEFORE the tank is full. If all tank fittings are tight, the ball float valve can create enough back pressure to restrict product flow into the tank--which can notify the driver to close the truck's shutoff valve. However, if the UST has loose fittings, sufficient back pressure may not develop and will result in an overfill.

16 Ball Float Valve Open the extractor fitting Find the ball
This slide illustrates how to find the ball float valve. Go to the vent side of the tank to find if the UST has a ball float. Not all USTs have ball float valves. You must inspect the ball float and make sure that: The air hole is not plugged. The ball cage is still intact. The ball still moves freely in the cage. The ball still seals tightly on the pipe.

17 Ball Float Considerations
In 2005, Petroleum Equipment Institute began advising against using ball float valves for new installations. (RP-100). Consider replacing them. This slide discusses the hazards of ball floats; they are allowed by law, but discouraged by industry. You should not use a ball float valve for overfill protection if any of the following apply: Your UST receives pressurized deliveries. Your UST system has suction piping. Your UST system has single point (coaxial) stage 1 vapor recovery

18 Overfill Alarm Set to alarm when 90% full.
Requires driver, not the operator, be alerted. Tied into tank gauge or stand-alone alarm. Common settings: 90% High 95% High-High 100% Max This slide describes how high-level alarms work and what the common settings are. This type of overfill device activates an audible and/or visual warning to delivery personnel when the tank is either 90/95/100% full or is within one minute of being overfilled. The alarm must be located so it can be seen and/or heard from the UST delivery location. Once the electronic overfill alarm sounds, the delivery person has approximately one minute to stop the flow of fuel to the tank. Electronic overfill alarm devices have no mechanism to shut off or restrict flow. Therefore, the fuel remaining in the delivery hose after the delivery has been stopped will flow into the tank as long as the tank is not yet full.

19 Is it where the driver can see or hear it?
Overfill Alarm Is it where the driver can see or hear it? Alarms should be outside near the fill opening. You should ensure that the alarm can be heard and/or seen from where the tank is fueled and make sure that the electronic device and probe are operating properly. You should post signs that the delivery person can easily see and that alert the delivery person to the overfill warning devices and alarms in use at your facility.

20 Overfill Alarm Problems
Alarm not where driver can see or hear it. Driver desensitized to meaning of alarm. Fuel flowing over 300 gallons/minute. Alarm doesn’t stop anything. Operator doesn’t hear it or know what it means. Operator doesn’t know how to respond. Operators tend to ignore or silence them. This slide discusses common overfill alarm problems. There is always a chance the overfill device won’t work.

21 Monitoring Owner or Operator:
Measure the fuel level immediately before each delivery to make sure there is enough room in the tank. Monitor the entire fuel transfer. Report and cleanup all overfills. This slide discusses that monitoring the fuel level is usually ignored by owners as well as regulators. It requires that you: Make and record accurate readings for product and water in the tank before fuel delivery. Order only the quantity of fuel that will fit into 90% of the tank. Have an accurate tank capacity chart available for the fuel delivery person. Provide safety barriers around the fueling zone. Make sure there is adequate lighting around the fueling zone.. Make and record accurate readings for product and water in the tank after fuel delivery. Monitor the entire fuel transfer. Verify the amount of fuel received. Ensure the spill bucket is free of product and clean up any small spills.

22 Careful Preparation This slide illustrates the sequence of a safe and proper delivery.

23 The slide illustrates three things that are wrong with a delivery:
Operator not paying attention (talking on phone). Operator filling two USTs at once. Wheels not chocked.

24 Overfill in Biloxi, MS, 1998 This slide describes the story of the Biloxi overfill and fire: 5 dead, 1 badly burned. On August 9, 1998, about 12:53 a.m., a Premium Tank Lines, Inc., truck driver was transferring gasoline from a cargo tank to the underground storage tanks at a Fast Lane gasoline station-convenience store in Biloxi, Mississippi, when an underground storage tank containing gasoline overflowed. An estimated 550 gallons of gasoline flowed from the storage tank, across the station lot into the adjacent highway, and through a nearby intersection. The gasoline ignited, and fire engulfed three vehicles near the intersection, which ultimately resulted in the deaths of five occupants and the serious injury of one. Damages were estimated at $55,000.

