During the early 1990’s, due to the concerns of impacting the Air Quality, areas classified by the EPA as Serious, Severe,  and Extreme Non Attainment  for Ozone, Gasoline Dispensing Facilities (GDFs) with high throughput were required to install and maintain these Stage II Vapor Collection Systems.

These Vapor Collection systems  and their required presence at GDFs would have remained the same except that in 1998, automobile manufacturing companies began to install “onboard Refueling Vapor Recovery” (ORVR) systems directly into cars.

Under the Clean Air Act, once these vehicles equipped with ORVR were in “widespread use”, non attainment areas classified as Serious and above, could begin decommissioning their Stage II systems.  The empirical percentage of vehicles with  ORVR as expressed by the term “Widespread Use”  was determined to be 70% by EPA.

Based upon EPA’s modeling and statistical data profiling,   EPA determined that  by April 2012 timeline, 75% of gasoline will be  dispensed to ORVR equipped vehicles.

In the final analysis, EPA has determined that ORVR is in “widespread use” therefore allowing states to begin modifying their regulations and SIP programs  to remove the requirements of Stage II systems.

However, removing the Stage II equipment in certain states that fall under the OTR (ozone transport region) (stretching from Virginia to Maine), can be more problematic in that those states must revise their SIP (State Implementation Program) in a way that they must implement OTHER measures that are capable of maintaining emissions reductions COMPARABLE to that was achieved by the Stage II systems.

It appears that these new EPA regulations seem to indicate, that it probably would allow removal of Stage II systems if ORVR by itself  achieves equal or greater reduction compared to what Stage II had demonstrated to achieve based on the old SIP programs with Stage II systems alone.

I believe this should allow for even the most stringent states in the OTR to move forward to implement a removal program due to the fact that ORVR alone has demonstrated that it exceeds emissions reductions above that of the older Stage II systems.

To view the EPA regulations 40 CFR Part 51 for more specifics please em to indicate, that it probably would allow removal of Stage II systems if ORVR by itself achieves equal or greater reduction compared to what Stage II had demonstrated to achieve based on the old SIP programs with Stage II systems alone. I believe this should allow for even the most stringent states in the OTR to move forward to implement a removal program due to the fact that ORVR alone has demonstrated that it exceeds emissions reductions above that of the older Stage II systems. Click here to view the regulations.

- Joel Hershey, Director of Eclipse

• UST Compliance
• storage tanks
• Stage II Decommissioning
• Stage II
• UST Regulations

Clearing autodial failure alarms, unfortunately, is not as simple as just hitting a button.  Clearing an autodial failure requires a maintenance technician to visit the ATG, manually connect to the ATG, and send the proper command to the ATG to clear the alarm.  Or, if you prefer not to spend the time and money sending maintenance out, another option is to connect to the site remotely and clear the alarm within moments.  With ECS Eclipse Remote Monitoring services, clearing some alarms like the autodial failure is included with the service, which really adds up in cost savings through reduced maintenance visits.  Check us out for more ways that Eclipse remote monitoring services can reduce your headaches and save you some money!  

- Michael Sawkiewicz, Senior Compliance Manager

• UST Compliance
• ATG monitoring
• ATG
• Alarms

Some of the key items to note in the draft:

Additions to Compliance Inspection Rules

• An added requirement for monthly and semi-annual (every 6 months) inspections to be performed by, or under the direction of the Class A or B operator.
• An added requirement for the UST owner or operator to self-certify compliance, every 3 years.  The owner or operator would complete a compliance certification, to attest to whether or not they have met the requirements for things such as financial responsibility, testing, recordkeeping, completion of the monthly and semi-annual inspections, etc. 
• The MassDEP will assign due dates for the Third-Party Inspections (TPIs) between August 8, 2013 and August 8, 2016 and this will be the permanent future due date (except in the case of early submittal, which would change the due date).
• The self-certifications would alternate with the TPIs, so that one item will be submitted to the MassDEP every 18 months.

Changes to Third-Party Inspector Certification and Training

• The MassDEP will continue the TPI program currently in place. However, the eligibility requirements for inspectors would be more stringent.
• Individuals that are currently registered as TPIs with the MassDEP would be exempted from the new pre-qualification requirements.
• In order to be certified as an inspector, an individual would need to take and pass an exam and meet other pre-qualification requirements.
• To keep certification, the inspector would need to complete annual MassDEP training.

Additions to General Operating Requirements

• Integrity testing requirement for sumps (every 3 years, by vacuum or hydrostatic testing)
• Integrity testing requirement for single-walled spill buckets (annually, by vacuum or hydrostatic testing)
• Change to tank and piping tightness testing method: Until December 31, 2015, must be able to detect 0.1 gallon per hour leak rate; on and after January 1, 2016, must be able to detect 0.05 gallon per hour leak rate.
• Change to temporary out-of-service requirements: The draft regulations would allow for a temporary out-of-service period of no more than 5 years (increased from the current maximum allowed 2 year period for double-walled UST systems)

The Discussion Draft will be the topic of the next UST Stakeholder Meeting, to be held on May 1, 2012.  To read the draft in full detail or for more information about the DEP UST Vision or where to send comments, please see the link below for the MassDEP UST Stakeholder Group webpage or contact a member of the Eclipse staff at 413-789-3530 or info@ecseclipse.com

http://www.mass.gov/dep/public/committee/ust.htm

-          Megan Kazmierczak, Senior Compliance Manager

• UST Rules
• Underground Storage Tank Regulations
• Massachusetts
• MA UST Regulations
• MA DEP
• MA UST
• Draft UST Regulations

On or before August 8, 2012 all owners and operators of underground storage tank facilities need to ensure that they satisfy the Operator Training requirements established by the 2005 Energy Policy Act (the “Act”).  This is a National requirement and each state will ultimately have their own requirements with variations in reciprocity, recertification and mode of training (e.g., classroom, multi-language, on-line etc.).

Three distinct classes of operators will exist once the requirements go into effect.  The three types of operators are summarized as follows:  

• Class A Operator may be the owner/operator, an employee or a contractor with general knowledge and understanding of the UST system(s) for which s/he is designated the operator, as well as the federal and state regulatory requirements that apply to the system(s).
• Class B Operator may be the owner/operator, an employee or a contractor with in-depth knowledge and understanding of the UST system(s) for which s/he is designated the operator, and how to operate and maintain the system(s), as well as the federal and state regulatory requirements that apply to the system(s).
• Class C Operator is an on-site employee who is trained by a Class A, B or A/B Operator on UST system(s), emergency procedures, and response to alarms at the facility.

In short, employees from senior management to store clerks are required to undergo some form of training relating to UST operations. The type of training will vary depending on the individual job requirements. In general, all operators must have some understanding of UST systems as it pertains to leak detection, spill prevention, overfill prevention, corrosion protection and emergency response procedures.  For certain station owners, one person may be the designated operator for all three classes.

