Copyright Adams/Hunter Publishing, Inc. May 2002| [Headnote] |
| Now that they're in compliance, here's how to keep them that way |
| [Photograph] |
| The EPA's 1998 deadline for UST compliance has come and gone, but that doesn't mean that the tanks no longer need to be repaired or maintained. |
The nomenclature seems right out of some science-fiction novel: sacrificial anodes, interstitial space, impressed current, statistical inventory reconciliation.
In reality, those are some of the terms that petroleum marketers have had to familiarize themselves with in recent years as the Environmental Protection Agency's deadline to get underground storage tanks in compliance by 1998 came and went.
That deadline - which was the culmination of a 10-year EPA program to inspect the country's USTs for leaks - brought an end to the out-of-sight, out-of-mind UST, but now that the tanks have been brought into compliance, what must the marketer do to keep them that way?
"I'm in the middle of doing a compliance reminder notice," said Gary Turgeon, director of business development for Lino Lakes, Minn.-based EPOCH Environmental. "There's about three or four main things that are needed to maintain tanks."
Turgeon lists these things as:
* If the UST is steel, it needs protection against rusting, and then the tank has to be tested every 60 days or three years.
* Tanks have to have spill and overfill protection, which usually consists of a containment area around the fill pipe that prevents product from spilling on the ground when the fuel-- truck driver disconnects the hose when completing the filling process.
* An alarm or automatic shutoff device that sounds when the driver overfills the tanks.
* A leak-detection system. Depending on the type of system, data on leak detection needs to be collected monthly, while others need to be collected on a daily or annual basis.
Rust never sleeps
Determining whether or not a tank is corroding is where the science-fiction terminology comes in.
One of the more popular ways to detect rust, according to Dave Rau, president and principal engineer for Ft. Collins, Colo.-based Paragon Consulting Group, is through the use of a sacrificial anode. A sacrificial anode is a piece of metal that is attached to the tank that corrodes faster than the steel of the tank. If the sacrificial anode is corroded upon inspection, that could indicate that the tank itself will soon begin to corrode. Regulations state that sacrificial anodes need to be checked every three years, but Rau said people have a hard time remembering that and recommends that they do it on an annual basis.
Impressed current is another way to check for corrosion.
"When steel corrodes it creates a little bit of a battery," Rau explained. "Combine that with a little liquid like water or moisture and a small current is created. To combat that, you can attach a device to the tank that has the opposite current and it will neutralize the current that can be created by corrosion."
While those are two ways to check for corrosion on steel tanks, when the EPA announced the compliance program in 1988, some marketers chose to line their steel tanks with a coating or bladder.
"With lined tanks you have to inspect them after 10 years and every five years thereafter, which means you have to empty the tank, crawl inside and visually inspect it," said Rau. "Some people lined their tanks, which was a great idea at the time, but now that 10 years have passed and it's time to pay the piper, they don't want to do it. The states, instead of demanding a visual inspection, are allowing tank owners to install impressed current on their tanks."
How fast or when a tank corrodes depends upon a number of factors, not the least of which is the type of soil that will surround the tank.
"That's one of the reasons you need to test those things every 60 days or three years," said Turgeon. "A lot of the dynamic in the ground has to do with the soil type. If it's well-draining, the tank will last a long time. We've pulled tanks up that have been in the ground 15 years and you can still read the writing on the sides, and others that have been in the ground only five years and it's corroded."
Another way of combating corrosion and rust is using fiberglass tanks instead of steel.
"There's no corrosion danger and they don't rust," said Turgeon. "They're a bit more fragile, but they're designed pretty well."
Leak detection
While actually looking at the tank is one way of inspecting it, there are others that can help determine whether a UST remains in compliance, or needs repairs or, in the worst-case scenario, replacement.
"One of the things that's fairly common is automatic tank gauges," said Turgeon. "They help operators keep track of inventory; that's where their money is made."
These gauges provide product-- inventory readouts that can tip off the operator if there is a problem with product being lost due to leakage. Another aid for the operator are leak-- detection programs can be set to run at specific times of the day, every day.
"As long as they get readouts or pay attention, they are in compliance, but they need to understand the report" said Turgeon. "Things can throw off the test and make it inconclusive. If somebody's pumping gas, or the transport is filling up the tank, or if something is wrong with the equipment the report can be affected. You need to work around deliveries and program the test for a different time."
| [Photograph] |
| The type of soil surrounding the tank is a major factor in determining its corrosion rate. |
A more cost-effective leak-detection device is the statistical inventory report, or SIR. Marketers have been using this way of inventory control for quite some time. What it involves is dipping a stick measured at 1/8-inch increments in the tank and measuring the depth of the product and taking that measurement and converting it to gallons of gasoline. The owner then ships those measurements to an approved SIR party that runs the numbers through a computer model that has been calibrated to the size and type of tank being tested.