25 The next two slides provide an overview of UST employee training.
While most USTs have equipment that complies with program requirements, proper operation and maintenance remains a problem. Owners and operators of USTs often have many responsibilities in their place of business that compete with the time needed to properly operate and maintain UST systems. Additional compliance assistance and operation and maintenance training, are needed to improve the operation and maintenance of UST systems UST Employee Training

26 Training Employees New Federal law will eventually require training for UST facility employees. Owner’s responsibility to train. Training expectations not decided yet. It’s OK Sir. I ‘m a TRAINED PROFESSIONAL! Employee training will be required by the Energy Policy Act of Phase in of the requirement for employee training is anticipated by 2007 to 2009.

27 What attendants and clerks should know
Basic parts of the system. Emergency shut-down procedures. Preventing overfills during deliveries. Who to call if there is a problem. This slide describes what attendants and clerks should know. It’s not the law (yet) but these are some good ideas to reduce risk. The training should include: 1) the operation of the UST system; 2) the employee’s role with regard to the UST monitoring equipment; 3) the employee’s role with regard to spills and overfills ; and 4) the name of the contact person(s) for emergencies and monitoring equipment alarms.

28 Corrosion Protection Unprotected underground metal components of the UST system can corrode and release product through corrosion holes. Corrosion can begin as pitting on the metal surface. As the pitting becomes deeper, holes may develop. Even a small corrosion hole can leak hundreds of gallons of petroleum into the surrounding environment over a year. In addition to tanks and piping, metal components can include flexible connectors, swing joints, and turbines. All metal UST system components that are in contact with the ground and routinely contain product must be protected from corrosion. GAO has also reported that approximately 29 percent of USTs were not operated or maintained properly, finding particular problems with leak detection systems and anti-corrosion equipment.

29 Overview General requirements Equipment Operation and maintenance
Testing Problems Record keeping This slide presents an overview of the general requirements for cathodic protection.

30 General Requirements Tank and piping must be protected from corrosion.
Includes portions of UST system routinely containing product. Yes: tank, product piping. No: vent and fill piping. Three ways to meet this requirement: Non-metal materials, Galvanic cathodic protection, Impressed current cathodic protection and/or internal epoxy liner. This slide present basic information on corrosion protection including what must be protected and where corrosion protection is not required. There are three ways to protect USTs from corrosion, and there are two types of systems for cathodic protection: Sacrificial Anode, and Impressed Current. Sacrificial anodes can be attached to a coated steel UST for corrosion protection. Sacrificial anodes are pieces of metal more electrically active than the steel UST. Because these anodes are more active, the corrosive current will exit from them rather than the UST. An impressed current system uses a rectifier to convert alternating current to direct current. This current is sent through an insulated wire to the anodes, which are special metal bars buried in the soil near the UST. The 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. The interior of a structurally sound tank may be lined with a thick layer of noncorrodible material. The lining material and application method must be both comply with applicable industry codes. The lining used must also meet the same federal requirements as for repaired tanks.

31 General Requirements Non-metal tank/pipe material
Tank: Fiberglass, Fiberglass-clad steel Pipe: Fiberglass, flexible plastic Galvanic cathodic protection STI-p3 Impressed current cathodic protection Older systems used in retrofits Impressed current, internal epoxy lining or both Three common ways of preventing corrosion are described above. The STI-p3 ® is a Steel Tank Institute standard. It includes: Dielectric Coating – Either epoxy, polyurethane or polyester resin coating the exterior of the UST Cathodic Protection – Sacrificial galvanic anodes and electrical isolation to protect the UST from stray currents Secondary Containment Tank including: Primary Steel Inner Tank with a minimum steel thickness of 10 gauge Secondary Steel Outer Tank Interstitial Leak Detection Monitoring

32 Equipment: Non-Metal This slide presents photos of non-metallic options. Photo 1 – Fiberglass tanks Photo 2 – Fiberglass tanks Photo 3 – Clad steel tank. STI "ACT-100®" Standard "Specification for External Corrosion Protection of FRP Composite Steel Tanks (F894-91)". Composite tanks are tested at the factory prior to shipping for "holidays", or voids, in the laminate, so corrosion will not occur and no on-going monitoring is required. Composite tanks are made in both single and dual-wall configurations, and also can be cost-effectively compartmented. Photo 4 – Jacketed tank. Secondary containment through incorporation of primary tanks built of steel and outer walls fabricated of other materials. Jacketed tanks provide both containment and corrosion protection of the primary tank.

33 Equipment: Galvanic Steel
This slide describes the STI-p3 tank. The sti-P3® specification covers a pre-engineered external corrosion control system (termed sti-P3®) for underground steel storage tanks. The system is a practical and economical means of extending the life of underground tanks from a minimum of thirty (30) years in corrosive soil conditions to an indefinite term in less severe environments. The sti-P3® system combines three basic methods of underground corrosion control, all installed on the tanks during manufacture: (1) Cathodic Protection, (2) Protective Coating, (3) Electrical Isolation of the tank from other underground metallic structures. More than 1/4 million sti-P3® steel underground storage tanks have been placed in service during the past quarter century. An audit by Tillinghast, a leading risk management consultancy, reviewed the sti-P3® performance record and documented that sti-P3® tanks have the best UST performance record, an incidence rate of less than 0.04%.