The Department of Environmental Protection (“MassDEP”) is charged with the regulatory responsibility of implementing the operator training requirements in Massachusetts.  The MassDEP is exclusively administering the exam for Class A and B operators.

Key areas of interest in the MassDEP regulations include:

• The owner and operator shall ensure that a Class A, B or C operator is present on-site at all times an underground storage tank facility is staffed or open for business.
• If an UST facility is closed or unstaffed, a Class A, B or C operator does not have to be present at the facility, but the Class A, B and C operators are still responsible for operation and maintenance activities or responding to emergencies and shall be certified in accordance with the regulations.
• If an individual takes and fails any operator examination three (3) times within six (6) months, s/he shall wait an additional six (6) months from the third failure to re-take any operator examination.

The operator training requirements under the Energy Policy Act of 2005 will undoubtedly impose greater challenges and responsibilities upon UST owners and operators.  Compliance with your state specific operator training requirements is a regulatory requirement that in the end could be your greatest resource for avoiding environmental liability.

- William Alpine, Director of Cost Recovery and Corporate Counsel

• Operator Training
• MA
• August 8 2012
• UST Regulations

If you have a single-walled underground storage tank in the State of New Hampshire, it is important to start planning for the implementation of the regulations set forth in 2005 requiring permanent closure by December 22, 2015.  As of that date, all such tanks containing regulated substance that do not have secondary containment and leak monitoring must be closed.  Those that do not comply with the regulations will be subject to a number of enforcement penalties, including fines, civil penalties , and delivery prohibition, much like the current “Red-Tag” program for facilities that violate spill prevention, overfill protection, release detection, leak monitoring, or corrosion protection requirements.  Not complying will also affect eligibility for state funds.  For further information about the 2015 requirements, visit the New Hampshire Department of Environmental Protection’s Underground Storage Tank Program’s website at http://des.nh.gov/organization/divisions/waste/orcb/ocs/ustp/index.htm .

Sources:

NH Code of Administrative Rules, Env-Wm 1401.18 des.nh.gov/organization/commissioner/legal/rules/documents/env-wm1400.pdf

“Environmental Fact Sheet: Delivery Prohibition of Petroleum to Regulated Underground Storage Tanks,”  NH DES 2008 des.nh.gov/organization/commissioner/pip/factsheets/rem/documents/rem-27.pdf

“New Hampshire’s Storage Tank Program.”  Power Point Presentation, NH DES, July 23, 2009.  http://des.nh.gov/organization/commissioner/p2au/pps/gsp/documents/storage_tank_program.pdf

- Melissa Murkette, Compliance Analyst

• Underground storage tanks
• SW Closure
• Single wall ust closure
• permanent tank closure
• NH UST Regulations
• UST

• UST Training
• UST Regulations
• Operator Training
• Independent Oil Marketers Association
• IOMA

What exactly is the EPA proposing?

The EPA is proposing owners and operators perform walk through inspections of their UST systems at least once every 30 days and meet one of these three options:

Option 1: Conduct operation and maintenance walkthrough inspections that, at a minimum and as appropriate to the facility, check the following equipment:

• Spill prevention equipment
• Open and visually check for any damage;
• Remove any liquid or debris;
• Check each fill cap to make sure it is securely on the fill pipe; and
• If secondarily contained with continuous interstitial monitoring, check for a leak in the interstitial area.
• Sumps and dispenser cabinets
• Open and visually check for any damage, leaks to the containment area, or releases to the environment;
• Remove any liquid (in contained areas) or debris; and
• If contained areas are secondarily contained with continuous interstitial monitoring, check for a leak in the interstitial area.*
• Monitoring/observation wells
• Check covers to make sure they are secured.
• Cathodic protection Check to make sure impressed current cathodic protection rectifiers are on and operating; and
• Ensure records of three year cathodic protection testing and 60 day cathodic protection testing and 60 day impressed current system inspections are reviewed and current.
• Release detection
• Check to make sure the release detection system is on and operating with no alarm conditions or other unusual operating conditions present;
• Check any devices such as tank gauge sticks, groundwater bailers, and hand-held vapor monitoring devices for operability and serviceability; and
• Ensure records of release detection testing are reviewed monthly and current.

Option 2—Conduct operation and maintenance walkthrough inspections according to a standard code of practice developed by a nationally recognized association or independent testing laboratory that are comparable to the specific requirements listed above.

Option 3—Conduct operation and maintenance walkthrough inspections developed by the implementing agency that are comparable to the specific requirements listed above.

The EPA is proposing owners and operators maintain walkthrough inspection records for one year. Each record must include a listing of each area checked, whether each area checked was acceptable or needed to have some action taken, and a description of actions taken to correct an issue.

Why is the EPA proposing this change?

The 1988 UST regulation focused on owners and operators installing improved UST equipment, but did not require significant equipment operation and maintenance activities. After more than 20 years of experience with UST requirements, The EPA found that improved equipment and operating and maintaining UST equipment are necessary to protect human health and the environment.  12 states have adopted monthly walk through inspection requirements for their UST facilities. Of those states, only California has been implementing the requirement long enough to provide input about the effectiveness of walk through inspections.  California indicates that, according to UST inspectors and industry people, the monthly inspections decreased the number of violations found, reduced the frequency and duration of release detection alarms, prompted better record keeping, and resulted in overall better operations at the UST facility.

As part of operating and maintaining UST systems, the EPA proposes owners and operators conduct walk through inspections at least once every 30 days.

Periodic walk through inspections will help owners and operators detect problems earlier, resulting in fewer releases to the environment and reduced environmental impacts of releases that reach the environment. Walk through inspections are designed to verify proper function or operating condition of easily accessible UST system components and ensure required records are current. These inspections typically include reviewing records and checking components to confirm function or condition. For example, owners and operators will be required to review current records and ensure equipment is operating properly; containment sumps are free of liquid and debris; and leaks are not occurring at dispensers, submersible turbine pumps, and other areas. EPA used the Petroleum Equipment Institute’s Recommended Practice 900, Recommend Practices for the Inspection and Maintenance of UST Systems, as a walk through inspection requirements.

The EPA is proposing allowing owners and operators to hire a third party to conduct walk through inspections instead of performing the inspection themselves.

