Copyright Adams/Hunter Publishing, Inc. Feb 2000| [Headnote] |
| Monitoring the leak detection process is crucial, often overlooked |
Retailers spent a lot of time and money making sure the Environmental Protection Agency's 1998 Underground Storage Tank deadline was met. A lot of checks were written to purchase new tanks, leak detection equipment like automatic tank gauges, and the numerous ancillary items needed to make petroleum systems as leak-proof as possible. Unfortunately, the initial equipment purchases were only the first part of the battle.
"There are people who invest $100,000 in leak detection and storage system upgrades and think, 'How can I have a problem?"' said Marcel Moreau, president of the storage system consultancy Marcel Moreau Associates, Portland, Maine. "If the lowest bidder did the work, you got what you paid for. I've seen a number of problems that existed from Day 1. Even good installers can make small mistakes that have big consequences.
"The same holds true for equipment," Moreau added. "The first six months to a year are critical in determining if a new or upgraded system is performing as well as it should. A 'bury it and forget it' attitude is an invitation to disaster."
Moreau can recount any number of horror stories that drive the point home.
A retailer in Maine thought he had a minor release into a piping sump, when in fact hundreds of gallons had already leaked out through a faulty seal in the bottom of the sump.
A retailer in Maryland with a secondarily contained piping system experienced 47 false alarms in 28 days. just like the boy who cried wolf, he ignored the last alarm which was a catastrophic piping failure that pumped his tank dry.
. Another facility was pumping over 10 percent of its premium product sales into the ground for several months before product showed up in a basement and somebody bothered to look at the monitoring records.
Such failures can make the money initially spent on the equipment inconsequential compared to the cost of a failure.
"A million dollar clean-up incident occurred in Maine where it is likely that during a few deliveries the contents of the delivery hose were dumped into the ground in spite of overfill prevention equipment and spill containment manholes," said Moreau. "The overfill incidents occurred because the operator apparently assumed that his 10,000gallon tank held 10,000 gallons, when in fact the working capacity was 8,459 gallons. The incident was so expensive because the product contained MTBE and a public water supply was nearby. A little MTBE goes a long way. "
Problems can arise from every component of a new or upgraded UST. Small flaws can exist in spill containment and piping that slowly leak product into the ground. Sensors fail without being noticed, or leaky covers allow water entry leading to false alarms that make it difficult to spot real problems. These issues may not be the retailer's fault, but the retailer is still liable.
"We did a good job educating operators about the need to update equipment," said Paul Miller, environmental engineer for the EPAs Office of Underground Storage Tanks. "People saw the regulations and got equipped to meet them. We now have to educate them that they have to do more. However, the requirements are on the books and are being enforced."
The level of enforcement will likely depend on the extent of resources human and financial - in the individual states. Initially, the state inspectors will have to get up to speed on how to evaluate the hundreds of hundreds of hardware and software components used by petroleum retailers. Many states are echoing the EPA's focus on outreach and education.
The Texas Natural Resources Conservation Commission recently called upon leak detection vendor EBW, Inc., Muskegon, Mich., for assistance in the process.
"I was surprised six months ago when I was asked to speak to an audience of licensed installation contractors, UST owners and operators, and state regulators," said Peter Violino, EBW's vice president of marketing. "It was well past the compliance deadline, yet Texas was gearing up to deal with what happens after the equipment is in the ground "
When education fails, fines will likely be scaled according to the nature of the violation.
Alaska has one of the more successful state programs, helped no doubt by its smaller tank population of about 1000 USTs.
"We're working towards educational outreach for operations and maintenance, and we have developed our own operations and maintenance guide for owners and operators," said Ben Thomas, environmental specialist, Storage Tank Program, Alaska Department of Environmental Conservation "We are constantly looking for ways to get the word out and make sure the message is received.
"To compliment outreach efforts, however, we have initiated a third-party inspector program where a third-party inspector will visit each UST site once every three years! said Thomas. "We also have an honor system where a site can inspect itself, find problems, correct them and notify us with no formal violation being assessed.
"If we find a violation, particularly if leakage is occurring, then we proceed from there with fines appropriate to the situation. For example, if a system is operational and functional, but does not have the proper records when inspected, we will likely pass it with probation. However, it will have to mail in its testing records for the next six months to get off of probation. "
For those who fail inspection and do not make the necessary repairs, ADEC will not issue an operations tag essentially barring fuel deliveries.
On the surface, the basic operational and maintenance requirements are not daunting (specifics can be found at the EPA Web site http://www.epa.gov/swerust 1, and through state agencies). Basically, an operator is required to run regular tests to determine if system components are leaking and corrosion protection equipment is functioning. With modem equipment, this is largely an automated process with tests scheduled daily to every 10 years depending on the system design and age. Test records have to be kept for when an inspector comes calling.
