An owner of an underground storage tank recently reported a release from his system. That is-- a shiny, new, five-month old system!
The system consisted of a three-compartment double-walled tank, with sumps under the dispensers and at the turbines, connected with flexible double-walled piping. Sensors in each of the sumps were connected to an Automatic Tank Gauge.
After two weeks of noticing an apparent inventory control problem and the automatic tank gauge sounding off partial alarms, the owner and installer determined “they had a problem.” There was a problem indeed. A fitting at the output side of the turbine pump failed causing it to leak into the sump. This should have been okay -- the product should have been contained in the sump and the sensor in the sump should have set off an alarm at the automatic tank gauge. Unfortunately, a seal between the riser and sump failed, which caused the product to leak into the ground. When the partial alarm went off (not enough product collected into the sump to set the tank gauge into full alarm), the owner and operator checked under the dispensers and not the turbine sumps.
Is there any requirement to test the sumps (secondary containment)? The answer is “no.” However, there is a requirement to test the secondary containment of double-walled piping.
With the 1998 UST upgrade requirements approaching, a large number of piping system upgrades will be installed just like the one mentioned. Here are a couple of ways to protect yourself against leakage:
1. Require that your installer perform a hydrostatic test on the sump(s) to insure they don’t leak.
2. If you have sensors on your tank system(s) and you get an alarm, be sure to check all of the sensor locations. Don’t just reset the alarm. Go out and check the system immediately. Be sure all personnel are aware of what to do if an alarm occurs from your UST system. If you don’t have any of these types of sensors, it is also a good idea to check your equipment occasionally by opening all covers of your UST system and checking for possible leaks. If necessary, call in a service provider to check the various systems for leaks.
Final Note: Needless to say, the owner was very unhappy that his new system leaked. The equipment manufacturer and the installer are looking at possible reasons for the failure of the two systems.
Ice storms and blizzards descended, but the tank seminars continued right on schedule. From November 12 through November 22, Ecology and the Washington Oil Marketers’ Association (WOMA) held seven workshops throughout the state on “Managing Your UST Resources Wisely: Compliance & Cleanups.” The topics included:
If you are an owner or operator of an underground storage tank (UST), you may be asking: "What options are available for upgrading, replacing, or closing my UST to meet the 1998 regulatory requirements?" and "How much do these options cost?"
To help you answer these questions, the table describes various options and provides estimate costs for equipment and labor. Costs are based on a single UST system. These estimates do not include additional costs such as equipment repair or site cleanup, which may be necessary. We also want you to know that the lowest cost choice may not necessarily be the best choice. You should discuss the options with contractors to find out which choice is right for your facility.
| Underground used oil tanks with capacities greater than 110 gallons must be upgraded, replaced, or closed by December 1998. |
EPA's publication, Don't Wait Until 1998, provides information on cathodic protection, corrosion protection options, and spill and overfill protection requirements. For a free copy of this booklet and information on other EPA publications about USTs, call EPA's toll-free RCRA/Superfund Hotline at 800-424-9346.
| Here's a tip for saving money during future reinspections of a lined tank. Have a manway installed in the tank at the same time it is lined. The manway will allow entry into the tank for future inspections without repeatedly excavating the top of the tank. |
The bullets below highlight some information you should know about protecting metal USTs from corrosion.
Was your underground storage tank (UST) installed before December 22, 1988? If the answer is “yes,” you must select one of the following three options before December 22, 1998:
For information on standard safety practices, you should refer to “Closure of Underground Petroleum Storage Tanks,” API recommended Practice 1604 (1996), which is available for about $22 from the American Petroleum Institute, 1220 L St. NW, Washington, D.C. 20005 or (202) 682-8000. A video and companion booklet called “Tank Closure Without Tears: An Inspector’s Safety Guide” is available for $35 from the New England Interstate Environmental Training Center, Attn: VIDEOS, 2 Fort Road, South Portland ME 04106 or call (207) 767-2539.
If you need information on the requirements for temporary tank closure, call Ecology at 1-800-826-7716 and ask for publication #F-TC-95-609.
Congratulations are in order to the following individuals. They participated in Ecology’s Technical Assistance Program and their site(s) were found in COMPLIANCE. YEAH!
When the American Society for Testing and Materials (ASTM) came out with an interim standard for new alternatives to internal inspection of USTs when upgrading with cathodic protection, the Department of Ecology adopted that standard. ASTM issued that standard as “Emergency Standard 40-94,” meaning that it would not become a regular standard until the membership of ASTM votes to adopt it. An emergency standard is in effect for two years to allow for that voting. The two years have expired for ASTM ES 40-94, and the membership has not been able to come to agreement.
The federal Environmental Protection Agency has recommended that states which have accepted the emergency standard continue to accept the alternative methods while ASTM works to gain a consensus standard. The Department of Ecology has decided to follow EPA’s recommendation and will continue to allow owners to upgrade tanks using the alternative methods of ASTM ES 40-94.
The American Society of Testing and Materials (ASTM) is offering courses in Seattle and Portland on “Environmental Site Assessment Practices for Commercial Real Estate - Transaction Screen and Phase 1 Site Assessment.”
The Seattle training will be held on April 1-2 and the Portland training on October 21-22. Some of the topics to be covered include:
The course will be taught by instructors who contributed to the development of E 1527 and E 1528 and who are now involved in developing new ASTM environmental assessment standards. The cost of the course is $595. Each participant will receive a certificate of completion and 1.4 Continuing Education Credits.
For more information, please contact Kristina Falkenstein, ASTM, (610) 932-0668 or via the world wide web at http://www.astm.org/envdates.html.
Ecology recently revised its checklist that certified UST Supervisors complete when working on UST systems. This revision should come as good news, because Ecology has combined the Tank Testing, Cathodic Protection and Retrofit/Repair Checklists into one basic form (there are still three checklists). In addition, a cover sheet attached to the checklists contains site, owner/operator, and Certified UST Supervisor information and signatures.
What’s great about this new format is that there is room to include as many as four tanks on one checklist--rather than a checklist for each tank. And if you have more than four tanks at a site, additional copies can be made.
Ecology will have the new checklists available in January 1997. For more information, call 1-800-826-7716.
Washington State requires that all people wanting to perform site assessments associated with tank closures either:
1) be a registered engineer in the State of Washington who is competent by means of examination, experience, or education or
2) take and pass the Washington State Site Assessment Examination given by the International Fire Code Institute (IFCI). There are no re-examination requirements for the Site Assessment Exam administered by the IFCI.
If you have any questions regarding these requirements, please contact Charles Hinds at (360) 407-7210.
Map of Ecology's Regional Offices
UST/LUST Information: 1-800-826-7716