At a minimum, walk through inspections conducted according to a code of practice or developed by the implementing agency need to be comparable to the following requirements. The specific requirements proposed and reasons for their inclusion in the regulation are:

• For spill prevention equipment— open each spill prevention area, check for damage, and remove any liquid or debris; check the fill cap to make sure it is securely on the fill pipe; and for secondarily contained spill prevention equipment with continuous interstitial monitoring, check for a leak in the interstitial area.
  • Damaged spill prevention equipment can release regulated substances into the environment and liquid or debris can reduce the equipment’s capacity. Fill caps not secure on the fill pipe can result in vapors exiting the tank and can render overfill prevention inoperable in tanks that use flow restrictors in the vent line.  Some spill prevention equipment construction materials may not be designed to contain regulated substances for long periods of time. For spill prevention equipment with two walls and continuous interstitial area monitoring, owners and operators need to check the monitoring device or area to make sure the interstitial monitoring is operating properly and does not indicate a leak in the interstitial area.
  • For sumps, including submersible turbine pump sumps and transition sumps—open and visually check for damage, leaks to the containment area, or releases to the environment; remove any liquid (in contained sumps) or debris; and for secondarily contained sumps with continuous interstitial monitoring, check for a leak in the interstitial area.
  • Drips and other small releases from damaged components contained by the sump can result in regulated substances remaining in the sump. Damaged sumps can release regulated substances into the environment. Liquid or debris can reduce the capacity of a contained sump. Some sump construction materials may not be designed to contain regulated substances for long periods of time. For sumps with two walls and continuous interstitial area monitoring, owners and operators need to check the monitoring device or area to make sure the interstitial monitoring is operating properly and does not indicate a leak in the interstitial area.
  • For dispenser cabinets—open each cabinet; visually check for damage, leaks to the containment area, or releases to the environment; remove any liquid (in dispensers with under dispenser containment) or debris; and for dispenser sumps with continuous interstitial monitoring, check for a leak in the interstitial area.
  • Visual checks for dispensers are important because the 1988 UST regulation does not require release detection for dispensers. Drips and other small releases from damaged components in the dispenser cabinet can result in regulated substances remaining in the dispenser sump or being released to the environment. Damaged under-dispenser containment (if present) can release regulated substances into the environment. If under-dispenser containment is present, liquid or debris can reduce the capacity of the containment sump. Some under dispenser containment construction materials may not be designed to contain regulated substances for long periods of time. For dispenser sumps with two walls and continuous interstitial area monitoring, owners and operators need to check the monitoring device or area to make sure the interstitial monitoring is operating properly and does not indicate a leak in the interstitial area.
  • For monitoring or observation wells—check the covers to make sure they are secured.   These wells need to be secured to avoid potential contamination of wells through the well cover (for example by surface runoff or accidental fuel delivery to the well).
  • For cathodic protection—check to make sure impressed current cathodic protection rectifiers are on and operating; ensure records of three year cathodic protection testing and 60 day impressed current system inspections are reviewed and up to date.
    • Impressed current cathodic protection systems need to be on and operating to protect underground metal components of the UST system that routinely contain regulated substances from corrosion. In addition, owners and operators need to retain records of the most recent two cathodic protection tests (required once every three years) and the most recent three inspections (required once every 60 days) for impressed current systems. These records show that cathodic protection systems are on and operating properly to protect UST system components from corrosion. Owners and operators who record rectifier readings and compare those readings to the normal operating parameters of the rectifier during the 30 day walkthrough inspections will meet the 60 day impressed current inspection requirement in § 280.31(c) without further activity. Failure to operate and maintain cathodic protection could mean that metal UST system components are corroding and could result in a release to the environment.
    • For release detection—check to make sure the release detection system is on and operating with no alarm conditions or other unusual operating conditions present; check any devices such as tank gauge sticks, groundwater bailers, and hand-held vapor monitoring devices for operability and serviceability; and ensure records of release detection testing are reviewed monthly and up to date.
      • Release detection equipment needs to be operable in order to detect releases when they occur. Owners and operators must respond to release detection alarms. Manual release detection equipment needs to be serviceable and operational so owners and operators can perform proper release detection. In addition, owners and operators need to ensure they review the most recent month’s release detection information and retain the most recent year’s worth of release detection records. These records are required for all methods of release detection, and reviews ensure UST systems are being checked for a release at least once every 30 days. Failure to perform these checks could mean release detection equipment is not operating properly and could result in a release to the environment.
      • Owners and operators using continuous interstitial monitoring for double-walled spill prevention devices, sumps, or dispenser containment areas need to check the interstitial monitoring to make sure it is operating properly and does not indicate a leak in the interstitial area. EPA is aware of these continuous interstitial monitoring methods: vacuum, pressure, or liquid filled interstitial area monitoring and placing sensors in the interstitial area.  For vacuum, pressure, or liquid-filled interstitial area monitoring using electronic devices and sensors, owners and operators will need to check the electronic device to make sure it is not in alarm. For interstitial areas monitored using vacuum, pressure, or liquid-filled interstitial area monitoring not using some type of electronic monitoring, owners and operators will need to make sure the vacuum, pressure, or liquid is maintaining its appropriate level.

• Owners and operators who do not check the interstitial monitoring of spill prevention devices must perform periodic spill prevention equipment testing described in § 280.35(a)(ii) of the proposed UST regulation. Owners and operators who do not check the interstitial monitoring of sumps or dispenser containment areas and who use those areas for interstitial monitoring for their piping must perform the periodic testing of secondary containment described § 280.36(a)(iii) of the proposed UST regulation.

EPA is proposing walkthrough inspections be conducted at least every 30 days. 30 days is a reasonable time frame because:

• Deliveries occur frequently—often daily or every few days;
• Dispenser filters are changed every few weeks or months;
• It is consistent with the 30 day release detection monitoring requirement; and
• Current operation and maintenance industry standards (Petroleum Equipment Institute Recommended Practice 900) recommend monthly checks as one of the periodic inspection frequencies.

EPA is proposing owners and operators retain the most recent year’s worth of records to demonstrate compliance with the walkthrough inspection requirement. Owners and operators will be required to document they performed each of the required activities at least once every 30 days.  Keeping one year’s worth of records is consistent with the current recordkeeping requirement for release detection monitoring. EPA is proposing owners and operators document each area checked, whether each area checked was acceptable or needed to have some action taken, and provide a description of any actions taken to correct an issue. This information is important to assist implementing agencies in determining proper operation and maintenance.

What issues related to this change does EPA request comment or additional data on?

• Is a 30 day inspection frequency an appropriate time frame for owners and operators to conduct walkthrough inspections? Is it reasonable for owners and operators to begin conducting walkthrough inspections immediately?  After the final UST regulation becomes effective?
• Is specialized training required for individuals completing walkthrough inspections? If yes, what should EPA establish as the extent of the training?
• Are there other codes of practice that should be included for conducting walkthrough inspections?
• Is requiring owners and operators to keep the most recent year’s worth of records sufficient?
• Are the items EPA proposes checking appropriate? Should EPA add anything? Are there checks EPA is proposing that should not be required?
• Should EPA consider not requiring owners and operators to remove water from contained sumps when both of the following conditions exist?
• Owners and operators choose to connect an anode to the metal components in the sump for corrosion protection and The sump is not used for interstitial monitoring.