The human element
What can the leak detection/fuel management developers do to increase the ease of compliance? Actually not much, since the issue involves the human element more than the system interface.
Unfortunately, current forces in the industry, like high employee turnover and trying to squeeze out every cent of margin in a competitive environment, complicate what is otherwise a simple management process.
Managers frequently quit and are harder to replace than in past years. When they are replaced, getting a new person fully up to speed just with store operations can take months and require regular oversight. Also, some periodic tests require significant short-term disruptions to operations, like making sure a tank is empty or not in use for a number of hours, that can lead to the test being put off until a better time. Before too long, months have gone by and the equipment, bought with hard-earned money, is just gathering dust on the wall.
No approach to leak detection is immune to operational problems, notes Moreau.
"ATGs may fail to run tests because they have been improperly programmed; failed tests are sometimes ignored and records documenting that the tests have been conducted are very often not kept," said Moreau. "People using a statistical inventory reconciliation service have to recognize that if they keep getting inconclusive results, they need to improve their inventory techniques or use another method of leak detection.
| [Photograph] |
| While not complicated, keeping track of leak detection requirements involves a dedicated effort. |
"With SIR it is also very important to know the meaning of the terms used to report results. Innocuous terms like 'investigate' or 'loss detected' may in fact mean that you have a possible leak that must be checked out. "Piping sumps associated with secondarily contained piping are a frequent source of alarms because of water intrusion. A typical response is to raise the leak detection sensor way above the bottom of the sump rather than pressuring the installation contractor to fix the source of the water intrusion.'
Plan, then act
| [Photograph] |
| An installer inserts a probe in a UST as part of its leak detection and fuel management services. |
The process of operating and maintaining USTs can be made easier with some forethought and planning.
With any retail operation, a clear understanding of the exact state rules and regulations, along with a set calendar for scheduling tests, can provide a solid foundation upon which to build an effective operations and maintenance program. This information needs to be centralized and documented in order to keep it secure from turnover related disruptions. The same holds true for the records gathered from the periodic tests.
With larger operations, a dedicated management training course can then be implemented that covers leak detection equally alongside the store management procedures when educating new hires. Further, moving to a centralized, remote fuel management system administered at the headquarters facility can provide owners with a better overview of the fuel management process along with minimizing turnover related issues.
Joe Gauthier, operations director for 
Wesco Inc., Muskegon, Mich., a retail petroleum operations with 52 sites, incorporates its fuel management process into a formal maintenance program covering the broad scope of operations.
"We have a routine set up on daily, monthly, and four-month schedules that allows us to control our leak detection operations," said Gauthier. "Each cycle is centered on a leak detection requirement, but we take advantage of the time to inspect a broad range of other equipment as well. The daily testing with the ATGs is automated, so all that our site managers have to do is send the daily results to our headquarters as part of their operational report. This information then goes to our SIR vendor.
"All of the scheduled maintenance is conducted by our centralized maintenance staff, so we're confident of the quality and have far fewer turnover issues to deal with. Inspectors do come around from time to time, and keeping to the system makes life a whole lot easier when that happens.'
Fuel management itself represents an issue for retailers that goes beyond basic leak detection requirements. A retailer may have bought the equipment strictly for compliance, yet in most cases the equipment can help an operator manage inventory and be more sophisticated when purchasing bulk fuel. Higher margins can be attained in an industry where competition is high and margins are low and unstable.
"In order to protect assets, regulatory compliance and routine monitoring are necessary for access to state trust funds, to fulfill requirements for pollution liability insurance, or to preserve corporate value," said Tom Nielson, vice president, business development for fuel management system developer Warren Rogers Associates, Inc., Middletown, R.I. "Fuel management, on the other hand, is driven by the goal of securing and preserving profit margins. A properly designed fuel management program will identify the sources of shrink in product handling and storage so that resources can be directed to correct the problem that caused the shrink to occur."
For smaller operations, outsourcing the leak detection responsibilities can be a cost-effective solution. Bill Marshall, vice president of remote monitoring, Tanknology, Austin, Texas, a company that provides such services, notes some advantages.
"At some point, an owner needs to dedicate resources to the process," said Marshall. "Owners have to ask themselves, do they have the time and skills to keep up with the process, or is it easier and more efficient to have someone else do it for them. If you have two different managers at a site in eight months, the training and time, not to mention the quality of the work, can be significant issues. If sites are located in different states, then there are even more complications."
Regardless of how much effort a retailer spent getting into basic compliance, the continuing operational requirements are here to stay. Although the process can be initially painful to get under control, given the liability from a major leak, a wise resolution for 2000 would be to get into operational compliance without delay.
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