PRODUCT PIPE LEAK DETECTION Annual GTEC Underground Storage Tank Management & Compliance Seminar – 2016 PRODUCT PIPE LEAK DETECTION (including the UST regulations) Katie Seaborn AMERICAN CONTAINMENT SERVICES, INC.® “NEW” Good Afternoon Class – My name is Katie, and I’ll be your entertainment for the next 30-minutes or so. We are going to get the technical boring stuff out of the way first, followed by a pop quiz, and then some fun photos and facts. Here we go… <CLICK>

Suction Systems 1. Common Method 2. Safe-Suction Method SUCTION PUMP 2. Safe-Suction Method Suction Systems fall into 1 of 2 categories based on their configuration, as defined by the check valve location: For a suction system to operate properly, a check valve is required. In a Common Suction System, the check valve is traditionally located either at the top or bottom of the suction stub/tube. The “Common Method” was historically the most common suction system configuration; however, it is becoming increasingly rare, b/c this system presents a higher potential for environmental impact and requires periodic tightness testing. <CLICK> The 2nd type of suction system is a Safe Suction System. The check valve in this system must be located as close as practical to suction pump. This is achieved by either installing a union check which is a check valve that is placed between the two halves of the pipe union located directly beneath the pump, or via the use of a purpose built check valve fitting. The benefits of a safe suction system include: Better Check Valve Access for maintenance and trouble-shooting. Faster Breach Notification to the system operator (b/c the line drains back into the tank, increasing pump pick-up time or preventing fuel delivery all together). Lesser regulatory requirements. Product Pipe Under Pump Check Valve UST Angle Check Valve OR Foot Check Valve

SUCTION SYSTEM Leak Detection Requirements: For COMMON SUCTION systems: If Installed on or before April 11, 2016… Product Pipe Tightness Test Every 3-Years OR Monthly Monitoring Method meeting 40 CFR 280.44(c) Interstitial Monitoring Statistical Inventory Reconciliation Groundwater or Vapor Monitoring Other Method Approved by AHJ (with limitations) If Installed after April 11, 2016… pipe must be double-wall and Interstitial Monitoring must be performed every 30-days. These are the Regulatory Requirements for Suction Systems which can be found in 40 CFR Part 280.41 & .44. Depending on when the pipe was installed, periodic line testing OR a monthly method that monitors the entire tank system can be used. <CLICK> If installed after April 11, 2016, secondary containment monitoring is required to be done and documented monthly. <CLICK>

SUCTION SYSTEM Leak Detection Requirements: For SAFE-SUCTION systems: RELEASE DETECTION IS NOT REQUIRED, regardless of installation date, IF… 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. For Safe Suction Systems, regardless of installation date, the piping is required to comply with all of the criteria listed here. Although release detection on safe suction pipes is not required, if you wanted the extra assurance of testing, safe suction pipes are unavoidably tested as part of the tank when doing non-volumetric tightness testing such as a pressure-decay test. <CLICK>

Submerged Turbine Pump Pressurized Systems Dispenser Pump Head Shear Valve For dispensing applications requiring higher flow rates than standard suction systems can provide, Pressurized Delivery Systems are needed. Unlike suction systems, Pressurized Systems operate under positive pressure instead of negative pressure, and deliver higher volumes and rates of delivery. As such, the risk of environmental impact is greater with pressurized systems then with suction systems. A typical pressurized system is fed by a submerged turbine pump, which is located within the UST, and the system’s check valve is located within the Pump. Also, a pressurized system is governed by more stringent rules, including the need for an emergency fire/shear valve located at the dispenser, and additional leak detection requirements. <CLICK> UST Submerged Turbine Pump Pump Motor

PRESSURIZED SYSTEM Leak Detection Requirements: If installed on or before April 11, 2016… Must be equipped with an automatic line leak detector which must be tested annually, AND use one of the following: Annual Line Tightness Testing Interstitial Monitoring Statistical Inventory Reconciliation Groundwater or Vapor Monitoring Other Method Approved by AHJ (with limitations) If installed after April 11, 2016… Must be equipped with an automatic line leak detector, which must be tested annually, AND Must have Monthly Interstitial Monitoring These are the Regulatory Requirements for Pressurized Systems which can be found in 40 CFR Part 280.41. Only one means of leak detection is required in addition to the use of an Automatic Line Leak Detector (tested annually). Vapor and Groundwater Monitoring are not recommended – they are not cost effective and by the time you detect a leak, it is too late. <CLICK>

More PRESSURIZED SYSTEM Leak Detection Requirements: Federal EPA Requirements for Automatic Line Leak Detectors (LLDs): 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 proper operation annually. On the topic of Automatic Line Leak Detectors, a listed leak detection device is required on pressurized underground product pipes, and must meet specific requirements as per 40 CFR Part 280.44 AND NFPA 30. The whole idea here is that when a leak is sensed by the leak detector, it will limit the amount of fuel loss and alert the operator. Compliance with these requirements is typically achieved through the installation of a mechanical or electronic leak detection device. <CLICK>