The bottom line is that the new regulations will require a huge quantum leap in owner operator requirements. It means a very high level of commitment by the operators and their staff.

Quite frankly, the nature and the technical requirements of these inspections will require specialized training, equipment so as personnel do not endanger themselves (and others around them). Personally, I really can’t see these monthly inspections being performed by MOST internal owner operator personnel. Most likely these inspections will be eventually performed by UST compliance service providers.

This literally means that hundreds of thousands of inspections will be happening each and every month all across the United States.

It is kind of mind numbing when you think about it. I call it punctuated equilibrium or another way to put it, a quantum evolution in UST compliance.

How will you as an owner operator handle this requirement? I would love the opportunity to discuss with any interested parties the impact and ramifications.

Call me any time @ 1-800-789-3530 and ask for Joel Hershey or Lorenzo DiBacco.

-Joel Hershey, Director of Eclipse

• UST Regulations
• UST paperwork
• UST Compliance
• underground storage tanks
• Inspections
• Facility Compliance
• EPA

So you have this scenario; There is 100’ of DW flex piping buried from the tank pad to the dispenser islands. The piping is properly pitched at 1/8 minimum per foot. You have a sensor in the STP sump back at the tank pad. There is no sensor in the dispenser pan. You are relying on the sensor in the STP sump to notify you in the event of a leak because….. you have DW piping with interstitial monitoring. You still with me? The meter under one of your dispensers just blew a gasket and is now leaking. It’s dripping out of that meter at 2 GPH. But, under line pressure, this gasket blows out and the line is pumping at 27psi. Your mechanical leak detector in the STP sump doesn’t catch this. It only triggers at a catastrophic 3 GPH. But you’re a high pumping station, its noon time and the STP motor is constantly running due to the high demand. There is always one nozzle out of the cradle keeping that STP relay closed sending power to the STP. The mechanical leak detector didn’t even get a chance to run the 3 GPH test. How long do you think it would take to fill a typical 95 gallon dispenser pan at 27psi pumping at approximately 8.5 GPM? How about 11 minutes before it starts flowing out onto the island, over the pad, down the driveway, into the street, into a storm drain and into the local river. Liquid takes the path of least resistance. The product didn’t have enough time to make it from the dispenser pan to the STP sensor to trigger an alarm. Not in the 1.29 hours it would take for the product to start dripping into the STP sump. But, you tell me you have a fast thinking attendant monitoring your service station. He immediately hits the emergency stop button. This interrupted the power to the dispensers and will shut down the handle switch signal pulling in the STP relay. Phew! Major crisis averted, still a clean-up needs to occur - But wait, the relay is stuck closed. The power is still going to the STP – product is still flowing. HELP!

Your worst nightmare just came true. What do you do? Well for starters, before this scenario or something like it happens to you, install dispenser pan sensors under your dispensers. There is already a requirement from some states for continuous monitoring of the dispenser pan for product loss on new and substantially upgraded systems. And by continuous monitoring the intent of these regulations is to have a dispenser pan sensor located under the dispenser. Connecting the dispenser sump to a monitored tank top sump just doesn’t cut it. If you had a sensor in the dispenser pan, it would have triggered an alarm notifying you of an issue. The site attendant would then have time to investigate before the worst occurred.

You might want to also put into place a weekly visual check of the dispenser interior. This means opening the dispenser skirt and checking the components and piping. This way you may be able to identify any potential future issues, like weeping fittings or leaking meters and filters.  You can then be proactive on resolving any problems before they occur.

Third party management with remote monitoring of the automatic tank gauging systems is just one of ECS Eclipse’s specialties. We can take the headaches away. Please call for more information.

-Lorenzo DiBacco, Field Services Manager

• underground piping
• DW Piping
• Double Wall piping
• construction

Fuel prices rising by as much as 20% on an annual  basis  has encouraged and spurred on  petroleum wet stock theft from gas stations and truck stops.

This crime is now costing the United States billions of dollars per year according to industry statistics.

The rate of fuel theft is accelerating as climbing fuel prices tempt more and more people and even employees  to steal gasoline, diesel and even heating oil.

We all know that gas is getting pretty expensive. Industry experts  predict by spring,  gas prices will  probably be on average  $4.00 per gallon and as much as 5 bucks per gallon later this year.

Because of this hikes in gas prices some people are taking an extreme route to save money.

Tuesday February 21, 2012 at 1am in Hillsborough County Florida a van pulled into a local BP station and attempted to steal gasoline from the underground storage tanks into their vehicle. 

After some time the thieves left the scene leaving behind several hundred gallons of gasoline in the vehicle as well as spilling gasoline on the station parking lot.

So, could this happen to you? Or more importantly, is it already happening. At your site after hours ( even during business hours)?  Are you protected from fuel theft??

How can you protect from something like this?  Open your station 24 hours?  What about monitoring of your system?

These thefts occur more often than you would realize and ECS Eclipse has found a way to help, just like ADT we monitor your system.

Our constant fuel  monitoring systems manned by a 24x7 team of analysts  will protect your valuable wet stock inventory as well as give you peace of mind. 

The ECS Eclipse Fuel Management Systems and 24x7 team  monitors facilities throughout the United States protecting your assets.

We strive to be your peace of mind, to be your eyes and ears to your underground storage tanks, you may not be able at all times but we can! 

To see more about this   Florida Theft visit: http://www.baynews9.com/article/news/2012/february/385096/Thieves-attempt-to-steal-hundreds-of-gallons-of-gas

To find out more about ECS Eclipse’s Wet Stock  Remote Monitoring visit: http://www.ecseclipse.com/facility-remote-monitoring.html

-Victoria DiBacco, Compliance Analyst

• remote monitoring
• gasoline
• Fuel Theft
• underground storage tanks
• 24/7

This deadline applies to single-walled tanks and piping installed before May 8, 1985.  The most recent Rhode Island Underground Storage Tank Regulations, which were effective on April 21, 2011, actually extended the mandatory closure date by two years, to December 22, 2017.  (Previously, in regulations effective August 2007, the deadline was December 22, 2015.)

The 2011 regulations state:

Mandatory Deadline for Permanent Closure of Single-Walled UST Systems (Tanks and/or Piping): Except as provided in Rule 8.01, all existing tank and piping systems without secondary containment shall be permanently closed as follows:

(A) Single-walled tanks and/or piping installed prior to May 8, 1985 shall be permanently closed by December 22, 2017.

(B) Single-walled tanks and/or piping installed between May 8, 1985 and July 20, 1992 shall be permanently closed within thirty-two (32) years of the date of installation.

The exemption mentioned above (in Rule 8.01) refers to systems that store heating oil that is consumed on site for heating purposes.   As stated in the rule, single-walled tanks and piping installed after May 8, 1985, must be permanently closed within 32 years from install date.  