While SIR is an accepted method of measuring product inventory, it is time-- intensive in that the measurements need to be taken daily with the SIR company reconciling the numbers on a monthly basis.
One of the newer, and more expensive, ways to detect tank leaks is with a secondary containment system, or tank-with-- in-a-tank. The theory is that if the main tank leaks, the product will be collected in the surrounding area, preventing it from seeping into the ground. To determine if a leak has occurred to the main tank, the interstitial space between the two needs to be tested for the presence of product.
Other areas to check for leaks are the overflow devices where the gasoline is pumped into the tanks. Rau said that many of those devices are getting older so that they need to be checked regularly.
While the tanks themselves may be in tip-top shape, that doesn't mean that there aren't potential problems lurking. Another area of potential system failure is in the lines leading to and from the tanks. According to Rau, there are two types of tests that can be run to determine the viability of the fuel lines.
"Line testing is a visual examination that tells you is product is leaking," he said. "Line-leak detection occurs when the pump is kicked on and the line is pressurized. If the line doesn't hold that pressure, an alarm can go off in the store, or the fuel isn't pumped, or it's pumped very slowly. All of these can indicate a problem."
"A lot of the problems end up in the piping," added Turgeon. "They're easier to fix, but a lot of times you're still breaking pavement, but at least you're not messing with your major investment - the tank."
With any test, there is a margin for error, but the operator must be aware of the red flags that are raised when a test falls out of the expected norm. Turgeon suggests a few steps to follow if a test comes back positive for a leak:
* Redo the test. "There is an acceptable variance," he said, "but if it is way out of whack, you have to take action more quickly."
* Call in a company to do a precision test. The company will pressurize the tank and test it or the lines for tightness. It usually takes three or four hours and is done if the operator doesn't think it's an anomaly with the equipment or with the product expanding.
* Go inside and inspect the tank. An individual inspection might reveal where gasoline or diesel fuel is leaking into the soil.
* Perform a "skunk test." This involves emptying the tank, injecting it with a gas like hydrogen and placing gas probes in the ground along the line to indicate where there might be gas leaks along the line.
Vigilance is key
In keeping USTs up to code, Rau suggested the operator treat them like a new car. In other words, regular maintenance and upkeep will keep them on the "road" longer and result in less trips to the "mechanic."
Rau also pointed out that all USTs currently fall under the purview of the individual states in which they are located. It will be state inspectors that will come to your site to check if your USTs are in compliance with EPA guidelines.
"In terms of compliance, the states are really getting better," he said. "At first, that was a pretty big sandwich to swallow and they really didn't know what they were doing, in a lot of cases. If you keep up with the compliance standards of your system, you shouldn't have any problems keeping it up to code."
| [Sidebar] |
| UST-fields program earns final EPA approval |
| [Sidebar] |
| While in-use underground storage tanks were expected to be federally compliant by 1998, the quandary of how to inspect and, if necessary, clean up sites that had been abandoned continued to dog the United States Environmental Protection Agency. |
| A pilot program developed last year by the EPA may be the answer to any lingering questions, as it was announced in March that the program, which is designed to clean up leaking and abandoned underground storage tanks, is being made permanent, according to EPA officials. |
| The EPA developed the pilot in September 2001, but a $50 million authorization included in the recently enacted Small Business Liability Relief and Brownfields Revitalization Act allows the agency to make the new "UST-fields" program permanent. |
| Under previous law, the EPA could use Brownfields funds to clean up contaminated sites as long as petroleum was not the only contaminant. However, the recently enacted act specifically provides funding for contaminated UST fields, such as those found at abandoned gasoline stations in urban areas. The EPA estimates that there are as many as 200,000 such sites around the country. The agency already has awarded UST-field pilot grants of $100,000 each to 10 cities, with 40 more grants expected to be awarded later this year. |
| In announcing the UST-fields program last year, EPA administrator Christine Whitman said, "These sites have caused problems that in many cases have very costly solutions. With this pilot money, recipients will be able to accelerate cleanup and return properties to viable use. Fostering cleanup at these sites not only restores the land but helps protect our water resources from petroleum contamination. The new pilot program is similar to our Brownfields initiatives in that it can help revitalize industrial areas and communities." |
| While Brownfields has been extremely successful, it has been unable to address abandoned petroleum tanks. These new pilots are building on the successful Brownfields program by bridging that gap. The pilot project involves abandoned or under-used industrial and commercial properties with perceived or actual contamination from petroleum that has leaked from underground storage tanks. |
| The EPA invited states, territories and federally recognized Indian Tribes, as well as eligible intertribal consortia, to compete for the pilot-program grants. Each selected pilot will receive up to $100,000 in Leaking Underground Storage Tank Trust Fund monies. |
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