34 Equipment: Impressed Current
The slide describes how impressed current works. An impressed current system uses a rectifier to convert alternating current to direct current. This current is sent through an insulated wire to the anodes, which are special metal bars buried in the soil near the UST. The 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. Regulations require that the cathodic protection systems installed at UST sites be designed by a corrosion expert. The system must be tested by a qualified cathodic protection tester within 6 months of installation and at least every 3 years thereafter. You will need to keep the results of the last two tests to prove that the cathodic protection is working. In addition, you must inspect an impressed current system every 60 days to verify that the system is operating. Keep results of your last three 60-day inspections to prove that the impressed current system is operating properly.

35 Equipment: Internal Lining
This slide provides pictures and describes how the interior of a tank is lined. The interior of a structurally sound tank may be lined with a thick layer of noncorrodible material. The lining material and application method must be both comply with applicable industry codes. The lining used must also meet the same federal requirements as for repaired tanks. The steps involved in internal lining are: Sludge and residue are removed from the tank. The interior of the UST is cleaned to a white metal surface. The UST is checked for structural soundness. Any necessary repairs are made. The interior is lined with a noncorrodible material. The UST is inspected periodically.

36 Corrosion Operation and Maintenance
Non-Metal: None. Galvanic: None. Impressed current: Check rectifier every 60 days and log results. Looks for trends over time. Zero value is not good, no power, no protection. This slide describes what type of operations and maintenance are required based on the type of corrosion protection installed on the UST.

37 Corrosion Testing Galvanic and impressed current system must have cathodic protection test done: Every 3 years, By a certified tester (NACE), As close to original test conditions as possible. Also, impressed current systems must have current levels checked every 60 days. (Most operators check every 30 days.) For corrosion protection, it’s all about the test. You need to have a test done every three years by a qualified corrosion tester belonging to NACE (National Association of Corrosion Engineers) or a registered professional engineer with certification or licensing in corrosion control . You need to keep the results of at least the last two tests on file. You need to inspect your rectifier at least every 60 days to make sure that it is operating within normal limits. This inspection involves reading and recording the voltage and amperage readouts on the rectifier. You or your employees can perform this periodic inspection. You need to keep records of at least the last 3 rectifier readings. You should have a trained professional periodically service your impressed current system. Never turn off your rectifier!

38 Corrosion Testing Tester has certain test standards to follow.
All test failures should be promptly investigated. Tank or piping must demonstrate it has sufficient current to overcome corrosion in soils. Most common target is -850 mV. 100 mV shift acceptable. This slide describes general testing issues. Note that it is easy to get false positives and false negatives with corrosion testing.

39 Corrosion Testing Test contact at test station or inside tank.
If no test station, should have written procedure. The quality of the corrosion protection test is very important. A Cathodic Protection Tester is a person who can demonstrate an understanding of the principals and measurements of all common types of cathodic protection systems as applied to buried or submerged metal piping and tank systems and who has education and experience in soil resistivity, stray current, structure-to-soil potential, and component electrical isolation measurements of buried metal piping and tank systems. Records of testing and inspection of cathodic protection systems must demonstrate compliance with the testing criteria specified by the corrosion expert or corrosion engineer that designed the cathodic protection system. Steps that were followed in arriving at whether the cathodic protection system is or is not performing adequately to protect the UST system against corrosion must be included in the documentation. These steps must also provide an adequate number of measurements that will properly determine the adequacy of the protection provided. A simple statement to the effect that the system “passed” or did not “pass” the test is not adequate documentation for a cathodic protection system test.

40 Corrosion Testing: Steel Pipe
Make sure steel pipe is protected from corrosion. Pipe may or may not be electronically connected to cathodically protected tank. Unprotected steel pipe should be removed. This slide describes issues with steel piping. Piping is particularly vulnerable to corrosion failure.