In order to permanently close a UST, the required steps of the regulations must be followed, which include submitting a closure application and application fees.  Generally, “permanent closure” will mean removal of the UST.   However, in certain instances, the agency may approve closure in place, rather than removal.  In order to get approval, an owner or operator would need to show that specific circumstances at the location would make the excavation involved with removal a poor choice.  For instance, if removal would compromise the integrity of a building or could negatively impact a sensitive environmental area, then the DEM may determine closure in place is the better option.

To read the full rule about the deadline for closure of single-walled systems, 8.04 of the UST regulations, follow this link:

http://www.dem.ri.gov/pubs/regs/regs/waste/ustreg11.pdf

- Megan Kazmierczak, Senior Compliance Manager

• Regulations
• Rhode Island
• single wall tanks
• Underground storage tanks
• UST removals

Are you aware that the first time since federal regulations regarding underground storage tanks (USTs) were first promulgated in 1988, the United States Environmental Protection Agency (EPA) is proposing significant changes and additions to these regulations?  The proposed rulemaking includes new requirements for USTs primarily focusing on proper operation and maintenance, training, additional release detection requirements and testing of secondary systems and spill prevention.

EPA’s intent for the new rulemaking revisions will allow for improved  detection and prevention of UST releases to the environment.

The proposed changes will be significant to the retail motor vehicle, commercial and manufacturing sectors who own and operate USTs if they become effective.

From a practical standpoint, owners and operators of tanks in the vast majority of states with approved UST programs may ultimately see changes in state regulations.

States currently operating under an approved UST program will have three years to submit a revised program approval package to conform to the new regulations. Therefore, if the proposed regulations become effective, owners and operators of USTs should monitor changes to state programs closely.

         If you would like to provide comments to EPA concerning these changes, you should submit right now.

         You can submit via www.regulations.gov and reference  Docket ID No. EPA-HQ-UST-2011-0301.

Frankly, I personally believe we’ve been long overdue (24 years!) for a change in the regulations. Given new technologies and types of  UST equipment, as well as fuels compatibilities issues and frankly a poor track record of monthly release detection to identify and allow for operators to react, investigate potential releases, the new rules will allow for “belt and suspenders” to the challenge of  preventing releases. Anyways, that’s my personally opinion. On the flip side, this will probably have an impact on your annual operating costs to your facility. One way to look at it though  is  that releases are very costly and another way to look at it is “an ounce of prevention is worth a pound of cure”.  Your facility is valuable. Why not protect it?

Here are the key elements of the new rules under proposal

A. Changes To Establish Federal Requirements For Operator Training And Secondary Containment

      1. Operator Training

     2. Secondary Containment

B. Additional Requirements For Operation And Maintenance

     1. Walkthrough Inspections

     2. Spill Prevention Equipment Tests

     3.  Overfill Prevention Equipment Tests

     4. Secondary Containment Tests

     5.  Operation And Maintenance Requirements For Release Detection Equipment

C. Addressing Deferrals

       1. Emergency Power Generator UST Systems

       2. Airport Hydrant Fuel Distribution Systems

       3. UST Systems With Field-Constructed Tanks

       4. Wastewater Treatment Tank Systems

       5. Maintain Deferral For USTs Containing Radioactive Material And Emergency Generator UST Systems At Nuclear Power Generation Facilities Regulated By The Nuclear Regulatory Commission

D. Other Changes

        1. Changes To Overfill Prevention Equipment Requirements

       2. Internal Linings That Fail The Periodic Lining Inspection And Cannot Be Repaired

       3. Notification Requirements

        4. Alternative Fuels And Compatibility

        5. Improving Repairs

       6. Phase Out Vapor Monitoring And Groundwater Monitoring As Release Detection Methods

       7. Interstitial Monitoring Results, Including Interstitial Alarms

-Joel Hershey, Director of Eclipse Services

• underground storage tanks
• tank regulations
• Regulations
• petroleum
• gas station tanks
• EPA
• UST Compliance

Currently the state owes more then $17 million dollars to businesses who have received approval to be reimbursed for cleanup costs, and more then $81.6 million worth of applications for reimbursement.  

Due to state cutbacks and troubling economic times the fund has lost much of its state funding.  "At current funding levels, most owners and operators will not receive reimbursement in their lifetime," James T. Owens III, director of the EPA's Office of Site Remediation and Restoration, wrote to state Environmental Protection officials. "Clearly, in its current condition, the use of the state fund as a means of financial responsibility does not encourage -- or in some cases enable -- releases to be addressed promptly."

January 26, 2012 the EPA sent a letter to Bureau of Water Protection and Land Reuse Chief Betsey Wingfield stating “EPA will begin the process of withdrawing approval of the CT DEEP Program state fund as a mechanism of financial responsibility should a solution not be achieved by the end of the legislative session on May 9, 2012.”

If the state can not find a solution by May 9^th and the EPA ends its recognition of the program, gas stations across the state will be forced to find private insurance, with the high costs these station owners  will be forced to raise prices or to close down completely.

 -Victoria DiBacco, Complaince Analyst

• Petroleum
• EPA
• DEEP
• CT
• Cleanup Program
• State Fund

Lorenzo DiBacco, Field Services Manager

• Inspection
• alarms
• sensors
• manways
• ATG

Perspective was lost in this situation.  The shear valve is essential for compliance and for protecting your business and the environment.  If a vehicle were to crash into a dispenser and sever the fuel line to the pump, a properly functioning shear valve would shut off the flow of fuel and prevent a major release.  This wrench will negate the purpose of the shear valve and allow product to gush out onto the site in the event of dispenser dislodgement.

Which would be a greater loss to your business:

            -A temporary shut off of one dispenser to repair the sticky shear valve,

                                    or

            -A collision with the dispenser causes a release, endangering customers and incurring thousands of dollars in clean up costs?

Bottom line: the equipment is there for a reason.  Make sure it is working.  Functioning compliance equipment is good for your business, good for your customers and good for the environment.

-Brian Yellan, Eclipse Trainer

• Shear Valve

As required, a method of monthly release detection must be in place for all new and existing UST systems.  However, in certain instances, inventory reconciliation can be temporarily used to meet the release detection requirements.

If the method of release detection becomes defective, the owner must immediately have the necessary repairs or maintenance performed.  While the repairs are performed, the owner may use inventory control or automatic tank gauging (in the case where interstitial monitoring is the method of release detection) for up to 60 days from the last passing result in order to meet the monthly release detection requirements.

Additionally, if the automatic tank gauging system (ATG) is found to be not defective but a monthly passing release detection result cannot be acquired from the ATG due to low product levels in the tank, the owner may use inventory control as an alternative method of release detection for up to 90 days after the last passing result.  Within that 90-day period, the owner is expected to schedule a fuel delivery in order bring the tank fuel level to the needed level.