Mechanical Pressurized Line Leak Detectors (MLLDs) (Electronic Sump Sensor) Red Jacket MLLD Due to time constraints, only the more common types, manufacturers, and configurations of leak detectors are represented in this presentation. The photo on the left shows a Red Jacket STP within a containment sump. The STP is equipped with a Red Jacket Mechanical Leak Detector (in the yellow circle), and the sump is equipped with an leak detection sensor (in the purple circle). At this particular site, the leak detection sensor is integrated with the STP controller to provide shut-down in the event a leak is detected, thereby providing redundant protections. The photo on the right depicts an FE Petro STP equipped with a an FE Petro mechanical leak detector. In the event either of these leak detectors becomes tripped, they will go into a slow-flow mode, which restricts the fuel flow and thereby alerts the operator of a problem. <CLICK> FE Petro MLLD

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 As an alternate to a Mechanical Line Leak Detector, electronic line leak detectors are also available from various manufactures, in multiple configurations. These work in conjunction with a controller and/or Automatic Tank Gauge System. Some benefits associated with electronic leak detectors include: 1. Programmable line testing at 0.1, 0.2, & 3-gph leak rates (which can be used instead of annual line leak testing by a 3rd party tester). 2. Automatically generated reports and data storage capabilities which assist with record keeping. AND 3. Provides automatic shut-down instead of a slow-flow condition in the event a leak is detected, which minimizes fuel loss to the environment or 2ndary containment. Electronic Line Leak Test Report (Wireless PLLD)

Secondary Containment Dispenser Containment for Interstitial Monitoring of Piping: Tank Sump, Secondary Product Pipe, and Dispenser Pan PER 40 CFR 280.12 - Definitions Secondary containment or Secondarily contained means a release prevention and release detection system for a tank or piping. This system has an inner and outer barrier with an interstitial space that is monitored for leaks. This term includes containment sumps when used for interstitial monitoring of piping. Containment Sump means a liquid-tight container that protects the environment by containing leaks and spills of regulated substances from piping, dispensers, pumps and related components in the containment area. Containment sumps may be single walled or secondarily contained and located at the tank top, underneath the dispenser, or at other points in the piping run (such as a transition sump). <CLICK> Liquid Sensor Liquid Sensor Sump and Dispenser Pan can be single wall, or double wall with a monitor-able interstice. UST

Leak Detection for SECONDARY CONTAINMENT / INTERSTICES: NEW Leak Detection for SECONDARY CONTAINMENT / INTERSTICES: Requirements for containment sumps used for interstitial monitoring of piping: 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 RP1200), or other method determined by the implementing agency. As per 40 CFR Part 280.35, these are the regulatory requirements for the operation and maintenance of secondary containment. Petroleum Equipment Institute Publication RP1200 is a “Recommended Practices for the Testing and Verification of Spill, Overfill, Leak Detection and Secondary Containment Equipment at UST Facilities” <CLICK>

“Walkthrough Inspections” NEW MONTHLY - conduct inspections in accordance with an approved, standard code of practice (i.e. PEI’s RP900) 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 These requirements can be found in 40 CFR Part 280.36. There are a few ways to comply with this section of the rules; however, I would recommend adopting the use of an industry standard such as Petroleum Equipment Institute Recommended Practice RP 900, “Recommended Practices for the Inspection and Maintenance of UST Systems” This will help remove any guess work, and give you a sound foundation for your site’s maintenance program going forward.

“Walkthrough Inspections” NEW ANNUALLY - 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 inspect and test leak detection equipment check other, hand-held equipment for operability review and retain records from inspections (photographic documentation is a good idea) As per 40 CFR Part 280.36 Sites are to clean their tank sumps and dispenser pans, and inspect them for bulges, cracks, separations, water intrusion, fuel leaks, signs of settlement, boot failures, etc. Once a year, all ATGs are to also be inspected and tested for proper operation. Sensors should be cleaned and replaced as needed. And this should be done by a qualified technician. In addition to these requirements, tank sticks are to be inspected and replaced as necessary at least annually. As well as water finding paste and other ancillary, hand operated equipment. Taking and printing photos for your records will help provide proof of inspection should you need it, and also supply a good visual reference without having to open the containments. Photographs taken over time may also show rate of corrosion and provide other helpful information related to various maintenance activities. Also, note that the federal deadline for completion of the first walkthrough inspection is October 13, 2018. And remember that the state can be more stringent, so they can require a sooner date. <CLICK>

Leak Detection for SECONDARY CONTAINMENT / INTERSTICES: NEW Leak Detection for SECONDARY 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. The content of this slide is a direct quote from the code book. This deadline will apply to the majority of the UST systems out there, and the closer we get to it, the less availability service providers will have. So don’t wait until the last minute. <CLICK>