41 Corrosion Testing: Liner Only
Internal liner must be inspected after 10 years. Also must be inspected every 5 years thereafter. A few different testing options available. Liners can fail. Inspection critical but not always required. After the lining has been applied to existing UST, several tests must be conducted. These include: Thickness - a thickness gauge (e.g., Elcometer) used to determine that the lining has been applied within the manufacturer’s specifications. The lining can not be below the minimum, and must be with a nominal tolerance. Hardness - a hardness gauge (e.g., Barcol Hardness Tester) used to establish if the lining has cured to the proper tolerance established by the manufacturer. Holidays - a Holiday tester used to determine if the lining is within tolerances for air pockets or pin holes, referred to as holidays. Testing options include use of a video camera to inspect lined tanks.

42 Corrosion Problems STIp3 Tank Cracking isolation bushing.
Coating damaged at installation. Current This slide describes common corrosion problems with piping and emphasizes why separating tanks and pipes is VERY important with STIp3s. Current

43 Corrosion Problems Impressed Current Anode wires damaged.
Stray current. Rectifier damaged. Large decrease in current. The slide describes corrosion problems with impressed current. Impressed current is easy to damage or put off-line. A qualified tester is important to ensure that the system is working as designed.

44 Corrosion Record Keeping
For non-metal materials: keep installation documents. For galvanic systems, keep last two cathodic protection test results. For impressed current, keep last three cathodic protection test results plus 60-day monitoring log. (Most operators do it every 30 days.) Records are vital to prove compliance during inspections. These include: Impressed Current System - Keep results of last three inspections of the system to ensure that it is working properly and of the last two tests conducted by a qualified cathodic protection tester. A log or journal of the proper operation of the rectifier must be maintained every 60 days. The log should include: the date, voltage, amperage and hour meter readings, and be initialed by the reader. Sacrificial Anodes - Keep records of the last two tests conducted by a qualified cathodic protection tester.

45 Corrosion Considerations
Check metal flex connectors even if not required. Check rectifier every 30 days and know who to call to troubleshoot. Some additional corrosion considerations are: Ancillary equipment such as metal flex-connectors, are used on rigid fiberglass reinforced plastic lines. These are metal piping and should be inspected regularly. To ensure proper protection of the tank system, the rectifier must run continuously 24 hours a day. Checking the rectifier every 30 days provides critical data that may be used to determine where problems have occurred and when repairs are needed. Maintaining this log could save you money in the long run.

46 The next set of slides discusses what to do when there is a suspected release and concludes with a summary on UST issues. Suspected Releases

47 Suspected Releases About Leaks and Spills Investigate and Confirm
Reporting System tests Site Assessment Off-site impact Actual releases Notify These slides present an overview of what to do about suspected releases from USTs. This includes: Sources of leaks and spills and their causes and how they are detected How to investigate and confirm that there was a release What the reporting requirements are for a release When operating conditions suggest a release has occurred What tests may be required to confirm a release When a site assessment may be required When an assessment of off-site impacts may be required Can you find the leak?

48 About Leaks and Spills: Sources
From a Florida Department of Environmental Protection study, piping, spill/overfill and dispenser leaks top the list of items that are suspected as the source for much of the new contamination being discovered throughout the country. Information indicates trends related to equipment, system and operator performance. Other Sources Include: Fuel Filters, Outlet Valve, and Human Spilling

49 About Leaks and Spills: Causes
The Florida study also analyzed how releases occur. Evaluation of UST systems has found faults in the design, installation, operation, and maintenance of various components. Many of the causes appear to be human error or lack of oversight, such as failure to test and maintain corrosion protection and leak detection systems. UST system piping has been identified as a major concern, as have spills and overflows during product delivery and releases from dispensers. Release detection is not always reliable and is reactive by design, not registering the leak until it has entered the environment, unless there is a secondary containment system with interstitial monitoring. Other Causes Include: Vandalism, Valve Failure, Contractor Accident, Other Human Error

50 About Spills and Leaks: Detection
The Florida study also summarized how we typically find spills or leaks. Notice that 68% of detection is done by olfactory or visual identification (bad news, folks).

51 Suspected Releases Investigate and confirm
Upon discovery, owner/operator must take immediate action to investigate. If cannot verify the event was false alarm, must report to regulatory agency. If false alarm: No evidence of release If release: Contact regulatory agency, hire contractor, develop investigation cleanup plan, Investigation complete in 7 days. This slide describes what to do when you first think you have a problem. When a second tightness test is used to confirm a suspected release, the UST owner must "repair, replace, or upgrade the UST system and begin corrective action" if the system is non-tight. The actual approach followed is dependent on site conditions and the implementing agency's decision as to whether the initial abatement actions, site check activities, and corrective action measures necessitate tank removal.

