Annual GTEC Underground Storage Tank Management Compliance Seminar

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Annual GTEC Underground Storage Tank Management & Compliance Seminar – 2016 PRODUCT PIPE LEAK

Annual GTEC Underground Storage Tank Management & Compliance Seminar – 2016 PRODUCT PIPE LEAK DETECTION (including the “NEW” UST regulations) Katie Seaborn AMERICAN CONTAINMENT SERVICES, INC. ®

Suction Systems 1. Common Method SUCTION PUMP 2. Safe-Suction Method e Product Pip UST

Suction Systems 1. Common Method SUCTION PUMP 2. Safe-Suction Method e Product Pip UST Under Pump Check Valve Angle Check Valve OR Foot Check Valve

SUCTION SYSTEM Leak Detection Requirements: For COMMON SUCTION systems: n If Installed on or

SUCTION SYSTEM Leak Detection Requirements: For COMMON SUCTION systems: n If Installed on or before April 11, 2016… n n Product Pipe Tightness Test Every 3 -Years OR Monthly Monitoring Method meeting 40 CFR 280. 44(c) n n n Interstitial Monitoring Statistical Inventory Reconciliation Groundwater or Vapor Monitoring Other Method Approved by AHJ (with limitations) If Installed after April 11, 2016… n pipe must be double-wall and Interstitial Monitoring must be performed every 30 -days.

SUCTION SYSTEM Leak Detection Requirements: For SAFE-SUCTION systems: RELEASE DETECTION IS NOT REQUIRED, regardless

SUCTION SYSTEM Leak Detection Requirements: For SAFE-SUCTION systems: RELEASE DETECTION IS NOT REQUIRED, regardless of installation date, IF… n n below-grade piping slopes so that the contents of the pipe will drain back into the tank if suction is lost; there is only one check valve, and it is located as close as practical to the pump; the requirements above can be readily determined or proven (by the AHJ); and the pipe operates at less than atmospheric pressure.

Pressurized Systems Pump Head UST Pump Motor Dispenser Shear Valve Submerged Turbine Pump

Pressurized Systems Pump Head UST Pump Motor Dispenser Shear Valve Submerged Turbine Pump

PRESSURIZED SYSTEM Leak Detection Requirements: Ø If installed on or before April 11, 2016…

PRESSURIZED SYSTEM Leak Detection Requirements: Ø If installed on or before April 11, 2016… Ø Ø Must be equipped with an automatic line leak detector which must be tested annually, AND use one of the following: Ø Annual Line Tightness Testing Ø Interstitial Monitoring Ø Statistical Inventory Reconciliation Ø Groundwater or Vapor Monitoring Ø Other Method Approved by AHJ (with limitations) If installed after April 11, 2016… Ø Ø Must be equipped with an automatic line leak detector, which must be tested annually, AND Must have Monthly Interstitial Monitoring

More PRESSURIZED SYSTEM Leak Detection Requirements: Federal EPA Requirements for Automatic Line Leak Detectors

More PRESSURIZED SYSTEM Leak Detection Requirements: Federal EPA Requirements for Automatic Line Leak Detectors (LLDs): n n Can detect a 3 -gallon per hour leak, at a line pressure of 10 -psi, within 1 -hour. When a leak is detected, LLDs must shut off the product flow, restrict the product flow, or trigger an audible or visual alarm. Must have a Third Party Certification. Must be tested for properation annually.

Mechanical Pressurized Line Leak Detectors (MLLDs) (Electronic Sump Sensor) Red Jacket MLLD FE Petro

Mechanical Pressurized Line Leak Detectors (MLLDs) (Electronic Sump Sensor) Red Jacket MLLD FE Petro MLLD

Electronic Pressurized Line Leak Detectors (PLLDs) Should be tested annually for proper detection of

Electronic Pressurized Line Leak Detectors (PLLDs) Should be tested annually for proper detection of a leak at 3 -Gallons-Per-Hour (GPH), 0. 2 -GPH, and 1. 0 -GPH. Incon PLLD’s V/R PLLD’s Electronic Line Leak Test Report (Wireless PLLD)

Secondary Containment Dispenser Containment for Interstitial Monitoring of Piping: Tank Sump, Secondary Product Pipe,

Secondary Containment Dispenser Containment for Interstitial Monitoring of Piping: Tank Sump, Secondary Product Pipe, and Dispenser Pan Liquid Sensor UST Liquid Sensor Sump and Dispenser Pan can be single wall, or double wall with a monitor -able interstice.