To read the full rule – Release Detection Methods and Requirements for UST systems, follow this link:

http://codes.ohio.gov/oac/1301:7-9-07

-Megan Kazmierczak

Senior Compliance Manager

• release detection
• Ohio
• Inventory reconciliation
• automatic tank gauge
• ATG

The requirement for new vehicles in the USA to be equipped with On-board Refueling Vapor Recovery (ORVR) systems is leading to the elimination of Stage II Vapor Recovery requirements.   To explain briefly, Stage II systems capture gasoline vapor during vehicle fueling and return the emissions to the gasoline storage tank.  ORVR equipment also controls the release of hydrocarbon emissions during vehicle fueling by collecting the vapor into a canister in the vehicle.  Therefore, the amount of displaced gasoline vapors meant to be captured by Stage II Vapor Recovery systems is being eliminated as more vehicles equipped with ORVR replace older vehicles.  Additionally, the two systems are actually incompatible with each other since use of Stage II Vapor Recovery on a vehicle equipped with ORVR can actually cause more emissions to be released into the atmosphere. 

Therefore, states in the Northeastern US have begun using several EPA criteria to classify that ORVR is in “widespread use” throughout their state.  These states have begun to phase-out or discontinue the requirement for Stage II vapor recovery systems at gasoline dispensing facilities (GDFs).   The phase-out of Stage II vapor recovery is good news for GDF owners and operators because the Stage II systems can be complicated and require periodic testing and upkeep that is expensive.

The state of Connecticut is currently moving forward with steps to repeal their requirements (see Eclipse article dated January 3, 2012: http://www.ecseclipse.com/post-details/items/connecticut-moving-to-repeal-the-stage-ii-vapor-recovery-requirements.html). 

Other states have already amended their regulations to phase-out Stage II systems.  Here are details for some Northeastern US states that have regulations updated to allow discontinuing Stage II.

Chapter 118 of the state of Maine’s air rules was amended on April 3, 2011.  Stage II requirements have been repealed as of January 1, 2012.  GDFs with Stage II must discontinue the use of and/or remove the Stage II system by January 1, 2013, in compliance with Appendix A of Chapter 118.  Previous rule amendments allowed that new facilities constructed on or after June 30, 2008 and facilities that exceeded the throughput requirements which would have made them subject to Stage II after January 1, 2008, did not need to install Stage II systems. 

In New Hampshire, changes to Env-Wm 1404.17 were effective on November 29, 2011.  New facilities constructed after January 1, 2012 or facilities where Stage II equipment had not already been installed, are no longer required to install Stage II systems.  Stage II systems can be decommissioned starting after January 1, 2012, and must be decommissioned by December 22, 2015. 

The state of Vermont enacted a law in 2009 (10 V.S.A. 583) that authorizes the phase-out of Stage II systems.  New facilities that began operation after May 1, 2009 and facilities that did not exceed the throughput threshold (requiring Stage II installation) before the 2009 calendar year were not required to install Stage II systems.   Owners or operators can discontinue the use of their Stage II systems after January 1, 2013.   The systems must then be properly decommissioned by January 1, 2015, although the DEC encourages decommissioning to be done immediately after discontinuing the system.  Early phase-out is allowed, but only in the cases where “significant excavation” is done or if all gasoline dispensers are replaced with dispensers that support triple data encryption standard usage to comply with payment card industry standards.  Agency approval is required for early phase-out.

The state of New York has not yet repealed their Stage II requirements.  However, the DEC issued a directive stating that the agency will use discretion in enforcement and will not issue violations for failure to comply with Stage II requirements at gasoline dispensing facilities that did not have a Stage II system prior to January 1, 2011 but were subject to the requirements after that date or for facilities that decommission their existing Stage II system after January 1, 2011 by following the procedure in Appendix A of the agency’s directive.

In order to decommission a Stage II system in one of these states, you must follow the state’s required procedures and approved methods.   Generally, the agencies require advance notice or request for permission to decommission.  Testing will be required and the Stage II piping is usually disconnected from the tank.  The Stage II equipment, such as hanging hardware and pressure vacuum caps, must be replaced.  The final step usually involves notification and/or submitting test reports to the agency.

Something to remember is that once a facility’s Stage II system has been decommissioned, gasoline dispensing facilities would then be subject to the federal National Emissions Standards for Hazardous Air Pollutants (NESHAP) - 40 CFR Part 63, Subpart CCCCCC.   There would be additional equipment and sometimes testing requirements (dependent on gasoline throughput) associated with this regulation.

For more information, visit the following links:

ME: http://www.maine.gov/dep/air/rules/index.html  (Chapter 118)

NH: http://des.nh.gov/organization/commissioner/legal/rulemaking/documents/env-wm1404.17as-amd.pdf

VT: http://www.anr.state.vt.us/air/Compliance/htm/Gasoline.htm

NY: http://www.dec.ny.gov/regulations/74990.html

- Megan Kazmierczak

Senior Compliance Manager

• Stage II Vapor Recovery
• Regulations
• Decommissioning

Organization is a key factor. Keeping your records organized, in chronological order and accessible goes a long way towards avoiding any fines. Typically if an inspector views the condition of the record keeping of release detection records as indicated by the photo, he will more apt to be dissatisfied and become increasingly critical during his inspection. This could potentially lead to NOV’s and fines. This is a common compliance issue that is a fairly easy fix.

There are many ways to do this. One is to place the monthly/weekly printouts in an envelope in chronological order by calendar year and save them in an accessible area for inspections. Another method that I was extremely impressed with was a retailer had purchased a three ring binder. The binder was clearly marked “Release Detection Records” Inside the 3 ring binder were collector card sleeves like the ones used to collect baseball cards. These clear plastic 3 ring sleeves each had 12 pouches that were used to hold the monthly release detection printouts by month. Each sleeve pouch was marked with month and year. And the 3 ring binder held 5 sleeves for the last 5 years. This doesn’t have to be your method, but you get the picture. Organization of record keeping is an easy way to avoid fines.

Third party management with remote monitoring of the automatic tank gauging systems is just one of ECS/eclipse’s specialties. We can take the headaches away. Please call for more information.

-Lorenzo DiBacco

Field Services Manager

• Organization
• NOV's
• inspections
• compliance audits
• Compliance

-Brian Yellan, Eclipse Trainer

• Ethanol

Controlling these emissions has been an issue for all stakeholders involved in the reduction of ozone and the production and dispensing of gasoline since the late 1980s. VOC and HAP emissions occur from two types of sources at GDF: Stage I and Stage II processes. Stage I refers to processes at GDF when the gasoline is delivered or transferred from the tanker truck to the underground storage tank (UST).  Stage II refers to processes at a GDF when the gasoline is delivered or transferred from the UST to the vehicle fuel tank. Emissions from Stage II processes are the focus of this article.  Stage I processes are mentioned only for clarity. Emissions from GDF are a nationwide problem, and gasoline use in vehicles and trucks is increasing annually however there has been a fundamental movement to eliminate the requirements for Stage II regulations. The reason is that the automotive manufacturers have been installing an  on-board refueling vapor recovery (ORVR) canisters for over a decade, (ORVR will be used forward in this article).  Basically the ORVR system in essence reclaims the vapor emission during the vehicle fueling process, negating the need for the complex and costly Stage II equipment at GDFs.