52 Suspected Releases Reporting
Notify regulatory agency within 24 hours of discovery of potential problem, including: Obvious signs of leakage, Unusual operating conditions, or Monitoring alarm. This slide describes reporting obligations when a release is confirmed. Various warning signals can indicate that your UST may be leaking and creating problems for the environment and your facility. You can minimize these problems by paying careful attention to early warning signals and reacting to them quickly before major problems develop. You should suspect a leak when you discover any of the following warning signals: You, your coworkers, or customers smell escaped product or see anything like an oily sheen on water near the facility. Your neighbors complain of vapors in their basements or about water that tastes or smells like petroleum. Someone reports unusual operating conditions at your facility, such as erratic behavior of the dispensing pump. You receive or generate results from leak detection monitoring and testing that indicate a leak. If you suspect that a release may have occurred, you must your state or local implementing agency within 24 hours.

53 Suspected Releases Unusual operating conditions can include:
Erratic dispenser, Sudden loss of product, Widely fluctuating water levels, Unexplained water in tank. This slide describes some operating conditions that may or may not be a problem.

54 Suspected Releases Other scenarios of concern are:
Fuel in secondary containment area. Double wall tank Piping sumps Monitoring results that show alarm situation. This slide describes some additional operating conditions that may or may not suggest a release. Leaking flex connector with loss less than detectable limit

55 Suspected Releases System Tests
Owner/operator may have to conduct tightness test to confirm if release occurred. Owner/operator may have test any double-wall systems. Repair or replace damaged pieces of equipment Shut down use of UST system until corrected. This slide describes the requirements to confirm if a release has occurred. After reporting the release to the appropriate agencies, the owner/operator has seven days to investigate and confirm the suspected release by performing a tightness test and a site check. If a release is confirmed at any time, the owner/operator must perform the following within 24 hours of a release: (a) Report the confirmed release to the appropriate agencies; (b) Take immediate action to prevent any further release of the regulated substance into the environment; (c) Identity and mitigate fire, explosion and vapor hazards. Unless directed to do otherwise, owner/operator must also perform the following initial abatement measures: (1) Remove as much of the regulated substance from the underground storage tank system as is necessary to prevent further release into the environment; (2) Visibly inspect any above-ground releases or exposed below-ground releases and prevent further migration of the release substance into the surrounding soils and groundwater; (3) Continue to monitor and mitigate any additional fire and safety hazards posed by vapors or free product that have migrated from the underground storage tank excavation zone and entered into subsurface structures (such as sewers or basements); (4) Remedy hazards posed by contaminated soils

56 Suspected Releases Site Assessment May be required if:
Obvious sign of problem, Tank or pipe tests tight but obvious problem anyway (like sheen in creek), or Directed by regulatory agency. Site-specific soil and ground water sampling. Site characterization (also referred to as site assessment) is a crucial early stage in understanding what has happened at the UST site. This stage needs to find answers to such questions as how far has the release traveled?, what is the hydrogeology of the site?, and so on. The overall efficiency and effectiveness of site characterization can be improved by using expedited site assessment process. Expedited Site Assessment Tools For Underground Storage Tank Sites: A Guide For Regulators (EPA 510-B ) A site assessment may be required by the regulatory agency even if no leak was found (yet).

57 Suspected Releases Off-Site Impacts
Regulatory agency may require owner to determine whether or not any off-site impact exists observed by agency or another person. One of the major concerns about contaminated sites is their potential for off-site environmental impacts. Contaminated sites can cause adverse environmental impacts on adjacent land and water through the distribution of wind-borne dusts and by leaching of contaminants into ground water and/or surface water run-off. Groundwater contamination is of particular concern in areas with shallow water tables and permeable surface layers. From a human health perspective, groundwater contamination is a serious concern when the aquifer is used as a drinking water supply. Identification of off-site impacts may be required by the regulatory agency if you have sensitive neighboring receptors.

58 Clean it up…Immediately!
Contain and cleanup all spills. Report spill or overfill of 25 gallons within 24 hours (Federal Requirement). Report any amount that causes a sheen on nearby water surface. Even if not reportable, keep a record. The slide provides a simple overview of what to do in the event of release. Keep it simple. Respond, clean up, report, close. Note that the reporting requirement for 25 gallons is a federal requirement and refers to spills in or threatening surface water. You must check your individual state which can have a lower spill reporting threshold.

59 Summary UST systems can and do leak today.
Federal facilities must comply with all UST laws. Leak detection is a critical part of fueling operations. Overfill prevention equipment and activities are vital in stopping large releases. Corrosion protection can reduce rust-related problems. Suspected releases must be promptly addressed. Trained staff should be able to intercept many problems. This slide provides a summary of the UST issues discussed in the previous slides.

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