Leak Detection for SECONDARY W E N CONTAINMENT / INTERSTICES: Requirements for containment sumps

Leak Detection for SECONDARY W E N CONTAINMENT / INTERSTICES: Requirements for containment sumps used for interstitial monitoring of piping: n n If double-walled, the integrity of both walls must be monitored monthly (as part of “walkthrough inspections”). OR The containment must be tightness tested every 3 years, using pressure-decay or hydrostatic method, in accordance with the manufacturer, a nationally recognized industry standard (i. e. , PEI’s RP 1200), or other method determined by the implementing agency.

NEW “Walkthrough Inspections” MONTHLY n n n conduct inspections in accordance with an approved,

NEW “Walkthrough Inspections” MONTHLY n n n conduct inspections in accordance with an approved, standard code of practice (i. e. PEI’s RP 900) check to make sure there are no alarms or other unusual conditions present related to Automatic Tank Gauges (ATGs) used for interstitial monitoring and leak testing review and retain records from system checks and leak tests

NEW “Walkthrough Inspections” ANNUALLY n n n remove accumulated liquid and debris visually check

NEW “Walkthrough Inspections” ANNUALLY n n n remove accumulated liquid and debris visually check for leaks into containments, releases to the environment, and damage check the interstice of double-wall sumps/pans for leaks into or out of the interstice n inspect and test leak detection equipment n check other, hand-held equipment for operability n review and retain records from inspections (photographic documentation is a good idea)

Leak Detection for SECONDARY W E N CONTAINMENT / INTERSTICES: As per 40 CFR

Leak Detection for SECONDARY W E N CONTAINMENT / INTERSTICES: As per 40 CFR Part 280. 35(b)… (1) For UST systems in use on or before October 13, 2015, the initial spill prevention equipment test, containment sump test and overfill prevention equipment inspection must be conducted not later than October 13, 2018. (2) For UST systems brought into use after October 13, 2015, these requirements apply at installation.

RECORD KEEPING & REPORTING: As per 40 CFR Part 280. 35(c)… (1) All records

RECORD KEEPING & REPORTING: As per 40 CFR Part 280. 35(c)… (1) All records of testing or inspection must be maintained for three years; and (2) For spill prevention equipment and containment sumps used for interstitial monitoring of piping not tested every three years, documentation showing that the prevention equipment is double walled and the integrity of both walls is periodically monitored must be maintained for as long as the equipment is periodically monitored. 40 CFR 280. 50 and 280. 52… Describes proper response to interstitial/secondary containment alarms and suspected release reporting.

POP QUIZ! What kind of system is it, and what is required? Common Suction

POP QUIZ! What kind of system is it, and what is required? Common Suction Method Safe-Suction Method PUMP Pressurized PUMP UST No Leak Detection Required for the Product Piping Line PTT Every 3 -yrs, OR Interstitial Monitoring, OR Stat. Inv. Reconciliation UST Annual LD Test AND Annual Line PTT, OR Interstice Monitoring, OR Stat. Inv. Reconciliation

POP QUIZ!. . . (last question) What kind of system is it, and what

POP QUIZ!. . . (last question) What kind of system is it, and what is required? Supply Pipe = SUCTION/SIPHON Return Pipe = PRESSURE/GRAVITY UST EMERGENCY POWER GENERATOR PUMP SOLENOID VALVES Return = Annual Test AND Supply = Test Every 3 -yrs OR Monthly SIR (or Interstitial Monitoring if double-wall) ATTENTION!! Leak Detection is no longer deferred for Emergency Power Generator Systems as of October 13, 2018

What is wrong with these pictures?

What is wrong with these pictures?

What is wrong with these pictures?

What is wrong with these pictures?

What is wrong with these pictures?

What is wrong with these pictures?

What is wrong with these pictures?

What is wrong with these pictures?

What is wrong with this picture?

What is wrong with this picture?

At the end of the day…. Photograph courtesy of Mommy with her camera Photograph

At the end of the day…. Photograph courtesy of Mommy with her camera Photograph courtesy of Mike Moreland Photography …this is what leak detection is really all about.

? ? ? Any Questions? ? ? Katie Seaborn 770 -427 -9777 x 155

? ? ? Any Questions? ? ? Katie Seaborn 770 -427 -9777 x 155 kseaborn@acsinc. com American Containment Services, Inc. 60 Covington Avenue Marietta, GA 30060 ? ? ?