Eventually, given enough vehicles in use in the United States equipped with ORVR, technically Stage II equipment at the GDF is no longer required. In fact, continuing to have Stage II equipment during the fueling process for vehicles that have ORVR can actually CREATE and exasperate the emissions problem. CARB (California Air Resource Bureau) predicts that, as a result of ORVR/vacuum assist system incompatibility, “up to 35% efficiency loss could occur [in assist system control efficiency] based on theoretical calculations.”

The Clean Air Act (CAA) Section 202 (a) (6) states, with respect to ORVR requirements, “The requirements of Section 7511a (b) (3) of this title (relating to Stage II gasoline vapor recovery) for areas classified under Section 7511 of this title as moderate for ozone shall not apply after promulgation of such standards…”

The general interpretation of this is to indicate that states with Stage II programs in Moderate ozone nonattainment areas, as well as Marginal and attainment areas in the Ozone Transport Region (OTR), may begin to phase out their Stage II programs. The Northeast states are beginning to feel pressure to repeal their Stage II programs, as in the state of Maine, which essentially has begun the process of Stage II phase out process quite some time ago  as well as other states.

According to CAA Section 202 (a) (6), the EPA Administrator may repeal the federal requirement mandating Stage II vapor recovery programs upon determination that vehicles equipped with ORVR systems are in “widespread use.”

On the question to the definition of “widespread use,” the EPA took a position as a guidance to all States that such a determination would be based on “the percentage of the automobile fleet equipped with ORVR.”  To most industry stakeholders, this suggested that “widespread use” would occur when ORVR achieves emissions reductions on a one-to-one basis when compared to Stage II.  For heavily populated areas  with strong economic “engines” such as the Northeast, that time is already here.

Connecticut is now one of the Northeast states moving forward to establish a phase out of Stage II requirements  however they are potentially looking to “beef up” the Stage I requirements but I question why……….As far as Stage I,  I’m surprised CT would even pursue tougher standards given already a pretty tough federal standards under

 National Emissions Standard for Hazardous Air Pollutants (NESHAP), Subpart CCCCCC

Traditionally Connecticut moves relatively slowly as it relates to reg. changes but there is a keen interest by the impacted stakeholders, namely the owner/operators in CT wishing to see this come to pass quickly.

 - Joel Hershey, Director

• Connecticut
• Stage II Vapor Recovery
• Regulations

• secondary containment
• Regulations
• operator training
• EPA

As per the Federal requirements under the Grant Guidelines that implement 42 U.S.C. and as amended by Section 1524 of the Energy Act of 2005, Effective August 8, 2012 no person shall own or operate a UST system without a designated trained and certified Class A, Class B, and Class C operator for the UST system.

MADEP approach to implementing these regulations, is to require that all Class A and B UST operator be required to take and pass  an online  examination. This approach fundamentally differs from most other state’s approach, whereby the majority of states  approach this requirement by implementing a  UST training program.

The MADEP online examination process works by a Class A or B  taking the examination and when passing,  demonstrates full knowledge of both the federal and state requirements for proper and safe operations of the UST system.

Once passing, the individual is issued a certificate attesting that they have been properly trained and possess the  knowledge and understanding of UST systems and Massachusetts UST program requirements. In the future, if the MADEP determines that your facility is out of compliance, they will probably require the Class and B operator of the facility  to retake and pass the examination as part of returning back to compliance.

As it stands to date, the online examination will be available by sometime in January of 2012. From the information we’ve  received from individuals who were selected to participate in the beta testing, this is one tough examination to pass. An individual has to receive at least an 85% grade to pass and receive the certificate. The subject matter will take into consideration the following areas of UST operations.

1.       Tanks and Piping

2.       Regulated substances stored

3.       Leak detection

4.       Spill prevention

5.       Overfill prevention

6.       Corrosion Protection

7.       Emergency response procedures

8.       Product compatibility

9.       Financial Responsibility

10.   Registrations, Licenses and Permits

11.   Reporting and Recordkeeping

12.   UST testing requirements

13.   Temporary and permanent closures

14.   Class A, B, and C qualifications and requirements

15.   Understanding of 527 CMR regulations

The results of the beta examination testing has indicated that the majority of the people failed in the examination. Not surprising given the indept nature of the subject matter.

We feel that the overwhelming majority of people  tagged to be an Class A or B operator (roughly 5,000 individuals) will  need to have some level of prior training and refreshers to be able to pass the examination.

ECS Eclipse can help  train you  (and your staff) to be prepared  to master this tough  examination.

We are experts in UST compliance with over 35 years of experience in UST operations.

We provide both online and classroom training to UST operators.

Contact us and be sure to be prepared for your states training requirements.

• Operator Training
• Massachusetts

• Spill Bucket

• UST Compliance

You’re planning to buy a gas station.  From the outside, it appears to be in good shape with no potential issues. Right? Wrong.  If it’s been operating for a period of time, chances are there will be underground contamination. Even with over 20 years of ever-tightening regulatory release detection and compliance requirements around proper tank operation, there will be spills and releases. It’s a basic fact.

From a business acquisition perspective, it is extremely important to understand just how much routine background contamination exists vs. contamination at the station due to major unreported or undisclosed releases. Both the buyer and seller have liabilities after that transaction from an environmental perspective.

Environmental Assessments – Get One

Most gas stations that are bought and sold will likely have an environmental assessment (EA) performed. The primary reason an EA gets performed is that the bank requires it prior to financing the purchase. Even then, not all EA’s are created equal. Often times the level of due diligence a bank requires may fall short in determining the true level of contamination present at the site. Regardless, this needs to be put into perspective. You may not want to spend more for an EA to identify a cleanup that costs less than the cost of the EA, but on the same note, it doesn’t make sense to spend only  $6,000.00 for a simple EA when buying a $1,000,000 or more for a  gas/convenience store. Just how much is spent on the environmental and property assessments should be dictated by numerous factors including, but not limited to,  the age of the UST system, its compliance history, the level of testing and release detection history and the type of release prevention equipment in place.

When a Release Happens

As a general rule, most releases will often be generally in two places:  around the spill bucket tank pad area and under the fueling dispensers. Confirming the presence of dispenser pans, spill buckets and the integrity of these devices are key in establishing the potential for possible high levels of contaminations.

It’s well known in the industry that spill buckets are prone to fail, sometimes within a few years of installation. This is especially true in areas prone to inclement weather, including frost heaves. For older stations, factor in that most spill buckets are likely to be as old as the UST system itself. Currently only a handful of states require this testing and even then only recently.