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. This is also a direct quote out of the regulations. Maintain your records for a minimum of 3-years. Although if you have the space, we recommend to our customers that they strive for 5 to 7-years of documentation. Note that suspected or confirmed releases can be in the form of spills or overfills in excess of 25-gallons, observed contamination in soils or water, unusual operating conditions (i.e. sudden product loss or water gain), sudden level changes in leak detection fluid levels, failing leak test results, etc. These are to be reported to the EPD within 24-hours of discovery. There are some exceptions which can be found in the referenced codes. <CLICK>

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

POP QUIZ!... (last question) What kind of system is it, and what is required? Supply Pipe = SUCTION/SIPHON Return Pipe = PRESSURE/GRAVITY Return = Annual Test AND Supply = Test Every 3-yrs OR Monthly SIR (or Interstitial Monitoring if double-wall) UST EMERGENCY POWER GENERATOR Per 40 CFR 280.10 (ii) UST systems that store fuel solely for use by emergency power generators installed on or before October 13, 2015 must meet the subpart D requirements on or before October 13, 2018. (iii) UST systems that store fuel solely for use by emergency power generators installed after October 13, 2015 must meet all applicable requirements of this part at installation. Just a side note, an Anti-siphon valve would also be a really good thing to have in this configuration. <CLICK> ATTENTION!! Leak Detection is no longer deferred for Emergency Power Generator Systems as of October 13, 2018 PUMP SOLENOID VALVES

What is wrong with these pictures?   Bad Sump – Good Sump  

What is wrong with these pictures? <CLICK> This is a system with redundant STP’s. <CLICK> The yellow circles mark where leak detectors should be installed, and the blue circle shows an electronic leak sensor that is not installed in the lowest point of the sump, as required. <CLICK> This sump contains a suction product pipe, and ATG riser, and a hard-piped vent line. <CLICK> The red circle shows an electronic leak sensor that is laying ion its side. This sensor is activated when a float with an imbedded magnet actuates a reed switch. If the sensor is not installed vertically, the float cannot travel, thereby preventing proper operation. These pumps feed an emergency power generator, which by environmental regulation is currently deferred from leak detection requirements; however, by fire code, leak detection of the pressurized piping is still required. (2003 NFPA 30, 7.6.9) <CLICK>

What is wrong with these pictures? These are all things that negatively impact the ability to perform leak detection… <CLICK> <CLICK> The boot in the red square is torn, rendering it useless for testing the secondary containment piping. Also, there is so little clearance between the end of the containment piping and the first fitting on the product pipe, that the boot cannot be properly pulled back when not in use. <CLICK> The boot in the red circle is encumbered and stressed by the product line that was installed up against it. <CLICK>

What is wrong with these pictures? These are all things that negatively impact the ability to perform leak detection… The STP in the red square is completely buried. There are areas of an STP that can release product without tripping a leak detector. With the soils covering the STP, visual inspection is limited. Additionally, the soils can accelerate corrosion and encumber service activities. The red circle shows two, double wall product pipes. They are inadequately protected from physical damage, and the fiberglass outer pipe is also inadequately protected damaging ultra violet rays, which are causing the fiberglass to delaminate. <CLICK>

What is wrong with this picture? The leak detection sensor is where is should be and in a holder to maintain proper orientation. The sump looks tight and basically dry. Test boots are un-clamped to allow liquids to enter the sump. I don’t see any tell-tale signs of leakage, and the pipes are labeled supply and return. There is a little bit of liquid near the sensor that could be removed. This is a suction system, which would have been considered a safe suction, except for the sections of flexible fuel lines that are too long. As such, they rise, almost to the top of the sump, creating a high spot in the line and trapping fuel. This is no longer a “safe suction” system.

…this is what leak detection is really all about. At the end of the day…. Photograph courtesy of Mommy with her camera According to the EPA: From October 1, 2015 to March 31, 2016, GA has reported 121 confirmed releases (the highest in Region 4). During that same time span, GA performed more on-site inspections, and also issued the highest number of “delivery prohibitions” than any other state in Region 4. Per the EPA, the average cost to cleanup a fuel release is $130,000. If only a small amount of soil needs to be removed or treated, cleanup costs may be as low as $10,000. However, costs to clean more extensive soil contamination, and remediation for leaks that affect ground water typically cost from $100,000 to over $1 million, depending on the extent of contamination. 121 releases x $130,000 = 15 million, 851 thousand dollars Cost is a measurable justification for maintaining proper leak detection. There is also an un-measurable cost associated with fuel releases - contamination to drinking water and the environment have lasting effects, and carry long term liabilities that are much harder to quantify. <CLICK> Photograph courtesy of Mike Moreland Photography …this is what leak detection is really all about.

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