Tanks and piping are not the primary sources of ongoing problems that substantially continue to add levels of contamination at a station. It’s the cumulative effect of small releases that can ultimately create environmental problems.

You might not have a catastrophic tank or piping failure that has gone undetected however this is rare as most stations are performing some level of inventory control and release detection. Regardless, the whole system should be tested for “tightness”.

As important as all of this is to the buyer, this is also pertinent from a seller’s perspective. The seller needs to think about the nature of equipment and operating practices, being realistic and factoring in the value of the property from an environmental impact perspective. Often, prices for properties do not accurately reflect its true value.  As a result, the seller is either unrealistically high on the asking price or leaves money on the table having underestimated the integrity and value of the overall fueling system.

Any seller demonstrating strict adherence to compliance requirements, including proper record retention and high level of due diligence, will often get a better selling price.

In general, it’s good business practice to fully disclose adequate representation of the environmental status on the property. This includes all of the testing and adherence to compliance requirements stated above. This way, there will be minimal liability for both the buyer and the seller in the future. If not, there can often be legal issues after the property transaction if proper due diligence was not performed on either end. The state that the gas station is located in may have a cleanup fund that the site could be eligible for. Some states have up to $1.5 million in cleanup funds (per incident) available to gas station owners who can demonstrate that they are in compliance with all regulatory requirements. This can add greatly to the value of the property.

Another issue is a lack of concern around proper fueling system compliance to prevent and minimize leaks and releases to the environment.

Paying attention to fill operations, ensuring that any spill and overfill prevention devices are functioning properly and liquid tight is vital. Spill bucket testing is often the least costly testing, sometimes priced under $50, quite an affordable form of insurance.

Another important component is the dispenser. With new ethanol blends being introduced across the country, and increased pressure from government to introduce higher levels of ethanol in gasoline, there will be an increase in problems around the fueling dispenser. Let’s face it, ethanol is corrosive on soft metals in most dispensers and gaskets and o-rings haven’t been tested for long-term effects. Only since 2007 have major dispenser manufacturers received UL approval for dispensers in production to be compatible for E10 with E15 following in 2010.
Prior to this, there was no guarantee that fueling dispensers could withstand the long-term effects of ethanol on those unproven components in legacy dispensers.

If there isn’t a dispenser pan to catch leaks as well as an electronic sensor for notification of a problem via alarms , one of the best preventive measures is to  routinely take off the dispenser skirt and take a look to see if there is a problem. Once a month may not be too often.

1.    The following is a list of common mistakes seen in most gas station acquisitions and divestments. The buyer and seller do not adequately perform the right types of environmental due diligence.
2.    The expectations of contamination are unrealistic. Any gas station that has been in operation for a period of time will not still be at virgin background levels.
3.    Due diligence data is not used effectively to negotiate the sales and purchase of the property.
4.    Complete integrity testing of the fueling system is not performed. This includes the secondary containment areas of the fueling system.
5.    Not asking for complete operational permits, licenses, registrations, testing history, maintenance records prior to the sale. By law either the current or new owner must be able to show regulators all above paperwork for up to the life of the system. This can heavily affect any state fund reimbursement status going forward.
6.    Get construction “As Builds”’. Showing proper equipment and installation practices adds value to the property.
7.    Not adequately determining the value of the fueling system. A fueling system that’s seven years old is worth much more than a fueling system that’s 20-25 years old. Many states are establishing a life expectancy of tanks systems and that age can be around 30 years old.  To replace a typical three tank system from tank to the tip of the nozzle may cost anywhere from $350,000 to $500,000.. I’m often amazed at how buyers (and sellers) don’t seem to realistically appraise and value the property based around fueling system age and type of construction and release preventative equipment.
8.    Not taking release detection measures. After the purchase, pay attention to release detection measures. There are now third party service providers who have the expertise and the ability to monitor your fueling system on a 24 x7 basis to protect your investment.

• UST
• Tightness Testing
• Spill Bucket
• Selling Station
• Gas Station
• Fuel Spill
• Cleanup Fund
• Buying Station
• buying a convenience store
• Selling a convenience store

What is an ATG and what is its purpose? To simplify, an ATG is a system with probes and sensors put in place to quickly identify leaks and to prevent significant impacts to the environment.

Being the owner and/or operator of an underground storage tank system you have a vested interest on the impact a leaking tank can have on the environment. Costly cleanups, liability, notices of violation (NOV’s), impacts to the environment and impacts to your business all can play a role if product is released. If you do not understand your automatic tank gauge and its function and purpose, you risk that scenario.

If you do not already know how to properly maintain and operate your ATG, insist that your service provider, installer or consultant properly train you. Have them provide clear, concise instructions on the proper operation and maintenance of your system including what is required for weekly / monthly and annual compliance. Familiarize yourself with the requirements for documentation of the required weekly / monthly and annual reports. Keep these records readily available for any inspector upon request.

This may sound real obvious, but make sure your ATG is turned on at all times. I have been to many locations where the store was not 24 hours and would close at 10pm. The attendants / operators at closing time were shutting the power breaker off to the ATG system. When the ATG system is turned off it cannot monitor the tank system.

Don’t ignore an alarm. Ignoring an alarm defeats the purpose of having the ATG system to begin with. Plus you are federally required through the regulations to maintain leak detection. The earlier you can identify a leak the less costly it becomes. Document the alarm condition and the response actions and service performed and report the alarm condition to the appropriate authority if required. It is highly recommended that you immediately investigate and confirm all suspected leaks. Some states require this notification. When in doubt, report it. Many NOV’s have been issued by inspectors from regulatory agencies for failure to report a potential release to the environment.

Maintain the ATG system. Most states require that maintenance be performed following the manufacturers recommendations. Some states and jurisdictions require full functionality tests be performed. I personally prefer a full functionality of the ATG be performed on an annual basis as a preventative measure. Some ATG manufactures take the stance that the system self diagnosis itself and will let you know when it is not working properly. Although that statement in itself is correct, it does not take into account the human factor. I have been to many locations over the years to perform service on systems and found that although a sensor reads normal it does not go into alarm when an alarm is simulated. In some of these cases, I found that the programming was set up incorrectly and needed to be programmed properly. In the cases of Double Wall tank systems if the interstitial sensor is not programmed properly and not alarming, then you run the risk of a potential leak going undetected. During these annual inspections the maintenance personnel can also identify areas of service that may need to be performed to keep the ATG system running smoothly. Examples include replacing corroded ATG caps, sensor and wiring issues.

Put the responsibility of overseeing the ATG system with a competent person. Whether that is yourself or one of your employees, make sure that the system and its functions are understood. Verify that all your on-site employees are aware of the ATG system and at the very least, know what it does and who to notify when an alarm occurs.

• interstitial monitoring
• ATG
• Automatic tank gauge